The Systems Reliability Section (SRS) oversees the Quality Control – Failure Incident Team (QC-FIT) technical evaluations. SRS/QC-FIT evaluates incidents, reported concerns of manufactured equipment and/or systems with identified quality assurance/quality control (QA/QC) concerns, and/or improper "fit for service," which may impact safe oil and gas operations and the environment on the Outer Continental Shelf (OCS). The SRS/QC-FIT technical evaluations may identify the following: gaps in requirements for equipment manufacture and performance among industry standards, and/or the need for new industry standards and/or regulations; QA/QC design, manufacture and performance issues for equipment and/or systems utilized for offshore oil and gas operations. SRS/QC-FIT technical evaluations are distinct from District Form 2010 Incident Investigations or regional panel investigations which focus on field operational procedures, regulatory compliance, plans and permits. SRS/QC-FIT evaluations may recommend the need for further applied technology studies to address QA/QC performance reliability concerns of new equipment or technology which may not have an applicable existing industry standard and/or regulation. SRS/QC-FIT evaluations makes recommendations through official reports to the BSEE Director to improve the safety, reliability, and performance of equipment, and environmental protection during offshore oil and gas operations performed on the OCS.
QC-FIT Goals
Determine if a piece of manufactured equipment is “fit for service.”
Evaluate the equipment “life cycle” from design and construction through its use, inspection, maintenance, and retirement.
Provide an independent validation and verification of manufacturer recommendations/specifications that impact QA/QC, performance, and reliability.
Recommend changes to BSEE policy, procedures, Notice to Lessees (NTLs), and/or regulations that will promote continuous improvement in the regulatory regime for offshore oil and gas operations, which may include:
- Recommend modification of an existing regulation;
- Promulgation of a new regulation;
- Recommend incorporation of a new and/or modified industry standard
Recommend changes, improvements, requirements to industry standards which promote QA/QC improvements of equipment or systems’ manufacture, performance, reliability and safe operation; which may include:
- Recommendation for the development of anew industry standard;
- Identification of gaps in requirements among industry standards, become involved in the revision of industry standard requirements;
Recommend issuance of a Safety Alert or an applied technical research studies, e.g. a joint industry research project (JIP) specifically addressing an issue identified during the QC-FIT evaluation.
Recommend improvements which BSEE can implement to ensure that the use of best available and safest technology (BAST) is implemented during all phases of offshore oil and gas operations.
QC-FIT Technical Evaluation
The QC-FIT Technical Evaluations utilizes several sources for information and interacts with many other branches and agencies in addition to OEMs throughout the course of an evaluation. The evaluations are augmented through the interaction between BSEE’s District, Regions and branches such as the Offshore Safety Improvement Branch (OSIB), Best Available Safest Technology Branch (BAST), and the Risk Assessment and Analysis Branch, as well as national laboratories such as Department of Energy Argonne National Laboratory and NASA.
Complete QC-FIT Technical Evaluations
Jump to a section below
QC-FIT Connector and Bolts Failures
QC-FIT Seal Assemblies and Cement Failures
QC-FIT Addendum II Bolt Failures
QC-FIT Connector and Bolts failure
During drilling operations in the Gulf of Mexico (GOM), leaks were detected which identified failure, severe stress corrosion cracking fracture of bolts on the lower marine riser package (LMRP). The QC-FIT evaluated QA/QC concerns of bolts failure on the connector on a lower marine riser package (LMRP). There were QA/QC issues with second and third tier sub-contracted vendors that performed heat treatment processes and QA/QC manufacture, design, and material properties (hardness) issues with the bolts for effective subsea operation.
After learning of the December 18th incident, BSEE worked with the operator to ensure that the company replaced any faulty bolts that were in use in equipment deployed on the Outer Continental Shelf (OCS), in a timely manner. Replacement bolts for all known H4 connectors were sent to customers worldwide. This process resulted in the replacement of more than 10,000 bolts over a relatively short time frame and short-term disruption of related deepwater activities. This report was completed and publicly released August 2014.
Key Findings and Recommendations
The failure of the GE H4 connector bolts was primarily caused by hydrogen induced stress corrosion cracking (SCC) due to hydrogen embrittlement. Bolt coatings were not processed in accordance with the latest edition of ASTM B633 coating standard. Existing industry standards do not adequately address bolting/connector performance in subsea marine applications. BSEE is working to improve industry standards by encouraging industry standard committees to develop a consistent set of standard material properties requirements for the manufacture of fasteners; Request API and ASTM further revise its relevant standards and request that industry issue guidance or a standard for the optimal voltage limits for cathodic protection systems.
The quality management system (QMS), which met the industry standards and certification programs, qualified and audited only first-tier level suppliers and not others in the supply chain. BSEE is encouraging industry to develop an improved quality management standard that addresses multiple tier subcontractors and promoting failure reporting involving critical safety equipment.
BSEE has initiated joint industry research initiatives that studies fastener design and fitness for service.
BSEE may develop regulations that ensure specific design standards are met.
QC-FIT Connector and Bolts Failure report.
Click for more information on bolt failures.
QC-FIT Fastener Failures
Failed studs (connectors) were identified during an in-between well maintenance inspection on the LMRP of a BOP. The failed connectors’ material hardness was out of the manufacturer’s material design specification. An unapproved, sub-contracted third-tier vendor did not follow the manufacturer’s heat treatment procedure. This QC-FIT evaluated QA/QC concerns of fastener failures on the connector on a BOP collet connector flange. Several QA/QC issues were identified throughout the manufacturing process with second and third tier sub-contracted vendors. QA/QC manufacturing oversights resulted in the improper heat treatment and raw material orders for several lots of fasteners. The failed fastener’s had material properties (hardness) out of specification which led to issues with the bolts for effective subsea operation.
Key Findings and Recommendations
Existing industry practices and BSEE regulations related to QA/QC and quality management systems may not be adequate to ensure that critical components are manufactured as fit for service at all levels of the manufacturing supply chain. BSEE should consider modifying its regulations to ensure that the integrity of all critical components can be verified throughout the manufacturer’s supply chain.
The failure mechanism of subsea fasteners is not fully understood. Industry and/or BSEE should perform scientific studies to test the conditions fasteners are exposed to in subsea service, in order to better understand and predict the failure modes of fasteners.
A comprehensive analysis of industry standards and best industry practices regarding the manufacture and service conditions of fasteners for use in subsea environments around the world needs to be performed by either BSEE or the industry, in order to minimize the risk of a loss of well control event.
Standards development organizations should collaborate on developing consistent global standards, based on scientific evidence and best practices, for material property requirements regarding fasteners.
QC-FIT Addendum Bolt Failure report.
Click for more information on bolt failures.
QC-FIT Seal Assemblies and Cement
During drilling operations in the GOM, a gas kick occurred in which the casing, cement and liner top seal assembly failed resulting in a loss of well control. The elastomeric based liner top seal assembly may not have been qualified for exposure to high operating temperatures and gas exposure. The QC-FIT evaluated the QA/QC “fit for service” concerns for liner seal assembly and cementing failures. Concerns with equipment (seal) “fitness for service” use for operational conditions, appropriate material selection, and with equipment test protocol verification and validation conditions. Current industry practices and BSEE regulations for pressure testing may not be sufficient to evaluate the integrity of the seal assembly and/or the cement column. Currently both barriers are not independently pressure tested, therefore the dual barrier system is tested as a whole. The performance rating of downhole equipment may not be clearly communicated or understood between operators and manufacturers globally.
Key Findings and recommendations
Existing industry practices and BSEE regulations related to pressure testing may not be adequate to evaluate the integrity of either the seal assembly or the cement column. BSEE should consider modifying its regulations to ensure that the integrity of these barriers can be verified after installation.
Operators should be required to verify that any pressure containing equipment installed downhole has been designed, tested, and rated for any potential loss of well control condition to which it might be exposed during its service life.
A comprehensive analysis of well designs utilizing shallow liners and sub mudline casing hangers needs to be performed by either BSEE or the industry to ensure that best engineering practices are being utilized to minimize the risk of a loss of well control event.
QC-FIT Seal Assemblies and Cement Failures.
QC-FIT Wing Valve
During qualification pressure testing of horizontal tree wing valve, the actuator fastener bolts became disengaged (flew off). The bolts were subjected to excessively high loads. There were design concerns with bolts not being long enough for the threads to fully engage the nuts which keep the housing together. The QC-FIT evaluated the “fit for service,” QA/QC design, manufacture, material, safety concerns for a horizontal tree wing valve. The technical evaluation identified safety and reliability concerns for an international 10,000 psi wing valve and actuator not meeting API 17D standards and possibly failing under pressure. There was also QA/QC design concerns regarding the low safety factors and poor design of the bolt studs which are not long enough to fully engage the nuts.
Key Findings and Recommendations
The OEM’s design specification outlined that the wing valve assembly was designed to a hydraulic operating pressure of 3,000 psi with a qualification test rating of 4,700 psi.
The OEM’s calculation analyses for the connector showed that a hydraulic operating pressure above 8,000 psi is required to produce this type of failure. This was based on the condition that all eight connectors had a minimum (worst case) thread engagement of 0.5 inches into the retainer ring (i.e. the depth that each connector was engaged into the retainer ring).
The minimum thread engagement did not meet the requirements of API 6A nineteenth nor twentieth editions and API 17D first edition standards.
The third party who informed BSEE of the failure noted several potential design deficiencies regarding the fitness for service for the wing valve assembly.
BSEE should request that API perform an assessment of the latest of API 6A twentieth edition and API 17D second edition to determine whether these documents provide adequate guidelines for the design and qualification testing of wing valve assemblies and associated equipment.
BSEE and industry should consider a joint industry project to assess whether there is a need for additional research related for wing valve assembly design and manufacturing processes, including qualification testing, over-pressurization protection via a safety relief valve, and material property requirements. This assessment should include an analysis of the following: optimal thread engagement; optimal material properties; and load designs for wing valve assemblies.
BSEE should evaluate whether incorporation by reference of API 6A twentieth edition into BSEE regulations would lead to an improvement in safety and environmental protection on the OCS.
QC-FIT Wing Valve Failures - QC-FIT Report #004
QC-FIT Sheaves Failures
While conducting drilling operations in the Gulf of Mexico (GOM), a drilling crew discovered a crack in a sheave on a drilling rig. The failed sheave was a dual web design, 78 inches in diameter, and was in service for five months. Additional cracked sheaves were identified on four rigs operating in GOM and one operating in Colombia. All of the affected 78-inch diameter dual web design sheaves were located in the derricks’ Crown Mounted Compensators (CMC). The QC-FIT evaluated the “fit for service,” QA/QC design, manufacture, material, safety concerns for the sheave. There were QA/QC design, manufacture concerns with the sheaves.
Key Findings and Recommendations
Design deficiencies that could result in failure which could pose a safety risk to personnel;
Whether the design and the material mechanical properties (yield and ultimate tensile strengths) were adequate to meet the anticipated operating conditions;
Whether the welding procedure used to create a hub-web weld joint was adequate for the design.
QC-FIT Sheaves Failures report.
QC-FIT Addendum II Bolt Failures
On October 13, 2015, while conducting initial latch-up blow out preventer (BOP) pressure and function testing on the Garden Banks block 216 Well Number 5 in 1,450 feet of water in the Gulf of Mexico (GOM); the Noble Paul Romano rig was unable to actuate the BOP high pressure blind shear ram (BSR) shear function. After several attempts to actuate the rams, the Noble crew discovered that the failure to operate the BOP BSR actuator was a result of failed actuator fasteners. Upon inspection of the BOP stack on the deck, Hess, Noble, Subsea Solutions and the Original Equipment Manufacturer (OEM) (National Oilwell Varco (NOV)) crew identified six of the eight fasteners fractured on the BOP BSR assembly.
Key Findings and Recommendations
Operators and inspectors should understand that the fastener failures are not limited to BOP BSR fasteners. There have been failures with fasteners with higher hardness values in other BOP locations e.g. shear blades, connectors, lower marine riser package (LMRP) assemblies, etc. Inspections should be performed on these locations during maintenance when the BOP stack is retrieved to the surface.
Industry should perform a comprehensive review of manufacturing best practices, environmental service conditions, and relevant industry standards such as API, ASTM, ASME, NACE, NORSOK, ISO, etc. to develop consistent guidance for ideal material property requirements for the manufacture of fasteners used for critical subsea equipment.
Industry has addressed supply sub-tier vendor manufacturing QA/QC concerns in API 20E for fastener manufacturing. Efforts to address manufacturing QA/QC concerns for fasteners and other critical subsea equipment should continue since existing industry practices and BSEE regulations related to QA/QC and quality management systems (QMS) may not be robust enough to ensure that all manufactured components are “fit for service” throughout the supply chain. QA/QC practices should include controls for identifying non-conformities to industry standards and OEM specifications.
Industry should evaluate API Specification Q1, Ninth Edition, June 2014 including the addendums, “Specification of Quality Management Systems Requirements for Manufacturing Organizations for the Petroleum and Gas Industry” for the following:
- Consider including oversight and auditing of subcontracted second-tier, third-tier and lower tiered vendors who perform a manufacturing process into API Specification Q1. This requirement would ensure that all components manufactured throughout the supply chain are “fit for service.”
- Ensure that the API monogram program provides a sufficient auditing mechanism such that the OEMs are in full compliance with API Specification Q1 Ninth Edition.
- Consider including fasteners for critical equipment in the API monogram program.
API has funded a plating subcommittee to develop a matrix of various coatings and hardness levels to evaluate fasteners’ susceptibility to hydrogen embrittlement performance. Industry should consider conducting a joint industry research project on fasteners to determine the ideal material and coating properties, design, torque specification based on the lubricant, installation, maintenance, human factors, fatigue loading, fastener thread manufacture, load capacity, cathodic protection, environment, and the impact of the stress load conditions on fastener performance and reliability during subsea service.
QC-FIT Evaluation Of Fasteners Failures Addendum II - QC-FIT Report # 006 July 2017