• • • • • • 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 • • • • • 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. • • • • • 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: • • • • • 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??