Posted in CCS, energy policy, Offshore Energy - General, Regulation, tagged Atlantic OCS, CCS, New Jersey, PureGen One on November 22, 2021| Leave a Comment »
The plan was for SCS Energy’s PurGen One plant in Linden, NJ to burn coal to generate electricity and produce fertilizer. SCS proposed to inject 90% of the CO2 into subsurface reservoirs 70 miles offshore. The project faced strong opposition and was ultimately nixed by the State. The plan had been presented to the Federal offshore regulator (MMS), but the company was advised that there was no legal framework for disposing CO2 beneath the OCS.
Posted in energy policy, Regulation, Uncategorized, tagged reorganization on November 15, 2021| Leave a Comment »
Posted in hurricanes, Regulation, tagged OSHA, Regulation, vaccine mandate on November 7, 2021| Leave a Comment »
The 5th U.S. Circuit Court of Appeals granted an emergency stay of the requirement by the federal Occupational Safety and Health Administration that those workers be vaccinated by Jan. 4 or face mask requirements and weekly tests.
NPR
This court action was completely predictable from the outset. OSHA no doubt knew this but had no option but to dedicate substantial resources to the task. In all likelihood, the ETS/regulation will never be finalized.
Many (probably most) proposed regulations are never completed. Others never get beyond the concept stage. Establishing an OSHA rule takes an average of 7 years. That is not at all atypical for Federal regulators. There are much better ways to accomplish the regulatory objectives as was demonstrated after Hurricanes Katrina and Rita in 2005. Unfortunately our political system frowns on collaborative approaches so we do things the hard way – accomplishing much less in much more time and at a far greater cost.
Posted in Offshore Energy - General, Regulation, tagged emergency temporary standard, offshore industry, OSHA, vaccination on November 5, 2021| Leave a Comment »
The legal challenges are already in motion, and the arguments are compelling:
“The order is unconscionable. OSHA does not know how to run our companies. We do,” said Steve Fettig, Secretary and Treasurer of Tankcraft and Plasticraft. “OSHA does not know how to keep our employees safe. We do. And we have done so successfully since the start of the pandemic without the interference of a federal bureaucracy. We respect our employees’ fundamental right to make their own private, difficult medical choices.”
Milwaukee Journal
Posted in energy policy, Gulf of Mexico, natural gas, Offshore Energy - General, Regulation, tagged Argonne, BSEE, EPA, flaring, methane, venting on November 4, 2021| Leave a Comment »
Among other provisions, EPA’s proposed rule, issued on 11/2/2021, specifies that associated gas be handled as follows:
Route associated gas to a sales line. If access to a sales line is not available, the gas can be used as an onsite fuel source, used for another useful purpose that a purchased fuel or raw material would serve, or routed to a flare or other control device that achieves at least 95 percent reduction in methane and VOC emissions.
Because the Dept. of the Interior has jurisdiction over air emissions on most of the Gulf of Mexico OCS, I assume this proposed rule does not apply to those facilities. However, the EPA proposal is not entirely clear in that regard. If the EPA proposal does not apply, will BOEM/BSEE be proposing similar restrictions in their regulations?
MMS/DOI considered prohibiting venting, but determined that adding flaring capability was not feasible for many shelf platforms, and for some platforms there would have been a net increase in emissions. That said, venting is not insignificant. A 2017 Argonne study indicated (table 2) that, for shelf platforms from 2011 through 2015, more than 3 times as much gas was vented as was flared. More recent data should be reviewed to get a better sense of the costs, benefits, and safety considerations associated with achieving further reductions in venting.
Current flaring/venting regulations for OCS facilities are here.
Posted in decommissioning, energy policy, Offshore Energy - General, pipelines, Regulation, tagged decommissioning, pipelines, Regulation, Scandpower on October 19, 2021| Leave a Comment »
Scandpower study (2004) for MMS:
Overall Conclusion
Currently, there are no regulations that require removal of subsea pipelines if they are not an obstruction to navigation. Based on the high costs for removing the pipelines, the personnel risk involved in the removal operations, the negative effect on overall emissions to air and the very limited reduction in discharges to sea, the overall conclusion is that it is better to leave the pipelines in place. If possible, re-use of the pipelines is the optimal solution.
Environmental Impacts
The impacts on the environment and the marine environment from pipelines and cables left in place were found to be very minor. Conversely recovery operations will have a negative impact on the environment. The number of vessels required for removal operations and long operating hours will result in considerably more releases and emissions than leaving the pipelines in place. In addition the energy savings benefit from recycling the pipeline materials will be exceeded by the energy required to remove the pipelines and separate the materials.
Pipeline Decommissioning: Environmental Impact Metric (per Scandpower)
| Remove/ recycle | Remove/ landfill | Reuse or preserve | Bury | Abandon in place | |
| Energy | High | High | Low | Moderate | None |
| Emissions | High | High | Low | Low | Low |
| Discharges | Low | Low | Moderate | Low | Low |
| Habitat | Low | Low | Moderate | Low | Low |
| Aesthetics | Low | Moderate | None | None | None |
| Resource Utilization | High | None | High | None | None |
| Littering | Low | Low | Low | Low | Moderate |
The “Habitat” impacts row seems questionable. Pipeline removal certainly has a greater impact on habitat than abandonment in place, particularly for buried pipelines.
Posted in accidents, California, Offshore Energy - General, oil, Regulation, tagged Amplify, Beta Unit, Huntington Beach, inspections, pipeline spill, SLC on October 17, 2021| Leave a Comment »
This quote from an AP article is consistent with the view expressed here after our review of the inspection reports for the Beta Unit (Platform Elly to shore) pipeline. Further per the AP article:
Safety inspections in 2015, 2017 and 2019 found anomalies in Amplify’s pipeline, including instances of metal loss and three dents that were previously repaired. But several experts who reviewed the reports said the metal loss — which can be a sign of a pipe wall thinning as it corrodes with age — was relatively minor. The dents were not in the same area as the spill.
AP
Posted in accidents, California, Offshore Energy - General, oil, Regulation, tagged Beta Unit, BSEE, Huntington Beach, inspections, pipeline spill, SLC on October 14, 2021| Leave a Comment »
Aqueos 2020 external (ROV) inspection:
The 16” oil pipeline was found to be in good condition with no visible damage or anomalies.
Aqueos inspection report, May 2020
One (1) CP test point that was installed in 2014 was found to be displaced from its location on the pipeline (this was also noted in the 2018 survey), and no damage was noted at the location (Fix #101).
Pipe‐to‐electrolyte potential values recorded were:
‐ 921 millivolts (mV) on the 6” gas pipeline
‐ 910 millivolts (mV) on the 10” water pipeline
‐ 963 millivolts (mV) on the 10” gross fluids pipeline
‐ 906 millivolts (mV) on the 16” oil pipelineAs the NACE Standard SP0169‐2013 “Control of External Corrosion on Underground or Submerged Metallic Pipelines” criterion is ‐800 mV, all readings indicate that Cathodic Potential is within specifications.
Aqueos inspection report, May 2020
Metal loss data from Baker Hughes internal inspection (12/2019):
| Depth of Metal Loss | External Anomalies | Internal Anomalies |
| 30+% | 0 | 0 |
| 20-29% | 1 | 0 |
| 10-19% | 0 | 0 |
| total | 1 | 0 |
The metal loss findings are consistent with those reported in a previous internal inspection (Baker Hughes, 11/2017).
BSEE has general authority to require pipeline inspections under 30 CFR 250.1005. BSEE, the State Lands Commission, and the operator appear to have implemented an effective inspection program for the Beta Unit.
Posted in Gulf of Mexico, hurricanes, Offshore Energy - General, Regulation, tagged collaboration, DOI, Gale Norton, Hurricane Katrina, Hurricane Rita, OSHA, Regulation on October 13, 2021| Leave a Comment »
Establishing an OSHA rule takes an average of 7 years, and the process has ranged from 15 months to 19 years between 1981 and 2010, the Government Accountability Office (GAO) reported to Congress in 2012
EHS Daily Advisor
OSHA’s long rule promulgation timeframes are actually quite typical for US regulatory agencies. In some cases, employees work on a single rule for most of their careers! On the plus side, the rigorous internal and public review processes help prevent arbitrary and capricious actions by regulators. However, the long promulgation process often results in regulations that are outdated before they are published. As a result, the entire process repeats and you have a regulatory “do loop.”
To avoid the daunting rulemaking process, regulators often resort to issuing notices, letters, or conditions of approval that accomplish some of their objectives. However, these actions are not always consistent with the rule promulgation requirements of the Administrative Procedures Act and other directives, and are less likely to survive legal challenges.
The optimal approach is for the regulator to establish clear objectives for the operating companies and a schedule for achieving those objectives. This approach was demonstrated following the 2005 hurricane season (Katrina and Rita) when numerous mooring system and other stationkeeping issues were identified. In a face-to-face meeting, Department of the Interior Secretary Gale Norton outlined her concerns and informed offshore operators that there would be no drilling from moored MODUs or jackups during hurricane season until the issues identified during Hurricanes Katrina and Rita were addressed.
The collaborative effort that followed was a resounding success. In addition to addressing station keeping concerns, a comprehensive list of hurricane issues was developed. Industry and government then worked together to assess mitigations and develop new standards and procedures. The essential MODU standards were completed before the 2006 hurricane season, and all of the related concerns were effectively addressed prior to the 2009 hurricane season. Had the government elected to promulgate regulations to address all of these issues, much of this work would have never been completed.
Posted in Australia, NOPSEMA, Offshore Energy - General, Regulation, tagged Australia, inspection, NOPSEMA, offshore facilities on October 12, 2021| Leave a Comment »
Good read for you inspection and regulatory policy nerds. (I know you’re out there! 😃). The draft policy looks very good at first glance.
If (like me) you can’t help yourself, here is the link for providing feedback.
Bud's Offshore Energy (BOE) 