GCREAG Regulatory Update
November, 2013
Jodie Connor
J. Connor Consulting, Inc.
Key Topics
•
•
•
•
•
Status of Agency Re-Organization
Deepwater Exploration Plan Approval Times
Inspection and Permit Fees
Enforcement
Proposed Rules
Reorganization
Sec. of the Interior
Sally Jewel
Asst. Secretary Policy,
Management & Budget
Asst. Secretary
Land & Minerals Management
Tommy Beaudreau
Rhea S. Suh
ONRR
Gregory Gould
• Revenue Collections
BSEE
Brian Salerno
•Permits
•Inspections
•Spill Response
IRU
•Investigate Allegations
of Misconduct
BOEM
Tommy Beaudreau
•Leasing
•NEPA Analysis
•Resource Evaluation
Deepwater Initial EP Approval Times
Time Period
EP Avg. Approval
Time (Days)
Pre DWH
52
2010 (Post DWH)
234
2011
144
2012
121
2013
109
Bureau of Ocean Energy (BOEM)
• Certain BOEM fees are being adjusted for inflation
• Effective Date: February 2, 2013
Plan/ Permit Action
2013 Fee Amount
Conservation Information Document
$27,348.00
Development Operations Coordination
Document (DOCD)
$4,238.00 for each well proposed; no
fee for revisions.
Exploration Plan (EP)
$3,673 for each surface location; no fee
for revisions.
Record Title/ Operating Rights (Transfer)
$198.00
Right-of-Use and Easement (RUE) for
State lessee
$2,742.00
Bureau of Safety and Environmental
Enforcement (BSEE)
• Certain BSEE fees are being adjusted for inflation
• Effective Date: October 1, 2013
Plan/ Permit Action
2013 Fee Amount
Deepwater Operations Plan
$3,599
Application for Permit to Drill
$2,113
Application for Permit to Modify
$125
New Facility Production Safety System
(>125 components)
$5,425 Permit
$14,280 to Visit Facility Offshore
$7,426 to Visit Facility in Shipyard
Platform Application
$22,734 Under PF Verification Program
$3,256 Under PF Approval Program
$1,657 Caisson/Well Protector
Pipeline Application
$4,169 ROW
$2,056 Lease Term
Inspection Fees Beginning 2012
Type Facility/Drilling Rig
Fee
2012/13
$10,500
Fee
2011
$2,000
Fee
2010
$2,000
$17,000
$3,250
$3,250
Facilities > 10 active or inactive wells
$31,500
$6,000
$6,000
Drilling rigs in WD < 500 feet
$16,700*
0
0
Drilling rigs in WD 500 ‘ or more
$30,500*
0
0
Facility - No wells - Processing
equipment or gathering lines
Facilities 1-10 active or inactive wells
* Per Inspection
Summary of Incidents
of Non-Compliance (INCs)
Total OCS INCs
2012
2011
2010
Rig Inspections
1,274
870
724
307
257
112
Facility Components
Inspected
66,441
56,998
60,164
Production INCs
2,406
2,288
2,795
Drilling INCs
BSEE Top 10 INCs
#
2013
2012
2011
1
2
3
4
5
6
7
8
9
10
G-111
G-110
G- 112
G- 115
P- 412
M- 200
P- 240
E- 100
P- 404
P- 280
G-111
G-110
G- 112
G- 115
P- 412
E- 100
L- 141
P- 422
F- 108
M- 200
G-111
G-110
G- 112
G- 115
P- 412
P- 406
E- 100
F- 108
P- 470
L- 141
INC Descriptions
INC
INC Description
G- 111 DOES THE LESSEE MAINTAIN ALL EQUIPMENT IN A SAFE CONDITION TO PROVIDE
FOR THE PROTECTION OF THE LEASE AND ASSOCIATED FACILITIES?
G -110 DOES THE LESSEE PERFORM ALL OPERATIONS IN A SAFE AND WORKMANLIKE
MANNER AND PROVIDE FOR THE PRESERVATION AND CONSERVATION OF
PROPERTY AND THE ENVIRONMENT?
G- 112 DOES THE LESSEE PROVIDE FOR THE SAFETY OF ALL PERSONNEL AND TAKE ALL
NECESSARY PRECAUTIONS TO CORRECT AND REMOVE ANY HAZARDOUS OIL AND
GAS ACCUMULATION OR OTHER HEALTH, SAFETY, OR FIRE HAZARDS?
G -115 ARE OPERATIONS CONDUCTED IN ACCORDANCE WITH APPROVED APPLICATIONS?
E- 100
IS THE OPERATOR PREVENTING UNATHORIZED DISCHARGE OF POLLUTANTS INTO
OFFSHORE WATERS?
BSEE Oversight
10 Yr Comparison of Civil Penalties
Year
INCs with
Civil
Penalties
Total Civil Penalty
First Half 2013
23
1,634,000
2012
31
2,022,500
2011
30
1,866,250
2010
26
2,073,000
2009
22
1,093,000
2008
31
2,210,250
2007
36
3,106,000
2006
41
1,480,000
2005
26
796,600
2004
21
885,750
Prepared by JCC using data from BSEE.gov
Transparent Oversight
ISEE Program
• INCs by Company
• INCs by Facility
• Investigation Reports
• Enforcement Actions including Civil Penalties
Black Elk Incident INCs
41 INCs issued by BSEE to Black Elk and three
contractors
•
•
•
•
Black Elk
Compass Engineering
Wood Group
Grand Isle Shipyard
12
9
11
9
Oil Spill Response Plans
Regulatory
Reference
Title
30 CFR Part 254
NO Change
Oil Spill Response Requirements for Facilities
Located Seaward of the Coast Line
NTL 2012 N06
Guidance to Owners and Operators of
Offshore Facilities Seaward of the Coast Line
Concerning Regional OSRPs
NTL 2012 N07
Oil Discharge Written Follow-up Reports
NTL 2013 N02
Significant Change to OSRP Worst Case
Discharge Scenario
Purpose of NTL 2013-N02
• To clarify what BSEE considers a significant
change in your OSRP WCD which requires
submittal of a revised OSRP for BSEE approval.
WCD Comparison
• The requirement to update your OSRP was
based on increase of WCD volume.
• NTL requires Operator to update the WCD in
their OSRP if additional equipment is necessary
to respond.
– If proposed operations or purchased assets require
more response equipment, revise your OSRP and
submit to BSEE within 15 days.
– For drilling WCD, the 15 day deadline begins when
you submit an APD.
GOADS
• NTL 2014-G01: 2014 Gulfwide OCS Air
Emissions Inventory (“GOADS”)
• OCS Operators will be required to collect and
submit production activities information
(facility, equipment, fuel usage, etc.) for use in
the 2014 GOADS
GOADS Tools
• Available on the BOEM GOMR homepage
www.boem.gov/Gulfwide-Offshore-Activity-Data-SystemGOADS/
• The 2014-G01 NTL
• GOADS-2014 Software (to collect and report OCS activity
data)
• GOADS-2014 User’s Guide
• Frequently Asked Questions (FAQ’s)
• How to Submit Emissions Reports
• Technical Support/Updates.
• All activity data is required to be submitted to the BOEM
GOMR by April 15, 2015.
Oil and Gas Production Safety Systems
• Proposed Rule – August 22, 2013
• Comments due December 5, 2013
– Lifecycle analysis and failure reporting of Safety and
Pollution Prevention Equipment
– Foam firefighting systems
– Electronic-based emergency shutdown systems (ESDs)
– Valve closure timing
– Valve leakage rates
– Boarding shut down valves (BSDV) and
– Equipment used for high temperature and high pressure
wells
Proposed Regulations
• Proposed Rule on Production Safety
Systems and Lifecycle Analysis
• Best Available and Safest Technology
(BAST)
• Operator must use BAST that BSEE
determines to be economically feasible
Proposed Regulations
• BSEE strategy for BAST:
• Investigate new technologies, procedures and
materials that would promote:
• Safe operations
• Prevent oil pollution
• Improve oil spill response and clean up
• Concentrate on deepwater
• ID high risk components and systems (BOPs)
Proposed Regulations
• BSEE strategy for BAST:
• Interagency agreement with DOE National
Laboratory System to collaborate on riskbased decision making and applying BAST
• If new component, system or procedure is
BAST, BSEE will issue regulation, NTL or
condition of approval.
Future Regulations
• Future Rule to enhance the requirements for
BOPs
• Pipeline regulations
• Decommissioning of offshore facilities
Ocean Energy Safety Institute
• BSEE selected Texas A&M Engineering Experiment
Station- Process Safety Center to manage the OES
Institute
• The Institute will develop a program of research,
technical assistance and education that serves as a
center of expertise in offshore oil and gas
Near Miss Reporting System
• BSEE and DOT Bureau of Transportation Statistics
(BTS) signed interagency agreement
– Develop confidential near-miss reporting system for
OCS operations
– Expect to be operational within one year
– Industry and federal personnel will voluntarily report
near misses
• BTS will maintain control of individual reports
• Provide trend analysis and statistical data to BSEE
BOEM/BSEE Holiday Office Closings
• Monday, November 11th – Veteran’s Day
• Thursday, November 28nth– Thanksgiving Day
• Wednesday, December 18th – Closed at 10:30 a.m. for
Employee’s Holiday Celebration
• Wednesday, December 25th – Christmas Day
• Wednesday, January 1st – New Year’s Day
Jodie Connor
J. Connor Consulting, Inc.
281.578.3388
Jodie.Connor@jccteam.com