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Posts Tagged ‘BSEE’

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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Comments on BSEE’s proposed Well Control Rule are due by Nov. 14

Posted in drilling, Offshore Energy - General, Regulation, well control incidents, tagged , , , on October 18, 2022| Leave a Comment »

Comments on BSEE’s proposed revisions to the Well Control Rule are due in 27 days (by Nov. 14). Given the fundamental importance of well control to offshore safety and pollution prevention, all interested parties are encouraged to comment. Although some of the proposed revisions are rather nuanced, the document is neither long nor complex.

My completely independent comments are being drafted and will be posted here after they have been submitted to Regulations.gov.

My comments will explain why the proposal may reduce the rigor of the BOP system performance standard and will address a related shear ram issue. The comments will also discuss the management of BOP equipment failure and other safety data, the use of independent third parties and standards development organizations, dual shear rams on surface BOP stacks, ROV intervention capabilities, and BOP test data reporting and management.

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Well Control Rule comments

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

Hopefully, the attached response is indicative of the quality of comments BSEE will receive on their proposed WCR revisions.

The comments, which were submitted by a retired engineer (always the best commenters 😉), express the opinion that BSEE should not remove the option for submitting failure data to BTS. While my comments will express a somewhat different opinion, I thought he made good arguments in support of his position.

bsee-2022-0009-0004_attachment_1Download

The chart below is excerpted from the SafeOCS Dashboard cited in the comment letter:

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BSEE Ian shut-in report

Posted in Gulf of Mexico, hurricanes, Offshore Energy - General, tagged , , , on September 27, 2022| Leave a Comment »

190,358 BOPD shut-in as of 12:30 p.m. ET today. Presumably, most of the shut-in production is associated with the major deepwater platforms mentioned in our previous post. Given the projected storm track, these shut-ins should be brief.

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Mixed DC Appeals Court decision on Lease Sales 250 and 251

Posted in Offshore Energy - General, Regulation, tagged , , , on September 2, 2022| Leave a Comment »

The U.S. Court of Appeals for the D.C. Circuit ruled that BOEM “unreasonably refused to consider possible deficiencies in environmental enforcement” in their Supplemental EIS for Sales 250 and 251. The court found that BOEM did not adequately consider a 2016 Government Accountability Office (GAO) report that was critical of BSEE’s oversight of offshore activities.

More positively, the court chose not to vacate the sales or the EIS:

Moreover, vacatur would be highly disruptive for the lessees. They have paid millions of dollars to obtain their leases and have acted for some four years in reliance on them—including by investing substantial additional sums and by executing contracts with third parties. Moreover, any redo of the lease sales “would be tainted by prior publication of [the] lessees’ proprietary valuation of the leases” following the original sales.

Comments:

  1. How many GAO reports on BSEE or MMS have not been critical of some processes or procedures? None that I can recall.
  2. It’s unreasonable to expect BOEM to consider every GAO or other external criticism of the regulatory program in their EIS’s.
  3. All of the GAO recommendations in the subject report were process related and were closed (implemented) several years ago.
  4. The court exercised good judgement in declining to vacate the sale. Per the decision, the case will be remanded to BOEM for further consideration of the GAO report.

 

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Interesting commitments in the Amplify Energy Plea Agreement (Huntington Beach pipeline spill)

Posted in accidents, California, pipelines, Regulation, tagged , , , , , , , , on August 30, 2022| Leave a Comment »

Dept. of Justice announcement

In addition to the penalty and reimbursement elements of the plea agreement, there are two Amplify commitments that may be of particular interest to BOE readers:

  1. New leak detection system for the pipeline: More information on the leak detection improvements for this low pressure oil pipeline would be helpful.
  2. Notification to regulators of all leak detection alarms:
    • Which regulators? DOT? BSEE? State? All?
    • Real time reporting or periodic compilations? With real time reporting for every alarm, the distinction between the pipeline operator and regulator(s) would be blurred and new organizational and competence risks would be added. The probability of communications errors and delayed decisions would increase, and the operator would no longer be accountable for bad decisions.

Also, given that the investigating agencies have still not issued their report on the October 2021 spill and no action has yet been taken against the shipping companies that caused the pipeline rupture, the congratulatory Coast Guard, EPA, FBI, and DOT quotes in the announcement seem rather premature and self-serving.

Two final thoughts:

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Still waiting for…

Posted in accidents, CCS, decommissioning, Offshore Energy - General, pipelines, Regulation, tagged , , , , , , , , , , on August 11, 2022| Leave a Comment »

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