US Minerals Management Service inspectors conduct field inspections of offshore drilling rigs and production platforms 7 days a week in the Gulf of Mexico, off California, and off Alaska.
The Gulf of Mexico MMS region is responsible for the most inspections. In the gulf, 55 inspectors go offshore every day using 14 leased helicopters.
The Outer Continental Shelf Lands Act charges the MMS with the responsibility of ensuring all oil and gas companies conduct offshore operations in a safe and pollution-free manner.
One of the first things an inspector notices is the housekeeping, Mike Saucier, MMS regional supervisor of field operations for the Gulf of Mexico, told OGJ in a telephone interview from his New Orleans office.
"It's amazing, but housekeeping is a key indicator," Saucier said. "If everything is neat and orderly, then the rest of the inspection usually goes really well."
Inspectors report that another key indicator is the level of supervision that oil companies provide their employees. Top performing companies tend to provide a lot of personnel oversight and training, he said.
Saucier notes that the hurricanes of past years did not make any difference in MMS inspection procedures.
"As we see different trends that occur in the gulf, maybe due to pollution issues, maybe due to safety issues, the regulations can be revised," Saucier said. "As far as issues that would require regulatory revision, we don't see anything at this point."
Crane inspections
Recently, a special MMS task force conducted numerous inspections of offshore cranes because of an increasing number of lifting incidents involving primarily cargo but also some personnel lifting accidents.
"It looked like the incident of crane accidents were up so we did a blitz inspection, and the results came out pretty favorable. I don't see that we are going to revise any regulations," Saucier said. "Of course, we are going to keep looking at the cranes as we always do." Crane inspections are part of the annual inspection process.
MMS statistics show a total of 2,724 safety incidents reported during 2005-08 on the OCS, of which 506 incidents involved lifting operations. These statistics were outlined in Houston during an Offshore Safe Lifting Conference sponsored by the American Petroleum Institute in June (OGJ, Aug. 10, 2009, p. 33).
ExxonMobil Corp.'s Hoover Diana platform won the 2008 MMS Gulf of Mexico Region's Lake Jackson District Safety Award for Excellent in the high-production category. Photo from ExxonMobil.
Joe Levine, senior engineer with the MMS office in Herndon, Va., reviewed statistics based upon reports that industry makes to MMS. Out of 506 lifting-related accidents, 351 happened during production operations and 155 happened during drilling operations.
During 2005-08, four fatalities resulted from lifting operations of which two involved cranes and two involved other lifting devices such as hoists, tuggers, winches, or come-a-longs.
Of the 506 lifting incidents, two-thirds involved operations in less than 1,000 ft of water. Levine also noted that one-third of the incidents happened on 2% of the infrastructure.
Timing of inspections
Under the OCS Lands Act authorization, MMS conducts at least one annual announced inspection for each of the 3,700 production platforms in the gulf.
"At any point, we can drop by unannounced," Saucier said. "We can be flying offshore, and if we think we need to stop at a particular facility, we can do that."
Although the drilling rig number varies daily, Saucier reported 81 drilling rigs were in the gulf in late September. Each drilling rig is inspected at least once a month while it is drilling.
Drilling inspections are not announced in advance. A typical drilling inspection takes about 3 hr.
Production inspections vary depending upon the type of platform. Inspection of a single-well structure can be completed in 30 min while a major deepwater production platform can take 3-5 days. Depending upon the remoteness of the platform, an inspector may decide to stay on the platform rather than fly back and forth daily.
"We rotate inspectors between the drilling and production so that all inspectors can do any type of inspection," Saucier said.
The total number of MMS inspections in the gulf for 2008 was 24,895. Saucier said this number is so large because inspectors visiting a production platform will conduct several categories of inspections.
Among the major categories of inspections done last year, Saucier reported 665 drilling inspections, 3,458 production inspections, 342 workover and completion inspections, 4,468 pipeline inspections, and 6,941 royalty meter inspections.
MMS also inspects stockpiles of industry's equipment to contain and clean oil spills.
"Industry is doing a good job on maintaining the oil spill response equipment," Saucier said, adding MMS inspects skimming equipment and booms annually.
Operators must keep available all equipment listed in their oil spill response plan. They must keep the equipment operational ready and also keep records of any equipment maintenance.
"This equipment is located at various locations across the gulf from Panama City, Fla., all the way to Corpus Christi, Tex.," Saucier said. "From our inspection program and monitoring, we are very confident that the equipment is there ready to be used when needed."
Before the Sept. 11, 2001, terrorist attacks on the US, the US Coast Guard was responsible for platform and rig inspections involving safety equipment for personnel such as life jackets, life rings, life floats, and escape capsules.
Since the USCG has become more involved in homeland security, MMS has taken over inspections on bottom-supported fixed production platforms. If MMS inspectors see any issue with personnel safety equipment, then they report it to the USCG.
"We are out there anyway doing our annual inspections," Saucier said. "It adds a little more time, but we go ahead and do those inspections for Coast Guard."
Operators' responsibilities
MMS inspectors meet with representatives of both an oil company and also the drilling contractor involved.
"When we do an inspection, anything that we find that may need correcting, it is the responsibility of the operator of the lease," Saucier said. "The operator is working with the drilling rig contractor, who is there also, so MMS really talks to both parties."
In about February 2010, MMS plans to schedule individual annual performance reviews with some of the 120 operators in the gulf. Generally, MMS meets with operators that are performing below the industry average and a few operators performing above the industry average.
"We'll go over their statistics for 2009," Saucier said. "We meet with the ones who could improve, and we meet with the ones doing very well. It helps us determine what is working and what is not."
In addition to the annual review, MMS meets with operators throughout the year and on a weekly basis. MMS might initiate such a meeting if an operator is having trouble with something related to inspections.
Operators also can initiate a meeting with the MMS if for example they want to discuss compliance or new technology that they would like to use, he said.
Inspection process
For completion inspections, MMS inspectors use a four-step process:
- Review operator records to verify completion of all required operator-performed inspections, tests, and training since the last complete MMS inspection.
- Visually inspect all safety and pollution-prevention devices.
- Test or demonstrate the operation of critical safety and pollution-prevention devices to ensure proper installation and operation as well as to witness critical pressure and operational tests.
- Inspect for operational safety throughout the facility, looking for unsafe conditions, spills, leaks, and environmental effects.
Partial inspections also are done with inspectors reviewing randomly selected records and randomly selected devices.
Each year, MMS presents the Safety Award for Excellence (SAFE) Program to recognize companies going above and beyond inspection requirements on both district and national levels.
The 2009 National SAFE Award went to Devon Energy Production Co., primarily in recognition of what one regulator called an "almost unprecedented" period without a lost-time accident.
Devon has gone 5 years without an accident that caused an employee to lose work time. In addition, Devon had good drilling performance with no incidents of noncompliance out of 13 wells drilled.
Bud Danenberger, who heads the MMS Office of Regulatory Programs, said Devon had the best operator safety index number.
The safety index is a formula that measures compliance on numerous aspects of offshore drilling rig and production platform operations. The index measures accidents and inspection violations by their severity. In 2008, MMS inspected 1,012 safety components on 98 Devon complexes in the gulf.
Tony Vaughn, senior vice-president for Devon's Offshore Division, said the accident-free record demonstrates the company's commitment to safety.
"More important than the recognition itself, however, are the daily actions that led to this recognition," Vaughn said of the SAFE award. "Day in and day out, our employees and our contractors demonstrate their commitment not only to safety, but to regulatory compliance and environmental protection."
ExxonMobil Corp.'s Hoover-Diana platform received the 2008 Lake Jackson District SAFE in the high-production category and also was named a national finalist for the 2009 SAFE award in OCS high-activity category.
Gary Walz, ExxonMobil US production operations manager for the gulf, said operating safely—in an environmentally sound manner and in strict compliance with regulatory requirements—is a business fundamental.
"It's part of our commitment to corporate citizenship wherever we're operating that we strive to implement our global safety and environmental programs, 'No One Gets Hurt' and 'Protect Tomorrow. Today.'"
ExxonMobil has internally audited management systems that guide its Operations Integrity Management System. Walz said this provides strong management processes and helps the company adhere to all applicable laws and regulations.
"Operation of facilities within established parameters and according to regulations is essential," Walz said. "Applicable laws, regulations, permits, and other governmental requirements are met, and the resulting operating requirements are documented and communicated to those affected. Compliance is periodically verified."
He noted this practice ensures a good working relationship with offshore regulators.
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