3

Options for Improving Bolting Reliability

There is a keen interest in improving the reliability of offshore equipment and structures and in reducing the risk of damage to the environment to as close zero as possible. With many disparate views on the preferred approach, there should be a forum by which all stakeholders have an opportunity to contribute their ideas and have them adequately investigated to enhance the development of offshore resources. Traditionally in engineering design, materials selection, manufacturing, installation and operation, this has been accomplished through the development and use of standards and specifications.

Indeed, the inscription in the lobby of the National Institute of Science and Technology (NIST) main administration building (Building 101) (formerly the National Bureau of Standards) in Gaithersburg, Maryland, graphically makes the case for the importance of standards to modern society: “It is therefore the unanimous opinion of your committee that no more essential aid could be given to manufacturing, commerce, the makers of scientific apparatus, the scientific work of the government, of schools, colleges, and universities than by the establishment of the institution proposed in this bill.”¹

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¹ Report on the bill to establish the National Bureau of Standards, House of Representatives, HR1452, 56th Congress, 1st Session, May 14, 1900 (U.S. House Reports, Serial 4026, Volume 6, 1899-1900).

SPECIFICATIONS AND STANDARDS

A complex challenge in improving the reliability of bolted connections in the oil and gas industry is the multitude of specifications and standards that currently exist that can be read to apply to one or more elements of these connections in some manner. One bolt manufacturer reported that their library contains approximately 1,000 specifications and standards that address various aspects of bolt design and bolt manufacture. This includes more than 500 specifications and standards of trade organizations (American Section of the International Association for Testing Materials [ASTM], American Petroleum Institute [API], American Society of Mechanical Engineers, American Society for Nondestructive Testing, etc.), plus well over 500 customer-specific standards.²Appendix H contains a summary and brief explanation of the most commonly used bolting regulations and standards, including the pertinent federal regulations; industry standards, specifications, and recommended practices from API and ASTM; NACE Materials Requirements; NORSOK materials standard; and API flange bolt design specifications.

This multitude of requirements, many of which are overlapping, contradictory or lack consistency, is an unnecessary burden on the industry, and counterproductive to safety. Design engineers with the major oil companies and original equipment manufacturers (OEMs), along with their sourcing experts, can readily manage this multitude of standards and specifications. But within the lower vendor tiers, this multiplicity, overlap, and contradictory standards and specifications can lead to confusion and application of the wrong standard or specification. Therefore, there is a need for leadership in consolidating standards, using a balanced group of subject matter experts from industry, government, and trade organizations to provide uniformity and simplicity the supply chain. For instance, the process used to produce the 2nd Edition (issued February 1, 2017 ) of API SPEC 20E, “Alloy and Carbon Steel Bolting for Use in the Petroleum and Natural Gas Industries,” appears to be a step in the right direction since there was wide participation in its development, and the standard is written in clear, unambiguous language.

In addition to the multiplicity of standards previous mentioned, the bolting industry itself has a multitude of proprietary internal standards that do not foster cooperation and shared expertise across the industry.

Development of specifications and standards should be based on science and be informed by history, shared data and experience. There are numerous industries and organizations that have developed effective means of collating this information into specifications and standards. Discussion later in this chapter describes specific examples from the Aviation Industry and the U.S. Navy, but others can be found

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² Personal communication, Tom Goin, president U.S. Bolt Manufacturing, Inc., August 15, 2017.

in diverse industries such as the nuclear power industry,³ construction industry, automotive industry, communications industry, food industry and the pressure vessel industry. The USS Thresher disaster was a wake-up call for the U.S. Navy to develop a preeminent safety culture in submarine design and construction, and the Northridge earthquake was a wake-up call for the construction industry to include greater attention to seismic design. Similarly the Deepwater Horizon incident must continue its progress as a wake-up call for the further improvement of specifications and standards in the offshore oil and gas industry.

An overly prescriptive regulatory environment can have a suffocating effect on new technological developments and applications. The preferred alternative is a move toward a performance or goal-oriented regulatory system such as is practiced by Norway and the United Kingdom. The authoring committee for the National Academy of Engineering/National Research Council report Macondo Well Deepwater Horizon Blowout: Lessons for Improving Offshore Drilling Safety also believed in the advantages of goal-oriented regulations. Contained in their report is Summary Recommendation 6.1 “The United States should fully implement a hybrid regulatory system that incorporates a limited number of prescriptive elements into a proactive, goal-oriented risk management system for health, safety, and the environment.”⁴ This regulatory system will prevent any firm from gaining a competitive cost advantage through cutting corners on safety, by forcing everyone to bear the associated cost increases of safety measures as a part of doing business.

A National Academies of Sciences, Engineering, and Medicine committee recently assessed various considerations for designing a safety regulatory approach for high-hazard industries. Its report, as two of its case studies, examined the offshore regulatory regime in the United States.⁵ Among other findings, it states,

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³ Some sense of the regulations can be found in Regulatory Guide 1.65, “Materials and Inspection for Reactor Vessel Closure Studs” and references therein. Some indication of issue resolution in this context can be found in R.E. Johnson, Resolution of Generic Safety Issue 29: Bolting Degradation or Failure in Nuclear Power Plants, NUREG-1339, U.S. Nuclear Regulatory Commission, Washington, D.C., 1990.

⁴ National Academy of Engineering and National Research Council, Macondo Well Deepwater Horizon Blowout: Lessons for Improving Offshore Drilling Safety, The National Academies Press, Washington, D.C., 2012.

⁵ National Academies of Sciences, Engineering, and Medicine, Designing Safety Regulations for High-Hazard Industries, Transportation Research Board, Special Report 324, 2018, The National Academies Press, Washington, D.C., doi:10.17226/24907.

Outside of standards committees themselves, there is no well-defined, proactive process for proposing areas/topics to develop new standards or improve current standards for other stakeholders, such as regulators and academia.

Standards will not totally solve the fastener reliability concerns, as these standards cannot mandate judgment and insight, and do not address the enforcement process. In some instances safety critical standards are not incorporated into current federal regulations—for example, Part 250 of the U.S. Code, and as a result are not directly enforceable. Additionally, regulations are only enforced at the operator level of the oil and gas industry and thus do not directly impact the complex tiers of vendor systems of manufacturing and operation. Unless incorporated into the Code of Federal Regulations (CFR), the industry standards do not have force of law. Industry will take an active interest in development of safety standards if it is understood that these standards will be incorporated in the CFR. Standards drafted by industry stakeholders alone, creates an incentive to withhold industry expertise to maintain a competitive advantage. Safety critical standards must be owned or monitored by an independent stakeholder that is charged with responsibility for safety and reliability.

BSEE reported to the committee that they were sponsoring a project through Argonne National Laboratory (ANL) that had the goal of evaluating fastener standards used by the oil and gas, refining, aerospace, aviation, nuclear, military, naval, and automotive industries to identify differences in manufacturing, material property requirements, and cathodic protection systems between these documents and provide recommendations on harmonizing the information into a consistent set of material property and manufacturing requirements for subsea application.⁷ ANL is also tasked to make recommendations to BSEE on how to proceed to oversee use of these fasteners on the OCS. Presumably this report will be publicly available when completed.

QUALITY ASSURANCE OPTIONS

Quality assurance (QA) is the process by which industries verify that a product conforms to specifications and avoids mistakes and defects. Quality control (QC)

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⁶ Ibid., p. 68.

⁷ Bureau of Safety and Environmental Enforcement (BSEE) presentation at the Workshop on Bolting Reliability for Offshore Oil and Natural Gas Operations, April 10-11, 2017. Note: The contract was originally with Lawrence Berkeley National Laboratory, but at some point during 2017, the contract shifted over to Argonne National Laboratory.

pertains to insuring the product fulfills its quality requirements.⁸ The fastener manufacturing industry for oil and gas typically uses API Specification Q1 or ISO 9001 for quality management. These standards cover areas such contract review, design controls, management process, documentation, and inspection. The overall objective is to ensure that critical components are fit for service. Unfortunately all quality control can do is reduce the probability of a substandard manufactured part to an acceptable level. No part of a quality control process addresses the correctness of the design specification for the component. In the case of fasteners, the QC process would establish checks aimed to ensure that each step in the bolt manufacturing process from original casting to thread cutting or rolling meets specifications and purchase requirements.

Managing the supply chain is a difficult endeavor. There are many tiers of subcontracted suppliers that continually change due to costs and schedule demands. QA/QC issues have been cited as a contributory cause by even RCA provided to the committee.⁹ Typically, there is a QA/QC specific team within each organization, and the final buyer has oversight of the entire supply chain. It should be incumbent on operating companies to ensure there are no lower tier supply chain issues and critical components are fit for service, and incumbent on the buyer to ensure that the parts purchased have the correct and verifiable pedigree.

Safety critical components require a more in-depth approach to QA/QC and the enforcement of material specifications than is typically required for common components. The U.S. Nuclear Regulatory Agency addresses some of these issues in their QA regulation which holds all levels of the supply chain to the same standard.¹⁰ Equipment manufacturers often opt to have an in-depth internal process for qualifying a vendor and ensuring that those vendors maintain qualification.¹¹ These checks take the form of an initial audit of their quality management system and a full vetting of the product by the buyer’s engineering team. This process should involve analysis of the variability in outcomes of the manufacturing process and a determination that variability is within overall acceptable tolerances. Firms at all

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⁸ Note that quality control is reactive in nature and is used to identify and respond to nonconformities. Quality assurance is proactive in its approach to quality planning and instituting system improvements to prevent defects and maintain reliability while maintaining after-the-fact quality control and audit functions.

⁹ BSEE, “QC-FIT Connector and Bolts Failure,” https://www.bsee.gov/what-we-do/regulatory-safety-programs/systems-reliability-section/findings-recommendations. See, for example, BSEE, QC-FIT Evaluation of Fastener Failures—Addendum, QC-FIT Report #2016-04, Office of Offshore Regulatory Programs, Washington, D.C., February 2016, https://www.bsee.gov/sites/bsee_prod.opengov.ibmcloud.com/files/memos/public-engagement/qc-fit-bp-bolts-report-final.pdf.

¹⁰ U.S. Nuclear Regulatory Commission, “Appendix B to Part 50: Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants,” NRC 10 CFR, last reviewed/updated August 29, 2017.

¹¹ One example was presented during the committee visit to Schlumberger visit on March 23, 2017.

levels of the supply chain should be periodically audited to ensure that quality is maintained, which does not appear to be currently the practice.

Quality issues arise for the following reasons:

• While subject matter experts are often involved in initial vetting of suppliers, they are not directly involved in ongoing maintenance of the QA program. Subject matter experts should be involved in audits and inspections.
• Small QA inspections sample sizes can result in a statistically unacceptably large possibility of critical component failures. The level of acceptable risk of a component not meeting specifications should determine the frequency and scope of inspections. A similar logic should determine if quality standards are sufficient or if there should be increased oversight to reduce risk.
• Clear, traceable documentation of all steps is required. Relying on undocumented individual expertise that makes continuity and reproducibility in the process difficult to maintain, particularly when there is a change in lower tier vendors
• The entire fastener process from manufacturing through installation and maintenance should be subjected to audits for quality. The organizations performing audits must be free from external influence.

The multiple layers of QA inherent in the procurement and manufacture of bolts for critical service is an organizational challenge for the oil & gas industry. This is evidenced in the past by substandard bolts finding their way into critical service in deepwater drilling equipment.

REGULATORY EXAMPLES FROM OTHER INDUSTRIES

Across industries, engineering best practices and regulations are often identified because of significant critical failures. While this process is inherently reactionary, it has a proven track record of preventing failures similar to past failures, but naturally falls short at preventing other “new” failure types. Failure events also provide an opportunity to determine the gaps and limitations in the overall approach to safety and reliability that extends beyond the cause of the failure event.

This section presents lessons learned by the Federal Aviation Administration (FAA) and the U.S. Navy and how regulatory practices were changed in response to low-probability, high-consequence events. Both the FAA Aviation Safety organization and U.S. Navy SUBSAFE regulatory approaches, and their governing authorities, have elements that BSEE could tailor for their field of interest. These focus on the core areas of empowered centralized engineering oversight of critical areas, industry-wide engineering to identify risk reduction solutions, and promulgate institutional culture to reduce risk. In some cases, to ensure the newly identified

best practices were implemented throughout the industry, additional statutory authority may be necessary and would have to be pursued.

Federal Aviation Administration

The FAA, U.S. Department of Transportation, has the mission to provide the safest, most efficient aerospace system in the world.¹² The FAA was established in 1958, by the Federal Aviation Act, after aviation safety’s wake up call, the DC-7/F100 collision near Las Vegas, Nevada, which transferred functions from the Civil Aeronautics Authority to provide a focus on civil aviation safety.¹³

The FAA, working with the aerospace industry and its supply chain and the airline operators, including flight crews, have dramatically improved flight safety. American commercial aviation has become the safest travel mode. Scheduled airlines operate under the stringent rules of Federal Aviation Regulation (FAR) Part 121. The last fatal accident involving a scheduled U.S. airline was in 2009. In 2015, U.S. airlines flew 7.6 billion miles on airplanes with 10 or more seats. Even thought there were no fatalities, there were close calls and accidents. The accident rate was low: 0.155 per 100,000 aircraft flight hours. That’s down by half from 2004, when there were 0.302 accidents per 100,000 flight hours. In 1960, at the beginning of the jet age, U.S.-certificated air carriers had 7.9 accidents per 100 million aircraft miles flown.¹⁴

The FAA’s Aviation Safety organization is responsible for the certification, production approval, and continued airworthiness of aircraft; and certification of pilots, mechanics, and others in safety-related positions.¹⁵ This organization promotes safe flight through standards for design, material construction, quality work and performance of aircraft and aircraft engines. FAA Aviation Safety establishes requirements for aviation safety including:

1. Regulations, orders and advisory circulars;
2. Requirements for quality systems, design, manufacturing and maintenance of operating organizations;

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¹² Federal Aviation Administration (FAA), “About FAA,” https://www.faa.gov/about/, accessed June 2, 2017.

¹³ FAA, “A Brief History of the FAA,” https://www.faa.gov/about/history/brief_history, accessed June 2, 2017.

¹⁴ D. Reed, “In A Dangerous World, U.S. Commercial Aviation Is On A Remarkable Safety Streak,” Forbes.com, December 28, 2016, https://www.forbes.com/sites/danielreed/2016/12/28/in-the-last-7-years-you-were-more-likely-to-be-run-over-by-a-car-than-to-die-in-an-airline-crash/#39af873d428a.

¹⁵ FAA, “Aviation Safety (AVS),” https://www.faa.gov/about/office_org/headquarters_offices/avs/, accessed June 2, 2017.

3. Certificates and approvals for design and design changes, production and manufacturing, maintenance and operations;
4. Production approvals with a detailed fifteen element check list to ensure quality production of products and articles
5. FAA oversight and control of Production Approval Holders (PHA) including guidance for surveillance, and FAA authority to act in the interest of safety at any time.
6. FAA use of certificate management to ensure that each PHA remains in compliance with manufacturing regulations through inspections, audits, accident investigations, and evaluation of suspected unapproved parts. Further audits are conducted at multiple points including at PHA supplier facilities and/or its’ suppliers;
7. FAA initial and annual risk assessments of all PHAs are used to determine certificate management audit responsibilities. Even with these extensive regulations and processes the industry has experienced defective parts in critical applications and they have ongoing efforts with the industry to find and eliminate them.

While the FAA monitors and interacts closely with the aviation industry, it allows for the use of standard parts (e.g., nuts and bolts) Such parts can be manufactured by anyone if the parts meet government and industry standards. The responsibility for the quality of such parts lies with the installers with some FAA oversight. However, the parts used under these criteria are defined by the FAA as non-critical.

The FAA also employs designated engineering representatives (DERs) who typically work for an aerospace firm, including OEMs, but who have a responsibility to the FAA. The DER system enables the FAA to use qualified technical people to perform certain examinations, testing, and inspections necessary to determine compliance with applicable airworthiness standards. A DER offers state-of-the-art technical expertise. FAA interaction with DERs is highly interdependent, building on the mutual interests that the FAA, manufacturers, and operators have in achieving the highest level of safety.¹⁶ BSEE could easily adopt a similar approach by requiring Professional Engineers to be involved during critical design, manufacturing, assembly and testing activities.

An example of the FAA’s proactive response to an accident is establishment of the Jet Engine Titanium Quality Committee (JETQC). In 1989, a titanium fan disk failed in the center engine of a DC-10 airplane; shrapnel from the disk severed

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¹⁶ FAA, 8110.37E—Designated Engineering Representative (DER) Guidance Handbook, https://www.faa.gov/regulations_policies/orders_notices/index.cfm/go/document.information/documentID/1018533.

the lines of the three hydraulic systems that powered the airplane’s flight controls. The flight crew had difficulty controlling the airplane for landing, and it crashed on landing at Sioux Gateway Airport, Iowa, leading to loss of 111 passengers and crew. The root cause of the disk failure was determined to be metallurgical inclusion located in a high-stress region of the disk that led to an undetected fatigue crack.¹⁷

The objective of the JETQC is to provide the industry an early warning system of potential problems in the manufacturing of titanium components. The JETQC included membership from all premium quality titanium alloy suppliers and engine manufacturers. The JETQC established detailed specifications for reporting inclusions at all stages for the processes used for manufacturing premium-quality titanium.

Because of the proactive industrial initiative to improve inspection and processing technologies, educate the workforce, and share information among all consortium members, there has been a one to two order of magnitude reduction in identified melt inclusions in titanium components and no reported component failures.¹⁸

The JETQC incorporated the following strategies:

1. Membership is comprised of the FAA, engine OEMs, and the titanium suppliers of premium-quality material; membership is global
2. Regulations require mandatory reporting of all inclusions, and regular reporting to all consortium members of the statistics
3. Continuous process improvements in the processing and inspection of premium-quality titanium
4. Proactive cooperative industry initiatives to enhance reliability of premium-quality titanium rotating-part components

The FAA regulatory approach has effectively worked with all stakeholders in the aviation industry to continuously improve aviation safety. The formation of JETQC is an example of the proactive leadership role the FAA has taken to address the root cause of an accident: Establish a metric (i.e., identified metallurgical defects),

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¹⁷ National Transportation Safety Board, United Airlines Flight 232 McDonnell Douglas DC-10-10, November 1, 1991, https://www.ntsb.gov/investigations/accidentreports/pages/AAR9006.aspx; FAA, “Manufacturing Process of Premium Quality Titanium Alloy Rotating Engine Components,” Advisory Circular 33.15-1, September 22, 1998; FAA, “FAA Engine Titanium Consortium,” FAA William J. Hughes Technical Center, http://www.tc.faa.gov/its/cmd/visitors/data/AAR-430/engtitan.pdf, accessed June 2, 2017.

¹⁸ See Figure 5.4, courtesy of Andy Woodfield, GE Aviation, in National Academies of Sciences, Engineering, and Medicine, Bolting Reliability for Offshore Oil and Natural Gas Operations: Proceedings of a Workshop, The National Academies Press, Washington, D.C.

harness the efforts of the entire industrial base to provide continued improvements, and measure and report progress against the metric.

U.S. Navy Practices

The U.S. Navy operates a fleet of more than 270 ships and 3,700 aircraft and is by a significant margin is the largest Navy in the world and its air force is second in size only to the U.S. Air Force. These assets have highly demanding operational requirements ranging from submarines operating at depth, to high-speed surface vessels, to aircraft designed for both aerial combat and carrier landings. The performance, material requirements, and complexity needed in these operational environments is high and requires a stringent approach to design, qualification, inspection, and maintenance to meet safety and reliability standards. For example, the critical fasteners attaching a controllable pitch propeller blade on DDG 51 destroyer required critical evaluation of the fastener design, an in situ study to determine the operational conditions, fastener material and specialized installation practices.¹⁹ The Navy has established the proper controls and processes to manage both standard and specialized processes and controls to meet high-performance requirements while mitigating risk.

The nuclear submarine fleet has successfully established the institutional structure through the SUBSAFE program to ensure safety across the submarine fleet even as new designs are implemented. The following summarizes Rear Admiral Paul E. Sullivan’s statement on the inception of the SUBSAFE design practices and lessons learned during intervening reviews of the SUBSAFE program as presented to the House Science Committee, on October 29, 2003.²⁰

On April 10, 1963, the USS Thresher was lost at sea. The USS Thresher inquiry led to 166 findings of fact, 55 opinions, and 19 recommendations. While the exact cause is not known, the inquiry found deficient specifications, deficient shipbuilding, deficient maintenance, and deficient operational procedures. This report formed the basis of the Navy’s SUBSAFE design and operational requirements and were codified into the Submarine Safety Requirements Manual (NAVSEA 0024-062-0010) in 1974. Since the loss of the USS Thresher, there have been no SUBSAFE certified submarines lost. In 1985, an independent organization was established

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¹⁹ H. Stefansson, Rolls-Royce Naval Marine, “Controllable Pitch Propeller Blade Bolt Design,” presentation at the Workshop on Bolting Reliability for Offshore Oil and Natural Gas Operations on April 11, 2017.

²⁰ Statement of Rear Admiral Paul E. Sullivan, U.S. Navy Deputy Commander for Ship Design, Integration and Engineering, Naval Sea Systems Command, before the House Science Committee on the Subsafe Program October 29, 2003, http://www.navy.mil/navydata/testimony/safety/sullivan031029.txt.

within the Naval Sea Systems Command (NAVSEA) to strengthen and review compliance with SUBSEA requirements. Theses audits found critical lessons learned:

• Disciplined compliance with standards and requirements is mandatory.
• There must be an engineering review system in place to resolve technical problems and issues.
• There must be a safety and quality programs in place to support operation.
• Safety and quality organizations must have sufficient authority and freedom to operate without external pressure.

The SUBSAFE program has a clearly defined objective to provide maximum reasonable assurance of maintaining watertight integrity and recovery capability. To maintain the safety culture, clear, concise non-negotiable requirements are enforced through multiple structured audits that hold personnel at all levels accountable for safety and annual training that emphases strong emotional lessons learned from past failures.

There is a single submarine program manager who manages and ultimately approves all aspects of construction, maintenance and life cycle management and ensure compliance with SUBSAFE requirements. There is a single technical authority that overseas each specific technical area of the SUBSAFE program such as subject matter experts to support the submarine program managers. These technical authorities are warranted and have the responsibility and accountability to establish, monitor and approve technical products to ensure conformance to requirements. They must ensure that a full technical discussion is held prior to making designs. When technical products are not in conformance with policy, the technical authority must evaluate risk.

The certification process covers design, material, fabrication, and testing and is implemented through three critical areas: work discipline, material control, and documentation. Work discipline is conveying the knowledge of the requirements and compliance with those requirements to everyone who works with submarines. Material control ensures that the correct material is purchased on procurement contract, receipt inspection, storage handling, and installation on the submarine. Documentation begins at the design phase of the submarine when a drawing is established and maintained through the life of the ship for every component and includes system diagrams and manuals.

The overall objective is to generate an identifiable accountable and auditable record of work performed within the SUBSAFE boundary. For each component there is a comprehensive record of the quality of any work performed on a component—for example, nondestructive testing of a material, weld records, and work orders. Documentation of quality evidence proves the materials and work were performed to specification and allow for any deviations or nonconformity to be

adjudicated by the appropriate authority. All organizations and contractors performing SUBSAFE work must be evaluated, subject to routine audits and certified by NAVSEA that these requirements are met.

The fastener technical warrant holder is empowered to make design decisions related to fastener use and nonconformity in the fleet.²¹ Common issues encountered include the following:

• Requirements set before consulting fastener engineer or environment. Were requirements based on an engineering need or a business decision?
• Be proactive regarding design changes. Retrofitting is often significantly more expensive
• Quality such as ISO17025 must be built into both the contract and design

An important component of the decision process is determining risk. Each risk is assigned a both a probability and a criticality or severity of consequence. The ultimate responsibility for determining the risk and severity lies with the technical warrant holder who has the responsibility to approve all designs and design modifications and communicate that risk to other stakeholders.

The SUBSAFE program established procedures to ensure the most critical components related to operational safety are maintained through design, implementation and maintenance and are carried over to new designs. It established a centralized empowered authority to oversee each technical area individually and the system as whole. The culture of safety was established and emphasized to every level of personnel. Routine accreditation and standards compliance audits of both internal and external organizations are routinely made. A comprehensive set of documentation is tracked for each critical component to ensure quality.

A bolting reliability improvement roadmap—a meaningful comprehensive government-industry initiative—could be constructed and aimed primarily at improving fastener reliability for the most critical subsea applications. The challenge is to reduce the probability of a subsea fastener failure, which is already low, by another 1 to 2 orders of magnitude over a defined period of time, such as the next 10 years.

Initially organizing an industry-wide effort to construct a comprehensive roadmap is likely beyond the purview of industry, if for no other reason to avoid the appearance of unlawful collusion. Thus, it is likely that BSEE will need to undertake the proactive role of establishing a consortium to construct a comprehensive

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²¹ See the presentation summary for Frederick Kachele, Acting NAVSEA Fastener Technical Warrant Holder, in National Academies of Sciences, Engineering, and Medicine, Bolting Reliability for Offshore Oil and Natural Gas Operations: Proceedings of a Workshop, The National Academies Press, Washington, D.C., 2017, pp. 89-92.

roadmap that could advance the safety of threaded fasteners. Statutory changes to oil industry anti-trust requirements may be needed. The multi-faceted roadmap could contain key objectives and priorities that could be executed and implemented by the industry, much as was done in the FAA’s JETQC and the Navy’s SUBSAFE efforts. Industry should have large role in determining the priority for addressing potential improvements. The roadmap could be divided into the following sections:

• Clearing and legal obstacles to having multiple companies working closely and sharing data.
• Research and development of specific innovation opportunities that have the potential to significantly advance the reliability of offshore fasteners in critical service. Specific opportunities are suggested in Chapter 5 of this report.
• Collection of necessary statistical data for key operational environment design parameters; this would allow a statistically based probabilistic risk assessment (PRA) to be performed to quantify the safety factors to use in the design.
• Identification of gaps in current standards and obtaining the necessary data to guide updating the standards.
• Promotion of a strategic vision for the safety culture required by oil and gas operations. This would include collecting and disseminating information about fastener performance, failures, and near misses across different disciplines and organizations, and quite importantly, assessing how this information would affect roadmap priorities.

SUMMARY AND RECOMMENDATIONS

There is a keen interest in improving the reliability of offshore engineering structures and in reducing the risk of damage to the environment to as close zero as possible. With many disparate views on the preferred approach, there should be a forum by which stakeholders have an opportunity to contribute their ideas and have them adequately investigated to enhance the development of offshore resources. Traditionally in engineering design, materials selection, manufacturing, installation and operation, this forum has been accomplished through the development and use of standards and specifications.

Finding: A challenge in improving the reliability of bolted connections in the oil and gas industry is the multitude of specifications and standards that currently exist. Bolt manufacturers must deal with more than 1,000 specifications that address various aspects of bolt design and bolt manufacture. This includes more than 500

specifications and standards of trade organizations (ASTM, API, Mil, AS, ASME, ASNT, etc.), plus well over 500 customer-specific standards.²²

Finding: An overly prescriptive regulatory environment can impede newer technological developments and applications. A 2012 report on the Macondo Well Deepwater Horizon Blowout by the National Academies of Sciences, Engineering, and Medicine stated, “The United States should fully implement a hybrid regulatory system that incorporates a limited number of prescriptive elements into a proactive, goal-oriented risk management system for health, safety, and the environment.”²³

Finding: Standards will not totally solve the fastener reliability concern. For instance, current standards do not address the enforcement process. They are not incorporated into current federal regulations, e.g., Part 250 of the U.S. Code, and as a result are not directly enforceable. Regulations are also only enforced at the operator level of the oil and gas industry and do not directly apply to the complex systems of manufacturing and operation.

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²² Personal communication, Tom Goin, president U.S. Bolt Manufacturing, Inc., August 15, 2017.

²³ National Academy of Engineering and National Research Council, Macondo Well Deepwater Horizon Blowout: Lessons for Improving Offshore Drilling Safety, The National Academies Press, Washington, D.C., 2012.

²⁴ Ibid.

Finding: Managing the supply chain is a difficult endeavor. There are many tiers of subcontracted suppliers that continually change due to costs and schedule demands. QA/QC issues are often cited as contributory causes in failure analyses.²⁵

Finding: Across industries, engineering best practices and regulations are often the result of lessons learned from a critical failure of significance. While this process is inherently reactionary, it has a proven track record of preventing failures similar to those of past failures. The FAA and the U.S. Navy, in response to low-probability, high-consequence failures, have successfully implemented long-term programs that have dramatically increased safety.

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²⁵ BSEE, “QC-FIT Connector and Bolts Failure,” https://www.bsee.gov/what-we-do/regulatory-safety-programs/systems-reliability-section/findings-recommendations. See, for example, BSEE, QC-FIT Evaluation of Fastener Failures—Addendum, 2016.

²⁶ BSEE, QC-FIT Evaluation of Fastener Failures—Addendum, 2016.