|Image from World Atlas|
This post began with an email from the University of Alaska Fairbanks Frontier Science website about their new Arctic Sea Ice videos. I thought it relevant to see what Shell Oil had up on sea ice in the Chukchi Sea. I was close to posting Tuesday night when I was having trouble with blogger and saved the post and reopened it to find most of the post gone.
A severe storm that's been predicted for Anchorage has just made its presence known through noisy wind slamming windows and mimicking airplanes flying over the house. We're supposed to have 80 to 100 mile/hour winds. I was sure that the electricity would go out before I finished this. Now that I have to recreate much of it, I can only cross my fingers. I've gotten candles out just in case. In my heart of hearts, I know this will be a better post for being rewritten, but I'm still not happy.
Here are two Frontier Science videos on Arctic ice. The first is Modeling Arctic Ice:
and the second one on Bering Sea Ice Movements
Tuesday 10:26pm - the electricity just went out, but J had lit the candles already. The wind is huffing and puffing and banging tree limbs against the house.
So, I wanted to see what Shell Oil had about sea ice. At the Alaska Press Club Conference in April I learned at one panel that included a Shell representative and other Arctic researchers, that Shell (and I think other corporations) had agreed to share their research findings in the Arctic and not keep them proprietary. So if that has happened, then the Frontier Scientists should have access to it.
A Shell webpage on Oil spill prevention and response got me to a pdf of a report: PREVENTING AND RESPONDING TO OIL SPILLS IN THE ALASKAN ARCTIC. On page three it had a Prevention Toolkit. The tools listed included:
- Redundancy - "Shell applies a multi-layered well control system designed to eliminate the possibility of a low probability, high impact event. If any one system or device fails, it should not lead to a blowout." It suggests that there are different systems to notice problems so if one fails another will pick it up. I'd note that in Outliers, Malcolm Gladwell wrote that airplane crashes happen when five or six backup systems go wrong at once.
- The Safety Case Approach - "As an example, Shell has used the “Safety Case” approach recommended by the National Commission on the BP Deepwater Horizon Oil Spill and Offshore Drilling for all its contracted drilling rigs, globally, for many years." That's odd, since the spill occurred in 2010 and the National Commission report came out in 2011. How could they have used this approach for many years? Maybe the approach was around and the Commission endorsed it in its report. Ah, writing is so tricky.
- Safety Culture - "Since 90% or more of all incidents are caused by human error, a true culture of safety that permeates and guides all activities is perhaps the most important method of spill prevention"
- Blowout Preventer - "In the unlikely event that measures of early detection fail, mechanical barriers such as blowout preventers (BOP) can seal off the well."
- Ice Management - For the previous tools, I've just given an excerpt of each, but since this is the issue we started with, I should give you their whole explanation:
"Shell’s exploration activities will occur during a four-month period from mid-July through October, in predominantly open water conditions. However, to address the natural variability of ice conditions during thaw and freeze up, Shell has developed an Ice Management Plan (IMP) to ensure safe drilling operations and identify conditions that may put operations at risk.
Shell’s ice management system is a combination of ice monitoring, forecasting, and management techniques. Monitoring includes satellite-based Synthetic Aperture Radar, airborne and vessel reconnaissance. Forecasting incorporates data from the National Oceanic and Atmospheric Administration and the Canadian Ice Service. Shell will use specialized software to integrate ice speed and direction data from the vessel’s radar, aerial reconnaissance, and satellite imagery in order to predict individual ice floe movement, allowing modification of ice management operations on a real-time basis. Shell has established strict protocols to be followed in the event of potential hazards. Ice management vessels can be used to deflect approaching ice around the rig and, if necessary, the rig can quickly stop drilling, secure the well, and move safely off-site." [emphasis added.]I wasn't paying close enough attention the first time and glazed over the Ice Management Plan (IMP) but I did see "strict protocols to be followed in the event of potential hazards" and googled that and got to "2010 Plan of Cooperation Camden Bay, Alaska" and this relevant paragraph:
"Shell has developed and will implement a Critical Operations and Curtailment Plan (COCP), which establishes protocols to be followed in the event potential hazards, including ice, are identified in the vicinity of the drilling operations (e.g., ice floes, inclement weather, etc.). Like the IMP, the COCP threat classifications are based on the time available to prepare the well and escape the location. The COCP also contains provisions for not initiating certain critical operations if there is insufficient time available before the arrival of the hazard at the drill site."At this point I started questioning my obligations as a blogger. How far am I supposed to go digging? Couldn't I just say my job was to start raising these issues and let someone else take the baton from here?
But how much trouble would it be to look up COCP and IMP? It turns out, not much at all. I found them easily. But then writing up what I found was another issue altogether. That took time. Time enough to lose most of what I wrote and then get disconnected from the internet by a windstorm taking out our electricity. I just looked out the window. It is really, really dark out. The only lights I can see are a few car lights off in the distance. I guess a severe storm is an appropriate context for writing about Chukchi Sea emergency oil drilling procedures. I have an hour left on my laptop battery.
CRITICAL OPERATIONS AND CURTAILMENT PLAN (COCP)
Chukchi Sea, Alaska (Total of 16 pages)
That's a mouthful, but if you actually think about it, it really says what it's about - a) critical operations and b) curtailment plan. You'll see below. It basically is about procedures. It . . .
- Identifies Planned and Unplanned Critical Operations
- Identifies Circumstance/Conditions Requiring Curtailment
- Severe Weather Sea
- Sea Spray .
- Unavailability of Materials, Personnel, and / or Equipment
- Well Control
"Critical operations, other than efforts to restore primary well control, will not be undertaken during a well control event (e.g., drilling will cease pending circulation of a kick out of the hole and adjusting mud density to prevent further kicks from entering the wellbore). The curtailment of critical operations due to a well control event is the responsibility of the Shell Drilling Foreman."I guess this means if something goes wrong with the well, they'll stop everything else, but I'm not sure.
Then it goes into different kinds of Time.
There's ST or Secure Time which is how long it takes to secure the rig
There's MT or Move-Off Time - how long it takes to get people evacuated
There's T-Tine or Total time, which combines ST and MT.
But there is also HT or Hazard Time, how long, in hours, before the hazard arrives.
My question was what if the Hazard Time is less than the T-Time? That is, if the hazard is due to arrive before they have time to curtail and evacuate? It turns out that got answered in IMP below.*
Then there's the curtailment decision process which basically is about who makes the decisions and who gets told by whom.
And then there's training:
All personnel will be made aware of their roles and responsibilities described within this COCP and the IMP through a training program to be taught before the vessel is on site. All persons with a key position in the COCP will be provided a copy of this document, and training will be provided by Shell prior to deployment. This training will include a table-top exercise that will be carried out prior to initiating operations in the Chukchi Sea.Table-top exercise, according CSOOnline,
"is a great way to get business continuity plans off the written page without the interruption of a full-scale drill. Rather than actually simulating a disaster, the crisis management group gathers for three hours to talk through a simulated disaster.Just talking is good up to a point. I'd really like them to be doing some shipboard training in a storm.
ICE MANAGEMENT PLAN (IMP)
(Total 50 pages)
Then I went looking for the Ice Management Plan (IMP). [Doesn't Shell know the definition of 'imp'? Dictionary.com's first definition of 'imp' is:
"a little devil or demon; an evil spirit."]
Here's the overview from the the little devil's Table of Contents:
- VESSELS COVERED BY IMP
- SHELL ICE AND WEATHER ADVISORY CENTER
- ICE ALERT LEVELS AND PROCEDURES
- ICE MANAGEMENT PHILOSOPHY
- WELL SUSPENSION
- MOORING SYSTEM RELEASE/RECOVERY MOVING ONTO OR RETURNING TO THE DRILL SITE
- Vessels - this is probably the most technical section that describes the ships and their capabilities. For example:
"The Kulluk has an Arctic Class IV hull design, is capable of drilling in up to 600 feet (ft) [182.9 meters (m)]) of water and is moored using a 12-point anchor system. The Kulluk mooring system consists of 12 Hepburn winches located on the outboard side of the main deck, Anchor wires lead off the bottom of each winch drum inboard for approximately 55 ft (16.8 m). The wire is then redirected by a sheave, down through a hawse pipe to an underwater, ice protected, swivel fairlead. The wire travels from the fairlead directly under the hull to the anchor system on the seafloor.
The Kulluk is designed to maintain its location in drilling mode in moving ice with thickness up to 4 ft (1.2 m) without the aid of any active ice management. With the aid of IMVs, the Kulluk would be able to withstand more severe ice conditions. In more open water conditions, the Kulluk can maintain its drilling location during storm events with wave heights up to 18 ft (5.5 m) while drilling, and can withstand wave heights of up to 40 ft (12.2 m) when not drilling and disconnected (assuming a storm duration of 24 hours)."
- Shell Ice and Weather Advisory Center (SIWAC) - Unit in Anchorage that monitors ice and weather conditions and gets the information out to the drilling rigs.
- Ice Alerts and Procedures - Color coded chart from green to red (black is shut down.) This gives a sense of how long it takes to shut down, because 24 hours notice is green. Between 24 and 12 hours they initiate risk assessment. Between 12 and 6 hours limited operations and begin to secure the well. Under 6 hours the well should be shut down and anchor recovery should commence.
*This section also answers the question I had above about what happens if the hazard time is greater than the total time to shut down:"Guidance Note: If T-Time becomes greater than HT at any time, well securement and drill site evacuation contingency plans will be implemented."
There are also more detailed charts and description of who is responsible for doing what in the event of a shut down.
- Ice Management Philosophy - I don't know how to take their use of the word Philosophy here. Is it an attempt to make this sound grander than it is? If so it is good to know that Philosophy still has a noble image. But I'd hardly call this a philosophy. Particularly after reading McPhee's The Control of Nature, I'd call this more a religious doctrine of faith - We believe that if we have these procedures in place, God will not allow bad things to happen. Really, this is just a list of conditions of alleged readiness. For example:
- "The IMVs will be capable IMVs, with the appropriate ice strengthening, and have been contracted to support the exploration campaign."
- "A systematic approach for risk mitigation is adopted by developing effective work processes.
Development of effective ice management strategies based on available information (global and local)"
- Well Suspension Procedures - Why is this not reassuring? "As part of securing the well, well suspension procedures will be established. These procedures will supplement the detailed well securing procedures that will be contained within the Rig Operations Procedures and will be specific to securing the well in response to the threat of hazardous ice."OK, it's not quite that bad. There is a more detailed table of things to do (p. 16) though I don't have the expertise to know how adequate it is.
- Mooring System Recovery and Release - Again, I don't have the expertise to evaluate this, but it is always disconcerting when one of the options - Running of Wires - in the cell for "Advantages" has the word 'none.' If there are no advantages to that method, then why is it there?
- Moving onto the Drill Site - Clarifies who decides when to return to the rig.
- Training - Each ship will have a table top exercise and it has a list of people who will participate.
Both the IMP and the COCP have what I'll call a "good judgment clause."
This is obviously a complicated affair. These two plans - the CRITICAL OPERATIONS AND CURTAILMENT PLAN (COCP) and the ICE MANAGEMENT PLAN (IMP) are more about gathering weather data, who makes decisions and who communicates with whom. These are important things, but they don't really address the technical issues of ice flows in the Arctic and how to shut actually shut down the rig in an emergency. Those are referred to, almost in passing, in what I'm calling the IMP's 'good judgement' clause. (p. 1)
"This plan is not a substitute for good judgment.
Guidance Note: This document is not intended to contain detailed procedures. Detailed procedures are contained within the vessel-specific operating manuals." [Emphasis added.]So, the actual procedures for dealing with ice emergencies are yet somewhere else. Perhaps they are so detailed that there is a justifiable reason for their not being here with these plans. And presumably each vessel has different plans. But those more detailed manuals would be critical for someone evaluating the adequacy of the plans. And given the BP Deepwater Horizon disaster, I don't think anyone is willing to just trust the assurances of the oil companies. But the internet is still out at my house this morning - though the electricity came on around 7am, so I can't search for the operating manuals of the vessels. (That's an excuse I'm happy to use to get this post done. Maybe I'll do a follow up post.)
I would note that the Critical Operations and Curtailment Plan (COCP) also has a 'good judgment' clause:
"No contingency plan can adequately cover all conceivable situations and circumstances, nor is this plan intended to be a substitute for good judgment and experience in dealing with unexpected situations."This is way more than I was expecting to do on this and I haven't even scratched the surface. I hope it piques some people's curiosity and they try some links and go exploring further. If you find anything interesting, please report back in the comments.
NOTE: It's 2:30pm Wednesday. I'm at the dentist's office where there's wifi. I need to review this, but I'm not sure the internet is working at home, so I'm scheduling it to post at 5pm. I think it's mostly ok. If our home internet isn't working and there are problems, I'll fix it later.
5:51 - I didn't have internet at home so now I'm at Loussac library working on this.
It wasn't until the end of this that I found the Bureau of Ocean Energy Management (BOEM) webpage with lots of links related to their permitting of Shell's 2012 Chukchi oil exploration.
2:35pm Thursday - I thought this went up Wednesday night, but it didn't. OK, I'll hold it another day.