Sandi Fury, Chevron, 8-3-13

The is a Comment on the Bureau of Safety and Environmental Enforcement (BSEE) Proposed Rule: Oil and Gas and Sulphur Operations on the Outer Continental Shelf: Oil and Gas Production Safety Systems

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Our initial review of the proposed update of 30 CFR 250.800 (Subpart H) indicates that this is a significant rulemaking that will require extensive review, discussion, and comparison of the existing Subpart H rule and current BSEE policies by the regulated community. Chevron believes an additiona1120 days is necessary to have the input and feedback from the many areas of our operations that will be impacted by this rule.

The Bureau in the Executive Summary of the rule states, "This proposed rule would amend and update the Subpart H. Oil and Gas Production Safety Systems regulations. Subpart H has not had a major revision since it was first published in
1988. Since that time, much of the oil and gas production on the OCS has moved into deeper waters and the regulations have not kept pace with the technological advancements."

Chevron recognizes the importance of the Bureau's efforts to update the regulations; however, we believe that the updates go well beyond "amendments." The proposed rulemaking announcement acknowledges that the rule will in fact:
• "Expand the regulations to" ...
• "Incorporate new industry standards" ...
• "Add new requirements for, but not limited to, the following:
SPPE life cycle and failure reporting;
Foam firefighting systems;
Electronic-based emergency shutdown systems (ESDs);
Valve closure timing;
Valve leakage rates;
Boarding shut down valves (BSDV); and
Equipment used for high temperature and high pressure wells"

The introduction of new concepts, including "lifecycle analysis" and "failure reporting" for certain critical equipment by Operators to manufacturers and/or third party vendors is a major undertaking. Additional dialogue and clarity to reconcile the Bureau's general comment in the Executive Summary regarding Failure Reporting and Information Dissemination with the actual proposed rule language is required to understand the Bureau's intent. A workshop dedicated to this topic may provide the most effective vehicle for Industry to engage the Bureau in an effort to clarify its expectations and proposed plan for implementation.

Within the Subpart H notice of proposed rule, the Bureau also advises Industry that it is revising the regulation in Subpart A requiring best available and safest technology (BAST) to follow more closely the Outer Continental Shelf Lands Act's (OCSLA, or the Act) statutory provision for BAST, 43 U.S.C. 1347(b). While it is not clear as to the implications of this revision, given the fact that the current regulatory guidance has been consistent since 1978, the significance of this revision is a cause for concern. It is hoped that the upcoming BAST workshop, now postponed to the January/February
2014 timeframe, will provide additional insight in how BSEE intends to use BAST as it applies to the subpart H regulations. The information exchange that will take place at the workshop will provide valuable insight to both internal and external stakeholders. It would be a loss to all parties to not allow this exchange of information to be adequately considered and used in preparing comments on this rulemaking.

The above regulatory additions are not insignificant and in fact are far-reaching, having implications to all existing producing facilities and ongoing producing operations as well as impacting facilities currently under construction and planned operations. The rationale for an extra 120 days is intended to provide Chevron adequate time to analyze and comment on a proposed rule that not only makes major revisions, including significant additions, but further requests submittal of information from operators regarding equipment currently in service today that is critical to the safeguard of personnel and the environment. Further the 120 day extension would allow for valuable exchange of information facilitated by Bureau workshops held within the comment period that could aid our interpretation of the rulemaking and possibly resolve unwarranted concerns.

We ask for your consideration of this request and look forward to working with you on this very important matter.



Letter requesting 120 day extension

View Attachment:

Comment Period Closed
Oct 21 2013, at 11:59 PM ET
ID: BSEE-2012-0005-0010
Tracking Number: 1jx-87bq-6swz

Document Information

Date Posted: Aug 30, 2013
RIN: 1014-AA10
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Submitter Information

Submitter Name: Sandi Fury
Organization Name: Chevron North America Exploration and Production