Sudden Exposure - Mitigate your Financial Risk to Short and Long Term Environmental Impacts in Drilling Project Management

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1 Sudden Exposure - Mitigate your Financial Risk to Short and Long Term Environmental Impacts in Drilling Project Management David van Senden September 2015

2 Outline Introduction Drilling and Production Risks of Marine Oil Spills Ecosystem Values (Environmental and Socioeconomic) Potential consequences for proponents i.e. polluter pays NOPSEMA Financial Assurance (OPGGS amendment 2013) APPEA Method for estimating FA Readiness Planning for Impact and Damage Assessment EP/OPEP Impact assessment: Baseline (pre-spill) vs rapid response Statistical confidence in attributing impacts (and damages) to an oil spill Conclusions

3 Drilling and Production Operations Project Management Engineering Services Well Optimization Planning and Approvals Compliance Monitoring Project Management

4 Approvals, Drilling & Production Services > Drilling & Production service offerings include: Project management and outsourcing Global rig management services Well engineering and design Production management Environmental Investigations and Planning (EP, OPEP) Environmental Compliance Monitoring Financial Assurance Compliance > Managed the drilling, workover, or completion of over 2,500 wells around the world > Cardno manages between 5 and 15 third-party rigs around the world at any given time

5 Ecological Risks of Marine Oil Spills Ecosystem Value (Environmental and Socioeconomic) Marine Reserves, Bio regions, Coastal Habitats (RAMSAR) Primary Industries (Fisheries, etc) Recreation and Aesthetics Industrial Cultural and Spiritual Basis for EP/OPEP/OSMP Figure 3 Example conceptual process model for oil spills. NOPSEMA N IP1349

6 Potential consequences for proponents i.e. polluter pays Exxon Valdez Natural Resource Damages Settlement approx $1 Billion in early 90 s dollars Gulf Spill - Published estimates of $25-30 Billion in clean up, economic damages and early restoration (does not include NRDA or Civil Penalties) Small spill clean up 100,000 gallons can easily breach at 1 million a day, damage assessment costs and natural resource claims can be in the $5-15 million range Brazilian prosecutors submitted claims in civil lawsuits against Chevron seeking $17.5 billion in damages for a November 2011 oil spill. Final settlement agreement includes about $130 million in compensatory actions for the 3,600-barrel (~ gallons) spill northeast of Rio de Janeiro.

7 NOPSEMA - Offshore Titleholders Financial Assurance Offshore Petroleum and Greenhouse Gas Storage Act 2006 (OPGGS Act) and related regulations amended 28 May 2013 to strengthen the polluter pays principles of the act, clarify and broaden its financial assurance requirements. Titleholder is required (1 Jan 2015) to maintain financial assurance sufficient to meet the costs of the operational response measures (e.g. well control and containment) and costs arising from addressing the environmental consequences (e.g. monitoring and remediating the environment) amendments included provision for regulation requiring titleholders to demonstrate financial assurance as a prior condition for the acceptance of an environment plan (EP) by NOPSEMA. APPEA developed a standard method (GHD, 2014) for use by titleholders to estimate the level of financial assurance necessary to meet the requirements of the OPGGS Act. GHD Report for APPEA - Method to assist titleholders in estimating appropriate levels of financial assurance for pollution incidents arising from petroleum activities, 61/31048

8 Reasonableness of APPEA method The APPEA calculation method requires that: Reasonable worst case scenario identified during fate and transport modelling be generally consistent with, or more extreme than, any incident that actually occurs; Small number of incident parameters (type of hydrocarbon released, volume of hydrocarbon released, and a measure of shoreline impact) can reasonably predict the general magnitude of operational response costs associated with hydrocarbon releases in marine waters of Australia; The type and level of effort required to respond to, clean up, and monitor a release described in the NOPSEMA approved Environmental Plan is adequate to achieve desired clean-up endpoints; The bottom up approach to costing well control, operational response, and monitoring efforts for the 10 case studies generates reasonable estimates; and 10 case studies relied upon are reasonably representative of the universe of petroleum activities other titleholders subject to the financial assurance requirement may undertake.

9 Bottom-up costing comparison

10 Oil Spill Response Readiness Planning Impact assessment: Baseline (pre-spill) vs rapid sampling Issue of scale Spatial - 10m s to 1000km s Temporal - hours to years Baseline Data Cost versus return (risk reduction) Focus effort (if required) to high risk areas Rapid response baseline information is collected at control or reference sites asap during/after spill Response time Prioritisation of effort Broad scale assessments (e.g. remote sensing) OPEP and OSMP need to provide sufficient detail that titleholders are ready with capacity to respond

11 Impact and Damage Assessment Statistical confidence in attributing impacts (and damages) Confounding effects due to range of habitat types and natural variability Ability to resolve spill effects from natural variability Remote sensing, temporal information at reference sites Statistical analysis as a tool to provide unequivocal apportionment for litigation defence Basis for legal argument about apportionment of liability and costs 3 rd party damages (eg. tourism, fishing) currently not included in Financial Assurance Estimate but titleholders are potentially liable after the event

12 Concluding Remarks Recent regulatory changes require greater commitment to event readiness and Financial Assurance to cover costs of spill incident cleanup, restoration (but not third party liability) Implementation of operational and response monitoring - requires improved preparedness e.g. environmental monitoring drills, enhancement of impact resolution tools (audits by NOPSEMA) Future liability assessment will require robust statistical treatment for impact assessment and implications on data quality Consequences and processes for apportionment of liability for spill effects need to be better understood Including these issues in planning for exploration drilling programs helps to mitigate risk