|Publisher||Society of Petroleum Engineers||Language||English|
|Content Type||Conference Paper|
|Title||Technology Alone is Not the Answer|
|Authors||Cook, William S., U.S. Minerals Management Service|
SPE/EPA Exploration and Production Environmental Conference, 3-5 March 1997, Dallas, Texas
|Copyright||1997. Not subject to copyright. This document was prepared by government employees or with government funding that places it in the public domain.|
The regulatory program for oil and gas operations conducted on the Federal OCS is administered by the Minerals Management Service (MMS). Those regulations are based upon the use of best available and safest technology, The program is intended to ensure a balance between orderly oil and gas development and protection of the environment. Simply complying with those regulations does not ensure safety and environmental protection. The technology must be integrated into the human environment of the operator through a system safety management approach to be most effective.
Development of technology, even mind-boggling technology, is not enough. Sooner or later, it comes face to face with a human being. What that human being does or does not do, often ensures that the technology works as it was intended--or does not. Technology--in particular--new, innovative, cutting edge technology must be integrated with human and organizational factors (HOF) into a system safety management approach.
The Minerals Management Service (MMS) is a bureau of the Department of Interior. We manage the United States natural gas, oil and other mineral resources on the Outer Continental Shelf (OCS). We also collect, account for, and disburse about $4 billion yearly in revenues from Federal offshore oil and gas leases and from onshore oil and gas leases located on Federal and indian lands.
A primary function of MMS as a minerals and lands manager under the OCS Land Act is to provide a balance. The Act requires the Secretary of Interior to establish policies and procedures for managing the oil and natural gas resources of the OCS which preserve, protect, and develop those resources in a manner to balance orderly energy resource development with protection of the human, marine, and coastal environments. The OCS Lands Act also provides that the Secretary require, on all new drilling and production operations and, wherever practicable, on existing operations, the use of the best available and safest technologies which the Secretary determines to be economically feasible, wherever failure of equipment would have a significant effect on safety, health, or the environment.
In enacting the the OCS Lands Act Amendments of 1978, the Congress found that technology is or can be made available which will allow significantly increased domestic production of oil and gas without undue harm or damage to the environment. The act required that the Secretary encourage development of new and improved technology for energy resource production which will eliminate or minimize risk of damage to the human, marine, and coastal environments.
It is a legal responsibility and primary function of the MMS to ensure the use and promote the continued development of technology that provides safety and environmental protection. Technology and the MMS Operating Regulations
The regulatory program of the MMS is largely prescriptive and based on equipment--the use of the best available and safest technology. It relies heavily upon the technology developed by the industry, and incorporates roughly 75 industry standards by reference. The MMS operating regulations at 30 CFR 250 explicitly provide that a company may use alternative means of compliance where it can be demonstrated that the alternative provides equal or greater protection. It is a regulatory framework that has served the industry and the public well. The exceptional pollution record of the industry is an example. The MMS regulations require that an operator install a subsurface safety valve in each producing oil well. In 1992, hurricane Andrew swept through the middle of the producing oil and gas fields in the Gulf of Mexico. Even though many wells and platforms were damaged, and some completely toppled, there was only a few hundred barrels of oil spilled as a result. The daily production in the Gulf at that time was roughly one million barrels of oil per day. The subsurface safety valves are rightfully credited with keeping the amount of oil spilled so small.
A major program of the MMS is the Technology Assessment and Research (TAR) Program. The MMS promotes the development of technology through contract projects. This includes oil spill detection, prevention and clean up. P. 99^
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