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Archive for the ‘Regulation’ Category

Whenever oil and gas prices rise, we hear the non-producing leases shtick

Posted in energy policy, Offshore Energy - General, Regulation, tagged , , , , on May 13, 2022| Leave a Comment »

Department of the Interior spokesperson: “there are 10.9 million acres of offshore federal waters already under lease to industry,” and “of those, the industry is not producing on more than three-quarters (75.7% or 8.26 million acres).”

Fox Business

As if the preventable expiration of the 5 year leasing program wasn’t bad enough, we get to hear the non-producing leases bit yet again. This pitch was popularized during the oil embargoes in the 1970’s and resurfaces whenever it is deemed to be politically helpful.

New comments:

Old comments:

  • 539 days since the last US offshore oil and gas lease sale
  • 182 lease sales since 1954, but none since 2020
  • Only 0.5% of US offshore land is leased for oil and gas exploration and production (assuming commercial quantities of oil and gas are discovered).
  • When you acquire a lease, you are not purchasing oil and gas. You are acquiring the right to explore for, and hopefully produce, those resources. Most leases will never produce.
  • Drilling strategies are linked to geophysical data and geologic information obtained in drilling other wells in the area and region.
  • Leases expire if they are not producing by the end of the lease term, which is 5 to 10 years depending on location.
  • You pay bonuses for all leases and annual rental fees for non-producing leases. None of these payments are returned if no discoveries are made.
  • US offshore leases are among the smallest in the world, only a fraction of the sized of those offered by most other nations with offshore oil and gas programs. This complicates exploration and often makes development contingent on the acquisition of additional tracts at future sales.
  • Oil is where you find it, not where you or the government think it is or want it to be.

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Questions about Gulf of Mexico carbon sequestration

Posted in CCS, climate, energy policy, Gulf of Mexico, pipelines, Regulation, tagged , , , , , , , , on May 12, 2022| Leave a Comment »

Background:

Questions:

  • What are the costs per ton of offshore carbon sequestration including emissions collection, offshore wells and platforms, the associated pipeline infrastructure, ongoing operational and maintenance costs, and decommissioning?
  • What is the timeframe given that the starting point is likely years away?
  • How long would CO2 sequestration continue.
  • Who pays? Polluters? Federal subsidies? Tax credits?
  • Who is liable for:
    • safety and environmental incidents associated with these projects?
    • CO2 that escapes from reservoirs, wells, and pipelines (now and centuries from now)?
    • decommissioning?
    • hurricane preparedness and damage?
  • For Gulf of Mexico sequestration, how much energy would be consumed per ton of CO2 injected? Power source? Emissions?
  • To what extent will these operations interfere with other offshore activities?
  • Relatively speaking, how important is US sequestration given:
  • What are the benefits of offshore sequestration relative to investments in other carbon reduction alternatives?
  • Will BOEM conduct a proper carbon sequestration lease sale with public notice (as required by BOEM regulations) such that all interested parties can bid?
    • What will be the lease terms?
    • Environmental assessment?
    • How will bids be evaluated?
  • What happens to the Exxon bids if the Judge’s Sale 257 decision is reversed?
  • What is the status of the DOI regulations mandated in the legislation with an 11/15/2022 deadline?
    • When will we see an Advanced Notice or Notice of Proposed Rulemaking?
    • Given that DOI has no jurisdiction over the State waters and onshore aspects of these projects, what is the status of parallel regulatory initiatives?
  • Finally and most importantly, how does drilling offshore sequestration wells instead of exploration and development wells increase oil and gas production?
highly simplified conceptual diagram

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Thank you US Coast Guard….

Posted in Offshore Energy - General, Regulation, tagged , , , , , , , , , on May 11, 2022| Leave a Comment »

….for continuing to recognize the Conservation Division of the Geological Survey (USGS) as the US offshore safety regulator, even though 40 years have passed since that was the case and there have been 3 successor bureaus. 😀

33 CFR § 140.4 Relationship to other law. (current text excerpted from Coast Guard Subchapter N regulations)

(a) Design and equipment requirements of this subchapter for OCS facilities, including mobile offshore drilling units in contact with the seabed of the OCS for exploration or exploitation of subsea resources, are in addition to the regulations and orders of the U.S. Geological Survey applicable to those facilities.

USGS North Atlantic District, Hyannis, MA, Halloween 1980

Most of us old-timers think the best regulatory framework for the offshore program was in the USGS days (pre-1982). Some of this may be nostalgia, but there are some good reasons for this thinking:

  • USGS was/is an internationally acclaimed scientific organization that was always headed by a renowned geologist. The regulatory program was thus somewhat insulated from political pressures. Vince McKelvey, Bill Menard, and Dallas Peck were the Directors when I worked for USGS. Their credentials are linked. Bill and Dallas visited our Hyannis office (not at Halloween 😀) and were very supportive.
  • The Conservation Division was responsible for onshore operations on Federal lands as well as offshore activity. This facilitated information sharing and offered diverse career opportunities. My first bosses in New Orleans had worked previously in the Farmington and Roswell, NM offices.
  • We had excellent synergy with the other USGS divisions. The Marine Science Center in Woods Hole was an incredible resource for our Hyannis office. The Woods Hole office, particularly Mike Bothner and Brad Butman, had a critical role in the Georges Bank Monitoring Program, the best ever (in my biased opinion) environmental study of exploratory drilling operations in a frontier area.
  • The USGS Conservation Division had a very small and supportive headquarter’s staff, which minimized the potential for conflict with field offices.
  • Prior to the formation of the Minerals Management Service (MMS) in 1982, the Bureau of Land Management was responsible for leasing, but all regulatory functions were under USGS. This included resource evaluation/conservation, plan review and approval, permitting, inspections and enforcement, and investigations. The division of MMS responsibilities, most notably the assignment of plan approval to the leasing bureau (BOEM) rather than the regulatory bureau (BSEE), complicates the work of both bureaus and is a prescription for inefficiency, confusion, overlap, and conflict.

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Macondo revisited, Part 4: What might have been

Posted in accidents, Gulf of Mexico, Offshore Energy - General, Regulation, well control incidents, tagged , , , , , , on April 21, 2022| Leave a Comment »

While the previously discussed planning, cementing, and well suspension issues allowed the well to flow, there were many other equipment, operational, and management deficiencies that elevated the incident to a disaster. Below are those that bother me the most:

  • Blowout Preventers
    • The Deepwater Horizon BOP stack had a single blind shear ram. Regardless of what the regulations allowed, you don’t drill a complex well like this without redundant shearing capability (and at the time of the blowout most deepwater drillers were using rigs with dual shear rams). All well control emergencies requiring the emergency disconnect sequence, deadman, and autoshear functions are dependent on effective shearing capability. You can have redundancy in every other BOP element, but without dual shear rams, you don’t have a redundant BOP system. Further, for full redundancy both shear rams should be capable of sealing the well bore after shearing. In that regard, the present regulations and the applicable standard (API S 53) require only one shear ram capable of sealing. They are thus deficient and should be updated.
    • The DWH BOP system did not have full bore shearing capability (available at the time) which may have sheared the deflected drill pipe.
    • The DWH BOP system was not properly maintained and recertified as required by regulation.
    • Transocean’s “condition based maintenance” was a euphenism for “fix it when it fails.” Perhaps worse, BP authorized the continuation of operations knowing that an annular preventer was leaking.
  • The initial flow from the well was directed to the mud-gas separator instead of being routed overboard via the diverter. Routing the flow to the diverter would have provided additional time for the crew to safely evacuate.
  • Gas detectors
    • Not all gas detectors were fully operational. As justification, Transocean’s report expressed concerns about alarm fatigue, a weak excuse. Alarm issues can be effectively managed without disabling the devices.
    • The gas detectors did not automatically shutdown the generators, the source of the initial explosion. This is somewhat understandable on a dynamically positioned rig that is dependent on power to maintain position. However, someone should have shut down the generators as soon as gas was detected.
  • Engine overspeed devices didn’t work, and apparently weren’t tested regularly. Had they worked, the engine room explosion may have been prevented.
  • The crew had time to activate the Emergency Disconnect Sequence, but did not.
    • Deficient training
    • Uncertain chain of command
    • Fear of repercussions?

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4 operators accounted for 64% of Gulf of Mexico violations during Q1 of 2022

Posted in Gulf of Mexico, Regulation on April 8, 2022| Leave a Comment »

Per BSEE’s online Incident of Non-Compliance (INC) data, 4 operating companies accounted for 64% of the INCs during Q1 of 2022 (see chart below). Fieldwood was once again cited for the most INCs (132), but GOM Shelf LLC had the highest INC/inspection ratio (1.53). All 55 of the Whitney Oil & Gas INCs resulted in Facility Shut-In orders. Whitney was cited for failing to comply with damage inspection and records requirements following Hurricane Ida.

The overall violations rate during Q1 of 2022 was essentially unchanged from 2021. A number of companies had outstanding records. We’ll comment on them later in the year.

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500 days

Posted in energy policy, Gulf of Mexico, Offshore Energy - General, Regulation, Russia, tagged , , , , on April 4, 2022| Leave a Comment »

500 days (and counting) since the last US offshore oil and gas lease sale. Abbreviated chronology:

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Congratulations to Bryan Domangue, BSEE’s new Gulf of Mexico Regional Director

Posted in Gulf of Mexico, Offshore Energy - General, Regulation, tagged , , , on March 29, 2022| Leave a Comment »

Mr. Domangue began his career with BSEE in 1997 and has more than 30 years of experience in the oil and gas industry. He has served as the Deputy Regional Director for Districts, Investigations, Environmental, and Enforcement (DIEE), as Senior Technical Advisor for the BSEE Gulf of Mexico Region and was the Acting Chief of the National Offshore Training Center. Mr. Domangue also previously served as Office Supervisor for Regional Operations, and as District Manager for the Houma District Office of the BSEE Gulf of Mexico OCS Region. He holds a BS degree in petroleum engineering from Louisiana State University.

BSEE

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C-NLOPB’s prompt public notification of incidents is good regulatory practice

Posted in accidents, Canada, Offshore Energy - General, Regulation, tagged , , on March 28, 2022| Leave a Comment »

Below and linked is the most recent C-NLOPB incident posting:

  • Timely
  • Front page
  • Advises about any casualties or pollution (none in this case)
  • Briefly describes incident without speculating on causes
  • Informs about next steps
  • Well done

INCIDENT DISCLOSURE 2022

NEAR MISS ON THE HIBERNIA PLATFORM

March 25, 2022

Hibernia Management and Development Company (HMDC) has reported that on March 20, 2022 a crane on the Hibernia Platform was lifting a mini container when it made contact with a scaffold hoarding. There were three people working inside the hoarding at the time of contact. No one was injured and there was no damage to the scaffold hoarding.

West pedestal crane operations were halted and HMDC has initiated an investigation to determine the potential classification of the incident.

C-NLOPB Safety Officers were already scheduled to travel to the Hibernia Platform in the coming days and will follow up with HMDC to review this incident and the near miss that occurred on March 15.

The C-NLOPB is also monitoring HMDC’s investigations of these incidents.

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Well Control Equipment Systems Safety Report

Posted in drilling, Gulf of Mexico, Regulation, well control incidents, tagged , , , , , on March 10, 2022| Leave a Comment »

This useful SafeOCS report summarizes and itemizes well control equipment failures associated with well operations on the Gulf of Mexico OCS in 2020. Of particular note was the absence of any loss of containment (leak of wellbore fluids) events in 2020 or the prior two years.

Unfortunately, there appear to be significant reporting gaps despite the fact that reporting of these data is required by regulation (30 CFR 250.730(c)). The reporting issues are particularly serious for surface systems (surface BOP and associated equipment). Per SafeOCS, surface rig reports were received from less than 50% of active operators and rigs. Reporting for subsea systems (subsea BOP and associated equipment) was much better with 85% of the active rigs represented.

Of further concern with regard to the reporting of surface equipment events, the data indicate only 5.3 events per 1000 hours for surface systems vs. 71.5 for subsea systems. While subsea systems are more complex, the cost of pulling and repairing subsea equipment dictates newer, better maintained equipment. As a result, surface BOPs have historically had higher failure rates than subsea BOPs. The data below are from a presentation to MMS approximately 15 years ago. Both the Sintef and OOC data show higher failure rates for surface BOPs.

The SafeOCS team did a very good job of analyzing the reports and presenting the data. However, the reporting issues need to be investigated and resolved to get maximum value from this very important work.

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OSHA vax standard lives on as a proposed rule

Posted in Health, Regulation, tagged , , on January 27, 2022| Leave a Comment »

Although OSHA is withdrawing the Vaccination and Testing ETS as an enforceable emergency temporary standard, OSHA is not withdrawing the ETS to the extent that it serves as a proposed rule

OHSA Notice

Should we call the proposed rule an ETS variant?

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