SUGGESTED INDICATORS OF ENVIRONMENTALLY RESPONSIBLE

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SUGGESTED INDICATORS OF,ENVIRONMENTALLY RESPONSIBLE. PERFORMANCE OF OFFSHORE OIL,AND GAS COMPANIES PROPOSING TO. DRILL IN THE U S ARCTIC,Harvard Law School,Emmett Environmental. Law Policy Clinic,Harvard Law School December 2013. Emmett Environmental,Law Policy Clinic,Emmett Environmental Law Policy Clinic.
Harvard Law,6 Everett Street Suite 4119,Cambridge MA 02138. Phone 1 617 496 2058,Fax 1 617 384 7633, Website http blogs law harvard edu environmentallawprogram clinic. This paper may be cited as Wendy B Jacobs Suggested Indicators of Environmentally Responsible. Performance of Offshore Oil and Gas Companies Proposing to Drill in the U S Arctic Emmett. Environmental Law Policy Clinic Harvard Law School Cambridge Mass December 2013. Comments are welcome and may be directed to Wendy B Jacobs at wjacobs law harvard edu. The Emmett Environmental Law and Policy Clinic at Harvard Law School ELPC works on a. variety of local national and international projects covering the spectrum of environmental law and. policy issues under the direction of Wendy B Jacobs Esq a Clinical Professor at Harvard Law School. and Director of the ELPC This paper was authored by Wendy B Jacobs with assistance from David. Baake and Mary Schnoor who are respectively third and first year students at Harvard Law School. Other students who contributed to this project are Elisabeth Costa Ephraim Olson and Jocelyn. Sedlet all current or recently graduated Harvard Law School students. Copyright 2013 by the President and Fellows of Harvard College All rights reserved to the Emmett. Environmental Law Policy Clinic Harvard Law School. Cover Image BP arctic drilling rig available at http www propublica org images bp slideshow IMG 9930 jpg. TABLE OF CONTENTS,Executive Summary 5,Table of Suggested Indicators 8. Introduction 10,Leading Indicators 11, 1 Personnel Surveys Regarding Operator s Safety and Environmental Management System 11. 2 Safety and Pollution Prevention Equipment Maintenance Backlog 14. 3 Air Pollution 16,Intermediate Indicators 19,4 Civil and Administrative Violations 19.
5 Kick Frequency and Kick Response Time 20,Lagging Indicators 23. 6 Loss of Primary Containment Events 23,7 Oil Releases 25. 8 Work Related Fatalities and Reportable Injuries 28. Conclusion 29,EXECUTIVE SUMMARY, This paper suggests a set of performance indicators for use to evaluate and predict the environmental. performance of companies proposing to drill for oil or gas in the U S Arctic We use the term per. formance indicator to refer to an observable metric that correlates with an aspect of an operator s. performance that is either too difficult to measure directly or too broad to be reduced to a single. precisely quantifiable metric 1 Performance indicators can be used to compare an operator s perfor. mance in a particular year against its performance in previous years or against average industry per. formance 2 Hence these indicators provide important information for regulators investors members. of the general public and operators themselves 3, In the years since the Deepwater Horizon oil spill in the Gulf of Mexico policymakers have been very. interested in developing performance indicators for the offshore oil and gas industry 4 Much of their. focus has been on the development of process safety indicators indicators that correlate with the risk. of catastrophic accidents 5 Less consideration has been given to the development of indicators that. correlate with harm to public health or the environment resulting from the routine construction op. eration and decommissioning of offshore wells Yet a true culture of safety cannot limit its attention. to the prevention of catastrophic accidents but must also seek to protect against the cumulative harms. 1 See Org for Econ Coop Dev Guidance on Developing Safety Performance Indicators Related to. Chemical Accident Prevention Preparedness and Response 5 2d ed 2008 hereinafter OECD Guidance. The term indicators is used to mean observable measures that provide insights into a concept safety that. is difficult to measure directly, 2 See Ian Whewell Performance Indicators in Major Hazard Industries 8 Chem Safety Bd Pub Hearing.
Safety Performance Indicators 2012 http perma law harvard edu 0xoqT9KTsTm. 3 Operators may benefit from performance indicators by integrating them into their managerial control systems. See Paolo Perego Frank Hartmann Aligning Performance Measurement Systems With Strategy The Case of. Environmental Strategy 45 Abacus 397 2009, 4 See Int l Ass n Oil Gas Prod Recommended Practice on Key Performance Indicators Report No 456. 2011 available at http perma law harvard edu 0jhs3Cvbynv Chem Safety Bd Pub Hearing supra note 2. Comm on the Effectiveness of Safety Envtl Mgmt Sys for Outer Cont l Shelf Oil Gas Operations. Transp Research Bd Evaluating the Effectiveness of Offshore Safety and Environmental Management. Systems Special Report 309 5 2012 hereinafter Transp Research Bd. 5 See Int l Ass n Oil Gas Prod supra note 4 Chem Safety Bd Pub Hearing supra Note 2. Emmett Environmental Law Policy Clinic Harvard Law School 5. resulting from an operator s day to day operations 6 Thus although there remains an urgent need for. continued development of process safety indicators the development of environment specific indica. tors is also imperative, As the offshore oil and gas drilling industry expands into U S waters off the coast of Alaska it is criti. cal that policymakers develop both process safety and environment specific indicators that are tai. lored for effective oversight of operator performance in this environmentally significant and challeng. ing setting The Arctic presents formidable new challenges to operators accustomed to working in. temperate climate including extreme cold varying forms and amount of sea ice seasonal darkness. high winds extended periods of heavy fog and week long storms that approach hurricane strength 7. These demanding physical conditions can be expected to both heighten the risk of an oil spill and. limit the effectiveness of oil spill response operations 8 Compounding these challenges is the fact that. the Arctic is remote and far from the critical resources infrastructure and supplies needed to clean up. chemical spills and releases Given the heightened accident risk in the Arctic there is a pressing need. for process safety indicators that can be used to evaluate the safety performance of companies operat. ing in this region, The development of environment specific indicators is similarly crucial The Arctic region is home. to a number of unique diverse and fragile ecosystems 9 These ecosystems sustain a diverse collec. tion of species including many marine mammals and endangered species as well as human commu. nities that depend on these ecosystems for their food and way of life 10 These interests are threatened. not only by catastrophic accidents but also by environmental impacts resulting from routine drilling. activities including but not limited to exploration construction of wells and pipelines transporta. 6 See Emmett Envtl L Pol y Clinic Comments on Bureau of Safety and Environmental Enforcement BSEE. Draft Safety Culture Policy Statement 3 Docket ID BSEE 2012 0017 March 20 2013 While it is critical to. prevent accidents of all sorts accident prevention is not synonymous with safety A true culture of safety. is broader and protects against intended as well as unintended danger and damage to persons property and the. environment, 7 Nat l Comm n on the BP Deepwater Horizon Oil Spill Offshore Drilling Offshore Drilling in the Arc. tic Background and Issues for the Future Consideration of Oil and Gas Activities 10 Staff Working Paper. No 13 2011,9 Id at 22,10 See id at 13 15, 6 Suggested Indicators of Environmentally Responsible Performance 2013.
tion of oil and gas and day to day operation of vessels wells and associated structures 11 To minimize. damage to and adverse impacts on valuable human and environmental interests environment specific. indicators must be developed and applied,Choice of Indicators. In identifying appropriate performance indicators we sought to include a mix of leading intermedi. ate and lagging indicators Leading indicators measure the strength of a company s safeguards against. future failures in environmental performance Intermediate indicators track relatively minor failures. in an operator s performance that may be predictive of more substantial performance failures Lag. ging indicators track past failures in an operator s environmental performance 12 We include several. leading indicators because they help industry and interested persons to focus on the need for changes. in an operator s behavior before environmental harm occurs Such a proactive approach is necessary. where as here an operator s failure to act in an environmentally responsible manner risks degrading a. precious and irreplaceable ecosystem such as exists in the Arctic. The indicators presented here are intended to provide a comprehensive portrait of an operator s en. vironmental performance We attempted to address all aspects of offshore oil and gas operations in. the Arctic including exploration drilling production and product transportation and to cover both. the risk of catastrophic accidents and environmental impacts that occur during the course of normal. operations We chose indicators for which data is available or reasonably easy to acquire and where. possible we drew from indicators that are used by other nations or industry groups The collection of. suggested indicators is large enough to be comprehensive but small enough to permit tracking of all. indicators A summary of the indicators is presented in Table 1. 11 See Oil Ind Int l Exploration Prod Forum UNEP Environmental Management in Oil and Gas Explo. ration and Production 20 1997 listing environmental impacts associated with the day to day operation of an. offshore well including air water noise and light pollution. 12 Cf OECD Guidance supra note 1 at 5 describing outcome and activities indicators. Emmett Environmental Law Policy Clinic Harvard Law School 7. Table 1 Suggested Indicators, Indicator Metric Data Already Data Already Authority for Data Notes Precedent. Collected by Collected by Collection relevant agency. Operators BSEE is BSEE unless otherwise,Leading Indicators. SEMS Personnel Satisfactory or unsatisfactory performance on No No 30 C F R 250 1924 Clear predictive value incentive for operators to improve their. Survey Indicators questions pertaining to clarity of SEMS goals and SEMS programs some administrative costs and need to comply. responsibilities supervisory involvement worker with the Paperwork Reduction Act. professionalism empowerment reporting, performance feedback safety values commitment Precedent. procedures and equipment and training,NOPSEMA Australia process safety survey program.
Safety and Percentage of SPEE maintenance projects not Yes No 30 C F R 250 1916 Clear predictive value incentive for operators to increase. Pollution completed on time 250 1924 investment in SPEE maintenance need to issue NTL. Prevention,Equipment Precedent, Maintenance Oil Gas UK s safety critical maintenance backlog indicator. Air Pollution Metric tons of NOx emitted per million barrels of Yes Yes for operators in 30 C F R 550 303 k This indicator will provide information about air pollution. oil produced the Gulf every 3 BOEM resulting from the day to day operations of offshore wells and will. years since 2005 tend to correlate with an operator s commitment to. Metric tons of SO2 emitted per million barrels of No for operators in environmentally responsible performance need to issue NTLs to. oil produced the Arctic begin tracking emissions in the Arctic. Metric tons of VOCs emitted per million barrels of. oil produced, Metric tons of GHGs emitted per million barrels of. oil produced, Suggested Indicators of Environmentally Responsible Performance 2013. Intermediate Indicators, Civil and Major violations per million barrels of oil Yes Yes N A Clear predictive value incentive for operators to improve. Administrative produced significant violations per million barrels compliance data already available and accessible. Violations of oil produced minor violations per million. barrels of oil produced, Kick Frequency Kicks per year or per 10 000 well completions Yes Yes well kicks No 30 C F R 250 466 250 469 Clear predictive value incentive for operators to improve pressure.
Kick Response time until response to kick response time management and kick management difficult to manipulate and. Time not open to interpretation need to issue NTLs. Loss of Primary Tier 2 events per million barrels of oil produced Yes if Yes with exceptions 30 C F R 250 188 This indicator will provide information about events that cause. Containment mass released from primary containment per year required by e g events some harm to people or the environment data already publicly. LOPC Events regulation involving super available for LOPC covered by Section 250 188 not all LOPC are. Tier 2 threshold releases of covered by regulation at present. substances that do,not cause another,reportable event. Indicator Metric Data Already Data Already Authority for Data Notes Precedent. Collected by Collected by Collection relevant agency. Operators BSEE is BSEE unless otherwise,Lagging Indicators. Loss of Primary Tier 1 events per million barrels of oil produced Yes if Yes with exceptions 30 C F R 250 188 This indicator will provide information about events that cause. 6 Suggested Indicators of Environmentally Responsible Performance ecmb resulting from an operator s day to day operations 6 Thus although there remains an urgent need for continued development of process safety indicators the development of environment specific indica

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