Developing Science and Metric-Based Oil Spill Response Planning Requirements for E&P Operations

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1 Developing Science and Metric-Based Oil Spill Response Planning Requirements for E&P Operations John Caplis Oil Spill Preparedness Division Phone: Oct 25, 2016

2 Key Discussion Items Significant developmental activities in support of efforts to revise BSEE Oil Spill Response Plan (OSRP) requirements: Response Calculators (Collaboration between BSEE, USCG, and Genwest) Oil Spill Response Equipment Capabilities Analysis 2 (Collaboration between BSEE, Booz Allen Hamilton (BAH), Environmental Research Consulting (ERC), SEA Consulting Group, RPS ASA) or

3 Background Information Clean Water/Oil Pollution Act Mandate The President shall issue regulations which require an owner or operator of...a facility...to prepare and submit...a plan for responding, to the maximum extent practicable, to a worst case discharge. 33 USC 1321 (j)(5)(a)(i) 3 Final Rule published in 1997 Notice to Lessees (NTLs) have provided additional clarification on 1997 requirements

4 Background: OSRP Baseline Estimated Daily Recovery Capacity (EDRC) is the metric for mechanical recovery Operators must calculate EDRC for listed equipment Historically, operators have matched their WCD volume, adjusted for oil weathering, with an equivalent amount of EDRC as the baseline planning threshold Dispersant and in situ burn plans are required No capability metrics or targets are stipulated for OSRPs No stated target levels or response times for any listed countermeasures Planning sustainment period is 30 days 4

5 Regulatory Development Work DWH lessons learned indicated that regulations should be updated After DWH, BSEE initiated a series of supporting regulatory studies and development work which resulted in: Response Calculators OSRP Equipment Capabilities Analysis 5

6 Response Calculators & User Manuals Calculators Estimate Potential Response Capabilities Encounter Rate, Systems-Based Metrics/Tools Allow comparisons between different systems and/or countermeasures Afford opportunities to optimize existing systems Provide incentives to improve/invest in future systems Estimated Recovery System Potential (ERSP) - Mechanical Recovery Estimated Burn System Potential (EBSP) In Situ Burning Estimated Dispersant System Potential (EDSP) Surface Dispersants 6

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14 14 OSRP Equipment Capabilities Analysis - Methodology

15 Regulatory Benchmarking Reviewed regulatory schemes of 8 countries (Australia, Brazil, Canada, Denmark, Greenland New Zealand, Norway, United Kingdom) Reviewed US Coast Guard regulations Benchmarking - General Findings Many different schemes, each different No one system stood out as the best Each was impacted by their NCP, their division between public/private, etc Common strong elements did stand out across the different schemes

16 Benchmarking Strong Elements Scenario based planning practices Oil characterization & weathering studies Oil spill modeling Stochastical modeling for identifying Resources at Risk Trajectory analysis of worst case for spill response planning Multiple Barrier Concept of Operations Use of aerial surveillance Targets for removal capabilities Response times for removal capabilities Use of mobilization factors

17 Deepwater Horizon Oil Spill Case Study - Findings Demonstrated the criticality of effective source control operations Highlighted limitations of mechanical recovery capabilities Demonstrated the need for aerial surveillance Validated large scale use of dispersants and in situ burning as effective response countermeasures

18 WCD Response Modeling Scenarios Lease Block Mississippi Canyon (MC807) West Delta (WD28) West Cameron (WC168) High Island East South Extension (HIA376) Keathley Canyon (KC919) DeSoto Canyon (DC187) WCD Flow Rate (bbl/day) Flow Duration Relief Well Only (days) Total WCD Release Volume (bbl) 449, ,718,000 97, ,589,000 26, ,006,400 77, ,850, , ,240, , ,546,000

19 Pacific and Arctic WCD Modeling Scenarios Planning Area Southern California Santa Barbara Channel Lease Block Santa Maria 6683 WCD Flow Rate (bbl/day) Flow Duration Relief Well Only (days) Total WCD Release Volume (bbl) 5, ,000 Planning Area Chukchi Sea Beaufort Sea Lease Block Posey 6912 (P6912) Flaxman Island 6610 (FI6610) WCD Flow Rate (bbl/day) Flow Duration Relief Well Only (days) Total WCD Release Volume (bbl) 25, ,000 16, ,000

20 Stochastic Modeling Results: Relief Well Only Surface Oiling Probability Example : Scenario 1: GOM- HIA Day Release Water surface oiling probabilities for floating oil 8.0 g/m 2 (the minimum thickness for mechanical recovery)

21 Stochastic Modeling Results: Relief Well Only Water Column Oiling Probability Example: Scenario 1: GOM- HIA Day Release Total Hydrocarbon Concentration in water column 100 ppb

22 Stochastic Modeling Results: Relief Well Only Shoreline Oiling/Stranding Probability Example: Scenario: HIA Day Release Shoreline oiling probabilities (including tar balls) 1 g/m 2

23 Stochastic Modeling Results: Relief Well Only Surface Oiling Travel Times Example: Scenario 1: GOM- HIA Day Release Minimum travel times for floating oil 8 g/m 2

24 Response Countermeasures Modeling Deterministic Simulations for Each WCD Scenario No Response Source Control Only Mechanical Recovery Source Control with Additional Surface Response Options Mechanical Recovery Dispersants Mechanical Recovery Dispersants In Situ Burning Source Control with Subsea Dispersant and All Surface Response Options

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26 Impact of Effective Temporary Source Control Capabilities Surface Oiling during High Island WCD Scenario Relief Well Only Capping Stack Only

27 Use of Response Countermeasures Surface Oiling during High Island WCD Scenario Capping Stack Only Capping Stack and Multiple Response Countermeasures

28 Oil Viscosity Modeling showed the oil viscosity changing as the oil moved away from the spill site and weathered

29 Equipment Types vs Oil Viscosity Oil Viscosity affects skimmer Performance Level of impact depends upon the characteristics of the skimmer Skimmer Group A B C Skimmer Types Oleophilic (drums, disc, brush, belt, and rope mop) Paddle belt, submersion plane Weir, air conveyor, direct suction, vortex Viscosity (cp) Limits Recovery Efficiency >80% Recovery Efficiency> 50% Recovery Efficiency <50% Recovery Efficiency <30% 1 8,000 10,000 20,000 30,000 35, ,000 3,000 5,

30 Mechanical Recovery Dispersants Skimmer Group A B C Skimmer Types Oleophilic (drums, disc, brush, belt, and rope mop) Paddle belt, submersion plane Weir, air conveyor, direct suction, vortex Viscosity (cp) Limits Recovery Efficiency >80% Recovery Efficiency> 50% Recovery Efficiency <50% Recovery Efficiency <30% 1 8,000 10,000 20,000 30,000 35, ,000 3,000 5, Viscosity limit modeled for dispersants <20,000 cst Response modeling found that the windows for each response countermeasure were significantly affected by changes in oil viscosity and slick thickness

31 Where is the window for recovering or dispersing the oil?

32 Offshore Response Concept of Operations High Volume Removal Operations focused on areas where oil is thickest and fresh High Island Scenario Response Divisions based on Oil Weathering and Trajectories

33 This oil in this scenario weathered very rapidly

34 Mechanical Recovery for Pacific SM6683 Simulation Response Type Response Division Response System Type Maximum Recovery Potential (bbl/day) Total Recovery Achieved (bbl) Mechanical High-Volume Skimmer Group A 31,065 8,545 Skimmer Group C 31,363 0 Secondary Skimmer Group A ,491 Nearshore Skimmer Group A Mechanical Total All 71,605 10,945 Dispersants High Volume/Secondary All Categories All Categories Total All 11,298 Group C Type skimmers were not effective at removing oil

35 60 50 MR Capability/Flowrate Ratios vs Oil Removal MC807 WD28 WC168 HIA376 KC919 DC187 SM6683 P6912 F6610 MR Capability to Discharge Flowrate Ratio % Oil Skimmed (Mass Balance) There was no consistent relationship between the ratio of mechanical recovery capability employed as compared to the volume of the discharge and the oil removal achieved from scenario to scenario

36 Multiple-countermeasure response capabilities were more effective than using just mechanical recovery.

37 400,000 Volume of Oil Stranded on Shore (bbls) WCDs > 75,000 bbls/day (MC807 not shown due to chart scale reasons) 350, , , ,000 WD28 HI376 DC187 KC , ,000 50,000 0 Multiple-countermeasure response capabilities were more effective than using just mechanical recovery.

38 450,000 WD 28 Scenario 400, , , , , , ,000 50,000 0 Original MR 25% Increase MR 50 % Increase MR 75% Increase MR Original MR + Dispersants Surface Area Oiling >8g/sq meter (sq mi) 38 Multiple Countermeasures were more effective than increased mechanical recovery in terms of oiling outcomes

39 90,000 WD 28 Scenario 80,000 70,000 60,000 50,000 40,000 30,000 20,000 10,000 0 Original MR 25% Increase MR 50 % Increase MR 75% Increase MR Original MR + Dispersants Oil Stranded Onshore (bbl) 39 Multiple Countermeasures were more effective than increased mechanical recovery in terms of oiling outcomes

40 P6912 (Chukchi Sea) Late Season Scenario 500, , , , , , , , ,000 50,000 0 Original MR 25% Increase MR 50 % Increase MR 75% Increase MR Original MR + Dispersants MR + D + SubD Surface Area Oiling >8g/m2 (sq mi) <# > Multiple Countermeasures were more effective than increased mechanical recovery in terms of oiling outcomes

41 35,000 P6912 (Chukchi Sea) Late Season Scenario 30,000 25,000 20,000 15,000 10,000 5,000 0 Original MR 25% Increase MR 50 % Increase MR 75% Increase MR Original MR + Dispersants Oil Stranded Onshore (bbl) MR + D + SubD <# > Multiple Countermeasures were more effective than increased mechanical recovery in terms of oiling outcomes

42 BSEE Website: BSEEgov Bureau of Safety and Environmental Enforcement BSEEgov To promote safety, protect the environment and conserve resources offshore through vigorous regulatory oversight and enforcement.

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