Shell responds to BOEM
Fills in some additional details for company’s Chukchi Sea exploration plan
Shell has responded to a request from the Bureau of Ocean Energy Management, or BOEM, for additional information relating to the company’s latest Chukchi Sea exploration plan. The company, with hopes of restarting its Chukchi Sea drilling campaign in the summer of 2014, had filed a revised exploration plan in early November. BOEM subsequently sent the company a list of additional information it needs before deeming the plan complete and ready for release for public comment.
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Peter Voser, the company’s CEO, has recently said that Shell is preparing to drill in the Chukchi in 2014 or 2015 but has not yet made a final drilling decision.
Permits neededShell has said that it wants to drill in 2014, but that the drilling would be contingent on the company obtaining all of the necessary permits for the fleet of some 30 vessels that it plans to deploy. In addition to its exploration plan, the company has filed an integrated operations plan with BOEM for its Chukchi Sea program — BOEM required Shell to file the integrated operations plan as one of the outcomes of the Department of the Interior’s investigation of issues that arose during Shell’s Beaufort and Chukchi drilling project in 2012.
The exploration plan envisages the drillship Noble Discoverer completing a well in the Burger prospect, about 80 miles offshore the western end of the North Slope, as part of a program to drill up to six wells over a time span of three years. The Discoverer drilled the top-hole section of that first Burger well during the open water season of 2012. Shell also drilled a top-hole section of a well in its Beaufort Sea Sivulliq prospect in the same drilling season but the company has no immediate plans to return to the Beaufort.
Following damage to Kulluk, Shell’s Arctic floating drilling platform, during a grounding incident in the Gulf of Alaska at the end of 2012, Shell has decided to scrap that drilling vessel. And so, to ensure the presence of a backup rig for the drilling of a relief well in the unlikely event of a well blowout, Shell has contacted the use of a semi-submersible drilling rig, the Polar Pioneer. According to the revised exploration plan, Shell will position the Polar Pioneer and some support vessels at Dutch Harbor in the Aleutian Islands during the Chukchi Sea drilling.
Noble DiscovererIn addition to the damage to the Kulluk, Shell encountered some problems with the Noble Discoverer in 2012, including some U.S. Coast Guard and Environmental Protection Agency regulatory non-compliance issues, and some problems with the vessel’s propulsion system. And, as part of its request for additional exploration plan information, BOEM asked Shell to describe any modifications that the company has since made to the vessel to address the non-compliance difficulties.
Shell has responded by referring BOEM to the integrated operations plan, which spells out a list of modifications made to the Noble Discoverer since 2012. Noble Drilling Corp. owns and operates the Noble Discoverer, under contract with Shell.
Maintenance and upgrades“Since the end of 2012 operations, the Discoverer has undergone a rigorous maintenance and upgrade program implemented by Noble Drilling with Shell’s involvement,” the integrated operations plan says. “Improvements in the scope of work include modifications based on lessons learned during the 2012 season as well as maintenance items to preserve the ship’s operability and reliability in preparation for further work in Alaskan offshore waters.”
Improvements include a sponson extension to shift the vessel’s center of gravity aft, thus improving the vessel’s yaw characteristics, the integrated operations plan says. All walkways on the vessel have been coated with a non-skid finish and some railing heights have been increased. The bilge system was reconfigured “in conjunction with the new main engine,” the plan says. Other safety-related modifications include a new structure that allows escape from the lowest level of the main engine room in the event of a fire.
Modifications to improve crew comfort in cold conditions include new and upgraded steam heating systems, additional thermal insulation on some internal areas of the hull and some new external windbreaks, the integrated operations plan says.
In response to a request from BOEM for an explanation for the engine failures in the Aiviq at the start of a chain of events that led to the grounding of the Kulluk in 2012, Shell offered to supply the agency with copies of the various U.S. Coast Guard certifications and documents for the vessel. The Aiviq, a new Arctic anchor handling vessel under charter to Shell, had been towing the Kulluk prior to the grounding.
Oil containment systemDelays and problems with the completion and testing of Shell’s new Arctic oil containment system were major factors in impeding drilling during Shell’s 2012 operations — the containment system is designed to gather oil from an out-of-control well, should emergency systems such as the blowout preventer fail. But Shell says that the containment system has now been tested, is fully operational and will be stationed in Kotzebue Sound while Chukchi drilling is in progress.
As part of its drilling fleet, Shell has self-contained offshore oil spill response capabilities. The company also has arrangements for coastline spill response, should that prove necessary.
Blowout preventer testingIn its request for additional information BOEM asked Shell to provide a rationale for a decision to reduce the frequency of blowout preventer testing from every seven days to every 14 days. A blowout preventer is a device designed to shut in a well in the event of a loss of well control.
In its response to BOEM, Shell said that the pressure testing procedure that the company now proposes in the Chukchi — pressure testing every 14 days, with a function test every seven days — is consistent with the way in which industry conducts blowout preventer testing in the Gulf of Mexico.
“Standardizing the frequency of the pressure test to concur with the Gulf of Mexico will reduce wear on the BOP sealing elements, enhancing rather than degrading BOP reliability,” Shell told BOEM.
Air emissions dataIn response to questions regarding air emissions from the Chukchi Sea drilling operations Shell has provided a large amount of information about estimated emissions and the techniques used to manage those emissions. BOEM has taken over Arctic outer continental shelf air permitting from the Environmental Protection Agency and will review Shell’s anticipated air emissions as part of the agency’s review of the company’s exploration plan.
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Shell explains its contractor management
When the U.S. Department of the Interior reviewed Shell’s 2012 drilling operations, following a series of problems culminating in the grounding of the Kulluk, the company’s floating drilling platform, the agency particularly criticized Shell’s oversight of its contractors, saying that the company’s management systems were insufficiently robust to manage and minimize risk in contracted operations.
In a newly filed integrated operations plan, required by Interior in conjunction with Shell’s planned continuation of drilling in the Chukchi Sea, the company has spelled out a series of contractor-management procedures.
The plan says that Shell will use what it refers to as a “control framework” for overall management of the various contractors that will be engaged in the multifarious activities required to conduct and support a drilling operation in the Arctic offshore.
Evolving with experienceAnd Shell’s management structure has continued to evolve, the plan says.
“Building on Arctic operating experience since 2006, Alaska has become a center of Arctic operating experience within Shell,” the plan says.
A single integrated activity plan will drive the massive operation involved in conducting and supporting drilling in the Chukchi. The plan will be supplemented by procedures for managing project changes; achieving continuous improvement; and managing health, safety and environmental risks, Shell says.
A Shell “contract owner” for each contract will assume responsibility for the contract, while a “contract holder” will take responsibility for the contractor’s performance, the integrated operations plan says.
An assurance committee, headed by Shell’s executive vice president for the Arctic, will oversee safety assurance activities such as audits and inspections.
Other procedures for managing contractors include the use of required contractor qualifications; readiness audits and reviews; table-top exercises; and conferences with contractors, to select contractors and assure contractor readiness for the field operations, the integrated operations plan says.