Oil Spill Response Plan Bo2 April 2018 Redacted - 001 050
Oil Spill Response Plan Bo2 April 2018 Redacted - 001 050
Oil Spill Response Plan Bo2 April 2018 Redacted - 001 050
Security Classification:
BP Canada Energy Group ULC
BP Public
B02 Issued for Use Mike Condon Allen Pere April 9 , 2018
A01 Issued for Review Mike Condon Allen Pere November 1, 2017
Rev
Unique Identifier: CN001-HS-PLN-600-00003
B02
Uncontrolled when printed or stored locally
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DocuSign Envelope ID: D652A638-4CBC-4F52-85B2-91C835A5928A
Revision History
Reviewers
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Input Multiple
Table of Contents
Table of Contents .................................................................................................................. ii
List of Figures ........................................................................................................................ v
List of Tables ........................................................................................................................ vi
Acronyms, Abbreviations & Definitions................................................................................ vii
1 Policy, Responsibility and Planning Systems .................................................................... 1
1.1 Introduction .........................................................................................................................1
1.2 Scope ...................................................................................................................................1
1.3 OSRP Organisation................................................................................................................2
1.4 Linked Plans .........................................................................................................................5
1.5 Multi-Tier Oil Spill Response Philosophy................................................................................7
1.6 Policy ...................................................................................................................................8
1.6.1 Health, Safety and Environmental Policy ................................................................................ 8
1.6.2 Response Priorities ................................................................................................................ 10
1.7 Regulatory Background .......................................................................................................11
1.7.1 Area Contingency Plans......................................................................................................... 14
1.7.2 Nova Scotia Emergency Response Plan (NSERP)................................................................... 14
1.7.3 CANUSLANT ........................................................................................................................... 14
1.8 Plan Review, Updating and Access ......................................................................................15
1.8.1 Review and Updating Procedures ......................................................................................... 15
1.8.2 Electronic Plan Access ........................................................................................................... 15
2 Initial Oil Spill Response Actions .................................................................................... 16
2.1 On-scene Initial Response Actions .......................................................................................16
2.2 IMT Initial Actions Checklists...............................................................................................19
2.3 Hazards Assessment ...........................................................................................................23
2.4 Initial Notifications .............................................................................................................23
2.5 Spill Assessment .................................................................................................................24
2.5.1 General .................................................................................................................................. 24
2.5.2 Spill Volume Estimation ........................................................................................................ 24
2.5.3 Oil Spill Surveillance and Tracking ......................................................................................... 26
2.5.4 Oil Spill Trajectory Modelling ................................................................................................ 27
2.6 Response Objectives and Strategies ....................................................................................28
2.7 Response Information Management ...................................................................................29
2.7.1 Information System ............................................................................................................... 29
2.7.2 Situational Awareness/Common Operating Picture ............................................................. 30
3 Notification Procedures ................................................................................................. 31
3.1 Notification Procedures ......................................................................................................31
3.1.1 Internal Reporting Requirements ......................................................................................... 33
3.1.2 External Reporting Requirements ......................................................................................... 36
List of Figures
Figure 1-1: Aspy 11 Project Summary ........................................................................................................... 2
Figure 1-2: General Pattern of Oil Spill Response .......................................................................................... 3
Figure 1-3: BP Canada Scotian Basin Exploration Project OSRP – Linked Plans ............................................. 6
Figure 1-4: Tier Response Model (from IPIECA 2015) ................................................................................... 8
Figure 1-6: Regulatory Overview ................................................................................................................. 12
Figure 2-1: Initial Response Actions ............................................................................................................ 17
Figure 2-2: Oil Spill Initial Data Form ........................................................................................................... 18
Figure 2-3: Initial Response Actions IMT Incident Commander................................................................... 21
Figure 2-4: Oil Trajectory – Manual Calculation .......................................................................................... 27
Figure 2-5: Response Strategy Flowchart .................................................................................................... 29
Figure 2-6: Concept of Simultaneous Operations........................................................................................ 30
Figure 3-1. Oil Spill Notification Log ............................................................................................................ 33
Figure 3-2: BP Scotian basin exploration project Incident Notification Process .......................................... 35
Figure 5-1: BP Incident Management Organization .................................................................................... 43
Figure 5-2: BP Full IMT Structure for Major Event E.g. Oil Spill (Including MRT and Unified Coordination
alignment) ................................................................................................................................................... 45
Figure 6-1: The Cone of Response ............................................................................................................... 47
Figure 6-2: Spill Response Strategy Decision Guide..................................................................................... 50
Figure 6-4: Offshore Containment and Recovery Decision Tree ................................................................. 56
Figure 6-5: Surface Dispersant Application Decision Tree ........................................................................... 59
Figure 6-6: In-Situ Burning Decision Tree .................................................................................................... 63
List of Tables
Table 1-1: Overview of OSRP ......................................................................................................................... 4
Table 1-2: Tier Level for this OSRP................................................................................................................. 7
Table 1-3: Key Relevant Legislation or Guidelines with Potential Relevance to Spills ................................. 13
Table 2-1: Response Facilities...................................................................................................................... 22
Table 2-2: Hazard Identification Chart......................................................................................................... 23
Table 2-3: Spill Volume Estimation Chart .................................................................................................... 25
Table 2-4 Trajectory Modelling Sources ...................................................................................................... 27
Table 6-1: Potential Spill Events .................................................................................................................. 46
Table 6-2: Time- and Conditions-Related Windows of Opportunity Descriptions ....................................... 51
Table 10-1: KPMG Contacts ......................................................................................................................... 71
Table 12-1 Scotian Basin Exploration Project Oil Spill-Related Training and Exercise Schedule .............. 74
Section
1
1 Policy, Responsibility and Planning Systems
1.1 Introduction
This Oil Spill Response Plan (OSRP) provides BP Incident Management Team (IMT) and response
personnel with tactical and strategic guidance regarding response management, capabilities and
resources in the unlikely event of an oil spill during the BP Canada Energy Group ULC (‘BP’) Scotian Basin
Exploration Project. The OSRP follows international practices and the Canadian Coast Guard’s (CCG)
Marine Spills Contingency Plan – National Chapter, ISO 15544 (Offshore production installations –
Requirements and guidelines for emergency response) and the International Maritime Organization
(IMO) Manual on Assessment of Oil Spill Risk and Preparedness. The tiered preparedness and response in
this OSRP is consistent with the International Convention on Oil Pollution Preparedness, Response and
Co-operation 1990 (OPRC 1990). The OSRP identifies potential types and magnitudes of oil spills and their
relative potential impact. It provides key steps for initial actions, notification procedures, and important
safety information. The OSRP establishes the role of the IMT, lists oil spill response resources, identifies
the Spill Response Operating Team, describes response facilities, and provides information on
implementing oil spill response strategies.
In the event of an actual spill, this OSRP cannot guarantee that all discharged oil will be recovered, or that
all sensitive area protection strategies will be successful. However, the plan incorporates practical
information intended to help achieve the best possible response. This Plan provides information to help
guide a response; however, specific actions taken and response options employed will be dependent on
the specifics of an incident and will, ultimately, be determined by the Incident Management Team.
1.2 Scope
BP, in its capacity as operator of the proposed Scotian Basin Exploration Project (herein referred to as the
‘Project’), proposes to drill an initial exploration well in 2018 with potential to drill up to seven exploration
wells in phases over the term of the licences, from 2018 to 2022.
The exploration drilling project location is depicted in Figure 1-1 and encompasses portions of BP’s
offshore ELs 2431, 2432, 2433, and 2434. These licences cover 13,982 km2 and, at their shortest distance,
are located approximately 230 km southeast of Halifax and 48 km from Sable Island National Park
Reserve. Water depths in the ELs range from 100 metres (m) to more than 3,000 m.
For the initial exploration well, designated Aspy D-11, (location indicated by red dot) the Seadrill West
Aquarius will be utilized. The Seadrill West Aquarius is a 6th generation ultra-deepwater semi-submersible
pattern of oil spill response and sequence of activities that will normally occur over the duration of a
response (Figure 1-2).
BP’s key priorities and objectives during oil spill response include, but are not limited to, the following:
1. People – Preserve safety of human life. Consider the safety of all people in the immediate area
including your own.
2. Environment – Minimize adverse effects to the environment.
3. Property – Protect BP’s assets. Stabilize the situation to prevent the event from worsening.
4. Business including reputation.
As part of the overall response, BP is committed to developing incident-specific objectives and strategies
to address these priorities as well as developing incident-specific response objectives that minimize
further spill impacts and protect resources at risk.
While incident-specific objectives will be determined by the IMT, they would likely include:
1. ensure the safety of asset personnel, response personnel and the public;
2. search and rescue;
3. control the source of the incident;
4. manage a coordinated response effort;
5. maximize protection of environmentally-sensitive areas (e.g., Sable Island);
6. treat, or contain and recover spilled material;
7. keep the public and stakeholders informed of response activities.
Response objectives will be clearly communicated, measurable and achievable. Effective planning and
execution of response operations is based upon coordination with authorities and response partners to
allocate response resources (i.e., people, equipment, time) effectively.
To make sure an adequate response is available to address the incident, BP will, as required, apply the
following response philosophy:
• (Over) React.
• Assessment.
• Response.
• Stand-down.
The IMT provides support in the event of an emergency at any facility for which it is responsible. Should
the affected site (MODU, supply base, helicopter operations, PSVs, etc.) ask for BP IMT assistance, all such
requests are complied with on every occasion through activation of the IMT.
Figure 1-6 below shows the relationships between agencies, regulators, operators and response
contractors.
In the event of a spill, the CNSOPB can access scientific advice on a variety of issues from other agencies
or groups through National Environmental Emergencies Centre’s (NEEC) Environmental Emergencies
Science Table (the “Science Table”) chaired by ECCC. Science Table experts may include representatives
from other government agencies such as CWS, CCG, DFO, Nova Scotia Environment, Emergency
Management Office (EMO) or subject matter experts from response agencies, Indigenous
representatives, local communities, fishermen’s associations, environmental non-government
organizations, and academic institutions. The Science Table works to advise the lead agency on matters
such as sensitivities, fisheries and wildlife, cultural resources at risk, etc. and helps to identify protection
and response priorities.
In addition to the OSRP required for offshore operators for petroleum activities, the MODU and Platform
Support Vessels must also have Ship Oil Pollution Emergency Plans (SOPEP) as per the Canada Shipping
Act (CSA). The CCG is the lead regulatory agency for oil spills from vessel or MODUs while in transit. TC
also has compliance, enforcement and implementation responsibilities of regulations relating to response
organizations.
Legislation, regulations, guidelines and memoranda of understanding relevant to operations within the
scope of this OSRP are summarized in Table 1-3. These are not exhaustive, and all parties are to be fully
compliant with flag, port state, local, national, international laws, codes and standards.
For more details see Appendix 1: Roles and Responsibilities of Government Agencies.
The CNSOPB has active MOUs in place with numerous agencies describing their mutual roles and
responsibilities in administering relevant legislation. These detailed MOUs are found at:
http://www.cnsopb.ns.ca/reference.
1.7.1 Area Contingency Plans
Canadian Response Organizations (ROs; i.e., ECRC, ALERT) have their own Area Response Plans and BP has
access to these plans through the contractual agreements for the provision of response resources.
1.7.2 Nova Scotia Emergency Response Plan (NSERP)
The Emergency Management Office (EMO) Nova Scotia has legislative responsibilities to ensure that
emergency management planning occurs within all levels of the provincial government. The NSERP serves
as the provincial master plan for the managing of emergency events and lays out the structure to be used
the by EMO in coordinating a provincial response. The NSERP is designed to ensure an integrated
response involving all provincial departments, municipalities, non-governmental organizations and the
private sector. The plan includes the role of the Joint Emergency Operations Centre (JEOC), individual
roles and responsibilities, an incident command system, planning assumptions and a concept of
operations, as well as plan maintenance responsibilities. The NSERP is found at:
http://novascotia.ca/dma/emo/resources/docs/the-ns-emergency-response-plan-150114.pdf
1.7.3 CANUSLANT
Through a bilateral Joint Marine Pollution Contingency Plan (JMPCP), Canada and the United States have
established a coordinated system for planning, preparedness, and responding to harmful substance
incidents in the contiguous waters along shared marine borders. This joint plan supplements each
country's national response systems and coordinates the interface of these systems for boundary areas.
The JMPCP calls for five Geographic Annexes that specify response procedures and are the responsibility
of the Regional Directors of the Canadian Coast Guard and District Commanders of the United States
Coast Guard. The Coast Guards also chair Joint Response Teams (JRTs) for each geographic area that
consist of appropriate government representatives to provide advice and counsel to facilitate
coordinated planning, preparedness, and response to a harmful substance incident, recommend
amendments to the JMPCP or the Geographic Annexes, or provide advisory support to the CCG On-Scene
Commander and the USCG On-Scene Coordinator.
The CANUSLANT Geographic Annex covers the Atlantic marine boundary between Canada and the United
States, defines the CANUSLANT JRT, and is regularly tested and improved in an ongoing series of
CANUSLANT exercises. If the CCG becomes aware of an incident in the adjacent or non-adjacent waters
covered by this plan, they will notify the USCG without delay; similarly, the USCG would notify the CCG if
they became aware of an incident.
This document will be held in the project SharePoint site controlled versions and revision announcements
will be published and communicated to the appropriate BP and contractor personnel to ensure local
implementation. Copies or extracts of this document, which have been downloaded from the SharePoint
site, are uncontrolled copies and cannot be guaranteed to be the latest version.
Section
2
2 Initial Oil Spill Response Actions
2.1 On-scene Initial Response Actions
Figure 2-1 below provides the sequence of steps and activities to be followed during the initial stages of
an oil spill response.
For more details, including “first-in” and IMT role-specific checklists, refer to Appendix 2 of the Project IMP
(CN001-HS-PLN-600-00002): ICP Checklists.
For more details, refer to Appendix 3 of the Project IMP (CN001-HS-PLN-600-00002): Incident Specific
Incident Management Guides.
Spill assessment is conducted by the Planning section of the IMT using information provided by field
personnel and involves:
• spill volume estimation;
• oil spill surveillance; and
• oil spill trajectory modelling.
2.5.2 Spill Volume Estimation
It is important to estimate the size of the spill so that it can be correctly categorised into a tier to alert
onshore responders and regulators to the type of incident, possible impact and likely severity.
There are two methods to estimate a spill size:
1. Known quantity: for example, if you know that all the oil has been lost from a tank or a hose that
contained a known amount, report that amount.
2. Unknown quantity: estimate the quantity visually based on the area the slick covers and the
relationship between the observed oil colour/ appearance which determines its thickness.
For unknown quantities, follow the steps below in Table 2-3 to establish an initial best estimate of the
quantity of oil observed.
Oil Appearance Thickness Loading Coverage [%] ÷ Total oil area Min volume Max volume
Code [mm] [m3/km2] 100 [km2] [m3] [m3]
1. Sheen
0.00004 to 0.04 X /100 X =
0.0003 0.3
2. Rainbow
0.0003 to 0.3 X /100 X =
0.005 5.0
3. Metallic
0.005 to 5.0 X /100 X =
0.05 50
4. Discontinuous
0.05 to 50 X /100 X =
true colour
0.2 200
5. Continuous
>0.2 +200 X /100 X =
true colour
The surveillance strategy will be implemented as soon as a notification of an incident is received with the
following actions:
1. Obtain first visual observations from the MODU (if safe to do so) and support vessels on site;
2. Deploy satellite tracking buoys from MODU or support vessel in the area of the spill;
3. Mobilize ECRC for aerial surveillance aircrafts (See Appendix 4 for contact details);
4. Satellite imagery may be obtained from OSRL if necessary (See Appendix 4 for contact details);
5. Reassess aerial surveillance needs throughout the response.
If the spill scenario requires so, these assets may be supplemented by other means such as airborne
remote sensing, aerostats (tethered balloons with remote sensing equipment) and Unmanned Aerial
Vehicles (UAV/drones). These tools will be tasked to specific surveillance missions such as monitoring
operations or wildlife. Each of these tools have advantages and disadvantages, and no single tool will
provide all surveillance requirements and therefore a suite of surveillance tools will be deployed to
provide a 24-hr comprehensive surveillance capability based around aerial visual observation and satellite
imagery. Oil spill trajectory modelling will also be used and will be validated by the surveillance from
multiple platforms.
If required, assets from Transport Canada’s National Aerial Surveillance Program (NASP) could assist with
surveillance activities. Transport Canada operates a fleet of surveillance aircrafts equipped with SLAR,
EO/IR, UV/IR and video and still cameras. These assets may be activated through the CNSOPB.
For more details see Appendix 2: Surveillance Guidelines.
For smaller spills, ECRC will be requested to run trajectories using OilMap with results likely available
within a 6-hour period.
For larger or more complex spills (such as loss of well control), modelling will be done internally at BP
using OSCAR with results likely available within a 12- to 24-hour period. OSRL modelling capacity is used
as a backup solution.
All models will require spill data to calculate trajectory and behaviour such as:
• oil properties;
• spill information (location, volume, source, continuous spill or not, etc.);
• met-ocean data (weather forecast, currents, tides).
It is important to note that oil spill trajectory calculations provide an estimate of oil movement and
potential behaviour. The results must be validated by actual spill surveillance.
During an oil spill response, all effective and feasible response tools will be activated and used
simultaneously to maximize the effectiveness of the response.
Should simultaneous response operations (SIMOPS) occur, the probability of a hazardous or conflicting
event is increased as numerous assets will be working at the same time in close proximity. Coordination
of SIMOPS and effective communications are necessary to ensure all activities are performed in a safe
and controlled manner. BP has established SIMOPS procedures which will be followed during a spill
response, and an incident-specific SIMOPS plan will be developed if required and adapted with the scale
of the spill (Figure 2-6). Additional information can be found in Section 6.5.3 of this Plan.
Section
3
3 Notification Procedures
3.1 Notification Procedures
In the event of a spill, BP will ensure that proper notifications are made in a timely manner, both
internally and externally. This section contains:
• an oil spill-specific notification log (Figure 3-1);
• information on the internal BP notification process;
• external notification requirements.
Note - BP’s full notification procedure and notification matrix are found in Section 3 and Appendix 9,
respectively, of the Project IMP (CN001-HS-PLN-600-00002).
Person Making
notified contact
Reference # /
Time/Date of
Notification
Comments
Contacted
Name of
Name of
contact
Person
RESPONDERS
ECRC (Tier 2 oil spill +
responder) (24/7)
OSRL (Tier 3 oil spill responder +44 23 8033 1551
(24/7)
FACILITIES
West Aquarius OIM (bridge)
West Aquarius Rig Manager
West Aquarius BP Well Site
Leader Satellite phones
Details for all HSE-related incident reporting and investigation are detailed in BP’s Scotian Basin
Exploration Project Incident Investigation and Reporting Guide (CN001-HS-GLN-600-00001).
3.1.1 Internal Reporting Requirements
All those that may be required to assist in an emergency are to be notified as early as possible. They are
to be stood down as per instruction from the BST or BP Halifax Incident Commander (IC) respectively,
only when their level of involvement has been accurately assessed. Therefore, the following notification
process is to be used:
1. The incident is reported to the Wells Superintendent via the duty phone # . Should
the Wells Superintendent not be immediately reachable, a Duty Manager can be reached via the on-
call phone # . At this point the person contacted becomes the Incident Commander
and, as such, is now accountable for managing the BP response to the incident.
2. Wherever possible the IC will discuss the incident details with the On-scene Commander (OC) and
mobilize the IMT accordingly. The nature of the incoming report may be such that the IMT is
mobilized without contact with the OC (e.g., ditched helicopter). In these cases, the IMT must form
and gather the incident details.
3. If this is a well control event, the IC will notify the VP of Wells for New Ventures, as per the Incident
Notification Chart for Non-US Waters for mobilization of Source Control resources.
4. The IMT will action any appropriate response plans and mobilize the required resources for the
incident.
5. If the IMT is activated, the IC will notify the BST Leader (or alternate) via the Naperville Notification
Centre using Send Word Now. The IC and BST Leader will decide if a BST needs to be stood up, and
what type of support it would provide. For example, depending on the nature and scale of the
incident, the BP Halifax IC may request additional support from Calgary such as HR and C&EA, or MRT
support.
6. If the BST mobilizes, the BST Leader will notify the Group Duty Manager, by calling the Response
Information Centre, who will liaise with the Duty Segment Executive and Head of Region as required.
7. The BST Leader and Group Duty Manager will review the situation and will consider the requirement
to mobilize the EST in St James’s Square or request assistance from the MRT.
Figure 3-2 below summarises the BP Scotian Basin Exploration Project incident notification process.
BP will comply with the CNSOPB Incident Reporting and Investigation Guidelines (October 2017), in
accordance with the Accord Acts, the regulations, and the terms and conditions of Board approvals and
authorizations for the reporting and investigation of incidents that occur in the offshore area. The
Guidelines outline:
• what constitutes an incident that is reportable to the Board;
• the process for the operator to report an incident;
• the Boards’ expectations for incident investigations conducted by the operator; and
• the process for periodic reporting of statistics and reports describing continual improvement
initiatives based on the results of incident trending and analysis.
CNSOPB
The CNSOPB, as lead regulatory agency for offshore oil and gas activities, typically coordinates
communications regarding incidents.
• Must be verbally notified as soon as possible following spills greater than 25L.
o Including but not limited to crude oil, natural gas, condensate, lubricants,
hydraulic oils, fuels, petroleum based synthetic drilling fluids, or any other
refined petroleum product or for a collision during spill response that results in
an injury or major damage / impairment.
• For spills <25L, written notification must be submitted via the CNSOPB website as soon as
possible following the incident.
o Written notification must also be submitted via the CNSOPB website if any
collisions occur during spill response that do not result in an injury or major
damage / impairment within 24 hours of the incident.
Canadian Coast Guard (CCG)
• CCG must be notified verbally immediately following any spill or any other marine pollution
incident.
o This can be done via telephone or VHF radio.
o CCG will initiate notification of TC Marine Safety, ECCC, and DFO as part of their
own notification procedures.
Joint Rescue Coordination Centre (JRCC)
• The JRCC must be notified immediately following a marine incident that requires search
and rescue services or a medevac.
o This can be done directly via telephone or by VHF/MF radio via MCTS (Marine
Communications and Traffic Services).
Transport Canada Aviation
• Transport Canada Aviation must be notified immediately following an aviation emergency
or incident during the spill response operations.
For all incidents, the operator will complete the BP Initial Spill Data Collection Form found in Section 2.4
of this document.
3.2.2 External Forms
CNSOPB: For all incidents, the operator shall provide a written notification to the CNSOPB as soon as
reasonably practicable, but no later than 24 hours after the operator becomes aware of any incident. A
copy of the CNSOPB Notification Form is provided in Appendix 3: Notification Forms.
• The written notification may be submitted to the CNSOPB by email to incident@cnsopb.ns.ca.
• E-mailed notifications will contain a short descriptive title and any incident identification number
assigned by the operator. An operator will use the Incident Notification Form posted on the CNSOPB
website (www.cnsopb.ns.ca/environment/incident-reporting) for this purpose.
ECRC: ECRC is notified by calling the 24-hour emergency number provided to members. A copy of the
ECRC Call out Data Collection Sheet is provided in Appendix 3: Notification Forms, of this document.
OSRL: OSRL is notified by calling the 24-hour emergency number provided in the Notification Log. The
OSRL notification form is provided in Appendix 3: Notification Forms, of this document. Note that written
mobilization is required for dispersant use.