Weekly Compliance Digest – U.S. Well Control Final Rule
Oil and Gas and Sulfur Operations in the Outer Continental Shelf – Blowout Preventer Systems and Well Control
What is it?
Last week, the U.S. Department of the Interior (DOI) and the Bureau of Safety and Environmental Enforcement (BSEE) announced final well control regulations to reduce the risk of an offshore oil or gas blowout that could result in the loss of life, serious injuries or harm to the environment.
Following the Deepwater Horizon disaster in 2010, the DOI and BSEE issued a series of notices and regulations to improve safety offshore. In 2012, the BSEE published the final drilling safety rule, and addressed some key recommendations made after the Deepwater Horizon disaster. In this final rule announced last week, the BSEE closes gaps in existing requirements, addresses additional Deepwater Horizon recommendations, and updates BSEE regulations to reflect industry best practices.
The final rule builds upon findings and recommendations from several investigations and reports concerning the root causes of Deepwater Horizon, and extensive consultation with industry groups, equipment manufacturers, federal agencies, academia and environmental organizations, the DOI says. The rule addresses many dimensions of well control, including more stringent design requirements and operational procedures for critical well control equipment used in oil and gas operations on the U.S. Outer Continental Shelf. Specifically, the final rule addresses the full range of systems and equipment related to well control operations, with a focus on blowout preventer requirements, well design, well control casing, cementing, real-time monitoring and subsea containment.
Who is affected?
The final rule applies to the following industries:
- Crude Petroleum and Natural Gas Extraction (NAICS code 211111)
- Drilling Oil and Gas Wells (NAICS code 213111)
What are the requirements?
Specifically, the final rule:
- Incorporates the latest industry standards that establish minimum baseline requirements for the design, manufacture, repair, and maintenance of blowout preventers (BOPs).
- Requires more controls over the maintenance and repair of BOPs.
- Requires the use of dual shear rams in deepwater BOPs, which is now included in a baseline industry standard (API Standard 53).
- Requires that BOP systems include a technology that allows the drill pipe to be centered during shearing operations.
- Requires more rigorous third party certification of the shearing capability of BOPs.
- Expands accumulator capacity and operational capabilities for increased functionality.
- Requires real-time monitoring capability for deepwater and high-temperature / high- pressure drilling activities.
- Establishes criteria for the testing and inspection of subsea well containment equipment.
- Increases the reporting of BOP failure data to BSEE and the OEMs.
- Adopts criteria for safe drilling margins consistent with recommendations arising out of the Deepwater Horizon disaster.
- Requires the use of accepted engineering principles and establishes general performance criteria for drilling and completion equipment.
- Establishes additional requirements for using remotely operated vehicles (ROV) to function certain components on the BOP stack.
- Requires adequate centralization of casing during cementing.
- Makes the testing frequency of BOPs used on workover and decommissioning operations the same as drilling operations.
Click here for more details on each of the requirements provided above. The requirements in the final rule will be phased in over several years to ensure an orderly transition, the DOI says.
What is next?
As of today, the final rule has not been published yet in the Federal Register. The final rule will become effective 90 days after it is published in the Federal Register. Finally, this New York Times article includes reactions to the final rule from environmentalists, oil industry groups and other advocacy groups.
Visit Enablon Insights again next Friday for a brand new Weekly Compliance Digest!