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4 ALTERNATIVE APPROACHES TO SAElDlY INSPECTION Current Minerals Management Service (MMS) inspection practice for offshore platforms was described in Chapter 2. In this chapter, five alternative approaches to inspection are described. Three of them essentially are modified versions of the present system that could improve aspects of the inspection program from the standpoint of either safety or program management. They are . ~ . alternative 1; increased inspection onsite by MMS; alternative 2; inspection of a sampling of potential incidents of non-compliance (PINCs) during annual inspections, and increased spot inspections; and alternative 3; annual inspection of a sampling of facilities, and increased spot inspections. The other two alternative approaches are true alternatives, in that they involve fundamental departures from current practice. They are alternative 4; third-party inspection with government audit, and alternative 5; self-inspection. An important point is that those alternatives that propose some form of reduced onsite inspection relate to production facilities only. The potential for accidents is higher in drilling operations than in production operations, which are more stable and predictable. Most continuous spills and some of the most serious accidents have resulted from drilling. Redundant safety devices and backup systems have been incorporated into the production process to a degree that is not feasible for drilling operations. Furthermore, safety of drilling operations is more directly affected by human behavior and its sometimes unpredictable sub-seabed conditions. There are far fewer drilling facilities than production platforms on the outer continental shelf (OCS), nevertheless, because of the large crews needed for drilling operations, during periods of development in the Gulf of Mexico the total number of personnel associated with mobile offshore drilling units (MODUs) and platform drilling equipment may be slightly higher than the number of personnel on production platforms (for example 10,551 drilling to 10,385 production, according to Coast Guard data,). Therefore, the committee believes that the present program of annual and spot inspections of drilling and workover activities should be continued. This is not to say that the inspection program enhancements discussed in this report should not be applied to inspection of drilling operationsthey most assuredly should! This figure represents an average, over the period 1980-1986. The number of drilling operations in the U.S. OCS dropped drastically (by 50 percent) in 1986 because of the effect of low crude oil prices, and the OCS drilling population was correspondingly lower. 45

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46 The next chapter presents several key considerations that the committee took into account in evaluating the alternative OCS inspection programs for efficacy and suitability. Chapter 6 discusses the results of the committee's assessment of both the present MMS program and the alternative approaches in light of these considerations. MODIFICATIONS OF PRESENT PRACTICES Alternative 1: Increased Inspection Onsite by MMS This alternative involves modifying the present program by increasing MMS announced inspection activity over current levels. MMS inspectors would witness all mandatory tests and safety drills, i.e., all prescribed weekly, monthly, quarterly, and semiannual tests, in addition to witnessing tests of all devices once a year (the current goal) while continuing to perform occasional spot inspections. The primary objective would be to reduce the likelihood of incomplete or inaccurate test data in the first instance, since from a compliance viewpoint spot inspections could be targeted at facilities believed to be deficient in recordkeeping. An increase in scheduled witnessing of tests would add substantially to the manpower requirements of the MMS inspection program. Alternative 2: Inspection of a Sampling of PINCs During Annual Inspections, and Increased Spot Inspections Under this alternative, MMS would . introduce a formal sampling program for conducting annual inspections to confirm that operators had accomplished prescribed tests properly; . initiate a program of formal safety analyses; and perform a larger number of targeted spot inspections based on the results of the annual inspections and the safety analyses. lithe immediate consequence of this alternative is to reduce the amount of time MMS inspectors spend onsite on production facilities to carry out the annual inspection and to compensate for the reduction with a program of more sophisticated safer analysis supporting more (and better targeted) spot inspections.2 The program contemplates also that steps would be taken to establish more clear-cut operator accountability for facility safety by requiring operators to . record all routine tests of safety equipment by operating personnel, as well as those conducted at scheduled intervals prescribed by MMS (test results should be recorded in a format acceptable to MMS); establish a formal program for the operator's supervisors to follow up on their personnel's adherence to test schedules, to review test results, and to report the audit results periodically to MMS; and conduct internal (by management) reviews to ensure the performance of prescribed testsperformance of the prescribed internal review would be confirmed by MMS inspectors during the annual inspection, using the MMS-developed sampling plan. 2The committee believes that a shift to this alternative could be undertaken with acceptable risk while the essential task of enhancing the usefulness of the current MMS database is in progress.

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47 Illustrative Scenario The following is an illustrative scenario: several days prior to the annual inspection, the MMS would request that the operator send to the local MMS district office a certified copy of specified test and drill records for the platform. This might include, for example, all records for any particular item or all records covering a specified time span since the last annual inspection. The operator would have 48 hours after notification to submit the records. The MMS inspectors would review the records in their offices for adequacy and for possible trends and would plan for the best use of MMS offshore inspection time. The efficiency of this activity would be enhanced by using a sampling program in which limited numbers of like devices would be tested based on the operator's past safety history, the test result data accumulated by the operator, and the number of such devices installed on the facility. A facility-specific sampling plan could be developed based on the operator's inspection records, which would allow moving from the present program that emphasizes monitoring of tests to a program emphasizing verification of the operator's inspection records. Appendix G provides detailed commentary on the methods and feasibility of sampling. Greater Operator Accountability The present inspection program emphasizes an MMS role of detecting discrepancies affecting safety bv annually witnessing a test of event safety device. Alternative 2 is intended to emphasize the responsibility of operators for making good safety practices an integral element of production operations. That is to say, this alternative would bring home to operating personnel and their immediate supervisors that they have full responsibility for the day-to-day safety of a facility; operator management would be accountable to closely monitor safety practices on its facilities; and MMS would use an increased number of spot inspections to verify adherence to good safety practices, rather than expending its resources in witnessing the repetitive mechanical testing of safety equipment. The transition from what has become a program of monitoring of testing to what would be a program based on verifying the operators' inspection results will require thorough retraining of MMS inspectors, operator management, and particularly, operating personnel. Operator training programs will have to emphasize the need for close rapport between operating personnel and management on safety-related matters. One difficult problem for the operator will be that, in order to improve the usefulness of the inspection data base, it will be necessary to record discrepancies even if they are corrected immediately. Periodically, the onsite supervisor will have to review tests and inspections to ensure that operating personnel have performed tests and inspections correctly. These reviews will have to be noted in the facility records and signed by the onsite supervisor. Also, operator management will have to be required to formally review the onsite supervisors' performance and record the results. With this type of system in place, MMS inspectors would be able to screen the facility records rapidly during spot inspections and identify the problems being encountered. Similarly, the follow-up being performed by the onsite supervisor and the operator's management could be tracked through the facility's records. Safer Analyses Analysis of test results, past violations and events (accidents), and other safety-related data would be performed by the MMS as a distinct inspection activity (see Chapter 7 for elaboration). In-depth analyses could increase the probability of safe operations in several ways. For example, during the committee's visit to a Pacific Coast platform, an MMS inspector took time to verify that repairs had been made to six relief valves that MMS had rejected on the previous inspection. The

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48 MMS inspector stated that this number of discrepancies involving relief valves was common in the region. In the New of the committee, this was an excessively high failure rate for such a critical device, particularly in light of the frequency of MMS inspections of the facility. Ongoing safety analyses of inspection data might have flagged the possibility of a failure trend requiring remedial action. Where potentially important findings had been made by MMS inspectors performing these analyses, the results would be provided to MMS management and to operators along with background and recommendations for appropriate action. Such actions could take the form of changes in procedures or specifications, modifications in hardware design, or reallocations of test or inspection effort. Enhanced Spot Inspections By reducing the time devoted to annual inspections, more spot inspections could be carried out. Like the annual inspections, these spot inspections also would rely on sampling techniques for the selection of PINCs to be checked; similar techniques could be used for selecting the facilities to be visited. More spot inspections would offer the dual benefit of increasing the MMS presence on all OCS facilities, and making operators more continually aware of their safety responsibilities and performance. Based on the results of safety analyses, MMS could use the increased spot inspections to exert a concerted effort to address identified problem areas. PINC sampling technique could thus be tied to safety analysis methodology to yield highly targeted spot inspections. Alternative 3: Annual Inspection of a Sampling of Facilities, and Increased Spot Inspections With an adequate data base reflecting the safety history of individual facilities it would be possible to develop a sampling plan to conduct annual inspections only at selected facilities. The sampling plan would require data for ranking each facility on the basis of its safety history, the safety history of the operator, the location of the facility, and the safety history of like facilities. An alternative built on this approach would allow MMS inspectors to focus their annual inspections on those facilities identified as being more susceptible to having safety problems. It would reduce the amount of time spent in onsite inspection by MMS inspectors for annual inspections of production facilities by reducing the number of annual inspections performed each year. As in alternative 2, the resources thus freed would have to be used to increase spot inspections and to institute a safety analysis program. An element of this alternative would be that each facility be subject to at least one onsite spot inspection each year. The key to an effective selected-facility inspection program is the development of a valid sampling plan. In the case of a selected-facility inspection program the sampling plan would be particularly critical since the annual inspection of some facilities would be foregone. In order to develop the sampling plan, more extensive data will be needed regarding the operators and facilities than currently is available. Adoption of this alternative will have to be preceded by an intensified data-gathering period in which all facilities would continue to be subject to annual inspections. (Introduction of the sampling program for PINCs would not interfere with the data collection effort). The annual inspections of the selected facilities by the MMS could extend either to the witnessing of 100 percent of the tests of safety devices, as is currently required, or more probably to an inspection limited to witnessing a sampling of PINCs. In the committee's view, the use of a sampling plan for selecting the items to be checked during selected-facility annual inspections would not result in an unacceptable level of safety.

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49 The credibility of the selected-facility annual inspection program would require that each facility be visited at least once a year for spot inspection. Spot inspections could be as abbreviated as a simple Walk-around. The findings in spot inspections, event (accident) investigations, as well as those in the annual inspections of the selected facilities, would be used to refine the selected-facility and PINC sampling plans and as a basis for the issuance of safety alerts. DEPARTURES FROM PRESENT INSPECTION PRACTICE Alternative 4: Third-par Inspection with Government Audit Under this alternative, MMS would mandate that operators contract with independent, certified third-party inspectors to perform the annual and spot inspections now performed by MMS personnel. MMS would certify the third-party;inspectors on the basis of specific certification criteria, and periodically would conduct audits of the inspections conducted by the third parties to establish that they were performed properly. MMS also would monitor and verily the continuing qualifications of the third-partr inspectors. MMS would specify the documentation required to be completed and submitted by the third-party inspectors to record that an acceptable annual or spot inspection had been performed and would institute a follow-up program to see that the prescribed inspections were performed for each platform. This inspection program alternative is similar to the program currently employed in the United Kingdom sector of the North Sea. One element of this alternative that would distinguish it from current practice is that several considerations (the large number of variations in local circumstances, the need to establish the private inspection organization's responsibilities with certainty, and the removal of MMS personnel from day-to-day activity on the platforms) would require the operators and/or the private inspection organizations to formulate a safety plan for MMS approval that describes the inspection processes to be followed. The mere process of preparing a safety plan (which would require a detailed analysis of the operation) could yield safety benefits. To implement this alternative, the MMS would have to establish criteria for certifying third-party inspectors and guidelines for preparing safety plans and procedure manuals to be submitted by operators for MMS approval. The manuals would specify how the required inspections would be performed. Two variations are readily evident: 1. The operator could chose to perform all mandated tests and drills using his own personnel and use a certified third-party inspector to audit the performance of the mandated periodic tests and drills and to perform the annual inspection; or 2. the operator could elect to have a certified third-party inspector perform all the mandated tests and drills as well as the annual inspection. Whatever variation is selected, an operator would not be permitted to perform the annual inspection of his own facility. It would be essential that the MMS establish a formal procedure for certifying the qualifications of third-party inspection services and for auditing their performance. The procedure would have to ensure that conflict-of-interest situations are avoided. It also would have to provide for continuous monitoring to ensure that the third-party inspector's technical capabilities and personnel resources for carrying out a safety inspection program are maintained in the face of turnovers of either staff or management. By conducting periodic audits of the performance of the certified third-party inspectors, and by requiring them to be certified at regular intervals, the MMS would be able to measure the effectiveness of the program and ensure that adequate inspections are carried out. Third-party inspectors would be subject to losing their certification if they did not perform effectively.

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so A variation of this alternative would be for the MMS to hire the third-party inspection services directly. This alternative would involve less of a possibility of a conflict of interest between the third-party inspector and the operator. However, it would not serge as effectively to overcome the unwanted perception that safety on OCS facilities is primarily the responsibility of the MMS (through enforcement of compliance with PINCs) rather than the operator (through safety management.) If the MMS were to hire a third-party inspection service directly, the change would amount to no more than replacing government inspectors with private-sector inspectors. Thus, there would be no substantive improvement in the efficiency of the performance of the inspection program, although it is arguable that more flexible utilization of personnel might be achievable (with concomitant cost savings.) Alternative 5: Self-inspection The MMS would require that the operators inspect themselves, i.e., that they conduct all tests and inspections without MMS witnessing. In its ultimate form, the alternative would be similar to the program recently announced by the U.S. Coast Guard, in which operators report the results of their annual inspections on a standardized form, with the Coast Guard reviewing these reports and verifying them with spot inspections. This alternative obviously would produce substantial savings in manpower and budgetary resources, some of which the MMS could utilize to conduct more spot inspections and needed in-depth safety analyses of OCS facilities and the safety programs of the individual operators. Even with more spot inspections, this alternative could well serve to reduce MMS personnel day-to-day contact with OCS operations to unacceptable levels.