The Risk Management Tool Box Blog

Well done to Santos

Graham Marshall - Friday, March 14, 2014

The Greenies reaction to the news of aquifer contamination - which actually occurred several years ago - at a location recently purchased by Santos in NSW shows how these people try to create a climate of fear around low-risk and low-impact events.

In response to the leak, NSW Labor put out a press release stating that: “The O’Farrell Government’s Memorandum of Understanding with Santos to fast track the approval process for Coal Seam Gas mining in the Pilliga forest should be torn up in light of revelations of contamination of the water aquifer.”

And the Greens exclaimed that this event meant it was "game over for coal seam gas”.

Which is, of course, their ultimate aim to achieve.

Many environmental groups have also leapt on the bandwagon to justify their opposition to Coal Seam Gas (CSG).

But what actually happened - and more importantly - what is the risk?

Several years ago a retaining dam was constructed in the Pilliga Forest, near Narrabri, to hold produced water extracted from wells drilled in the search for CSG.

The dam was not lined properly and it leaked.

The leaking water then entered an aquifer.

According to the NSW EPA, the contaminated aquifer - being inside the Pilliga forest - was not used for livestock, crop irrigation or human consumption.

But the leaking water contained NORM - Naturally-occurring Radioactive Materials - and other naturally-occurring minerals found in bedrock through which the drill-string passed (e.g., lead, arsenic and barium).

Fast forward to a couple of years ago - when Santos purchased the legacy asset from the original owners.

In looking over the asset as part of its due-diligence process (a good way to identify environmental issues so they can be managed properly), Santos themselves discovered the problem with the dam.

You'll recall that the dam was constructed by the prior owner of the operation before Santos acquired it.

Being a good corporate citizen, however, Santos then reported the leaking dam to the EPA.

For whatever legal reason, the NSW EPA fined Santos $1,500 because the dam leak (which occurred prior to Santos' ownership) had contaminated the aquifer.

Maybe fair enough I guess.

But the Greenies jumped on the story and the minor fine to beef-up the talk and transform the issue of NORM into "Uranium" poisoning in drinking water and lead, arsenic, and barium toxicity.

The Greenies know that "Uranium" holds a special place of fear in the human psyche due to its association atomic bombs.

So they'll stoop to any level of fear-mongering in their desperate attempt to convince the Australian population that Santos and the search for CSG is evil.

The reality, in this case, is that a small and relatively low consequence spill, with absolutely low-risk consequence to animal or public health should not be allowed to stand in the way of a billion-dollar industry that creates tens of thousands of jobs for Australians.

And Santos should be congratulated for its environmental practices; firstly discovering the leak, secondly reporting it to the EPA, and finally, in remediating it!

Well done Santos!

Hydrocarbon Releases in the North Sea for 2012

Graham Marshall - Tuesday, June 18, 2013

Hydrocarbon releases in the UK sector of the North Sea reached a record low last year according to new figures from the Health and Safety Executive (UK HSE).

There were 97 incidents reported to the UK HSE in 2012.

This is down from 133 reported incidents in 2011 and continuing a long-term downward trend.

The figures reveal a 48 per cent reduction in the number of hydrocarbon releases over the last three years – just short of the target the industry set itself in 2010 to halve releases.

The target was set following pressure from the UK HSE to improve performance.

In 2009 there were 187 hydrocarbon releases, of which 86 were classified as significant or major (84 significant and two major).

Tom Thumb Lagoon

Graham Marshall - Saturday, January 12, 2013

Several years ago I was involved in a project to develop the Community Ambassadors Program (CAP) for BlueScope Steel in Wollongong.  I fondly remember how passionate the BlueScope folks were about their local environment.

So I was saddened to hear that rail freight company Pacific National have spilled about 500 litres of oily water into Tom Thumb Lagoon near the Steelworks in Wollongong.

Wollongong City Council notified the coal haulage company of the fuel spill last December.

The source of the spill was a decommissioned oil separator sump. The sump contained about 7,000 litres of contaminated waste, which has since been removed.

Tests found the sump was linked to the company's waste pit and to a storm water drain that drained into Tom Thumb Lagoon.

An EPA investigation found that about 500 litres of oily water had spilled into a remnant wetland that provides habitat for a range of birds and animals, including migratory birds protected under international agreements and threatened species.

Species that live at Tom Thumb lagoon include the green and golden bell frog.

A company spokeswoman said it had "reacted quickly" to contain the spill, removing oil from the water and putting in place measures to stop it from spreading into nearby waterways.

In compensation for the spill, Pacific National will now give $100,000 each to Conservation Volunteers Australia and Wollongong City Council for environmental works and education initiatives at Tom Thumb Lagoon under an "enforceable undertaking" with the NSW EPA.

The $100,000 is expected to help fund works including weed removal and planting native bush.

The council will also use it to help fund a building and to provide office space for a park supervisor.

Risk Assessment Methods for Flammable Liquids Storage Depots

Graham Marshall - Thursday, September 27, 2012

Enclosed here is a benchmark study into the outcomes of two risk assessment methods which are used by regulators in Holland and France to make risk-management decisions for land use planning in and around storage depots containing flammable liquids.

 The study will be of particular interest to any person with control over tank farms and such like.

The area where vulnerable objects are undesirable and where future vulnerable objects should be avoided is largely the same in the two risk assessments. The area where severe consequences from a potential accident have to be considered is comparable as well.

 

Emergency Response Guidebook 2012

Graham Marshall - Monday, August 27, 2012

The 2012 Emergency Response Guidebook has been recently released for use by fire fighters, police, and other emergency services personnel who may be the first to arrive at the scene of a transportation incident involving dangerous goods.

Developed jointly by Transport Canada, the U.S. Department of Transportation, the Secretariat of Transport and Communications of Mexico and with the collaboration of the Centro de Informaciòn Quìmica para Emergencias of Argentina, the guide assists first responders in quickly identifying the specific or generic hazards of the material(s) involved in the incident, and protecting themselves and the general public during the initial response phase of the incident.

This guidebook will assist responders in making initial decisions upon arriving at the scene of a dangerous goods incident.

The Guidebook is not a substitute for emergency response training, knowledge or sound judgment and it does not address all possible circumstances that may be associated with a dangerous goods incident.

It is primarily designed for use at a dangerous goods incident occurring on a highway or railroad.

It may also have some limited value in its application at fixed facility locations.

A copy of the 2012 Emergency Response Guidebook is available here (free).

 

Flammable Vapour Cloud Risks

Graham Marshall - Monday, August 13, 2012

In December 2005, a flammable vapour cloud was released at the Buncefield fuel depot in the UK, ignited and caused several explosions after a large petrol-storage tank was overfilled. 

Numerous investigations were conducted into the causes of the incident, with the latest UK HSE report looking into how different tank designs are likely to behave if they overflow causing a vapour cloud. 

The work provides a first step towards developing a mathematical model which will predict the likely size of flammable vapour clouds based on simple measures such as the tank dimensions, tank design type, pumping rates and liquid composition.

Three main types of storage tank are identified in the report which are each likely to produce different flow behaviour in the event of overfilling:

+    Fixed roof tanks with vents;

+    Fixed roof tanks with pressure/vacuum valves; and

+    Floating deck tanks with no fixed roof.

The likely release scenarios from overfilling each of the tank designs are discussed.

The UK HSE report into flammable vapour cloud risks can be found here.

 

Use of Sorbent Materials during Oil Spills

Graham Marshall - Wednesday, August 08, 2012

Sorbent materials provide a useful resource to oil spill managers to assist in recovering oil when other techniques are unsuitable.

But sorbents should be used sparingly because their use can create excessive amounts of waste.

This Technical Information paper provides an overview of the use of sorbent materials in oil spill response.

Poor Safety Culture & Not Following Procedures Contributes to Pipeline Spill

Graham Marshall - Wednesday, July 18, 2012

A visitor to the Risk Tool Box safety blog has emailed to me the information reported below.  It makes interesting reading for any safety professional and shows how an inadequate safety culture and a lack of procedures being followed can contribute to disasters. 

 

Pervasive organizational failures by a pipeline operator along with weak federal regulations led to a pipeline rupture and subsequent oil spill in 2010, the National Transportation Safety Board said today.

On Sunday, July 25, 2010, at about 5:58 p.m., a 30 inch-diameter pipeline (Line 6B) owned and operated by Enbridge Incorporated ruptured and spilled crude oil into an ecologically sensitive area near the Kalamazoo River in Marshall, Mich., for 17 hours.

A local utility worker discovered the oil and contacted Enbridge to report the rupture.

The NTSB found that the material failure of the pipeline was the result of multiple small corrosion-fatigue cracks that over time grew in size and linked together, creating a gaping breach in the pipe measuring over 80 inches long.

"This investigation identified a complete breakdown of safety at Enbridge. Their employees performed like Keystone Kops and failed to recognize their pipeline had ruptured and continued to pump crude into the environment," said NTSB Chairman Deborah A.P. Hersman.

“Despite multiple alarms and a loss of pressure in the pipeline, for more than 17 hours and through three shifts they failed to follow their own shutdown procedures.”

Clean up costs are estimated by Enbridge and the EPA at $800 million and counting, making the Marshall rupture the single most expensive on-shore spill in US history.

Over 840,000 gallons of crude oil – enough to fill 120 tanker trucks – spilled into hundreds of acres of Michigan wetlands, fouling a creek and a river.

A Michigan Department of Community Health study concluded that over 300 individuals suffered adverse health effects related to benzene exposure, a toxic component of crude oil.
 
Line 6B had been scheduled for a routine shutdown at the time of the rupture to accommodate changing delivery schedules.

Following the shutdown, operators in the Enbridge control room in Edmonton, Alberta, received multiple alarms indicating a problem with low pressure in the pipeline, which were dismissed as being caused by factors other than a rupture.

"Inadequate training of control center personnel" was cited as contributing to the accident.

The investigation found that Enbridge failed to accurately assess the structural integrity of the pipeline, including correctly analyzing cracks that required repair.

The NTSB characterized Enbridge's control room operations, leak detection, and environmental response as deficient, and described the event as an "organizational accident."

Following the first alarm, Enbridge controllers restarted Line 6B twice, pumping an additional 683,000 gallons of crude oil, or 81 percent of the total amount spilled, through the ruptured pipeline.

The NTSB determined that if Enbridge's own procedures had been followed during the initial phases of the accident, the magnitude of the spill would have been significantly reduced.

Further, the NTSB attributed systemic flaws in operational decision-making to a "culture of deviance," which concluded that personnel had a developed an operating culture in which not adhering to approved procedures and protocols was normalized.

The NTSB also cited the Pipeline and Hazardous Materials Safety Administration's weak regulations regarding pipeline assessment and repair criteria as well as a cursory review of Enbridge's oil spill response plan as contributing to the magnitude of the accident.

The investigation revealed that the cracks in Line 6B that ultimately ruptured were detected by Enbridge in 2005 but were not repaired.

A further examination of records revealed that Enbridge's crack assessment process was inadequate, increasing the risk of a rupture.

"This accident is a wake-up call to the industry, the regulator, and the public.

Enbridge knew for years that this section of the pipeline was vulnerable yet they didn't act on that information," said Chairman Hersman.

"Likewise, for the regulator to delegate too much authority to the regulated to assess their own system risks and correct them is tantamount to the fox guarding the hen house.

Regulators need regulations and practices with teeth, and the resources to enable them to take corrective action before a spill. Not just after."

As a result of the investigation, the NTSB reiterated one recommendation to PHMSA and issued 17 new safety recommendations to the Department of the Transportation, PHMSA, Enbridge Incorporated, the American Petroleum Institute, the International Association of Fire Chiefs, and the National Emergency Number Association.

 

 

Oil Spill Shore-line Clean Up

Graham Marshall - Tuesday, July 17, 2012

The majority of marine oil spills occur close to the coast and the techniques used for shoreline clean-up are relatively straightforward. 

Clean up operations on shorelines can be considered under three stages.  These are:

1. Emergency phase involving the collection of floating oil close to shore;

2. Project phase involving the removal of stranded oil and oiled shoreline materials; and

3. Polishing phase involving the final clean up of light contamination and removal of oil stains.

Enclosed here is an excellent technical information paper from the International Tanker Owners Federation dealing with techniques for clean-up of oil from shorelines across the three-phases of action.

Sub-sea First Response Toolkit (SFRT)

Graham Marshall - Saturday, July 07, 2012

Twelve of the World's largest oil and gas companies have committed $25.2 million towards an Australian industry program to deal with the potential for uncontrolled oil and gas leaks.

Woodside Petroleum is joined by Royal Dutch Shell, Apache, Chevron, BHP Billiton, ConocoPhillips, Eni, INPEX, Santos, ExxonMobil, PTTP, and BP.  Each partner has committed $2.1 million to the new program.

The Australian Petroleum Production and Exploration Association (APPEA) will co-ordinate the program and the 12 companies will commit the funds over five years to ensure access to a sub-sea first response toolkit (SFRT).

The SFRT is designed to address the risk of any uncontrolled discharge from offshore sub-sea oil and gas wells.

The specialized equipment will be located in Australia and contracted through the industry-funded Australian Marine Oil Spill Center (AMOSC) for immediate mobilization if there is an sub-sea blow-out.

The SFRT contains all equipment needed to clean the area around the wellhead, enable intervention and prepare for relief well drilling and safe installation of a capping device.

All Australian offshore operators will be able to access the SFRT on an affordable basis.

Speaking at the launch of the program, APPEA chief executive David Byers said "The continued development of offshore oil and gas is essential for Australia's prosperity and energy security, but the industry must ensure we have access to the latest systems, technology and expertise to achieve the highest standards for our environment and safety performance."

Mr Byers said the Montara and Macondo offshore oil spill disasters, and subsequent inquiry recommendations, had highlighted the need for the international offshore petroleum exploration and production industry to create a capability for fast and effective response to uncontrolled hydrocarbons releases.

 


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