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GoM Accident and its impact on
Pre-Salt development
Daniel (Danny) Walker
VP Compliance Services
Lloyd’s Register North America Inc.
26th October 2010
Lloyd’s Register services to the energy industry

Terms of reference – MONTARA INCIDENT


                                                   Uncontrolled release of Hydrocarbons from
                                                   the Montara unmanned Wellhead Platform
                                                   – Ashmore Cartier region (Timor Sea) 690
                                                   miles West of Darwin – August 2009


                                                   www.nopsa.gov.au
                                                   Initial Investigation findings: Root Cause
                                                   Analysis
                                                   •Systematic Failure of MANAGEMENT
                                                   SYSTEMS
                                                   •Non-Compliance with Operational
                                                   process’ and procedures
Lloyd’s Register services to the energy industry

Terms of reference – DEEPWATER HORIZON


                                                   Explosion and Fire on MODU “Deepwater
                                                   Horizon” – 60 miles Offshore Louisiana –
                                                   April 2010



                                                   www.boemre.gov
                                                   Initial Investigation findings: POSSIBLE
                                                   Root Causes
                                                   •Equipment Design/Maintenance
                                                   •Operational safety culture
                                                   •Procedures and Process training
                                                   (Competence)
Lloyd’s Register services to the energy industry

Implications for developing Pre-Salt Reserves

                                                   •   Operators


         Media spotlight
         Loss of reputation and Community trust
         Insurance and liability (unlimited liability)
         Cost increases
         Long term viability for smaller companies
         Minimum standards vs best practice
Lloyd’s Register services to the energy industry

WELL INTEGRITY = PRESSURE CONTAINMENT =
BARRIERS




                           30 CFR PART 250 (OCTOBER 14 2010)
Lloyd’s Register services to the energy industry

30 CFR Part 250 – Immediate mandatory changes to
the Prescriptive requirements in the GoM

                                                   The Primary purpose of this interim final rule is to clarify and
                                                   incorporate safeguards that will decrease the likelihood of a
                                                   blowout during drilling operations on the Ouetr Continental Shelf
                                                   (OCS)


                                                   The interim final rule implements certain safety measures
                                                   recommended in the report entitled “Increased Safety Measures
                                                   for Energy Development on the OCS” dated May 27 2010.
                                                   The Rule becomes effective October 14 2010
                                                   Additionally, please refer to the following BOEMRE Factsheets:

                                                   The Workplace Safety Rule on Safety and
                                                   Environmental Management Systems (SEMS)

                                                   The Drilling Safety Rule
Lloyd’s Register services to the energy industry

 The safeguards address well bore integrity and well control
 equipment

1. Establish new casing installation requirements
2. Establish new cementing requirements (Incorporate API RP 65 – Part 2, Isolating Potential Flow
   Zones During Well Construction)
3. Require independent third party verification of blind-shear ram capability
4. Require independent third party verification of subsea BOP stack capability
5. Require new casing and cementing integrity tests
6. Establish new requirements for subsea secondary BOP intervention
7. Require function testing for subsea secondary BOP intervention
8. Require documentation for BOP inspections and maintenance
9. Require a Registered Professional Engineer to certify casing and cementing requirements, and
10. Establish new requirements for specific well control training to include deepwater operations
Lloyd’s Register services to the energy industry

Implications for developing Pre-Salt Reserves

                                                   •   REGULATORS


         Independence of safety regulator
         Prescriptive or Performance based regulatory environment (or a
          combination of both)
         International Regulation (IMO)
         Competence
Lloyd’s Register services to the energy industry

Implications for developing Pre-Salt Reserves

                          •   Materials Management Service (MMS) Reorganization


•   Bureau of Ocean Energy Management: A new bureau under the supervision of the Assistant
    Secretary for Land and Minerals Management that will be responsible for the sustainable
    development of OCS conventional and renewable energy resources, including resource
    evaluation, planning, and other activities related to leasing.


•   Bureau of Safety and Environmental Enforcement: A bureau under the supervision of the
    Assistant Secretary for Land and Minerals Management that will be responsible for
    ensuring comprehensive oversight, safety, and environmental protection in all offshore
    energy activities.


•   Office of Natural Resources Revenue: An office under the supervision of the Assistant
    Secretary for Policy, Management and Budget that will be responsible for the royalty and
    revenue management function including the collection and distribution of revenue, auditing
    and compliance, and asset management.
Lloyd’s Register services to the energy industry


The safe operation of a facility is the responsibility of the facility
operator
The primary responsibility for ensuring health and safety lies
with those who create risks and those who work with them

1. What is the role of the regulator in all of this
2. Use the identification and mitigation of Risk AS a minimum standard
3. Meeting Regulatory requirements is NOT a minimum standard
4. Compliance with prescriptive regulation is ONLY a compliance issue
5. To what extent are regulations responsible for setting the threshold for safety
6. Are you doing enough to ensure safety
7. Are you doing what you have indicated you would do
8. What level of enforcement is required
9. Is there a minimum threshold required for operator competence
Lloyd’s Register services to the energy industry


Objective/Performance based (or goal setting) regimes, (including the UK safety case regime), are based on
the principle that the legislation sets the broad safety goals to be attained and the operator of the facility
develops the most appropriate methods of achieving those goals. A basic assumption is the premise that the
ongoing management of safety is the responsibility of the operator and not the regulator.



Any goal setting is not just minimum requirement, it is the basis
of a mature & continuously improving safety culture wihin an
organization.
                                      Accidents and Dangerous Occurences 2008 - 2009                                  Root Causes Deck and Drilling Lifting MajorInjuries 2007-2009 (UK Offshore
                                                                                                                                                        Sector)

      Preventitive maintenance

                                                                                                                                                     Other



                                 Procedures Not Followed                                                                                                               Supervision
                                                                                                                                      Planning
                                                       Design Specifications   Design Review
                                                                                               Incorrect Procedures




                                                                                                                                  Risk Assessment
                                                                                                                                                                 Hazard Awareness




                   UK Offshore (HSE figures)                                                                           Australia Offshore (NOPSA Figures)
Lloyd’s Register services to the energy industry

 For more information please visit: www.lrenergy.org




Danny Walker
VP Compliance Services
LRNA Inc


Danny.Walker@lr.org
+1 281 675 3119

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Gulf of Mexico Accident and its impact on Pre-Salt development

  • 1. Lloyd’s Register services to the energy industry GoM Accident and its impact on Pre-Salt development Daniel (Danny) Walker VP Compliance Services Lloyd’s Register North America Inc. 26th October 2010
  • 2. Lloyd’s Register services to the energy industry Terms of reference – MONTARA INCIDENT Uncontrolled release of Hydrocarbons from the Montara unmanned Wellhead Platform – Ashmore Cartier region (Timor Sea) 690 miles West of Darwin – August 2009 www.nopsa.gov.au Initial Investigation findings: Root Cause Analysis •Systematic Failure of MANAGEMENT SYSTEMS •Non-Compliance with Operational process’ and procedures
  • 3. Lloyd’s Register services to the energy industry Terms of reference – DEEPWATER HORIZON Explosion and Fire on MODU “Deepwater Horizon” – 60 miles Offshore Louisiana – April 2010 www.boemre.gov Initial Investigation findings: POSSIBLE Root Causes •Equipment Design/Maintenance •Operational safety culture •Procedures and Process training (Competence)
  • 4. Lloyd’s Register services to the energy industry Implications for developing Pre-Salt Reserves • Operators  Media spotlight  Loss of reputation and Community trust  Insurance and liability (unlimited liability)  Cost increases  Long term viability for smaller companies  Minimum standards vs best practice
  • 5. Lloyd’s Register services to the energy industry WELL INTEGRITY = PRESSURE CONTAINMENT = BARRIERS 30 CFR PART 250 (OCTOBER 14 2010)
  • 6. Lloyd’s Register services to the energy industry 30 CFR Part 250 – Immediate mandatory changes to the Prescriptive requirements in the GoM The Primary purpose of this interim final rule is to clarify and incorporate safeguards that will decrease the likelihood of a blowout during drilling operations on the Ouetr Continental Shelf (OCS) The interim final rule implements certain safety measures recommended in the report entitled “Increased Safety Measures for Energy Development on the OCS” dated May 27 2010. The Rule becomes effective October 14 2010 Additionally, please refer to the following BOEMRE Factsheets: The Workplace Safety Rule on Safety and Environmental Management Systems (SEMS) The Drilling Safety Rule
  • 7. Lloyd’s Register services to the energy industry The safeguards address well bore integrity and well control equipment 1. Establish new casing installation requirements 2. Establish new cementing requirements (Incorporate API RP 65 – Part 2, Isolating Potential Flow Zones During Well Construction) 3. Require independent third party verification of blind-shear ram capability 4. Require independent third party verification of subsea BOP stack capability 5. Require new casing and cementing integrity tests 6. Establish new requirements for subsea secondary BOP intervention 7. Require function testing for subsea secondary BOP intervention 8. Require documentation for BOP inspections and maintenance 9. Require a Registered Professional Engineer to certify casing and cementing requirements, and 10. Establish new requirements for specific well control training to include deepwater operations
  • 8. Lloyd’s Register services to the energy industry Implications for developing Pre-Salt Reserves • REGULATORS  Independence of safety regulator  Prescriptive or Performance based regulatory environment (or a combination of both)  International Regulation (IMO)  Competence
  • 9. Lloyd’s Register services to the energy industry Implications for developing Pre-Salt Reserves • Materials Management Service (MMS) Reorganization • Bureau of Ocean Energy Management: A new bureau under the supervision of the Assistant Secretary for Land and Minerals Management that will be responsible for the sustainable development of OCS conventional and renewable energy resources, including resource evaluation, planning, and other activities related to leasing. • Bureau of Safety and Environmental Enforcement: A bureau under the supervision of the Assistant Secretary for Land and Minerals Management that will be responsible for ensuring comprehensive oversight, safety, and environmental protection in all offshore energy activities. • Office of Natural Resources Revenue: An office under the supervision of the Assistant Secretary for Policy, Management and Budget that will be responsible for the royalty and revenue management function including the collection and distribution of revenue, auditing and compliance, and asset management.
  • 10. Lloyd’s Register services to the energy industry The safe operation of a facility is the responsibility of the facility operator The primary responsibility for ensuring health and safety lies with those who create risks and those who work with them 1. What is the role of the regulator in all of this 2. Use the identification and mitigation of Risk AS a minimum standard 3. Meeting Regulatory requirements is NOT a minimum standard 4. Compliance with prescriptive regulation is ONLY a compliance issue 5. To what extent are regulations responsible for setting the threshold for safety 6. Are you doing enough to ensure safety 7. Are you doing what you have indicated you would do 8. What level of enforcement is required 9. Is there a minimum threshold required for operator competence
  • 11. Lloyd’s Register services to the energy industry Objective/Performance based (or goal setting) regimes, (including the UK safety case regime), are based on the principle that the legislation sets the broad safety goals to be attained and the operator of the facility develops the most appropriate methods of achieving those goals. A basic assumption is the premise that the ongoing management of safety is the responsibility of the operator and not the regulator. Any goal setting is not just minimum requirement, it is the basis of a mature & continuously improving safety culture wihin an organization. Accidents and Dangerous Occurences 2008 - 2009 Root Causes Deck and Drilling Lifting MajorInjuries 2007-2009 (UK Offshore Sector) Preventitive maintenance Other Procedures Not Followed Supervision Planning Design Specifications Design Review Incorrect Procedures Risk Assessment Hazard Awareness UK Offshore (HSE figures) Australia Offshore (NOPSA Figures)
  • 12. Lloyd’s Register services to the energy industry For more information please visit: www.lrenergy.org Danny Walker VP Compliance Services LRNA Inc Danny.Walker@lr.org +1 281 675 3119