Energy Safety Annual Report 2017
A key role of the CRU is to ensure safe, secure and sustainable energy at a reasonable cost for every Irish home and business. 2 CRU Energy Safety Annual Report 2017
Foreword To: Mr Denis Naughten, TD Minister for Communications, Climate Action and the Environment The Commission for Regulation of Utilities is Ireland s independent energy and water regulator. Central to what the CRU does is its public interest mandate. A key role is to ensure safe, secure and sustainable energy at a reasonable cost for every Irish home and business. Irish people s well-being, our environment and the country s economic competitiveness, and growth, are all dependent on the sectors the CRU regulates. An important part of our regulatory remit is ensuring safe supply of energy. This report sets out the work of the CRU in 2017 in support of its energy safety functions. It fulfils the CRU s reporting functions under the Gas Safety Regulatory Framework and the Petroleum Safety Framework 1. In addition, it presents information on the CRU s performance around Electrical Safety Supervision. The specific sectors the CRU regulates for safety are: Downstream: Natural gas undertakings Liquefied Petroleum Gas (LPG) undertakings Gas installers Electrical contractors. Upstream (petroleum exploration and extraction activities): Petroleum undertakings Operators Owners. The CRU engages with the public and a wide-range of stakeholders to maintain an appropriate standard of safety in the sectors it regulates. Not only does the work set out in this report help ensure the safe development and operation of infrastructure, it is also fundamental to protecting lives and property. 1 Section 9 (1G) (a) of the Electricity Regulation Act 1999, as amended by the Energy (Miscellaneous Provisions) Act 2006 (in respect of the Gas Safety Regulatory Framework) and section 13I (6) of the Electricity Regulation Act 1999, as amended by the Petroleum (Exploration and Extraction) Safety Act 2010 and the Petroleum (Exploration and Extraction) Safety Act 2015 (in respect of the Petroleum Safety Framework). 3 CRU Energy Safety Annual Report 2017
Contents Executive Summary 6 1. Gas Safety Regulatory Framework 8 1.1 Regulation of Gas Undertakings 10 1.2 Compliance Assurance 11 1.3 Registration of Gas Installers 14 1.4 Key Performance Indicators (KPIs) 17 1.5 Continuous Improvement 26 2. Electrical Safety Supervision 27 2.1 Electrical Safety Supervisory Body (ESSB) - Safe Electric 29 2.2 Enforcement 30 2.3 Electrical Safety Promotion and Public Awareness 31 2.4 Transition of the National Wiring Rules from ETCI to the NSAI 32 3. Petroleum Safety Framework 33 3.1 Safety Permit Application Assessments 35 3.2 Safety Performance Reporting 36 3.3 Reporting 37 3.4 Audits and Inspections 38 3.5 Enforcement 39 3.6 Decommissioning 39 3.7 Public Request for Safety Case 39 3.8 Engagement with Irish Agencies 39 3.9 Engagement with Indsutry 40 3.10 International Engagement 40 Acronyms 41 Appendix 42 4 CRU Energy Safety Annual Report 2017
GAS SAFETY 2,952 2016: RGI S IN THE REGULATORY SCHEME AT THE END OF 2017 9 SHIPPER/SUPPLIERS 2017: 12 SHIPPERS 2 SUPPLIERS 10 SHIPPER/SUPPLIERS 14 SHIPPERS 2 SUPPLIERS 6 SUCCESSFUL PROSECUTIONS IN 2017, BRINGING TOTAL SINCE 2009 TO 35 ELECTRICAL SAFETY 2016: 2017: 4,213 REGISTERED ELECTRICAL SUPPLIERS 5,215 QUALIFIED CERTIFIERS 4,153 REGISTERED ELECTRICAL SUPPLIERS 4,829 QUALIFIED CERTIFIERS 78 INVESTIGATIONS WITH 4 SUCCESSFUL PROSECUTIONS 84% OF PEOPLE HAVING ELECTRICAL WORK CARRIED OUT IN 2017USED A REGISTERED ELECTRICAL CONTRACTOR 60% OF PEOPLE ARE AWARE OF THE SAFE ELECTRIC LOGO PETROLEUM SAFETY 7 PLANNED INSPECTIONS 6 FURTHER INSPECTIONS SAFETY INCIDENTS WERE NOTIFIED, ONE 17MORE THAN IN 2016 3 PRODUCTION 3 ACKNOWLEDGEMENTS SAFETY PERMITS WERE LIVE IN 2017 OF COMPLIANCE (AoC) WERE IN PLACE IN 2017 5 CRU Energy Safety Annual Report 2017
Executive Summary Gas Safety Regulatory Framework The CRU Energy Safety Division continued to carry out its regulatory safety functions of gas undertakings and installers during 2017. This included audits and inspections of licensed undertakings to ensure compliance, alongside working with the RGII (Register of Gas Installers of Ireland) to ensure domestic gas safety. A major incident occurred at the Corrib entry point in September 2017. Non-odourised natural gas entered Gas Networks Ireland s (GNI s) transmission network, resulting in a hazard to public safety. This resulted in an interruption of the supply of natural gas to approximately 10,000 customers for 72 hours. Initiation of the Natural Gas Emergency Plan (NGEP) was a clear example of a measured, appropriate and coordinated response to an emergency. The Gas Safety Regulatory Framework (GSF) team had three enforcement actions in 2017, each at a different type of installation. One resulted from the Corrib incident, another at the Shannon GNI installation, and the third with Calor Teoranta Ltd. This demonstrates the wide range of work the CRU carries out under the GSF, and the CRU continues to monitor these enforcement actions to ensure appropriate learnings. For domestic gas, a core part of safety is for only registered, qualified and competent installers to undertake domestic works. Here, the CRU discharges its safety regulation of registered gas installers through the RGII, who manage registration and the ongoing inspection of installers. There were 2,952 RGIs in the regulatory scheme at the end of 2017. 2,952 RGI S IN THE REGULATORY SCHEME AT THE END OF 2017 In order to ensure safe supply of gas, the CRU has a series of high-level KPIs for the GSF, covering the spectrum of safety issues from loss of containment to public awareness of safety. The KPIs demonstrate good performance, for example a decrease in the number of encroachments and in public reported gas escapes. In addition, the number of CO alarms in homes has increased, and so has awareness of the RGI scheme. The CRU is assured that through ongoing monitoring, the GSF delivered good outcomes during 2017, and it is committed to keeping it under review to ensure that it continues to operate effectively and remains fit for purpose. 6 CRU Energy Safety Annual Report 2017
Electrical Safety Supervision The CRU and Register of Electrical Contractors Ireland (RECI) are committed to ensuring the Safe Electric scheme benefits the public through improving safety in the home. The CRU investigates reports alleging illegal electrical works. During 2017, it commenced 78 investigations, with four successful prosecutions. The CRU will continue to carry out investigations and take enforcement actions, including interviews of suspected illegal electrical contractors, cease-anddesist warning letters and prosecutions. 78 INVESTIGATIONS WITH 4 SUCCSSFUL PROSECUTIONS Overall, the CRU is satisfied with how the Safe Electric scheme has worked in 2017. Public awareness of the scheme continues to show good improvement, with 60% of people aware of the Safe Electric logo and 84% of people having electrical work carried out in 2017 using a Registered Electrical Contractor (REC). Petroleum Safety Framework 2017 marked the fourth full year of operations for the Petroleum Safety Framework (PSF), with delivery of a significant workload. The CRU continued to monitor its designated petroleum activities through assessing safety performance reports, investigating petroleum incidents, carrying out audits and inspections, and taking enforcement actions. In addition to the safety regulation of two production facilities, the CRU assessed a number of material changes to current safety cases, two Acknowledgements of Compliance (AoC), and one well work safety case. 7 PLANNED INSPECTIONS 6 FURTHER INSPECTIONS Operators and owners submit safety performance reports to the CRU. These reports set out leading and lagging safety performance indicators. For 2017, these continued to be low in comparison to similar installations in other countries. In 2017, the CRU continued its role of audit, inspection and, where necessary, enforcement. There were seven planned inspections and six further inspections following up on enforcement action. In addition, the CRU issued Shell E&P Ireland Ltd with one Prohibition Notice and one Direction to Submit an Improvement Plan. To ensure that regulation meets international best practice, the CRU continued to engage with national and European regulators and governmental agencies. It also continued to support the development of an EU member states regulatory team, demonstrating the organisation s increasing international standing. 7 CRU Energy Safety Annual Report 2017
Gas Safety Regulatory Framework 8 CRU Energy Safety Annual Report 2017
1 Gas Safety Regulatory Framework 1.1 Regulation of Gas Undertakings 10 1.2 Compliance Assurance 11 1.3 Registration of Gas Installers 14 1.4 Key Performance Indicators (KPIs) 17 1.5 Continuous Improvement 26 9 CRU Energy Safety Annual Report 2017
Gas Safety Regulatory Framework This section provides an overview of the Gas Safety Regulatory Framework (GSF) and the safety regulation of gas undertakings and gas installers by the CRU through that Framework. It details how the GSF performed during 2017 and identifies key developments planned for 2018. In accordance with the Electricity Regulation Act, 1999, as amended (the 1999 Act), the CRU regulates the safety performance of the downstream Irish natural gas and LPG industries. The scope of the relevant legislation includes the safety regulation of all natural gas and LPG undertakings, including those involved in storage, transmission, distribution, supply and shipping. Under this legislation, promoting the safe use of gas is also a responsibility of the CRU. The CRU helps ensure the safe use of gas in homes throughout Ireland through the RGII, who manage registration and the ongoing inspection of installers (see Section 1.3.1). 1.1 Regulation of Gas Undertakings Under the GSF Safety Case Guidelines 2, all undertakings involved in the transmission, distribution, supply, shipping or storage of natural gas and LPG undertakings operating networks to domestic customers are required to submit a safety case to the CRU, and are subject to ongoing regulation. Table 1 lists gas undertakings with safety cases accepted by the CRU. Table 1: Accepted gas safety cases Transmission and Distribution of natural gas Gas Networks Ireland (GNI) Gas Storage PSE Kinsale Energy Shipper/Supplier Bord Gáis Energy Energia Electric Ireland ESB Independent Energy Flogas Natural Gas Ltd Gazprom Marketing & Trading Retail Ltd Go Power Panda Power SSE Airtricity Vayu Ltd Supplier Just Energy Prepay Power LPG Distribution Calor Teoranta Flogas Ireland Ltd. Shipper Aughinish Alumina ElectroRoute ESB Energy International Huntstown Power Manx Utilities PSE Kinsale Energy Statoil Exploration Ireland Ltd Statoil Gas Hibernia Ltd Shell Energy Europe Ltd SSE Energy Supply Ltd Tynagh Energy Ltd Vayu Energy Ltd Vermilion Energy Ireland Ltd Danske Commodities 2 CER (2017) Gas Safety Regulatory Framework Safety Case Guidelines. 10 CRU Energy Safety Annual Report 2017
Gas Safety Regulatory Framework 1.2 Compliance Assurance 1.2.1 Safety Case Assessments In 2017, the CRU accepted a material change to Gas Networks Ireland s (GNI) distribution system operators safety case to take account of the introduction of Compressed Natural Gas (CNG) assets into the GNI gas network. The CRU also accepted a material change in relation to emergency response arrangements from Flogas Ireland Ltd. Three new safety cases were accepted: one for Go Power as a shipper/supplier, and two for shippers: ElectroRoute and Danske Commodities. 1.2.2 Audits and Inspections of Gas Undertakings As part of its annual work programme, the CRU agrees an audit and inspection programme for natural gas and LPG undertakings. Decisions on review topics take into account previous audit and inspection findings, incident reports and safety case risk ratings. 1.2.3 Gas Networks Ireland GNI, as Distribution and Transmission System Operator (DSO/TSO), was subject to eight audits and inspections in 2017 (see Table 2). GNI follows up on the findings and recommendations within specified timeframes, and the CRU monitors progress through a programme of verification meetings. Table 2: Audits and inspections of GNI for 2017 Network Area Audit/Inspection Topic Cathodic Protection Connections to Non-Domestic Installations Distribution Inspection C&I Meter Installation GNI Technical Auditing Cathodic Protection Audit Asset Lifecycle Transmission Inspection Permit to Work Quality Assurance Transmission Emergency Stores and Critical Spares 1.2.4 Licensed LPG Undertakings In 2017, the CRU conducted two audits of both Calor Teoranta and Flogas Ireland Ltd. The LPG undertakings were subject to system extension and internal audits, and audits of their emergency responses. As with the DSO/TSO, all the CRU s findings and recommendations were reported for follow-up and implementation, and monitored through a series of verification meetings. 1.2.5 Shipper/Supplier Audits The CRU completed four gas shipper/supplier audits in 2017: Aughinish Alumina, Huntstown power station and Tynagh Energy (shippers), and Prepay Power (supplier). The audits purpose was to ensure compliance with the GSF and to verify satisfactory resolution of any previously raised actions. 2016: 9 shipper/suppliers 12 shippers 2 suppliers 2017: 10 shipper/suppliers 14 shippers 2 suppliers 11 CRU Energy Safety Annual Report 2017
Gas Safety Regulatory Framework 1.2.6 Incidents Reported by Gas Undertakings The CRU monitors all licensed undertakings safety performance and investigates incidents. It also reviews reported incidents to help prevent reoccurrence. The criteria for natural gas incident reporting have been operational since 2009. Furthermore, regulations in 2014 made it a legal requirement to report certain LPG incidents to the CRU 3. The incident types that necessitate reporting are: A Involves a fatality B Injury requiring hospitalisation C Property damage in excess of 6,349 (natural gas) or 6,500 (LPG). The CRU received reports of 15 incidents in 2017, down five from 2016. A breakdown of the incidents by category is set out in Table 3. Table 3: Incidents Reported to the CRU in 2017 N/A Type A/B/C RuG Voluntary Reported LPG Natural Gas 2 0 11-13 LPG - 0-2 2 Total Table 3 also shows two further classifications of incidents that do not fall under Type A, B or C but could be of interest to the CRU. For natural gas these are referred to as Reportable under Guidelines (RuG) and for LPG as Voluntary Reported incidents. There were no reports of Type A, B or C incidents in 2017. For RuGs, on further investigation two were determined not to involve natural gas and therefore did not meet the CRU s reporting requirements. The remaining 11 RuGs and two Voluntary Reported LPG incidents are broken down in Figure 1. Figure 1: Breakdown of Incidents At the Corrib entry point in September 2017, non-odourised natural gas entered the transmission pipeline systems, leading to interruption of supply to approximately 10,000 customers for 72 hours. As this presented a major safety risk, the Natural Gas Emergency Plan (NGEP) was initiated (see Section 1.2.8 for more detail). 3 Liquefied Petroleum Gas Safety (Liquefied Petroleum Gas Incident) Regulations 2014 (SI No: 77); and Liquefied Petroleum Gas Safety (Liquefied Petroleum Gas Incident Reporting and Investigation) Regulations 2014 (SI No: 78). 12 CRU Energy Safety Annual Report 2017
Gas Safety Regulatory Framework 1.2.7 Dublin-Cork Pipeline at Mullinahone, County Tipperary The CRU was informed of damage to the Dublin-Cork pipeline on a Coillte forest site in Mullinahone, County Tipperary, in October 2016. The damage was identified as part of a routine inspection carried out on behalf of GNI. Although reported to the CRU by GNI, the incident was not formally reportable as defined in legislation (see section 1.2.6). The CRU carried out a follow up inspection of pipeline repair works in January 2017. At this stage a bypass was in place and operational with the damaged section of pipe cut out and a new section in place. 1.2.8 Enforcement Following an investigation into the Corrib non-odourised gas incident, the CRU issued GNI an Intent to Serve an Improvement Notice in November 2017. Having considered representations made by GNI, the CRU proceeded to serve an Improvement Notice on them in January 2018. The enforcement action is ongoing, and the CRU will issue a full report on the incident in due course. In August 2017, the CRU issued a Direction to Submit an Improvement Plan against GNI in relation to mechanical controls in place at its Shannon Compressed Natural Gas (CNG) installation. GNI submitted the Plan and the action was closed. In June 2017, following a routine audit of Calor Teoranta Ltd, the CRU issued an Intent to Serve an Improvement Notice regarding emergency response arrangements. The CRU served the Notice in December 2017. The enforcement action was ongoing at the end of 2017. 1.2.9 Third Party Owned LPG Networks The Electricity Regulation Act 1999, as amended, makes no provision for a party other than an LPG undertaking to apply for a LPG Safety Licence. Furthermore, it is an offence for a person to make available LPG by way of a piped LPG distribution network for use by individual domestic final customers unless a LPG safety licence is in force in respect of the activity. In 2017, the CRU wrote to both Calor and Flogas, asking for details of customers where the LPG undertaking fills the tank but another party owns and operates a piped LPG distribution network. The response identified 63 networks. The CRU has developed a plan for inspections of the LPG networks, which aims to be completed by May 2018. 1.2.10 Emergency Response Programme GNI prepares the NGEP under direction of the CRU and in consultation with the Government and the gas and electricity sectors. The purpose of the Programme is to establish procedures in the event of a natural gas emergency in Ireland. During 2017, GNI carried out three emergency exercises to test NGEP procedures. In addition, there were exercises in conjunction with the Department of Communications, Climate Action and Environment, and with Eirgrid. Such training is essential for ensuring emergency preparedness. Separately, GNI carries out emergency exercises on the distribution network, with two in 2017. 13 CRU Energy Safety Annual Report 2017
Gas Safety Regulatory Framework 1.3 Registration of Gas Installers 1.3.1 Gas Safety Supervisory Body (GSSB) The CRU discharges its safety regulation of domestic gas installers through the GSSB. The GSSB s duties and responsibilities are set out in the 1999 Act and in the Gas Safety Supervisory Criteria Document 4. In 2015, following a competitive public procurement process, the Register of Gas Installers of Ireland Ltd. (RGII) was reappointed to the role of GSSB. RGII s contract runs for seven years from January 2016. At present, the GSSB only covers domestic gas works, but from January 2019 it will extend to cover non-domestic gas works (see Section 1.3.4). 1.3.2 Register of Gas Installers There were 2,952 Registered Gas Installers (RGIs) in the regulatory scheme at the end of 2017. The number of registrations has remained relatively steady at 3,000 +/-2% since 2012. A complete list of RGIs operating in Ireland is available on the RGII website: rgii.ie. A primary means of ensuring gas safety is to prohibit anyone other than an RGI from undertaking domestic gas works. RGII affirms the competence of individual installers at entry to the scheme and through ongoing inspection. Where an RGI carries out substandard work or does not comply with conditions of registration, the RGII can suspend or revoke registration. RGIs are subject to two inspections in their first year of registration and to at least one a year thereafter. RGIs may also be subject to additional checks if inspections show unsatisfactory safety performance. During 2017, the RGII carried out 3,236 inspections, in comparison to the 3,174 planned for the year. This is the first year that actual inspections have exceeded the number planned. The CRU s technical specialist uses an approved audit and inspection programme to monitor the RGII and its inspectors and to verify their safety performance. 1.3.3 New Performance Management Framework for RGII The Performance Management Framework developed by the CRU requires the RGII to report quarterly against an updated series of Key Performance Indicators (KPIs) and supporting metrics. As part of the Framework, the RGII provides quarterly Safety and Compliance reports to the CRU. The aim is to increase transparency and accountability, while promoting continuous improvement. In addition, the reports provide assurance the RGII is fulfilling its obligations. From 2017, the RGII s Safety and Compliance reporting includes assessment against eight new KPIs. These cover: 1. Inspection and auditing of RGIs (3 KPIs) 2. Registration applications and return of certificates (3 KPIs) 3. Complaint resolution (2 KPIs). It is important to note the KPIs are new. Further information from subsequent years is required before the metrics will provide detailed information on any trends. Nevertheless, CRU will continue to work with the RGII to ensure ongoing improvement. 4 CER (2016) Criteria Document Version 1.6 Regulation of Gas Installers with Respect to Safety. 14 CRU Energy Safety Annual Report 2017
Gas Safety Regulatory Framework 1.3.4 Introduction of a Scheme of Registration for Non-Domestic Gas Works From January 2019, the regulatory system for non-domestic gas will mirror the domestic scheme. This will make it a legal requirement for only registered installers to perform non-domestic gas works. In 2017, the CRU focused on establishing a provisional register for installers, stakeholder engagement, development of legislation, and setting scheme entry requirements: Provisional register The CRU worked with the RGII and industry stakeholders to deliver a voluntary non-domestic gas register, launched in July 2017. RGII administers the register. At the end of 2017, there were 298 registrants. Stakeholder engagement To ensure the greatest possible number of installers on the provisional register ahead of January 2019, the CRU began a promotion and publicity campaign in 2017. This included newspaper and trade press advertisements, posters at builders merchants, presentations to trade associations and contacting representative groups. Setting scheme requirements To involve the sector in setting new entry requirements, the CRU established a scheme committee to advise on the training, competency assessment and certification system for the extended register. Membership includes the RGII, GNI, Irish Liquid Petroleum Gas Association (ILPGA), An tseirbhís Oideachais Leanúnaigh Agus Scileanna (SOLAS) and certification bodies alongside representatives from industry, e.g. installer representative panel. This work continued throughout 2017. Development of legislation During 2017, the CRU began drafting a Statutory Instrument to provide the legal basis for extending registration to non-domestic gas installers. This will be in place for the start of the mandatory scheme. 15 CRU Energy Safety Annual Report 2017
Gas Safety Regulatory Framework 1.3.5 Enforcement For domestic gas works, unregistered installers who work on appliances or misleadingly suggest they are an RGI face penalties of up to a 15,000 fine, up to three years imprisonment, or both. In 2017, the CRU initiated 70 investigations into alleged regulatory breaches. There were six successful prosecutions, bringing the total to 35 since the scheme was introduced in 2009. The remainder are either still under investigation or were not taken forward due to lack of evidence that an offence had taken place in the Republic of Ireland. Case Study 1: Gas works enforcement Following an extensive investigation in County Tipperary, the CRU took a case against an installer for carrying out illegal gas works and falsely portraying himself as an RGI. The defendant contested the charges, and the case proceeded to full trial in February 2017. Multiple witnesses were required as part of the CRU s evidence. 6 successful prosecutions in 2017, bringing the total to 35 since 2009 Ultimately, the CRU s case was upheld and the installer was convicted of both offences. A fine of 500 was imposed together with an order for costs in the sum of 2,500 plus VAT and witness expenses of 1,800. The CRU will continue to carry out investigations and take enforcement actions, including interviews of suspected illegal gas installers, cease-and-desist warning letters and prosecutions. 16 CRU Energy Safety Annual Report 2017
Gas Safety Regulatory Framework 1.4 Performance Indicators (KPIs) In order to ensure safe supply of gas, the CRU has established a series of high-level safety objectives for the GSF: 1. Minimising the risk of loss of containment 2. Maintaining safe system operating pressure 3. Minimising the risk of injecting gas of non-conforming quality 4. Providing an efficient and coordinated response to gas emergencies 5. Minimising the safety risks associated with the use of gas 6. Promoting public awareness of gas safety. For each, the CRU has specified a set of KPIs for quarterly reporting by licensed natural gas and LPG undertakings and by the GSSB. Calor Teoranta Ltd and Flogas Ireland Ltd received their LPG safety licences in December 2015. As such, there is currently insufficient data to identify trends in the LPG sector, but these will be identified in future Annual Safety Reports. 1.4.1 Key Safety Objective 1: Minimising the Loss of Containment Gas undertakings are required to demonstrate suitable management systems and procedures for managing the risk of a gas containment event. This covers: Gas escapes reported by the public Damage to the gas transmission and distribution networks Surveillance of works near pipelines Corrosion protection and prevention. Gas Escape Reports There were 16,249 Public Reported Escapes (PREs) in 2017, a decrease on 2016 (17,428). Events where no gas was detected accounted for 50.7% of PREs in 2017 (see Figure 2). Figure 2: Public reported gas escape frequencies 0.7 25000 % of Total escapes per anumn 0.6 0.5 0.4 0.3 0.2 0.1 20332 19430 19569 18147 19406 19031 19449 17428 20000 16249 15000 10000 5000 Total number of escapes 0 2009 2010 2011 2012 2013 2014 2015 2016 2017 % External % Internal % No Leak detected Total PRE's Received 0 On the transmission network, there were 14 PREs reported, compared to six in 2016, all at Above Ground Installations (AGIs). 17 CRU Energy Safety Annual Report 2017
Gas Safety Regulatory Framework Third-Party Damage On the distribution system, 107 third-party damage instances occurred to gas mains (up 15% on 2016) and 457 to gas services (up 7%). See Figure 3. GNI aims to mitigate instances of third-party damage through active promotion of the Dial Before You Dig advertising campaign (see Section 1.4.6). In addition, it runs initiatives to promote the sharing of map data through the Field Access to Automated Records (FAAR) system. Figure 3: Distribution of third-party damage frequencies by supply type 700 600 500 400 300 200 100 0 2009 2010 2011 2012 2013 2014 2015 2016 2017 PE - Mains PE -Services Transmission Pipeline Encroachment Ongoing monitoring of the transmission network helps ensure prevention of damage. GNI maintains a surveillance programme by foot, vehicular and aerial surveys to identify unusual occurrences and irregularities, in accordance with the UK Onshore Pipeline Operators Association good practice guides. Figure 4: Total number of encroachment events 60 50 40 30 20 10 0 2009 2010 2011 2012 2013 2014 2015 2016 2017 Identified encroachments were the result of installing poles, deepening of ditches, drainage installations, road works, building works and cable laying (see Figure 4). When works are close to a transmission pipeline, GNI can provide supervisory assistance. The reduction in encroachments in 2017 is partly due to reclassification of ditch cleaning as a GNI-supervised activity. 18 CRU Energy Safety Annual Report 2017
Gas Safety Regulatory Framework 1.4.2 Key Safety Objective 2: Maintaining Safe System Operating Pressure Gas undertakings are required to demonstrate they have suitable management systems in place for managing risks resulting in dangerously high or low gas operating pressure. Within the scope of this objective are: Gas outages System pressure management. Gas Outages In 2017, there was one unplanned gas outage on the distribution network, compared to three in 2016; this was as part of the Corrib non-odourised gas incident (discussed in Section 1.2.8). System Pressure Management As part of the Supervisory Control and Data Acquisition (SCADA) operated by GNI, a number of defined parameters, such as system pressure, are constantly monitored and controlled. No system pressure drops or over-pressure events occurred on the distribution or transmission networks in 2017. 1.4.3 Key Safety Objective 3: Minimising the Risk of Injecting Gas of Non-Conforming Quality Gas emergency incidents can arise due to injection of non-conforming gas into the system. As such, gas undertakings are required to demonstrate they have suitable management systems in place for monitoring gas quality and managing the risks associated with gas quality. The KPIs for this objective are: Odorant management Gas quality. Odorant Management Natural gas has odorant added to help identify escapes. To ensure consistency, measurements of concentration levels are in accordance with the internationally recognised Sales scale. Figure 5: Total number of planned and completed odour tests carried out 300 250 200 150 100 50 0 2009 2010 2011 2012 2013 2014 2015 2016 2017 Odour tests planned Odour tests undertaken 2017 saw 34 non-compliant tests, all related to the non-odourised gas incident at the Corrib entry point, which is part of an ongoing enforcement action against GNI (see Section 1.2.8). The spike in gas odour tests undertaken for 2017 shown in Figure 5 is largely due to the Corrib incident. Figure 6 shows the number of non-compliant test results. 19 CRU Energy Safety Annual Report 2017
Gas Safety Regulatory Framework Figure 6: Non-compliant test results 40 35 34 30 25 20 15 10 5 0 0 0 4 2011 2012 2013 2014 2015 2016 2017 1.4.4 Key Safety Objective 4: Providing an Efficient and Coordinated Response to Gas Emergencies Gas emergency events can occur due to insufficient supplies of gas of the correct quality into the network, or to a transportation constraint. In turn, these can be caused by damage to the networks or to a gas supply emergency due to a problem with supply entry points. GNI is required to demonstrate it has provisions for: Managing the response to localised gas emergencies Undertaking the role of National Gas Emergency Manager during network gas emergencies. Additionally, all gas undertakings must demonstrate they have suitable arrangements in place for responding to a large-scale network gas emergency. The KPIs for this objective are: Gas Supply Emergencies Public Reported Escapes Response Times. Gas Supply Emergencies There was one gas supply emergency the non-odourisation incident at the Corrib entry point (Section 1.2.8) that required initiation of the NGEP. Public Reported Gas Escapes Response Times GNI s commitment is to respond to 97% of reported gas escapes within one hour. In 2017, 99.91% were, compared to 99.9% in 2016. This equates to 14 out of 16,249 responses outside the one-hour response criterion. See Figure 7. Figure 7: Gas escape responses efficiency 30000 25000 20000 20332 19430 19569 18147 19406 19031 19449 17428 16249 15000 10000 5000 0 2009 2010 2011 2012 2013 2014 2015 2016 2017 Number of Public Reported Escapes % response within 1 hour 20 CRU Energy Safety Annual Report 2017
Gas Safety Regulatory Framework 1.4.5 Key Safety Objective 5: Minimising the Safety Risks Associated with the Use of Gas The GSF provides for a comprehensive regime to ensure that the safety risk from using gas is minimised. This objective addresses the safety risks associated with the connection and reconnection of customers installations to the gas supply network and their servicing. The KPIs for this regulatory objective are: Meters Carbon monoxide Safety disconnections. Meters Meters are monitored by reviewing meter-tampering incidents and meter joint gas escapes (see Figure 8) and by implementing the meter replacement programme. In 2017, 406 occasions of meter tampering were recorded, up 3% on 2016. GNI s Revenue Protection team, combined with gas meter inspections, continue to monitor possible incidents. During the works relating to the meter replacement programme in 2017, GNI identified 69 meter joint gas escapes, down 20% on 2016. Figure 8: Number of tampered meters identified 2000 1800 1600 1400 1200 1000 800 600 400 200 0 2009 2010 2011 2012 2013 2014 2015 2016 2017 Meter tampering events discovered Meter Joint Leaking Meter Replacement Programme The meter replacement programme continued during 2017, with 27,616 replacements compared to 23,668 in 2016. Since the beginning of the programme in 2011, GNI has replaced 198,344 meters. The meter replacement programme has greatly decreased the number of meter joint leakage events. The number of meter tampering events has been decreasing since the peak of the economic recession. Safety Disconnections Figure 9: Gas Networks Ireland safety disconnections at the meter 14000 12000 10000 8000 6000 6241 7429 6508 8006 11947 9784 8788 4000 2000 0 0 0 2009 2010 2011 2012 2013 2014 2015 2016 2017 Number of Disconnections NoHZ issued 21 CRU Energy Safety Annual Report 2017
Gas Safety Regulatory Framework On identification of an unsafe gas appliance or installation, GNI will isolate the gas supply and issue a Notice of Hazard (NoHZ) advising that an RGI make the necessary repairs. All issued NoHZs are because the gas installation does not conform to Irish standards (I.S. 813). However, an NoHZ does not always result in a disconnection: during 2017, there were 8,788 NoHZ issued to customers, 4,352 of which resulted in customers having supply of gas isolated. See Figure 9. 1.4.6 Key Safety Objective 6: Promoting Public Awareness of Gas Safety An objective of the CRU is to increase the public s awareness of gas safety in general, and of the dangers of carbon monoxide in particular. It is also important that owners and occupiers be cognisant of their responsibilities for the maintenance of gas fittings and appliances. Under the Gas Safety Regulatory Framework, responsibility for awareness-raising lies with both individual gas undertakings such as suppliers and with the industry as a whole. The CRU s role is to coordinate activities. As part of this role, the CRU chairs the Gas Safety Promotion and Public Awareness Expert Group, made up of distributers and suppliers of natural gas and LPG, alongside representatives of distribution/ transmission, industry, training, and government. The Expert Group oversees the development and review of national gas safety activities through developing programmes of media promotion, safety surveys, public awareness initiatives and promotions. The 2017 programme continued to focus on developing awareness of gas escapes, carbon monoxide, Dial Before You Dig and the RGI scheme, as outlined below. Gas escapes Natural gas escapes advertising campaign has run since 2014 Raising awareness of what to do/who to call if suspect a gas leak Targeting customers in natural gas supply areas Advertising activity in January, June, August, and October TV, radio and digital. To monitor public awareness and the effectiveness of advertising, all calls to the emergency gas escapes phone number are logged. During 2017, there were 25,107 calls, up from 23,191 in 2016. 65% of calls concerned gas escapes, with the remainder classified as related but non-emergency, regarding carbon monoxide or bill enquiries. Figure 10 demonstrates the success of the natural gas escapes publicity campaign begun in 2014. The proportion of genuine gas-escape emergency calls increased significantly in 2015, from 43% to 62%, and remained relatively steady in 2016 and 2017. From the 2017 promotional campaign, research shows that 64% of people have seen and could spontaneously recall adverts benchmarking well against advertising norms. 22 CRU Energy Safety Annual Report 2017
Gas Safety Regulatory Framework Figure 10: Calls to GNI gas escapes number in 2012 17 120% 100% 80% 60% 40% 20% 0% 2012 2013 2014 2015 2016 2017 Gas escape all non-emergency Carbon monoxide Raising awareness of dangers, signs, symptoms and preventative measures for CO Targeting all adults nationally Advertising activity in February, September (CO Week & bill insert) and October/November (i.e. the heating season) Tommy McAnairey is the popular CO spokesperson since 2014 TV, radio, press and digital. There were 1,012 calls to the carbon monoxide (CO) phone number and 66,364 visits to the website, carbonmonoxide.ie, during 2017, down 4% and 13% respectively on 2016. Figure 11 details results of a survey conducted on behalf of GNI. It shows the campaign has been a success: the percentage of homes with a CO alarm has increased steadily during the period of the Tommy McAnairey advertising campaign, from 25% in July 2014 to 65% at the end of 2017. Figure 11: Percentage of homes with audible CO alarms 2014 17 70% 60% 50% 40% 30% 20% 25% 32% 32% 38% 50% 48% 56% 54% 53% 59% 59% 65% 10% 0% Nov-13 Jun-14 Dec-14 Jul-15 Jan-16 Aug-16 Mar-17 Sep-17 Apr-18 23 CRU Energy Safety Annual Report 2017
Gas Safety Regulatory Framework Dial Before You Dig Targeting plant operators, construction contractors, small and large builders, planners, designers, local authorities, utilities, landowners and farmers Advertising activity in March and August (historical peak times for third-party damage) Trade press, digital GNI s Dial Before You Dig calendar issued to all landowners, and Golden Pages advertising. The Dial Before You Dig campaign has been running since 2009. It encourages anyone undertaking excavations to contact GNI to check whether they will be working in the area of gas pipelines. The campaign targets particular workers, which means the results of the general research on awareness levels is not applicable. Nevertheless, from a practical viewpoint, the campaign is very successful. Figure 12 shows an inverse correlation between the number of enquiries and reported incidents. The greater the number of enquiries received in a year, the lower the number of incidents, showing that Dial Before You Dig is an effective means of decreasing the level of third-party damage to gas pipelines. The numbers have tailed off since 2013, with 7,550 in 2017. GNI has recognised this, and a new campaign was launched at the start of 2018. Figure 12: Number of enquiries to Dial Before You Dig (n./10) and number of third-party-damage incidents, 2009 17 900 797.5 800 740.6 749.5 682 806.8 713.5 754.9 700 654.4 638.7 564 600 523 525 519 452 467 479 500 527 571 400 300 200 100 0 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 3rd party damage No. enquiries / 10 Notes: To assist comparison, the number of enquiries decreased by a factor of 10 (number of enquiries = n./10). Correlation: R² = 0.737, significance: p = 0.003083 24 CRU Energy Safety Annual Report 2017
Gas Safety Regulatory Framework RGI Scheme Raising awareness of the importance of using an RGI and how to find one Targeting existing and potential gas customers Advertising activity in March and October/November (generally following carbon monoxide) TV, radio, press and digital. A new advertising campaign for the RGI scheme started in 2016 and continued through 2017. This covered TV, press, radio and digital, featuring Daniel O Donnell. Figure 13 shows the increase in the Irish public s awareness of the RGI scheme and the importance of using an RGI. Before the Daniel O Donnell campaign, the number of people aware of the RGI scheme was around 55%. After the campaign began in 2016, this increased to 64%. Importantly, this number increases to 77% of people with natural gas in their home. Figure 13: Awareness of RGI scheme 25 CRU Energy Safety Annual Report 2017
Gas Safety Regulatory Framework 1.5 Continuous Improvement 1.5.1 Stakeholder Engagement The CRU holds regular meetings to discuss natural gas and LPG safety issues with stakeholders, including GNI, LPG undertakings, natural gas shippers and suppliers, RGII and the Department of Communications, Climate Action and Environment (DCCAE). Wider industry stakeholders, such as the National Standards Authority of Ireland (NSAI), the Health and Safety Authority (HSA), consumer groups and associations are also involved as required. The CRU attends the Gas Safety Committee alongside GNI, DCCAE, RGII and representatives from the LPG industry. The Committee met four times in 2017 to discuss gas-related incidents and associated issues in order to identify learning outcomes and to recommend any follow-up actions, which could improve safety outcomes. During 2017, the CRU and GNI attended the Distribution and Transmission Interface Group on a quarterly basis to discuss progress on all major safety-related work items and operational issues. In addition, there were ongoing TSO/DSO inspection verification meetings between the CRU and GNI and between the CRU and LPG undertakings to discuss issues arising from the CRU s audits and inspections. Members of the GSF team also visited the Finnish regulatory authority to learn about its experiences with incorporating biogas and CNG into its regulatory system. 1.5.2 Compressed Natural Gas (CNG) Under the Causeway Project 5, GNI plans to establish a network of fast-fill CNG refuelling stations for use in public and private transport. The CRU is responsible for regulating the safety of the GNI networks assets, while CNG suppliers are required to obtain a licence from the CRU to supply. As part of their licence application, they must submit a safety case for acceptance. The CRU published its revised Gas Safety Case Guidelines for Natural Gas & LPG Licensed Undertakings in May 2017 6, which incorporated CNG into the safety case regime. This followed extensive consultation and research into CNG refuelling stations. The CRU is currently assessing safety cases from Topaz Energy and GNI in relation to the first publicly accessible CNG stations, proposed for Dublin Port. 5 GNI (2018) The Causeway Project. 6 CER (2017) Gas Safety Case Guidelines for Natural Gas & LPG Licensed Undertakings. 26 CRU Energy Safety Annual Report 2017
Electrical Safety Supervision 27 CRU Energy Safety Annual Report 2017
Electrical Safety Supervision 2 Electrical Safety Supervision 2.1 Electrical Safety Supervisory Body (ESSB) Safe Electric 29 2.2 Enforcement 30 2.3 Electrical Safety Promotion and Public Awareness 31 2.4 Transition of the National Wiring Rules from ETCI to the NSAI 32 28 CRU Energy Safety Annual Report 2017
Electrical Safety Supervision The CRU has a statutory obligation to regulate the activities of electrical contractors. It fulfils this through the single Electrical Safety Supervisory Body (ESSB). Following a competitive public procurement process, the Register of Electrical Contractors of Ireland Ltd (RECI) has operated as the ESSB from January 2016. Its contract runs until 2022. 2.1 Electrical Safety Supervisory Body (ESSB) Safe Electric Under the Safe Electric brand, RECI s aim is to protect the safety interests of customers of electrical installers. It does this through managing the Register of Electrical Contractors. A Registered Electrical Contractor (REC) is a company employing one or more Qualified Certifier (QC). It is mandatory for RECs to issue a Completion Certificate for all electrical works (excluding minor works, unless requested by the customer). Only the REC s named QC can sign-off electrical work. RECs and QCs must adhere to the Rules of Registration covering training, competence, inspection and audit, insurance and completion certificates. Safe Electric monitors and validates whether electrical works meet safety standards. The total number of RECs on the Safe Electric register at the end of 2017 was 4,153, down slightly on the 4,213 registered in 2016. For QCs, there were 5,215 registered at the end of 2017, up on 4,829 at the beginning of the year. A complete list of RECs is available at the Safe Electric website: safeelectric.ie. 2.1.1 Inspections of RECs Safe Electric submits an annual audit and inspection programme, and reports quarterly on Safety and Compliance statistics for approval by the CRU. 2016: 4,213 Registered Electrical Contractors 5,215 Qualified Certifiers 2017: 4,153 Registered Electrical Contractors 4,829 Qualified Certifiers New RECs are required to have two inspections in their first year of registration, followed by at least one a year. In 2017, Safe Electric carried out 4,740 inspections on RECs. Although less than the planned 5,121, the number of inspections is up 8% compared to 2016. RECs not inspected in 2017 are prioritised for 2018. 2.1.2 New Performance Management Framework for RECI The CRU requires assurance that RECI is fulfilling its obligations as detailed in the Criteria Document and the Terms and Conditions of Appointment. It has developed a Performance Management Framework 9 under which RECI reports quarterly against a series of KPIs and supporting metrics. In order to further improve monitoring and ensure RECI is performing its core functions, the KPIs were reviewed and a new performance framework introduced for 2017. 7 6 9 Functions are set out in the 1999 Act, the Electrical Safety Supervisory Criteria document V 3.0 (CER/16/001), and the Terms and Conditions of Appointment. CER (2016) Criteria for the Regulation of Electrical Contractors. CER (2008) Economic Regulation of the Gas Safety Supervisory Body and any Electrical Safety Supervisory Bodies to be designated by the CRU. 29 CRU Energy Safety Annual Report 2017
Electrical Safety Supervision This centres on eight KPIs detailing progress on: 1. Inspection and auditing of RECs (3 KPIs) 2. Registration applications and return of certificates (3 KPIs) 3. Complaint resolution (2 KPIs). As the KPIs are new, it will take time to gather metrics to show what adjustments need to be made to improve performance. The CRU will continue to work closely with RECI to address the failed KPIs, so that performance improves throughout 2018. 2.2 Enforcement Since October 2013, it is a criminal offence for an individual or company to undertake certain electrical works without registration, to describe themselves as an REC or to incorrectly suggest they are an REC. Doing so could result in a fine of up to 15,000 or imprisonment for up to three years, or both. The CRU undertakes investigations into reports alleging illegal electrical works. During 2017, it commenced 78 investigations, with four successful prosecutions. The status of the remaining reports is under investigation or not prosecuted due to lack of evidence that an offence had occurred in Ireland. Case Study 2: Electrical works enforcement Following a complaint alleging illegal works, the CRU undertook an investigation that found evidence of gas and electrical works carried out by unrestricted contractors. The case against the two accused was put before Dublin District Court in April 2017. One contractor submitted a guilty plea and was convicted for all three offences listed on his summons, namely illegal electrical works, illegal gas works, and falsely portraying himself as an RGI. He was ultimately fined 300 and made compensation to the plaintiff of 3,300. The CRU will continue to carry out investigations and take enforcement actions, including interviews of suspected illegal electrical contractors, cease-and-desist warning letters, and prosecutions. 30 CRU Energy Safety Annual Report 2017
Electrical Safety Supervision 2.3 Electrical Safety Promotion and Public Awareness The CRU runs an annual Safe Electric public awareness campaign across a range of media. The main messages are to highlight that only RECs should carry out most domestic electrical works and to ensure they issue a Certificate of Completion. Publicising that only RECs should carry out most electrical works in the home Main target are homeowners Advertising activity in March and October/November TV, radio, press and digital NOT ALL COWBOYS RIDE HORSES Always: Use a Registered Electrical Contractor Ask for a Completion Certificate Survey research of the 2017 campaign shows it was successful across a number of metrics. 60% of people are aware of the Safe Electric logo, up 16% from before the campaign. In addition, four in 10 know that the scheme means only a REC should carry out major works. See Figure 14. ROI only. Figure 14: Overall campaign awareness 31 CRU Energy Safety Annual Report 2017
Electrical Safety Supervision The publicity around Safe Electric carried through to practical results. 84% of people having electrical work carried out in 2017 had it done by an REC: the biggest percentage so far. Moreover, the registration status of an electrical contractor is the number one criterion when making a decision on who to hire for electrical work, up 8% from 2016. 2.4 Transition of the National Wiring Rules from ETCI to the NSAI In 2009, the CRU and the Electro Technical Council of Ireland (ETCI) agreed a memorandum of understanding which stated that the CRU would prescribe the certification system developed and implemented by ETCI. 4,153 Following a review of the regulatory scheme for electrical contractors in 2014, to ensure the continued development of the National Wiring Rules, the CRU decided funding should be via the National Standards Authority of Ireland (NSAI), and to transfer the printing and sale of certificates from ETCI to Safe Electric. In 2017, this NSAI has assumed direct responsibility for the maintenance and development of the national system of electrical installation standards. The CRU recognises and appreciates the significant contribution made by ETCI members in electrical safety while operating largely on a voluntary basis. 60% of people are aware of the Safe Electric logo Corri 84% of people having electrical work carried out in 2017 used a Registered Electrical Contractor 32 CRU Energy Safety Annual Report 2017
Petroleum Safety Supervision 33 CRU Energy Safety Annual Report 2017
Petroleum Safety Supervision 3 Petroleum Safety Supervision 3.1 Safety Permit Application Assessments 35 3.2 Safety Performance Reporting 36 3.3 Reporting 37 3.4 Audits and Inspections 38 3.5 Enforcement 39 3.6 Decommissioning 39 3.7 Public Request for Safety Case 39 3.8 Engagement with Irish Agencies 39 3.9 Engagement with Industry 40 3.10 International Engagement 40 34 CRU Energy Safety Annual Report 2017
Petroleum Safety Supervision The Petroleum Safety Framework (PSF) sets out the basis on which the CRU regulates the safety of onshore and offshore petroleum activities, including oil and gas exploration and production. This section outlines the work the CRU undertook to assess and monitor the designated activities of the petroleum industry in 2017. 3.1 Safety Permit Application Assessments Three production safety permits were live in 2017: SP08A for PSE Kinsale Energy Ltd (issued 2016): Kinsale Head, Ballycotton and Southwest Kinsale gas field SP09A for PSE Kinsale Seven Heads Ltd, Island (Seven Heads) Ltd (Sunningdale Oils Ireland Ltd) (issued 2016): Seven Heads gas field SP01C for Shell E&P Ireland Ltd (SEPIL), Statoil Exploration (Ireland) Ltd and Vermilion Energy Ireland Ltd (issued 2017): Corrib gas field. Corrib Gas Field Galway Dublin In addition, three Acknowledgements of Compliance (AoC) were in place in 2017: AoC-02 for the Ocean Valiant (issued 2016) AoC-03 for the Ocean Guardian (issued 2016) AoC-04 for the Stena IceMAX (issued 2017). Limerick Cork Kinsale Head Gas Field Seven Heads Gas Field The CRU received three safety permit applications and two AoC applications in 2017. Two of the safety permit applications were material changes to accepted safety cases. One AoC application was still under assessment at the end of 2017 (see Table 4). Table 4: Details of the AoC and safety permit applications received by CRU in 2017 Safety Permit Type Application date Petroleum Undertaking(s)/Owners Application Status Well Work January 2017 Providence Resources Capricorn Ireland Sosina Exploration Ltd Well Work (material change) Production (material change) Acknowledgement of Compliance Acknowledgement of Compliance July 2017 February 2017 Providence Resources Capricorn Ireland Sosina Exploration Ltd SEPIL Statoil Exploration (Ireland) Ltd Vermilion Energy Ireland Ltd SP12 issued June 2017 SP12A issued July 2017 SP01C issued April 2017 (superseded SP01B) January 2017 Stena Drilling Ltd AoC-04 issued June 2017 May 2017 Helix Well Ops (UK) Ltd In assessment 35 CRU Energy Safety Annual Report 2017
Petroleum Safety Supervision 3.2 Safety Performance Reporting Petroleum undertakings, operators and owners are required to submit safety performance reports to the CRU within six weeks of the end of the reporting quarter, or, where related to a well work safety permit, two weeks after cessation. These reports set out leading and lagging safety performance indicators. The Compliance Assurance System document provides a full list. The following figures illustrate the combined leading (Figure 15) and lagging (Figure 16) production safety performance indicators reported to the CRU in 2017. Individually, the data sets received by the CRU from the production operators did not identify any specific safety concerns, and any queries raised from the assessment of the data received were adequately responded to by the operator/owner. A full description of all safety performance indicators can be found in Appendix 1. Figure 15: Total number of leading production safety performance indicators submitted to CRU in 2016 and 2017. ID Leading Safety Performance Indicator Production Activities L1 Number of anomalies raised by Independent Competent Bodies in the quarter 57 0 L2 Number of verification anomalies that were not closed-out by the planned due date at the end of the quarter 57 0 L3 Number of verification reservations raised by the operator or owner in the quarter. 0 0 L4 L5 Number of Safety and Environmental Critical Elements (S(E)CEs) with overdue preventative maintenance at the end of the quarter. Number of S(E)CEs maintenance hours required to clear any backlog in safety performance indicator L4. 96 10 965 200 L6 Number of live operational risk assessments at the end of the quarter. 16 0 L7 Number of planned emergency drills not carried out within the quarter. 965 200 Well Work Activities ID A3 A4 Leading Safety Performance Indicator Number of unintentional releases of not ignited liquid of petroleum hydrocarbon if mass released 60 kg Number of unintentional releases or escapes of any non-petroleum hazardous substance Production Activities 2 0 2 0 B3 Number of instances of a mechanical failure of any part of a well 1 0 C1 C2 C3 H1 H3 Number of instances of an S(E)CE not meeting its performance standard, requiring Immediate Remedial Action Number of instances of an S(E)CE not meeting its performance standard, not reportable under C1 Number of activations of an S(E)CE except where testing and/or maintenance is being carried out. Number of serious injuries to workers resulting from a designated petroleum activity; Number of injuries to workers where: the person could not perform all of their normal work activities for more than 3 consecutive days or treatment at hospital 4 1 57 3 16 0 1 0 3 0 I Number of work related evacuations of personnel 1 0 L N Number of instances of a stand-by vessel not being within its defined geographical area, irrespective of prevailing weather or climate conditions. Number of occurrences of mustering on onshore or offshore petroleum infrastructure, other than for planned drills 1 0 6 0 Well Work Activities 10 Leading safety performance indicators are produced from active monitoring of risk reduction measures to ensure their continued effectiveness; and lagging safety performance indicators relate to incidents as defined in the Petroleum Safety (Petroleum Incident) Regulation and Guidance for Notification of Incidents (CER/16/016). 36 CRU Energy Safety Annual Report 2017
Petroleum Safety Supervision Petroleum undertakings, operators and owners are subject to ongoing regulation by the CRU through its compliance assurance activities. The CRU reviews, records and trends all data submitted by petroleum undertakings, operators and owners submitted in safety performance reports. The trends identified in Figures 15 and 16 are broadly in line with previous years. Assessment of the safety performance reports of 2017 has not identified any additional safety issues for the CRU. The CRU s 2016 Annual Safety Report explains the increase in Leading Indicator L5 (maintenance hours): Following investigation, the apparent increase in time spent maintaining SECEs was found to be the result of the operator working to a different definition of backlog in previous years than that used by the CER. Once this was corrected by the operator the number of hours subsequently appeared to have risen significantly. On receipt of this information, the CER required no further action. 3.3 Reporting When an incident occurs, operators and owners are required to submit a notification immediately to the CRU. Each petroleum incident notification is reviewed, and a determination is made as to the extent of incident investigation required. 3.3.1 Petroleum Incident Reporting As with the safety performance reports (see Section 3.2), the CRU reviews petroleum incidents as part of its overall regulation of petroleum activity. In 2017, 17 petroleum safety incidents were notified to the CRU, one more than in 2016. Table 5: Number and type of petroleum incidents submitted to the CRU in 2017 Incident Type A Unintended release of oil, gas or other hazardous substances, whether or not ignited 4 B C Loss of well control requiring actuation of well control equipment, or failure of a well barrier requiring its replacement or repair Failure of a safety (and environmentally) critical element: Any loss or non-availability of a S(E)CE requiring Immediate Remedial Action H Any serious injury 1 I Any evacuation of personnel 1 N Mustering on onshore or offshore petroleum infrastructure, other than for planned drills. 6 Total incidents in 2017 17 Number reported 1 4 One of the Type C incidents shown in Table 5 led to a full investigation by the CRU and Stena Drilling (the owner). While the initial incident in August 2017 did not result in a major accident, on further investigation it became clear there was potential for a more significant incident. 11 The petroleum incidents reported to CRU are set out in S.I. 166/2016, Petroleum Safety (Petroleum Incident) Regulations 2016. The guidance on reporting under the 2016 regulations is provided in the CRU Guidance for Notification of Incidents. 37 CRU Energy Safety Annual Report 2017
Petroleum Safety Supervision The subsequent investigation included discussions with the Bureau of Safety and Environmental Enforcement (BSEE) in the United States, who had experience of similar issues. International and European regulators were kept informed of the incident through safety alerts highlighting the root cause of the incident. All remaining incidents were addressed to the satisfaction of the CRU without immediate investigation. Where necessary, follow-ups were combined with planned inspections. See Section 3.5 for more detail. 3.3.2 European Commission Reporting In common with offshore petroleum safety regulators across the EU, the CRU is required to submit an annual report to the European Commission relating to specific petroleum incidents 12. Submission of the first report, covering 2016, was in June 2017 13. There were no reportable incidents in Ireland in 2016. 3.4 Audits and Inspections In order to assess compliance with the safety permit, the CRU develops an annual audit and inspection plan for each production facility as shown in Table 6. In 2017, the CRU carried out five planned inspections and six following up on enforcement actions, with one planned inspection postponed until 2018. A further safety case assessment inspection was carried out on a non-production drill ship. It should be noted that a single enforcement action can result in multiple enforcement inspections in order to address and close out the issue to the satisfaction of the CRU. Table 6: Number of audits and inspections planned and carried out in 2017. Safety Case Inspection Type Number Kinsale Energy Production - SP08/09A Planned Inspections 2 1* SEPIL Corrib Production SP01 Unscheduled Inspections 6 Planned Inspection 2 Stena IceMAX - AoC 04 Unscheduled Inspections 1 Safety Case Assessment Inspection 1 *Inspection postponed until 2018 Reports of Audit and Inspection (ROAIs) are issued to the petroleum undertakings/operators as appropriate. The recipients must submit a plan to the CRU for addressing the findings set out in the ROAIs within one month of receipt. The CRU tracks the findings of the inspections as part of its ongoing monitoring function. This ensures that all actions and findings are closed out. 12 EC (2014) Commission Implementing Regulation (EU) No 1112/2014 of 13 October 2014 determining a common format for sharing of information on major hazard indicators by the operators and owners of offshore oil and gas installations and a common format for the publication of the information on major hazard indicators by the Member States Text with EEA relevance. 13 CER (2017) Incident Data and Performance of Offshore Operations. 38 CRU Energy Safety Annual Report 2017
Petroleum Safety Supervision 3.5 Enforcement In accordance with the Act, the CRU may issue enforcement actions on the grounds of non-compliance with a safety permit. Where the CRU identifies a breach, after activities such as an audit and inspection or after an incident, the CRU decides on the appropriate enforcement action depending on its seriousness. In 2017 the CRU carried out an inspection at Bellanaboy Bridge Gas Terminal for the Corrib gas field terminal in County Mayo. Following investigation, the CRU issued a Prohibition Notice to SEPIL, Statoil Exploration and Vermillion Energy Ireland Ltd against safety permit SP01B, relating to the petroleum incident of the unintended release of oil, gas or other hazardous substances type. The prohibition notice specified the actions proposed to return the activity to a state of compliance. Following a further inspection, the CRU was satisfied with the remedial action. The CRU also issued a Direction to Submit an Improvement Plan against SP01C in 2017 following the Corrib incident (noted in Section 1.2.8). The non-compliance related to the undertaking failing to ensure that all task instructions were complete or fit for purpose in identifying and documenting safety-critical tasks. Following a review of the Improvement Plan, the CRU agreed to the remedial action proposed by the undertaking. This work continued into 2018. 3.6 Decommissioning In 2017, PSE Kinsale Energy Ltd notified the CRU of its intent to decommission and permanently plug wells at its production facilities covered by safety permits SP08A and SP09A. In preparation, Kinsale submitted a preliminary well work Safety Case for review by CRU. The assessment continued into 2018. Formal applications to the CRU will follow. 3.7 Public Request for Safety Case The CRU received a request for a public version of a safety case from SEPIL in 2017. The CRU began its process for assessing such a request in accordance with the guidance set out in the Requirements of the Petroleum Safety Framework 14. This process continued into 2018. 3.8 Engagement with Irish Agencies The CRU interacts with the Irish Coast Guard (IRCG) on a regular basis. Part of this work is around oil-spill contingency plans: the Requirements of the Petroleum Safety Framework and the European Offshore Safety Directive 15 state that to issue a safety permit the CRU requires the IRCG s acceptance of plans. Under this new process, in 2017 the IRCG participated in the CRU safety case assessment for submitted offshore safety cases. 14 CER (2016) Requirements of the Petroleum Safety Framework. 15 EC (2013) Directive 2013/30/EU on safety of offshore oil and gas operations. 39 CRU Energy Safety Annual Report 2017
Petroleum Safety Supervision 3.9 Engagement with Industry The PSF continued to hold meetings with the Irish Offshore Operators Association (IOOA) in 2017. These meetings facilitated information-sharing on safety regulation aspects of the petroleum industry in Ireland. Furthermore, the CRU held a number of safety case pre-submission meetings with oil and gas exploration companies to discuss prospective drilling campaigns. 3.10 International Engagement To ensure regulation meets international best practice, the CRU continued to engage with national and international regulators and governmental agencies throughout 2017. 3.10.1 North Sea Offshore Authorities Forum (NSOAF) The CRU continued its participation with European safety regulators through the North Sea Offshore Authorities Forum (NSOAF). This included attendance at the plenary meeting and hosting the Wells Working Group and EU Legislation Network. The CRU also carried out a multi-nation audit in conjunction with other European regulatory authorities as part of the NSOAF. The topic of the audit was Maintaining Safe Operation, with emphasis on ageing offshore installations that if possible had experienced a change in operatorship. Full results will be published in 2018. 3.10.2 European Offshore Authorities Group (EUOAG) The CRU is one of the Irish representatives at the European Offshore Authorities Group (EUOAG). As well as attending meetings, the CRU continued to provide support to a fellow European member state by facilitating participation on a CRU production inspection in 2017. The CRU also consulted with the BSEE, the Canada-Nova Scotia Offshore Petroleum Board and the Canada-Newfoundland and Labrador Offshore Petroleum Board as part of its international co-operation and knowledge sharing. Interactions with groups such as the NSOAF, the EUOAG and international regulators ensure the CRU regularly shares knowledge with European and international counterparts to maintain high standards of safety regulation. 40 CRU Energy Safety Annual Report 2017
ACRONYMS AGI ALARP AoC BSEE CO DCCAE DSO ESSB EUOAG GNI GSSB HSA KPI LPG MoU NGEP NoHZ NSAI NSOAF PAPA PRE QRA REC RECI RGI RGII RuG SCADA SECE SP TSO Above Ground Installation As Low As Reasonably Practicable Acknowledgment of Compliance Bureau of Safety and Environmental Enforcement Carbon Monoxide Department of Communications, Climate Action and Environment Distribution System Operator Electrical Safety Supervisory Body European Offshore Authorities Group Gas Networks Ireland Gas Safety Supervisory Body Health and Safety Authority Key Performance Indicator Liquefied Petroleum Gas Memorandum of Understanding Natural Gas Emergency Plan Notice of Hazard National Standards Authority of Ireland North Sea Offshore Authorities Forum Promotion and Public Awareness Public Reported (Gas) Escape Quantitative Risk Analysis Registered Electrical Contractor Registered Electrical Contractors of Ireland Limited Registered Gas Installer Registered Gas Installers of Ireland Limited Reportable under Guidelines Supervisory Control and Data Acquisition Safety and Environmentally Critical Element Safety Permit Transmission System Operator 41 CRU Energy Safety Annual Report 2017
APPENDIX Table 7: Leading Safety Performance Indicators under the PSF (2017) ID L1 L2 L3 L4 L5 Leading Safety Performance Indicator Number of anomalies raised by Independent Competent Bodies in the quarter Number of verification anomalies that were not closed-out by the planned due date at the end of the quarter Number of verification reservations raised by the operator or owner in the quarter. Number of Safety and Environmental Critical Elements (S(E)CEs) with overdue preventative maintenance at the end of the quarter. Number of S(E)CEs maintenance hours required to clear any backlog in safety performance indicator L4. Production Activities 57 0 57 0 0 0 96 10 965 200 L6 Number of live operational risk assessments at the end of the quarter. 16 0 L7 Number of planned emergency drills not carried out within the quarter. 965 200 Well Work Activities Table 8: Lagging Safety Performance Indicators under the PSF (2017) ID Leading Safety Performance Indicator Production Activities A1 Number of unintentional releases of ignited gas or petroleum liquid 0 0 A2 A3 A4 Number of unintentional releases of not ignited natural gas or evaporated associated gas if mass released 1kg Number of unintentional releases of not ignited liquid of petroleum hydrocarbon if mass released 60 kg Number of unintentional releases or escapes of any non-petroleum hazardous substance 0 0 2 0 2 0 B1 Number of blowouts 0 0 B2 Number of activations of a blowout prevention or diverter system to control flow of well-fluids 0 0 B3 Number of instances of a mechanical failure of any part of a well 1 0 B4 Number of unintentional releases of ignited gas or petroleum liquid 0 0 C1 C2 C3 D Number of instances of an S(E)CE not meeting its performance standard, requiring Immediate Remedial Action Number of instances of an S(E)CE not meeting its performance standard, not reportable under C1 Number of activations of an S(E)CE except where testing and/or maintenance is being carried out. Number of instances where Immediate Remedial Action was required due to significant loss of structural integrity or station keeping 4 1 57 3 16 0 0 0 E1 Number of potential vessel collisions with any petroleum infrastructure 0 0 E2 Number of vessel collisions with any petroleum infrastructure 0 0 F1 Number of potential helicopter accidents within the safety zone 0 0 F2 Number of helicopter accidents within the safety zone 0 0 G1 Number of worker fatalities resulting from a designated petroleum activity 0 0 Well Work Activities 42 CRU Energy Safety Annual Report 2017
Table 8 contd. ID G2 H1 H2 H3 Leading Safety Performance Indicator Number of non-worker fatalities resulting from a designated petroleum activity Number of serious injuries to workers resulting from a designated petroleum activity; Number of serious injuries to non-workers resulting from a designated petroleum activity; Number of injuries to workers where: the person could not perform all of their normal work activities for more than 3 consecutive days or treatment at hospital Production Activities 0 0 1 0 0 0 3 0 I Number of work related evacuations of personnel 1 0 J Number of major environmental incidents 0 0 K Number of uncontrolled fires or explosions 0 0 L Number of instances of a stand-by vessel not being within its defined geographical area, irrespective of prevailing weather or climate conditions. 1 0 M Number of instances of a person falling into the sea 0 0 N O P Number of occurrences of mustering on onshore or offshore petroleum infrastructure, other than for planned drills Number of occurrences of detection of hydrogen sulphide in the course of operations at a well Number of occurrences of the collapse, overturning, or failure of any load-bearing part of any lift, hoist, crane, or derrick 6 0 0 0 0 0 Q Number of instances damage to third party property 0 0 R S Number of occurrences of the dropping of an object that could have resulted in a major accident. Number of instances of a collision by a vehicle, crane or aircraft with any petroleum infrastructure 0 0 0 0 Well Work Activities 43 CRU Energy Safety Annual Report 2017