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Archive for the ‘Gulf of Mexico’ Category

BSEE incident investigations are another window into OCS safety performance.

Panel reports are published for the most significant OCS incidents (e.g. fatalities, serious injuries, significant pollution). Unfortunately, these reports have been unacceptably delayed in recent years. Status reports are not provided leaving the public in the dark as to what is being investigated and why.

The more common investigations, conducted by BSEE’s district offices, are timely and informative. The Districts typically investigate lost time (>72 hours) injuries, crane and lifting equipment incidents, small fires, pollution events, property damage > $25k, gas releases, and other incidents requiring workers to muster for possible evacuation.

The number of District investigations in 2024 declined significantly to 31, one-third fewer than the average of 46.25 for the past 4 years.

Violations were not identified for 2/3 of the incidents.

A complete list of the 2024 District investigations follows. Hyperlinks are provided for those who want to review the reports.

DateOperatorTimeViolation(s)Area/BlockAccident Type
12-25-2024bp1330noGC 584lifting, LTA
11-24-2024Anadarko1710noVK 915Muster, gas release
11-15-2024Anadarko837noGB 668Muster
11-10-2024Murphy145noGC 432LTA
10-12-2024LLOG540yesAC 337LTA – Lifting
10-03-2024Shell900noAC 857Fire, > $25K damage
09-27-2024LLOG200noAC 337LTA, Crane
09-21-2024Talos1630noSM 160LTA
08-11-2024Gulf Offshore1910yesVR 170Fire, Explosion, >$25k, Muster, LTA
07-20-2024Talos2200noSS 224DLTA
07-11-2024Manta Ray730noHI A 5LTA
07-08-2024Cantium1908yesST 23CCLifting
06-05-2024Kosmos1538noMC 727Muster, > $25K
05-31-2024MC Offshore100yesGC 52Crane, > $25K
05-02-2024Murphy1620noGC 478Crane; > $25K
04-24-2024Murphy815noGC 389LTA
04-04-2024Renaissance2230yesVR 369 ALTA
03-28-2024BOE2200yesWR 51LTA
03-20-2024Talos700yesGB 506LTA
03-19-2024Chevron1330noMC 607Lifting, <$25k
03-13-2024Walter2010noSS 189Crane
03-07-2024LLOG1500yesKC 785LTA, lifting
03-05-2024Shell415yesMC 391Pollution, >$25k
02-25-2024Talos930yesSM 130 BCrane,> $25K
02-21-2024W&T1319noHI A 379BFire
02-16-2024Chevron1335noWR 29LTA, Crane
02-13-2024Shell2035noMC 899LTA
02-07-2024Williams855noGA A 244JPLTA
01-29-2024Cantium1900noST 23 CCFire,>$25K
01-18-2024Murphy1303noGC 478Lifting, > $25k
01-16-2024Arena252noSM 128 BFire, > $25K

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The 2024 Gulf of America Safety Compliance Leaders are ranked below according to the number of incidents of non-compliance (INCs) per facility inspection. To be ranked, a company must:

  • operate at least 2 production platforms
  • have drilled at least 2 wells during the year
  • average <1 INC for every 3 facility inspections (0.33 INCs/facility inspection)
  • average <1 INC for every 10 inspections (0.1 INCs/inspection). Note that each facility inspection may include multiple types of inspections (e.g. production, pipeline, pollution, Coast Guard, site security, etc). In 2024, there were on average 3.4 inspections for every facility inspection.

This ranking is based solely on BSEE’s published compliance data. The absence of timely public information on safety incidents (e.g. injuries, fires, pollution, gas releases, property damage) precludes inclusion of these data.

District investigation reports are more timely and provide additional insights into safety performance. Impressively, Hess had no incidents warranting a District investigation, and was the only ranked operator with this distinction. I will comment more on the District reports in a future post

Chevron’s 2024 compliance record was among the best in the history of the US OCS oil and gas program. Was it the absolute best? Were it not for the FSI INC at a Unocal (Chevron) facility, one could unequivocally assert that it was. Further evaluation of that INC would be helpful. However, details on specific INCs are not publicly available, so the significance of that violation cannot be evaluated.

operatorWCSIFSItotal INCsfacility inspINCs/
fac insp
inspINCs/
insp
Chevron10121170.023110.006
BP2305930.052510.02
Anadarko891181430.133440.05
Hess2305260.19670.07
Walter64111500.221610.07
Shell23175451990.234950.09
Cantium2480321230.265370.06
Murphy89118700.261910.09
Arena29283601890.328030.07
Gulf-wide957398109146431330.47106640.14
Notes: Numbers are from published BSEE data; INC=incident of non-compliance; W=warning INC; CSI=component shut-in INC; FSI=facility shut-in INC; INCs/fac insp= INCs issued per facility inspection; each facility-inspection may include multiple types of inspections (e.g. production, pipeline, pollution, Coast Guard, site security, etc), in 2024, there were on average 3.4 inspections for every facility inspection

Not meeting the production facilities requirement to be ranked among the top performers, but nonetheless noteworthy, was the compliance record of BOE Exploration & Production (no relation to the BOE blog 😀). See their impressive inspection results below:

WCSIFSItotal INCsfacility inspINCs/
fac insp
inspINCs/
insp
BOE1102210.1480.04

Transparency on inspections and incidents is important for a program that is dependent on public confidence. For independent observers to better evaluate industry-wide and company-specific safety performance, publication of the following information should be considered:

  • quarterly updates of the incident tables, as was once common practice
  • posting of violation summaries for inspections resulting in the issuance of one or more INCs
  • more timely publication of panel reports for more serious incidents
  • real time list of ongoing investigations including the reason for each investigation
  • status summary for civil penalties that have been proposed, including the violations and responsible parties

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The announcement was during an interview this morning (4/4/2025) with Lawrence Jones on Fox News, and is consistent with expectations and the current 5 year leasing plan.

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In June 2023, Cox and affiliates operated 435 platforms in the Gulf. That number is now only 46, all of which are on relinquished or terminated leases.

Cox Operating LLC and affiliates were once again the violations leaders in 2024 accounting for 50% (479/957) of the warnings, 12% (47/398) of the component shut-ins, and 7.3% (8/109) of the facility shut-ins.

All but 3 of the Cox enforcement actions were during the first half of the year. This is presumably because of the termination of Cox operations and the ongoing divestiture of their assets.

According to BOEM’s platform data base, Cox (43) and affiliates Energy XXI (3) and EPL (0) now operate only 46 platforms. This is a big decline from Sept. 2024 and June 2023 when the Cox companies operated 243 and 435 platforms respectively. All of the remaining Cox platforms are non-producing and are on relinquished or terminated leases.

The curtailment of Cox operations is no doubt an important factor in the sharp decline in Gulf of America violations in the second half of 2024. Per the data below, total GoA wide violations declined by 58% (1031 vs. 433) in the second half of 2024 as Cox violations essentially disappeared:

Gulf of America
inspection data
warningscomponent
shut-ins
facility
shut-ins
facility
inspections
first half 2024725243631586
2nd half 2024232155461546
reduction493 (68%)88 (36%)17 (27%)40 (2.5%)

Cox companies inspection datawarningscomponent
shut-ins
facility
shut-ins
facility inspections
first half 2024478467 404
2nd half 2024111174

Some Cox assets have been acquired by W&T and Natural Resources Worldwide. BOEM records indicate that 8 record title assignments and 3 operating rights assignments from Cox to W&T were approved in the first half of 2024. W&T currently operates 116 platforms, but it’s unclear how many are former Cox facilities.

The acquisition of Cox properties does not appear to have significantly affected W&T 2024 inspection results, which were respectable:

W&T insp. datawarningscomponent
shut-ins
facility
shut-ins
facility
inspections
first half 20241231083
2nd half 202417142105

Additional record title and operating rights assignments to Natural Resources Worldwide (NRW) were approved in 2025, but NRW does not appear to be operating any platforms.

Ironically, NRW was cited for 1 warning and 1 facility shut-in without a single inspection. Presumably, these violations were the result of administrative issues.

Online data are insufficient to account for the 435 platforms that were on the Cox ledger in June 2023 or determine the remaining decommissioning liabilities. Per the platform database, no Cox, Energy XXI, or EPL platforms were removed in 2023, 2024, or 2025.

On a more positive note, most GoA operators had good safety and compliance records in 2024. One major producer had a historically significant record. More on that to follow.

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Sustaining or preferably increasing production rates will be dependent on a reliable schedule of lease offerings and a consistent regulatory regime based on best safety management principles and continuous improvement in technology, practices, and culture. Poorly considered operating restrictions imposed by activist judges are a major risk to both safety and production.

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OCS Lease Sale 259 was mandated by Congress, and was held on March 29, 2023, two days before the deadline established in the Inflation Reduction Act. Ah, but compliance with environmental law, which is of course subject to interpretation, was still required.

So the formula for eNGOs in such cases is to sue on NEPA grounds in a friendly Federal court. In the case of Sale 259, the plaintiffs asserted that BOEM’s climate change and Rice’s whale analyses were inadequate.

With regard to climate change, the reality is that incremental Gulf of America production will have virtually no effect on petroleum consumption and global GHG emissions. Increased GoA production will actually have a slight positive effect on worldwide GHG emissions given the relatively lower carbon intensity for deepwater Gulf production.

With regard to the Rice’s whale, Darren Ireland’s analysis is compelling:

Based on the limited data available on the use and occurrence of Rice’s whale in the central and northwestern GOMx (one acoustic study (Soldevilla et al. 2022b), one confirmed sighting (NMFS 2018a) and a few unconfirmed sightings (Rosel et al. 2021)), there is insufficient scientific evidence to determine that essential features for Rice’s whale conservation are indeed present in the central and northwestern GOMx. In fact, data on the life-history requirements of Rice’s whale even in the core habitat are still lacking and need further investigation.“

Unsurprisingly, Judge Amit P. Mehta of the US District Court for the District of Columbia, has ruled that BOEM’s environmental assessments on climate change and the Rice’s whale were deficient, and has ordered the parties and intervenors to jointly submit a proposed briefing schedule by April 3, 2025. “The court will also order additional briefing on remedy” (e.g. onerous operating restrictions).

In case you haven’t suffered enough, the judge’s full opinion is attached.

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BOEM’s 2024 Marine Archaeology Rule

Exercising authority granted in the Congressional Review Act (Chapter 8 of Title 5 of the United States Code), Congress passed Joint Resolution 11 nullifying the Bureau of Ocean Energy Management rule titled “Protection of Marine Archaeological Resources” (Sept. 3, 2024).

Nullification of a final rule is not common. Since its Enactment in 1996, the CRA has been used to overturn only 20 rules. This is the first time an OCS energy rule has been nullified.

Enactment of a CRA resolution of disapproval is unlikely in most circumstances, because a President would be expected to veto a joint resolution disapproving a rule issued by the President’s own Administration.

There are also time limitations for nullifying a rule. The joint resolution must be introduced during a 60-days- of-continuous-session period beginning when the rule has been published in the Federal Register and been received by Congress. However, if within 60 session days after a rule is submitted, Congress adjourns its session, the periods to introduce and act on a disapproval resolution reoccur in their entirety in the next session of Congress.

It’s also noteworthy that a CRA resolution cannot be filibustered if the Senate acts on the resolution during a 60-days-of-Senate-session period beginning when the rule has been received by Congress.

Most of the 20 nullifications involved rules finalized at the end of a previous administration that were nullified at the beginning of a new administration with a majority in both chambers of Congress. That is the case for the Marine Archaeology Rule, which was published at the end of the Biden administration and nullified at the beginning of the Trump administration. .

The nullified OCS rule required operators to submit an archaeological report identifying potential archaeological resources with any exploration or development plan. The rule modified regulations that only required such a report only when a BOEM regional director had reason to believe that an archaeological resource may be present in the lease area. 

Archaeological survey requirements have been somewhat contentious since they were introduced in the 1970s. There were concerns about decisions to require the protection of speculative, low probability sites that could significantly alter operating plans.

A reasonable balance and an apparent consensus was achieved by limiting the report requirements to areas where studies and other information indicated the potential for such resources. BOEM’s new rule tightened the requirement considerably, which led to opposition and ultimately nullification.

Resolution Timeline

2/4/2025SenateResolution Introduced by Sen. Kennedy
2/25/2025SenatePassed by Yea-Nay Vote 54 – 44
3/6/2025HousePassed by Yea-Nay vote: 221 – 202, 1 Present
3/13/2025Presidentsigned

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In light of the recent NASA/SpaceX advances in rocketry, a manned mission to Mars seems inevitable, perhaps within the next 5 years. See the SpaceX Mars landing video below.

While the space program generates more media buzz given the sci-fi appeal, the achievements of the offshore oil and gas industry are similarly impressive. The Gulf of America has its own Mars, a massive deepwater project that has been ongoing and expanding for 30 years, and may ultimately produce more than 1 billion barrels of oil equivalent (boe).

Like a mission to Mars, the successful development of deepwater oil and gas resources is a technical marvel that requires:

  • Identifying prospects deep beneath the seafloor using advanced subsurface imaging capabilities.
  • Drilling exploratory wells from floating rigs, using advanced stationkeeping systems that maintain a precise location on the water surface.
  • Drilling deep beneath the seafloor while transmitting real-time geologic, temperature, and pressure data to the rig and distant onshore locations.
  • Ensuring well integrity by installing and cementing multiple strings of protective casing.
  • Processing production at buoyant surface facilities designed to withstand worst case storm conditions.
  • Connecting clusters of subsea wells to a host surface facility that may be many miles away.
  • Increasing ultimate recovery with reservoir engineering studies and advanced well completion practices.

Life on the planet Mars will be dependent on technology developed for the offshore Mars and other deepwater projects.

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Historically, falls are the most common cause of offshore injuries and fatalities, and hazardous grating is a leading contributing factor to these incidents.

BSEE’s risk-based inspection and safety alert programs have effectively drawn attention to grating risks. Attached is a recent alert describing a grating incident that could have been fatal.

A worker installing a pump in a skid above unsafe grating was kneeling on scaffolding boards. The tip of his boot was on the corroded grating when it suddenly gave way. The worker was able to grab a nearby section of piping to support himself. The 36″ x 36″ piece of grating collapsed and fell into the water.

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Actually, the latest data are for December 2024, so that was before the name change. It’s a nice story nonetheless, very patriotic.😉

Most likely, the jump in production is related to increased output from the new deepwater facilities we have been following.

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