BOPs with double shear rams, real-time monitoring of deepwater and HP/HT drilling activities and third-party reviews of BOP maintenance and repair are among the proposed well-control rules unveiled by the U.S. federal government.

The 264-page document detailing the U.S. Bureau of Safety and Environmental Enforcement’s (BSEE) proposal was announced April 13, nearly five years after the Deepwater Horizon accident in the U.S. Gulf of Mexico and following several investigations and reports.

“Blowout preventer systems are obviously a large focus of the rule. By adopting detailed requirements relating to their design, fabrication, maintenance and inspection we intend to increase their performance and reliability,” BSEE director Brian Salerno said during a media call. “We also seek to improve the quality of information that is collected on blowout preventer component failures. This will allow both BSEE and the industry to identify trends and note failures and ultimately help prevent accidents.”

Some of the proposed rules already have been adopted by the industry, which worked with regulators following Deepwater Horizon to improve operations, while others are new. The use of double shear rams in the BOP stack is one of the proposed rules that is now a baseline industry standard.

“This will dramatically reduce the possibility of a non-severable joint or other component impeding the function of this vital capability and increasing the likelihood that a well can safely be shut in during an emergency,” Salerno said of the practice, which was created by the American Petroleum Institute.

However, unlike the API standard, the federal rule does not include an opt-out provision.

The proposal also:

  • Incorporates the latest industry standards establishing minimum baseline requirements for the design, manufacture, repair and maintenance of BOPs;
  • Requires an annual review of repair and maintenance records of BOP equipment by a third-party, approved by BSEE, to ensure the equipment still meets original design criteria;
  • Requires that shear rams include technology that allows drill pipe to be centered during shearing operations along with more rigorous third-party verification of the BOPs shearing capability;
  • Requires expanded accumulator capacity to help ensure the BOP system will close and seal the well;
  • Requires used of accepted engineering principals and establishes general performance criteria for drilling and completion equipment;
  • Adopts industry standards on ROV intervention capabilities;
  • Establishes criteria for testing subsea well containment equipment; and
  • Establishes more guidelines for cementing and use of centralizers “to ensure that we have proper cementing jobs and allow for a more secure well,” Salerno said.

In addition, companies will be required to have real-time monitoring capability for deepwater and HP/HT, providing another “set of eyes” onshore during critical operations. The proposed rule, which gives BSEE access, also would apply to shallow-water operators involved in high-risk operations, BSEE said.

The rules also would mandate operators and drilling contractors report BOP failure data, but it reduces the testing frequency BOPs used on workover operations to the same as that of drilling operations.

Another requirement would mandate operators submit their drilling plans with a description of the pressures and the well control options they will employ during the drilling of a well, Salerno said.

“This is a comprehensive rule containing both prescriptive- and performance-based requirements that will reduce risks and save lives,” he added.

But the government specifically asked for the industry’s thoughts on a possible 10-year requirement for BOP shear ram technology that is capable of severing anything downhole to help seal off open wells. That technology does not currently exist, Salerno said, adding BSEE wants to know whether that is realistic.

BSEE estimates the rule would cost the industry about $88 million each year for the next 10 years; however, federal officials said some of the proposed rules are already being undertaken by companies.

Comments on the rules will be taken for 60 days and the rules would take effect about three months after being finalized.

The American Petroleum Institute (API) is reviewing the proposed rules and “hope they will complement industry’s own efforts to enhance safety,” upstream group director Erik Milito said. The group has revised or created more than 100 industry standards, including for BOPs, in the last five years aimed at improving E&P operations.

“A great deal of effort has been put into strengthening spill containment and response, but our first goal is always to prevent accidents from happening at all,” Milito said. “Our industry is committed to meeting the nation’s energy needs while maintaining safe and environmentally responsible operations.”

National Ocean Industries Association President Randall Luthi said the association is reviewing the proposal “line by line and word by word.”

“We are keenly interested in the proposed design and function changes for blow out preventers, requirements for dual shear rams, real-time monitoring, testing schedules for exploration, workover and decommissioning operations and the hot stab requirements,” Luthi said. “We are concerned that reasonable and necessary time is allowed for proposed design and manufacturing modifications and that third-party certifications are a useful tool for verifying safety measures and not merely an increase in a bureaucratic process.”

He added that 60 days may not be enough time to sufficiently review the proposed rules and give meaningful feedback.

“Safety is the first priority offshore, and industry will always strive to continue improving,” Luthi said. “Transparent, thorough and two-way communications between the regulator and industry will greatly enhance all efforts for safe and clean operations.”

Contact the author, Velda Addison, at vaddison@hartenergy.com.

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