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State looking at preparedness changes Alaska resource agencies tell Senate Resources Committee changes may be recommended to governor for next legislative session Kristen Nelson Petroleum News
Industry is encouraging the State of Alaska to wait for results of reports on the Gulf of Mexico Macondo disaster before making any changes in the state’s oil spill prevention and response requirements (see story in Sept. 26 issue).
Environmental groups want improvements in Alaska’s oil spill preparedness and response, as do coastal communities (see story in this issue).
State resource agencies — individually and collectively — have been discussing what changes the state might need to make over the summer.
Senate Resource Committee co-chairs Lesil McGuire, R-Anchorage, and Bill Wielechowski, D-Anchorage, heard an overview from state resource agencies Sept. 21at a Senate Resources Committee hearing.
C-plans required Commissioner Larry Hartig of the Alaska Department of Environmental Conservation acknowledged concerns raised by the Gulf of Mexico blowout, but said laws and regulations in place to “prevent and respond to marine spills in Alaska have been developed over decades by people with Alaska experience and expertise” and cautioned care in making sure “that what we enforce will work here and not compromise the system that we already have.”
Work is under way “by some of the best experts in the nation” on oil spill and response, he said, but “as we proceed here in Alaska, we must take into account … which lessons apply here and the best ways to incorporate them into what we have.”
Many facilities in Alaska, including oil terminals, exploration and production facilities, pipelines, tank vessels, non-tank vessels and even the railroad are required to have oil discharge prevention and contingency plans, commonly referred to as C-plans, he said, and are required to meet financial responsibility standards.
The C-plans detail spill prevention measures and equipment the plan holder must have in place: “And I stress ‘have in place’ — this is not theoretical,” Hartig said.
Prevention and preparedness Hartig said DEC tries to reduce the risk of a spill “by identifying and developing technical standards and other requirements to assure the integrity of critical equipment used in the storage and transport of crude oil;” by incorporating the requirements into regulations and C-plan approvals; by checking and inspecting records, operations and equipment to assure compliance; and by enforcement actions as needed.
Response preparedness activities are included in C-plan requirements, Hartig said, and facilities with C-plans are subject to inspections, drills, exercises and table-top drills.
Over the years since the Exxon Valdez oil spill the state has been strengthening C-plan requirements, he said.
There “may be some areas of disagreement as to what needs to be strengthened further and where we’re at in our progress, but there has been progress in many areas in the last 20 years.” DEC continues to evaluate general response procedures, deployment strategy and tactics and to evaluate technologies and determine their applicability.
Well control in a blowout DEC requires that an operator must have a plan in place to regain control of a well within 15 days of loss of well control.
Hartig said DEC may recommend a change there because while there is a requirement that the operator have a plan to regain well control, there is no review process for that plan.
DEC would refer to the Alaska Oil and Gas Conservation Commission on that plan review, he said, and could either get AOGCC’s opinion on the plan or transfer that authority to them.
Other areas DEC is focusing on for possible recommendations for changes include: the accuracy and methods it uses for estimating crude oil flows; technology for regaining control in the event of a blowout; planning and resource requirements to respond to a worst-case spill scenario; and evaluation of mechanical and nonmechanical technologies for oil recovery and dispersion.
DEC will be focusing on the reports due out over the next couple of months from national panels “and internally we’ve had a lot of discussions with all the agencies; I anticipate … going into the session that you’ll be getting recommendations from all the state agencies,” Hartig told the committee.
Well operation oversight Alaska Oil and Gas Conservation Commission Chair Dan Seamount said the commission has no authority over oil spill cleanup, but “would have oversight over well operations and relief well drilling in order to solve the blowout.”
On the prevention side, Seamount said AOGCC staff thoroughly review drilling permit applications to ensure “that the well plan includes adequate mud weight, which is the first line of defense; proper casing and cement design, which is the second line of defense; and properly working blowout preventers, which is the third line of defense.”
After a well is completed, AOGCC oversees other elements of well integrity, he said.
The commission has “a robust field well inspection program” to ensure regulatory and permit compliance. There are five inspectors now, Seamount said, and the commission is trying to get two more.
“And the five that we have now have an average of 30 years oil and gas experience each. They witness critical tests of equipment used in the drilling, production and measurement of hydrocarbons and the proper abandonment of wells,” he said.
“In essence every rig, every active rig in Alaska, is inspected by the AOGCC at least once every 60 days,” Seamount said, and blowout preventer tests are reviewed by the commission’s engineers and inspectors to ensure tests have been done properly and that all components of the equipment function properly.
Once a well is in production, he said, the safety valve system provides the function of a blowout preventer when a well is being drilled — “if there is a release it will shut the well in immediately.”
Seamount said that as far as he knows there’s never been a failed safety valve system in Alaska that’s resulted in a loss of well control.”
Regulatory review The commission recently revised its blowout prevention equipment, well safety valve systems and suspended well regulations, he said.
As for changes AOGCC would recommend to improve preparedness and response capability, the commission has been working on its regulations to make them tighter, and has provided a notice of inquiry of possible changes to well control in offshore and ultra-extended reach wells. Seamount said the commission has announced a public meeting on possible changes to be held 30 days after the public report is issues by the national committee investigating the Deepwater Horizon blowout.
Offshore production success Kevin Banks, director of DNR’s Division of Oil and Gas, emphasized the importance of outer continental shelf production to the state “because of the impact it will have on the facilities on the North Slope and especially TAPS in adding to the longevity of those facilities.” By keeping North Slope production facilities and the trans-Alaska oil pipeline running, more of the state’s lands can be developed, Banks said.
Alaska has experience in offshore development from nearshore state lands — from Endicott in 1987, through Northstar and more recently Oooguruk — all with offshore drilling. Nikaitchuq, the newest offshore project, is slated to begin production soon, he said.
State production is in shallower waters than deepwater Gulf of Mexico projects, and that means there’s better access to the sea floor and the equipment is different, with exploration done from bottom-founded structures or ice or gravel islands.
Offshore oversight team Banks said that the dialogue about a broader role for AOGCC “was conducted in part under an offshore oversight team that the governor established earlier in the summer.” That team “involves members of state agencies involved in oil and gas development, including DEC, AOGCC and the Department of Natural Resources,” he said, has “met numerous times over the summer and they’re developing recommendations for the governor’s consideration.”
Within DNR, the Petroleum Systems Integrity Office is working on a gap analysis to identify changes that would improve the integrity of facilities, operations and methodology of oil development in the state.
PSIO is also working on a quality management assessment program which would examine and oversee industry’s quality management programs, Banks said.
He said that while the Deepwater Horizon blowout and explosion was a serious event, “it is something of a rare event,” and in considering changes to the state’s statutory or regulatory oversight of oil and gas operations, “we need to keep in mind that those changes are reasonable and that they are efficient.”
Recommended changes need to be “things that will actually work and that are not a response to or a reaction to an event that is highly unlikely to occur again,” Banks said.
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