Presentation
Obtaining Regulatory Authorization for Subsea Dispersant Injection in the Gulf of Mexico
SessionSubsea Response Options
DescriptionSubsea dispersant injection (SSDI) was utilized extensively and for the first time during the 2010 Deepwater Horizon (DWH) incident. Consequently, an SSDI-specific, regulatory authorization process did not exist requiring a somewhat ad hoc process to be followed based on surface dispersant application guidelines. Following the DWH incident, the industry made significant investments to further develop SSDI capabilities and understand its impact on spill response operations and the environment. Operators in the Gulf of Mexico have also conducted several deep-water, loss of well control exercises but due to the continued absence of regulatory guidance, SSDI authorization or concurrence requests followed a similar ad hoc process. To fill the void, the American Petroleum Institute (API) developed an SSDI authorization guideline titled Industry Guidelines on Requesting Regulatory Concurrence for Subsea Dispersant Use (API Bulletin 4719, 2017) that outlined a suggested application process and justification based primarily on mitigating ecological impacts. It also included considerations for SSDI’s effectiveness in mitigating the VOC associated health and safety risks for response workers (safety case). In some of those exercises, however, authorization for SSDI was denied by the Regional Response Team (RRT) for various reasons.
Because SSDI has proven effective in mitigating safety case risks on the water’s surface and, by extension, facilitates the rapid installation of well capping and containment (well intervention) equipment necessary to stop or control the discharge, industry concluded a new approach was required that focused on the more critical safety case issues. To that end, Chevron, and then API, led the development of an additional SSDI authorization guidance document based solely on mitigating health and safety risks titled Industry Recommended Response Worker Safety Considerations for Requesting Regulatory Concurrence for Subsea Dispersant Use (API Bulletin 4719b, 2022). This document can be used independently or in conjunction with API Bulletin 4719 when requesting SSDI authorization. In subsequent exercises, however, the RRT and/or Captain of the Port/Federal On-Scene Coordinator (FOSC) denied SSDI authorization for applications utilizing the safety case justification.
This paper will discuss the background and genesis of the two API SSDI guidance documents as well as some of their key components with the primary focus being on the more recent, safety case related, document. It will also include a description of the proposed SSDI authorization process including a discussion of the regulatory responsibility (FOSC or RRT) with respect to the safety case justification. Additionally, the paper will include a discussion of exercises in the Gulf of Mexico where Operators requested SSDI authorization/concurrence including identifying relevant issues and providing recommendations to inform future requests for SSDI authorization.
Because SSDI has proven effective in mitigating safety case risks on the water’s surface and, by extension, facilitates the rapid installation of well capping and containment (well intervention) equipment necessary to stop or control the discharge, industry concluded a new approach was required that focused on the more critical safety case issues. To that end, Chevron, and then API, led the development of an additional SSDI authorization guidance document based solely on mitigating health and safety risks titled Industry Recommended Response Worker Safety Considerations for Requesting Regulatory Concurrence for Subsea Dispersant Use (API Bulletin 4719b, 2022). This document can be used independently or in conjunction with API Bulletin 4719 when requesting SSDI authorization. In subsequent exercises, however, the RRT and/or Captain of the Port/Federal On-Scene Coordinator (FOSC) denied SSDI authorization for applications utilizing the safety case justification.
This paper will discuss the background and genesis of the two API SSDI guidance documents as well as some of their key components with the primary focus being on the more recent, safety case related, document. It will also include a description of the proposed SSDI authorization process including a discussion of the regulatory responsibility (FOSC or RRT) with respect to the safety case justification. Additionally, the paper will include a discussion of exercises in the Gulf of Mexico where Operators requested SSDI authorization/concurrence including identifying relevant issues and providing recommendations to inform future requests for SSDI authorization.
Event Type
Paper
TimeTuesday, May 14th3:30pm - 3:50pm CDT
Location278-280
Response