- The flaring provision complicates compliance and may increase safety risks: (p. 649) Exception 1 exempts “gas vented or flared for not longer than 48 hours in an emergency situation that poses a danger to human health, safety, or the environment.” This is inconsistent with the carefully constructed BSEE regulations which allow limited (48 hours cumulative) flaring for certain operations (e.g. during the unloading or cleaning of a well, drill-stem testing, production testing, and other well-evaluation testing). Such flaring is essential but not normally “an emergency situation.” The bill could thus compromise safety by unnecessarily restricting or complicating well operations and by limiting flaring in circumstances where such flaring reduces safety risks.
- Time for BOEM to get to work 😉: (p. 650): Per our previous post, the highlight section of the bill (from an offshore oil and gas standpoint) reinstates Lease Sale 257 (GoM) and requires that the scheduled 2022 lease sales 258 (GoM) and 259 (Cook Inlet) be held by 12/31/2022. Lease Sale 261 (GoM) must be held by 9/30/2023.
- Petty but perhaps necessary: p. 655: The provision restricting wind leasing when no oil and gas lease sale has been held in the prior year is in the final bill.
Posts Tagged ‘flaring’
Inflation Reduction Act: BOE’s top 3 takeaways
Posted in climate, energy policy, Gulf of Mexico, Offshore Energy - General, tagged flaring, Inflation Reduction Act, Lease Sale 257, offshore oil, Offshore Wind on August 15, 2022| Leave a Comment »
Still waiting for…
Posted in accidents, CCS, decommissioning, Offshore Energy - General, pipelines, Regulation, tagged aban pearl, BSEE, CCS, flaring, Hogan and Houchin, Huntington Beach, incident data, offshore pipelines, Russell Peterson, Trinity Spirit, USCG on August 11, 2022| Leave a Comment »
- 2021 (entire year) and 2022 (first half) BSEE incident tables. If safety is the highest priority, these data should be updated quarterly.
- IRF 2021 safety performance data
- An international treaty (accompanied by a standard) on disclosing major offshore accidents and the collection and release of incident data. (Also, see this related post.)
- Hogan and Houchin decommissioning update, most notably the financial responsibility aspects
- Huntington Beach pipeline spill report
- Workable California decommissioning legislation
- ONRR flaring and venting data (update: ONRR advises that they anticipate publication of these data in September.)
- DOI statement on the Sale 257 carbon sequestration bids
- Definitive casualty information and report on the 2-2-2022 Trinity Spirit FPSO fire
- Updated DOI-DOT offshore pipeline regulations
- Coast Guard report on the May 2008 Russell Peterson liftboat tragedy
- Updated US Coast Guard Subchapter N regulations
- Information on the mysterious sinking of the Aban Pearl semi-submersible in May 2010.
Inspector General reports on Gulf of Mexico flaring violator
Posted in energy policy, Gulf of Mexico, Offshore Energy - General, Regulation, tagged flaring, flaring data, Gulf of Mexico, OIG report, reporting on June 16, 2022| Leave a Comment »
We determined that over approximately 5 years, the energy company’s venting and flaring activities exceeded regulatory limits without the required approvals, resulting in a loss of Federal mineral royalties and resources. More specifically, we identified approximately 229,066 MCF of vented and flared natural gas as suspicious or exceeding the allowable amount across four platforms in the Gulf of Mexico between January 2014 and April 2020. We presented our findings to ONRR, which assisted us in analyzing the energy company’s venting and flaring activities and determining the amount of lost Federal mineral royalties. Based on this analysis, ONRR submitted and secured a proof of claim in the amount of $712,857.82 for unpaid mineral royalties during the energy company’s bankruptcy proceeding.
OIG report 6/13/2022
Comments:
- The report doesn’t name the company, but one can make an educated guess based on some of the information provided (e.g. number of platforms the company operated, bankruptcy proceedings, etc.)
- The regulator usually finds out about false or misleading recordkeeping. Reports from employees, anonymous or otherwise, are a common source of such charges, as was the case here. (In my District in California, a toolpusher informed us that BOP pressure test records were being falsified. This led to multiple felony convictions.)
- The IG’s recommendations to BSEE and ONRR are reasonable and appropriate:
- Examine venting and flaring reports for patterns that may reflect violations or amounts that exceed permissible limits.
- Develop a process to ensure that royalties are being paid for improperly flared or vented gas.
- As BOE has previously reported, available public flaring data do not match. These data inconsistencies should be addressed.
- BSEE/ONRR should make more detailed flaring/venting data publicly available so differences between facilities and sectors (e.g. deepwater vs. shelf) can be assessed. Efforts should also be made to post these data in a more timely manner. Data for 2021 are still not available.
Proposed EPA rule prohibits venting of associated gas
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.
Bud's Offshore Energy (BOE) 