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The 2025 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 5 facility inspections (0.20 INCs/facility inspection). This is a higher standard (fewer INCs) than in previous years.
  • 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 2025, there were on average 3.2 inspections for every facility inspection.
operatorWCSIFSItotal INCsfacility inspINCs/
fac insp
inspINCs/
insp
Shell381122310.055570.02
Chevron1080182600.077720.02
Oxy26191330.073250.03
BP820101220.083040.03
Murphy6208700.111770.05
Cantium574161210.134880.03
Gulf-wide 202581544584134431790.42102180.13
Gulf-wide 2024957398109146431330.47106640.14
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 2025, there were on average 3.2 inspections for every facility inspection

Criteria: 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. Although Panel Investigations are conducted for fatalities, serious injuries, and significant pollution events, the last panel report was for an incident on 3/25/2022, and no information is available for any ongoing investigations. BSEE District offices investigate the more significant incidents that don’t qualify for panel investigations. These District Investigation reports are more timely, but some are not issued within 90 days of the incident. The District reports will be reviewed later in the year. Note that there were no occupational fatalities in 2025.

Observations:

  • The overall inspection and INC results for 2025 were similar to those for 2024.
  • The top companies performed better in 2025 than in 2024. In 2024, only 2 companies had INC/facility inspection ratios of <0.10 and only 3 had ratios <0.15. In 2025, all 6 of the performance leaders had ratios <0.15.
  • All 6 of these top companies were also on the 2024 top performers list.
  • Shell’s total INCs and INCs/facility inspection decreased by 73% and 78% respectively vs. 2024
  • Cantium, which operates 85 shallow water platforms, has demonstrated that a shelf operator can be an outstanding safety performer. Cantium’s total INCs and INCs/facility inspection decreased by 50% vs. 2024
  • Should fewer inspections be conducted at facilities that have such low INC rates? On the one hand, fewer inspections would reduce regulatory costs and transportation risks. On the other hand, there are benefits from BSEE inspection visits besides compliance enforcement. These include direct communication with offshore workers (including contractors) regarding regulatory policies and safety practices, witnessing safety tests, evaluating new technology, and assessing management system implementation and corporate culture at the facility level.
  • Absent specific details on the violations, no attempt was made to weight the INCs. Although shut-in INCs are generally considered to be more significant than warnings, that is not always the case. For example, a component shut-in INC for a safety device that is marginally out of tolerance and is corrected on the spot may be less serious than a warning that is indicative of structural deterioration, poor maintenance, or organizational shortcomings.

Not meeting one of the activity level requirements, but nonetheless noteworthy, were the compliance records of LLOG and BOE Exploration & Production (younger than and unrelated to the BOE blog 😀). See their impressive results below:

operatorWCSIFSItotal INCsfacility inspINCs/
fac insp
inspINCs/
insp
BOE0011330.03780.01
LLOG1113290.10780.04

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Shell topped the list followed by Chevron, Oxy/Anadarko, bp, Murphy, and Cantium.

Details and observations will be posted tomorrow.

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Big Beautiful Gulf of America

Will the oil and gas lease sale boldly named Big Beautiful Gulf 1 (BBG1) live up to its grand name? Given the more favorable lease terms and the 2 year gap since the last sale, BBG1 should surpass the previous 3 sales (table below). Questions:

  • Which majors will be the most active bidders? Chevron? Shell? BP? Oxy/Anadarko?
  • Will former Gulf of Mexico stalwarts Exxon and Conoco Phillips participate for the first time in years? Probably not, but US super-majors should participate in the US offshore program.
  • How many companies will submit bids? Would like that to be a number >35.
  • How many tracts will receive bids? A number >300 would be very encouraging.
  • Will the total high bids exceed $400 million?
  • Will we see an increase in shelf interest?
  • Which independents will be the most active?
  • After the not-so-clever carbon disposal acquisitions in the last 3 sales, will the number of carbon disposal bids be zero? For the first time ever, the Federal government felt compelled to stipulate the obvious (see the proposed notice for OCS Sale 262) – that an Oil and Gas Lease Sale is only for oil and gas exploration and development.

See the summary data below for the last 3 Gulf lease sales. We’ll fill in the blanks next week.

Sale No.257259261BBG1
date11/17/20213/29/202312/20/202312/10/2025
companies
participating
333226
total bids223328423161
tracts receiving bids214324422751
sum of all bids
$millions
198.5309.8441.9
sum of high bids
($millions)
101.7263.8382.2
highest bid
company
block
$10,001,252.00
Anadarko
AC 259
$15,911,947
Chevron
KC 96
$25,500,085
Anadarko
MC 389
most high bids
company
sum ($millions)
46
bp
29.0
75
Chevron
108.0
65
Shell
69.0
sum of high bids ($millions)
company
47.1
Chevron
108
Chevron
88.3
Hess
most high bids by independent14-DG Expl.13-Beacon
13-Red Willow
22-Red Willow
1excludes 36 leases improperly acquired for carbon disposal purposes; 2excludes 69 leases improperly acquired for carbon disposal purposes; 3excludes 94 leases improperly acquired for carbon disposal purposes

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Salamanca FPU (Repsol photo)

Every deepwater platform installed since Feb. 2018, when Chevron installed its Big Foot tension leg platform (TLP), has been a Floating Production Unit (aka FPU or production semisubmersible). During that period, no new SPARs, FPSOs, or TLPs were installed.

The list (below) of these simpler, safer, greener FPUs has grown by two with the initiation of production at Shenandoah and Salamanca. Note the water depth range from 3725 to 8600 ft.

platformoperatorwater depth (ft)first production
AppomattoxShell7400May 2019
King’s QuayMurphy3725April 2022
VitoShell4050Feb 2023
Argosbp4440April 2023
AnchorChevron4600Aug 2024
WhaleShell8600Jan 2025
ShenandoahBeacon5840July 2025
SalamancaLLOG6405Sept 2025

The efficiencies achieved with the simpler platform designs combined with the high pressure (>15,000 psi) technology developed over the past 2 decades is facilitatihg production from the highly prospective Paleogene (Wilcox) deepwater fans. (For those interested in learning more about the geology, see the excellent presentation by Dr. Mike Sweet, Univ. of Texas, that is embedded in this post.)

With bp’s commitment to Tiber, 3 new high-pressure projects, ala Chevron’s Anchor, are in the pipeline:

platformoperatorwater depth (ft)discovery datefirst production
Kaskidabp600020062029
SpartaShell470020122028
Tiberbp413020092030
All of the operators note the cost-saving similarities in their FPU designs. For example, Vito and Whale are very much the same despite the 4550′ difference in water depth.

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The table below captures the shorter public comments and provides links to the longer ones. They are listed in the order they were posted on Regulations.gov.

commentersummary/link
anonymousI recommend under no circumstance that we allow the onsite worker to approve the commingling of bore holes because there is extreme significant safety and environmental hazards that exist.
The best alternative is to have an environmental engineer and environmental scientist approve any commingling
Our Children’s Trust…your regulatory proposal is inconsistent with the federal law, the best available science on protecting the health and lives of children, and the legal mandate that agency decision-making does not deprive children of their fundamental constitutional rights…
E.P. DanenbergerSee BOE post
anonymousI support updating the regulations to align with the One Big Beautiful Bill Act, but I encourage BSEE to ensure that safety standards and environmental protections remain the highest priority in all commingling approvals. Clear guidance for industry compliance and transparent public reporting would also strengthen confidence in this rule.
Ananda FosterRegulations need to catch up with technology and we have not had a chance to do that yet. If you allow them on throttle access, they will destroy it. We all rely on the ocean, how can you do this to your own constituents?
APISupports direct final rule
bp AmericaSupports direct final rule

Legislatively dictating well construction, completion, or operational approvals is a redline for me, and I continue to strongly believe the downhole commingling rule should be published as a draft for public review and comment.

The only industry comments are from API and bp America. Both support the direct final rule, and I respect their position. My main quarrel is with the legislative action that put us in this position.

I have had many disagreements with API members over the years, but the dialogue has always been professional. Technical and policy disagreements are healthy for the OCS program, and I will continue to raise potential issues and concerns on this blog.

With regard to bp, I have been impressed by their commitment to the Gulf of America, as summarized in this excerpt from their comments:

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Deepwater Titan, Gulf of America

The latest Baker Hughes Rig Count Report shows only 10 rigs actively drilling in the Gulf. All are at deepwater locations – 7 in the Mississippi Canyon area, 2 in Green Canyon, and 1 in Alaminos Canyon. Per the BSEE borehole file, Shell accounts for most of the current MS Canyon wells and the Alaminous Canyon well. Beacon is also drilling in the MS Canyon, and the Green Canyon well appears to be a Chevron operation.

This current rig count, which has hovered between 9 and 12 all year, is troubling if you are concerned about long-term production. By comparison the Gulf rig count reached 22 last year and was 100+ during the 10 year period from 1994 to 2003.

Only Anadarko/Oxy, Beacon/BOE, BP, Chevron/Hess, Shell, and Talos have spudded deepwater exploratory wells in 2025 YTD. Arena and Cantium are the only shelf drillers – all development wells.

Technological advances and extensions of past discoveries have sustained Gulf production, but declines are certain over the longer term if drilling activity doesn’t increase. Oil price uncertainty is an issue, but that’s always the case. Semiannual lease sales are now legislatively required and the terms will be attractive, so those issues are off the table. Let’s see what the bidding looks like at the upcoming sale.

The decline in deepwater discoveries (BOEM data below) is particularly discouraging. Per BOEM, the last deepwater field discovery was in March 2023.

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Per bp, the Bumerangue block well is located in the Santos Basin, 404 kilometres from Rio de Janeiro, in 2,372 metres of water. The well was drilled to a total depth of 5,855 metres.

Looks like the buzz may be warranted:

The well intersected the reservoir about 500 metres below the crest of the structure and penetrated an estimated 500 metre gross hydrocarbon column in high-quality pre-salt carbonate reservoir with an areal extent of greater than 300 square kilometres. 

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JL Daeschler recalls the inauguration of production at the Argyll field (18 June 1975) and Forties field (3 Nov 1975):

  • While some were bitter that Hamilton Brothers, a company owned by 2 brothers from Denver, was able to start production before British giant BP, there was never a race between the companies.
  • Instead there was a broad industry effort to initiate production during a financial crisis.
  • All operators exercized caution. We learned slowly with safety in mind. There was a great transfer of knowledge between operators small and big.
  • BP’s Forties field was a major achievement – designed for 400,000 bopd.  240 miles of 36″ pipeline were required (110 miles offshore and 130 miles onshore). The biggest delay was associated with the pipeline system, not the platform or wells.
  • The Hamilton Brothers Argyll field project (30,000 bopd) was not comparable in magnitude, requiring only a few wells and short infield flowlines.
  • The inauguration of Argyll  (photo above) was with the UK Energy Minister, Ferris and Fred Hamilton, and a  Greek tanker captain. There was minimal promotion and PR followup.
  • Contrast that with the Forties inauguration (photo above), a big event featuring Queen Elizabeth!

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BP dropped the regrettable Beyond Petroleum campaign and has now cut their renewable energy investments to focus on oil and gas production. They are doing quite well in the Gulf of America where they are the no. 2 oil and gas producer.

The leading Gulf of America oil and gas producer, Shell, has also slowed its renewable investments and is no longer participating in any US offshore wind projects.

Only Equinor (formerly Statoil), which is 2/3 Norwegian government owned, remains committed to renewable projects, much to the chagrin of some private investors. Equinor’s Empire Wind misadventure may be matched in the Pacific where their floating wind project offshore California is a long way from reality.

Farther in the past, there were noteworthy failures (below) like Mobil’s acquisition of Montgomery Ward, Exxon’s investment in Reliance Electric, and Gulf’s real estate ventures.

Finally, don’t expect the carbon sequestration boom that some are forecasting. As wind investors have discovered, industries dependent on mandates and subsidies are risky.

Not much unites climate activists and skeptics, but they are largely aligned in their opposition to carbon sequestration (euphemism for disposal), as are fiscal conservatives. The word chutzpah comes to mind when companies seek public funds to dispose of emissions associated with the combustion of their products.

And how are those 199 wrongfully acquired carbon sequestration leases in the Gulf working out (graphic below)? Barring some legislative sleight of hand, those leases are worthless.

199 oil and gas leases were wrongfully acquired at Sales 257, 259, and 261 with the intent of developing these leases for carbon disposal purposes. Repsol was the sole bidder at Sale 261 for 36 nearshore Texas tracts in the Mustang Island and Matagorda Island areas (red blocks at the western end of the map above). Exxon acquired 163 nearshore Texas tracts (blue in map above) at Sales 257 (94) and 259 (69).

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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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