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BSEE INC/Civil Penalty Update Gulf Coast Action Team (GCAT) Meeting
Shell Robert Facility
Robert, Louisiana
May 14, 2014
Office of Safety Management (OSM)
2
[email protected] – Chief OSM
[email protected] – Safety and Environmental Management Specialist (SEMS) Regional Coordinator
[email protected] – SEMS / District Incident Reviews / Safety Alerts
[email protected] – SEMS
[email protected] – SEMS District Incident Reviews / Safety Alerts
[email protected] – Annual Performance Review / Performance Improvement Plan (APR/PIP) Regional Coordinator
[email protected] – Civil Penalty Compliance Reviewing Officer (CRO)
[email protected] – CRO
[email protected] – CRO
[email protected] – CRO
[email protected] – Regional Accident Investigator (Panels) / Safety Alerts
[email protected] – 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
3
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. 5
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 0 0 0 0 1
Flow Surface 3 3 2 1 2 4 4
Diverter Flow 0 1 0 0 0 0 3
Surface Equipment Failure
3 3 4 3 1 0 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 0 0 0 1 0 0 0
Major 0 0 0 1 1 2 0
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 outside of deepwater.
Spills > 50 *Barrels
Year 2007 2008 2009 2010 2011 2012 Crude & NGC 1 19 4 2 1 1
*Refined Petroleum
5 0 0 0 0 0
* *Synthetic-Based Fluids
2 2 4 2 2 3
Chemicals 1 12 3 1 0 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
12
0
500
1000
1500
2000
2500
3000
3500
4000
4500
2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
INCs
issu
ed in
GO
MR
Total Production Process Inspection INCs issued vs. Inspections – Production Facilities
Total INCs Inspections
13
0
10000
20000
30000
40000
50000
60000
0
500
1000
1500
2000
2500
3000
3500
4000
4500
2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
PRD
Com
pone
nts I
nspe
cted
INCs
issu
ed in
GO
MR
Total Production Process Equipment INCs issued vs. Components Inspected - Production Facilities
Total INCs PRD_CMPNTS
14
0
500
1000
1500
2000
2500
2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
INCs
issu
ed in
GO
MR
Production Facility INCs by Enforcement Type C S W
15
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
16
0
500
1000
1500
2000
2500
0
50
100
150
200
250
300
350
400
2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
Rig
Insp
ectio
ns in
GO
MR
INCs
issu
ed in
GO
MR
Total INCs & Inspections - Rig Facilities Total INCs Inspections
17
0
50
100
150
200
250
2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
INCs
issu
ed in
GO
MR
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 operable 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 23
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 once every 24-hour period alternating between control stations for surface diverter systems;
25
Top 10 Rig INC Descriptions (Cont’d.)
D425-All classified drilling fluid-handling areas are fitted with gas detectors and alarms except in open 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;
27
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;
29
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 of 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;
30
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 operator/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)
31
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 or ignition sources;
Top 10 Civil Penalty INC Descriptions (Continued)
32
Number of Civil Penalties for Operators and Contractors
0 0 0 0
7
35
27
4239
49
2009 2010 2011 2012 2013
# of CPs Operators and Contractors 2009-13Contractors Operators
33
Civil Penalty Case Status
2009 2010 2011 2012 2013 2014 *Total Cases 35 27 42 38 56 21
Appeals 0 0 2 2 0 0 Review 0 0 1 1 19 18
Notice Sent 0 0 0 2 8 3 Paid & Closed 31 26 36 32 29 0
Other 0 0 2 0 0 0 Dismissed 4 1 1 1 0 0
Total Collected ($MM) $2.18 $1.76 $2.42 $1.32 $1.92 N/A
*Note: Data is based on case year.
34
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 or the environment Violations that are not corrected within the time allowed Violations of the Oil Spill Financial Responsibility Requirements
35
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 or 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.
37
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 oil at a level sufficient to prevent discharge of oil into the offshore 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.
40
[email protected] – Chief
[email protected] – CP Compliance Review Officer
[email protected] – APR/PIP Regional Coordinator
41
THANKS – Questions?
