BSEE INC/Civil Penalty Update Gulf Coast Action Team (GCAT) Meeting - - PowerPoint PPT Presentation

BSEE INC/Civil Penalty Update

Gulf Coast Action Team (GCAT) Meeting Shell Robert Facility Robert, Louisiana May 14, 2014

Office of Safety Management (OSM)

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Glynn.Breaux@bsee.gov – Chief OSM Jason.Mathews@bsee.gov – Safety and Environmental Management Specialist (SEMS) Regional Coordinator Roderick.Belson@bsee.gov – SEMS / District Incident Reviews / Safety Alerts Robert.Carroll@bsee.gov – SEMS Matthew.Nagy@bsee.gov – SEMS District Incident Reviews / Safety Alerts Tommy.Machado@bsee.gov – Annual Performance Review / Performance Improvement Plan (APR/PIP) Regional Coordinator Kenneth.Kinnett@bsee.gov – Civil Penalty Compliance Reviewing Officer (CRO) Stephen.Kovacs@bsee.gov – CRO Kevin.Sterling@bsee.gov – CRO Michael.Wilson@bsee.gov – CRO Jack.Williams@bsee.gov – Regional Accident Investigator (Panels) / Safety Alerts Stephen.Garcia@bsee.gov – Regional Accident Investigator (Panels) / Safety Alerts

• Office of Safety Management (OSM)
• Incident Statistics and Summaries (Rainbow Chart – bsee.gov website)

Fatalities (Work Related) Injuries Loss of Well Control Fires/Explosions Spills > 50 Barrels (2013 data not yet available)

• GOM Region Production INCs

Total INCs and Production Inspections Graph Total INCs issued vs. Components Inspected Graph Production facility INCs by Enforcement Type

• GOM Region Drilling INCs

Total INCs and Inspections Graph Rig Facility INCs by Enforcement Type

• Top 10 Production INCs

Top 10 Production INC Descriptions (appearing every year) Top 10 Production INC Descriptions (all remaining)

• Top 10 Rig INCs

Top 10 Rig INC Descriptions (appearing every year) Top 10 Rig INC Descriptions (all remaining)

• Top 10 Civil Penalty (CP) INCs

Top 10 CP INCs (appearing every year) Top 10 CP INC Descriptions (all remaining)

• Number of CPs for Operators and Contractors
• CP Case Status
• INC Violations Warranting CP Review
• Guidelines for Determining a Threat
• INCs that Automatically Trigger a CP Review
• CP Matrix/Assessment Table – July 30, 2011
• Criminal Penalty Referrals

AGENDA INC & CP Data

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Incident Statistics and Summaries

OCS Incidents/Spills by Category: CY 2007 – 2013

TYPE

2007 2008 2009 2010 2011 2012 2013 GOM GOM GOM GOM GOM GOM GOM FATALITIES

5 11 4 12 3 4 3

INJURIES *** #

423 318 285 273 213 253 226

LOSS OF WELL CONTROL ***

7 8 6 4 3 4 9

FIRES/EXPLOSIONS

110 139 133 126 103 134 97

COLLISIONS ***

20 22 29 8 14 9 19

SPILLS ≥ 50 bbls

4 33 11 5 3 8 ^

OTHER ***

268 278 308 155 186 236 272

INCIDENT TOTAL FOR THE YEAR

837 809 776 583 525 648 626

COMBINED TOTAL FOR THE YEAR

890 871 832 616 560 730 691

Note: Taken from bsee.gov website – See explanations for each legend (***#, ***, etc.) on website.

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GOM Region Safety Statistics

Category 2007 2008 2009 2010 2011 2012 2013 Fatalities

(Work Related)

5 11 4 12 3 4 3

Injuries

423 318 285 273 213 253 226

Loss of Well Control

7 8 6 4 3 4 9

Fires & Explosions

110 139 133 126 103 134 97

Collisions

20 22 29 8 14 9 19

Sig.(>50bbl) Spills

4 33 11 5 3 8

*Data to be provided

later.

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Explosions/Fires – 16 (11-Deepwater Horizon; 1-tank cleaning fire; 4-hot work on tankage) Crush Points – 7 (4-Vessel transfers; 1-pipelay; 1-crane; 1-pipehandler) Falling Objects – 10 (all during rig/well operations) Falls – 9 (8 from heights or swing ropes & 1-decommissioning) Diving Related – 6 Helicopter Crashes – 3 Electrocution – 1

Fatalities (Work Related)

Year 2007 2008 2009 2010 2011 2012 2013 Fatalities 5 11 4 12 3 4 3

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Effective July 17, 2006 (MMS Incident Reporting Rule):

• Operators required to report Lost Time Accidents, Restricted Work, Job

Transfers for which total work time is lost, the employee’s work is restricted, or the person is transferred to another job for a period of at least one day. Also, if an injury required evacuation for the purpose of receiving medical treatment, it must be reported immediately. These are captured on the Accident/Incident Form as: LTA(1-3 days); LTA(> 3 days); RW/JT (1-3 days); RW/JT (> 3 days)

Injuries

Year 2007 2008 2009 2010 2011 2012 2013 Injuries 423 318 285 273 213 253 226

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OCS Injuries

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INJURIES *** # 2007 2008 2009 2010 2011 2012 2013 GOM GOM GOM GOM GOM GOM GOM Loss Time Accident (1-3 days) 26 22 17 18 14 30 29 Loss Time Accident (>3 days) 105 76 64 116 74 80 68 Restricted Work/Job Transfer (1-3 days) 26 27 29 15 16 17 18 Restricted Work/Job Transfer (>3 days) 94 93 61 53 50 66 59 Other (< 1 Day Lost Time / Restricted Work / Job Transfer) 172 100 114 71 59 60 52 INJURY TOTAL FOR THE YEAR 423 318 285 273 213 253 226

Loss of Well Control

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LOSS OF WELL CONTROL *** 2007 2008 2009 2010 2011 2012 2013 GOM GOM GOM GOM GOM GOM GOM Flow Underground 1 1 1 Flow Surface 3 3 2 1 2 4 4 Diverter Flow 1 3 Surface Equipment Failure 3 3 4 3 1 1 LOSS OF WELL CONTROL (TOTALS) 7 8 6 4 3 4 9 COMBINED TOTAL FOR THE YEAR 7 8 6 4 3 4 9

Catastrophic – destruction of a facility worth greater than $10 million Major – property damage greater than $1 million Minor – property damage greater than $25,000 but less than or equal $1 million Incidental – property damage equal to or less than $25,000

Fires/Explosions

Year 2007 2008 2009 2010 2011 2012 2013 Totals 110 139 133 126 103 134 97

Catastrophic

1 Major 1 1 2 Minor 6 9 3 5 4 4 3 Incidental 104 130 130 119 98 128 94

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* In the case of drilling muds, only the base fluids (e.g. diesel, mineral oil, synthetic fluid, etc.) are counted as

• pollution. A spill of 100 bbl of 65% diesel-based mud is counted as a 65 barrel diesel spill. A 100 bbl spill of

55% synthetic-based mud is counted as a 55 barrel synthetic-based fluid spill. * * In deepwater drilling, synthetic-based muds (SBM's) are preferred over petroleum oil-based muds (OBM's) due to the SBM's superior performance properties. The synthetic base fluid used in SBM's are less toxic to the marine environment and have the potential to biodegrade. Only the synthetic base fluids are counted as

• pollution. SBM's were first introduced in the Gulf of Mexico around 1999. Petroleum oil-based muds (OBM's)

were the predominant muds prior to this time (generally with diesel or mineral oil as the base), and are still used

• utside of deepwater.

Spills > 50 *Barrels

Year 2007 2008 2009 2010 2011 2012 Crude & NGC 1 19 4 2 1 1 *Refined Petroleum 5 * *Synthetic- Based Fluids 2 2 4 2 2 3 Chemicals 1 12 3 1 4 Totals 9 33 11 5 3 8

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GOM Region Production INCs

2007 2008 2009 2010 2011 2012 2013

Warning INCs 1149 776 984 1333 1006 960 1129 Component SI INCs 1040 736 1039 1381 1965 971 1055 Facility SI INCs 91 79 98 105 80 92 94 Total INCs 2280 1591 2121 2819 2151 2023 2278 Components Inspected 46323 51014 55016 60449 50993 46269 56,930 INC-to- Component Ratio 0.05 0.03 0.04 0.04 0.04 0.04 0.04

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500 1000 1500 2000 2500 3000 3500 4000 4500 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 INCs issued in GOMR

Total Production Process Inspection INCs issued vs. Inspections – Production Facilities

Total INCs Inspections

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10000 20000 30000 40000 50000 60000 500 1000 1500 2000 2500 3000 3500 4000 4500 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 PRD Components Inspected INCs issued in GOMR

Total Production Process Equipment INCs issued vs. Components Inspected - Production Facilities

Total INCs PRD_CMPNTS

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500 1000 1500 2000 2500 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 INCs issued in GOMR

Production Facility INCs by Enforcement Type

C S W

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GOM Region Drilling INCs

2007 2008 2009 2010 2011 2012 2013

Warning INCS

94 48 59 68 146 135 179

Component SI INCS

31 16 34 25 65 106 69

Facility SI INCS

30 7 20 19 51 38 49

Total INCS

155 71 113 112 262 279 297

Inspections

999 870 771 724 869 1257 1188

INC-to- Inspection Ratio

0.16 0.10 0.15 0.15 0.30 0.22 0.25

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500 1000 1500 2000 2500 50 100 150 200 250 300 350 400 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 Rig Inspections in GOMR INCs issued in GOMR

Total INCs & Inspections - Rig Facilities

Total INCs Inspections

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50 100 150 200 250 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 INCs issued in GOMR

Rig Facility INCs by Enforcement Type

C S W

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Top 10 Production INCs

2007 2008 2009 2010 2011 2012 2013

G111 G111 G111 G111 G111 G111 G111 G112 G110 G110 G110 G110 G110 G110 G110 G112 G112 G112 G112 G112 G112 F108 G115 G115 G115 G115 P412 M200 G115 P412 P412 P412 P412 M200 P412 E100 F108 P241 P406 E100 G115 E100 P412 E100 P470 E108 L141 P240 P280 P280 P240 F108 E100 P422 E100 G115 P470 P406 E100 P470 F108 P404 P470 Z100 L141 P422 E120 M200 P280 P121

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Top 10 Production INC Descriptions (Appearing Every Year)

G110 – Perform all operations in a safe and workmanlike manner; G111 – Maintain equipment in a safe condition; G112 – Take all necessary precautions to provide for personnel safety; G115 – Operations are conducted in accordance with approved applications; E100-The operator is preventing unauthorized discharge of pollutants into waters; P412 – Wellhead completion equipped with minimum of 1 master valve and an

• perable SSV or USV, above master in vertical run.

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Top 10 Production INC Descriptions Continued

E100- The operator is preventing unauthorized discharge of pollutants into waters; E108- Lessee preventing the disposal of equipment (cables, chains, etc.) into OCS waters; E120- Facilities and pipelines inspected for signs of pollution, and records are being maintained; F108-Electrical installations are made in accordance with API RP 500 and API RP 14F or API RP 505 and API RP 14FZ; L141- Pipelines out of service more than 1 year are end isolated; M200- Gas equipment installed and operated in accordance with API MPMS, incorporated by reference in 30 CFR 250.198; P240- The SSV closes within 45 seconds after automatic detection of an abnormal condition or activation of the ESD; P241-The SCSSV closes within 2 minutes after the ESD or fire detection system shut-in signal has close the SSV; P280- Each SCSSV installed in a well is tested when installed or reinstalled and at intervals not exceeding 6 months and removed, repaired and reinstalled, or replaced, if it does not operate properly; P404- The PSL on each flowline segment is set no lower than 15% or 5 psi, whichever is greater, below the lowest pressure in the operating range P406- An operable FSV is installed in the final flowline segment;

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Top 10 Production INC Descriptions Continued

P422- Each pressure vessel is equipped with an operable LSH; P470- Each atmospheric vessel is equipped with an operable LSH; Z100- USCG self inspections are performed annually and recorded on a CG Form 5432, with the Form maintained on each OCS fixed facility.

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Top 10 Rig INCs

2007 2008 2009 2010 2011 2012 2013 G110 G110 G110 G110 G110 G110 G110 G112 G112 G112 G111 G112 G111 G115 D256 G251 G111 G115 G111 G112 G111 G115 G111 E102 G112 G115 G115 E100 D290 D429 E100 E100 D290 W139 G112 G111 E100 G251 D327 G155 G155 D256 D314 F104 F121 D256 D425 E100 A150 D158 D290 D273 D426 E100 F108 C102 E100 D327 D290 D290 D256 I105 D251 C130 G115 W113 D266 F121 F121 D290

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Top 10 Drilling INC Descriptions (appearing every year)

G110 – Perform all operations in a safe and workmanlike manner; G111 – Maintain equipment in a safe condition; G112 – Take all necessary precautions to provide for personnel safety; E100-The operator is preventing unauthorized discharge of pollutants into waters;

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Top 10 Rig INC Descriptions (all remaining)

A105-The cement surface plug set in the smallest string of casing extends to the mud line; C102-Crew members have been instructed in the safety requirements of the operations to be performed, possible hazards encountered, and general safety considerations… C130-Ram-type BOPs, choke manifold and other BOP equipment has been tested to a pressure equal to the rated working pressure of the equipment (or per District Mgr); D158-Surface, intermediate and production casing properly pressure tested…; D251-Ram-type BOPs, choke manifold, and other BOP properly tested…; D256-Annulars and Ram BOPs are function tested every 7 days between tests; D266-Any problems or irregularities observed during BOP system testing are identified and the actions taken to remedy such problems or irregularities recorded; D273-Surface BOP system pressure testes are begun before 14 days have elapsed since the last BOP pressure test was completed; alternating between control stations; D290-Well-control drills are conducted for each drilling crew and recorded in report; D314-The control station is used during the diverter test or actuation identified; D327-Subsequent actuation tests or the diverter sealing element, diverter valves, and diverter-control systems, including the remote-control system, are conducted at least

• nce every 24-hour period alternating between control stations for surface diverter

systems;

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Top 10 Rig INC Descriptions (Cont’d.)

D425-All classified drilling fluid-handling areas are fitted with gas detectors and alarms except in

• pen areas where adequate ventilation is provided by natural means;

D426-All classified drilling fluid-handling areas are equipped with either explosion-proof or pressurized electrical equipment to prevent the ignition of explosive gases; D429-Gas detection systems are tested for operation and recalibrated at a frequency such that no more than 90 days elapse between tests; E100- The operator is preventing unauthorized discharge of pollutants into waters; E102-The facility is equipped with curbs, gutters, drip pans, and drains necessary to collect all contaminants not authorized for discharge; F104-Lighting fixtures are installed in classified locations suitable for the particular location and protected from damage in accordance with API RP 14F, Paragraphs 9.3.3.3 and 9.3.3.6, or API RP 14Z, paragraphs 9.3.3.3 and 9.3.3.6; F108-Electrical installations are made in accordance with API RP 500 and API RP 14F or API RP 505 and API RP 14FZ; F121-All metal equipment, such as buildings, vessels, and skids are grounded to the steel structure or grounding network in accordance with API RP 14F, paragraph 6.10.3 and API RP 14FZ, paragraph 6.10.3. G115- Operations are conducted in accordance with approved applications; G155- A manual or automatic air intake shutdown device is installed for diesel engines that continuously manned;

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Top 10 Rig INC Descriptions (Continued)

G251- Skid-mounted equipment, portable containers, spools or reels, and drums are clearly marked with the owner’s name using a media durable enough to resist the effects of the environmental conditions; I105- If deficiencies that impair safe operation are known, the crane is taken out of service or its operation restricted to eliminate the unsafe condition in accordance with API RP2D, paragraph 3.1.5c; W113-A recording mud-pit level indicator with both a visual and an audible warning device has been installed, maintained, and utilized; W139-Prior to conducting high-pressure tests, all BOP systems are tested to a low pressure of 200 to 300 psi;

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Top 10 Civil Penalty INCs

2009 2010 2011 2012 2013

10-G110 15-G111 19-P103 15-G110 11-P103 7-P103 8-P103 17-G110 10-P103 11-G110 3-E103 4-E100 5-G111 7-G111 4-E103 3-G111 3-G112 3-E100 2-E100 4-P173 2-I153 2-E103 2-G112 1-G309 2-P280 1-P280 1-E106 2-E120 1-I105 2-G112 1-I105 1-P283 2-P280 1-I143 2-G111 1-L106 1-P451 1-P132 1-G317 2-E100 1-G112 1-P263 1-I143 1-G112 1-E120 1-G303 1-G115 1-P314 1-G116 1-P452

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Top 10 Civil Penalty INCs (appearing every year)

G111-Maintain equipment in a safe condition; G112-Take all necessary precautions to provide for personnel safety; P103-Any surface or subsurface safety device, which is bypassed or blocked out of service, out of service due to start-up, testing, or maintenance, is flagged and monitored by personnel;

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Top 10 Civil Penalty INC Descriptions (Continued)

E100-The operator is preventing unauthorized discharge of pollutants into waters; E103-The sump system automatically maintains the oil at a level sufficient to prevent discharge of oil into offshore waters; E106-Sump piles are not used as processing devices; E120-Facilities and pipelines are being inspected for pollution, and records kept; G110-Perform all operations in a safe and workmanlike manner; G115- Operations are conducted in accordance with approved applications; G116-Operations are conducted in accordance with approved plans; G303-Equipment containing H/Cs or other flammable substances are relocated at least 35 feet horizontally from the welding site, 35 feet horizontally from the point of impact

• f slag, sparks, or burning material at lower elevations, or otherwise protected;

G309-The lessee’s designated PIC must issue a written authorization prior to the commencement of any welding or burning operations in areas other than approved safe welding or burning areas; G317-All water-discharge-point sources from H/C-handling vessels are monitored in order to stop welding and burning operations in case flammable liquids are d/c;

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I105-If deficiencies that impair safe operation are known, the crane is taken out of service or its operation restricted to eliminate the unsafe condition in accordance with API RP2D, paragraph 3.1.5c; I143-Pre-use inspections are performed prior to use by a qualified c crane

• perator/inspector with records maintained, in accordance with API RP 2D.

I153-Repairs or replacements of critical components are made promptly in accordance with API RP 2D; L106-Each pipeline pump PSV is set no higher than 15% above the highest pressure in the operating range and not above the pipeline’s MAOP; P173-Each fire-detection system is installed in accordance with API RP 14C, 14G, and 14F; P263-Subsruface safety devices are installed at a depth of 100 feet or more below the sea floor within 2 days after production is established;

Top 10 Civil Penalty INC Descriptions (Continued)

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P280-SCSSVs installed in a well is tested when installed or reinstalled and at intervals not exceeding 6 months and removed, repaired and reinstalled or replaced if it does not operate properly; P283-Each tubing plug installed in a well is inspected for leakage at intervals not exceeding 6 months and removed, repaired and reinstalled, or replaced if it leaks; P314-Each electronic PSH is tested for operations every 3 months , with no more than 120 days elapsing between tests; P451-Each PSV is set at a pressure no higher than the maximum-allowable working pressure; P452-Each PSH and vent is piped in such a way as to prevent fluid from striking personnel

• r ignition sources;

Top 10 Civil Penalty INC Descriptions (Continued)

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Number of Civil Penalties for Operators and Contractors

7 35 27 42 39 49 2009 2010 2011 2012 2013

# of CPs Operators and Contractors 2009-13

Contractors Operators

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Civil Penalty Case Status

2009 2010 2011 2012 2013 2014

*Total Cases 35 27 42 38 56 21 Appeals 2 2 Review 1 1 19 18 Notice Sent 2 8 3 Paid & Closed 31 26 36 32 29 Other 2 Dismissed 4 1 1 1 Total Collected ($MM) $2.18 $1.76 $2.42 $1.32 $1.92 N/A *Note: Data is based on case year.

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INC Violations Warranting Civil Penalty Review

30 CFR 250.1404 states that MMS/BSEE will review the following violations for Civil Penalty:

Violations that cause injury, death, or environmental damage Violations that pose a threat to human life, property

• r the environment

Violations that are not corrected within the time allowed Violations of the Oil Spill Financial Responsibility Requirements

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Guidelines for Determining a Threat

A violation may be considered as posing a threat of serious, irreparable, or immediate harm or damage to human life, property or the marine, coastal, and human environment if there is evidence that it is causing, has caused, or could have caused:

• Harm, death/injury to humans;
• Destruction or damage to property or equipment;
• Harm to commercial fishing, tourism, or recreational facilities;
• Discharge of oil, non-permitted drilling fluids, or toxic, chemical, liquid
• r solid wastes and pollutants into the ocean;
• Waste of resources by non-permitted flaring or venting of

hydrocarbons into the atmosphere;

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Guidelines for Determining a Threat

• Harm, injury, or death to seabirds, fish, marine mammals or other

aquatic life;

• Destruction or disturbance of any biological, archaeological, or historic

resources;

• Harm to endangered and threatened species protected under

applicable OCS statutes, BSEE regulations, lease stipulations or permit conditions; or

• Destruction or pollution of coastal wetlands, wildlife/fish habitats,

beached, lagoons and salt ponds; or

• A violation of State/County air quality standards, as may be identified

by any Federal, State, or local agencies implementing provisions of Federal or State laws applicable to the OCS operation that has caused the violation.

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INCs that Automatically Trigger a Civil Penalty Review

Note: Two INCs automatically trigger a civil penalty review: P-103: Is each surface or subsurface safety device, which is bypassed or blocked out of service, out of service due to start-up, testing, or maintenance and is it flagged and monitored by personnel? E-103: Does the sump system automatically maintain the

• il at a level sufficient to prevent discharge of oil into the
• ffshore waters?

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Civil Penalty Matrix

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Criminal Penalty Referrals

Authority: Section 24 (c) of the OCSLA BSEE refers to the Office of Inspector General (OIG) knowing and willful violations of:

• Any provision of the OCSLA, any lease term permit pursuant to the Act, or

any regulation or order issued under the Act designed to protect health, safety or the environment or to conserve natural resources;

• Any false statement, representation, or certification in any application, record

report, or other document filed or required to be maintained under the Act;

• Falsifying, tampering with, or rendering inaccurate any monitoring device or

method of record required to be maintained under the Act; and

• A disclosure of any data or information required to be kept confidential by the

Act. Note: Under Section 2 of the Inspector General Act (IGA), the Office of Inspector General’s (OIG) is authorized to investigate criminal penalty violations.

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Glynn.Breaux@bsee.gov – Chief Stephen.Kovacs@bsee.gov – CP Compliance Review Officer Tommy.Machado@bsee.gov – APR/PIP Regional Coordinator

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THANKS – Questions?