The Interior Department's Bureau of Ocean Energy Management, Regulation and Enforcement (BOEM) Monday issued additional guidance to address questions posed by the new regulations that were imposed on producers following the Macondo well blowout and sinking of the Deepwater Horizon rig in the Gulf of Mexico (GOM) earlier this year (see Daily GPI, April 22).
The guidance presents a clear path to move forward with the resumption of work in the GOM deepwater, which virtually has been closed to producers since the fatal incident in April. The guidance contains no new or additional regulatory requirements, but instead provides additional information to assist the oil and natural gas industry in its efforts to comply with rules and prior guidance issued by the BOEM, the agency said.
"As we continue to strengthen oversight and safety and environmental protections, we must ensure that the oil and gas industry has clear direction on what is expected," said BOEM Director Michael R. Bromwich.
The new regulations require operators to submit worst-case discharge (WCD) calculations to the agency. To ensure that operators understand the process, BOEM staff is available to meet with individual operators to discuss their WCD calculations that determine the daily volume potential resulting from an uncontrolled blowout, according to the agency. In this area, "we have found a high level of compliance among operators who have met with BOEM staff to discuss WCD calculations," the agency said.
BOEM further said that if an operator's original drilling permit "has demonstrated that it has access to and can deploy containment resources that would be adequate to properly respond to a blowout or other loss of well control," it does not have to re-address this for the same operation "unless any of the elements of the operator's available containment resources has changed."
With respect to oil spill response plans (OSRP), BOEM's regional supervisor may require an operator to revise its OSRP if significant deficiencies are indicated during periodic reviews, or during drills or actual spill responses. In the event that a BOEM supervisor requires an operator to revise its OSRP, the operator may continue to operate for up to two years while BOEM reviews the revised plan if the operator can certify that it has contracted with private personnel and has the necessary equipment available to respond to a discharge.
The primary deficiency that BOEM has identified in its review of OSRPs is the lack of sufficient subsea containment equipment and other resources, the agency said. To address this deficiency, an operator should submit information demonstrating that it has access to and can deploy containment resources that would be adequate to properly respond to a blowout or other loss of well control.
Operators are not required at this time to amend their OSRPs to include additional subsea containment information, but they may do so voluntarily, according to the BOEM.
Operators are expected to notify the BOEM at least 72 hours prior to all blowout preventer (BOP) stump tests and initial BOP tests on the sea floor so a BOEM representative can witness at least one of these tests, the agency said. If the BOEM receives appropriate notice and is unable to attend the test, the operator may proceed with the test. However, in cases in which BOEM does not witness a BOP stump test or initial sea floor test, the operator must provide the result of the test to BOEM with 72 hours.
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