The preliminary NTSB report was posted on 1/18/2023, but the final report has still not been published. Status update:
Will the investigators consider longstanding regulatory fragmentation issues? The most recent Coast Guard – BSEE MOA for fixed platforms added to helideck regulatory uncertainty by assigning decks and fuel handling to BSEE and railings and perimeter netting to the Coast Guard. This is the antithesis of holistic, systems-based regulation.
So at this time, some theories on the culprits appear to have dropped out. Those that are still in play include various versions of the Ukrainian rental yacht narrative and the Hersh account. Hopefully, the responsible parties will be identified, but given the political stakes, this is becoming increasingly unlikely.
Until the late Triassic period, Virginia, the Carolinas, and Georgia were cojoined with Mauritania and Senegal as part of the Pangea super-continent. These Pangea neighbors share a common ancient geology.
Paul Post believed the untested West African analogs in the US Atlantic were highly prospective, and could contain >20 billion BOE. Paul was not alone in his thinking about Atlantic resource potential. Sadly, Paul is no longer with us 😥, so I’m sharing a few of his slides as a reminder of his important work. I have also attached his 2016 report and am linking the 2021 update.
Given the current Atlantic moratoriums and the steep legal, social, and political barriers that would have to be cleared, evaluating the US Atlantic is not imminent. However, nearly all Atlantic nations and their Caribbean and North Sea cousins have exploration programs and some have been wildly successful. Oil and gas consumption will be stable or growing for the foreseeable future, and it’s important to better understand the petroleum potential of our Atlantic continental margin.
Last week, BOEM announced the acceptance of all 69 of Exxon’s Sale 259 carbon sequestration bids. This is despite these facts: (1) Exxon’s intentions were known, (2) there were no provisions for CCS bidding in the Notice of Sale, (3) no environmental review of CCS leasing was conducted, and (4) there are no procedures for evaluating CCS bids.
Absent some type of legislative maneuver, carbon sequestration is not authorized under these leases. If Exxon is just acquiring the leases for evaluation purposes in preparation for a possible CCS sale in the future, their lease acquisitions may be okay. If they are planning on retaining these leases for actual sequestration operations, that is not okay, at least not until a competitive process has been established for awarding or reclassifying such leases.
It’s also noteworthy that there was a second bidder for th blocks (in red above). Presumably that company, Focus Exploration, was interested in acquiring the tract for oil and gas exploration purposes. However, the Focus bid was a bit lower, so Exxon got the tract.
Along with Cox Operating, six affiliates also filed: MLCJR , M21K, EPL Oil & Gas, Cox Oil Offshore, Energy XXI Gulf Coast, and Energy XXI GOM.
The BOEM platform data base lists only Cox Operating (276 platforms), EPL (10 platforms), and Energy XXI GOM (26 platforms) as current operators of OCS platforms. However, according to the Cox Operating website, the company operates 600 producing wells on 500 structures. Presumably, ~200 of those structures are in State waters.
In 2020, the OPEC price war drove oil prices down, while stay-at-home orders and well shut-ins associated with the COVID-19 global pandemic sharply reduced production.
The debtors’ assets suffered significant damage from five named storms and hurricanes during 2020 and 2021, leading to further reductions in production. Comment: According to BSEE, 7 tropical systems affected GoM operations in 2021, so the number of storms is not in dispute. The extent to which maintenance or preparedness issues contributed to the damage is unknown.
In 2020, a foreign-flagged vessel struck a platform owned by one of the debtors resulting in major damage and substantial losses of production. Comment: Apparently, this is the incident being cited. According to the BSEE report, the operator (Cox) was not at fault. Per BSEE: (1) The navigational lights and foghorn on the platform were maintained and in operational order, (2) the allision was not due to any platform related error, and (3) the platform’s operator and safety system responded in accordance with the regulations.
At this time, the debtors’ production volume is half what it was in 2019. Comment: Comparing the 2019 and 2022 production data, OCS oil and gas production are down by about 30% and 40% respectively. However, the 50% reduction figure seems reasonable given the likelihood of further reductions in State water production and in 2023.
A recent fatal incident involving a person working on an offshore oil and gas facility has provided a tragic reminder of the risks of work involving the rigging, manipulation and movement of loads, including people and equipment.
Despite the international focus on lifting operations over the past 30 years, Norwegian and US data do not suggest improved performance. PSA Norway’s “Trends in risk level on the Norwegian Continental Shelf” report shows an increase in lifting incident rates for both fixed and mobile facilities over the past 10 years (first chart below).
Similarly, recent lifting data from BSEE’s incident tables (summary below) and Jason Mathew’s June 2022 presentation (pages 48-63) suggest that lifting risks are not being effectively mitigated. Why are industy/regulator messages regarding hazard identification and controls not achieving the desired results? Perhaps a fresh look and renewed dialogue are needed.
Crane or personnel/material handling incident (as used in 30 CFR 250.188(a)(8)) refers to an incident involving damage to, or a failure of, the crane itself (e.g., the boom, cables, winches, ballring), other lifting apparatuses (e.g., air tuggers, chain pulls), the rigging hardware (e.g., slings, shackles, turnbuckles), or the load (e.g., striking personnel, dropping the load, damaging the load, damaging the facility) at any time during exploration, development, or production operations on the OCS. This includes all incidents of shock loading that, upon inspection, reveals damage to any part of the crane, lifting apparatus, rigging hardware, or load. Personnel handling incidents include events involving swing ropes, personnel baskets, and any other means to move personnel. Material handling incidents include any activities involving the loading and unloading of material and moving it on, off, or around an OCS facility.
A Metairie-based oil company that’s one of the largest independent operators still working in the state’s shallow coastal waters has filed for bankruptcy protection, leaving dozens of south Louisiana service and supply companies facing potential bankruptcies of their own.
Bankruptcy court documents show Cox’s estimated liabilities are close to $500 million – more than $200 million of which is owed to small businesses in the Houma-Thibodeaux and Acadiana areas.
Court documents indicate that Cox followed a path that led to financial trouble for other companies in recent years: using debt to acquire large fields of aging wells in shallow Gulf waters.
This blog is primarily concerned with the potential impacts of the bankruptcy on safety performance, the plugging of wells, and the decommissioning of old facilities. Per BOEM’s data base, Cox currently operates 276 Gulf of Mexico platforms, all in shallow shelf waters. The company is reported (Nola.com) to owe $8 million in bond premiums needed to support well plugging operations.
Cox has not been an active driller of late with only 2 well starts since 1/1/2022 (BSEE borehole file).
Cox has been a major generator of INCs (incidents of noncompliance) with 437 INCs YTD. Cox has been responsible for 47% of all GoM INCs in 2023. Cox’s INC to inspection ratio was 2.46 vs. a combined ratio of 0.50 (490/972) for all other GoM operators.
Cox is currently ranked 11th and 18th respectively in GoM gas and oil production with 7.2 billion cu ft and 1.8 million barrels produced YTD.
Per BOEM’s latest update, 137 of the 313 Sale 259 tracts receiving bids have now been accepted. No decision has been made on the other 176 high bids, including the 69 bids for carbon sequestration purposes. For the reasons previously expressed, I continue to believe those sequestration bids were invalid.
I believe the OOC is the world’s oldest trade association for the offshore oil and gas industry. The OOC was formed in 1948, five years before the enactment of the OCS Lands Act and just one year after the first Gulf of Mexico well was completed out of sight of land.
For much of their history, OOC had just a single, part-time employee. The organization has matured, but still operates in the same efficient manner, relying on subject matter experts from their member companies. Since the days of the OCS Orders, the OOC has consistently provided informed comments on operating regulations. As a regulator, I had issues with some of their comments over the years, but the dialogue was (almost😉) always polite and professional.
Congratulations to the OOC for the support they have provided for US offshore energy! Although many have had important roles, these former OOC representatives come immediately to mind for their contributions to offshore safety: John Rullman, Steve Brooks, Mark Witten, Sandi Fury, Dave Wisch, Ken Arnold, Charlie Williams, Phil Smith, Peter Velez, Allen Verret, Wanda Parker, Cort Cooper, Charlie Duhon, Jodie Connor, Craig Castille, Susan Hathcock, and Pat O’Connor. Many of these retired safety leaders, and current OOC Executive Director Evan Zimmerman, were recipients of MMS Offshore Leadership Awards.
Just as I was lamenting the absence of scientific surveying in the Atlantic, my former colleague Renee Orr brought this NOAA announcement to my attention. Researchers from the University of Texas Institute of Geophysics and Lamont-Doherty Earth Observatory, with funding from the National Science Foundation, propose to conduct seismic surveys in the Blake Plateau area of the South Atlantic (map below).
The proposed study would acquire two-dimensional (2-D) seismic reflection and seismic refraction data to examine the structure and evolution of the rifted margins of the southeastern United States, including the rift dynamics during the formation of the Carolina Trough and Blake Plateau.
The survey will lead to a better understanding of “the interaction between tectonic and magmatic processes that led to continental breakup and the onset of seafloor spreading in the central Atlantic Ocean 200 million years ago.” The investigators are particularly interested in the “stratigraphy of sediments that formed during and after rifting, the degree of crustal stretching at the continental margins, crustal faults that formed during extension of the margin, and the geometry of lava flows that were placed on the crust before the start of seafloor spreading.”
While not a primary purpose, the research should improve our understanding of the relationship between productive oil and gas fields offshore Africa and US analogs. Paul Post and his BOEM team estimated that the US Atlantic could contain >20 billion BOE (link to the latest report).
NOAA has conducted a detailed review of the proposal and made a “preliminary determination that the impacts resulting from this activity are not expected to adversely affect any of the species or stocks through effects on annual rates of recruitment or survival.”