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ALTERNATIVES FOR INSPECTING OUTER CONTINENTAL SHELF OPERATIONS Committee on Alternatives for Inspection of Outer Continental Shelf Operations Marine Board Commission on Engineering and Technical Systems National Research Council NATIONAL ACADEMY PRESS Washington, D.C. 1990

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NOTICE: The project that is the subject of this report was approved by the Governing Board of the National Research Council, whose members are drawn from the councils of the National Academy of Sciences, the National Academy of Engineering, and the Institute of Medicine. The members of the panel responsible for the report were chosen for their special competences and with regard for appropriate balance. Ibis report has been reviewed by a group other than the authors according to procedures approved by a Report Review Committee consisting of members of the National Academy of Sciences, the National Academy of Engineering, and the Institute of Medicine. The National Academy of Sciences is a private, nonprofit, self-perpetuating society of distinguished scholars engaged in scientific and engineering research, dedicated to the furtherance of science and technology and to their use for the general welfare. Upon the authority of the charter granted to it by the Congress in 1863, the Academy has a mandate that requires it to advise the federal government on scientific and technical matters. Dr. Frank Press is president of the National Academy of Sciences. The National Academy of Engineering was established in 1964, under the charter of the National Academy of Sciences, as a parallel organization of outstanding engineers. It is autonomous in its administration and in the selection of its members, sharing with the National Academy of Sciences the responsibility for advising the federal government. The National Academy of Engineer- ing also sponsors engineering programs aimed at meeting national needs, encourages education and research, and recognizes the superior achievements of engineers Or- Rohe.rt M White is nrPciA-nt of the National Academv of Engineering. an_ _~^,~__^v. ~~. ~ FOVEA ~ Ace- '' 111~ 1~ ~1~1~11t ~ C' O The Institute of Medicine was established in 1970 by the National Academy of Sciences to secure the services of eminent members of appropriate professions in the examination of policy matters pertaining to the health of the public. The Institute acts under the responsibility given to the National Academy of Sciences by its congressional charter to be an adviser to the federal government and, upon its own initiative, to identify issues of medical care, research, and education. Dr. Samuel O. Thier is president of the Institute of Medicine. The National Research Council was organized by the National Academy of Sciences in 1916 to associate the broad community of science and technology with the Academy's purposes of furthering knowledge and advising the federal government. Functioning in accordance with general policies determined by the Academy, the Council has become the principal operating agency of both the National Academy of Sciences and the National Academy of Engineering in providing services to the government, the public, and the scientific and engineering communities. The Council is administered jointly by both Academies and the Institute of Medicine. Dr. Frank Press and Dr. Robert M. White are chairman and vice-chairman, respectively, of the National Research Council. The project described in this report is support by Cooperative Agreement No. 14-12-0001-30416 between the Minerals Management Service of the U.S. Department of the Interior and the National Academy of Sciences. Library of Congress Catalog Card No. 89-64416 International Standard Book Number 0-309-04227-5 Additional copies of this report are available from: National Academy Press 2101 Constitution Avenue, NW Washington, D.C. 20418 Printed in the United States of America

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COMMITTEE ON AL1TE:RNATIVES FOR INSPECTION OF OUTER CONTINENTAL SHELF OPERATIONS G. H. PATRICK BURSLEY, Chairman, U.S. Coast Guard (retired), Bethesda, Maryland KENNETH E. ARNOLD, Paragon Engineering Services, Inc., Houston, Texas LUDWIG BENNER, JR., Events Analysis, Inc., Oakton, Virginia Fl,OYD E. GARROT, Hot Springs Village, Arkansas STAN KAPLAN, Pickard, Lowe and Garrick, Inc., Newport Beach, California ROBERT P. MEEK, ECOMAR, Inc., Goleta, California DICK H. PINER, JR., T.E.S.T., Inc., Gretna, Louisiana MIKLOS D. G. SALAMON, Colorado School of Mines, Golden, Colorado EUGENE C. SMITH, Eugene C. Smith, Inc., New Orleans, Louisiana DEMO ~ STAVROS, Eastern Michigan University, Ypsilanti, Michigan EDWIN L. ZEBROSKI, APTEC Engineering SeIvice, Inc., Sunnyvale, California STAFF DONALD W. PERKINS, Associate Director COURTLAND S. LEWIS, Editor CARLA D. MOORE, Project Assistant . . . 111

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MARINE BOARD SIDNEY A. WALLACE, Chairman, Dyer, Ellis, Joseph & Mills, Washington, D.C. BRIAN J. WATT, Vice-Chairman, TECHSAVANT, Inc., Kingwood, Texas ROGER D. ANDERSON, Bee Gee Shrimp, Inc., Tampa, Florida ROBERT G. BEA, NAE, University of California, Berkeley, California JAMES M. BROADUS, III, Woods Hole Oceanographic Institution, Woods Hole, Massachusetts F. PAT DUNN, Shell Oil Company, Houston, Texas LARRY L. GENTRY, Lockheed Advanced Marine Systems, Sunnyvale, California DANA R. KESTER, University of Rhode Island, Kingston, Rhode Island JUDITH T. KILDOW, Massachusetts Institute of Technology, Cambridge, Massachusetts BERNARD LE MEHAUTE, University of Miami, Miami, Florida WILLIAM R. MURDEN, NAE, Murden Marine, Ltd., Alexandria, Virginia EUGENE K. PENTIMONTI, American President Lines, Ltd., Oakland, California JOSEPH D. PORRICELLI, ECO, Inc., Annapolis, Maryland JERRY R. SCHUBEL, State University of New York, Stony Brook, New York RICHARD J. SEYMOUR, Scripps Institution of Oceanography, La Jolla, California ROBERT N. STEINER, Atlantic Container Line, South Plainfield, New Jersey EDWARD WENK, JR., NAE, University of Washington, Seattle, Washington STAFF CHARLES A. BOOKMAN, Director DONALD W. PERKINS, Associate Director SUSAN GARBINI, Project Officer PAUL M. SCHOLZ, Research Fellow ALEXANDER B. STAVOVY, Project Officer WAYNE YOUNG, Project Officer DORIS C. HOLMES, Staff Associate AURORE BLECK, Senior Project Assistant DELPHINE D. GLAZE, Administrative Secretary GLORIA B. GREEN, Project Assistant CARLA D. MOORE, Project Assistant 1V

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PREFACE The safe operation of offshore oil and gas development and production facilities on the outer continental shelf (OCS), is important to public acceptance of these operations and the continued ability of the United States to develop what has become the source of one-fourth of the nation's gas and one-eighth of its oil. The Outer Continental Shelf Lands Act of 1978 (OCSLA) requires regular inspections of operations to promote safe practices to protect personnel, facilities, and the environment; and to conserve offshore resources. The Minerals Management Service (MMS) of the Department of the Interior has the responsibility for prescribing safe practices and inspecting oil and gas operations on the OCS. Nevertheless, the primary responsibility for establishing a safe working environment and for conducting the necessary inspections to achieve safe practices to carry out the congressional safebr mandate is with the oil and gas leaseholders of the offshore facilities. In recent years, there have been few major accidents on the OCS involving exploration and production operations under MMS jurisdiction. Even so, recent disasters in the North Sea, and accidents involving spills from pipelines adjacent to platforms and from vessels (which are not in MMS's purview), emphasize the need to have an aggressive safety inspection program and to continually seek ways to enhance its effectiveness. With these needs in mind, the MMS requested that the Marine Board investigate alternative strategies for the inspection of OCS operations and that it recommend improvements in operational safety and environmental protection inspection practices. Previous Marine Board studiesespecially Implementing Best Available and Safest Technologies for Offshore Oil and Gas (1979), Safer and Offshore Oil (1981), and Safety Innovation and Management on the OCS (1984)stress the need for an evolutionary OCS regulatory regime and suggest that MMS try alternative inspection, enforcement, and compliance approaches. This report is intended to assist MMS to find ways to benefit from its experience with its OCS inspection program as well as that of the Coast Guard, which has an extensive program of marine safety inspections affecting OCS operations. The report assesses alternatives for revising the present MMS inspection system. The assessment was conducted by the Committee on Alternatives for Inspection of Outer Continental Shelf Operations, operating under the auspices of the Marine Board of the National Research Council. The committee was charged with developing inspection strategies to improve safety and the effectiveness of the inspection process. The methodology stipulated for conducting the study was to The OCS is that portion of the submerged continental margin that is subject to U.S. jurisdiction. For the purpose of this report, the OCS extends from a state's offshore boundary out to the limit of economic exploitation. v

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review the current OCS inspection program; appraise inspection practices elsewhere for lessons learned, including inspection of OCS operations not under direct federal jurisdiction (i.e., those in state waters) as well as analogous inspection programs in other industries; develop alternatives for conducting inspection programs and assess their advantages and disadvantages; and - recommend alternative inspection procedures that may be more effective and efficient than present ones and that may make industry more conscious of its accountability for safety. Committee members were selected for their expertise and to achieve a balanced viewpoint. The members have experience in the fields of OCS oil and gas operations, safety management, safety systems analysis, safety in the nuclear power and mining industries, and public interest in environmental protection. The principle guiding the makeup of the committee and its work, consistent with the policy of the National Research Council, was not to exclude the bias that might accompany expertise vital to the study, but to seek balance and fair treatment. MMS inspection programs and data bases were reviewed to determine how present inspections are conducted, the extent of the MMS overview on OCS platforms, the inspection functions undertaken by industry personnel, and the OCS safety record. The committee visited OCS operations in the Gulf of Mexico and off the coast of Southern California, and met district and regional MMS managers. In support of this study, the Coast Guard provided information and data concerning safety statistics and its approach to OCS inspection. Information regarding state and foreign inspection practices was obtained through the personal contacts of individual committee members. This report describes the various inspection alternatives the committee examined; presents the evaluation criteria used; and evaluates each alternative against the criteria. In evaluating alternatives, the committee did not limit itself to current inspection functions. It also examined functions that could and should be included in the safety inspection program to enhance safety in the workplace. Chapter 7 of the report focuses on these additional inspection activities at length. The committee's findings, conclusions, and recommendations are set out in the final chapter. V1

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CON - NTS PREFACE EXECUTIVE SUMMARY 1 INTRODUCTION ......... OVERVIEW OF MMS FIJNCI~IONS The Safety Mission Inspection Budget .............................. v OVERVIEW OF THE OCS OPERATIONS Facilities .~uct~m Fit Man ~ Neiman t 6 6 7 , , O Aspects of Safety on the OCS Summary ...................... 2 CURRENT INSPECTION PROGRAM: EVOLUTION AND PRACTICE PRESENT INSPECI~ION PRACTICE Overview of Inspection Program Inscection Policv ........... 16 17 19 20 20 20 Inspection Procedures Summary TECHNICAL FOUNDATION FOR INSPECTION REQUIREMENTS _ Evolution of the SafeW Practices for Drilling Operations 25 Evolution of the Requirements for Safety Devices for Production Facilities 25 SAFETY PERFORMANCE RECORD ............... Adequac>,r of MMS OCS Safety Information System Iniuries and Fatalities Pollution (Shills Incidents ~ ~ , Fires, Explosions, and Blowouts ...................... Violations Cited During Inspections ................... . . V11 ................ 26 ................ 27 ................. 27 ................ 33 . . 34

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3 MAJOR CONSIDERATIONS IN FORMULATING AN INSPECTION PROGRAM RELATIONSHIP OF INSPECTION TO SAFETY Compliance versus Performance How Milch Incnertir~n~ Inspecting for Operational SafeW ADVANCES IN SAFETY RISK ASSESSMENT AND MANAGEMENT CONFORMANCE WITH PUBLIC LAW 4 ALTERNATIVE APPROACHES TO SAFETY INSPECTION MODIFICATIONS OF PRESENT PRACTICES 39 39 39 40 42 43 ................ 44 Increased Inspection Onsite by MMS 46 Inspection of a Sampling of PINCs During Annual Inspections and Increased Soot Insnections . . . 46 Annual Inspection of a Sampling of Facilities and Increased Spot Inspections 48 DEPARTURES FROM PRESENT INSPECTION PRACTICE 49 Third-party Inspection with Government Audit 49 Self-inspection s CONSIDERATIONS IN EVALUATING OCS INSPECTION ALTERNATIVES . 50 ....... 51 PROMOTION OF INDUSTRY SAFETY AWARENESS 51 MAINTAINING PUBLIC CONFIDENCE View of Congress .............. Media and Public Onininn Comparability With Other Federal and State Agency Practices EFFICIENT USE OF RESOURCES Government Resources .............. Operator Resources ..... Societal Costs and Benefits . . . . . . . . 52 52 52 ............. 53 ...53 53 54 54 QUALIFICATION AND TRAINING OF INSPECTOR FORCE IDENTIFICATION OF SAFETY TRENDS AND WARNINGS SAFETY PERFORMANCE ACCOUNTABILITY ADAPTABILITY OF THE INSPECTION SYSTEM TO CHANGING CIRCUMSTANCES ....... PRECEDENTS . . . . .. . . . . . GENERAL CONSIDERATIONS ~ . . . V111 54 55 56 56 57

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6 ASSESSMENT OF PRESENT PROGRAM AND ALTERNATIVES PRESENT PROGRAM 58 Responsiveness in Meeting Present Safety Needs: Adaptability to Changing Circumstances 58 Responsiveness to Other Evaluation Considerations 66 INCREASED INSPECTION ONSITE BY MMS 68 INSPECTION OF A SAMPLING OF PINCs DURING ANNUAL INSPECTIONS, AD INCREASED SPOT INSPECTIONS 69 ANNUAL INSPECTION OF A SAMPLING OF FACILITIES, AND INCREASED .~POTIN.~PF~TTON.~ _~_~_~_~_ ~ ~ 70 THIRD-PARTY INSPECTION WITH GOVERNMENT AUDIT 72 SELF-INSPECTION 73 RESULTS OF THE ASSESSMENT 7 REDIRECTION OF INSPECTOR ACTIVITY TO ENHANCE THE INSPECTION PROGRAM . ~ 74 75 TASK REDIRECTION 75 Determining the Acceptability of Operator Safety Performance 76 Data Collection and Remew 77 Verifying the Effectiveness of Regulator Requirements 77 IdentiB=tion of Emerging SafeW Risk 78 UNSPECTION FORCE CAPABILITIES 79 PERFORMANCE MEASUREMENT SYSTEMS 8 FINDINGS, CONCLUSIONS AND RECOMMENDATIONS FINDINGS AND CONCLUSIONS RECOMMENDATIONS REFERENCES APPENDICES GLOSSARY 79 80 80 82 84 112 1X