Supplementary Guidance for Reporting Hydrocarbon Releases

UK Offshore Operators Association

Supplementary
Guidance for Reporting
Hydrocarbon Releases

September 2002

Produced in Cooperation
with the HSE

September 2002 1
 Supplementary Guidance for Reporting Hydrocarbon Releases

SUPPLEMENTARY GUIDANCE FOR REPORTING OF HYDROCARBON RELEASES

This document is supplementary to the existing guidance on reporting of offshore

hydrocarbon releases (OTO 96 956), and should be used in conjunction with that document
when completing and submitting OIR/12 reports.

1. SUMMARY
A flowchart has been produced to aid decision making on the reporting of hydrocarbon
releases, and this is enclosed as Appendix A.
As a brief guide :
o ALL offshore ignitions (i.e. fires, explosions) are reportable no matter how
small. In these cases, the RIDDOR definitions are clear and unambiguous.
There is no need to consider potential or emergency actions, if it ignites,
report it!
o All 2-phase and condensate releases should be considered as reportable.
o For all other releases to be reportable under RIDDOR (DO 73), unless they
actually ignite (see above), then the potential for ignition/escalation needs to
be examined, particularly in the case of releases in the minor range.
o The extent of actions taken to prevent or limit the release are taken as an
indication of the potential for escalation (see existing RIDDOR guidance and
OTO 96 956 where examples of such actions are given e.g. alarms,
shutdowns, withdrawal of permits, withdrawal of personnel from the area,
musters, etc.) If any of these actions take place, then the release is deemed
reportable.
o For Subsea Wells, hydrocarbon releases from these are reportable as well
incidents (DO 13). However, only those involving an installation (e.g. MODU
or “parent platform”) and controlled from there will need an OIR/12.
o For Subsea Pipeline releases (DO 14), only those occurring within the 500
metres safety zone of an installation will need an OIR/12.

2. SUBMISSION OF OIR/12 FORMS

Completed OIR/12 forms should now be submitted to the Health & Safety Executive, HID
Central Intelligence Unit, Data Management Section (CD4C), at the following address:

2nd floor
St Anne's House
University Road
BOOTLE
Merseyside L20 3RA

Or by e-mail to: HCR.Admin@hse.gsi.gov.uk

NB :
• OIR/12 documentation should NOT be submitted to the Incident Contact Centre,
which only deals with incident reporting (i.e.OIR/9b) under the RIDDOR regulations.
• OIR/12 forms should NOT be submitted to any HSE address other than the above,
i.e. they must be sent separately from the OIR/9b.
• Interactive forms, which may be completed on-line and e-mailed direct to HSE
(including OIR/9b and OIR/12) will shortly be available from the HSE web-site
(http://www.hse.gov.uk). In addition, the HCR System is being upgraded to allow
submission of OIR/12 forms direct into the HCR system database via the internet.
Planned to be on-line in early 2003.

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Supplementary Guidance for Reporting Hydrocarbon Releases

3. LINK BETWEEN OIR/12 FORM AND PARENT OIR/9B SUBMISSION

• OIR/12 forms can only be entered and checked in the Hydrocarbon Releases
Database when parent OIR/9B information has been submitted under RIDDOR to HSE
via the Incident Contact Centre.
• If the release is not reportable under RIDDOR (see also section 1. ‘REPORTABILITY’
above), then an OIR/12 form is not required either, and should not be submitted
because it cannot be processed separately.
• All process and non-process hydrocarbon releases reportable under RIDDOR must
be reported under Dangerous Occurrence(DO)Code 73 (Release of Petroleum
Hydrocarbon).
• Hydrocarbon fuelled fires and explosions are ALL reportable under RIDDOR,
irrespective of the size of fire, time of burning or damage caused. These must also be
reported under DO Code 73 (Release of Petroleum Hydrocarbon) and NOT under DO
Code 74 (Fire or Explosion), which is for fires and explosions other than those fuelled by
petroleum hydrocarbon.
• Hydrocarbon releases from Wells and Pipelines, however, may still be reported under
DO 13 and DO 14 respectively to bring these to the direct attention of wells and pipeline
specialists respectively.

4. OFFSHORE INSTALLATION DETAILS AND LOCATION OF INCIDENT

Name (or other designation)

The name of the installation should specify the platform (or MODU) on which the
hydrocarbon release occurred (e.g. Bruce CR, Marnock PUQ) rather than more general
designations such as Bruce Complex, ETAP, well number, etc.

Registration Number
The use of Registration Numbers was discontinued following the introduction of the
Management and Administration Regulations (MAR) in 1995, and thus these no longer need
to be reported on the OIR/12 form.

Location
• Full location details (Quadrant, Block, Latitude and Longitude) are required on the OIR/12
form, especially for incidents involving mobile installations.
• It is insufficient to state only the name of the field involved.
• Quadrant and Block numbers should be inserted in the separate fields designated for this
information e.g. Quadrant 9; Block 13c. Please DO NOT show them in one field e.g. in the
form 9/13c

5. MAIN OIR/12 FORM COMPLETION

Hydrocarbon Released

• Releases of unprocessed hydrocarbon fluids (from wells, flowlines, manifolds and

drilling/workover operations) should be coded as 2-phase.
• Releases downstream of separation (such as oil/gas/produced water releases, for
example) should be coded as the hydrocarbon type related to the parent stream i.e. gas,
oil, or condensate, not as 2-phase.
• Releases of non-process hydrocarbons such as diesel, helifuel, lub oil, hydraulic oil,
seal oil, glycol, methanol, oil-based mud etc. are also reportable under RIDDOR, and an
OIR/12 is also required for these.
• Any gas density quoted should be at operating (i.e working) conditions, rather than a
relative density.
• Please remember to give gas density, liquid gravity, and GOR for 2-phase releases.

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Supplementary Guidance for Reporting Hydrocarbon Releases

Parameters for Basic Severity Classification

• To classify the basic severity (i.e. major, significant, minor) it is important that the best
possible estimates of “estimated quantity released”, “equivalent hole diameter”,
“duration”, and “actual (working) pressure” are provided.
• It is extremely difficult to estimate the severity if two or more of these parameters are
not provided , or are quoted as “not known”, "too small to measure" or "impossible to
quantify”.
• Advisory tables which can aid the estimation of these basic parameters are enclosed
in Appendix A. However, it is recommended that a process engineer be consulted on
this aspect prior to submission of the OIR/12 form.
• The “equivalent hole diameter” should be the hydraulic equivalent (round) hole
diameter which, if it is not round (e.g. crack, split ) may be calculated from the actual
hole geometry as 4A/P, where A = cross-sectional area, and P= Wetted Perimeter.

Location of Leak

Module / Area Name

This field is often used to determine (or corroborate) the system from which the
hydrocarbon release emanated. It would therefore be helpful to avoid using company or
plant specific terminology, or very general area designations here, (e.g. Module A, PO4,
Level 1, Package 4, Main Deck, Process Area) but to identify actual plant names instead
e.g. Separation module, wellheads module, etc.

System Selection

• It is essential that a single system is selected from the list on the OIR/12 form for
any one hydrocarbon incident.
• The series of tick boxes and other boxes for completion/deletion are based on the
definitions quoted in OTO96 956, and the choices made should best describe the
system considered to be responsible for the release.
• Avoid situations where all topsides incidents are coded solely as the "Processing"
system, for example.
• A number of hydrocarbon releases are "carry-over" type incidents, where a
hydrocarbon release occurs and the material passes through other systems / equipment
before subsequently being released to atmosphere. (e.g.via the flare system).
• Where possible, the system (and equipment) selection should represent the items
from which the hydrocarbon emerged (e.g. piping within the flare system).
• In “carry over” incidents, the causation details (see below) may then be used to reflect
the mode of failure of the system and/or equipment item which caused the release.
• System Selection Hints:

o Incidents involving Drilling Operations should be coded as "Drilling"

from the system list. They must also be further described as either
Exploration or Appraisal or Development or Completion, by selecting the
appropriate parameter from this section of the OIR/12 form. The
selection should also show whether the operation was on an Oil or Gas
well, and one of the water depth ranges (viz: <100m, 100-700m, 701-
1000 metres, >1000 metres) should also be selected.
o Incidents involving Well Operations (i.e. wireline, workovers) should also
be coded as "Drilling" from the system list. They must also be further
described as either Wireline or Coiled Tubing or Snubbing or Well Test
or Recompletion or Abandonment (or Other if necessary), by adding this
to the OIR/12 form. The selection should also show whether the
operation concerned was on an Oil or Gas well, and whether the
operation was With Tree or Without Tree.

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Supplementary Guidance for Reporting Hydrocarbon Releases

o Incidents involving permanent drilling equipment should also be coded

as "Drilling" from the systems list, but no further system related
information is required in this instance. The equipment type should then
be specified using only the Mud / Shale / Drilling option on the OIR/12
equipment list (see below).
o “Well Control” system should be selected for BOP equipment releases.
o “Well” system should be selected for Wellhead or Xmas Tree equipment
releases. The type of well should then be indicated from oil production or
gas production or gas injection, and whether surface or subsea.
o “Processing” systems should be either oil or gas. See OTO 96 956 for
secondary choices.
o “Utilities” systems should be either oil or gas. See OTO 96 956 for
secondary choices.
o “Flowlines Other” includes choke and kill lines.
o “Manifolds Other” includes choke and kill manifolds.
o Incidents involving a fuel line to a turbine should be coded as either the
“Diesel” or “Fuel Gas” system, rather than the “Power Generation”
system.

Equipment Selection

• It is essential that a single item of equipment is selected from the list on the OIR/12
form for any one hydrocarbon incident.
• The series of tick boxes and other boxes for completion/deletion are based on the
definitions quoted in OTO96 956, and the choices made should best describe the
equipment item considered to be responsible for the release.

• Equipment selection hints :

o No equipment type need be selected for Drilling Operations, since the

equipment population in the database excludes downhole components.
o No equipment classification is required to be selected for Well Operations (or
workover) as these are characterised by the use of temporary equipment,
which is not a permanent part of the installation.
o For a permanent drilling system failure (i.e. not Drilling/Well Operations) the
equipment type should then be specified using only the Mud / Shale / Drilling
option.
o “Well Control” system incidents should only ever be related to BOP
equipment (and not component flanges / valves etc.).
o “Well” system incidents should only ever be related to Wellhead or Xmas
Tree equipment (and not component flanges / valves etc.)
o Incidents involving a fuel line to a turbine should be coded as either the
“Diesel” or “Fuel Gas” system, rather than the “Power Generation” system.
o Topsides flowline incidents should be associated with piping, rather than
pipelines.
o It is important to distinguish between major equipment items such as
compressors / turbines / pumps, and the piping connected to them. Only
select the major equipment if the release was from the actual vessel, pump or
compressor, otherwise choose the actual flange, piping or valve as the piece
of equipment involved.
o It is important to source and report precise equipment details, since it can be
very difficult to estimate these with any accuracy if not given on the form,
namely :
ƒ For Pig Traps and Pressure Vessels: Indicate whether horizontal
or vertical, plus give length and diameter
ƒ For Storage Tank : Give capacity (m3)
ƒ For Compressors and Pumps : Indicate whether centrifugal or
reciprocating and whether single or double seal

September 2002 5
Supplementary Guidance for Reporting Hydrocarbon Releases

ƒ For Heat Exchangers : Indicate whether Plate or Hydrocarbon in

Shell or Hydrocarbon in Tube.
ƒ For Valves: Indicate whether Manual or Actuated, plus give
Function (e.g. control, block, etc.) plus Type (e.g. gate, ball,
globe, etc.) plus Size.
ƒ For Flanges, Piping, Pipelines and Risers the rating should be
expressed in psig or barg (not in ANSI, API etc.)
ƒ For Piping, Pipelines and Risers the material type should be
either Steel or Flexible (no need to give specification).

Hazardous Area Classification

• Zone 1: An area in which hydrocarbons, in the form of an explosive vapour/air

mixture, is likely to occur in normal operation (drill floor, vent or flare area).
• Zone 2: An area in which hydrocarbons are not likely to occur in normal operation,
and if occurring will exist only for a short time (process, wellhead area).
• Unclassified: Non-hazardous area (e.g. accommodation).

Total HC Inventory in System

The calibre of information quoted in this field is variable, and sometimes difficult to relate to
the estimated quantity released. Since we need to be able to relate estimated quantity
released to the total HC inventory, in terms of estimated percentage inventory lost, the units
used here should preferably be the same as those used in estimated quantity released. Also,
the inventory should be the amount normally resident in the system e.g. held between
isolation valves at the defined limits of the system.

Extent of Dispersion

As well as giving details of how hydrocarbons accumulated or dispersed in the area i.e.
extent of liquid pool or gas cloud, this box may also be used to describe details of gas
detection (in terms of LEL etc.) together with details of why fixed gas detection failed to detect
a particular leak.

Cause of Leak

For any one hydrocarbon incident, it is essential that a single factor is selected from each
category (i.e. design, equipment, operational and procedural causation) on the OIR/12 form.

• Design : Choose either “related to design” or “no design failure”.

• Equipment: Choose either “No failure in the equipment itself” or
o Corrosion which should be further specified as either Internal or
External.
o Mechanical which should be further specified as either Failure or Fatigue
or Wearout.
o Erosion
o Material defects
o Other equipment failure which should be further explained in text.
• Operation : Choose either “no operational failure” or
o Incorrectly fitted
o Improper which should be further specified as either Maintenance or
Inspection or Testing or Operation.
o Dropped Object / Other Impact which should be further specified as
either Dropped Object or Other Impact.
o Left open
o Opened when containing Hydrocarbon
o Other operational failure which should be further explained in text.
• Procedural: Choose either “no procedural failure” or

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Supplementary Guidance for Reporting Hydrocarbon Releases

o Noncompliance with, which should be further specified as either

Procedure or Permit to Work.
o Deficient Procedure
o Other procedural failure which should be further explained in text.

• NB : The "Other" Equipment, Operational and Procedural causation categories should

not be used to code statements that relate to existing code choices. For example :
• "suspect mechanical failure" should have been coded as Mechanical Failure
• "potential corrosion/erosion" should have been coded as either Erosion or Internal /
External Corrosion
• "operator left valve open" should have been coded as Left Open, etc.

Operational Mode (in the area at the time of release)

• Operational Mode should be used to confirm the status of work ongoing IN THE AREA
OF THE RELEASE. This means that if some maintenance, construction, pigging, workover,
sampling, equipment start-up, or other operation was being carried out on or around the
equipment when it leaked, then that box should be ticked, even if the remainder of the
Installation was in normal production. For the remaining Operational Mode selections,
further factors should be specified during selection, viz:

• Drilling or Well Operations: the choice here should match the system selection (see
section on “System Selection” above)
• Normal Production: Use this only where everything was normal with no intervention going
on in the area.
• Pigging
• Shutting Down / Shutdown / Blowdown should be further specified as either Shutting
Down or Shutdown or Blowdown.
• Flushing / Cleaning / Inspection should be further specified as either Flushing or
Cleaning or Inspection.
• Maintenance should be further specified as either Hot Work or Other, with further text to
explain
• Construction should be further specified as either Hot Work or Other, with further text to
explain
• Testing / Sampling should be further specified as either Testing or Sampling.
• Reinstatement / Start-up should be further specified as either Reinstatement or Start-up.
o Reinstatement should be used where the system was re-started following
work carried out on the item or plant from which the release emanated
including maintenance / construction operations, inspection, testing, venting
etc. including planned shutdowns.
o Start-up should be used where the system was re-started following an
operational shutdown such as a plant trip etc, and where no intervention work
was carried out.
o If the Reinstatement / Start-up is known to have followed a shutdown but it
is not clear whether this was following maintenance or construction etc., then
REINSTATEMENT should be assumed.
o If it is not known whether the Reinstatement / Start-up followed a shutdown
or not, then START-UP should be assumed.

Ignition Source and Ignition sequence

• Ignition Source information is invaluable in the modelling of ignitions, and for analysing
ignition probabilities. Details of the ignition source(s) must therefore be given (e.g. hot work
in area, spark from electrical contact, hot exhaust, spark from metallic impact etc.) especially
as this information is published in the annual hydrocarbon statistics report for each ignition
reported.

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Supplementary Guidance for Reporting Hydrocarbon Releases

• The ignition sequence is also important in ignitions modelling, and so the order of events
should be indicated by entering the sequence number(s) in the box(es) shown. For example,
for a Flash fire followed by an Explosion put ‘1’ in Flash Fire and ‘2’ in Explosion.
• Also indicate whether the ignition was immediate or delayed by ticking the appropriate
box. If delayed, the time of delay should also be added in seconds.

Emergency Actions

Shutdown and Blowdown emergency action codes do not solely relate to the shutdown and/or
blowdown of an entire system, but may also be used to describe instances of
shutdown/blowdown of individual items of machinery and sections of process, rather than
describing these in the "other emergency actions" field (though isolation activities can be
coded as "other emergency actions").

Additional Comments

This field is intended for use as an area where any other relevant information on the incident
may be added, other than that already provided in the various sections relating to weather,
extent of dispersion or other emergency actions.

For example, details of injuries or damage caused, results of investigations etc. may be
added here.

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 Supplementary Guidance for Reporting Hydrocarbon Releases
Appendix A. A Flowchart Summary of the Reporting Guidelines

Guidance Notes
Note 1
Is it a Hydrocarbon No Typical Substances;
Release? Gas, Oil, Condensate, 2-Phase, and Non-process
( Diesel, fuel oil, glycol, helifuel, lub-oil, methanol, heat transfer oil,
Note 1
hydraulic oil, seal oil, bottled gas etc.)
Yes

Note 2
Intentional Releases are defined as;
Is it an intentional Yes Did it No
Release ? escalate ? - Routine releases such as flaring, venting, sampling etc.
Note 2
where the activity remained within controlled limits and no
No Yes mitigating actions were required to prevent escalation

Note 3
Emergency stoppage of plant, either automatically or by operator,
Was emergency
to control the leakage of process or non-process hydrocarbons.
action required to
Yes Stoppage of, or suspension of work on a particular process, or
prevent escalation ?
stoppage of a permit to work following the confirmation of a
Note 3 hydrocarbon release with a potential for fire or explosion.
No Operation of a deluge, fixed fire-fighting system, blow-down etc
General shutdown, muster, evacuation of an area, or and
combination of these following a confirmed release.
Did ignition occur ?
Yes
Note 4
No
Any unintentional release within 500m zone, which results in;
- a fire or explosion
- the taking of action to prevent or limit the consequences of a
Does it meet No potential fire or explosion
Yes reportable criteria ? - has the potential to cause death or major injury to any person.
Note 4
GAS / 2-Phase: A release is reportable if it is;
1. A CONTINUOUS release at a rate greater than 1 kg / hour,
Nominally 20% LEL at 0.1 metres
OR
Submit OIR 9b 2. A DISCRETE release with a total mass of greater than 0.1 kg
within 10 days of
Incident Occurring LIQUIDS : A release is reportable if it is ;
1. A CONTINUOUS release of 100% hydrocarbons at a rate
greater than 5 kg/ day ( approx 4 drips / minute ), nominally 0.25
litres / hour.
2. A DISCRETE release of 100% hydrocarbon, of greater than
Investigate 5kg, ( nominally 5 litres ).
3. If produced water, the oil content must be greater than 10%,
and the total mass OF HYDROCARBONS released is greater
than 5kg, ( nominally 5 litres ).
Estimate Mass of
Release and other
reportable criteria Are other reports No
required ?

Consult Use
Onshore advisory
Process tables as Yes
Engineer required.

Submit OIR 12
within 30 days of
Incident Occurring
Raise
Reports
as required

OIR/9b for other

PON 1 for
Internal company RIDDOR events
Environmental
Are other reports record e.g. HP water,
Spill
required ? Yes mud, H2S

No
End

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Supplementary Guidance for Reporting Hydrocarbon Releases

APPENDIX B: Estimation of Gas Volumes Released

The following graphs and tables help give guidance on estimating the mass of gas
released for different, leak hole sizes, pressures, pipe system inventories etc.

Small Continuous Release Flowrates

1000

10mm
100
5mm

3mm
10

1mm
Mass Flowrate (kg/min)

1
0.5mm

0.1

0.1mm
0.01

0.001

0.0001

0.00001
1 10 100 1000
Pressure (bara)

Graph showing mass flow rates in kg/minute for a Small Continuous Gas
Release

Pressure Nominal Pipe Diameter ( inch )

( Bara )
3” 4” 6” 8” 10” 11” 12”
1 0.0045 0.0079 0.0178 0.0317 0.0495 0.0599 0.0713
5 0.0223 0.0396 0.0891 0.1585 0.2476 0.2996 0.3565
10 0.0446 0.0792 0.1783 0.3169 0.4952 0.5992 0.7131
15 0.0699 0.1188 0.2674 0.4754 0.7428 0.8988 1.0696
20 0.0891 0.1585 0.3565 0.6338 0.9904 1.1984 1.4261
25 0.1114 0.1981 0.4457 0.7923 1.2380 1.4979 1.7827
50 0.2228 0.3962 0.8913 1.5846 2.4759 2.9959 3.5654
100 0.4457 0.7923 1.7827 3.1692 4.9519 5.9918 7.1307
150 0.6685 1.1885 2.6740 4.7538 7.4278 8.9877 10.6961
200 0.8913 1.5846 3.5654 6.3384 9.9038 11.9836 14.2614
250 1.1142 1.9808 4.4567 7.9230 12.3797 14.9795 17.8268

Table showing Mass of Gas per Meter Length of Piping ( kg/m )

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 Supplementary Guidance for Reporting Hydrocarbon Releases

Estimation of Gas Volumes Released.- When Blowdown has been

Initiated

The following graphs provide guidance/help in an initial estimate of the TOTAL mass of
Gas released, assuming that the ESD/Blowdown commenced at the time of the initial release
and operated during the entire period. Calculations have been performed for various system
volumes from 10 m3 to 500m3.

Assumptions;
Gas Molecular weight = 26 kg/k-mole
Blowdown rate = As per API 521 ( Blowdown from operating pressure to either half the
original or 8 bara , which ever is the lowest, within 15 minutes of blowdown operation )

Mass of Gas Released From a 1mm Dia. Hole (Following ESD/Blowdown)

10
Mass Released (kg)

0.1
2 5 10 20 30 40 50 60 70 80 90 100 110 120 130 140 150 160 170 180 190 200
System Operating Pressure (bar)

10m3 25m3 50m3 100m3 200m3 500m3

Mass of Gas Released F rom a 3mm Dia. Hole (F ollow ing ES D/Blow d ow n)

100
Mass Released (kg)

10

1
2 5 10 20 30 40 50 60 70 80 90 100 110 120 130 140 150 160 170 180 190 200
Syste m O pe rat ing Pre ssure (bar)

10m 3 25m 3 50m 3 100m 3 200m 3 500m 3

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Supplementary Guidance for Reporting Hydrocarbon Releases

Mass of Gas Released From a 5mm Dia. Hole (Following ESD/Blowdown)

1000
Mass Released (kg)

100

10

1
2 5 10 20 30 40 50 60 70 80 90 100 110 120 130 140 150 160 170 180 190 200
System Operating Pressure (bar)

10m3 25m3 50m3 100m3 200m3 500m3

September 2002 12