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8/10/2019 Brazils Safety Regulatory Framework
1/19
8/10/2019 Brazils Safety Regulatory Framework
2/19
Self-sufficiency
Pre-salt discovery
20011998 19991995 20032000 20021997 2004 2005 2006
Constitu tional Amendment N 9/95
Law n 9.478/97Creation of ANP & CNPE
(National Energy Policy Council)
Implementation of the ANP
Concession contracts
signed with Petrobras
(Round Zero)
2007
Directive CNPE n 8/03
2008 2009
Bi ll s for the
Pre-Salt areas
Pre-salt IM group
2010
Pre-Salt
New Laws
2011
11th round
Pre-salt
discoveries
Brazilian Institutional Evolution
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Brazilian Scenario
29 sedimentary basins, in 7.5million km2(2.5 m il l ion o ffsho re)
8,000 km of Atlantic coast
Geological knowledge: < 7%
Under concession < 4.5%
Wells drilled ~ 22,5 thousand
40 national companies
38 foreign companies
400 production fields
345 exploratory blocks
Santos
Campos
Espri to Santo
Recncavo
Potiguar
Sergipe-Alagoas
Esprito Santo
Paran
Parecis
So Franc isco
Par naba
Amazonas
Solimes
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Production
Oil + LNG2.2 million bbl/day
Gas62.8 million m3/day
Imports/Exports Balance
Oil: + 292.7 thousand bbl/day
Gas:34.6 million m3/day
Proven Reserves
Oil~14 billion bbl (*)
Gas~423 billion m3(*) Pre-salt is not included, except Lula field
Brazilian Scenarioan oil exporter in 2010
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Source: PETROBRAS, 2009
Brazilian ScenarioCampos Basin
~ 2,600 wells drilled
56 platforms / 36 rigs
59 production fields
25% of worlds deepwater production
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Billion barrels
More than 30 billion bblLula, Iara, Guar, Parque das
Baleias, Franco
Brazilian ScenarioPetroleum Reserves
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Brazilian ScenarioSantos Basin needs and chal lenges
Needs
40 drillships and platforms
200 vessels
Infrastructure
Dri l l ing Chal lenges
2,200m Water Depth
2,000m salt layer
5,000-6,000m Reservoirs Depth
Product ion Chal lenges
Pipelines integrity
CO2 (08 a 12%)
Offshore LNG
Flow assuranceSource: PETROBRAS, 2009
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Worldwide ScenarioCatastrophic accidents in 2009 & 2010
http://lobusca.com
http://oilspilllawsuit.org
http://theconversation.edu.au
Does industry know how to ident i fy and control r isks?
Is the wo rst-case scenar io known?
Where was the Blowout
Preventer when we
really needed?
AreRegu latorsdoing
their job?
Does the pol i t ical environment
allow regulators to do their jobs?
Do we need str ic ter rules?
Were the events predictable/ avoidable?
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How should safety regulators deal wi thsuch challenges and uncertainties???
Regional ResponseBrazil
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PROCESSSAFETY
(ANP)
ENVIRONMENT
PROTECTION
(IBAMA)
NAVAL
SAFETY(Maritime
Authority)
PEOPLE
SAFETY
(Labor
Ministry)
Marit ime Autho r i ty
SOLAS
MODU Code
Further rules focusedon naval systems(Communication, hull,ballast, navigation,general condition,evacuation etc)
Labor Minist ry
Rules focused on theoccupational safetyand health risks
Petroleum Agency (ANP)
Rules focused on theprocess plant safety
Subsea / Well Control
Brazi l ian Inst i tute of
Environm ent (IBAMA)
Environmental Licensing
Spill response plans
Rules focused on theinteraction of facilitieswith the environment
Regional ResponseHSE Protection Arrangements in Brazil
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1) Very Strict onboard auditing process
- 90 audits on the last 12 months;
- 682 non-conform ity reports;
- US$ 8 mil l ion in fines; and- 10 cautionary m easures (operat ion halt) .
2) Regulator qualification improvement
- Use audits to identify gaps & needs;
- US$ 270,000.00 invested on training;
- Direct appl icat ion know ledge; and- Benchm arking.
3) Regulatory framework revision
- Safety barriers, well control, cementing;
- Imp rove perform ance indicators;
- Operators com petency ;
- Enhanced operat ions m onitor ing ; and
- Enco urage research and development.
4) Enhanced communication
- With environmental and health regulator;
- With industry (workshops);
- With society (website); and
- Among regulators (IRF).
The ANP ResponseMain I ssues
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Horizon had never been to dry dock since it wasbuilt in 2001
failed to rigorously analyze the risks created by
key decisions
procured only six centralizers () even though its
plans had originally called for a greater number
MP 12: Risk Identification and Analysis32 non-conformities (13 serious and 1 critical)
MP 13: Mechanical Integrity47 non-conformities (22 serious and 1 critical)
MP 16: Management of Change (MoC)37 non-conformities (7 serious and 1 critical)
The ANP ResponseSignals & I ndicators
http://oilspilllawsuit.org
682 non-conformity reports
MP 6: Continuous Improvement and
Performance Monitoring46 non-conformities (11 serious)
The ri g received several safety awards and a placeinside Transoceansexcell ence box, which compares
r igs based on safety performance...
Source: National Commission Report
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The ANP ResponseSignals & I ndicators
Source: International Regulators Forum
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Source: International Regulators Forum
The ANP ResponseSignals & I ndicators
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Focus on Safety Management Systems! ! !
Regulatory Framework for Offshore Safety
Performance-Based/Goal Setting Model
Fewer prescriptive requirements
Non-restrictive approach to technological innovations
Minimum requirements for: Mechanical Integrity, Risk Assessment,
Contractors Selection, Internal Audits, Incident Investigations, Management of
Change, Safe Working Practices, Safety Critical Elements Management,
Simultaneous Operations etc.
The ANP ResponseSafety F ramework - ANP Resolution N 43/2007
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Management, Leadership and Personnel
MP 1: Safety Culture and Managerial
Commitment & Responsibility
MP 2: Personnel Involvement
MP 3: Personnel Qualification, Trainingand Performance
MP 4: Work Environment and Human
Factors
MP 5: Contractors Management
MP 6: Continuous Improvement andPerformance Monitoring
MP 7: Audits
MP 8: Information and Documentation
Management
MP9: Incident Investigation
Facilities and Technology
MP 10: Design, Construction, Installation and
Decommissioning
MP 11: Critical Operational Safety Elements
MP 12: Risk Identification and Analysis
MP 13: Mechanical Integrity
MP 14: Management of Major Emergencies
Operational Practices
MP 15:Operational Procedures
MP 16: Management of Change (MoC)
MP 17: Safe Working Practices and Control
Procedures in Special Activities
The ANP ResponseSafety F ramework - ANP Resolution N 43/2007
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- Focus on Process Safety (major hazards) other regulators areresponsible for occupational safety, health risks and environmental issues
(including oil spill response and containment);
- Maritime Authority takes care of the ship features of the facility:
agreement protocols to cope with interfaces;
- Performance-oriented audits based on safety indicators;
- Non-conformity reports system (obligation to do) is a powerful tool to
enforce continuous improvement;
- Onboard presence is necessary to feelsafety climate and culture; and
- Precautionary measures (operation halt) are working much betterthan fines
The ANP ResponseWhat is working well
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National Petroleum Agency
Thank You!
Raphael N. MouraHead of Safety Division