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Oil & Gas UK Supplementary Guidance On The RIDDOR Reporting Of Hydrocarbon Releases Technical Presentation Hydrocarbon Release Reporting Agenda • • • • • • • • Objectives of the Workgroup Structure of Guidance Regulatory Requirements Reporting Methodology Technical Assessment Reportable Limits Additional Rules Reporting of Non Petroleum Hydrocarbons Objectives of Workgroup • Produce supplementary guidance that is – Fully aligned with RIDDOR 2013 requirements – Well-understood by the industry – Consistently applied by the industry • Primarily focussed on petroleum hydrocarbon releases • Also includes assessment on non-petroleum hydrocarbon releases Petroleum Hydrocarbon Releases Reportable Limit Major Significant Previous Guidance 2014 Guidance Minor Reportable Limit Not Reportable Number of releases Structure of Guidance • Regulatory Requirements – Review of DO relating to Hydrocarbon Releases (HCR) • Methodology for Assessing RIDDOR Reporting of Petroleum Hydrocarbon Releases – Define key words and phrases – Reporting flow chart • Technical Assessment – Defines Reportable Limits • Case Studies – Worked Examples • Appendices – Consequence Analysis – Application of Methodology to Non-Petroleum Hydrocarbon Fluids – High Water Content Liquids Regulatory Requirements – RIDDOR 2013 Release of petroleum hydrocarbon 75 The unintentional release of petroleum hydrocarbon on or from an offshore installation which – (a) results in – (i) a fire or explosion; or (ii) the taking of action to prevent or limit the consequences of a potential fire or explosion; or (b) could cause a specified injury to, or the death of, any person. Technical Assessment – Potential for Death or a Specified Injury • Petroleum Hydrocarbons – Well Fluids, Natural Gas, Natural Gas Liquids, Condensate, Crude Oil • Continuous & Discrete Releases • Gas, Vapour, Mist, Liquid • Consequence Analysis – – – – – Continuous Release - Jet Fire Continuous Release - Pool Fire Discrete Release - Fireball Discrete Release - Pool Fire Flash fire, Explosion, Toxic Cloud, Asphyxia, Narcosis - See Guidance RIDDOR DO 75 Assessment Flowchart Release of Petroleum Hydrocarbons? No Yes Confirmed? No Yes Unintentional? No Yes Fire or Explosion? Yes No Automatic Executive Action? Yes HCR is RIDDOR DO 75 Reportable No Other Action & Potential for Death or a Specified Injury? No Yes HCR is NOT RIDDOR DO 75 Reportable Technical Assessment • Continuous & Discrete Releases • Consequence Analysis – – – – Continuous Release - Jet Fire Continuous Release - Pool Fire Discrete Release - Fireball Discrete Release - Pool Fire • Additional Guidance Continuous And Discrete Releases • Continuous release – A continuous release is a loss of containment from a system which occurs, or has the potential to occur, for an extended period of time (minutes) prior to plant stoppage or action being taken to depressurise the system. For continuous releases, the release rate is the important factor in determining if a HCR has the potential to cause death or a specified injury. • Discrete release – A discrete release is a loss of containment from a system with a fixed mass inventory where the hydrocarbon is released over a short period of time (seconds rather than minutes) and where the initial mass released has a greater hazard potential than any following continuous release. Continuous Release - Jet Fire • • • • Jet fire flame length ≥ 1m Criterion – person must be in the flame Mass flow rate for 1m flame length = 3 kg/hour Equivalent gas concentration 20% LFL at 0.5m • Conservatisms – Jet fire flame length correlation – Adopted gas concentration criterion Continuous Release - Pool Fire • Pool fire flame diameter ≥ 1m • Criterion – person must be in the flame • Mass flow rate for sustained 1m diameter pool = 100 kg/hour • Conservatisms – Lowest burn rate adopted for all liquids – Adopted reportable limit lower than calculated Discrete Release – Fireball • • • • Transient analysis Criterion – thermal dose ≥ 1000 tdu Surface Emissive Power = 300 kW/m2 Mass of hydrocarbons for 1000 tdu = 0.15 kg • Conservatism – Assume person exposed to constant heat flux Discrete Release – Pool Fire • Transient analysis • Pool fire grows with time • Criterion – An escaping person is caught in the flame – The thermal dose received during escape ≥1000 tdu. • Mass of hydrocarbons to meet criterion – Natural Gas Liquids - 3 kg – Condensate - 10 kg – Crude Oil - 30 kg • Conservatism – Speed of escape Additional Guidance – Hydrocarbon Liquids • Water Cut – Hydrocarbon liquids with ≥ 90% water by mass are not combustible and are therefore not reportable • Accumulation – Liquid releases are only reportable if they can form pools. – If a liquid release falls to the sea and there is no pool or coating formed on equipment or the deck, it is not reportable. – If a liquid release is routed directly to the drains within 0.5 m of the point of release and does not form a pool, it is not reportable. Reportable Limits Type of Release Phase Gas / Vapour / Mist Hazard Fluid Reportable Limit Jet Fire Natural Gas Natural Gas Liquids Condensate Crude Oil 3 kg/hour (0.0008 kg/s) OR 20% LFL at 0.5 m Pool Fire Natural Gas Liquids Condensate Crude Oil 100 kg/hour (0.028 kg/s) Fireball Natural Gas Natural Gas Liquids Condensate Crude Oil 0.15 kg Pool Fire Natural Gas Liquids 3 kg Pool Fire Condensate 10 kg Pool Fire Crude Oil 30 kg Continuous Liquid Gas / Vapour / Mist Discrete Liquid Reportable Limits for Petroleum Hydrocarbon Releases – DO 75 (Appendix B of Guidance) Confirmed Release Phase of Release Liquid Accumulation Water Content Type of Release Composition of Release Reportable Limit Continuous (Section 10.2.1) Hydrocarbon Gas/Vapour/Mist 3 kg/hour, OR 20% LFL at 0.5m Discrete (Section 10.3.1) Hydrocarbon Gas/Vapour/Mist 0.15 kg Continuous (Section 10.2.2) Hydrocarbon Liquids 100 kg/hour Natural Gas Liquids 3 kg Condensate 10 kg Crude Oil 30 kg Gas/Vapour/Mist Petroleum Hydrocarbon Release Liquid Is the Water Content <90% by Mass? NO YES Did the Release Accumulate? NO YES Discrete (Section 10.3.2) Not RIDDOR DO 75 Reportable Reportable Limits for Non-Petroleum Hydrocarbon Fluids – DO 77 (Appendix D of Guidance) Confirmed Release Phase of Release Hazardous Liquid Water Content Liquid Accumulation Type of Release Composition of Release Reportable Limit Continuous All Flammable Gasses / Vapours / Mists / Sprays 3 kg/hour, OR 20% LFL at 0.5m Discrete All Flammable Gasses / Vapours / Mists / Sprays 0.15 kg Methanol 80 kg/hour All Other Flammable Liquids 100 kg/hour Methanol 45 kg All Other Flammable Liquids 30 kg Gas / Vapour Mist / Spray Non-Petroleum Hydrocarbon Fluid Release YES (Mist or Spray) Liquid Is the Water Content <90% by Mass? NO YES Is the Release a Hazardous Liquid? NO YES (Liquids) Continuous Did the Release Accumulate? NO YES Discrete Not RIDDOR DO 77 Reportable Regulatory Requirements RIDDOR 2013 Dangerous Occurrence RIDDOR Reportable Limit OIR/12 Wells DO 20 No All releases Pipelines DO 21 Yes (See HSE Website) Only if release is within 500m zone Release of petroleum hydrocarbons DO 75 Yes (See Sections 3 & 4) All RIDDOR DO 75 reportable releases Release of non-petroleum hydrocarbons DO 77 Yes (See Section 5) Not required RIDDOR 2013 Dangerous Occurrence RIDDOR Reportable Limit OIR/12 Wells DO 20 No All releases Pipelines DO 21 No Only if release is within 500m zone Release of petroleum hydrocarbons DO 75 No All fires & explosions Release of non-petroleum hydrocarbon fluids DO 76 No Not required Unignited Release Ignited Release Guidance on Hydrocarbon Release Reporting