Immediately following the Deepwater Horizon tragedy,
the Department of the Interior and the Bureau of Safety and Environmental Enforcement (BSEE) issued
a series of notices and regulations to improve
safety offshore. The latest improvement, the proposed
drilling safety rule, addresses
key recommendations made after the Deepwater Horizon tragedy, closes gaps in existing
requirements, and updates
BSEE regulations to reflect
industry best practices. The proposed rule will:
•
Incorporate the latest industry
standards that establish minimum baseline requirements for the design,
manufacture, repair, and maintenance of blowout preventers (BOP).
o
Existing BSEE regulations do not include recently implemented
standards that industry believes are key to ensuring
the reliable performance of this equipment.
o
Adoption of these documents will ensure that
BSEE’s regulations match the performance requirements recommended by the industry in the time since the Deepwater
Horizon tragedy.
o
These requirements could
help to improve the reliability of surface
BOP stacks that have
typically been in
service much longer
than subsea BOP stacks.
•
Require more controls over the maintenance and repair
of
BOPs.
o Existing regulations contain requirements related to the maintenance and repair
of this equipment.
o
The proposed regulation requires an annual
review of the repair and maintenance records
of the BOP
equipment by a BSEE approved third party to ensure that the equipment continues to meet the original design
criteria. This ensures
that there will be
complete traceability of the equipment even if it is serviced or repaired in a foreign jurisdiction.
o
The proposed regulation contains a performance requirement that the equipment be maintained
pursuant to Original
Equipment Manufacturer (OEM) requirements, good engineering practices, and industry
standards.
o The proposed
regulation requires
complete traceability of critical components.
o
The proposed regulation includes
personnel training requirements for repairs
and maintenance.
o
The proposed regulation includes
as a regulatory requirement, the complete break-down & detailed physical
inspection of BOP not longer than every 5 years (currently an industry
standard).
•
Require the use of BOPs with double
shear rams, which is now a baseline industry standard
(API Standard 53).
o The use of double
shear rams in the
BOP stack increases
the likelihood that the drill pipe can be
sheared in an emergency.
o The proposed
regulation does not include the opt-out
provision that the standard
contains related
to double shear rams. There was disagreement within
the industry on whether this opt-out
provision was appropriate; however many studies/reviews have concluded
this will provide
another necessary
barrier for wellbore safety.
•
Require that shear rams be designed to include
a technology that allows the drill pipe to be centered during shearing operations.
o
Some experts believe that
the failure of the Deepwater Horizon BOP stack to sever the drill pipe was
due to the fact that
the drill pipe was not centered.
o At least one manufacturer is currently
marketing this technology.
•
Require more rigorous third party certification of the shearing capability of BOPs.
o Existing regulations require independent third-party verification
of shearing capability of BOPs, but
do not specify
any testing criteria.
o
This proposed change places increased controls over the shearing certification process and
criteria used to establish shearing performance.
•
Request comments on a potential
long-term requirement that a technology be installed
to allow all equipment
in the hole to be severed.
o
Existing BSEE regulations require that the
drill pipe be severed
and exclude other components in the drill string
from this requirement.
o Although the use of double shear rams and centering
devices increase the likelihood that a drill string can be severed, the inability to sever
components such as
drill collars can present
significant complications during a well
control event.
o This requirement
could help to drive innovation in safety technologies.
•
Expand accumulator capacity for increased functionality.
o
Increased accumulator capacity will help to ensure
that the BOP system will close and seal the
well.
•
Require real-time
monitoring capability for deepwater
and high-temperature/high- pressure
drilling activities.
o
The real-time monitoring requirement ensures that the operator has access to onshore technical expertise if needed and that there is another
“set of eyes” available during critical
operations.
o Many deepwater operators have onshore
real-time monitoring capability. This requirement ensures BSEE access to these facilities.
o The requirement also applies to shallow
water operators involved
in high-risk operations.
•
Establish criteria for the testing of subsea well containment equipment in the regulations.
o This supplements existing NTL 2010-N10
on well containment.
•
Increase the reporting of failure
data of BOP to OEMs by operators
and drilling contractors.
o
The proposed regulation adopts the voluntary industry reporting protocols for reporting equipment
issues.
o OEMS and drilling
contractors have
stated that reporting
of failure data is necessary to address key safety issues.
•
Adopt criteria for safe drilling margins consistent with Department of Justice and Office of the Inspector
General (DOI) recommendations arising out of the Deepwater
Horizon tragedy.
o Current regulations require the operator to show the planned drilling
margin on the Application for Permit to
Drill and do not
clearly define the term.
o The new regulations provide a detailed
definition of what constitutes a safe drilling margin and requires that a safe drilling margin be
maintained throughout drilling.
•
Require the use of accepted engineering principles and establishes general performance criteria for drilling
and completion equipment.
o
The proposed regulation requires that
packers and bridge
plugs meet industry standards.
o
The proposed regulation requires the use of accepted engineering practices when
operating on the OCS to
reduce risks.
o
The proposed regulation requires that
equipment has been designed, tested, and rated for the most extreme
conditions to which it will be exposed
while in service.
•
Establish additional requirements for using remotely operated vehicles (ROV) to assist in closing
the BOP stack.
o The current requirement contains general performance objectives for ROV.
o The proposed
regulation adopts
industry standards on ROV intervention capabilities. This provision
will help to standardize this equipment.
•
Establish additional guidelines for cementing and the use of centralizers.
o
The proposed regulation provides
a general performance obligation to ensure that the operator provides the centralization needed to ensure proper cementing
of the well.
•
Make the testing frequency of BOPs used on workover
operations the same as drilling operations.
o This change will reduce the testing frequency for BOPs in workover
operations.
This change
will result in less “downtime” during operations.
•
Request comments on changing the test frequency
for both workover and drilling BOPs from 14 days to 21 days.
o
BSEE has historically relied on pressure testing
of BOPs in the field to establish the reliability of BOP equipment.
o
BSEE requests reliability data to support
the change and requests comments on whether the proposed
requirements will increase
equipment reliability enough to justify
a 21-day test frequency.