Oil Spill Prevention

The Mineral Resources Management Division staff inspects offshore oil production equipment monthly, consistent with its regulations (Article 3.3 and Article 3.4). The inspections include physical testing of production and processing alarms and shutdowns: including each well’s surface and subsurface safety valves; toxic and combustible gas detectors; fire and smoke detection equipment; fire, abandon platform, and man overboard alarms; pipeline alarms; the emergency shutdown system; fire pumps, deluge and fire control system; and the emergency generator. Staff also checks navigational aid functionality and inventories spill response equipment. Staff reviews maintenance records of PSV (pressure relief), cathodic protection rectifiers (corrosion control), firefighting equipment, and lifesaving equipment. Staff also checks pipeline right-of-way surveillance, spill drill, and boom deployment records for compliance. Each inspection takes two to three days and involves inspecting approximately 300 safety items on each facility. If deficiencies are not corrected immediately, the affected equipment is shut down and isolated, which may require that the facility is shut-in. Platform inspections ensure the integrity of platform safety systems and that equipment is available and in good operating condition to respond to emergencies or spills.

The Mineral Resources Management Division staff comprehensively audits offshore oil and gas production facilities on a five-year cycle. The audits, designed to ensure compliance with Articles 3.3, 3.4, and 3.6, assess the design and condition of each platform and shore-side facility and that the operators of the platforms are producing safely.  Staff analyzes the technical design of safety systems on oil and gas drilling and production facilities and verifies that the alarms and controls are installed and operate as designed. Staff also reviews equipment maintenance and corrosion prevention and inspection programs to evaluate fitness for pressure vessels, tanks, and piping. A third-party contractor analyzes and inspects the design, maintenance, and condition of electrical distribution systems. Training and qualification programs at platforms and oil facilities are reviewed to assure competent operation. Staff reviews the operating manual and spill prevention plan to evaluate procedure adequacy for normal operation, upset conditions, and response to spill incidents. Staff assesses, using a Safety Assessment of Management Systems (SAMS) program, the organizational safety culture, the human factor element, and the maturity level of safety programs. Staff evaluates these factors through confidential interviews with a cross-section of company operators, engineers, management, and contractors. The SAMS program is a model for other state and federal agencies. Safety audits provide a comprehensive evaluation of facility design, condition, procedures, and personnel. Audits usually result in a matrix of action items that are prioritized by risk and staff follows up to ensure operators implement corrective action items.

The Commission has strict regulations related to drilling and production on state leases. An operator cannot drill or abandon a well if it does not meet the Commission’s regulations in Article 3.2 and Article 3.4, and all industry and code specifications. Requirements include proper blowout prevention equipment and casing design, contingencies for hydrogen sulfide and oil spill response, critical curtailment plans, and abandonment of wells. Before drilling or abandoning any well, a lessee must provide the Commission details about its proposed well plan and copies of permits. Staff is usually present during critical times or during well testing, and receives daily updates about the drilling and completion activities. As a result of the April 2010 blowout of the Deepwater rig in the Gulf of Mexico, blowout prevention equipment requires third-party verification of fitness for purpose.

The Mineral Resources Management Division is responsible for overseeing operation and maintenance of all offshore oil and gas pipelines (California Oil Production Regulations (§2132, Pipeline Operations and Maintenance) and the Offshore California Pipeline Inspection Survey MOA between state and federal agencies). The Division monitors 34 offshore oil, gas, and utility (water) pipelines ranging from 3 inches to 24 inches diameter (a majority are 6 to 12 inches diameter) that extend a distance of 0.5 to 9.6 miles in state waters. Statewide, 11 pipelines originate from state facilities and 23 federal pipelines pass through state waters. All pipelines that cross state waters carrying oil and gas are inspected annually. Staff conducts internal inspections by pumping an electronic magnetic flux tool through the pipeline. A hydrostatic test to 1.5 times the maximum operating pressure of the pipeline is required if a smart pig run is not mechanically feasible. The test equipment and procedures must have prior approval, and the test results must be reviewed and approved by Mineral Resources Management Division engineers. Staff conducts external inspections of submerged pipelines using a diver or remote operating vehicle. The external inspections detect damage, movement, free spans (unsupported section of pipeline), or foreign objects lying across the pipeline that may cause failure owing to physical movement or accelerated corrosion. Videotapes and diver reports of external pipeline inspections are reviewed by Division engineers, and corrective actions, if necessary, are coordinated with the pipeline operator.

The Mineral Resources Management Division staff review and comment on oil spill contingency plans for each oil and gas facility to ensure the best achievable protection of state waters and natural resources. The Office of Spill Prevention and Response approves the plans.

The Mineral Resources Management Division reviews offshore oil and gas drilling and production facility operations manuals. All oil and gas drilling and production operations, whether platforms, islands, or pipelines, are required to prepare operations manuals that meet or exceed our regulations and industry standards, and to keep those approved manuals on site and available to the crews working on those facilities. The Division helps ensure that operators meet regulatory requirements by reviewing operations manual amendments, consistent with Article 3.6.