A Collaborative Effort to Define the Application, Approval, and Monitoring Process for Subsea Dispersant Use

Abstract

ABSTRACT Since the Deepwater Horizon (DWH) well control incident in 2010, oil and gas operators have worked diligently with Federal and State government officials and source control management organizations to develop equipment, operating procedures, monitoring plans and new technologies to support subsea dispersant operations. Many drilling permits in the U.S. Gulf of Mexico include a subsea dispersant injection capability in their oil spill response contingency plans. These contingency plans are frequently tested during command post or functional exercises to demonstrate preparedness. A critical step in this type of well control event is requesting governmental approval for subsea dispersant use. Although several years have elapsed since the DWH incident, the use of subsea dispersants has not been formally approved during an exercise despite industry demonstrating the capability of implementing subsea dispersant operations. The API D3 Joint Industry Task Force (JITF) Subsea Dispersant project has worked with Clean Gulf Associates, Marine Well Containment Company (MWCC), Helix Well Control Group (HWCG) and both Gulf Regional Response Teams to develop and improve the API recommended model subsea dispersant monitoring plan, and standardized documents that can be used for requesting RRT concurrence for subsea dispersant use. As these documents have evolved in response to lessons learned from industry led exercises over the last three years, the API D3 JITF has also worked to identify and test emerging monitoring technologies available to support subsea dispersant use. Recent advancements include the new LISST-DEEP instrument for in situ droplet size analysis at depth and pressure, and improvements to optical dissolved oxygen probe technology. The Region VI Regional Response Team (RRT) has also begun a process to improve clarity on approval request procedures, and has tasked its Industry Work Group (IWG) with developing standardized forms and documents that could be used to request RRT concurrence with subsea dispersant use decisions. The IWG will coordinate with the API D3 JITF in developing those products. This paper will discuss the results of those efforts and present a recommended RRT concurrence request submittal package, which will include the API recommended model subsea dispersant monitoring plan, monitoring equipment recommendations, and operational plans with injection equipment recommendations.