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Guidelines for the Petroleum and Geothermal Energy Resource (Resource Management and Administration) Regulations 2014 3.5.2 Identification of Sources of Risk and Their Impacts 3.5.2.1 Regulatory Requirements Regulation 17 of the Petroleum RMA Regulations requires that a WMP must include the information listed in Schedule 1. Item 7 of the Schedule 1 requires an explanation of how the title holder will identify, monitor, mitigate and otherwise deal with (a) a well integrity hazard and (b) a significant increase of an existing risk for the well. 3.5.2.2 Objective To demonstrate that an title holder has systematically identified all the sources of risk and their impacts likely to directly or indirectly arise from the activity, whether arising from normal operations or potential emergency conditions (incidents), accidental or otherwise. 3.5.2.3 Guidelines Identification Methodology It is the responsibility of the proponent to demonstrate that the sources of risk and consequent impacts arising from the proposal are identified and can be managed to avoid, reduce or mitigate harm. The Australian standard AS/NZS ISO 31000:2009 Risk Management provides a guide for carrying out risk assessments. This standard states that “comprehensive identification using a well- structured and systematic process is critical, because a potential risk not identified at this stage is excluded from further analysis.” Furthermore, if an impact and source of risk is not identified, measures to mitigate that risk will not be put in place. A WMP should outline the risk identification methodology used in the development of the WMP. AS/NZS ISO 31000:2009 Risk Management outlines the main elements required in the risk identification process. Identification of Sources of Risk and Their Impacts It is common practice to conduct a workshop to identify sources of risk and their impacts. This may include asking what can happen, how it can happen and why. This is best undertaken with a multidisciplinary team of personnel who have different perspectives and specialist knowledge of the proposal. Additionally, adequate literature reviews should be conducted, and appropriate specialist advice sought to ensure that all risks and associated impacts have been adequately identified. Sources of risks and their associated impacts must be identified for planned (routine and non-routine) and unplanned (accidents/incidents) activities for any given activity. Unplanned activities that are considered in this process should be those with a reasonable potential to occur (i.e. a credible event). Good knowledge of industry precedents is useful in identifying these sources of risks and their impacts. 3.5.3 Risk Assessment of well activity 3.5.3.1 Regulatory Requirements Regulation 33 of the (RMA) Regulations requires a titleholder to control a well integrity hazard or risk. Regulation 17 of the (RMA) Regulations relating to content of the WMP refers to Schedule 1 which in turn in item 7 refers to identifying, monitoring, mitigating and otherwise dealing with well integrity hazards and existing risks for the well. Consideration should also be given to Regulation 20 (b), which state that the WMP must be varied if a there is the occurrence or potential occurrence of a new detrimental risk and Regulation 20 (c) or increase in a detrimental risk 3.5.3.2 Objective To demonstrate that a title holder has systematically evaluated all the impacts likely to directly or indirectly arise from the activity, and has assessed their causes, likelihood, consequences and control measures. 3.5.3.3 Guidelines Assessment Methodology AS/NZS ISO 31000:2009 gives guidance on the analysis and evaluation of risks. For each risk identified in the proposal, the likelihood of an impact occurring, and the consequence of the impact should be identified. The WMP should contain details of the scoping process employed in identifying impacts and risks for the well activity, including details of the Risk Activity (RA) process, hazard identification workshops conducted and any other consultation process. Risk Matrices and Terminology In order to provide clarity on the RA process undertaken, the WMP should contain a description of the RA methodology used. In most cases, this involves presenting the corporate RA matrix used. A clear description of consequence and likelihood levels must also be provided. Descriptions may be of a semi-quantitative or qualitative nature. Consequence levels should be allocated based on the potential effects of a given impact on the well activity proposed in the WMP. In some cases, consequence levels are determined based on a combination of different parameters. This may vary depending on the type of RA methodology used by a title holder. This qualitative categorisation is provided as standard regulatory guidance and is independent to the actual terminology used in different title holder’s RA methodologies. As a result, it is critical that when conducting a RA, a title holder attributes a clear description of each consequence level. The Department must be in a position to interpret the adequacy of the reportable incident classification for unplanned events, based on the consequence level categorisation used by a title holder. 3.6 Performance Objectives, Standards and Measurement Criteria As per Item 6, Schedule 1 of the (RMA) Regulations, a WMP must include performance objectives, performance standards and measurement criteria. These three elements should be linked in a logical way. Figure 1 outlines the main elements and linkages involved in identifying performance objectives, standards and measurement criteria for each of the impacts identified during the risk assessment. There can be more than one performance standard applicable to a given objective and more than one criterion applicable to a given standard. www.dmp.wa.gov.au | 7PDF Image | Western Australia Guidelines for Geothermal Energy Resource
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