Worst Case Discharge Scenarios for Oil and Gas Offshore Facilities and Oil Spill Response Equipment

Client: Bureau of Safety and Environmental Enforcement (BSEE)

BSEE’s Oil Spill Preparedness Division (OSPD) is responsible for developing and administering regulations (30 CFR part 254) that oversee the oil and gas industry’s preparedness to contain, recover and remove oil discharges from offshore facilities operating seaward of the coastline. Current regulations require that operators of these offshore oil and gas facilities submit an Oil Spill Response Plan (OSRP) that identifies the procedures and contracted spill response resources necessary to respond, to the maximum extent practicable, to the facilities’ worst case discharge (WCD).

RPS, as a member of a team led by Booz Allen Hamilton, was awarded a contract in 2014 by BSEE OSPD to 1) examine how the portfolio of worst case discharge scenarios contained within the OSRP’s in each Outer Continental Shelf (OCS) Region has changed over time; 2) analyze the oil spill response equipment capabilities that are currently available to respond to these discharges, and 3) provide subsequent recommendations on how the requirements for OSRPs may be improved. The goal of this project was to provide data and information to BSEE in order to update their OSRP regulations, which have not been updated in nearly 20 years. Due to changes in that time span (e.g., changes in drilling trends and risks associated with oil spills), BSEE needs to understand and analyze the changes concerning offshore oil spill risks, as well as current oil spill response industry’s ability to meet the risk through its associate equipment stockpiles, technology and strategies.

This project consisted of the following:

  • Research and analysis of:
    • Evolving risk trends for WCD scenarios due to emerging industry drilling practices;
    • Current commercial availability of response resources and technologies; and
    • An assessment of the impacts on preparedness due to the implementation of a new mechanical oil recovery planning standard.
 
  • Trajectory modeling and identification of geographic areas at risk from each WCD from initial discharge time through a 60 day period of a sustained release at the maximum daily WCD flow rate. Trajectory modeling was run using WCD site specific volumes over locations in the Arctic, Pacific and Gulf of Mexico. The analysis was part of a relative risk evaluation.
  • Provided consultation, evaluation, and recommendations which will assist BSEE in developing potential OSRP requirements for a future rulemaking. Conducted three separate but related analyses in order to:
  • Better characterize current oil spill risks;
  • Assess current planning strategies, available technologies, and equipment in order to develop recommendations for enhanced OSRP response equipment capability requirements; and
  • Assess the impacts to industry plan holders’ and oil spill removal organizations’ response preparedness levels as a result of implementing the proposed Estimated Recovery System Potential (ERSP) planning standard.

The full report is available at https://www.bsee.gov/site-page/worst-case-discharge-scenarios-for-oil-and-gas-offshore-facilities-and-oil-spill-response

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