The Bureau of Ocean Energy Management (BOEM) has requested more information from Royal Dutch Shell plc to determine if the company has addressed problems associated with its Chukchi Sea drilling program.
In a Jan. 14 letter, BOEM requested that Shell clarify some of the information it submitted in its Nov. 26, 2013 integrated operations drilling plan and request for additional information in Shell’s second revision of its Chukchi Sea exploration plan submitted Dec. 20, 2013. BOEM is not only seeking assurances that Shell has addressed the physical deficiencies associated with its Chukchi drilling activity, but that Shell’s management deficiencies have been fixed.
BOEM enquired as to whether Shell has modified the drilling rig Noble Discoverer (mid-water drillship) to prepare it for Arctic drilling. BOEM said it would accept the U.S. Coast Guard Certification of Compliance as demonstration that Shell has corrected the deficiencies cited by the Coast Guard in 2012. Shell will still need to resolve with the U.S. Environmental Protection Agency any air quality permit deficiencies. The EPA verified in a Dec. 26, 2013 letter that it had terminated Shell’s air quality permit.
Shell submitted its Safety and Environmental Management System audit plan Jan. 7 to BOEM, but must still complete its third party audit before it restarts drilling in the Chukchi Sea, BOEM said in the letter.
BOEM also said that certifications and approvals from the Coast Guard and the Bureau of Safety and Environmental Enforcement of the capping stack, containment dome, and associated vessels must be submitted before drilling commences.
Additionally, BOEM requested that Shell submit logging while drilling logs and an explanation of how Shell determined that permafrost is not present based on these logs. In its drilling of Burger A, Shell excavated the mudline cellar approximately 21 feet in diameter by 40 feet deep and drilled a pilot hole to approximately 1,500 feet below sea level that was continuously logged while drilling.
Other requests by BOEM for additional information include details on Shell’s well control plan, the inclusion in the second revised drilling plan a table outlining the schedule of the Polar Pioneer and support vessels to mobilize to the Burger prospect and drill a relief well.
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