Response Strategies: Dispersant Use. Tom Coolbaugh November 30, 2016

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1 Response Strategies: Dispersant Use Tom Coolbaugh November 30, 2016

2 Topics Introduction to oil spill response The spill response tool box Reality of oil spill response options Overview Chemistry and dispersant effectiveness Toxicity, fate, and effects of dispersed oil and dispersants Net environmental and economic benefit analysis considerations (NEBA/SIMA) Communication Tools 2

3 Basic Response Information Response Priorities Protect the safety and health of people P Reduce the impact to the environment E Protect assets A Protect the company reputation R Safety and Health are the highest priorities Speed is essential in recovery efforts 3

4 Optimum Response Strategy Use appropriate combination of response tools to minimize impacts If possible, deploy mechanical in thick oil to maximize recovery Consider dispersant use early in a response Responder and public safety is critical Environmental protection priorities Minimize wildlife exposure Minimize habitat contamination Minimize oil stranding on sensitive shorelines Human resource protection priorities Tourist beaches Marinas, commercial activities Shoreline property values 4

5 Spill Response Options The Toolbox Monitor & Evaluate Aerial Mechanical Recovery Dispersants Vessel In-Situ Burning Subsea The goal is to design a response strategy based on Net Environmental Benefit Analysis (NEBA) 5

6 Primary Goal of Oil Spill Response Maximize Encounter Rates and Effectiveness to Minimize Impact 6

7 Encounter Rate is Key to Offshore Response Courtesy of Ocean Imaging 7

8 Rapid Response is Key Slick Continuously Expands as Oil Thins Direction of Wind/Currents The size of the problem increases with time Response is less efficient with time 8

affect the size and location of a spill T = 0 T = 5 seconds T =

9 Oil Slicks Spread Quickly Size of the slick can determine the ability to respond effectively Wind, waves and currents further affect the size and location of a spill T = 0 T = 5 seconds T = 10 seconds Alaska North Slope Crude Spreading on salt water in 1 m 2 pan 9

10 Net Environmental Benefit Analysis (NEBA) A risk comparison process to improve decision-making A planning and response tool Rank response options by least negative environmental consequences and effectiveness in treating/removing spilled oil Speed the selection of response options for various locations, weather conditions and spill circumstances Can be an intensive and detailed process to arrive at a consensus with respect to the response decision Have the necessary discussions in advance of a spill 10

11 NEBA Limit Water Column Organism Exposure Limit Surface Organism Exposure 11

12 What Happens When Dispersants Are Not Used? IN LARGER, OFFSHORE OIL SPILLS, MECHANICAL RECOVERY AND IN-SITU BURNING CAN ONLY PREVENT A SMALL PERCENTAGE OF THE OIL FROM IMPACTING OUR SHARED VALUES. WITHOUT THE USE OF DISPERSANTS, OIL OFTEN SPREADS TO THE SHORE, AFFECTING PEOPLE, THE ENVIRONMENT, AND COMMUNITY ASSETS. 12

13 Challenges to Oil Spill Response Weather Recovery Impossible In Rough Seas (>2 M) or High Winds (>25 kts) Safety concerns In high seas and inclement weather Thousands of different oils with a wide range of properties Weathering Effect Remote locations may not have immediate logistical support Wide Range of Impacted Habitats Rock Beaches to Sensitive Marshes Very little to no daylight during winter at higher latitudes Some work on night operations, e.g., Hawaii approval for vessel dispersant application Enhanced detection tools may enable May have limited access to impacted areas 13

14 Spill Conditions May Limit Response Options 14

EFFICACY OF OTHER RESPONSE OPTIONS FOR OFFSHORE SPILLS, DISPERSANTS CAN

SPILLS LOCATED FURTHER OFF-SHORE FASTER.

AREA THAN MECHANICAL RECOVERY, WHICH CAN ONLY BE ACHIEVED BY BOAT.

PROPORTIONATELY AND WITHOUT DISRUPTION, AND CAN PREVENT MOST OIL FROM

15 Why Dispersants? DISPERSANTS ARE USED WHEN ENVIRONMENTAL AND SPILL FACTORS LIMIT THE EFFICACY OF OTHER RESPONSE OPTIONS FOR OFFSHORE SPILLS, DISPERSANTS CAN BE TRANSPORTED AND APPLIED BY AIRPLANE, AND ARE THEREFORE ABLE TO REACH SPILLS LOCATED FURTHER OFF-SHORE FASTER. AERIAL APPLICATION ALLOWS DISPERSANTS TO REACH A GREATER SPILL SURFACE AREA THAN MECHANICAL RECOVERY, WHICH CAN ONLY BE ACHIEVED BY BOAT. IN THE EVENT OF A SUBSEA SPILL, DISPERSANTS CAN BE APPLIED PROPORTIONATELY AND WITHOUT DISRUPTION, AND CAN PREVENT MOST OIL FROM REACHING THE SURFACE. UNLIKE MECHANICAL RECOVERY AND IN-SITU BURNING, DISPERSANTS CAN BE APPLIED UNDER A BROADER RANGE OF WEATHER CONDITIONS, INCLUDING HIGH WINDS AND ROUGH SEAS. 15

spill area Continuous encounter with slick Large Dispersant Boat Small Dispersant Boat Large Skimmer

16 Dispersant Application Platform Comparison 5,000 MT spill (37K bbl) Slick 0.1 mm thick 100 MT/km 2 50 km 2 Slick C-130 Dispersant Plane 8 hrs of operation Systems X 10 still < spill area Continuous encounter with slick Large Dispersant Boat Small Dispersant Boat Large Skimmer Medium Skimmer For reference: 9300 American Football fields 6500 Football (soccer) fields 2900 Australian rules Football fields 16

17 Factors Influencing Effectiveness Oil Type/Properties Viscosity API Gravity Wax Content/Pour Point Emulsifiers Environmental Conditions Water Temperature Sea State (Mixing Energy) Extent of Weathering (How long on the sea) Water Salinity 17

18 Dispersant Dosages Typically 5 gallons per acre Dispersant to Oil Ratio (DOR) 1: mm Oil Thickness 5 + mm Low Oil Viscosity High 2 US gallons/acre DOR 1:50 10 US gallons/acre DOR 1:10 18

19 Dispersants What are they? Dispersants are solutions of surfactants dissolved in a solvent Surfactants reduce oil-water interfacial tension allows slicks to disperse into very small droplets with minimal wave energy Dispersed oil rapidly dilutes to concentrations <10 ppm within minutes, <1 ppm within hours, ppb range within a day 19

20 Dispersants What do they do? Dispersants Enhance Removal of Oil from the Environment Through Biodegradation Each dispersed oil droplet is a concentrated food source that is rapidly colonized and degraded by marine bacteria Dilution allows biodegradation to occur without nutrient or oxygen limits Graphic consistent with Venosa & Holder, EPA

DISPERSANTS ENHANCE THE SEPARATION PROCESS. SMALL DROPLETS REMAIN IN THE WATER COLUMN AND ARE MORE READILY AVAILABLE FOR BIODEGRADATION BY MICROORGANISMS.

21 How Do Dispersants Affect Oil? 1 DISPERSANTS CAN BE APPLIED BY BOAT, PLANE, OR SUBSEA INJECTION. OIL SLICK 2 DISPERSANTS REDUCE SURFACE TENSION BETWEEN OIL AND WATER SO THAT OIL SLICKS CAN BREAK APART. DISPERSANTS MICROORGANISM 4 WAVE MOTION NATURALLY BREAKS UP OIL. DISPERSANTS ENHANCE THE SEPARATION PROCESS. SMALL DROPLETS REMAIN IN THE WATER COLUMN AND ARE MORE READILY AVAILABLE FOR BIODEGRADATION BY MICROORGANISMS. 3 DISPERSANT MOLECULE ATTRACTS WATER ATTRACTS OIL DISPERSANTS ARE COMPRISED OF TWO PARTS. DISPERSANT MOLECULES ATTRACT WATER ON ONE END, AND OIL ON THE OTHER. 5 MICROORGANISMS CONVERT INGESTED OIL INTO MOSTLY CARBON DIOXIDE (CO 2 ) AND WATER (H 2 O). OIL DISPERSANTS SOURCE: NATIONAL ACADEMIES PRESS, UNDERSTANDING OIL SPILL DISPERSANTS: EFFICACY AND EFFECTS 21

Dispersants Break Down Oil in the Environment DISPERSANTS DON T REMOVE OIL FROM

HOUSE, AND A HUNDRED THOUSAND PEOPLE TRYING TO WOLF IT DOWN AT ONCE; THEN IMAGINE

-THE NEW YORKER, MARCH 2011 VERSUS DISPERSANTS WORK IN A SIMILAR FASHION TO THE

22 Dispersants Break Down Oil in the Environment DISPERSANTS DON T REMOVE OIL FROM THE SEA, BUT THEY ARE DESIGNED TO HELP NATURE DO SO IMAGINE A CAKE THE SIZE OF A HOUSE, AND A HUNDRED THOUSAND PEOPLE TRYING TO WOLF IT DOWN AT ONCE; THEN IMAGINE THAT CAKE CUT INTO SLICES AND PASSED AROUND TO THE SAME CROWD. -THE NEW YORKER, MARCH 2011 VERSUS DISPERSANTS WORK IN A SIMILAR FASHION TO THE CAKE ANALOGY ABOVE: OIL IS BROKEN INTO TINY DROPLETS THAT ARE MORE EASILY CONSUMED BY MICROORGANISMS. 22

23 Environmental Impacts Health Concerns Toxicity of oil > toxicity of the dispersant Modern dispersants use ingredients found in household products NALCO website* Centers for Disease Control assessment supports low health risk NOAA & FDA test results for dispersants in Gulf seafood, "There is no question Gulf seafood coming to market is safe from oil or dispersant residue. ( Other Uses of Corexit 9500 Ingredients (from Nalco website) Corexit 9500 Ingredients Span TM 80 (surfactant) Tween 80 (surfactant) Tween 85 (surfactant) Aerosol OT (surfactant) Glycol butyl ether (solvent) Isopar TM M (solvent) Common Day-to-Day Use Examples Skin cream, body shampoo, emulsifier in juice Baby bath, mouth wash, face lotion, emulsifier in food Body/Face lotion, tanning lotions Wetting agent in cosmetic products, gelatin, beverages Household cleaning products Air freshener, cleaner * 23

24 Environmental Impacts Toxicity Rapid dilution limits ecosystem impacts of both dispersant and dispersed oil Concentrations start low and rapidly dilute (National Academies, 1989) OF THE WATER COLUMN Lessard, R.R. and DeMarco, G. (2000) The significance of oil spill dispersants. Spill Science & Technology Bulletin, 6, Lab tests expose organisms to constant concentrations for days Organisms only see elevated concentrations for a few hours during a real spill Dispersants are only applied in areas with high potential for dilution 24

25 Relative Toxicity Environment Canada Study Product Toxicity (ppm) Palmolive Dish Soap 13 Sunlight Dish Soap 13 Mr. Clean 30 Corexit Corexit (96 HR Rainbow Trout LC50) Less toxic 25

26 How Do We Measure Toxicity? EXPERTS PERFORM LABORATORY TESTS TO DETERMINE THE EFFECT OF DISPERSANTS TO OIL TOXICITY LEVELS. ADDITIONALLY, STUDIES CONDUCTED BY THE US FOOD AND DRUG ADMINISTRATION AND NATIONAL OCEANIC AND ATMOSPHERIC ASSOCIATION HAVE SHOWN THAT, UNLIKE MERCURY, INGESTION OF DISPERSED OIL BY MARINE ORGANISMS DOES NOT IMPACT THE FOOD CHAIN. SOURCES: ENVIRONMENTAL PROTECTION AGENCY

27 How Do We Compare Toxicity? MEMBERS OF GOVERNMENT, INDUSTRY, AND ACADEMIA TEST TOXICITY LEVELS IN DISPERSANTS BEFORE THEY ARE APPROVED FOR USE. AN ENVIRONMENT CANADA STUDY FOUND DISHWASHER DETERGENT TO BE TIMES MORE TOXIC THAN COREXIT

28 Dispersant Use Approval May require a low inherent toxicity and a minimum level of effectiveness Verified by test protocols before placement on an approved list if required Regulations often require that permission be obtained before dispersants are used in certain locations, especially when close to shore and/or in shallow water A pre-approval process may be used, especially for offshore and/or in deep water Documentation to support their use is often based on an environmental risk-analysis of relevant scenarios and is part of an approved contingency plan Scenario-based contingency plans should demonstrate that the use of oil spill dispersants will give the best overall response for the environment (NEBAapproach) Potential for significant differences from country to country 29

29 Dispersant Use Across the Globe First or second response option in many countries today Used with permission of the API Source: International Tanker Owners Pollution Federation (ITOPF) 30

Post-Macondo Research Publication Concerns Publication Conclusions When Corexit 9500A and oil are mixed, toxicity increases up to 52-fold Response High exposure appears to be confused with high

Conclusions While it is intuitive to think the application of dispersant results in more oil being dispersed subsurface, simulations suggest that it made a marginal difference to the global

30 Post-Macondo Research Publication Concerns Publication Conclusions When Corexit 9500A and oil are mixed, toxicity increases up to 52-fold Response High exposure appears to be confused with high toxicity Oil toxicity does not change when dispersants are added Failure to recognize that dispersants change the bioavailability (exposure) of the oil by moving it to the water column Publication Conclusions While it is intuitive to think the application of dispersant results in more oil being dispersed subsurface, simulations suggest that it made a marginal difference to the global partitioning of surface and subsea oil, decreasing the surfacing oil by 1 2% Response The hazard of using models without understanding the realities of oil spill response Consider images of Macondo subsea dispersant test A review process was developed with API to address publications as they arise 32

31 Summary Along with prevention, robust oil spill response (OSR) is critical Highest priority in emergency response is human health and safety Basic strategy for addressing oil spilled from an offshore well Respond as close to the source as possible Utilize all appropriate tools to keep oil from reaching shorelines Dispersant use presents significant advantages over the limitations of mechanical recovery and should be considered as a primary response option Subsea injection is a step-change advance that may reduce spill impacts by an order of magnitude More research may enhance the optimization of subsea injection and allow better understanding of the long term effects of dispersed oil in deep waters 33

32 Subsea Dispersants

33 Subsea Injection of Dispersants Preliminary observations of DWH experience Benefits of subsea injection Long-term fate and effects 35

responders More precise application enhanced encounter rate

34 Subsea Injection of Dispersants Safety: Would reduce the amount of oil coming to the surface lower VOC exposure for responders More precise application enhanced encounter rate Require less dispersants 1:100 vs 1:20 DOR Could proceed 24/7 36

35 Release Site May 9: Prior to Injection Courtesy of Ocean Imaging / 16 knots Avg winds 64 / 16 knots Wind direction 37 37

36 Release Site May 10: 3 hrs of Injection Wind direction Courtesy of Ocean Imaging / 12 knots Avg winds 91 / 10 knots 38 38

37 Release Site May 10: 11 hrs of Injection Wind direction Courtesy of Ocean Imaging / 14 knots Avg winds 91 / 10 knots 39 39

38 Release Site May 11: 5 hrs after Injection Ended Wind direction Courtesy of Ocean Imaging / 8 knots Avg winds 134 / 10 knots 40

39 Release Site May 12: 28 hrs After Injection Ended Courtesy of Ocean Imaging / 7 knots Avg winds 130 / 7 knots Wind direction 41

40 Safety: Effect of Subsea Dispersant Use on VOC 42

41 Demonstration of Subsea Dispersant Effectiveness (API) OHMSETT Facility, New Jersey, July, 2014 Task Force Funded by API Joint Industry 43

42 The Oil Spill Response Joint Industry Project Three year project ( ) addressing recommendations for spill response developed following the Montara and Macondo incidents Nineteen members, twenty-two projects Improving co-ordination between the many groups that are also working global oil spill response issues Dispersant issues are being addressed in about 20% of the JIP work streams including subsea dispersant use 44

Development of Bench Scale Subsea Dispersant Effectiveness Test (IPIECA/IOGP) Project to improve bench-scale testing for subsea dispersant effectiveness Focus on testing and scaling applicable to API

43 Development of Bench Scale Subsea Dispersant Effectiveness Test (IPIECA/IOGP) Project to improve bench-scale testing for subsea dispersant effectiveness Focus on testing and scaling applicable to API s subsea dispersant program ( D3 ) using the same crude oils and dispersants SINTEF (Norway) & Cedre (France) running parallel testing programs Four crude oils Three dispersants Two mixing regimes (high and low energy) Similar (but different) experimental set-up 45

44 Development of Bench Scale Subsea Dispersant Effectiveness Test (IPIECA/IOGP) SINTEF (Norway) & Cedre (France) ran parallel testing programs A goal was to bridge the gap between real world and existing tests Kickoff June, 2013 in Trondheim, Norway Complete December, 2014 and comparative assessment received 46

45 Cedre 47

46 SINTEF 48

47 Example Example of of Results: Results: Droplet Size Effects Droplet Size Effects Cedre: Different Oils SINTEF: Different Dispersants Small Tank Increasing Effectiveness Big Tank Increasing droplet size 49

48 Observations and Conclusions Demonstrated ability to measure droplet size distributions and water column concentrations of oil Measured changes under different conditions, different oil and dispersant types and with respect to placement of dispersant injection relative to the oil outlet nozzle Oil droplet sizes were observed to decrease, indicating influences of DOR, energy level and proximity of dispersant injection to oil outlet nozzle Median droplet size decreased with increasing DOR and dispersant concentrations may be lower than used for surface dispersion, e.g., DOR of 1:50, 1:100 Evaluating potential utility of the tests development of standardized protocol 50

49 Key Messages Access to appropriate response tools is critical for successful response Highest priority in emergency response is human health and safety Basic strategy for addressing oil spilled from an offshore well Respond as close to the source as possible Utilize all appropriate tools to keep oil from reaching shorelines Dispersants are used in spill scenarios when they are the most effective tool in minimizing the impact of spilled oil to people and environment 51

50 Net Environmental Benefit Analysis: An Overview Dr Tom Coolbaugh, ExxonMobil Geeva Varghese, Oil Spill Response Limited

51 Overview NEBA NEBA in 4 Stages Response Strategy Development using NEBA 53

tools, and develop a response strategy that will reduce the impact of an oil spill on the environment Helps

52 Net Environmental Benefit Analysis (NEBA) Structured approach used by the response community and stakeholders during oil spill preparedness planning and response, to compare the environmental benefits of potential response tools, and develop a response strategy that will reduce the impact of an oil spill on the environment Helps decision-makers use the response tools to achieve the most beneficial outcome overall New IPIECA-IOGP Good Practice Guidance 54

NEBA in 4 stages 1. Compile and evaluate data to identify exposure scenario and potential response options, and to understand the potential impacts of that scenario 2.

53 NEBA in 4 stages 1. Compile and evaluate data to identify exposure scenario and potential response options, and to understand the potential impacts of that scenario 2. Predict outcomes for the given scenario to determine which techniques are effective and feasible 3. Balance trade-offs by weighing a range of benefits and drawbacks resulting from each feasible response option 4. Select the best options for a given scenario, based on which combination of tools and techniques will minimize impacts 55

54 Response strategy development using NEBA Before a spill Strategic NEBA During a spill Operational NEBA 56

55 Response strategy development using NEBA Compile and evaluate data Know your oil Predict outcomes Model fate and trajectory Consider sensitivity data Identify potential response options: effectiveness feasibility regulation Balance trade-offs Select best option(s) 57

56 Factors Influencing Feasibility Climate and sea state e.g. Evaporation Spreading Emulsification Increased viscosity Fragmentation Oil properties and weathering characteristics Encounter rate Spill volume(s) Logistics and support 58

review consequences of no response activities Consider how different

57 Response strategy development using NEBA Compile and evaluate data Predict outcomes Balance trade-offs Select best option(s) For chosen scenarios, review consequences of no response activities Consider how different combinations of response options may change these impacts in order to characterize trade-offs 59

58 Response strategy development using NEBA Compile and evaluate data Predict outcomes Balance trade-offs Select best option(s) How to predict outcomes? No response scenario covers the timescale needed for the oil to weather and naturally attenuate Identifies potential environmental effects at a general level With the number of variables involved, it is impractical to quantify potential damage to any environmental resource in the NEBA process Subject matter expert input; drawing on extensive knowledge of oil impacts 60

59 Response strategy development using NEBA Compile and evaluate data Predict outcomes Balance trade-offs Select best option(s) 1 Compile & evaluate data Oil spill modelling Sensitivity data 2 Predict outcomes Estimating the baseline environmental impact Ecological considerations + Socioeconomic considerations Baseline predicted environment al impact of spill Candidate response options Characterizing the effects of response options Evaluation of candidate response options in combination Benefits Drawbacks Direct or indirect environmental impacts of technique Predicted outcomes of response options 61

60 Response strategy development using NEBA Compile and evaluate data Predict outcomes Balance trade-offs Select best option(s) May be differing priorities relating to perceptions of the importance of sensitive resources No universally accepted way to assign value or importance to different environmental and socioeconomic sensitivities Essentially a qualitative process Seeks consensus A risk-based decision making approach may allow comparison of disparate resources in order to facilitate consensus on relative values of resources A more quantitative approach is being developed 62

61 Response strategy development using NEBA Compile and evaluate data Predict outcomes Balance trade-offs Select best option(s) BALANCING TRADE-OFFS 63

for each of the planning scenarios, and response capabilities are designed and developed accordingly During a spill, NEBA supports -

62 Response strategy development using NEBA Compile and evaluate data Predict outcomes Balance trade-offs Select best option(s) Target an optimum response strategy for planning scenarios and incident specific conditions Before a spill, response strategies are defined for each of the planning scenarios, and response capabilities are designed and developed accordingly During a spill, NEBA supports - the deployment and adjustment of response resources as conditions change - decisions about when response end-points have been reached 64

63 Summary A systematic NEBA process can: establish an understanding of the potential effects of a spill on environmental and other resources help to evaluate various response options address potential trade-offs that may result for different response strategies NEBA also has a role when a response is under way: safety at the forefront NEBA should regularly be considered as a scenario evolves response strategies are optimized for a balance of response techniques government and industry working together cooperatively effective, timely and transparent communication Currently looking to standardize the focus beyond environmental Spill Impact Mitigation Assessment (SIMA) 65

64 Communication Tools 66

65 Understanding the Challenge Information or misinformation comes from a variety of sources Misconceptions can be addressed using the tools that IOGP-IPIECA have developed 67

66 Challenges - Perceptions Dispersants are banned Dispersants are toxic Dispersants hide the problem Dispersants make the problem worse Mechanical recovery is the solution DISPERSANTS DO NOT HIDE THE PROBLEM DISPERSANTS DO MINIMIZE ENVIRONMENTAL AND ECONOMIC DAMAGE TO PEOPLE, HABITATS, AND NATURAL RESOURCES NEAR AND ON THE SHORELINE DISPERSANTS DO NOT DRIVE OIL TO THE SEA FLOOR DISPERSANTS DO BREAK DOWN OIL SLICKS INTO TINY DROPLETS SO THAT THEY CAN MORE EASILY BE BIODEGRADED DISPERSANTS DO NOT MAKE THE PROBLEM WORSE 68

Dispersant Advocacy and Education IPIECA-IOGP JIP joined with API to: Co-fund NEBA communication project to develop glance/scan products Co-fund dispersant literature review panel Develop materials

67 Dispersant Advocacy and Education IPIECA-IOGP JIP joined with API to: Co-fund NEBA communication project to develop glance/scan products Co-fund dispersant literature review panel Develop materials on dispersants added material on toxicity and human health; core basis is the API dispersant fact sheets posted on website Ongoing efforts to make the most of communication opportunities, e.g., IOSC 2014/2017, Interspill 2015, AMOP 2015/2016, Clean Pacific/Gulf conferences 2015/2016, and others as they arise 69

68 Dispersant Communications Products Videos Fact Sheets Conferences 70

formats Short narrated videos based on the presentations have been

69 Other Communications Products In addition to dispersants, other complementary topics have been addressed Consistent presentation formats Short narrated videos based on the presentations have been developed The goal is to have a suite of materials available as broadly as possible 71

70 Materials Developed for Specific Issues For example, How Dispersants Work and Toxicity Make the most of the range of materials that have been prepared 72

71 Communication Approaches Outreach and Communication High Level Briefings Workshops Videos & Animations Fact Sheets Social Media Webinars Community Engagement 73

72 IOGP-IPIECA OSR JIP/ API Products Provide a Solid Foundation for Ongoing Discussions With government regulators globally in support of dispersant approvals With communities to allay fears about dispersants and their use With other stakeholders to increase an understanding of the technical basis of dispersants To ensure that dispersants remain in the oil spill response tool box 74

73 Resources Can Be Found At: American Petroleum Institute (API)/Joint Industry Task Force (JITF) Website (Factsheets and Reports): IOGP/IPIECA JIP Website: OSRL Subsea Well Intervention Services (SWIS): IOGP Arctic JIP: 75

74 Thanks for listening 76

NEBA new Good Practice Guide Rob Holland, Technical Lead, OSRL. Copyright Oil Spill Response Limited.

NEBA new Good Practice Guide Rob Holland, Technical Lead, OSRL Copyright 2015. Oil Spill Response Limited. Overview! Acknowledgments! Background to NEBA! NEBA GPG! NEBA example! Questions NET ENVIRONMENTAL