BEST AVAILABLE AND SAFEST
TECHNOLOGIES FOR OFFSHORE
OIL AND GAS OPERATIONS

OPTIONS FOR IMPLEMENTATION

Committee on Options for Implementing the
Requirement of Best Available and Safest
Technologies for Offshore Oil and Gas Operations

Marine Board

NATIONAL ACADEMY OF ENGINEERING AND
                     NATIONAL RESEARCH COUNCIL
                                                 OF THE NATIONAL ACADEMIES

THE NATIONAL ACADEMIES PRESS

Washington, D.C.

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BES AVAILA ST ABLE AND SAFEST D T TECH HNOLOGIES FOR OFFSHOR O RE OIL AND GA OPERA AS ATIONS OPT TIONS FOR IMPLEME R ENTATION N Comm mittee on Opttions for Impplementing t the Requuirement of Best Availab and Safes B ble st Technolo ogies for Off fshore Oil an Gas Opera nd ations Ma arine Board

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THE NATIONAL ACADEMIES PRESS 500 Fifth Street, NW Washington, DC 20001 NOTICE: The project that is the subject of this report was approved by the Gov- erning 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 committee re- sponsible for the report were chosen for their special competences and with re- gard for appropriate balance. This project was supported by Contract No. E12PC00062 between the National Academy of Sciences and the U.S. Department of the Interior. Any opinions, findings, conclusions, or recommendations expressed in this publication are those of the author(s) and do not necessarily reflect the view of the organizations or agencies that provided support for this project. International Standard Book Number-13: 978-0-309-29427-0 International Standard Book Number-10: 0-309-29427-4 Additional copies of this report are available for sale from the National Acade- mies Press, 500 Fifth Street, NW, Keck 360, Washington, DC 20001; (800) 624- 6242 or (202) 334-3313; http://www.nap.edu/. Copyright 2013 by the National Academy of Sciences. All rights reserved. Printed in the United States of America

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The Na ational Academy of Sciences is a private, nonp s profit, self-perpeetuating society of y distingu uished scholars engaged in scie entific and engin neering research dedicated to the h, furthera ance of science and technology and to their use for the general w a a welfare. Upon t the authorit of the charter granted to it by the Congress in 1863, the Acade ty emy has a mand date that req quires it to advise the federal government on sci ientific and tech hnical matters. DDr. Ralph J. Cicerone is preesident of the Na ational Academy of Sciences. y The Nattional Academy of Engineering was establishe in 1964, unde the charter of the y ed er Nationa Academy of Sciences, as a pa al S arallel organizati of outstandin engineers. It is ion ng t autonom mous in its adm ministration and in the selection of its members sharing with t i s, the Nationa Academy of Sciences the res al S sponsibility for advising the feederal governme ent. The Naational Academy of Engineerin also sponsors engineering p y ng s programs aimed at d meeting national needs, encourages edu g ucation and reseearch, and recoggnizes the super rior achievements of engine eers. Dr. C. D. Mote, Jr., is pres M sident of the Na ational Academy of y ering. Enginee The Ins stitute of Medic cine was established in 1970 by t National Ac the cademy of Scienc ces to secur the services of eminent memb of appropri ate professions in the examinati re o bers ion of polic matters pertai cy ining to the heal of the public The Institute acts under the re- lth c. e sponsibility given to the National Acad e demy of Sciences by its congress s sional charter to be an adviser to the federal government and, upon its ow initiative, to identify issues of a wn o medical care, research, and education. Dr. Harvey V. Fineberg is pre l esident of the Inssti- tute of Medicine. M The National Research Council was organized by the National Acade h o e emy of Sciences in s 1916 to associate the broad community of science and technology w the Academy o b y d with y’s purpose of furthering knowledge and advising the fed es k deral governmen Functioning in nt. g accordaance with genera policies deter al rmined by the AAcademy, the Co ouncil has become the prin ncipal operating agency of both the National Aca a t ademy of Scienc and the Natio ces on- al Acaddemy of Enginee ering in providin services to th government, t public, and t ng he the the scientifi and engineer ic ring communitie es. The Counci is administere jointly by bo il ed oth Academ and the Inst mies titute of Medicin Dr. Ralph J. Cicerone and D C. D. Mote, Jr., ne. Dr. are chai and vice chair, respectively, of the National Re ir , f esearch Council l.   www.nation nal-academies.o org

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COMMITTEE ON OPTIONS FOR IMPLEMENTING THE REQUIREMENT OF BEST AVAILABLE AND SAFEST TECHNOLOGIES FOR OFFSHORE OIL AND GAS OPERATIONS Members DONALD C. WINTER (Chair), University of Michigan, Ann Arbor PAUL M. BOMMER, University of Texas at Austin ROBERT BRENNER, Duke University, Washington, D.C. ANTHONY P. CIAVARELLI, Human Factors Associates, Inc., Lake Oswego, Oregon LOUIS ANTHONY (TONY) COX, JR., Cox Associates, LLC, Denver, Colorado JAMES S. DYER, University of Texas at Austin THOMAS R. KITSOS, Ocean Policy Consultant, Bethesda, Maryland DONALD LIU, Independent Consultant, Willis, Texas ROGER L. MCCARTHY, McCarthy Engineering, Palo Alto, California CHARLES E. MCQUEARY, Independent Consultant, Greensboro, North Carolina RICHARD A. SEARS, Stanford University, Stanford, California GORDON H. STERLING, Independent Consultant, The Woodlands, Texas MANUEL TERRANOVA, Peaxy, Inc., San Jose, California Staff RAYMOND A. WASSEL, Project Director v

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MARINE BOARD THOMAS M. LESCHINE, University of Washington, Seattle (Chair) JAMES C. CARD (Vice Admiral, U.S. Coast Guard, retired), Maritime Consultant, Houston, Texas (Vice Chair) STEVEN R. BARNUM, Hydrographic Consultation Services, Suffolk, Virginia MARY R. BROOKS, Dalhousie University, Halifax, Nova Scotia, Canada STEPHEN M. CARMEL, Maersk Line Limited, Norfolk, Virginia EDWARD N. COMSTOCK, Raytheon Integrated Defense Systems, Sudbury, Massachusetts ELMER P. (BUD) DANENBERGER III, Consultant, Reston, Virginia JEANNE M. GRASSO, Blank Rome LLP, Washington, D.C. STEPHAN T. GRILLI, University of Rhode Island, Narragansett DOUGLAS J. GRUBBS, Crescent River Port Pilots Association, Metairie, Louisiana JOHN M. HOLMES, Port of Los Angeles, Los Angeles, California DONALD LIU, NAE, Marine Consultant, Willis, Texas RICHARD S. MERCIER, Texas A&M University, College Station EDMOND J. MORAN, JR., Moran Towing Corporation, New Canaan, Connecticut ALI MOSLEH, University of Maryland, College Park GEORGE BERRYMAN NEWTON, JR., Consultant, Marstons Mills, Massachusetts KARLENE H. ROBERTS, University of California, Berkeley (Emerita) PETER K. VELEZ, Peter Velez Engineering, LLC, Houston, Texas JOHN WILLIAM WAGGONER, Hornblower Marine Services, New Albany, Indiana TRANSPORTATION RESEARCH BOARD 2013 EXECUTIVE COMMITTEE OFFICERS DEBORAH H. BUTLER, Norfolk Southern Corporation, Norfolk, Virginia (Chair) KIRK T. STEUDLE, Michigan Department of Transportation, Lansing (Vice Chair) SUSAN HANSON, Clark University, Worcester, Massachusetts (Division Chair for NRC Oversight) ROBERT E. SKINNER, JR., Transportation Research Board (Executive Director) vi

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Preface Section 21(b) of the Outer Continental Shelf Lands Act (OCSLA)1 man- dates that the Secretary of the Interior2 shall require, on all new drilling and production operations and, wherever practicable, on existing operations, the use of the best available and safest technologies which the Secretary determines to be economically feasible, wherever failure of equipment would have a significant effect on safety, health, or the environment, except where the Secretary determines that the incremental benefits are clearly insufficient to justify the incremental costs of utilizing such technologies. In the aftermath of the Macondo well blowout and Deepwater Horizon ex- plosion in 2010, various analyses of the causes of the incident (for example, NAE and NRC 2012) identified the need for government agencies to incorporate more sophisticated approaches for assessing and managing risks associated with off- shore activities. Accordingly, the Bureau of Safety and Environmental Enforce- ment (BSEE)3 considered ways of enhancing the approach it uses in implementing the best available and safest technologies (BAST) mandate. The director of BSEE asked the National Academy of Engineering (NAE) and the National Research Council (NRC) to form a committee that would provide a range of options for improving the implementation of BAST. The committee was also asked to review options and issues that BSEE is already considering. However, the committee was not asked either to recommend a specific BAST implementation approach or to 1 Public Law 95-372, as amended on September 18, 1978. 2 The mandate is also directed to the secretary of the department in which the Coast Guard is operating. 3 On October 1, 2011, BSEE became the federal entity within the U.S. Department of the Interior responsible for safety and environmental oversight of internal processes of offshore oil and gas operations. vii

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viii Preface carry out an in-depth evaluation of BSEE’s past BAST approach. (The commit- tee’s statement of task is provided in Appendix A.)4 In response, NAE and NRC assembled a committee of 13 members providing expertise in petroleum engineer- ing, marine systems, system safety, risk analysis, testing and evaluation of new technologies, and human factors. In addition, the committee provided experience in regulatory and corporate decision making concerning the identification, devel- opment, and deployment of advanced technologies (see Study Committee Bio- graphical Information at the end of this document). The diverse background of the committee membership proved to be valuable, as the committee had to rely heavi- ly on its collective judgment and experience in providing its recommendations in this report. In accordance with its task statement, the committee did not recommend a specific BAST implementation approach. In accordance with its best judgment, the committee took an integrated approach in recommending actions to enhance BSEE’s fundamental capabilities for supporting any of the identified options. On the basis of conversations with the sponsor at its first meeting, the committee considered the specific options listed in its statement of task to be illustrative of the complexity of BAST implementation and not to define the set of topics to be considered in its report. Therefore, the committee used its discretion within the parameters of its scope of work to focus on the set of options to be discussed fully and analyzed within its report. The committee principally focused on de- veloping options with regard to BSEE’s plans for an independent Ocean Energy Safety Institute (OESI), which would provide technical support for BAST im- plementation. General plans for OESI were outlined by BSEE officials at the committee’s first meeting. As part of its information-gathering activities, the committee held three pub- lic sessions in 2013 to receive presentations from BSEE; other federal agencies involved in BAST-type approaches; and industry associations, individual compa- nies, and other organizations involved in offshore drilling and production opera- tions. On March 11, the committee heard from Michael Else and Joseph Levine (BSEE), Kevin Culligan (U.S. Environmental Protection Agency), Holly Hopkins (American Petroleum Institute), Alan Spackman (International Association of Drilling Contractors), and Thomas Moroney (Shell). On May 13, the committee heard from Homayoon Dezfuli (National Aeronautics and Space Administration), Lirio Liu (Federal Aviation Administration), James Simons (National Highway Traffic Safety Administration), and Brian Sheron (U.S. Nuclear Regulatory Com- mission). On May 30, the committee heard from Fred Florence (National Oilwell Varco), John Hensley (Petrobras), Robert Judge (GE Oil and Gas), Rod Larson 4 The committee issued a letter on April 15, 2013, which commented on BSEE’s pre- liminary plans for implementing the BAST requirement, as presented to the committee on March 11, 2013.  

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Preface ix (Oceaneering International), Roald (Ro) Lokken (ExxonMobil), Richard Mercier (Offshore Technology Research Center), Keith Seilhan (Stone Energy), Mel Whitby (Cameron Drilling Systems), and Charlie Williams (Center for Offshore Safety). Donald C. Winter, Chair Committee on Options for Implementing the Requirement of Best Available and Safest Technologies for Offshore Oil and Gas Operations

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Acknowledgments This report has been reviewed in draft form by individuals chosen for their diverse perspectives and technical expertise in accordance with procedures ap- proved by NRC’s Report Review Committee. The purpose of this independent review is to provide candid and critical comments that will assist the institution in making its published report as sound as possible and to ensure that the report meets institutional standards for objectivity, evidence, and responsiveness to the study charge. The review comments and draft manuscript remain confidential to protect the integrity of the deliberative process. We wish to thank the following individuals for their review of this report: R. Lyndon Arscott, International As- sociation of Oil and Gas Producers; Benton F. Baugh, Radoil, Inc.; Michael R. Bromwich, The Bromwich Group; Patricia M. Jones, University of Illinois at Urbana–Champaign; Alexander MacLachlan (DuPont, retired); Keith Seilhan, Stone Energy; Allen Verret, Offshore Operators Committee; and David Wisch, Chevron Energy Technology Company. Although the reviewers listed above have provided many constructive comments and suggestions, they were not asked to endorse the conclusions or recommendations, nor did they see the final draft of the report before its release. The review of this report was overseen by Robert A. Frosch (NAE), Harvard University, and Susan Hanson (NAS), Clark University. Appointed by NRC, they were responsible for making certain that an independent examination of this report was carried out in accordance with institutional procedures and that all review comments were carefully considered. Responsibility for the final con- tent of this report rests entirely with the authoring committee and the institution. Raymond Wassel managed the study under the guidance of the committee and the supervision of Stephen Godwin, Director, Studies and Special Programs, Transportation Research Board (TRB). Norman Solomon edited the report; Ra- diah Rose prepared the prepublication manuscript, under the supervision of Javy Awan, Director of Publications, TRB. Ricardo Payne and Timothy Devlin ar- ranged meetings and provided logistical communications to the committee. xi

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Abbreviations ALARP as low as reasonably practicable API American Petroleum Institute ASRS Aviation Safety Reporting System BAST best available and safest technologies BOEM Bureau of Ocean Energy Management BOP blowout preventer BSEE Bureau of Safety and Environmental Enforcement DOI U.S. Department of the Interior E&P exploration and production FAA Federal Aviation Administration FFRDC federally funded research and development center GOM Gulf of Mexico HFE human factors engineering HSE health, safety, and environment IP intellectual property JIP joint industry project NAE National Academy of Engineering NASA National Aeronautics and Space Administration NRC National Research Council NTNU Norwegian University of Science and Technology NTSB National Transportation Safety Board OCS outer continental shelf OCSLA Outer Continental Shelf Lands Act OESI Ocean Energy Safety Institute OGP International Association of Oil and Gas Producers R&D research and development SEMS Safety and Environmental Management Systems SINTEF Stiftelsen for Industriell og Teknisk Forskning TA&R Technology Assessment and Research UARC university-affiliated research center USCG United States Coast Guard xiii

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Contents SUMMARY ................................................................................................... 3 1 INTRODUCTION ............................................................................. 11 2 PROCESSES FOR IDENTIFYING TECHNOLOGIES ............... 15 Technology Push, 15 Technology Pull, 19 3 PROCESSES FOR EVALUATING AND DEVELOPING TECHNOLOGIES................................................. 27 Evaluation Methodologies, 27 Technology Development and Maturation, 33 4 IMPLEMENTATION MECHANISMS .......................................... 39 BSEE Organization and BAST, 39 People and Skills, 47 Committee’s Net Assessment, 50 REFERENCES ........................................................................................... 52 APPENDICES A. STATEMENT OF TASK.................................................................. 55 B. LESSONS FROM OTHER ORGANIZATIONS FOR BEST AVAILABLE AND SAFEST TECHNOLOGIES IMPLEMENTATION ....................................................................... 56 STUDY COMMITTEE BIOGRAPHICAL INFORMATION ............... 60 xv

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