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Guidelines for the Petroleum and Geothermal Energy Resource (Resource Management and Administration) Regulations 2014 For this reason industries like the upstream petroleum industry should carry the role of risk minimisation. There are, however, circumstances where prescriptive requirements are requires as in some of the contents of a WMP. The WMP regime aims to reduce risks and impacts of petroleum drilling activities, to a level which is ‘as low as reasonably practicable’ (ALARP). It is important to note that what is considered practical will evolve over time as technology, best practice and expertise improve. Title holders should have a mechanism in place to monitor improvements in technology and practices. Well activity means an activity relating to a well that is carried out during the life of the well and includes activities such as: a) exploratory drilling; b) production drilling; c) appraisal drilling; d) well drilling; e) hydraulic fracturing; f) well testing; g) well intervention; h) a wireline operation; i) a workover operation; j) well completion or re-completion; k) maintenance of a well; l) production testing (including initial and extended production testion); m) production; 3.1.1 WMP Requirements The Petroleum (RMA) Regulations require the submission of a WMP which: • is appropriate for the nature and scale of the activity or proposed use; • demonstrates that the drilling impacts and risks of the activity will be ALARP; • provides for appropriate well management performance objectives, standards and measurement criteria; and • complies with the Act, the relevant Petroleum (RMA) Regulations and applicable State statutes. A WMP must identify risks and effects, establish specific performance objectives and standards, including measurement criteria to assess performance against those standards. These elements must be interlinked in a systematic manner. The WMP, when approved, becomes the legally binding agreement between The Department and the title holder, setting out performance objectives, standards and criteria which the title holder will be assessed against. The intent of the WMP regime is to ensure that the WMP functions as a regulatory approval document and as a practical implementation and management tool to be used by the title holders and their contractors when conducting a well activity. It is the intention that the initial submission of a WMP will contain all the risk management and mitigation information plus the detailed first activity program. It should be noted that underlying risks should have mitigations, even if the likelihood of occurrence is low. For example, it is for this reason that all rigs drilling for petroleum are fitted with Blow Out Preventers (BOPs), even when the chance of an influx is known to be low. The risk management part should be separated from the detailed activity part so that, later, when a further activity is proposed, if the risk management for the further activity is still the same as in the original WMP submission, it will not need to be resubmitted. However, if there are additional risks associated with the further activity, details of the extra risk management and mitigation should be supplied along with the further activity program For a new well the first activity program in the WMP will be the drilling program. When a new activity is proposed for a well, a new WMP should be supplied to the Department for approval. Once approved, the program will be appended to the WMP and will be the current activity program until superseded by any further activity program. The submitted activity program should conclude with the proposed well status that will apply once the activity has been completed. A WMP may be a specific stand-alone document that relates to activities that might occur on one particular well, or, it may be a Generic WMP that relates to proposed numerous repetitive activities (for example, batch drilling a multi well drilling program). n) o) p) q) r) s) Note that inclusion re-entering a well; well shut-in and opening; enhanced recovery; injection; suspension of a well; abandonment of a well. any actual drilling for a well activity program will require the of a Geological Prognosis. The WMP regime requires that petroleum title holders prepare and implement an approved WMP for applicable well activities. An over- riding consideration in assessing a WMP is that if the plan does not adequately address risks associated with the activity, it will not be approved. Therefore, commencement or continuation of the well activity will also not be permitted. This WMP regime also encourages petroleum title holders to employ innovative and effective measures that are tailored to their specific circumstances to achieve superior well management practice and outcomes. In this sense, the WMP regime is co-regulatory and encourages ongoing consultation between The Department and title holders. www.dmp.wa.gov.au | 3PDF Image | Western Australia Guidelines for Geothermal Energy Resource
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