Five years after the Deepwater Horizon disaster, the Department of the Interior has proposed new regulations that include more stringent design requirements and operational procedures for critical well control equipment used in offshore oil and gas operations.
The measures in the proposed rule, which will be open for public comments, are designed to improve equipment reliability, and build upon enhanced industry standards for blowout preventers and blowout prevention technologies as a major focus. The rule also includes reforms in well design, well control, casing, cementing, real-time well monitoring and subsea containment.
BOPs. The blowout preventer, an essential piece of safety equipment used in offshore drilling operations, was a point of failure in the Deepwater Horizon event, but several other barriers failed as well. The cascade of multiple failures resulted in the loss of well control, an explosion, fire and subsequent months-long spill.
The BOP equipment and systems can be the last defense against a release of hydrocarbons into the environment when all other forms of well control have failed, the text of the proposed rule notes. The BOPs may also be the last line of defense in preventing release of gas that is volatile and considered to be an extreme safety hazard to rig personnel (uncontrolled gas releases can lead to explosions).
The primary purpose of BOP systems is to prevent the uncontrolled release of hydrocarbons in an emergency situation by mechanically closing valves or rams that block the flow of fluid from the well. In some situations, this may require shear rams on the BOP stack to sever the drill pipe before the well can be sealed.
BOP equipment and systems have increased in complexity as the water depth for offshore wells has increased and the industry develops reservoirs with pressures greater than 15,000 pounds per square inch (psi) or temperatures greater than 350 ˚F (177 ˚C). Reservoirs with these conditions are considered high pressure high temperature (HPHT).
Most of the BOPs that are used in deepwater operations (400 to 10,000 feet / 122 - 3,048 meters) are located on the seabed, which also presents technological and operational challenges. Additionally, HPHT operations create special metallurgical and design issues. In this rulemaking, BSEE intends to:
Implement many of the recommendations related to well-control equipment and fill gaps in the regulatory program.
Increase the performance and reliability of well-control equipment, especially BOPs.
Improve regulatory oversight over the design, fabrication, maintenance, inspection, and repair of critical equipment.
Gain information on leading and lagging indicators of BOP component failures, identify trends in those failures, and help prevent accidents.
Ensure that the industry uses recognized engineering practices, as well as innovative technology and techniques to increase overall safety.
Interior’s Bureau of Safety and Environmental Enforcement (BSEE) thoroughly analyzed the results of the investigations, including nearly 370 specific recommendations, and conducted extensive outreach to derive further enhancements from stakeholder input, academia, and industry best practices, standards and specifications.
We worked to collect the best ideas on the prevention of well control incidents and blowouts to develop this proposed rule—including knowledge and skill sets from industry and equipment managers. This rule proposes both prescriptive and performance-based standards that are based on this extensive engagement and analysis.—Assistant Secretary for Land and Minerals Management Janice Schneider
BSEE has already implemented several of the recommendations in rulemakings following the Deepwater Horizon incident. BSEE included the following recommended items included in the proposed rule; these arose out of the investigation reports or from other third-party recommendations:
Shearing requirements. Current equipment would not shear drill collars, heavy weight drill pipe, or drill pipe tool joints. This inability to shear all of the components in the drill string can create significant complications in an emergency situation and increase the likelihood of a catastrophic event occurring, BSEE said. As the industry continues to develop more technically challenging resources, shearing and sealing become more difficult for several reasons, including:
The improvements in drill pipe properties, particularly increased material strength and ductility, result in higher forces being required to shear the drill pipe in the future.
Increased water depths, in combination with drilling fluid density and shut-in pressure, contribute to a BOP having to generate additional force to successfully shear.
In this rule, BSEE is proposing to:
Require operators to assure that shearing capability for existing equipment complies with BSEE requirements related to shearing by performing tests and providing detailed results to a BSEE-approved verification organization.
Require compliance with the latest industry standards contained in API Standard 53. In addition to these industry standards, BSEE would also include a requirement that operators use two shear rams in subsea BOP stacks. The use of double shear rams would increase the likelihood that a drill string can be sheared by ensuring that a shearable component is opposite a shear ram. In this proposed rulemaking, BSEE will not propose adopting the provision in API Standard 53 that operators can “opt out” of this double shear ram requirement for moored rigs.
Require 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. Following the Deepwater Horizon incident, industry recognized the need to enhance BOP guidance and concluded that it was necessary to completely rewrite the older API RP 53—Recommended Practices for Blowout Prevention Equipment Systems for Drilling Wells, Third Edition, March 1, 1997 (Reaffirmed September 1, 2004)—and upgrade the document from an RP to a standard.
BSEE believes that the incorporation of this document, and other key industry standards, such as ANSI/API Spec. 6A, ANSI/API Spec. 16A, API Spec. 16C, API Spec. 16D, ANSI/API Spec. 17D, and API Spec. Q1, would establish minimum design, manufacture, and performance baselines for this equipment and is essential to ensure the reliability and performance of this equipment.
Third-party verification. In several sections of the proposed regulations, BSEE would require third- party verification of the design, maintenance, inspection, testing, and repair of BOP systems and equipment by a BSEE-approved entity.
The BSEE is also proposing an additional qualification and verification process for BOP(s) and related equipment used in HPHT wells. The verification must be specific to the conditions of the particular well at which the BOP(s) will be used.
Failure reporting/near-miss reporting. Several of the standards that BSEE proposes to incorporate by reference contain failure reporting processes that ensure that operators share information with OEMs related to the performance of their equipment.
Safe drilling practices. The proposed regulations include new requirements related to the maintenance of safe drilling margins consistent with the recommendations arising out of Deepwater Horizon investigations. The BSEE also proposes to add requirements related to liners and other downhole equipment.
The proposed rule would require that operators have the capability to monitor deepwater and HPHT drilling operations from the shore and in real time. This would allow operators to anticipate and identify issues in a timely manner and to utilize onshore resources to assist in addressing critical issues. It would allow BSEE greater visibility of operations so BSEE may focus on specific critical operations for additional oversight.
The proposed regulation would also include requirements concerning ROV operations, including the adoption of API RP 17H to standardize ROV hot stab activities. An ROV hot stab is a high pressure subsea connector used to connect the ROV into the BOP system. An ROV hot stab basically comprises two parts: a valve and a tool that connects onto the valve and controls the valve. The valve is usually placed on the subsea BOP stack panel, and is accessible for an ROV to insert the tool and activate certain functions on the BOP.
BOP testing. BSEE proposes to modify the BOP testing frequency for workover and decommissioning operations.
Well control. The well control measures would implement multiple recommendations from various investigations and reports of the Deepwater Horizon event, including the Bureau of Ocean Energy Management, Regulation and Enforcement/US Coast Guard Joint Investigation-Forensic Equipment Analysis (September 2011); National Academy of Engineering (May 2012); National Oil Spill Commission (January 2011); Ocean Energy Safety Advisory Committee; Government Accountability Office and others.
In addition to more stringent design requirements, the proposed rule requires improved controls of all repair and maintenance activities through the lifecycle of the blowout preventer and other well control equipment. It would provide verification of the performance of equipment designs through third party verification, enhanced oversight of operations through real-time monitoring viewed onshore, and require operators to, during operations, utilize recognized engineering best standards that reduce risk.—BSEE Director Brian Salerno
The Outer Continental Shelf accounts for more than 16% of the US oil production and about 5% of domestic natural gas production, bringing in revenues of over $7.4 billion dollars to the Treasury in 2014. There are more floating deepwater drilling rigs working in the Gulf of Mexico today than prior to the Deepwater Horizon spill, and drilling activity is expected to steadily increase over the coming year.
The public may submit comments on the proposed regulations during the 60-day comment period that begins 15 April 2015, when the proposed rule is published in the Federal Register.