Capacity to prevent, and mitigate the effect of an oil spill
This chapter explores the capacity of government and private interests
to mitigate the effect of an oil spill in the Great Australian Bight. A number
of submitters raised concerns that BP lacked the capacity to effectively
prevent and contain an oil spill. Many of these submitters referenced BP's
response to the Deepwater Horizon disaster, and Australia's response to the
Montara oil spill.
The committee also received evidence from BP, the Australian government,
and response agencies such as the Australian Marine Oil Spill Centre (AMOSC)
detailing response and recovery strategies which would be implemented in the
event of an oil spill.
The regulatory requirements in relation to oil spills are provided for
in a range of legislative instruments and policies.
Oil Pollution Emergency Plans
As has been noted in Chapter 2, the Offshore Petroleum and Greenhouse
Gas Storage (Environment) Regulations 2009 require a titleholder to prepare
and maintain an Environment Plan. The Environment Plan must have an
implementation strategy that must include an oil pollution emergency plan
(OPEP). The OPEP provides details of response and monitoring arrangements in
the event of an oil spill based on the unique characteristics of both the
proposed activity, and the surrounding environment. The OPEP must include
information on control measures, response capability, and monitoring
capability. It is intended to ensure that the titleholder has demonstrated its
ability to quickly and effectively respond in the event of an oil pollution
Assessment and approval of the OPEP is a critical part of the
Environment Plan assessment process conducted by National Offshore Petroleum
Safety and Environmental Management Authority (NOPSEMA). An OPEP must include
the following information:
the control measures necessary for the timely response to an oil
spill emergency. The control measures include the systems, equipment, personnel
the arrangements and capability that will be in place for the
duration of the offshore activity to ensure the timely and effective
implementation of control measures. This includes arrangements for ongoing
maintenance of response capabilities;
the arrangements and capability that will be in place to monitor
the effectiveness of control measures in the event of deployment; and
the arrangements and capability to monitor oil pollution to
inform response activities.
OPEPs are considered to be living documents and are required to be
reviewed and updated throughout the lifetime of the offshore activities to
ensure the currency of response arrangements and capabilities. The OPEP along
with other aspects of the Environment Plan are regularly inspected for compliance
Offshore Petroleum and Greenhouse
Gas Storage Act 2006
The Offshore Petroleum and Greenhouse Gas Storage Act 2006 (OPGGS
Act) and associated regulations establish a titleholder's responsibilities in
relation to incident notification to both the NOPSEMA and potentially affected
states and the Northern Territory. The regulatory regime also provides NOPSEMA,
or the responsible Commonwealth Minister, to direct titleholders to take
specific actions in response to incidents. It also requires the titleholder to
clean-up and monitor the impact of an oil spill.
The OPGGS Act also requires a titleholder, at all times while the title
is in force, to maintain financial assurance sufficient to give the titleholder
the capacity to meet costs, expenses and liabilities airings in connection with
the carrying out of an oil and gas activity in the title area. The Department
of Industry, Innovation and Science noted that 'the requirement is intended to
ensure that the titleholder will have the capacity to meeting extraordinary
costs, expenses and liability that go beyond the normal operational and
commercial costs of engaging in the offshore oil and gas sector'.
In the event of a titleholder failing to fulfil their obligations in
managing an incident, NOPSEMA, or the responsible Commonwealth Minister, may
carry out the failed actions. However, the titleholder remains financially
liable for the costs associated with these actions.
In the event of an offshore oil and gas environmental incident, the
titleholder has responsibility under the OPGGS Act for emergency response.
titleholders are required to report any incident to NOPSEMA
within two hours of the first occurrence, or first detection of the occurrence,
of the incident; and
titleholders operate as the Control Agency in responding to a
spill, as per their oil pollution emergency plan.
Under the OPGGS Act an oil and gas titleholder must do the following:
take all reasonably practicable steps to eliminate or control the
escape of oil and gas, as soon as possible after becoming aware of it;
clean up the escaped oil and gas and remediate any resulting
damage to the environment; and
carry out environmental monitoring of the impact of the escape on
National Plan for Maritime
The National Plan for Maritime Emergencies
(the National Plan) sets out national arrangements, policies and principles for
the management of maritime environmental emergencies. It provides a single,
national, comprehensive and integrated response for minimising the impacts of
marine pollution from spills and other maritime emergencies on: the
environment; the community, cultural and heritage resources, the economy, and
The National Plan has been operational since 1973 and is a cooperative
arrangement between Commonwealth and state/Northern Territory governments and
industry. It recognises that there is a need to maintain a shared
responsibility in order to respond to spills in a timely and effective manner.
The National Plan, in part, provides:
detailed national, state, local and industry plans and
communication arrangements for responding to oil pollution incidents;
an adequate level of pre-positioned spill combating equipment,
commensurate to the risk involved; and
a comprehensive competency-based national training program which
Marine pollution response plans are prepared by Commonwealth and
state/Northern territory governments, and operators of offshore facilities.
These plans contain the detailed arrangements required to implement the
National Plan. NOPSEMA is recognised under the National Plan as the primary
regulator of offshore petroleum activities. The National Plan also recognises
offshore titleholders as Control Agencies responsible for ensuring that they have
appropriate emergency response arrangements commensurate to the risk associated
with their operations.
The Australian Maritime Safety Authority (AMSA) is responsible for
managing the National Plan. It also represents the Australian Government at the
International Maritime Organisation (IMO) in relation to Australia's
obligations under the International Convention on Oil Pollution
Preparedness, Response and Co‑operation 1990 (OPRC Convention) and
the Protocol on Preparedness, Response and Co-operation to Pollution
Incidents by Hazardous and Noxious Substances 2000 (OPRC-HNS Protocol).
AMSA's functions include:
maintaining the National Plan, and Commonwealth contingency
managing the National Response Team, including training and
providing a national response equipment capability;
coordinating the national training programme;
maintaining uniform standards and testing protocols for oil spill
dispersants and other chemical response agents;
management of trajectory modelling; and
managing the national fixed-wing aerial dispersant contracts.
Titleholder strategies and response organisations
BP's Environment Plan Summary provides an overview of the strategies it
proposed to employ in the event of a blowout.
In addition, two organisations, Oil Spill Response Limited (OSRL) and AMOSC,
are able to provide oil spill response and cleanup services.
BP's Oil Spill Response Planning
On 15 September 2016, BP released its Oil Spill Response Planning
(Strategic Overview) in conjunction with its oil spill modelling for Stromlo-1
and Whinham-1. The Strategic Overview outlined BP's response strategies which
can be divided into four planning zones: source, at-sea, near-shore, and
BP's source control strategies included:
the closure of the blowout preventer;
the deployment of a remote operational vehicle;
the deployment of capping stack technology; and/or
the drilling a relief well.
While source control activities are underway, BP stated that a range of at-sea
response strategies would also be deployed. These included:
subsea dispersant injection;
surface dispersant application;
containment and recovery and in-situ controlled burning.
In the event that oil which has not been successfully dispersed, contained
or removed near the source is likely to move towards the coastline. BP
developed a range of near-shore response strategies which included:
the deployment and use of strike team vessels with booms and
skimmers to contain collect floating oil; and
working with aquaculture operators to relocate stock.
In the event that oil reaches the shoreline, BP developed a range of
clean-up strategies. These were divided into three phases:
Stage One – bulk oil removal from the shoreline;
Stage Two – removal of stranded oil and oiled shoreline material;
Stage Three – clean-up of light contamination, and the removal of
BP also developed an oiled wildlife response strategy which firstly
aimed to reduce the number of affected animals by preventing them from entering
the contaminated area, and capturing and removing animals at risk. Secondly,
the strategy sought to maximise the number of animals successfully treated and
rehabilitated. Finally, the strategy included measures to collect dead and
dying wildlife to reduce the risk of secondary exposure.
BP submitted that it also had access to response and recovery equipment
from a number of sources including:
OSRL which can provide capping and containment equipment, debris
removal and dispersant equipment;
AMOSC which can provide Australian Remote Operational Vehicle
(ROV) tooling, debris removal and dispersant equipment package; and
BP containment response equipment and tools.
Oil Spill Response Limited (OSRL)
OSRL is an industry-owned organisation which provides oil spill response
and cleanup services to members, including BP. In particular, the Subsea Well
Intervention Services (SWIS) provides OSRL members access to a full subsea
intervention capability which includes dispersant, capping, and containment. SWIS
includes four capping stacks which are used to shut-in an uncontrolled subsea
well, and hardware kits to clear debris and apply dispersant. BP submitted that
the four capping stack systems are located around the world, and for a response
in Australia, the capping stacks located in Singapore and Norway would be
Australian Marine Oil Spill Centre
AMOSC, a not-for-profit marine spill response organisation wholly owned
by the Australian Institute of Petroleum (AIP) provided the committee with a detailed
submission which outlined the capabilities and resources available in the event
of an oil spill. AMOSC stated that it 'considers there is currently a robust,
proven and highly coordinated capacity to mitigate the effect of an oil spill
AMOSC stated that the capacity to mitigate the effect of an oil spill is
oil spill response plans, preparedness and coordination at AMOSC,
and national and international levels;
full-time AMOSC staff of 12, dedicated to oil spill preparedness
established core group (120 personnel) of highly trained
Australian experts drawn from member companies to respond to a spill;
the establishment, availability and location of specialised oil
spill response equipment;
maintenance of international linkages to access capabilities and
the adoption of international best practices, regularly audited
and tested via annual exercises;
a particular focus on Australian locations of higher risk for oil
services of AMOSC also available to non-members through the
National Plan; and
appropriate industry resourcing of oil spill preparedness and
AMOSC operates the Australian oil industry's major oil spill response
facility with a stockpile of response equipment, and dedicated staff. AMOSC
maintains stockpiles of equipment around the country with the main stockpile
located in Geelong, three located in Perth, and additional stockpiles in
Exmouth and Broome.
The stockpile in Geelong includes oil spill combat equipment, and
containerised facilities to treat oiled wildlife. AMOSC stated that it has:
...procured two specialised and portable oiled wildlife
treatment containers designed to work in hot and cold areas, and to be deployed
in a very short time to a wildlife refuge centre. The wildlife containers
constitute the formation of a treatment ‘village’ very similar to the wildlife
model used successfully to treat thousands of animals during the New Zealand CV
Rena response (2011).
As earlier noted by BP, AMOSC owns and coordinates the industry's subsea
intervention equipment. This equipment is used to:
...undertake a seabed survey, clear debris away from the
well-head, undertake Blow out Preventer intervention, and prepare the
surrounding seabed for the arrival of a capping stack. The last intervention
capability this equipment enables is the deployment of dispersant at the well
head—this is made possible with additional equipment and tubing (provided by
the RP) but the essential (long lead for delivery) mechanical pieces are in
place to use dispersant subsea.
AMOSC also submitted that it owns 500m3 of dispersant which
is capable of treating between 5–10 days of a free flowing subsea incident. It
noted that should further dispersant be required, domestic and international
stocks would be sought. It stated that in addition, since 1996 there has been a
contract arrangement through AMSA for the provision of six Fixed Wing Aerial
Dispersant aircraft capable of deployment out to 200 nautical miles offshore.
These aircraft are available to all AMOSC member companies, and the contract
also allows for the provision of additional aircraft in the event that
dispersant becomes the primary response strategy.
AMOSC commented that as an oil spill response organisation, it is subject
to annual external audits to assess and ensure that its operational
capabilities are fit for purpose. It stated that these audits also prove
industry's capacity to adequate respond to oils spills for regulatory purposes.
AMOSC also stated that it utilises an international assessment tool called
RETOS which rigorously assesses its preparedness and response capacity. It
noted that according to RETOS, AMOSC is a fit-for-purpose response
BP also submitted that it has access to the Subsea First Response
Toolkit (SFRT) through AMOSC. The SFRT is similar to the equipment available
through OSRL, however it is stored in Fremantle, Western Australia.
BP containment response equipment
BP told the committee that its own containment response equipment and
tools are complementary to those services provided by OSRL and AMOSC. It stated
that following the Deepwater Horizon incident, a set of response and support
equipment was assembled and can now be rapidly mobilised via airfreight from
Texas to any of its operating sites. In addition, BP submitted that in the
event of drilling occurring in the Great Australian Bight, it would maintain an
inventory of oil spill response equipment at its Adelaide supply base.
Ms Claire Fitzpatrick, Managing Director, Exploration and Production,
BP, outlined to the committee where response equipment would be available in
the event of an oil spill in the Great Australian Bight. Ms Fitzpatrick stated:
There is equipment in a number of places. There will be
equipment on the rig, there will be equipment on the supply vessels which will
be in the area and there will be equipment at the supply base in Port Adelaide.
We are members of the AMOSC First Response Toolkit, which does have kit in both
Geelong and Freo, and we also have kit both in our warehouses in Houston and we
have access through OSRL, which is an industry-wide consortium, in Singapore.
So equipment will come from a number of places, but we will have stuff in South
Australia available immediately.
BP also commented that its internal standard requires the BP Containment
and Response Team to mobilise and deploy a stacking cap, and containment
equipment within 35 days. Ms Fitzpatrick stated:
...our internal standard of requirement is that we will not
drill a well unless we are comfortable and confident that we are able to cap it
within 35 days. We actually think we can do it faster than that; it is
probably nearer to 20, but our internal standard is 35 and, therefore, our
environmental plan has made reference to a 35-day scenario for the capping
stack to be in place.
BP noted in its Environment Plan summary that it had conducted logistics
studies on the schedule for the mobilisation and installation of OSRL capping
stacks located in Singapore and Norway. It submitted that preparatory work such
as debris removal will need to occur in anticipation of the arrival of this
OSRL equipment, and BP equipment based in Texas. BP concluded that:
Detailed logistical studies have demonstrated that the
transportation of the capping stack is not on the critical path for capping the
well, as it is anticipated that it will be delivered in situ whilst preparatory
work is being completed.
BP also submitted that each well to be drilled would have an individual
Relief Well Plan to be implemented in the event of a blowout. The drilling of a
relief well would occur parallel to the deployment of well capping and
containment activities. The Environment Plan Summary provided to the committee
stated that BP estimated it would take 149 days to kill the well. However it
noted that this estimate was based on a worst-case time forecast.
Concerns with the adequacy of oil spill response strategies
Submitters questioned whether industry and government would be able to
adequately respond to an oil spill in the Great Australian Bight. The
Australian Marine Conservation Society (AMCS) commented that it did 'not
believe government or private interests have the capacity to swiftly or
adequately mitigate the effect of an oil spill'.
The AMCS and many other submitters pointed to the harsh weather
conditions and the remoteness of coastal areas in the Bight and argued that
this will hamper efforts to prevent an oil spill, and clean-up activities. For
example, the Conservation Council of South Australia submitted that:
...BP outlined a 35-day process to cap wells should a loss of
well control be experienced in its Great Australian Bight operations.
Conservation Council SA considers that this is an overly optimistic response
time and is manifestly inadequate: the Great Australian Bight is a most
physically challenging area in which to conduct operations.
Concerns were also raised in relation to the type of response equipment
available and the length of time required in deploying response equipment. Mr Matthew
Collis, International Fund for Animal Welfare (IFAW) commented that:
In IFAW's view there remain major question marks over the
capacity to respond to a catastrophic oil spill in the bight. The bight is a
harsh marine environment, meaning that the ability to successfully deploy
responses such as oil containment and recovery is severely limited. There is
also a big question mark over whether BP or government agencies have access to
sufficient manpower to successfully undertake manual cleaning across potentially
hundreds of kilometres of remote and sparsely populated coast in the event of
oil reaching the shore.
Submitters also pointed to the response to the Deepwater Horizon
incident, both in relation to the time it took to cap the well and its location
in relatively calm waters near to major industrial areas. IFAW, for example,
noted that it took:
...several attempts and nearly three months to cap the
Deepwater Horizon well, which was located in waters as much as 1,500m shallower
than the deepest locations in the proposed GAB site.
The Conservation Council of SA also commented on the Deepwater Horizon
incident and noted:
BP's most recent marine oil disaster occurred on the doorstep
of a highly populated oil industry region. Virtually all the infrastructure,
supplies and staff used in the containment efforts were on hand. Sadly, this
proved ineffective in mitigating the impacts of the oil on local fisheries,
tourism and ecosystems. In comparison, the Great Australian Bight has a low
population base, extremely limited infrastructure, and hundreds of miles of
high cliff and inaccessible coastline.
A further matter in relation to Deepwater Horizon was highlighted by
Greenpeace Australia Pacific. Greenpeace stated that BP was unprepared for the
conditions which hampered its early attempts to stem oil flows at Deepwater
Horizon and as a consequence BP used ten different techniques to try to stem
the oil flow. It also stated that 'governments globally have acknowledged that
the industry is alarmingly unprepared across its operations for "black
swan" events—events which they deem to be unlikely, but which once they
have occurred, have devastating consequences'.
A number of submitters highlighted the harsh wave and wind conditions
which are seen in the Great Australian Bight and questioned how BP would be
able to adequately respond to an oil spill in this operating environment.
The Humane Society International described the environment as
'extraordinarily rough, unpredictable and remote',
while Mr Jeff Hansen, Managing Director, Sea Shepherd Australia described the
Great Australian Bight as having 'the biggest, roughest seas in the world.'
Similarly, The Wilderness Society described it as:
...one of the roughest bodies of water on the planet, with bigger
waves and stronger winds than the Gulf of Mexico. The Southern Ocean winds are
now stronger than at any other time in the past 1000 years because of climate
change, according to ANU researchers.
Ms Warhurst, Conservation Council of South Australia, told the committee
that the geography of the Great Australian Bight would make the deployment of
containment technologies such as booms and skimmers difficult. Ms Warhurst also
...manual clean-up will be really difficult, because what we
are talking about along the coastlines particularly is really high cliffs. We
have stretches of cliffs that are inaccessible for hundreds of kilometres and
have no good shoreline at the bottom of them, yet there are marine creatures
there, so that is a significant limitation on how we can effect any clean-up.
The Kangaroo Island Council submitted that personnel from AMOSC had
raised concern that booms to protect coastal areas from oil would not work in
the Great Australian Bight. It stated:
Through field visits while preparing 'Tactical Response
Plans' for BP, personnel from the Australian Marine Oil Spill Centre (AMOSC)
have commented that the booms used to protect coastal areas from the oil will
not work in our relatively exposed waters because of the size of the waves. BP
has not provided an alternate solution.
Mr Hansen, Sea Shepherd Australia, similarly stated that:
If there were a spill there, it would be impossible to clean
up. You cannot put these booms out and clean it up; you are just going to have
to spray dispersant everywhere. Where is that going to go? It could go all over
the ocean floor and destroy the whole basis of that marine ecosystem. It is
just unacceptable for any company to operate in the Great Australian Bight. It
is high risk.
IFAW also submitted that it was concerned about the capacity to deploy
mitigation responses such as oil containment and recovery in the Great
Australian Bight where weather conditions are harsh. It noted that high wave
heights and wind speeds are common in the region, and that in the event that
oil containment and recovery options are not feasible, the only remaining
options are the natural weathering of oil, and the use of dispersants. IFAW
submitted that both of these options would result in oils and chemicals left to
persist in the environment for considerable periods of time.
BP's Oil Spill Response Planning Strategic Review acknowledged the
constraints that weather and sea conditions may place on response activities.
Both containment and recovery and in-situ controlled burning
(ISB) have many operational constraints within GAB, principally due to weather
and sea-state constraints, and are not expected to provide significant benefit.
Personnel and access to
A number of submitters questioned whether sufficient personnel would be
available for response activities in the event of an oil spill. For example,
IFAW questioned whether BP and government agencies have access to sufficient
personnel to carry out the manual cleaning of remote and sparsely-populated
coastlines in the event of oil reaching the shore.
Similarly, Mr Hansen, Sea Shepherd Australia told that committee that the
Deepwater Horizon disaster required thousands of vessels, aircraft and
personnel to conduct response activities. Mr Hansen questioned where BP would
source similar resources in the Great Australian Bight. Mr Hansen stated:
In contrast to the 20 clean-up boats highlighted by BP in the
far rougher and more remote waters of the bight, the Gulf of Mexico disaster used
6,850 vessels, 117 aircraft, 46,000 personnel and 17½ thousand National
Guard troops. If there were a spill in the bight, in far deeper, rougher
waters, where is all that infrastructure going to come to support that, and who
is going to pay for that?
The Kangaroo Island Council likewise submitted that:
In the Gulf of Mexico more than 6,500 boats were used in the
containment and cleanup phase, plus BP had access to significant resources of
the well-established oil industry operating in the adjacent shallow areas.
South Australia and its neighbouring states firstly would not have that number
of boats and secondly, based on the depth of the ocean and distance to the
drilling site there are very few vessels (at best around 20) that can operate
safely in the area.
Mr Hansen also noted that there is little support infrastructure along
the Great Australian Bight, which may hamper response activities in the event
of an oil spill. Mr Hansen stated:
There is very little support infrastructure along that coast.
It is not industrialised. So if there is a blow-out from where is all the
infrastructure going to come to relieve it? If you look at what happened in the
gulf and compare the huge arsenal of ships, aircraft and people who can do work
on it, and it still took 87 days to cap the well.
The Wilderness Society noted that BP's oil spill response document
stated that 122 people would be deployed to conduct wildlife cleaning
activities and that additional volunteers could be trained 'just in time' if
required. The Wilderness Society raised concern that 'this is the only
reference to personnel numbers in the document and there is no reference to how
much the recruitment, deployment and training of response personnel would cost
or who would pay for this'.
The Humane Society International raised concern that in the event of an
oil spill, BP would need to access critical response infrastructure that is
based in Singapore and the United States of America. It also expressed concern
regarding the estimated 149 days required to complete the relief well, and
stated that this 'would likely have catastrophic impacts on the marine
Dr Andrew Hopkins, Emeritus Professor at the Australian National
University similarly expressed concern that both of BP's key response strategies—capping
the well and drilling a relief well— will leave the Great Australian Bight
exposed to pollution for long periods of time. Dr Hopkins submitted that
exercises in the Gulf of Mexico have demonstrated that locally available
capping stacks have shown that a blowout can be capped in 15 days. This is in
contrast to BP's plan to bring a capping stack from Singapore, a measure which
is estimated to take 35 days. Dr Hopkins stated that 'in this respect, BP's
estimate of time it would take to cap a blowout is a long way short of industry
Dr Hopkins also suggested that BP's proposed mitigation strategies in
relation to drilling relief wells in the Great Australian Bight were 'well
short of industry best practice' and that BP 'should rethink its approach to
drilling relief wells.'
Dr Hopkins drew the committee's attention to regulation governing drilling in
the Arctic which required 'that a relief rig be available nearby.' Dr Hopkins
noted that when Shell proposed to drill in the Arctic, it intended on having
two drilling rigs operating simultaneously so that in the event of a blowout,
the other rig could quickly disconnect from the well and begin drilling a
Concerns with the ability of proponents to prevent an oil spill
A number of submitters also expressed concern in relation to the
conditions of the Great Australian Bight—namely the depths of its waters, and
the severe weather conditions frequently experienced there—and the impact of
these conditions on the safety of oil drilling.
Dr Robert Bea, Emeritus Professor at the University of California
Berkeley a, provided a Quantitative Risk Assessment of the Major Accident Event
Risks associated with an uncontrolled blowout in the Great Australian Bight.
Dr Bea used information from comparable international drilling operations, and
oil spill modelling provided by Mr Laurent Lebreton to The Wilderness Society.
Dr Bea concluded that the risk of an uncontrolled blowout occurring during BP's
exploratory drilling was not As Low as Reasonably Practicable (ALARP). However
Dr Bea also stated that with additional mitigation measures, the risk could be
developed to ALARP standards.
With proposed drilling to occur at water depths up to 2200 metres, and
at depths of up to 3000 metres into the seabed, the Humane Society
International described it as 'deep-water drilling at the frontier of technical
The Australia Institute noted that in comparison, the principal oil and gas
fields in the North West Shelf area occur in ranges between 125 and 131 metres.
The Wilderness Society concluded that 'oil development in the Great Australian
Bight is therefore riskier, rougher and potentially deeper than
BP's Deepwater Horizon well'.
However, oil and gas exploration companies responded to concerns and
noted that they had been undertaking activities successfully for many years.
Santos Ltd, for example, commented:
Santos has been undertaking offshore petroleum activities for
more than 30 years and, in that time, has developed an expertise in, and
safe and effective operation. The company's internal processes ensure that
proposed activities in even the most challenging of offshore settings are well
planned and carefully managed and, in the context of the Commonwealth waters of
Australia, accepted by NOPSEMA as demonstrating that impacts and risks are
reduced to ALARP.
A number of submitters expressed concern that BP would be using new
technology to drill in the Great Australian Bight. For example, the Kangaroo
Island Council submitted that:
The rig to be used in the GAB has been built specifically for
this location as no oil exploration has ever occurred in waters as deep and as
rough as the GAB. Realistically this rig is being used as a 'prototype' and the
GAB as a trial location.
The Kangaroo Island Council went on to comment on the specific
characteristics of the proposed rig:
The rig will not be anchored to the sea floor; it will only
be connected by the drill pipe and is held in position by thrusters. The
ability of these thrusters to hold the rig in position with the sea conditions
that occur in the GAB will not be tested until the drilling is actually
underway. Nor is it known what impact rig movement from wind, wave and swell
exposure has on the integrity of the drill pipe.
Lessons learnt from Deepwater Horizon
The Deepwater Horizon disaster was raised throughout the conduct of the
inquiry particularly in the context of BP's ability to both prevent, and
recover from an oil spill. Concerns included BP's risk management culture, and
whether BP had implemented recommendations from investigations of the disaster.
Concerns were also raised as to whether BP had presented an Environment Plan
that appropriately demonstrated that it had managed the risk to the Great
Australian Bight to the required As Low as Reasonably Practicable (ALARP).
Dr Hopkins submitted that BP's report on the Deepwater Horizon disaster
had only identified technical causes not the organisational causes, and that
'unless and until these are dealt with we can have no confidence in the
precautions the company proposes to take' in the Great Australian Bight.
Dr Hopkins argued that a range of organisation or cultural issues
contributed to the Deepwater Horizon incident. These included:
A lack of centralisation – BP did not exercise sufficient quality
control over the leaders of its business and sub-units. Dr Hopkins noted that
as a result, BP created a new Safety and Operational Risk (S&OR)
Function which employs staff in local business units, but who report directly
to the S&OR management in London. Dr Hopkins submitted that BP needed to
explain the role of the S&OR in its Great Australian Bight venture;
Risk indicators – Dr Hopkins submitted that at the time of the
Deepwater Horizon incident, BP was utilising incorrect risk indicators and
argued that BP needed to demonstrate that it had developed an appropriate
suite of risk indicators for risks in the Great Australian Bight; 
Risk complacency – BP's employees had become complacent with
respect to the risk of a blowout and believed that everything was under
control. Dr Hopkins submitted that one way to overcome complacency is to
'incentivise the reporting of bad news' and noted that at the time of the
disaster, BP's management had discouraged the reporting of bad news. Dr Hopkins
submitted that BP needed to demonstrate how it would encourage employees to
report bad news in the Great Australian Bight;
Incentive payment schemes – BP instituted a system whereby
employees at every level were required under their employment performance
agreements to show evidence of having reduced costs to the company. Dr Hopkins
noted that the company's official investigation into the Deepwater Horizon
incident showed that on ten separate occasions, employees had accepted a higher
risk in order to reduce drilling time and cost.
Submitters such as Dr Bea, Sea Shepherd Australia and The Wilderness
Society also noted findings by US regulators in 2016 that faulty sub-sea bolts
may have been responsible for the Deepwater Horizon disaster. Sea Shepherd
Australia raised concern that NOPSEMA's response to this issue was inadequate
while Dr Bea stated that issues associated with sub-sea bolts should be
'effectively resolved before proceeding with the proposed BP GAB drilling
BP provided the committee with evidence of its response to the Deepwater
Horizon accident. It noted that an internal investigation into the event had
made eight findings and 26 recommendations specific to drilling which BP
as implemented across its worldwide drilling activities. In addition, the
'eight key findings of the Accident Investigation Report have all been directly
addressed in preventative planning for operations in the Great Australian
These were provided in detail in BP's submission.
Navigation: Previous Page | Contents | Next Page