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Archive for the ‘Regulation’ Category

New BOEM Director: Liz Klein

Posted in energy policy, Gulf of Mexico, Offshore Energy - General, Regulation, tagged , , , on January 10, 2023| Leave a Comment »

Liz is an experienced attorney and leader in clean energy, climate change, and environmental law and policy. A member of the Biden-Harris administration since January 20, 2021, Liz has served as Senior Counselor to Secretary Haaland with an emphasis on water policy and climate change resilience. In this role, Liz also served as Chair of the Indian Water Rights Working Group, which manages, negotiates and implements settlements of water rights claims.

Prior to joining the Administration, Liz was Deputy Director of the non-partisan State Energy & Environmental Impact Center at NYU School of Law, which supports state Attorneys General addressing clean energy, climate, and environmental initiatives of regional and national importance. President Biden is the third President under which Liz has served at Interior, having worked for both the Clinton and Obama administrations. Under Secretaries Ken Salazar and Sally Jewell, Liz served as Interior’s Associate Deputy Secretary as well as Principal Deputy Assistant Secretary in the Office of Policy, Management and Budget. She was a key architect of the Obama Administration’s work to create a new offshore wind industry and leasing program.

DOI

Congratulations to Ms. Klein on being appointed to lead the Bureau of Ocean Energy Management. In addition to her commendable support for offshore wind energy, I trust that she appreciates the national importance of the OCS oil and gas program and the need for regular lease sales.

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More on the tragic Gulf of Mexico helicopter crash (12/29/2022)

Posted in accidents, Gulf of Mexico, Offshore Energy - General, Regulation, tagged , , , , , , , , , on January 9, 2023| Leave a Comment »

David Scarborough, Island Operating Co. employee who died in the crash.
  • The bodies of the 4 victims have been recovered.
  • The 3 offshore workers were employees of Island Operating Co., a production contractor. The pilot worked for Rotorcraft Leasing Company, the owner of the Bell 406 helicopter that crashed. The platform is owned by Walter Oil and Gas, the operating company.
  • A preliminary FAA report confirms that the helicopter crashed onto the helideck during takeoff, breaking apart and falling into the Gulf.
  • 4 passengers had been dropped off at the platform before the fatal takeoff. Presumably there were witnesses to the incident.
  • According to the FAA report, the platform was located at West Delta Block 106. Per the BOEM platform data base, the platform was installed in 1994, is in 252′ of water, and is continuously manned.
  • Per the BSEE INC data base, the platform had not been cited for any violations since 2016.

Lacy Scarborough, wife of victim David Scarborough, is pregnant. Tragically, the couple lost their first child in an accidental drowning in March. David was heading home for the holidays after completing his 2 week shift on the platform. He had worked offshore for 8 years. Per Lacy, David’s last message was that he was taking off and would be home soon.

The only other victim who has been identified is Tim Graham of Quitman, Mississippi.

I trust that the NTSB will conduct a timely and thorough investigation, and hope they consider offshore helideck oversight, both in terms of industry programs and government regulation. 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.

More on the crash: ominous message, update #3

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Raphael Moura (ANP Brazil) interview

Posted in IRF, Offshore Energy - General, Regulation, well control incidents, tagged , , , , on December 22, 2022| Leave a Comment »

Raphael is a highly regarded offshore safety leader and a positive force for continuous safety achievement in Brazil and internationally.

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This Well Control Rule comment, endorsed by 7 trade associations, hit a nerve. Here’s why.

Posted in drilling, Offshore Energy - General, Regulation, well control incidents, tagged , , , , , on November 30, 2022| Leave a Comment »

The comment (pasted below) by the trade associations asserts that BSEE ignored the requirements of the National Technology Transfer and Advancement Act (NTTAA).

Reaction:

  • BSEE and its predecessors (MMS and the Conservation Div. of USGS) have been incorporating industry standards since 1969, 27 years prior to the enactment of the NTTAA (1996).
  • 127 standards are currently incorporated into the BSEE regulations. Does this imply ignoring the NTTAA?
  • The keystone of the BOP regulations, API Standard 53, is cited in 250.730, the very section of the rule that is under discussion. Seven other industry standards are cited in that section of the rule. Does this imply ignoring the NTTAA?
  • Regulators cannot cede their authority to standards development organizations. If a standard is outdated or deficient, the regulator must address the issues of concern.
  • Deviations between provisions in the regulations and API Standard 53 are expected and specifically provided for in 250.730 as follows: “If there is a conflict between API Standard 53 and the requirements of this subpart, you must follow the requirements of this subpart.“
  • For years, the production safety system regulations specified different leakage rates for surface and subsurface safety valves than those allowed in the API standards. An MMS research project addressed and helped resolve these differences.
  • While essential to safety and regulatory programs, standards are not a panacea; nor is the standards development process without weaknesses. One need only consider the case of the delayed cementing (zonal isolation) standard to appreciate both the importance of standards and the potential weaknesses in the development process.

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OK, but what do you think about the revisions to the Well Control Rule? 😀

Posted in Offshore Energy - General, Regulation, well control incidents, tagged , , on November 23, 2022| Leave a Comment »

I recommend we Nationalize the Oil and gas industry. I think the government is the right entity at this time to seize all the assets and infrastructure of the cartels. The resources mostly on public lands and water, belong to the USA anyway. It is time we transition more rapidly to renewables to break the leverage of the cartels on governments, and people, to stop wars and profiteering.

People are paying high prices and cartels like API, Exxon, Sinclair are making record profits from American’s purses. All the while escaping the costs of oil spills and leaks, and denying responsibility for climate change disasters and their costs.

Anonymous WCR commenter (0010)

Diverse input on proposed regulations is healthy and desirable. However, comments should not be posted at Regulations.gov unless (1) the commenter is identified and (2) the comments include at least one sentence about the regulation being proposed.

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Well Control Rule commenters

Posted in Offshore Energy - General, Regulation, well control incidents, tagged , , on November 22, 2022| Leave a Comment »

Per Regulations.gov. BSEE received 30 comments on the proposed revisions to the Well Control Rule, 25 of which have been posted. The other comments were presumably deemed inappropriate for posting per the guidance at Regulations.gov.

Two of the responses were submitted collectively by 8 industry trade associations. Only 3 operating companies commented and their comments largely echoed the trade association responses. Only 2 drilling contractors responded independently. Four service and engineering companies commented.

Three environmental organizations, a group of Atlantic states, a government watchdog, and a law school provided comments.

Three individuals and 4 anonymous or unknown parties commented.

Below is a list of the respondents preceded by their comment identifiers. More to follow.

  • 0003 Foley Engineering
  • 0004 Frank Adamek
  • 0005 Anonymous
  • 0006 Project on Government Oversight (POGO)
  • 0007 E.P. Danenberger
  • 0008 Chevron
  • 0009 B. Mercier
  • 0010 Anonymous
  • 0011 Anonymous
  • 0012 Foley Engineering (2nd comment)
  • 0013 HMH (?)
  • 0014 NYU School of Law
  • 0015 Beacon Offshore
  • 0016 Shell
  • 0017 Diamond Offshore
  • 0018 7 industry trade associations: API, IADC, IPAA, NOIA, OOC, EWTC, USOGA
  • 0019 NOV (service company)
  • 0020 NRDC
  • 0021 Oceana
  • 0022 Transocean
  • 0023 Louisiana Mid-Continent Oil & Gas Association
  • 0024 Kinetic Pressure Control Limited
  • 0025 Attorneys General of Maryland, Connecticut, Maine, Massachusetts, New York, and North Carolina
  • 0026 Ocean Conservancy
  • 0027 Rigscope International

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RIP Mike Conner, deepwater safety leader

Posted in Gulf of Mexico, Offshore Energy - General, Regulation, Uncategorized, tagged , , , , on November 16, 2022| Leave a Comment »

On Monday, the offshore world lost Mike Conner, an outstanding engineer and a major contributor to the success of the US offshore program.

Mike is the person most responsible for the Deepwater Operations Plan (DWOP), a pioneering safety-case approach to regulating deepwater oil and gas development. The DWOP program was initiated 30 years ago and facilitated deepwater production at a time when there were no deepwater-specific regulations or standards. Innovative tension leg platform, compliant tower, spar, production semisubmersible, and subsea projects would not have been possible without the DWOP program. 93% of Gulf of Mexico oil production and 76% of the gas is now attributable to deepwater production facilities. Thanks in large part to the DWOP program, these facilities have had a nearly flawless safety and environmental record.

While his obituary is no yet available, this link announces Mike’s well-deserved selection for the OTC Heritage Award in 2017, and provides good information on Mike and his career.

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Comments on revisions to BSEE’s Well Control Rule

Posted in Offshore Energy - General, Regulation, well control incidents, tagged , , on November 10, 2022| Leave a Comment »

Comments on the proposed revisions to BSEE’s Well Control Rule are due on Monday (11/14/2022). My comments were submitted yesterday, and I have attached a copy for those who might be interested. Bud

wcr-comments-2Download

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BSEE’s decommissioning notice has been posted

Posted in decommissioning, Gulf of Mexico, Offshore Energy - General, Regulation, tagged , , , on November 8, 2022| Leave a Comment »

BSEE’s temporary abandonment/decommissioning solicitation has been posted. Some details:

  • 14 wells to be decommissioned
  • 1 well to be checked to confirm temporary abandonment
  • Well depths: 2359′ to 11934′
  • Water depths: 70′ to 477′
  • 11 gas wells, 3 oil wells
  • Well completion dates: 2006-2008
  • Last production: 2010-2013 (Presumably, the short productive life of these wells either contributed to or was because of the lessees’ bankruptcies.)
  • $25,000😀 minimum to $100,000,000 maximum contract guarantee

If I was an offshore contractor, I wouldn’t touch this work without:

  1. Ironclad liability protection after the work is completed and inspected. A contractor should not inherit the perpetual liability that the lessees knowingly and willfully accepted when they purchased the leases and conducted operations; nor is the contractor responsible for the failure of industry and government to establish a financial assurance framework that protects the taxpayer from such liabilities.
  2. Protection against likely cost overruns related to the uncertain downhole condition of the wells.

Previous posts on this matter:

Taxpayer funded decommissioning – troubling precedent for the US offshore program

NOT a shining moment for the offshore industry

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Programmatic EIS for Pacific OCS platform decommissioning presents 4 alternatives, none of which are workable

Posted in California, decommissioning, Offshore Energy - General, Regulation, rigs-to-reefs, tagged , , , , on October 20, 2022| Leave a Comment »

The 23 platforms in Federal waters offshore California are from 33 to 55 years old. Most are no longer producing and 8 are on terminated leases. Some of the platforms are massive structures in water depths up to 1200′ (list of platforms and map below).

BOEM’s draft programmatic EIS evaluates 4 decommissioning alternatives, none of which appear to be workable for a combination of economic, environmental, and legal reasons:

  • Alternative 1 involves the complete removal of platforms and pipelines. This alternative is cost prohibitive and environmentally unfavorable.
  • Alternatives 2 and 3 evaluate prudent and environmentally responsible partial removal options. Unfortunately, partial removal and reefing are not feasible under the California Resources Legacy Act (AB 2503). This legislation holds the donating company perpetually liable for any damages associated with the reef structure. While not assuming any liability, the State nonetheless collects 80% of the savings (reefing vs. complete removal). As a result, it’s no surprise that no company has applied to participate in the State’s program.
  • Alternative 4 calls for leaving platforms and pipelines in place after emptying tanks and flushing pipelines. This “no action” baseline alternative violates the lease agreement and 30 CFR 250.1725, and would only be permissible if an alternate use was approved for the platforms per 30 CFR Part 585.
  • The EIS, with minimal discussion and no supporting data, rules out alternate uses at any of the 23 platforms. This exclusion would seem to be premature given the win-win-win opportunities for industry, government (Federal, State, and local), and academia. These include deferred decommissioning liabilities, a wide range of research opportunities, security and defense applications, weather observation and climate studies, maritime communications support, education programs, marine seismicity studies, and hydrokinetic energy projects. With proper maintenance, platforms can continue to provide social benefits long after all wells are plugged and production equipment is removed. However, once removed, replacement costs would be prohibitive.
  • Lastly, the EIS avoids the thorny financial responsibility issues that will complicate decommissioning decisions. Note the questions raised in the “troubling case of platforms Hogan and Houchin.”
  • Those wishing to comment on the draft EIS should follow the posted instructions.

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