Oil Spill Strategy for Stanley Harbour

Operations

A01 Issued For Review Braemar/Aiuká 03/10/17 L Lindgren 06/10/17 R Lobeck 06/10/17
Rev Reason for Issue Author Date Checker Date Approver Date

This document contains proprietary information belonging to Premier Document Number Rev
Oil and must not be wholly or partially reproduced nor disclosed
without prior written permission from Premier Oil.

The master copy of this document is held electronically within FK-SL-PMO-EV-STY-0008 A01
Premier’s Document Management System. If you are using a paper
copy or a digital issue of this document, it is your responsibility to
ensure it is the latest version.
 Oil Spill Strategy for Stanley Harbour Operations
Document No: FK-SL-PMO-EV-STY-0008 REV. A01

REVISION HISTORY
Amendment Revision Amender Amendment
Date Number Initials

Stakeholders
Stakeholders will be agreed with the Approver during small group review.

Name Position Date Reviewed

Jon Boot Falkland Islands Business Unit Manager

Richard Lobeck Group Head of HSES & Technical Safety

David Hartell Senior Development Manager

Tim Martin Country Manager

Pippa Christie Deputy Country Manager

Lindsey Lindgren Senior Project Engineer - Offtake

Mike Mason Senior Environmental Manager

Sean Hayes Environmental Advisor

Dominic Murphy Drilling, Logistics and Infrastructure Manager

Related Documents

Document Number Document Name Description of

Content
FK-SL-PMO-EV-REP-0008 Environmental Impact Statement

FK-SL-PMO-EV-STY-0003 Oil Spill Strategy for Inshore Crude Oil Transfer Ops

FK-SL-PMO-EV-STY-0007 Oil Spill Strategy for Offshore Operations

FK-SL-PMO-EV-REP-0012 OSOP Report Oil Spill on Paper Workshop Report

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 Oil Spill Strategy for Stanley Harbour Operations
Document No: FK-SL-PMO-EV-STY-0008 REV. A01

TABLE OF CONTENTS

STAKEHOLDERS 2

RELATED DOCUMENTS 2

STRUCTURE OF THIS DOCUMENT 5

1 INTRODUCTION 6
1.1 Background 6

1.2 Operational use of TDF 7

1.3 Tiered Response Concept 8

2 SPILL SCENARIOS 9
2.1 Sources of Spills 9

3 FATE OF PRODUCTS IN THE MARINE ENVIRONMENT 12

3.1 Fuel Oils and Hydraulic Oils 12

3.2 Chemicals 12

4 ENVIRONMENTAL SENSITIVITIES 14

5 PREVENTION 15

6 RESPONSE OPTIONS 16
6.1 Net Environmental Benefit Analysis 16

6.2 Monitor and Evaluate 16

6.3 Containment at Source 17

6.4 Containment and Recovery at Sea 17

6.5 Shoreline Response 17

6.6 Use of Dispersants 19

6.7 Enhanced Natural Dispersion 19

6.8 Moored Booms 19

7 WILDLIFE RESPONSE 21

8 WASTE MANAGEMENT 23

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9 TACTICAL RESPONSE PLANS 24

9.1 Small Operational Spill 24

9.2 Diesel bunkering or chemical transfer at TDF 24

9.3 Vessel collision/grounding in Stanley Harbour 24

10 INCIDENT MANAGEMENT 25

11 EQUIPMENT LIST 27

12 TRAINING AND EXERCISES 28

13 REFERENCES 29

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 Oil Spill Strategy for Stanley Harbour Operations
Document No: FK-SL-PMO-EV-STY-0008 REV. A01

STRUCTURE OF THIS DOCUMENT

This document sets out the oil spill response strategy for the planned Stanley Harbour operations
for the Sea Lion project, namely at the TDF. The structure of the document is as follows:

Section Content Key Supporting Information

1 Introduction High-level account of oil spill Premier Sea Lion Phase 1 EIS
response strategy and operational
use of the TDF.
2 Spill The identified spill scenarios Premier Sea Lion Phase 1 EIS
Scenarios
3 Fate of High level description of the physical
products in and chemical changes oils and
the marine chemicals undergo once released
environment into the marine environment.
4 Environmental Sensitive environmental receptors Premier Sea Lion Phase 1 EIS
Sensitivities and potential impact.
5 Prevention High level description of prevention
measures in place to reduce the risk
of a spill occurring.
6 Oil Spill Details of the response methods IPIECA/IOGP Good Practice JIP &
Response proposed to respond to a spill at the ITOPF Guidelines
Strategy TDF.
7 Oiled Wildlife How Premier will respond to an oiled
Response wildlife response at the TDF
8 Waste A high-level description on how Premier Sea Lion Phase 1 Waste
Management Premier will manage waste following Management Strategy
a spill event.
9 Tactical High level description of possible
Response tactical response plans
Plans
10 Incident High level account of Premier’s Emergency Planning Standard and
Management incident and crisis management Crisis Management Procedure
procedures.
11 Equipment A description of spill response
List equipment that will be available to
respond to a spill at the TDF.
12 Training and A high-level description on the
Exercising training and exercising of TDF
response teams.

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1 INTRODUCTION

1.1 Background
This document has been developed to identify the spills scenarios, mitigation measures, and oil spill
response strategies associated with Premier Oil’s (Premier) use of the Temporary Docking Facility
(TDF), located in Stanley Harbour Figure 1.1

Figure 1.1 Temporary Docking Facility Location

The Temporary Dock Facility (TDF) was installed in Stanley Harbour to support exploration drilling
operations undertaken in 2015 by Premier and Noble Energy Falklands Limited (Noble).
The identified spill scenarios and response measures for the TDF were documented in the
Temporary Dock Facility Oil Spill Response Plan, FK-SL-PMO-EV-PLN-0002 (Premier, 2014).
In line with industry good practice, oil spill response plans should be regularly reviewed and adapted
when operations and associated risks change. Premier is currently applying to FIG to extend the
operational life of the TDF for use on the Sea Lion project with future modifications to improve the
Dock’s functionality being discussed.
This document is intended to inform the future operational oil spill contingency plan (OSCP) to
support the future intended use of the TDF for the Sea Lion project.
The Stanley Harbour OSCP will be compatible with the Falkland Islands National Oil Spill
Contingency Plan (NOSCP) and relevant regulatory legislation. This document:
- Describes the intended use of the TDF;
- Identifies credible accidental spill scenarios;
- Identifies Oil Spill Response Resource and Capability, and
- Outlines Oil Spill Response Strategies.

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1.2 Operational use of TDF

The primary use of the TDF is to act as a quayside for a range of differing vessels throughout the
duration of the Sea Lion project (Table 1.1). The facility will support a variety of operations including
loading, offloading, vessel crew changes, bunkering (refuelling), and re-supply of chemicals and
consumables for the mobile offshore drilling unit (MODU) and the floating production, storage and
offloading facility (FPSO) located at the Sea Lion Field.
Coaster Supply Vessels (CSVs) will utilise the TDF to offload plant, chemicals and materials required
for the offshore operations throughout the duration of the project.
The indicative Sea Lion project timeline is identified in Table 1.1 and a brief description of the
operational use of the TDF throughout each phase of the project is provided in Sections 1.2.
Table 1.1 Envisaged Project Timeline
Year 8 – Year
Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Year 24
24 -2041
Q1

Q2

Q3

Q4

Q1

Q2

Q3

Q4

Q1

Q2

Q3

Q4

Q1

Q2

Q3

Q4

Q1

Q2

Q3

Q4

Q1

Q2

Q3

Q4

Q1

Q2

Q3

Q4

Q1

Q2

Q3

Q4

Q1

Q2

Q3

Q4
Stage 1: Mobilisation of materials and equipment, drilling
(commencing Q3 2018) / well construction installation of
subsea facilities commences immediately post sanction,
HUC a of the FPSO and ‘first-oil’

Stage 2: Post first-oil drilling, and concurrent

production operations and oil export c.3 years post
sanction

Stage 3:
Production
operations and oil
export

Stage 4: Decom b

1.2.1 Drilling Phase

Throughout the drilling phase of the Sea Lion project, the TDF will act as a quayside for two Anchor
Handling Tugs (AHTs) which will support the MODU. These vessels will call into the TDF as part of
their resupply duties for the MODU.
During the drilling phase, there will be an Emergency Response and Rescue Vessel (ERRV) located
in the Sea Lion Field. The ERRV will be located in the field most of the time; however, it may utilise
the TDF during crew changes, for unforeseen vessel maintenance and during an emergency
response.

1.2.2 Simultaneous Operations Phase

Simultaneous operations entail continued drilling by the MODU and initial production from the FPSO.
During the simultaneous operations phase, the TDF will continue being utilised by the two AHTs
supporting the MODU, by vessels supporting offshore production two Multi Role Support Vessels
(MRSV) and those supporting inshore transfer operations in Berkeley Sound, which includes, an
Inshore Support Vessel (ISV), a dedicated oil spill response vessel (DOSRV), two waste storage
barges (est. 25m in length), and one work boat.
The ISV, two storage barges and work boat will be moored at or in the vicinity of the TDF when not
undertaking inshore transfer operations. The inshore transfer process is expected to last for 24 - 48
hours and is expected to occur once every 13 days at peak production, reducing to once every 46
days after about 10 years of operation.

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One MRSV will be utilised as an ERRV in the field and the other will be used to transfer supplies to
the FPSO from Stanley and assist in inshore transfer operations.

1.2.3 Production Only Phase

Throughout the production phase, the TDF will be utilised by vessels required to support the FPSO
and Inshore Transfer operations as described in the Section above, i.e. two Multi Role Support
Vessels (MRSV), an Inshore Support Vessel (ISV), a dedicated oil spill response vessel (DOSRV),
two waste storage barges (est. 25m in length), and one work boat.

1.3 Tiered Response Concept

Premier’s preparedness and response capability to an accidental oil spill at the TDF will be in-line
with the tiered response framework according to the IPIECA/IMO international standard model of
‘Tiered Preparedness and Response’ so that there is sufficient preparedness and response
capability to commensurate the risk to the environmental and socioeconomic receptors.
Tier 1: - A spill that will be mitigated by using local TDF response resources held by Premier. Readily
accessible fish totes containing a range of chemical and oil spill absorbents, to mitigate the risk of
impact of day to day operational spills.
Tier 2: - A spill requiring support and resources of other local Premier resources in Stanley. Larger
spill response equipment including an oil spill recovery device, inshore fence boom, trained response
teams for oil recovery and oiled wildlife, and temporary waste storage, to mitigate the risk of larger
oil spills such as bunkering spills. If available, additional Tier 2 resources, personnel and equipment,
can be obtained from the offshore support vessels. The NOSCP will be activated providing support
and response resources from the Falklands Island Government if required.
Tier 3: - A spill requiring international resources in either oil spill or oiled wildlife response.

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2 SPILL SCENARIOS

Given the known activities occurring at the TDF during the exploration phase, a spill scenario
identification exercise was conducted in 2014 by Premier to identify the credible emergency
scenarios that could result in an oil or chemical spill. These scenarios have been identified below
and will be included in the Stanley Harbour Oil Spill Contingency Plan.

2.1 Sources of Spills

The potential sources of chemical and oil spills at the TDF during the Sea Lion project include:
 Dock machinery, equipment and storage facilities that utilise or store fluid products such as:
o Cranes
o Forklifts
o Ballast Pumps
o Diesel Generator
o Oil Storage tanks and supply pipelines
o Heavy goods vehicles and cars
 Chemical transfer from the TDF to support vessels
 Bunkering systems for fuel and oil based mud (OBM) , including pipe network when operational
 Vessels on the approach to the port facilities

2.1.1 Scenario 1: Day to Day Operations

Small scale spills and leaks may occur through the presence of stored fluids or the use of the
equipment listed above, specifically:
 Fuel oils,
 Hydraulic oils
 Oily bilges from machinery spaces
 Oil fouled waster from ballast tanks
 Leaks from propeller shaft or lubricating oils from various moving parts such as hydraulic
rams and deck moving/lifting mechanisms.
As stated in the EIS, leaks most commonly occur due to the incorrect maintenance or neglect of
maintenance schedules. These small leaks, when spilt on the ground, can be easily contained.
However, if spilt close to the water’s edge, or a large volume is spilt, the spilt product may enter the
water and spread quickly. The spreading oil will form a sheen on the water surface and pose a risk
to environmental receptors.

2.1.2 Scenario 2: Diesel Bunkering Operations

Diesel bunkering will be conducted at the TDF. As such, there is a risk that during bunkering
operations marine diesel could be spilled to sea, either due to equipment failure or malfunction
(dry break valve failure, perishing of hoses, failure of level gauge, level alarms tank failure) or

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operator error (poor bulk hose storage, neglect of hose inspections, neglect of following
operational procedures).
During bunkering at the TDF, flexible hoses will be connected to the receiving vessel with a dry
break connection. Vessels will follow Premier TDF bunkering procedures which will ensure all
preventative measures, warning alarms, manning levels and emergency stop systems are
inaugurated before operations commence.
In this scenario, it is anticipated that the maximum spill volume would be one tonne. This is
considered the worst-case scenario as dry-break couplings are being used on the hoses. This
scenario would only occur if automated emergency shut down valves failed and the quayside
watchmen monitoring the operation are unaware of the incident and pumps remain on for a period
before being shut off.

2.1.3 Scenario 3 Chemical Transfer Operations

Vessels will be loading and offloading several different chemicals that will be used in the drilling and
production operations.
Most of the chemicals required for drilling are dry ‘bulk’ chemicals used in the make-up of water-based
drilling mud and oil based muds.
Other chemicals that will be transferred at the TDF might include: cementing chemicals, rig cleaning
chemicals, and pipe dope. During the transfer of chemicals to and from the TDF there is a potential risk
that the chemicals could be spilled onto the sea. The worst-case scenario for chemicals being released
to sea at the TDF during the drilling phase would be the loss of an entire batch of cementing chemical.
Liquid chemicals will be transported in various sizes of sealed bags, drums, IBCs and tote tanks. As
such a loss of a sealed load during a transfer would not immediately result in a loss of chemical to sea;
the container would have to be breached in some way during the incident for this to occur.
OBM will be transferred to loading vessels in a similar process as bunkering. This creates a risk that
during loading operations oil based muds could be spilled to the sea, either due to equipment
malfunction or operator error. Premier will develop a Premier Loading Procedure which will ensure
preventative measures like the bunkering procedures will be inaugurated before operations commence.
Details on the specific chemicals which will be used during the production phase are not yet known.
However, it is known that two main chemical function groups, wax inhibitor and methanol are required
in significant volumes. These bulk chemicals will be transported from their place of manufacture to the
Falklands in 24,000 litre (20’) ISO frame tanks. The worst-case scenarios which could lead to the loss
of the content of an ISO frame tank include accidents when lifting the ISO tanks from the vessel to a
vehicle on the TDF and when pumping the ISO tank contents to a MRSV from the TDF.
There were two reported chemical spill incidents at the onshore supply base during the 2015 exploration
campaign. Neither incident resulted in a significant release of chemicals or any reported environmental
damage. Both incidents are described in detail in the EIS document. There were no spills to sea
reported from the TDF.

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2.1.4 Scenario 4 Vessel Collision or Grounding

The increase in vessels utilising Stanley Harbour during the project increases the potential risk of
vessel collision. However, by international standards, the Harbour is not regarded as a busy port
and collisions and groundings should be readily avoidable by following standard navigational
procedures (e.g. ColRegs).
Assuming a worst-case scenario, a fully laden supply vessel would contain approximately 800 m3
of diesel fuel. This would be distributed between numerous individual tanks on the vessel and
therefore it is extremely unlikely that all of this could be lost in a single event. A more credible
worst-case scenario is the loss of fuel from two fuel tanks, which is predicted to be around 320 m3
based on a typical MRSV. Nevertheless, a breach of a fuel tank could result in a sizeable spill in
sheltered inshore waters where dispersal by wind and waves would be limited.

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3 FATE OF PRODUCTS IN THE MARINE ENVIRONMENT

This section of the document describes the fate and effects of the products identified as a potential
spill risk in the ENVIID and EIS.

3.1 Fuel Oils and Hydraulic Oils

As oil is released into the marine environment, it undergoes several physical and chemical changes
which are dependent on the type and quantities of oil spilled and the prevailing meteorological and
oceanic conditions to which the oil is exposed to over time.
Marine gas oil (MGO) and plant equipment diesel contains a high percentage of low molecular weight
hydrocarbon compounds and tends to spread on the water surface to form a visible sheen. Small
MGO and plant diesel spills can affect marine birds due to ingestion during preening as well as by
hypothermia from matted feathers. As MGO readily dissolves into the water column, this impact can
be relatively small due to the limited exposure time.
Hydraulic oil, a heavier oil, behaves differently as some fractions will submerge to the seafloor and
remain there. When initially introduced to the marine environment they will spread to form a sheen
and are susceptible to sedimentation.

3.2 Chemicals
When chemicals are spilt, they behave in several different ways. It is important to understand this
behaviour, not only so that human health and safety implications are recognised but also to decide
on the most effective response.
A substance behaves in one or more of five ways when spilt:
- Dissolve
- Evaporate
- Float
- Gasify
- Sink
Chemicals that float will spread under the effect of gravity to form a slick in a similar way to oil.
Depending on the volume of the chemical spilt, it may be possible to deploy chemical absorbent
containment boom to contain and control the movement of substances and then undertake physical
recovery of the chemical.
A dissolving chemical will form a growing ‘plume’ of decreasing concentration in the water and
eventually dilute. It is important to monitor the concentration of the spilt chemical in the water to track
the movement of the chemical and therefore predict any hazard that may arise to the environment,
fisheries, fresh water intakes, recreational areas, etc.
The ability to contain and recover dissolved chemicals is extremely limited. Providing means to
accelerate the natural processes of dispersion and dilution may be the only way to respond to such
chemical spills.
Chemicals that sink have the potential to contaminate the seabed and sometimes to persist in the
sediment. Therefore, the response to any chemicals that sinks to the seabed may need to consider
the recovery of the chemical and any heavily contaminated sediment. In shallow waters, mechanical

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dredgers and pump/vacuum devices may be used to recover chemicals on the seabed.
Submersibles and remotely controlled underwater cameras may be used to identify and recover
chemicals on the seabed.

The behaviour of a methanol spill would be like that of a diesel spill (i.e. relatively rapid evaporation);
however, as methanol is soluble in water it would disperse more rapidly to non-toxic levels (<1 %),
dependent on water mixing due to tide or wind and would eventually biodegrade. Although
biodegradation of a large spill in enclosed waters could lead to localised deoxygenation of surface
waters.

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4 ENVIRONMENTAL SENSITIVITIES

The EIS details the key environmental sensitivities in Stanley Harbour including those potentially
impacted by a spills at the TDF. These include:
 Birds, including shoreline species and those rafting in harbour waters;
 Fish species in the harbour, particularly juveniles and larvae as they lack the ability to actively
move away from contaminated areas;
 Marine mammals, as they would have less opportunity to move away from a spill due to the
confined nature of the harbour and have been seen in the kelp beds, near the harbour
shoreline.
There are two onshore conservation sites near the TDF: Stanley Common and Cape Pembroke.
Additionally, enclosed areas of water, such as the Canache, can be considered as areas of key
sensitivity, as these natural harbours tend to retain a spill and have a lesser capacity to naturally
disperse the oil.
A summary of impacts to wildlife at risk to an oil spill at the TDF are shown in Table 4.1. A detailed
account of the oiled wildlife response measures are in Section 7.
Table 4.1 Summary of Impacts to Wildlife at Risk from an Oil Spill at the TDF

Class Summary of impact

Birds using the water-air interface are at risk, including divers and penguins, and
penguins are at risk in their use of contaminated shorelines. Badly oiled birds usually die,
and many cleaned birds also die within one season. The thermal and waterproofing
properties of feathers are lost in contact with oil, and oil is preened off and digested, with
Birds
toxic effects. Recovery of populations depends either on the existence of a reservoir of
young non-breeding adults from which breeding colonies can be replenished or a high
reproductive rate. There is little evidence that an oil spill can permanently damage
overall seabird populations, but species with very local distributions could be at risk.

Oil is unlikely to significantly affect adult fish populations in the open sea. Even when
many larvae have been killed, this has not been subsequently detected in adult
Fish
populations, possibly because the survivors had a competitive advantage. Wild adult fish
may be made unmarketable because of tainting.

It is rare for whales, dolphins, seals and sea lions to be affected following a spill. Fur
Mammals
seals may be more vulnerable due to their fur structure.

Invertebrates include shellfish (both molluscs and crustaceans), worms of various kinds,
sea urchins and corals. All these groups may suffer heavy casualties if coated with fresh
Invertebrates
crude oil. In contrast, it is quite common to see barnacles, winkles and limpets living on
rocks in the presence of residual weathered oil.

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5 PREVENTION

The industry standard mitigation measures used by Premier to prevent and mitigate against leaks
and spills for the scenarios described in Section 2 are listed below.
Day to day Operations
 Use of management maintenance systems (MMS) to ensure all equipment remains in good
working order and fit for purpose;
 Use of standard operating procedures, based on job safety analysis and building upon
lessons learned during the exploration drilling campaigns;
 Task specific planning, toolbox talks, risk assessments and pre-use checks;
 Liquids will not be permanently stored on the TDF but in adequately bunded storage areas
at the Premier yard;

Diesel Bunkering
 Bunkering procedures will be developed for the operation;
 Bunkering operations will be monitored throughout by trained personnel under PMO
supervision;
 Communication procedure for the operation, including emergency stop;
 Bunkering operations will be undertaken during daylight hours whenever possible;
 Dry-break coupling will be used on hoses during bunkering at the TDF.

Chemical Transfer
 Loading and offloading procedures will be developed;
 Personnel will be trained in lifting and securing equipment to UK LOLER standards;
 All loads will be subject to a specific risk assessment

Vessel Collision/Grounding
 TDF Harbour Management Plan will be in place;
 Stanley Harbour Authority Management Plan;
 AIS and ship navigation kit on board all vessels;
 Pre-notification protocols associated with the entry of vessels into Stanley Harbour during
operation;
 Marine night-time lighting requirements;
 VHF Radio communication protocols;
 Lighting of the TDF structure at night.

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6 RESPONSE OPTIONS

Premier’s overarching response philosophy is prioritised by:

- People
- Environment
- Assets
- Reputation
Premier will have in place interfacing emergency response plans, such as Premier Emergency
Response Plan (ERP), Stanley Harbour Oil Spill Contingency Plan, and use of Hazardous Chemical
Management Plan (HCMP).
The primary and continual response strategy to any spill is to monitor and evaluate which allows
response teams to develop the most appropriate response strategy and share information with
incident management teams and stakeholders.
The differing response options and strategies available for different products, based on spill situation
observations, are discussed throughout this section of the document.

6.1 Net Environmental Benefit Analysis

The primary objective of an oil spill response is to safely undertake actions to reduce the risk to
environmental and socioeconomic receptors. When determining the most environmental beneficial
response option, the advantages and disadvantages of differing response strategies need to be
compared with the potential for natural recovery. The process of choosing the optimum response
strategy to reduce the overall consequences of an accidental spill is called Net Environmental Benefit
Analysis (NEBA).
NEBA is a fundamental principle in planning for and responding to oil spills taking into account the
circumstances of a spill, the practicality of response options, receptors at risk and the relative impact
of the oil spill and clean-up options.
Before deploying response options, especially for Tier 2-3, the Incident Management Team will
undertake a NEBA assessment to ensure the risk to the environment from any response is as low
as reasonable practical (ALARP).

6.2 Monitor and Evaluate

Monitor and evaluate is the primary response strategy to all spills of any size. It is fundamental in
assessing the situation in terms of determining the source of the spill, estimating the volume spilled,
the location of the spill, and the environmental and socioeconomic receptors at risk.
The process of monitoring and evaluating should be undertaken throughout the duration of a spill
response with observers having available a range of resources and techniques to plot spill
trajectories and estimate the volume of oil on the surface of the water.
The Stanley Harbour OSCP will contain detailed instructions on how to effectively review aerial
photographs, tabulate information gained and calculate spill trajectories. The information will allow
the Incident Management Team to conduct a NEBA assessment, prioritise response strategies,
effectively command assets and prepare incident action plans.

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6.3 Containment at Source

Containment at source is a strategy which is crucial in mitigating the overall impact of an oil spill as
it reduces the degree of oiling and contains the oil in one location. For small localised day to day
operational oil spills on the surface of the TDF, this could be completed by stopping the spill, if safe
to do so, and placing absorbents on the spilt liquid. In some cases, a barrier to prevent the spread
of oil could be created from sand or absorbents.
For larger spills on water, either absorbent or fence boom, dependant on the size of the spill, can be
placed around the release. The effectiveness of this strategy is dependent on the time between the
incident occurring and initial notification and corresponding response times. Care must be taken on
deciding where to locate the boom as it may in some instances create a fire hazard, interfere with
attempts to stem the release, or interfere with salvage of a vessel.

6.4 Containment and Recovery at Sea

Containment and recovery at sea can be considered one of the most ideal response strategies as it
aims to physically remove oil from the marine environment. The response tactics/actions require the
deployment of floating containment booms and specialised skimmers, as recovery devices, to corral
and recover oil.
It must be noted there are significant constraints and limitations of the effectiveness of this strategy
in open waters due to the nature of spilled oil, encounter rate, and ability to operate safely and
effectively in rougher sea conditions.
This response strategy would be deployed for Tier 2 – 3 incidents dependant on risk to environmental
receptors, such as bird colonies, as it could prove beneficial in preventing interaction of oil with birds.
Equipment required for the deployment of this response tactic at the TDF is listed in Table 11.1.

6.5 Shoreline Response

In the event that the shoreline will be impacted by an oil spill where possible, oil will be removed
from contaminated shorelines as quickly as possible. As time passes and the oil weathers, it may
become mixed or buried in sediments.
There are three stages of shoreline clean up:
Stage 1 - bulk oil is removed from the shore to prevent remobilisation.
Stage 2 - removal of stranded oil and oiled shoreline material - often the most protracted
part of shoreline clean-up; and
Stage 3 - final clean-up of light contamination and removal of stains, if required.
The methods that would be used for different shoreline types are shown in Table 6.1 (per ITOPF
guidance).
Shoreline clean-up involves assessing the shoreline and appropriate techniques, followed by
cleaning as appropriate. Effective methods are described in IPIECA/IOGP, A guide to oiled shoreline
assessment (SCAT) surveys (2014) and ITOPF, Technical Information Paper 07 Clean-up of oil from
shorelines (2011).
As part of an oil spill response strategy, Shoreline Clean-up Assessment Technique (SCAT) teams
will systematically survey the area affected by the spill to provide rapid accurate geo-referenced

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documentation of shoreline oiling conditions. These teams will consist of either trained and
competent Premier personnel or personnel from an international response provider.
The primary objectives of an oiled shoreline assessment programme are to:
 define the location, extent and character of the oiling;
 develop shoreline treatment recommendations;
 support operations during the treatment program; and
 provide closure once the shoreline treatment objectives have been met.
Table 6.1 Shoreline Clean-Up Methods

Stage Shoreline Accessible shoreline Inaccessible shoreline

Type
Stage 1 Rock/boulders Skimmers/pumps; vacuum trucks; flushing Manual removal;
manual removal using
sorbents

Cobbles Skimmers/pumps; vacuum trucks; flushing Manual removal;

manual removal using
sorbents

Sand beaches Skimmers/pumps; vacuum trucks; Manual removal;

manual/mechanical removal; trenching; flushing manual removal using
sorbents

Stage 2 Rock/boulders Pressure washing; sorbent materials; natural Natural cleaning; hand
cleaning wiping

Cobbles Flushing; surf/cobble washing; mechanical; Natural cleaning; hand

natural cleaning wiping

Sand beaches Flushing; surf washing; manual/mechanical Natural cleaning;

manual

Stage 3 Rock/boulders Natural cleaning; pressure washing Natural cleaning

Cobbles Natural cleaning; surf/cobble washing Natural cleaning

Sand beaches Natural cleaning; surf washing; ploughing and Natural cleaning
harrowing; beach cleaning machines; sand
sieving

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6.6 Use of Dispersants

The purpose of dispersants is to transfer oil from the water surface into the water column and to
reduce droplet size and promote dissolution and breakdown, often to minimise the potential impact
to birds and to minimise the presence of oil films at the shoreline that can coat organisms.
The dispersants themselves have an element of toxicity, although they may be restricted to approved
lists such as the Marine Management Organisation (MMO) approved list in the UK whereby marine
and coastal toxicity tests are undertaken.
Due to the potentially toxic nature of the dispersants and requirement for prior approval before
application within 1 nautical mile of waters of 20 metre depth or less (UK Guidance), dispersant
application for oil spills in Stanley Harbour is not considered a viable response strategy.

6.7 Enhanced Natural Dispersion

Enhanced natural dispersion is a response strategy where the bow wave, propeller, or firefighting
systems of a response vessel are utilised to break up the oil into smaller fragments. The smaller
fragments are more susceptible to the effects of natural weathering and therefore reduce their visible
presence in the environment.
This strategy is generally utilised on light refined hydrocarbons and would not be a valid response
to heavier fuel oils. This strategy would only be viable and effective for small volumes of hydrocarbon
represented by silver and iridescent sheens on the water surface.
Before deploying this strategy, a NEBA should be conducted, considering all environmental and
socioeconomic receptors.

6.8 Moored Booms

In some circumstances, it might be appropriate to anchor booms to deflect oil from sensitive
receptors, around sources of pollution, or contain the pollutant close to the source.
The effectiveness of moored boom is dependent on the currents the boom is exposed to and the
method in which it is deployed, as the performance is dependent upon the angle of deflection Figure
6.1. Before deploying the boom, careful planning should be undertaken to address if the boom can
be deployed effectively and to prioritise sensitive receptors to be protected. Anchored boom mooring
can be undertaken utilising a small boat, Stevedore, anchors, tripping buoys and lengths of fence
boom. In many cases, when anchoring boom from a fixed structure, running moorings are required
to allow for the boom to fluctuate with tidal changes.

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Figure 6.1 The Effects of Current on Moored Booming Strategy

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7 WILDLIFE RESPONSE

Oiled wildlife response is an integral element of Premier’s oil spill response strategy and critical in
minimising the overall consequences of an oil spill event to environmental and socioeconomic
receptors. Early notification and mobilisation will allow real-time wildlife threats to be assessed so
that possibilities for prevention of wildlife oiling can be maximised.
To mitigate the overall impacts of an oil spill to the wildlife, Premier Oil will have in place adequate
sufficient materials to sustain a response for the first 96 hours, one on duty Premier Oiled Wildlife
Specialist and 15 trained resident wildlife responders.
Surveys are extremely important to calibrate the wildlife response. Using the data collected from the
field team reports, it is possible to confirm and verify baseline information, determine the number of
wildlife affected or potentially affected, identify priority species and habitats, monitor the impacts of
the oil spill on wildlife over time. Survey and monitoring activities will continue for the duration of
active wildlife response operations and post-release of rehabilitated animals.
Based on information obtained from the surveillance reports, a decision will be made to notify the
trained oiled wildlife responders and potential international resources. The oiled wildlife specialist
will brief locally trained wildlife responders at the wildlife facility. During the first day of response, the
team will be utilised to mobilise the rehabilitation facility.
The timely mobilisation of proper equipment and a facility for oiled wildlife response is key to ensure
that the narrow ‘window of opportunity’ for a successful response is utilised most effectively. The
ability to have an expandable oiled wildlife response facility will simplify planning at the time of a
response. The Premier’s wildlife response facility will be ready for Tier 1 and Tier 2 response and
will consider adjacent space for a secondary expansion plan.
Besides the initial procedures of surveying and monitoring, the response activities will include the
protection of nesting/haul-out sites, hazing and deterrence (scaring animals away from oil), pre-
emptive capture of un-oiled animals if feasible and for species of high conservation value, collection
and analysis of corpses, euthanasia and/or rehabilitation of live oiled animals.
Successful rehabilitation of oiled animals is dependent on available expertise. Premier will utilise
their nominated international oiled wildlife response organisation to deploy personnel and to apply
pre-defined and well proven protocols and principles in the handling and care while ensuring that the
response is well resourced and managed both in the field at emergency mobile stabilisation stations
and at the treatment and rehabilitation facilities.
The oiled wildlife response team will have access to the wildlife rehabilitation facility and mobile
wildlife emergency packages that will be permanently available and maintained in Stanley, which will
include initial resources for temporary shelter and personal safety, communications, initial
stabilisation and husbandry, medical equipment, cages and general support equipment. A specific
oiled wildlife response equipment list will have at the very minimum, the items listed below:
• 1x Oiled wildlife rehabilitation facility/ warehouse
• 1 x Survey, search and rescue package
• 1 x Hazing/ deterrence package
• 1 x Wildlife medical package
• 1 x Cleaning and rehabilitation package
• 1 x PPE package

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Throughout the Sea Lion Project Premier will be a member of an organisation which provides
international oiled wildlife response support. The organisation will be activated at the request of the
Premier Incident Commander. The mobilisation times for international responders to arrive in the
Falkland Islands with additional oiled wildlife response equipment and personnel is approximately
96 hours.

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8 WASTE MANAGEMENT

Premier will manage waste generated from an oil spill in a safe and environmentally responsible way
in accordance with Premier’s corporate environmental standards..
An initial detailed account of how PMO intends to manage waste arising from an oil spill can be
found in Appendix 3 of Sea Lion Phase 1 Waste Management Strategy, FK-SL-PMO-EV-STY-0005
(Premier 2017c) which is briefly described below.
In the event of a spill at the TDF, all liquid waste will be contained in temporary fast deployment
tanks and potentially transferred to both drums (205l) and intermediate bulk container’s (IBCs) (1000
litres). Solid contaminated wastes, debris and spent sorbents, will be double bagged in heavy duty
hazardous waste bags, cable tied and labelled then stored in a temporary bund constructed using
impermeable membrane. Waste from the TDF will be initially stored at the laydown yard, where it
will be appropriately segregated and consigned. Depending on the volumes of waste, an interim
waste management plan will be put in place to ensure all wastes are dealt with in an appropriate
manner.
In the highly unlikely event that a substantial accidental spill of oil occurs, a 1,000-tonne temporary
waste floating storage bladder, shown in Figure 8.1, will be used to store recovered oil at the TDF.
It is envisaged that the bladder will be anchored off the TDF with risk mitigation measures, such as
containment booming, in place during loading and offloading recovered oil.

Figure 8.1 A 1,000 Tonne Temporary Waste Storage Bladder

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9 TACTICAL RESPONSE PLANS

The size, location and nature of any spill will determine which response equipment is mobilised. For
the most credible spill scenarios, a typical tactical response plan is outlined below.

9.1 Small Operational Spill

The most probable action in the event of a small operational chemical or oil spill on the ground would
be to contain the spill with absorbent boom or a sand barrier to prevent oil from spreading. The spill
can then be recovered using absorbent pads. If staining is present, further cleaning can be
undertaken with a pressure washer.

9.2 Diesel bunkering or chemical transfer at TDF

The most probable action in the event of a diesel spill or chemical spill at TDF would be to deploy a
fence boom attached to a running mooring on to the TDF and held in place by the small boat. The
angle and position of the boom would be dependent on the location of the spill, prevailing winds, and
the tide. The boom would aim to contain the spill and prevent it from spreading. It would also allow
appropriate sorbents and / or the skimmer to be used to absorb / recover the pollutant corralled
within the boom.

9.3 Vessel collision/grounding in Stanley Harbour

A collision or grounding of a vessel could occur anywhere within Stanley Harbour. As such a fence
or inflatable boom would most likely be deployed, either from the TDF or FIPASS. It may also be
moved around the coast and deployed from the shoreline to provide the maximum containment of
the spill and/or in a remote protective capacity to prevent oil migrating onto / into areas of key
sensitivity, e.g. the Canache.
Before boom is deployed a NEBA would be undertaken to predetermine the effectiveness of the
strategy as it is dependent on several environmental limitations. Often when wave height is above 2
-3 m it could be beneficial to allow the high-energy wave action to assist in breaking up the spill
whilst monitoring closely.

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10 INCIDENT MANAGEMENT

A detailed management structure with roles and responsibilities will be defined in the TDF Oil Spill
Contingency Plan. These will be prepared in-line with Premier corporate requirements detailed in
Crisis and Emergency Planning Standard CP-BA-PMO-HS-ZZ-ST-0007 (Premier 2017a) and Crisis
Management Procedure CP-BA-PMO-HS-ZZ-PR-0002 (Premier 2017c).
The principal actions of the command team are:
• To ensure primacy for the overall incident response will be taken by Premier’s Emergency
Response Team;
• Work within the framework of the Falkland Islands NOSCP; the FI authorities (via the Harbour
Master) will be party to the oil spill response management and have the right to step in;
• Work in close liaison with the Harbour Master throughout any response;
• Vessel Masters retain primacy for the safety of their vessels;
• Vessels that are not under Premier control are legally responsible for pollution from their
vessels; and
• Apply its spill response resources to spills from a third-party vessel
A member of the Premier Oil Incident Management Team in the Falklands will be trained and
exercised as the Oil Wildlife Specialist. This person will have the responsibility of activating the oiled
wildlife plan, notifying the local oiled wildlife response team, guiding the incident management team
in terms of wildlife receptors, and overseeing the construction of the rehabilitation centre.
The Premier command structure is shown in Figure 10.1.

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Figure 10.1 Management structure for incident response

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11 EQUIPMENT LIST

This section of the document identifies the equipment which will be readily available and stored at
the TDF and warehouse facility in Stanley. The response equipment is to be deployed by personnel
adequately trained and competent in spill response. The equipment listed in Table 11.1 is for the
identified spill risk at the TDF. If available, additional equipment and personnel can be obtained from
the support vessels, which are equipped with equipment to mitigate the risks of an offshore oil spill.
Table 11.1 TDF Oil Spill Response Equipment
Qty Item Description
Tier 1 Equipment: Located on/at TDF to mitigate risks associated with small operational spills.

1 Chemical Sorbent Spill Kits
(stored in wheeled totes)
1 Oil sorbent spill kit (stored in
wheeled totes)
1 Sealed Plastic Fish Tote with
spare hand tools, basic PPE
Tier 2 Equipment located in warehouse on response trailers.
Chemical sorbent boom, chemical sorbent pads, waste bags,
cable ties, marker pens, labels, impermeable ground sheet, and
sand. To recover or contain localised chemical spills.
Oil sorbent boom, Oil sorbent pads, waste bags, cable ties,
marker pens, labels, impermeable ground sheet, sand. To be
applied to small spill to either recover or contain oil. Can also be
utilised in conjunction with Tier 2 response equipment.
Shovels, rakes, signage, waste bags and PPE.

150m Inshore Boom with ancillaries Inshore fence boom, for rapid deployment around source of
pollutant to contain spill, or corral oil to a localised area to recover
oil with either absorbents or oil recovery device. Includes ropes
and anchors to deploy effectively – Running mooring from TDF.
1 Oil Skimmer with power pack Oleophilic or weir skimmer capable of recovering light to med oils.
and ancillaries
2 Fast Deployment Waste Fast deployment waste tanks will be utilised as the primary
Storage tanks storage for recovered liquids from the oil skimmer. If necessary
one can be utilised for liquid wastes and the other for oil/chemical
contaminated wastes.
7 Fish Totes with oil spill Oil sorbent boom, Oil sorbent pads, waste bags, cable ties,
response sorbents marker pens, labels, impermeable ground sheet, sand, eliminator.
To be applied to small spill to either recover or contain oil. Can
also be utilised in conjunction with tier 2 response equipment.
1 Steam Generator To clean oil contaminated surfaces.
2 Trailers For the storage and transport of OSR Equipment
1 Small boat with outboard To deploy boom (both fence boom and absorbents) and potential
relocate skimmer to areas where oil have corralled.
20 205l Drums For both liquid and solid waste
10 IBC’s For both liquid and solid waste
Additional Resources in Stanley

N.A Vessels Adhoc vessel support provided by contractors.

N.A FIPASS OSR Equipment Mobilised by FIG if required.

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12 TRAINING AND EXERCISES

Training will be provided to all Premier and contractor personnel that are involved in bunkering
operations and that would be required to act in the event of a spill at the TDF, whether directly
employed by Premier or not. It is expected that there will be five stevedore personnel working on the
TDF when it is operational, all of which will be trained in spill counter measures. Training
requirements are shown in Table 12.1.
In addition to the training requirements identified below, 15 Falkland Islands residents will be trained
in oiled wildlife spill response.
Table 12.1 Training requirements for personnel

Personnel Bunkering Spill response IMO Hazardous Spill Response

procedures training (IMO Noxious Substances Management
training 1/MCA 3P) Level 1: Operational (IMO 2/MCA 4p)
First Responders

Premier Stanley
X X
Personnel

Personnel involved in
X X
bunkering operations

Small Boat Operators X

Stevedores X X X

To ensure training is effective, there will be regular exercises to test the Stanley Harbour OSCP.
Exercises will commence when the TDF is operational and will be included as part of the regular
emergency response training schedule.
Practical deployment exercises are expected to take place every 6 months, notification exercise
every month and table top incident management with practical deployment exercise every 3 years.
Additionally, when the spill response equipment has arrived in the country, training will be given to
those who will be deploying the equipment, and several exercises will take place to demonstrate that
the equipment can be effectively deployed.

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13 REFERENCES

Premier (2014) Temporary Docking Facility Oil Spill Response Plan FK-SL-PMO-EV-PLN-0002
Premier (2016a) Sea Lion Development - Phase 1 Environmental Impact Statement FK-SL-PMO-
EV-REP-0008.
Premier (2017a) Crisis and Emergency Planning Standard CP-BA-PMO-HS-ZZ-ST-0007
Premier (2017b) Crisis Management Procedure CP-BA-PMO-HS-ZZ-PR-0002.
Premier (2017c) Sea Lion Phase 1 Waste Management Strategy, FK-SL-PMO-EV-STY-0005 Rev
B01 document.
IPIECA/IOGP (2013) Oil spill risk assessment and response planning for offshore installations.
IPIECA/IOGP (2014) Oil spill waste minimization and management Good practice guidelines for
incident management and emergency response personnel.
IPIECA/IOGP (2015) Response strategy development using net environmental benefit analysis
(NEBA). Good practice guidelines for incident management and emergency response personnel.
IPIECA/IOGP (2015) Tiered preparedness and response.
ITOPF (2012) Response to Marine Chemical Incidents
IPIECA/IOGP (2014) A guide to oiled shoreline assessment (SCAT) surveys
ITOPF (2011) Clean-up of Oil from Shorelines. Technical Information Paper 07.
Maritime and Coastguard Agency (2016) Waste Management Guidance Following a Maritime
Pollution Incident in the UK. Scientific, Technical and Operational Advice Note - STOp 3/16.

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