(105d) Lessons Learned From Inspection 25,000 Upstream Oil and Gas Wells and Associated Plants

The inclusion of oil and gas wells sites and associated production facilities in OSHA's Process Safety Management (PSM) regulations stems from a 1998 accident at an oil and gas separation facility that killed four workers. In December 1999, the accident investigation resulted in OSHA rescinding their previous exclusion. Many well sites, processing facilities, and separation facilities then required inspection to comply with Recognized and Generally Accepted Good Engineering Practices (RAGAGEP). Oil and gas well sites and associated processing facilities represent a unique set of challenges when compared to inspection of more traditional process units in refining and chemical processing facilities. The purposes of this paper are to provide an overview of the methodology used to gather data in a manner which could be effectively analyzed, and to identify the most common high risk findings observed as a result of inspecting over 25,000 upstream oil and gas well sites and their associated processing facilities. An owner/operator's network of wells and processing facilities can have as many pressure vessels, piping circuits, and storage tanks as a chemical plant or refinery. However, a chemical plant or refinery occupies a small geographical area while well sites may be dispersed over thousands of square miles. The challenge of conducting an effective inspection program, maintaining accurate databases, and providing documentation for all of the equipment is daunting. These geographical problems can be compounded by conflicting naming conventions for well sites and equipment items. It is not uncommon for a well site to have more than one name in the owner/operators documents, and yet a different name on the well's sign. This is often a result of most wells having had multiple owners over their operational life. One of the most significant findings from inspecting thousands of well sites has been that there are a very limited number of frequently observed high risk conditions. Each of these high risk conditions represents a near miss. This paper identifies these common high priority items. Finally, there is a general assumption that just because a well site is new it would be able to pass an API-510 or API-570 inspection. However, this assumption does not hold up in the face of actual inspection which found that 40% or more of new well sites in may have high priority issues which need rapid remediation. The common high risk problems associated with new well sites will be discussed.