17.

0 Health and Safety Risk Management

Summary

A number of potential hazards will be introduced into the existing environment with the
development of the Kupe Gas Project. Potential hazards have been evaluated and
mitigation measures have been identified. Robust management plans together with
appropriate design will minimise the potential risks to the environment, workers, and the
local community.

A review of the Hazardous Facilities Screening Procedure (HFSP) was undertaken for the
Production Station in accordance with the partially operative South Taranaki District Plan
(STDP) (Sept 2003), which confirmed that the operations planned for the site are classed
as a Discretionary Activity.

17.1 Introduction

The scope of this assessment has been limited to 12 nautical miles offshore to be
comparable to the Resource Management Act (1991). This section assesses the potential
risks to the health and safety of the community surrounding the Kupe Gas Project.

17.2 Governing Legislation

The following Acts need to be considered when accessing the health and safety risks of
the Project to the environment, workers, and the local community:
• Hazardous Substances and New Organisms Act 1996 – which governs the Storage
of Hazardous Substances
• Transport Amendment Act 1997 – which governs the transport of Hazardous
Substances
• Health and Safety in Employment Act 1992 – which governs employee health and
safety at construction sites and operating sites.

17.3 Hazardous Materials

17.3.1 Hazardous Materials Management

As with all petrochemical facilities, the Kupe Production Station will contain hazardous
chemicals. These include (but are not limited to) the following:
• gas and liquid hydrocarbons
• anti-foaming agent
• biocide

Section 17 – Health and Safety Risk Management Page 17-1

 • tri-ethyl glycol
• hydrate inhibitor (methanol)
• amine
• liquid nitrogen
• water treatment chemicals
• corrosion inhibitor
• odourant (mercaptan)
• de-emulsifier
• reverse de-emulsifier
• drilling mud and associated additives (used during horizontal directional drilling)
• lubricants (oils and greases)
• oxy-acetylene gases (for maintenance purposes)
• diesel.

Chemicals On-Site
The operation of the Production Station requires a numbers of chemicals to be stored on-
site. Typical quantities and the expected delivery rates for chemicals stored on-site are
provided in Appendix E.

A dedicated purpose built hazardous chemical storage area will be used to store these
chemicals away from the general staff area and process facilities. Material Safety Data
Sheets for all relevant chemicals will be available for inspection following completion of
the detailed design of the Production Station.

Transportation
There will be a requirement to transport chemicals to and from the site for operational
purposes, as well as from the site (e.g. movement of LPG, potential movement of
Condensate or other hydrocarbon liquids, and waste chemical to approved waste disposal
facilities). The risks posed by transportation accidents include: injury, possible death as
a direct result of accident, potentially short-term evacuations, and loss of chemicals to
the environment.

The transport and Storage of all hazardous materials will be in compliance with the
Hazardous Substances and New Organisms Act 1996 and Transport Amendment Act 1997.

17.3.2 Hazardous Facilities Screening Procedure

A Hazardous Facilities Screening Procedure (HFSP) has been undertaken for the
Production Station in accordance with the South Taranaki District Plan (STDP, September
2003). The HFSP work sheets are presented in Appendix E.

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The HFSP is used to analytically screen potentially hazardous facilities and their sites.
This planning tool is used to categorise whether a site’s risk exceeds a certain threshold.
These are set out in Table 17.1. The value of the ‘Effects Ratio’ is only used to determine
if the activity is permitted or discretionary under the District Plan. If the risk is below
the threshold then the activity is permitted, otherwise consent is required.

First the risk level for the site is established then the zoning of the site is taken into
account to determine the status of the proposed activity. The HFSP is applied to
hazardous facilities in all zones and in addition to other zone-specific rules.

Table 17-1: South Taranaki District Council HFSP activity matrix

Zone Activity Status

Permitted Discretionary
Residential ≤ 0.05 > 0.05
Commercial Rural ≤ 0.25 > 0.25
Industrial ≤ 0.50 > 0.50

The HFSP confirms that the operations planned for the Production Station site are a
Discretionary Activity under the STDP.

17.4 Site Design

The design and layout of the Production Station in relation to workers health and safety,
the management of hazardous materials, and off-site effects is based on a series of
design guidelines that produce a safe operating environment. The primary safety
concern is the management of potential hydrocarbon discharges that may result in fire or
explosion.

All vessels containing hydrocarbons will be designed to recognised standards and codes of
practice that are accepted in New Zealand. The design of the Production Station includes
appropriate plant design, monitoring systems, and emergency systems (e.g. fire fighting
systems, emergency flare, etc.).

17.5 Hazards and Risk

The occupational health and safety risks to contractors and operators of the Kupe Gas
Project will be managed in accordance with the Health and Safety in Employment Act
1992. Each contractor will develop their own Health and Safety Plan that will mesh with
the overarching Kupe Gas Project Health and Safety Plan.

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The design of the Hazardous Goods store will comply with requirements of Hazardous
Substances and New Organisms Act 1996 (HSNO). An appropriate environmental
management programme will be developed and will include details on the operation of
the hazardous goods store and emergency procedures should a spill, fire, or explosion
occur.

Figure 17-1 : A lifeboat on Maui A Platform

Photo: Rob Tucker

The potential hazards, as a result of the construction and operation of the Kupe Gas
Project, need to be managed. The methodology used to identify risks and potential
mitigation measures is that of the Taranaki Civil Defence Emergency Management Group
(TRC, 2004d).

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Risk issues not considered in this section because they are beyond the 12 nautical miles
limit include:
• risks associated with offshore drilling
• risks associated with the installation, operation or decommissioning of the
offshore platform.

A Hazard and Risk Analysis was undertaken on the potential hazards associated with the
three phases of the Kupe Gas Project: construction, operation, and decommissioning.

The New Zealand Standard for risk management, the NZS4360 model, was used to
identify the likelihood and consequence of the effect for each potential hazard. The
‘level’ of risk is a combined result of both likelihood and effect resulting in each hazard
having a low, moderate, high or extreme level of risk. The following three tables present
the likelihood, consequence and risk descriptors.

Table 17-2: Measure of likelihood

Level Descriptor Description

A Almost Certain
B Likely
C Possible
D Unlikely
E Rare
Is expected to occur in most circumstances
Will probably occur in most circumstances
Might occur at some time
Could occur at some time
May occur only in exceptional circumstances

Table 17-3: Measure of consequence

Level Descriptor Description

1 Insignificant
2 Minor
3 Moderate
4 Major
5 Catastrophic
No injuries. Little or no damage, low financial loss
First aid treatment, minor building damage, medium financial loss
Medical treatment required, moderate building and infrastructure
damage, high financial loss
Extensive injuries, high level of building and infrastructure damage,
major financial loss
Death, most buildings extensively damaged major and infrastructure
failure, huge financial loss

Section 17 – Health and Safety Risk Management Page 17-5

Table 17-4: Level of risk

1 2 3 4 5
Likelihood Insignificant Minor Moderate Major Catastrophic
A – Almost Certain High High Extreme Extreme Extreme
B – Likely Moderate High High Extreme Extreme
C – Possible Low Moderate High Extreme Extreme
D – Unlikely Low Low Moderate High Extreme
E – Rare Low Low Moderate High High

The following assessment of Health and Safety risks is based on both quantitative and
qualitative data (refer to Table 17-5).

Page 17-6 Section 17 – Health and Safety Risk Management

Table 17-5: Hazard and risks

Activity Hazard Risk Likelihood Effect Level of Risk

General Construction Accidental Spill Fuel, Oil, and Chemical spills C 2 Moderate
Vehicle Accidents Fuel, Oil, and Chemical spills B 2 High
Pipeline Operation Accidental damage (external) Spill of product into surface water C 3 High
Loss of product onto or into the ground C 2 Moderate
Fire / Explosion C 2 Moderate
Corrosion Damage Spill of product into surface water C 3 High
Loss of product onto or into the ground C 2 Moderate
Fire / Explosion C 2 Moderate
Equipment / Operation Failure Spill of product into surface water D 3 Moderate
Loss of product onto or into the ground D 3 Low
Fire / Explosion D 3 Low
Production Station Liquid hydrocarbon leak Spill of product into surface water D 3 Moderate
Operation Fire / Explosion C 2 Moderate
Gaseous hydrocarbon leak Fire / Explosion C 2 Moderate
Condensate and LPG tanker loading Spill of product into surface water D 3 Moderate
Fire / Explosion C 2 Moderate
Accidental loss of liquid Hazardous Spill of product into surface water D 3 Moderate
material stored on-site Fire / Explosion C 2 Moderate
High winds / hurricane Spill of product into surface water D 3 Moderate
Fire / Explosion C 2 Moderate
Transport of LPG and/ or Vehicle accidents / collisions Spill of product into surface water C 3 High
condensate Fire / Explosion C 3 High
Discharge of process Accidental damage to pipe carrying Loss of process water to ground and surface water C 3 High
water process water to well Discharge of process water to potable aquifer D 3 Moderate
Pipelines Accidental failure resulting in a spill Fuel, Oil D 3 Moderate

Section 17 – Health and Safety Risk Management Page 17-7

17.6 Risk Mitigation

Appropriate design and management of the Kupe Gas Project is crucial to avoid, remedy,
or mitigate potential risks. The design and layout of the Production Station in relation to
workers health and safety, the management of hazardous materials and off-site effects is
based on a series of design guidelines that produce a safe operating environment.
Management Plans are covered in more detail in the Environmental Management Systems
chapter. Key aspects of the management plans are outlined below.

17.6.1 Construction Phase

The Kupe Gas Production Station Construction Plan and Pipeline Construction Plan will
identify potential risks. Design features (e.g. bunded areas) will provide a level of
protection but contingency plans will be developed should the following occur:
• chemical or fuel spills
• vehicle accidents resulting in chemical or fuel spills.

17.6.2 Operation Phase

Management Plan – Production Station

A Management Plan will be produced for the Production Station, prior to the
commencement of operation, which will identify safety features contained in the plant’s
design and operation. Features of the plan will include:
• compliance with recognised standards and Codes of Practice
• hazardous substances will be located and stored in accordance with Hazardous
Substances and New Organisms (HSNO) regulations
• a spill response plan for use in the event of a spill. Key to this will be the
development of management and monitoring systems to minimise the effect of
spills.
• a fire protection system
• smoke, fire and gas detection integrated into an alarm system
• response to vehicle accidents which result in chemical or fuel spills
• condensate and LPG safety systems (e.g. isolated from the rest of the plant to
improve safety, fire protection systems, etc)
• a sediment control plan.

The design and operation will meet the requirements of the Chief Inspector of Dangerous
Goods in terms of separation and fire protection.

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Pipeline Operation Management Plan
Once a pipeline has been commissioned it will be subject to ongoing routine monitoring.
Contingency plans, easement management and monitoring will all be included in the
Pipeline Operations Management Plan. It will also include the following:
• automatic monitoring of pressure fluctuations in the pipe
• spill plans for both spills onshore and offshore
• regular monitoring of cathode protection test points to detect faults in the pipe’s
coating systems
• regular maintenance inspections
• regular monitoring of easement.

17.7 Conclusion and Recommendations

A number of potential hazards will be introduced into the existing environment with the
development of the Kupe Gas Project. Potential hazards have been evaluated and
mitigation measures have been identified and will be covered in a range of management
plans for the construction and operation phases.

It is expected that robust management plans, developed in conjunction with appropriate

design, will minimise the potential risks to the public and the environment. The
following management plans will be implemented:
• Production Station Construction Plan
• Pipeline Construction Plan
• Production Station Management Plan
• Pipeline Operation Management Plan.

A review of the HFSP was undertaken for the Production Station in accordance with the
partially operative STDP (Sept 2003), which confirmed that the operations planned for
the site are classed as a Discretionary Activity.

The potential risks introduced into the South Taranaki region by the Kupe Gas Project are
similar to those posed by other petrochemical activities in the area (such as the Kapuni,
Maui, Pohokura and Rimu Production Stations). The risks are well known and can be
managed. New facilities can implement more advanced management plans than existing
facilities based on the experience gained at these other facilities.

No risks have been identified which should prevent the development of the Kupe Gas
Project.

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