BOEMRE’s New Regulatory Approach to Environmental and Safety Systems Management
Table 2: A Comparative Perspective of a Traditional Environmental Management System and the New Safety and Environmental Management System
17 Elements of a Traditional EMS Environmental policy
Environmental aspects and impacts Legal and other requirements Objectives and targets
Environmental management programmes Structure and responsibility
Training: awareness and competence Communication
EMS documentation
Document control Operational control
13 Elements of a BOEMRE SEMS (API’s RP 75)
General provisions Hazards analysis
Safety and environmental information Operating procedures Management of change Mechanical integrity Training
Safe work practices Records and documentation Pre-startup review
Monitoring and measurement Emergency preparedness and response Emergency response and control Nonconformance, corrective and
Investigation of accidents
preventative action Records
EMS audit Management review
API = American Petroleum Institute; BOEMRE = Bureau of Ocean Energy Management, Regulation, and Enforcement; EMS = environmental management system; RP = recommended practice; SEMS = safety and environmental management system.
Records and documentation Auditing the programme
ROV capabilities before deployment of the BOP to the sea floor. Independent verification must be provided to show that the blind-shear rams of the BOP are capable of shearing the drill pipe under any foreseeable conditions. If it is necessary to activate the blind shear rams in a well control situation then the BOP must be inspected to ensure that it remains serviceable.
resources will be available promptly in event of a blowout. The DOI has a process underway regarding establishment of a mechanism relating to availability of blowout containment resources.
The Safety NTL requires CEO certification that the operator is knowledgeable with respect to oil, gas and sulphur operations in the OCS in accordance with 30 Code of Federal Regulation (CFR) 250 and that operations will be conducted in compliance with pertinent regulations. An operations safety review to assure safe performance is required by 30 CFR 250.107(a)(1).
Some of the more detailed requirements of the NTL include submission of the BOP and well control system configuration information specific to the drilling rig that will be used. A detailed third party design review,
One cornerstone of the new regulations stipulates that the CEO of each operator seeking to perform drilling must certify that the operator has complied with all regulations.
an inspection to verify the physical characteristics of the BOP and the specific well design and certification of the compatibility of the BOP with the drilling rig are required. BOEMRE plans to inspect each deepwater drilling operation for compliance and will participate in the testing of BOPs.
Other requirements of the Safety NTL include a secondary control system and remotely operated vehicle (ROV) intervention capabilities for the BOP and any other emergency shut-in system. The BOP mechanisms must be tested for compatibility and functionality with the
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The Environmental NTL requires operators to develop Exploration Plans (EP), Development Operations Coordination Documents (DOCD) and/or supplements to previously submitted plans that include a blowout scenario, as established in 30 CFR 250.213(g) and 250.243(h). The blowout scenarios must provide assumptions and calculations showing that the Oil Spill Response Plan (OSRP) and its referenced resources are adequate to control the calculated worst-case daily discharge rates. All enhancements to prevent a blowout and methods to assure prompt intervention in the event of a blowout should be identified in the plans. Details of the Environmental NTL (2010-N06) requirements are available at:
www.gomr.boemre.gov/homepg/regulate/regs/ntls/2010NTLs/10-n06.pdf The Drilling Safety Rule incorporates many of the requirements contained in the Safety NTL. These NTLs require compliance with API Recommended Practices 65 covering the isolation of potential flow zones during well construction. This rule requires that a description of the best well-specific practices of the operator is written and that the plans identify mechanical barriers, describe the cementing plan and include schematic drawings of all control systems and control pods. Tests must include a negative pressure test to ensure proper casing installation, evaluation of the rams on BOPs, assure compatibility if ROV intervention is required and must provide a reliable ‘deadman’ system in case well connections are lost. Personnel requirements for BOP equipment operations must also be established. A chronological listing of the NTL requirements published since 1998 are available from:
www.gomr.boemre.gov/homepg/regulate/regs/ntls/ntl_lst2.html
The Workplace Safety Rule — A New Direction Perhaps the greatest change in the BOEMRE programme is taking the need for operators to use EMS from a voluntary to a required status. The Workplace Safety Rule (SEMS Rule) and how each operator will address it must be established before the commencement of deepwater drilling activities. The SEMS approach requires the operator, the CEO and the entire organisation to adopt a new environmental and safety approach. The traditional business philosophy had been that an effective environmental management programme simply required the implementation of compliance programmes to meet the regulatory requirements and help an organisation to avoid negative consequences. The new business philosophy under a corporate EMS or the SEMS rule will establish an integrated and effective management systems approach for safety and environmental management that will help the organisation focus on their mission, while simultaneously promoting sustainability and saving money.
The universal principles of EMS and quality improvement will be at the core of the systems approach of each organisation:
• environmental and safety policy; • planning; • implementation and operation; •
checking and corrective action; and • management review.
EXPLORATION & PRODUCTION – VOLUME 9 ISSUE 1
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