EMERGENCY RESPONSE PLANNING BLOG

Are new emergency planning regulations on the Horizon?

History has proven that safety regulations are born out of disaster and public outcry. Twenty years ago, Congress enacted The Oil Pollution Act of 1990 (OPA 90) as a result of the Exxon Valdez oil spill in Alaska's Prince William Sound.  FEMA can trace its beginnings to the Congressional Act of 1803, which provided assistance to a New Hampshire town following an extensive fire. The recent Gulf Oil Spill will likely spawn additional safety and oil spill planning regulations for offshore operations and potentially may impact other operations onshore.

On June 6, 2010, Bureau of Land Management Director and acting Director of the Minerals Management Service (MMS) Bob Abbey, announced that "before drilling new oil and gas wells on the Outer Continental Shelf, operators will be required to submit additional information about potential risks and safety considerations in their plans for exploration or development."  Exploration plans and development plans, even those previously approved by MMS, need to be resubmitted for approval before any drilling of new wells.

Oil and gas operations in waters less than 500 feet deep may move forward if they satisfy new safety and environmental requirements.  New Department of Interior requirements iclude the following:

• "Mandatory inspection of each BOP to be used on floating drilling operations to ensure that the BOP: meets manufacturer design specifications, taking into account any modifications that have been made; is compatible with the specific drilling equipment on the rig it is to be used on, including that the shear ram is compatible with the drill pipe to be used; has not been compromised or damaged from previous service; is designed to operate at the planned operating depth. Certification of these requirements will be made publicly available."

• "Requirement of new safety features on BOPs and related backup and safety equipment including: a requirement that BOPs have two sets of blind shear rams spaced at least four feet apart to prevent BOP failure if a drill pipe or drill tool is across on set of rams during an emergency; requirements for emergency back-up control systems; and requirements for remote operating vehicle capabilities. The Department will develop new surface and subsea testing requirements to verify reliability of these capabilities."

• "Overhaul of the testing, inspection and reporting requirements for BOP and related backup and safety equipment to ensure proper functioning, including new means of improving transparency and providing public access to the results of inspections and routine reporting."

In the near future, congress will likely re-evaluate how industry plans and prepares for disasters and may implement more stringent requirements.  One main question will come to the forefront once again - how will new regulations affect my operations, and are my disaster plans in compliance?

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