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Blowout Preventer Systems and Well Control Rule Proposed Revisions

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Blowout Preventer Systems and Well Control Rule Proposed Revisions

BSEE works to advance safe and environmentally sustainable offshore energy production for America, as authorized by the Outer Continental Shelf Lands Act of 1953. In response to Executive and Secretarial Orders directing BSEE to review regulations that potentially burden the development or use of domestically produced energy resources and appropriately suspend, revise, or rescind those that unduly burden the development of domestic energy resources beyond the degree necessary to protect the public interest or otherwise comply with the law, BSEE proposes the revisions described below to existing regulations for well control and blowout preventer systems.

After thoroughly reviewing the original Blowout Preventer Systems and Well Control rule (WCR) and its subsequent implementation, BSEE identified provisions that can be revised to reduce unnecessary regulatory burdens while ensuring that any such activity is safe and environmentally responsible.

This rulemaking proposes to revise current regulations that impact offshore oil and gas drilling, completions, workovers, and decommissioning activities. The proposed regulations would also address various issues that were identified during the implementation of the current well control regulations, as well as questions that have required substantial informal guidance from BSEE.

Highlights

What does the proposed revised rule not do?

  • Eliminate the BOP requirements or the BOP itself.
  • Remove real-time monitoring requirements.
  • Remove drilling margin requirements.
  • Remove third party requirements for BOP testing.
  • Remove failure reporting to BSEE.
  • Eliminate the BOP dual shear ram requirement.
  • Remove the requirements of the Remotely Operated Vehicle (ROV).
  • Eliminate the containment requirements for a fast response if a blowout were to occur.

What does the proposed revised rule accomplish?

  • Allows lease holders to use real time monitoring in a less prescriptive way and allows for it to be adaptive based off of the lease holder’s needs.
  • Allows for the combination of the shearing rams to be able to shear the pipe, tubing or wireline in the hole.
  • Reduces the amount of alternate compliances granted since the 2016 rule.

BSEE carefully analyzed all 342 provisions of the 2016 WCR and determined that 59 of those provisions -- or less than 18% of the 2016 Rule -- were appropriate for revision. The proposed rule would include, but is not limited to, the following revisions:

  • Clarify the rig movement reporting requirements.
    These revisions would address notifications of rig movements to and from the safe zone during permitted operations and any additional rig movements if a rig unit is already on a well. The original WCR did not address these provisions, however based upon BSEE experience, BSEE determined that these clarifications would minimize the number of duplicative rig movement notifications submitted to BSEE.
     
  • Clarify and revise the requirements for certain submittals to BSEE
    There are several redundant reporting requirements in the current regulations. These revisions would clarify and streamline certain submittals to BSEE and eliminate redundant and unnecessary reporting. Many of these proposed revisions were not associated with the original WCR and reflect current BSEE policy, practice, and experience.
     
  • Revise section 250.723 to remove lift boats from the types of vessels that require a shut-in of producing wells when they approach within 500 feet of a platform.
    Removing the references to lift boats from these requirements would minimize the number of unnecessary well shut-ins and delayed production. Since the original WCR, BSEE reevaluated the lift boat activities, and determined that the vast majority of lift boats used on the OCS are relatively small when compared to the size of a mobile offshore drilling unit (MODU) and would not have the same operational impacts and potential risks as a MODU.
     
  • Remove certain prescriptive requirements for real time monitoring.
    Based upon BSEE’s evaluation of real time monitoring since the publication of the original WCR, BSEE determined that the prescriptive requirements for how the data is handled may be revised to allow company-specific approaches to handling the data while still receiving the benefits of real- time monitoring.
     
  • Replace the use of a BSEE approved verification organization (BAVO) with the use of an independent third party for certain certifications and verifications of BOP systems and components, and remove the requirement to have a BAVO submit a Mechanical Integrity Assessment report for the BOP stack and system.
    Independent third parties have been utilized as a long-standing industry practice to carry out certifications and verifications similar to those which a BAVO would do. BSEE expected most of the companies or individuals currently being used as independent third parties to apply to become a BAVO. Since the publication of the original WCR, BSEE has increased its interaction with the independent third parties to better understand how they operate and carry out certifications and verifications. BSEE has determined that if, as expected, the majority of BAVOs would be drawn from the existing independent third parties who would continue to conduct the same verifications, additional BSEE oversight and submittal to become a BAVO would be unnecessary. The BAVO system implemented by the WCR would increase procedural burdens and costs without giving rise to meaningful improvements to safety or environmental protection.
     
  • Revise the accumulator system requirements and accumulator bottle requirements to better align with API Standard 53.
    These revisions would increase operator flexibility to utilize the appropriate accumulator capacity to perform the necessary emergency functions and by closing each required shear ram, ram locks, one pipe ram, and disconnect the LMRP. Through the implementation of the original WCR, BSEE was able to better evaluate the effects of the original WCR accumulator requirements impacting subsea BOP space and weight limitations. This revision would help ensure that the regulatory requirements do not exceed the operational or mechanical design limits of the wellhead and BOP systems, and help minimize risks associated with approaching those design limits.
     
  • Incorporate the latest edition of an incorporated industry standard API 17H on remotely operated tool and interfaces on subsea production systems
    There is a conflict between the API RP 17H first edition referenced in the original WCR, and the API Standard 53 ROV requirements. The second edition of API RP 17H eliminates the conflict between the first edition and API Standard 53. BSEE would incorporate by reference API RP 17H second edition to ensure the appropriate methods are utilized to comply with the API Standard 53 ROV closure timeframes of 45 seconds.
     
  • Revise the control station and pod testing schedules to ensure component functionality without inadvertently requiring duplicative testing.
    These revisions would ensure that operators develop a testing schedule that allows for alternating testing between the control stations, and also between the pods for subsea BOPs. The intended result of alternating the testing is to ensure that each control station, and each pod for subsea, can properly function all required BOP components. Based on BSEE experience during the implementation of the original WCR, BSEE has concluded that these revisions would help ensure BOP functionality while not inadvertently requiring unnecessarily duplicative testing.
     
  • Include coiled tubing and snubbing requirements in Subpart G.
    These additions would codify current BSEE policy regarding the coiled tubing testing and recording requirements, and would also reintroduce similar provisions that were inadvertently removed in the original WCR.
     
  • Allow for the combination of the shearing rams to be able to shear the pipe, tubing or wireline in the hole.
    This revision would better align the functionality of the BOP system with API Standard 53 and the regulations. BSEE expects the operators to better evaluate how the BOP system, including both shear rams, would function together to comply with the required shearing capabilities.

This proposed rule does not affect 283 provisions of the original WCR including, but not limited to, the subject areas summarized below:

  • Controls over the maintenance and repair of BOPs.
    Existing regulations contain requirements related to the maintenance and repair of this equipment and a performance requirement that the equipment be maintained pursuant to Original Equipment Manufacturer (OEM) requirements, good engineering practices, and industry standards. The existing regulations still include personnel training requirements for repairs and maintenance.
     
  • Safe drilling margins
    In the proposed rule text, drilling margin requirements are unchanged. Current regulations allow for a deviation from the default 0.5 pound per gallon (ppg) drilling margin, for which a request and justification may be submitted with the Application for Permit to Drill (APD). BSEE is currently approving margins other than 0.5 ppg based on specific well conditions.
     
  • The use of BOPs with double shear rams, which is now a baseline industry standard (API Standard 53).
    The use of double shear rams in the BOP stack increases the likelihood that the ranges of drill pipe can be sheared in an emergency. The regulation still does not include the opt-out provision that the industry standard contains related to double shear rams for surface BOP installed on new floating facilities.
     
  • Rigorous third-party certification of the shearing capability of BOPs.
    Existing regulations require independent third-party verification of shearing capability of BOPs and still requires controls over the shearing certification process and criteria used to establish shearing performance.
     
  • Real-time monitoring capability for deepwater and high-temperature/high-pressure drilling activities.
    BSEE would still require the ability to gather and monitor real-time well data using an independent, automatic, and continuous monitoring system capable of recording, storing, and transmitting data for the BOP control system, the well's fluid handling system on the rig, and the well's downhole conditions with the bottom hole assembly tools (if any tools are installed).
     
  • Criteria for the testing of subsea well containment equipment in the regulations.
    This supplements existing NTL 2010-N10 on well containment.
     
  • Reporting of failure data of BOP to OEMs by operators and drilling contractors.
    The current regulations still adopt the voluntary industry reporting protocols for reporting equipment issues. OEMs and drilling contractors have stated that reporting of failure data is necessary to address key safety issues.
     
  • Using accepted engineering principles and general performance criteria for drilling and completion equipment.
    The current regulation requires that packers and bridge plugs meet industry standards. The regulations still require the use of accepted engineering practices when operating on the OCS to reduce risks.
     
  • Use of remotely operated vehicles (ROV) to assist in closing the BOP stack.
    Based upon BSEE’s evaluation of real time monitoring since the publication of the original WCR, BSEE determined that the prescriptive requirements for how the data is handled may be revised to allow company-specific approaches to handling the data while still receiving the benefits of real- time monitoring.
     
  • Source control and containment.
    BSSE still requires operators to have access to, and the ability to deploy, source control and containment equipment (SCCE) necessary to regain control of the well.
     
  • Guidelines for cementing.
    The regulations provide a general performance obligation to ensure that the operator provides the centralization needed to ensure proper cementing of the well.
     
  • Testing frequency of BOPs used on workover operations
    BSEE testing requirements for testing of drilling, workovers, completions, and decommissioning operations are unchanged.
     
  • Process for changing test frequency for workover and drilling BOPs
    BSEE has historically relied on pressure testing of BOPs in the field to establish equipment reliability. BSEE requests reliability data from industry to support changing testing frequency requirements, as well as requesting comments on whether the proposed requirements would increase equipment reliability enough to justify a 21-day test frequency.

Updated April 26, 2018