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June 22, 2010 - ASCE Letter - Improve Federal Design and Construction Standards for Off-Shore Drilling

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June 22, 2010

The Honorable Barack Obama
President
The White House
Washington, D.C. 20500

Dear Mr. President:

On behalf of the 144,000 members of the American Society of Civil Engineers (ASCE), I am writing to support your administration’s efforts to improve federal standards for the design and construction of offshore oil-production systems pursuant to the Minerals Management Service (MMS) notice to the lessees and operators of federally permitted gas and oil leases issued on June 8, 2010.

NTL No. 2010-N05 establishes new casing and cementing design requirements in the design and construction for all offshore wells. It requires that lessees and operators must have all well casing designs and cementing program and procedures certified by a Professional Engineer (P.E.), verifying the casing design is appropriate for the purpose for which it is intended under expected wellbore conditions for any new surface or undersea well using a blowout preventer (BOP) stack.

This new standard, which complements the requirements for P.E.s to oversee the design and construction of mechanical and electrical systems on oil-production facilities found at 30 C.F.R. § 250.1628 (b) (4), will ensure the most rigorous engineering standards are applied to avoid future catastrophic oil spills offshore.

Meanwhile, ASCE stands ready to assist the government by providing the necessary technical and engineering experts to deal with the Deepwater Horizon petroleum discharge. The Coasts, Oceans, Ports, and Rivers Institute (COPRI) provides scientific and engineering knowledge in the sustainable development and protection of our coasts, ocean waters, ports, waterways, and wetlands.

In the past, ASCE has provided engineering technical assistance when asked by federal and state governments in response to engineering failures. Most recently, we reviewed the U.S. Army Corp of Engineers IPET report on the levee failures during Katrina. A key finding of ASCE’s report on the event was the need for clearer nexus between public safety and engineering design. The report states: 

"In the face of pressure to save money or make up time, engineers must remain strong and hold true to the requirements of the profession's canon of ethics, never compromising the safety of the public. Organizations must be structured to enable, not to inhibit, this focus on safety. Engineers must continually evaluate the appropriateness of design criteria. They must always consider how the performance of individual components affects the performance of a system." (Call to Action #10- Place Safety First, External Review Panel Report "The New Orleans Hurricane Protection System: What Went Wrong and Why, ASCE, 2007, p.82) http://www.asce.org/uploadedFiles/Publications/ASCE_News/2009/04_April/ERPreport.pdf

Since the release of that report ASCE focused a number of key efforts on developing a set of interdependent guiding principles to inform the nation’s approach to critical infrastructure (http://www.asce.org/Content.aspx?id=2147485369). The overarching principle for all critical infrastructure remains “Holding paramount the safety, health, and welfare of the public. The other guiding principles are:
• Quantify, communicate, and manage risk;
• Employ an integrated systems approach;
• Exercise sound leadership, management and stewardship in decision-making processes; and,
• Adapt critical infrastructure in response to dynamic conditions.

If ASCE can be of any assistance in helping your administration resolve the engineering problems facing the government in the Gulf of Mexico, please do not hesitate to contact Brian Pallasch, Managing Director of Government Relations and Infrastructure Initiatives, at 202-789-
7842 or at bpallasch@asce.org .

Sincerely yours,

Blaine D. Leonard, P.E., D.GE

Cc: Secretary Ken Salazar, Department of the Interior
Administrator Lisa Jackson, Environmental Protection Agency
Secretary Gary Locke, Department of Commerce
Chair Christina Romer, Council of Economic Advisors
Chair Nancy Sutley, Council on Environmental Quality
Majority Leader Harry Reid, United State Senate
Minority Leader Mitch McConnell, United State Senate
Speaker of the House Nancy Pelosi, United States House of Representatives
Minority Leader John Boehner, United States House of Representatives