IADC Environmental Conference and Exhibition, Trinidad and Tobago 12-13 May, 2011

Deepwater Oil Exploration Drilling Safety: The Cuban Regulatory Approach

Fidel Ilizastigui PerezProcess Safety/Risk Management Specialist

Office of Environment and Nuclear Safety Regulation (ORASEN)Technical Support Division

2011

Panel discussion: One Gulf - Drilling Offshore Cuba

The Evolution Deepwater Oil Drilling Safety Regulation in Cuba: Lessons learned

• Before Yamagua Well (2002 – 2004)• After Yamagua Well (2005 – 2010)• After Macondo (2010 - present time)

IADC Environmental Conference and Exhibition, Trinidad and Tobago 12-13 May, 2011

Before Yamagua Well (2002 – 2003)The preparatory stage

Mature regulatory regimes

Self-regulationPrescriptive

• What is the challenge?• What regulatory strategy

to adopt?• How to make it work?

IADC Environmental Conference and Exhibition, Trinidad and Tobago 12-13 May, 2011

The Big Challenge:“To protect people and the environment by preventing major

(organizational) accidents from occurring” (i.e from events that occur 1/decades!!!)

Safety Case approach to Regulation: UK Safety Case Regulations (SCR) 1992

IADC Environmental Conference and Exhibition, Trinidad and Tobago 12-13 May, 2011

Type of regulatory strategy

Influence on Safety Culture

Prescriptive Poor

Outcome-based Regular

Process-based Good

The Safety Case regime

• Major Accident Hazards (MAHs) are identified

• Risks have been evaluated and measures have been taken to reduce the risks levels to ALARP.

• There is an adequate SMS for process safety/integrity

• Adequate arrangements exist for audit of the SMS

• Compliance with national/international regulations

The Operator must demonstrate to ORASEN, that:

IADC Environmental Conference and Exhibition, Trinidad and Tobago 12-13 May, 2011

Yamagua -1 Exploratory Drilling2004

• Regulatory Guidance issued by ORASEN “Guidelines forpreparation of Risk Evaluation Report (RER) for Offshoreoil drilling facilities” – 2002 (now superseded).

• Environmental Licence issued by ORASEN for deepwaterdrilling:

Risk Evaluation Report (RER)Safety Evaluation Report (SER)Licence conditions for deepwater drilling operationsRegulatory inspection to the drilling facility

IADC Environmental Conference and Exhibition, Trinidad and Tobago 12-13 May, 2011

After Yamagua – 1: 2005-2010Adoption of international best practices and modernization

of Facility Safety Cases

2009

2004

IADC Environmental Conference and Exhibition, Trinidad and Tobago 12-13 May, 2011

Strengthening the Safety Case regime for major hazard facilities in Cuba - 2009

• CITMA Resolution 132/2009 “Rules for EnvironmentalImpact Assessment Process”

Updates previous rules and introduces Safety Cases for MajorHazard Facilities in support of Environmental Licenceapplications for all MHFs for the commencing of operation.

• ORASEN Resolution 31/2009 “Guidance for preparation of Safety Cases for drilling facilities for offshore oil and gas exploratory wells”

Establishes new requirements for Safety Cases according toIADC HSE Case guidelines (version 3.2).

IADC Environmental Conference and Exhibition, Trinidad and Tobago 12-13 May, 2011

“Modernization” of Safety Cases

• ORASEN “encourages” the use of Bow-Tie RiskManagement Methodology as part of the SafetyCase process:

Increasing the value of the Safety Case for SC“owners” - i.e managers and workers.Ensuring SC remains a “Living document”.Allowing better regulatory oversight.

IADC Environmental Conference and Exhibition, Trinidad and Tobago 12-13 May, 2011

“Modern” Safety Cases reviewed by ORASEN

• Bow –Ties for all MAHs

• SOOB Matrix (MOPO)

• Safety Critical Elements (SCEs)

• Performance Standards (PS)

IADC Environmental Conference and Exhibition, Trinidad and Tobago 12-13 May, 2011

• CITMA Resolution 73/2010 “The Safety Case Addendum”Introduces the Safety Case Addendum for Well Integrity issues;following US Well Construction Interfacing Document (WCID)recommendations.

• CITMA resolution (scheduled for 2011): “Safety CaseRegulation for Major Hazard Facilities” which avoidspiecemeal implementation.

Delineates all the features of the Safety Case regulatory regime“from cradle to grave”.

After Macondo: 2010-?Well Integrity, Emergency Response, Safety Culture Oversight

IADC Environmental Conference and Exhibition, Trinidad and Tobago 12-13 May, 2011

• Part 1. Drillsite location and Well Basis of Design (BOD).Bow-Tie Risk Assessment and Management for Well Major Hazards

• Part 2. DC Safety Case and (Well) Operator interfacingarrangements

Bridging Document (BD)• Part 3. Action Plan and justification for commencing of

drilling operationsAssess compliance with US Interim Drilling Safety Rule

The Safety Case Addendum (SCA)

US Well Construction Interfacing

Document (WCID)

IADC Environmental Conference and Exhibition, Trinidad and Tobago 12-13 May, 2011

Environmental Licence for deepwater exploratory drilling operations in EEZ in the

GOM

• Environmental Impact Study (EIS)

• Facility Safety Case (SC)

• Safety Case Addendum (SCA)

IADC Environmental Conference and Exhibition, Trinidad and Tobago 12-13 May, 2011

+

• Disaster Reduction Plan (DRP) – Civil Defense

Regulatory Pyramid

IADC Environmental Conference and Exhibition, Trinidad and Tobago 12-13 May, 2011

LAW 81(1999)

CITMA ResolutionNo. 132/2009

ORASEN Resolution No. 31/2009

ORASEN Resolution No. 73/2010

National / International Safety StandardsIMO, ISO, API

A consistent, sound and state-of-the-art regulatory framework for deepwater drilling

safety

• One Gulf means for us:– One COMMON interest: To protect people and

the environment while conducting deepwaterdrilling operations in the GOM.

– One COMMON challenge: To prevent majoraccidents from occurring and limiting theirconsequences should they occur.

– One COMMON solution: To set up a consistent,sound and state of the art regulatory frameworkaddressing Safety Culture aspects.

IADC Environmental Conference and Exhibition, Trinidad and Tobago 12-13 May, 2011

IADC Environmental Conference and Exhibition, Trinidad and Tobago 12-13 May, 2011

THANK YOU FOR YOUR ATTENTION