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GCREAG Regulatory Update November, 2013

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.

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GCREAG Regulatory Update November, 2013

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  1. GCREAG Regulatory UpdateNovember, 2013 Jodie Connor J. Connor Consulting, Inc.

  2. Key Topics • Status of Agency Re-Organization • Deepwater Exploration Plan Approval Times • Inspection and Permit Fees • Enforcement • Proposed Rules

  3. Reorganization Sec. of the Interior Sally Jewel Asst. Secretary Land & Minerals Management Tommy Beaudreau Asst. Secretary Policy, Management & Budget Rhea S. Suh • ONRR • Gregory Gould • Revenue Collections • BSEE • Brian Salerno • Permits • Inspections • Spill Response • BOEM • Tommy Beaudreau • Leasing • NEPA Analysis • Resource Evaluation • IRU • Investigate Allegations of Misconduct

  4. Deepwater Initial EP Approval Times

  5. Bureau of Ocean Energy (BOEM) • Certain BOEM fees are being adjusted for inflation • Effective Date: February 2, 2013

  6. Bureau of Safety and Environmental Enforcement (BSEE) • Certain BSEE fees are being adjusted for inflation • Effective Date: October 1, 2013

  7. Inspection Fees Beginning 2012 * Per Inspection

  8. Summary of Incidents of Non-Compliance (INCs)

  9. BSEE Top 10 INCs

  10. INC Descriptions

  11. BSEE Oversight10 Yr Comparison of Civil Penalties Prepared by JCC using data from BSEE.gov

  12. Transparent Oversight ISEE Program INCs by Company INCs by Facility Investigation Reports Enforcement Actions including Civil Penalties

  13. Black Elk Incident INCs 41 INCs issued by BSEE to Black Elk and three contractors Black Elk 12 Compass Engineering 9 Wood Group 11 Grand Isle Shipyard 9

  14. Oil Spill Response Plans

  15. 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.

  16. 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.

  17. 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

  18. GOADS Tools • Available on the BOEM GOMR homepage www.boem.gov/Gulfwide-Offshore-Activity-Data-System-GOADS/ • 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.

  19. 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

  20. 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

  21. 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)

  22. Proposed Regulations • BSEE strategy for BAST: • Interagency agreement with DOE National Laboratory System to collaborate on risk-based decision making and applying BAST • If new component, system or procedure is BAST, BSEE will issue regulation, NTL or condition of approval.

  23. Future Regulations • Future Rule to enhance the requirements for BOPs • Pipeline regulations • Decommissioning of offshore facilities

  24. 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

  25. 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

  26. 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

  27. Jodie Connor J. Connor Consulting, Inc. 281.578.3388 Jodie.Connor@jccteam.com

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