gulf of mexico accident and its impact on pre-salt development

Lloyd’s Register services to the energy industry

GoM Accident and its impact on

Pre-Salt developmentDaniel (Danny) Walker

VP Compliance Services

Lloyd’s Register North America Inc.

26th October 2010


Terms of reference – MONTARA INCIDENT

Uncontrolled release of Hydrocarbons from

the Montara unmanned Wellhead Platform

– Ashmore Cartier region (Timor Sea) 690

miles West of Darwin – August 2009

www.nopsa.gov.au

Initial Investigation findings: Root Cause

Analysis

•Systematic Failure of MANAGEMENT

SYSTEMS

•Non-Compliance with Operational

process’ and procedures

http://www.nopsa.gov.au/


Terms of reference – DEEPWATER HORIZON

Explosion and Fire on MODU “Deepwater

Horizon” – 60 miles Offshore Louisiana –

April 2010

www.boemre.gov

Initial Investigation findings: POSSIBLE

Root Causes

•Equipment Design/Maintenance

•Operational safety culture

•Procedures and Process training

(Competence)

http://www.boemre.gov/


Implications for developing Pre-Salt Reserves

• Operators

Media spotlight

Loss of reputation and Community trust

Insurance and liability (unlimited liability)

Cost increases

Long term viability for smaller companies

Minimum standards vs best practice


WELL INTEGRITY = PRESSURE CONTAINMENT =

BARRIERS

30 CFR PART 250 (OCTOBER 14 2010)


30 CFR Part 250 – Immediate mandatory changes to

the Prescriptive requirements in the GoM

The Primary purpose of this interim final rule is to clarify and

incorporate safeguards that will decrease the likelihood of a

blowout during drilling operations on the Ouetr Continental Shelf

(OCS)

The interim final rule implements certain safety measures

recommended in the report entitled “Increased Safety Measures

for Energy Development on the OCS” dated May 27 2010.

The Rule becomes effective October 14 2010

Additionally, please refer to the following BOEMRE Factsheets:

The Workplace Safety Rule on Safety and

Environmental Management Systems (SEMS)

The Drilling Safety Rule


The safeguards address well bore integrity and well control

equipment

1. Establish new casing installation requirements

2. Establish new cementing requirements (Incorporate API RP 65 – Part 2, Isolating Potential Flow

Zones During Well Construction)

3. Require independent third party verification of blind-shear ram capability

4. Require independent third party verification of subsea BOP stack capability

5. Require new casing and cementing integrity tests

6. Establish new requirements for subsea secondary BOP intervention

7. Require function testing for subsea secondary BOP intervention

8. Require documentation for BOP inspections and maintenance

9. Require a Registered Professional Engineer to certify casing and cementing requirements, and

10. Establish new requirements for specific well control training to include deepwater operations



• REGULATORS

Independence of safety regulator

Prescriptive or Performance based regulatory environment (or a

combination of both)

International Regulation (IMO)

Competence



• Materials Management Service (MMS) Reorganization

• Bureau of Ocean Energy Management: A new bureau under the supervision of the Assistant Secretary for Land and Minerals Management that will be responsible for the sustainable development of OCS conventional and renewable energy resources, including resource evaluation, planning, and other activities related to leasing.

• Bureau of Safety and Environmental Enforcement: A bureau under the supervision of the Assistant Secretary for Land and Minerals Management that will be responsible for ensuring comprehensive oversight, safety, and environmental protection in all offshore energy activities.

• Office of Natural Resources Revenue: An office under the supervision of the Assistant Secretary for Policy, Management and Budget that will be responsible for the royalty and revenue management function including the collection and distribution of revenue, auditing and compliance, and asset management.


The safe operation of a facility is the responsibility of the facility

operator

The primary responsibility for ensuring health and safety lies

with those who create risks and those who work with them

1. What is the role of the regulator in all of this

2. Use the identification and mitigation of Risk AS a minimum standard

3. Meeting Regulatory requirements is NOT a minimum standard

4. Compliance with prescriptive regulation is ONLY a compliance issue

5. To what extent are regulations responsible for setting the threshold for safety

6. Are you doing enough to ensure safety

7. Are you doing what you have indicated you would do

8. What level of enforcement is required

9. Is there a minimum threshold required for operator competence


Objective/Performance based (or goal setting) regimes, (including the UK safety case regime), are based on

the principle that the legislation sets the broad safety goals to be attained and the operator of the facility

develops the most appropriate methods of achieving those goals. A basic assumption is the premise that the

ongoing management of safety is the responsibility of the operator and not the regulator.

Any goal setting is not just minimum requirement, it is the basis

of a mature & continuously improving safety culture wihin an

organization.

Root Causes Deck and Drilling Lifting MajorInjuries 2007-2009 (UK Offshore

Sector)

SupervisionPlanning

Risk Assessment

Hazard Awareness

Other

Preventitive maintenance

Procedures Not Followed

Design Specifications Design Review

Incorrect Procedures

Accidents and Dangerous Occurences 2008 - 2009

UK Offshore (HSE figures) Australia Offshore (NOPSA Figures)


For more information please visit: www.lrenergy.org

Danny Walker

VP Compliance Services

LRNA Inc

[email protected]

+1 281 675 3119

http://www.lrenergy.org/

mailto:[email protected]

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