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
NATIONAL ACADEMY OF ENGINEERING AND
NATIONAL RESEARCH COUNCIL
OF THE NATIONAL ACADEMIES
THE NATIONAL ACADEMIES PRESS
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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 committee responsible for the report were chosen for their special competences and with regard 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.
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THE NATIONAL ACADEMIES
Advisers to the Nation on Science, Engineering, and Medicine
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COMMITTEE ON OPTIONS FOR IMPLEMENTING THE REQUIREMENT OF BEST AVAILABLE AND SAFEST TECHNOLOGIES FOR OFFSHORE OIL AND GAS OPERATIONS
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
RAYMOND A. WASSEL, Project Director
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)
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 explosion 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 offshore activities. Accordingly, the Bureau of Safety and Environmental Enforcement (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
1Public Law 95-372, as amended on September 18, 1978.
2The mandate is also directed to the secretary of the department in which the Coast Guard is operating.
3On 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.
carry out an in-depth evaluation of BSEE’s past BAST approach. (The committee’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 engineering, 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, development, and deployment of advanced technologies (see Study Committee Biographical Information at the end of this document). The diverse background of the committee membership proved to be valuable, as the committee had to rely heavily 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 developing options with regard to BSEE’s plans for an independent Ocean Energy Safety Institute (OESI), which would provide technical support for BAST implementation. 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 public sessions in 2013 to receive presentations from BSEE; other federal agencies involved in BAST-type approaches; and industry associations, individual companies, and other organizations involved in offshore drilling and production operations. 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 Commission). On May 30, the committee heard from Fred Florence (National Oilwell Varco), John Hensley (Petrobras), Robert Judge (GE Oil and Gas), Rod Larson
4The committee issued a letter on April 15, 2013, which commented on BSEE’s preliminary plans for implementing the BAST requirement, as presented to the committee on March 11, 2013.
(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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This report has been reviewed in draft form by individuals chosen for their diverse perspectives and technical expertise in accordance with procedures approved 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 Association 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 content 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; Radiah Rose prepared the prepublication manuscript, under the supervision of Javy Awan, Director of Publications, TRB. Ricardo Payne and Timothy Devlin arranged meetings and provided logistical communications to the committee.
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|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|
|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|
|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|
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