Environmental Impacts of Offshore Natural
Gas & Oil Exploration & Production
Activities in the Mediterranean (EIGOA)
Wohl center, Bar-Ilan University, Ramat-Gan,
Israel.
BSEE
Oil Spill Response Plans,
Application for Permit to Drill,
Inspection/Audits and
Enforcement
Joe Levine
June 10, 2012
Discussion Topics
• Oil Spill Response Plan requirements
• Applications for Permits to Drill
• Inspections/audits and enforcement
BSEE
June 10, 2012
30 CFR 254.1
Who must submit a spill response plan?
• “If you are the owner or operator of an oil
handling, storage, or transportation facility,
and it is located seaward of the coastline,
you must submit a spill response plan to
BSEE for approval.”
• “Your spill response plan must
demonstrate that you can respond quickly
and effectively whenever oil is discharged
from your facility.”
BSEE
June 10, 2012
OSRP Components
• Introduction and plan contents
– Facilities covered
• Emergency response action plan
– Qualified Individual (PIC)
– Spill management team (onshore/offshore)
– Spill response operating team (onsite)
– Incident command post
– Oil type
– Response procedures
BSEE
June 10, 2012
OSRP Components - continued
• Emergency response action plan (continued)
– Spill notification procedures
– Sensitive resources
– Integration with other plans
– Beach protection
– Waste disposal
• Appendices
– Equipment inventory
– Contractual agreements
– Worst case discharge
– Dispersant use plan
– In situ burning plan
– Training and drills
BSEE
June 10, 2012
Inspection of Oil Spill Response Equipment
• Inspections
•
•
•
•
Annually
Announced
Unannounced
Pass/Fail
• Verify
•
•
•
•
•
BSEE
Operability
Location
Maintenance
Usage
Records
June 10, 2012
Application for Permit to Drill (APD) Overview
• BSEE Review and Written Approval Required
for
– Each Well, Sidetrack, Deepen
• Purpose
- Regulatory Compliance
- Outlines Drilling Program
• Major Areas
- Operational Characteristics of Rig
- Well Design
- Equipment Use and Testing
BSEE
June 10, 2012
Application for Permit to Drill (APD)
Rig Information
USCG Certificate of Inspection/Letter of Compliance
ABS/DNV Load Line Certificate
Safe Welding Area
Rated Rig Drilling Depth
Rated Rig Water Depth
Rig Maximum Environmental Conditions
Hurricane Season Ratings
Evacuation Plan for MODU (COCP for ice)
For platform rig - structural assessment of platform rig to be installed
BSEE
June 10, 2012
Application for Permit to Drill (APD)
Geologic Information
Significant markers
Hydrocarbon bearing zones
Shallow hazards
Shallow water flows
Abnormally pressured zones
Lost circulation zones
Hydrogen Sulfide Presence
H2S Plan
Plans for mitigating hazards
BSEE
June 10, 2012
Application for Permit to Drill (APD)
Drilling Prognosis
Drilling procedure by hole section
Cementing programs (certified by professional engineer)
Type, density, volume, top
Drilling fluids program
Type, density, volume, mud onsite
Logging program
Type, interval
Well testing program (if any)
– Prior Notification
– Fluid Disposal
– BSEE Witness
– Data Collection
BSEE
June 10, 2012
Application for Permit to Drill (APD)
Engineering Calculations
Casing design (certified by professional engineer)
Casing test pressures
Verify that dual mechanical barriers are installed in production
casing (in addition to cement) (certified by professional engineer)
Maximum anticipated surface pressure (MASP) calculations and
assumptions
BSEE
June 10, 2012
Application for Permit to Drill (APD)
Surface BOP
One annular preventer
Two pipe rams
One blind/shear ram
Kill line with two full opening valves
Fill-up line above the uppermost
preventer
BSEE
Rated working pressure of the
choke manifold and
components equal to or
greater than working pressure
of the ram BOP’s
Accumulator system provides
1.5 times the volume of fluid
capacity required to close and
hold all BOP components
BOP control drawings
June 10, 2012
Application for Permit to Drill (APD)
Subsea BOP System
One annular preventer
Two pipe rams
One blind/shear ram
Kill line with two full opening valves
Fill-up line above the uppermost
preventer
Dual pod system for independent operation
of BOP
Secondary BOP control system with ROV
intervention capabilities
BSEE
Deadman and autoshear system
3rd party verification of BOP
BOP control drawings
Verify ROV can close, at a
minimum, one set of pipe rams,
one set of blind/shear rams and
disconnect from LMRP
June 10, 2012
Application for Permit to Drill (APD)
Other
Mud weight, pore pressure, fracture pressure plot
Anticipated safe drilling margin
Hydrogen sulfide contingency plan (if applicable)
Proposed well schematic
Coring program
Directional program
Departure request/alternative compliance request
Formation integrity test
Mud program
Containment
BSEE
June 10, 2012
BSEE Inspection Program
The Outer Continental Shelf Lands Act requires all facilities on the
OCS shall have an annual announced inspection
 Production Facilities – at least once per year
 Drilling Rigs – at least once a month
 Problem Operators – As often as necessary
BSEE
June 10, 2012
Inspection Categories
Drilling
Production
Measurement
Pipeline
Workover
Well Completion
BSEE
Coiled Tubing
Wireline
Crane
Hydrogen Sulfide
Environmental
Abandonment
Training
June 10, 2012
Inspection Type
Announced
Unannounced
Coast Guard
Electrical
Annual
Monthly
Random
Follow up
BSEE
Pollution
Blitz
Problem Operators
Hurricane Damage
Risk Based
Accident
Pre Start Up
Sampling
June 10, 2012
Factors Influencing Inspections
Incidents (Accidents)
Numerous Incidents of Noncompliance (INC)
Seriousness of INC
New Operators
Poor Performance
New Rigs & Platforms
Rebuilt Rigs & Platforms
Rigs Returning from Overseas
Major Equipment Changes
Change in Facility Ownership
BSEE
June 10, 2012
Enforcement
A Potential Incident of Non-Compliance becomes an
Incident of Non-Compliance when it is issued
INC’s have various degrees of actions
(W) Warning – normally 14 days to correct
(C) Component Shut-In
(S) Facility Shut-In – until violation is corrected
Certain INC’s, numerous INC’s, or undesirable events
result in frequent follow up inspections and can result in
civil penalty action
Office and Field INC’s
BSEE
June 10, 2012
BSEE SEMS Evaluations/Audits
• BSEE or authorized representative can audit
operators SEMS
– full, partial
– announced, unannounced
– onshore and/or offshore
– random, based on performance
• Operator to provide BSEE their SEMS program &
qualifications of independent third party
• Operators have started conducting their own SEMS
audits per Subpart S
BSEE
June 10, 2012
Civil Penalties
 Civil Penalty regulations are contained in 30 CFR 250, Subpart N, and
include provisions for:
 Forwarding case to Reviewing Officer for processing/action.
 Appeals process.
 Annual summary of each Civil Penalty case is posted on BSEE website.
 Max Civil Penalty amount is $40K/day/violation per 30 CFR
250.1403, and NTL No. 2011-N06 provides guidance on assessment
amounts…
BSEE
June 10, 2012
Criminal Penalties
Criminal violations are covered under Section 24(c) of the Outer
Continental Shelf Lands Act (OCSLA or the Act) (43 U.S.C.
1350(c)). Criminal violations are those that are knowing and willful
and may include:
 Violation of any provision of the OCSLA, any lease term, license, or
permit pursuant to the Act, or any regulation or order issued under the
Act designed to protect health, safety, or the environment or to conserve
natural resources;
 Any false statement, representation, or certification in any
application, record, report, or other document filed or required to
be maintained under the Act;
 Falsifying, tampering with, or rendering inaccurate any monitoring device
or method of record required to be maintained under the Act; and
 A disclosure of any data or information required to be kept confidential
by the Act.
Inspector General Act (IGA): The OIG is authorized to investigate violations
of OCSLA under Section 2 of the IGA (5 U.S.C. App §§ 2 and 4 (1998)).
BSEE
June 10, 2012
Questions?
THANKS
[email protected]
703-787-1033
BSEE
June 10, 2012