Oil & Gas UK

Supplementary Guidance On The

RIDDOR Reporting Of Hydrocarbon
Releases
Technical Presentation

Hydrocarbon Release Reporting Agenda

Objectives of the Workgroup

Structure of Guidance
Regulatory Requirements
Reporting Methodology
Technical Assessment
Reportable Limits
Additional Rules
Reporting of Non Petroleum Hydrocarbons

Objectives of Workgroup
Produce supplementary guidance that is
Fully aligned with RIDDOR 2013 requirements
Well-understood by the industry
Consistently applied by the industry
Primarily focussed on petroleum hydrocarbon releases
Also includes assessment on non-petroleum
hydrocarbon releases

Petroleum Hydrocarbon Releases

ReportableLimit
Limit
Reportable

Major
Major
Significa
Significa
ntnt
Minor
Minor

Previous
Previous
Guidance
Guidance
2014
2014
Guidance
Guidance

Reportab
Reportab
Limit
leleLimit

NotReportable
Reportable
Not
Number of releases

Structure of Guidance
Regulatory Requirements
Review of DO relating to Hydrocarbon Releases (HCR)

Methodology for Assessing RIDDOR Reporting of

Petroleum Hydrocarbon Releases
Define key words and phrases
Reporting flow chart

Technical Assessment
Defines Reportable Limits

Case Studies
Worked Examples

Appendices
Consequence Analysis
Application of Methodology to Non-Petroleum Hydrocarbon Fluids
High Water Content Liquids

Regulatory Requirements RIDDOR 2013

Release of petroleum hydrocarbon
75 The unintentional release of petroleum hydrocarbon on
or from an offshore installation which
(a) results in
(i) a fire or explosion; or
(ii) the taking of action to prevent or limit
the consequences of a potential fire or
explosion; or
(b) could cause a specified injury to, or the death
of, any person.

Technical Assessment Potential for

Death or a Specified Injury
Petroleum Hydrocarbons
Well Fluids, Natural Gas, Natural Gas Liquids, Condensate,
Crude Oil

Continuous & Discrete Releases

Gas, Vapour, Mist, Liquid
Consequence Analysis

Continuous Release - Jet Fire

Continuous Release - Pool Fire
Discrete Release - Fireball
Discrete Release - Pool Fire
Flash fire, Explosion, Toxic Cloud, Asphyxia, Narcosis - See
Guidance

RIDDOR DO 75 Assessment Flowchart

Technical Assessment
Continuous & Discrete Releases
Consequence Analysis

Continuous Release - Jet Fire

Continuous Release - Pool Fire
Discrete Release - Fireball
Discrete Release - Pool Fire

Additional Guidance

Continuous And Discrete Releases

Continuous release A continuous release is a loss of
containment from a system which occurs, or has the
potential to occur, for an extended period of time (minutes)
prior to plant stoppage or action being taken to depressurise
the system. For continuous releases, the release rate is the
important factor in determining if a HCR has the potential to
cause death or a specified injury.
Discrete release A discrete release is a loss of
containment from a system with a fixed mass inventory
where the hydrocarbon is released over a short period of
time (seconds rather than minutes) and where the initial
mass released has a greater hazard potential than any
following continuous release.

Continuous Release - Jet Fire

Jet fire flame length 1m

Criterion person must be in the flame
Mass flow rate for 1m flame length = 3 kg/hour
Equivalent gas concentration 20% LFL at 0.5m

Conservatisms
Jet fire flame length correlation
Adopted gas concentration criterion

Continuous Release - Pool Fire

Pool fire flame diameter 1m
Criterion person must be in the flame
Mass flow rate for sustained 1m diameter
pool = 100 kg/hour
Conservatisms
Lowest burn rate adopted for all liquids
Adopted reportable limit lower than calculated

Discrete Release Fireball

Transient analysis
Criterion thermal dose 1000 tdu
Surface Emissive Power = 300 kW/m2
Mass of hydrocarbons for 1000 tdu = 0.15 kg

Conservatism
Assume person exposed to constant heat flux

Discrete Release Pool Fire

Transient analysis
Pool fire grows with time
Criterion
An escaping person is caught in the flame
The thermal dose received during escape 1000 tdu.
Mass of hydrocarbons to meet criterion
Natural Gas Liquids - 3 kg
Condensate - 10 kg
Crude Oil - 30 kg
Conservatism
Speed of escape

Additional Guidance Hydrocarbon Liquids

Water Cut
Hydrocarbon liquids with 90% water by mass are not
combustible and are therefore not reportable
Accumulation
Liquid releases are only reportable if they can form pools.
If a liquid release falls to the sea and there is no pool or
coating formed on equipment or the deck, it is not
reportable.
If a liquid release is routed directly to the drains within 0.5
m of the point of release and does not form a pool, it is
not reportable.

Reportable Limits
Type of Release

Phase

Gas / Vapour / Mist

Hazard

Fluid

Reportable Limit

Jet Fire

Natural Gas
Natural Gas Liquids
Condensate
Crude Oil

3 kg/hour
(0.0008 kg/s)
OR
20% LFL at 0.5 m

Pool Fire

Natural Gas Liquids

Condensate
Crude Oil

100 kg/hour
(0.028 kg/s)

Fireball

Natural Gas
Natural Gas Liquids
Condensate
Crude Oil

0.15 kg

Pool Fire

Natural Gas Liquids

3 kg

Pool Fire

Condensate

10 kg

Pool Fire

Crude Oil

30 kg

Continuous
Liquid

Gas / Vapour / Mist

Discrete
Liquid

Reportable Limits for Petroleum Hydrocarbon

Releases DO 75 (Appendix B of Guidance)

Reportable Limits for Non-Petroleum Hydrocarbon

Fluids DO 77 (Appendix D of Guidance)

Regulatory Requirements
RIDDOR 2013
Dangerous Occurrence

RIDDOR
Reportable Limit

OIR/12

Wells

DO 20

No

All releases

Pipelines

DO 21

Yes
(See HSE Website)

Only if release is within

500m zone

Release of petroleum
hydrocarbons

DO 75

Yes
(See Sections 3 & 4)

All RIDDOR DO 75
reportable releases

Release of non-petroleum
hydrocarbons

DO 77

Yes
(See Section 5)

Not required

RIDDOR 2013
Dangerous Occurrence

RIDDOR
Reportable Limit

OIR/12

Wells

DO 20

No

All releases

Pipelines

DO 21

No

Only if release is within

500m zone

Release of petroleum
hydrocarbons

DO 75

No

All fires & explosions

Release of non-petroleum
hydrocarbon fluids

DO 76

No

Not required

Unignited Release

Ignited Release

Guidance on Hydrocarbon Release Reporting