GCREAG - 13-Mar

Report
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2013 Environmental Performance Results
2014 Environmental Performance Goals
Environmental Proactiveness
Hazard Communication Program Update
Regional Topics of Interest
Questions/Wrap-Up
2013 Goals
Reportable Spills to Sea = < 25
Total Gallons = < 5,000
2013 Actual
Reportable Spills to Sea = 26
Total Gallons = 2,331
FYI!
In 2012 Diamond Offshore
experienced 29 Spills (15,144 Gals)
ZERO REGULATORY SHUTDOWNS DUE TO ENVIRONMENTAL INCIDENTS
Ambassador
America
Concord
Confidence
Courage
Endeavor
King
Lexington
Monarch
Nugget
Quest
Saratoga
Scepter
Spur
Star
Summit
Valiant
Valor
Victory
Winner
Yatzy
Yorktown
= 2 Years w/out a Reportable Spill
2014 Goals
Reportable Spills to Sea = < 25
Total Gallons = < 5,000
ZERO Fines
and
ZERO REGULATORY SHUTDOWNS DUE TO ENVIRONMENTAL INCIDENTS
We CAN do this!!
Extending Beyond Compliance
The Diamond Offshore fleet is amongst the industry’s top performers in
regards to environmental performance and compliance.
The following rigs have volunteered their methods of what has assisted
them in achieving a high level of environmental performance.
Ocean Princess
• Designated Hazardous Storage Areas (HSAs) established soley for flammables.
• Each deck crew has a dedicated “Environmental Leader” who is responsible for
looking after the hazardous waste storage area.
• These Environmental Leaders will be attending a UK DECC recognized course.
Ocean Princess
• Pipe Band Legends posted in the following areas:
• Bulk Loading Stations (Port/Stbd)
• Outside Locker Room
• Sack and Pump Room
• Heavy Tool Store Room
• This helps everyone know which product belongs in which line and also
assists with walking and checking for proper bulk transfer line ups.
Ocean Princess
Posting of specific Drain Plans:
• Each location has a specific Drain
Plan associated with that area and
are checked daily by the Environmental
Leaders.
• This plan also facilitates the job
planning stage to identify potential
environmental hazards
Ocean Princess
• Posting of color coded waste streams and locations of spill kits
• Assists with proper and efficient waste management onboard
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8 Yrs without a Medium or High Env. Near Miss
Discharged only 23.5 L (6.2 Gal) to sea in last 4 Yrs
Zero N/C’s during the last two CONAMA Audits
2013- Installation of Graywater Treatment System
2013- Installation of Dust Collector System
Ocean Yatzy
• Environmental Lockbox Station and Sign Out Log
(Kept in the OIM’s Office per Compliance with GEMS)
Ocean Yatzy
• Overboard Discharge Valves Painted Yellow and Locked Out
Ocean Yatzy
• Take-On Station Valves Painted Yellow and Locked Out
• Valve Wheel Covers Installed
• 3rd Party Equipment Fuel Refill Valve Locked Out
Ocean Yatzy
• Graywater is filtered and disinfected by a
VICEL treatment prior to entering the sea.
• System is currently 100% operational!
Thank You!
Ocean Yatzy
Aker Dust Cyclone and Collector Unit installed and is
currently 100% Operational!
• Designed to remove dust from ventilation lines during
bulk transfers
• Collected dust is then placed back into storage tanks for
future use.
• System has a 2 Cubic Meter Capacity
Ocean Worker
“After having problems with third party personnel
using the absorbent pads from our spill kits, we
thought about something that would avoid this from
happening. We thought about some way to seal
them, but we all know, we cannot block a kit from
being used in case of an emergency. So, we put
breakable tape around the lids and if the tape breaks,
we will know which one has been violated. The tape
also really repels the curious. This helped us to always
keep our spill kits full and ready to be used in case of
a spill.”
• US OSHA’s Hazard Communication Program was originally implemented in 1988
• OSHA is transitioning from its “performance based system” to a more “structured system”
• OSHA system was not consistent
• MSDS and label styles were not consistent and varied from MFG-to-MFG
• OSHA has aligned with the UN GHS in 2012
• 29CFR1910.1200 will be updated to reflect this movement
• Benefit would include a more organized, uniform, and structured system internationally
which will then aid in compliance globally.
Dec 1st 2013:
All employers must train their employees regarding the new labeling and SDS
formats.  DIAMOND OFFSHORE HAS ALREADY IMPLEMENTED THIS TRAINING.
Dec 1st 2013 - Jun 1st 2015:
Participation with new labeling and SDS requirements are voluntary but some
manufacturers may start to implement this new system.
Jun 1st 2015:
All products must be shipped with new labels and SDS formats
Employers (Diamond Offshore):
Responsible for training all relevant employees on the Global Harmonized System/
Hazard Communication Program by the date required (Dec 2013). Diamond
Offshore employees are to install any labels that have fallen off or are illegible.
Labels can be obtained from the manufacturer or from LHR (generic labels)
Product Manufacturers:
Manufacturers are required to ship all products with the new GHS Labels along with the
new 16-section format SDS.
Material Safety Data Sheets (MSDS)  Safety Data Sheets (SDS)
The UN/OSHA is calling for a standard format consistent throughout all industries. The well
known 8 sectioned Material Safety Data Sheet (MSDS) will soon be replaced by a 16
sectioned Safety Data Sheet (SDS). All MSDS documents onboard must be replaced by June
01, 2015.
Hazardous Chemical Labeling
OSHA has adopted a new hazardous chemical labeling program for classifying certain
substances. Labels include one of only two “signal words" such as “Warning” or “Danger”
to indicate the severity. Labels also must include hazard and precautionary statements and
a pictogram.
(SAMPLE LABEL)
2013-BRAZIL
The Brasdril Environmental Team aided the South American
Fleet with ‘pre-audits’……
• Underwent strict CONAMA 306 audits which are
required for all Petrobras rigs
2013-BRAZIL
CONAMA 306 RESULTS
• CONAMA is the National Environmental Council in Brazil.
• Every two years the Petrobras rigs must endure a CONAMA 306 Inspection
• With support from the rigs, the Brasdril Environmental Team prepares the subject rig for a
three day audit onboard. This audit focuses on all the environmental requirements
needed to be met by the rig.
• During 2013, six rigs and the Macae Shorebase successfully completed the inspection with
an incredible result of only one non-conformance.
• These kind of results display to our client’s that the Company is fully committed towards
preserving the environment and upholding all legal requirements that are present.
2013-BRAZIL
CONAMA 306 RESULTS
• Brasdril facilities that were audited by CONAMA:
• Ocean Alliance
• (1) Non-Conformance for drains leading to the sea from the main deck with no
connection to a treatment system. Effluent discharge standards must meet MARPOL
Annex I, Regulation 39 of 15ppm.
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Ocean Concord
Ocean Clipper
Ocean Worker
Ocean Yatzy
Macae Shorebase
2013-BRAZIL
IBAMA INSPECTIONS
• IBAMA is the Brazilian Environmental Institute
• An inspection performed by IBAMA is required in order to allow rigs to obtain
drilling licenses.
• Every time a rig mobilizes from one location to another an IBAMA inspection
must take place.
• The inspection aims at ensuring that the rig poses no threat to the environment.
• During 2013 all inspections that took place had zero non-conformities.
• Conditional requirements still exist as part of the licensing process and that
requirement is for rigs to have a Pollution Control Project (PCP) developed.
2013-UNITED KINGDOM
REGULATORY OVERVIEW
WHAT ARE OUR LEGAL OBLIGATIONS AS A MODU OPERATOR??
2013-UNITED KINGDOM
LEGAL OBLIGATIONS AS A MODU OPERATOR
WHO IS THE DECC??
Department of Environment and Climate Control
UK’s Environmental equivalent of HSE, IBAMA, NOPSEMA, PROFEPA, EPA!
The DECC has the authority to inspect our facilities and implement their
tiered approach towards the following enforcement actions:
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Written Communication
Enforcement Notice
Prohibition Notice
Revoke Permits; and
Prosecution
2013-UNITED KINGDOM
LEGAL OBLIGATIONS AS A MODU OPERATOR
WHILE OPERATING A MODU IN THE UNITED KINGDOM, TWO RULE SETS APPLY
WHICH CONSISTS OF THE FOLLOWING:
• Emergency Response Legislation
• Offshore Environmental Legislation
2013-UNITED KINGDOM
LEGAL OBLIGATIONS AS A MODU OPERATOR
Emergency Response Legislation
Merchant Shipping (1998)
Oil Pollution Preparedness, Response Co-operation Convention Regulations
The Offshore Installations (2002)
Emergency Pollution Control Regulations
2013-UNITED KINGDOM
EMERGENCY RESPONSE REGULATIONS
The Merchant Shipping Regulations stipulate that every offshore installation MUST
have an approved Oil Pollution Emergency Plan (OPEP). OPEP is specific for each
well location. SOPEP is inherit to the vessel at any location.
Purpose: To establish how we will respond to an oil spill that may cause marine
pollution, with a view to preventing pollution, or reducing its effect. The
regulations also stipulate the minimum training requirements for anyone involved
in oil spill response
2013-UNITED KINGDOM
EMERGENCY RESPONSE REGULATIONS
The Offshore Installation Regulations give the government powers to intervene in
the event of an incident where there is a risk of significant pollution, or an operator
has failed to implement effective control. Our responsibilities include suitable
notification of such an incident to the relevant bodies (e.g. DECC, HM Coastguard)
2013-UNITED KINGDOM
OFFSHORE ENVIRONMENTAL LEGISLATION
• The Offshore Chemical Regulations (2002)
• The Offshore Petroleum Activities Regulations (2005)
Oil Pollution Prevention and Control
2013-UNITED KINGDOM
THE OFFSHORE CHEMICAL REGULATIONS (2002)
The “OCR” stipulate that to use ANY OPERATIONAL CHEMICAL, it must be listed on a permit,
which has to be approved by the Department of Energy and Climate Control (DECC).
“Operational” Chemicals
“Non-Operational” Chemicals
(Needs to be on Permitted)
(Permit Exempt Items)
Pipe Dope
Products used solely in Accommodations
Hydraulic Fluids used for BOP
Potable Water Additives
Drilling Fluids
Paints & Coatings
Cementing Chemicals
Fire Fighting Foams (AFFF)
2013-UNITED KINGDOM
THE OFFSHORE CHEMICAL REGULATIONS (2002) (OCR)
How can I do my part in assisting with regulatory compliance??
OIM
• Be aware of the permit requirements and limitations.
• Ensure that relevant staff are aware of the permit and chemicals.
Deck Crew
• Know the chemicals on the permit, as well as their uses and discharge limits.
• Do not exceed these discharge limits.
Storekeeper
• Be aware of permit allowances and if any of the chemicals purchased are permitted.
2013-UNITED KINGDOM
THE OFFSHORE PETROLEUM ACTIVITIES REGULATIONS (2005)
The Offshore Petroleum Activities Regulations (2005)
The Oil Pollution and Prevention Control (OPPC) regulations require that any
planned discharge must be permitted.
Applications must go through DECC, and are made by the operator/well owner.
Diamond Offshore, though, have a responsibility to ensure that the permits are in
place. Unplanned discharges are to be reported of any substance to DECC.
2013-UNITED KINGDOM
LEGAL OBLIGATIONS AS A MODU OPERATOR
How can I please the DECC upon inspections??
Proper
Hose Management
Proper
Chemical Storage
Identification of
Transfer Lines
ODVs
Identified/Locked
2013-UNITED KINGDOM
LEGAL OBLIGATIONS AS A MODU OPERATOR
How can I please the DECC upon inspections??
Drains Color Coded?
Drain Plan Onboard?
Spill Kits in Good
Condition?
Whats is in them??
Bulk Transfers:
JSA Established?
Sharp Card??

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