Offshore operators in the US face toughened standards and new requirements for blowout preventers and other elements of their work under the final well-control rule issued Apr. 14 by the Department of the Interior (OGJ Online, Apr. 14, 2016).
The department’s Bureau of Safety and Environmental Enforcement developed the rule in response to the fatal Macondo blowout and spill in the Gulf of Mexico in 2010.
BSEE issued a final drilling safety standard in 2012 (OGJ Online, Aug. 16, 2012).
Not part of the new well-control rule but still under review, according to BSEE, are well-control planning, training, and certification; major rig equipment; certification requirements for personnel servicing critical equipment; choke-and-kill systems; mud-gas separators; wellbore fluid safety practices, testing, and monitoring; diverter systems with subsea BOPs; coiled tubing, snubbing, and wireline units; and additional severing requirements.
Key provisions
Following is summary of key provisions of the well-control rule:
• Shearing requirements. The rule requires reporting of BOP shearing performance testing and results to an approved verification organization to “ensure that shearing capability for existing equipment complies with BSEE requirements;” compliance with the latest industry standards contained in API Standard 53; the use by operators of two shear rams in subsea BOP stacks; and the use of BOP technology “that provides for better shearing performance through the centering of the drill pipe in the shear rams.”
• Equipment reliability and performance. The rule requires compliance with industry standards and cites examples from API and the American National Standards Institute. “BOP operability will be improved by establishing minimum design, manufacture, and performance baselines that are essential to ensure the reliability and performance of this equipment,” it says. The rule also requires inspection, maintenance, and repair of BOP-related equipment by appropriately trained personnel, saying, “This will also increase the reliability of BOP-related equipment.”
• Equipment failure reporting and near-miss reporting. The rule requires that operators share information with original equipment manufacturers (OEMs) related to the performance of their BOP system equipment. “This sharing of information makes it possible for the OEMs to notify all users of any safety issues that arise with BOP system equipment,” it says. The rule also requires that operators report any significant problems with BOP or well-control equipment to BSEE to enable the bureau to determine whether information should be provided promptly to OCS operators and, if appropriate, to international offshore regulators and operators.
• Safe drilling practices. The rule sets requirements for drilling margins and other matters related to liners and other downhole equipment “to help reduce the likelihood of a major well-control event and ensure the overall integrity of the well design.” It requires monitoring of deepwater and high pressure-high temperature drilling from shore and in real time. “This will allow operators to anticipate and identify issues in a timely manner and to utilize onshore resources to assist in addressing critical issues,” it says. The rule further requires daily reports to BSEE about any leaks associated with BOP control systems to “ensure that the bureau is made aware of any leaks so it can determine if further action is appropriate.” And it requires compliance with API Recommended Practice 17H to standardize remotely operated vehicle hot-stab activities. “This will allow certain functions of the BOP to be activated remotely,” it says.
• BOP testing. The rule requires the same pressure-testing frequency—at least once every 14 days—for workovers and decommissioning as for drilling and completions. “Pressure-test results will aid in predicting future performance of a BOP, and harmonizing testing frequencies for all well operations will also help streamline the BOP function-testing criteria and reduce the unnecessary repetition every 7 days of testing in workover and decommissioning operations that could pose operational safety issues,” it explains. And the rule requires additional measures—for example, real-time monitoring and increased maintenance—“to help ensure the functionality and operability of the BOP system that will help reduce the safety and environmental risks.”