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The oil and natural gas industry continues to cooperate fully with the Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMRE) and the independent presidential commission as they consider the Gulf oil spill and potential changes in industry oversight. We have formed four joint industry task forces to examine various issues related to deepwater drilling, from offshore equipment and offshore operating procedures to subsea well control and oil spill response capabilities. The goals of these task forces are clear—to identify and learn from any gaps in operations or practices that would affect safety; seek options to address gaps through recommended practices, procedures, and research and development; and ultimately improve the industry’s capabilities in safety, environmental performance and spill prevention and response. In the last 60 years, our industry has safely drilled more than 42,000 wells, including 2,000 deepwater wells, in the Gulf without a major incident. The recommendations from these task forces, combined with the continued cooperation of government agencies and other stakeholders, should help ensure a similarly strong industry record for the next 60 years and beyond. On Sept.7, 2010, the industry released the preliminary findings of two of the four task forces: a Subsea Well Control and Containment task force to review technologies and practices for controlling the release of oil from its source, and an Oil Spill Response task force to review existing spill response processes and technologies. Recommendations from the other two task forces, covering industry operations and practices, were provided to the Department of the Interior on May 17, 2010. The Subsea task force is reviewing technologies and practices for controlling the release of oil from its source, including equipment designs, testing protocols, research and development, regulations and documentation. The Subsea task force has identified five key areas of focus for Gulf of Mexico deepwater operations: well containment at the seafloor; intervention within the subsea well; subsea collection and surface processing and storage; relief wells; and continuing research and development. The Subsea task force has developed 29 recommendations on specific steps to enhance the industry’s well control and containment capability, including 15 immediate action items: 1. Establish coordinated industry capability for owning and providing subsea well containment technology and capability through a Containment Company (CC). The CC will be responsible for building and deploying a rapid response system that will be able to capture and contain oil in the event of a potential future underwater well blowout in the deepwater Gulf. The CC will deliver a flexible, adaptable and rapidly deployable tool kit of containment equipment designed and constructed for rapid subsea containment; procure, construct, and test the needed equipment; and research improved methods and equipment for subsea well control and containment.
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2. Ensure that a lower marine riser package (LMRP) can be removed from lower blowout preventer (BOP) using a surface intervention vessel and remotely operated vehicle. This will allow access to the mandrel on top of the BOP and the installation of subsea containment assembly. 3. Ensure effective methods to release LMRP without riser tension. 4. Remove damaged or non-functioning BOP stack to allow installation of a new BOP on the wellhead housing, or the subsea containment assembly (Note: this capability is available now). 5. Regain full control of BOP stack by pulling and repairing the LMRP/pods and rerunning the LMRP (Note: this can be done now). Research and develop ways to regain control over all important BOP functions in the case where the LMRP is damaged and cannot be removed and in cases where the LMRP is removed but cannot be repaired and re-run. 6. Have CC acquire and maintain a full set of crossover spools, connectors and hub combinations. 7. Have CC design and construct subsea connectors to fully seal, connect and contain damaged connector profiles and casing stubs. Casing stubs will use BOP ram technology for connection and sealing. 8. Coordinate with the Equipment Task Force to ensure methods and equipment are providing effectiveness and reliability in delivery of control fluids and control to BOPs and ROVs. 9. Coordinate with API RP 96 workgroup to ensure deepwater well design includes a system evaluation of the design and material for subsea well head support and the release control methodology of the LMRP. 10. Coordinate further with API RP 96 workgroup to ensure they incorporate the importance of full shut-in capability into the containment capabilities. 11. Have CC deliver a modular solution for capturing, processing and transporting production from subsea wells that need to be produced until well control is complete. This system will be adaptable to water depths up to 10,000 feet and include freestanding production risers to move production to the surface away from the area of the well. 12. Develop a historical document of marine well control and containment. 13. Via focused workshops, determine and make a recommendation on the most effective methods and information that should be included in well plans regarding relief well drilling planning. 14. Undertake desk research to revisit published work on relief wells. 15. Develop a white paper on the feasibility and desirability of pre-drilling relief wells (Note: this task is complete).
The Oil Spill Response Task Force has produced an assessment of the industry’s entire spill response system and identified areas for improvement and additional research. In particular, it has made specific suggestions to improve the speed with which spill response can be ramped up, improvements in spill response plan content and structure, the role of federal and state regulatory agencies and improved training and exercises for large spill events. In the course of its deliberations concerning the state of our overall oil spill response capability, the task force has examined a number of broad topical issues, including oil spill response plans, dispersant use, in situ burning and shoreline protection and clean up. In the end, we developed recommendations for 15 near-term actions that would be initiated on or before April 1, 2011, and a number of long-term actions that would be initiated on or before Oct. 1, 2011. They include the following: 1. Review lessons learned and develop additional recommendations from other reports and, if necessary, reconcile those into our recommendations. 2. API will initiate the development of an API Recommended Practice on Oil Spill Response Planning. 3. Industry will initiate contact with federal agencies to investigate increased mechanical recovery as well the use of dispersants and in-situ burn capability in the Gulf of Mexico. 4. Industry will work with appropriate agencies to review and evaluate existing Effective Daily Recovery Capacity calculations. 5. Industry will convene a meeting among industry partners to initiate the development of an agreement for providing trained company personnel with expertise in specific areas of oil spill response to a Responsible Party in the event of a federally declared Spill of National Significance (SONS) level incident. 6. Industry will meet with major response co-ops to initiate the development of a preapproval agreement or process that facilitates identification, availability and commitment of necessary resources to be made available to any Responsible Party in the event of a federally declared SONS incident—without delay. 7. Industry will meet with appropriate federal and state agencies to initiate the development of a policy statement and possible Memorandum of Understanding to facilitate the cascading of resources and establish an alternative means of compliance for the “donor” areas, including waiving U.S. oil spill liability exposure and pre-emption of state requirements in the event of a SONS level incident. 8. Industry will continue to support the ongoing efforts by API and the Society of Petroleum Engineers in the development of a standard or recommended practice for calculating worst case and/or most likely discharge rates for loss of well control incidents. 9. To improve understanding regarding dispersants, industry will develop a series of simple fact sheets and/or other communications addressing various aspects of dispersants and review them with appropriate Government Agencies for concurrence. 10. A panel of experts will be chartered to review data collection efforts as part of a spill impact assessment and evaluations of ecological recovery rates for offshore, near shore, coastal and estuarine areas impacted by spills.
11. API will begin development of an API Recommended Practice on Personal Protection Equipment for Oil Spill Response Workers. 12. Industry will initiate communication with the National Response Team (NRT) to encourage publication of the Federal Volunteer Guidelines as soon as possible. 13. Industry will have in place a Source Control Branch identified in their Oil Spill Response Plans. 14. Industry will develop a summary of how subsea injection was utilized during the Deepwater Horizon response. 15. Industry will develop a program for modeling and scaled testing of subsea dispersant injection to develop implementation criteria. 16. Industry will investigate whether non-solvent based dispersants can be used effectively with this application mode due to rapid and uniform testing. 17. Industry will work in conjunction with the Marine Well Containment Task Force to develop more efficient methods of applying the dispersants. 18. Industry will conduct a review of surface application techniques and protocols to further safeguard response personnel while allowing for operational efficiency. It is the industry’s intent to begin discussions with other stakeholders on these recommendations as soon as possible. While industry has already taken steps to address many of these issues, it will be important for government and other stakeholders to work together to identify priorities for future improvements and develop necessary cooperative mechanisms. The ideas presented are offered as a first step in that process. Many, if not most, of our recommendations will require the active participation and support of other stakeholders, and building those relationships is an immediate priority. Recommendations from all four task forces already have helped improve the industry's safety and operations standards. This is vital, since offshore drilling in the Gulf of Mexico plays a critical role in meeting America’s growing demand for energy.
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