Application of remote real-time monitoring to offshore oil and gas operations
Date of Original Version
The U.S. outer continental shelf is a major source of energy for the United States, and over the past 25 years, deepwater oil and gas production in the Gulf of Mexico has increased significantly. With the move into greater water depths, industry is drilling deeper wells, where operations can experience higher pressures, higher temperatures, and greater uncertainty. Remote monitoring of drilling operations could help operators and regulators enhance the safety of these operations. This study advises the Bureau of Safety and Environmental Enforcement (BSEE) on the application and use of remote real-time monitoring (RRTM) to improve management of the safety and environmental risks of offshore oil and gas operations. As a central part of the charge (see Box 1 -1 in Chapter 1), BSEE asked the committee to conduct a workshop that addressed the critical operations and parameters to be monitored in real time, the role RRTM could play in automation and predictive software and condition-based maintenance (CBM), and how RRTM could be leveraged by BSEE and incorporated into its regulatory framework. Drillers have monitored drilling operations offshore in real time for decades; more recently, a few operators have also transmitted some of these data onshore to improve efficiency and risk management. During its information gathering, the committee was told that RRTM's benefits include increased efficiency, decreased downtime and operational disruptions, reduced equipment damage, improved safety, and overall reduction in risk. Whereas RRTM can provide the rig with technical support and access to onshore expertise, during the committee's workshop the U.S. industry expressed a belief that responsibility and authority for operational decision making should remain offshore. Situational awareness on the offshore facility is important, and RRTM data do not always provide the necessary context. The use of RRTM is variable across the offshore oil and gas industry, and diverse RRTM technologies are available. No RRTM industry standard or standard practice exists, and the industry exhibits varying levels of maturity in its use of RRTM. Thus, a standard approach is not likely to work or to be needed for every company or every well. The committee views RRTM as a best available and safest technology (BAST), when such technologies are consistent with the principles of ALARP (as low as reasonably practicable). The director of BSEE estab-lishes BAST through a documented process, but determining RRTM as BAST in some contexts would not mandate its use across the board. The decision to use RRTM occurs when such technologies are available and economically feasible. BSEE could use existing regulatory requirements, such as the Application for Permit to Drill (APD) and the Safety and Environmental Management System (SEMS) plan, to advance appropriate use of RRTM. By encouraging offshore operators to address RRTM in their APD or SEMS plans, BSEE could allow operators to determine the circumstances under which RRTM should be used and challenge them to do so when BSEE believes that RRTM is necessary for managing risk. RRTM information-whether in real time or archived-could also benefit BSEE in its inspection activities and support inspectors' review of safety-related information before they visit offshore facilities. Preparation, prioritized by risk, could allow for more efficient scheduling and effective execution of BSEE inspections. The committee is not in a position to recommend or validate a definitive list of critical operations and parameters for RRTM. In the committee's judgment, a single standard list for all operations is not practical in view of the variability in operating conditions, geology, and scope and scale of facilities; the evolution of technology; consideration of human factors; and the incorporation of RRTM in a risk-based approach to regulating offshore operations. However, companies using RRTM appear to monitor some of the same critical operations and parameters (see Chapter 2). As sensor technology advances and the ability to transmit that data improves, issues with regard to the management of massive volumes of real-time data will grow. Likewise, as more RRTM of offshore operations is introduced, cybersecurity risks associated with the increased use of technology will rise. Control systems for critical rig-based equipment, not originally designed for connectivity to Internet-facing systems, are likely be at risk. RRTM could contribute to achieving a longer-term goal of offshore systems CBM. Blowout preventers (BOPs) provide a promising case. However, before CBM can go forward, BOP operational data and maintenance history will need to be collected and stored continually over the lifetime of the equipment to allow development of predictive models. Retroactive analysis of BOP performance data may not be adequate due to the complexity and variability of offshore operations and incomplete BOP maintenance history. The committee's consensus recommendations, which are listed below and elaborated in Chapter 4, provide guidance to BSEE and stakeholders in addressing the issues associated with the application of RRTM to offshore oil and gas operations. Recommendation 1. BSEE should pursue a more performance-based regulatory framework by focusing on a risk-based regime that allows industry to determine relevant uses of RRTM on the basis of assessed levels of risk and complexity. BSEE could assess decisions about the monitoring of well parameters or the application of RRTM through the review of a company's APD or SEMS plans and challenge the company to apply RRTM to manage the risk of complex operations. Recommendation 2. The committee views RRTM as BAST when justified by the risk of particular wells. BSEE should monitor the spectrum of RRTM technologies and best practices by using either an internal BSEE group, such as the agency's proposed Engineering Technology Assessment Center, or an external organization, such as the Ocean Energy Safety Institute. Recommendation 3. Consistent with recommendations of previous committees of the National Academies (NAE and NRC 2012; NAE and NRC 2013), BSEE should encourage involvement of all stakeholders in the development of risk-based goals and standards governing offshore oil and gas processes. Specifically, BSEE should work with the American Petroleum Institute (API), the International Association of Drilling Contractors, and other relevant stakeholders to form an API standing technical committee (as opposed to an ad hoc committee) that would establish minimum requirements for which critical operations (and parameters) are monitored and for which data are collected and monitored in real time. In addition, BSEE, along with this technical committee, should propose standards for communication protocols between onshore and offshore facilities when RRTM is used. Recommendation 4. BSEE should encourage API to work with original equipment manufacturers, drilling contractors, and industry trade associations to establish a BOP CBM pilot project, with the goal of an API publication.
Transportation Research Board - Special Report
Card, James C., Mary R. Brooks, Edward N. Comstock, Elmer P. Danenberger, Samuel P. De Bow, Thomas J. Eccles, Jeanne M. Grasso, Martha R. Grabowski, Stephan T. Grilli, John M. Holmes, Thomas A. Jacobsen, Donald Liu, Richard S. Mercier, Edmond J. Moran, Ali Mosleh, John W. Murray, Karlene H. Roberts, Richard J. Steinke, Peter K. Velez, and Richard D. West. "Application of remote real-time monitoring to offshore oil and gas operations." Transportation Research Board - Special Report 2016-January, 322 (2016): 1-117. https://digitalcommons.uri.edu/oce_facpubs/122