‘Box-ticking’ GoM is 20 years behind Europe in risk-based structural integrity: Hess

Structural Integrity Management approaches in the Gulf of Mexico lag 20 years behind the North Sea, but the move off the shelf and into deeper water, plus the growing need to extend the life of assets, should force a shift to risk-based analysis, Doug Kemp, Hess Corporation’s offshore integrity advisor for Americas and West Africa, said.

Smaller operators in the shallow-water Gulf resist the more proactive approach to integrity management enshrined in the American Petroleum Institute’s new Recommended Practice (RP) 2SIM guidelines, but the move into deepwater projects will make change inevitable, Kemp told Upstream Intelligence.

“The Gulf of Mexico is probably about 20 years behind Europe in terms of general integrity practices. That’s kind of the lower end, the smaller operators. They’re very, very prescriptive based. They work to the letter of CFR250 and no more, and that goes to the application of, previously, RP2A, and then 2SIM,” Kemp said.

RP2SIM, published in November 2014, provides new guidance for managing the structural integrity of fixed offshore structures. Expanding on the recommendations for surveys and assessing existing platforms contained in API 2A-WSD, 2SIM is seen as promoting a more proactive approach to structural integrity risks. But Kemp said most of the industry is still locked in a box-ticking frame of mind.

“Even the recommended practice they look at as a rule,” he said. “Any they don’t question why they’re doing it, and they don’t even value analysis based on the trending of data. They do the activity, they get a pass and, from that perspective, they’re good and they can put a tick in the box for integrity. But they don’t do any intelligent thought beyond that, generally.”

Pinpointing risk

Kemp said operators can benefit from a proactive, risk-based approach as it provides a detailed and educated assessment which is tailored to the asset in question.
“You’re finding those areas that are risk hotspots particular to that asset – it’s operating conditions, its environment, its design parameters – and you’re going to go after the risk triggers and monitoring those in a way that’ll give you the best probability of protection.”

Hess and other bigger operators are moving towards the more proactive approach, which takes the recommended practice as a minimum requirement, but smaller operators resist change because they don’t see the need for it, Kemp said.

Compared to the North Sea, the shallow-water Gulf has smaller jackets of generic design, largely unmanned, operating in relatively benign conditions (when it isn’t hurricane season).

Furthermore, the proactive approach incurs costs. “If you’re going to have an iterative process and you’re going to work off your data and start to trend things, you’ll need to employ someone who can understand what that data’s telling you,” Kemp said.

But things should change, Kemp said. One driver will be the move into deeper water, where there are risks associated with more complex assets which have processing infrastructure and include non-generic types, such as FPSOs and semi-submersibles.

Kemp is concerned the box-ticking philosophy of the shelf is being reapplied to deeper projects.
“The problem that the Gulf of Mexico has is that it extrapolated those operating, design and integrity philosophies into deep water,” he said.

“They didn’t really mature when they moved into deep water in the late 1990s and early 2000s. They just followed the same practices. In deep water your risk profile is completely different, but operating practices didn’t mature and change," he said.

“Even after Macondo and more recent incidents we revisited pressure containment issues but from a structural perspective I don’t think the revision in thinking has really matured. There’s no appetite for a safety case or performance-based protocol here in the Gulf. They still want a set of rules they can follow and tick off against.”

Life pressure

Another key driver towards the proactive approach will be asset lifespans, Kemp argued.

“The [reactive] approach deals with design life, but fails you in life extension,” he said. “The things you did to say you were okay to operate within your design life, they don’t answer the question of how much more can we get out of the structure now that we’ve exceeded design life."

“Tick-box exercises don’t answer that question. You have to go back to first principles and ask, what condition is the structure in and what’s the remaining capacity in that structure? By default you’re getting into a risk-based programme just by answering those questions.”

Operators should prepare for life extension decisions early in the lifetime of the facility, Hemp said.

“If you’re asking these facilities to do more, you want to monitor those things that are important to the facility from an early age, so you’ve got that dataset. So when you get into life extension you’ve got what you need for a proper analysis.”

Overall, Kemp predicts the influence of RP2SIM will be felt gradually. “2SIM will evolve slowly through the needs of life extension,” he said.

“It will happen to us unseen. Some operators are moving in that direction faster than others, not because of the RP but because of their own needs, and that’s filtering back to the rest.”