The US lifted the six-month moratorium on deepwater exploration in October, while codifying new rules governing drilling safety and well control. Russell McCulley looks at what the new regulations could mean for oil & gas companies doing business in the Gulf of Mexico.
The Drilling Safety Rule, part of a broader package of regulations put in place by the US Bureau of Ocean Energy Management, Regulation & Enforcement after the Deepwater Horizon disaster, includes provisions addressing wellbore integrity and requirements for subsea blowout preventers and related control systems. The rule makes mandatory the recommended practices set forth in the American Petroleum Institute standards for isolating potential flow zones during well construction, and require a professional engineer’s certification of cementing and casing plans.
‘The big thing that’s different [in the new drilling safety rule] is the requirement for independent engineer and third-party certifications.’ Steve Kropla, IADCThe BOEM rule requires ‘two independent test barriers across each flow path during well completion activities,’ permission from the agency to replace a heavier drilling fluid with a lighter one, and enhanced well control training for rig personnel.
The new rule, issued as an interim measure in late September, includes a number of recommendations regarding BOPs that were part of Interior secretary Ken Salazar’s 27 May safety report to President Obama (OE July).
Operators will be required to submit to the BOEM documentation and schematics of all control systems, get third party verification that a BOP’s blind shear rams are capable of severing any drill pipe present in the hole, and equip the subsea BOP stack with ROV intervention capability, including the ability to close one set of pipe rams, one set of blind shear rams and unlatch the well’s lower marine riser package. The rule requires floating drilling rigs to have an ROV and trained ROV crew onboard, mandates auto shear and deadman systems for DP rigs, and makes mandatory a range of tests and documentation.
Salazar, while announcing the drilling moratorium’s early end, said the administration was taking ‘a cautious approach when it comes to deepwater drilling’ and alluded to ‘a regulatory environment that will remain dynamic as we continue to build on the reforms we have already implemented’.
The new drilling safety rule ‘is a little more prescriptive with some of the requirements it places on operators, as far as their cementing procedures and completion procedures and well design go,’ says Steve Kropla, group VP of operations and accreditation at the International Association of Drilling Contractors.
‘What it mainly did was codify a number of provisions that were already in place, particularly under BOEM Notice to Lessees 2010-N05. The big thing that’s different is the requirement for independent engineer and third-party certifications. There really was no requirement previously for independent certification.
That was the responsibility of the operator, in the case of well design, and contractor, in case of the BOP, to make sure their equipment was functioning properly and capable of performing under the conditions that would be required.’ Oil & gas companies have been ‘somewhat troubled’, he says, by the rule’s ‘lack of definition and specificity on what exactly satisfies a number of things’, including who would be a qualified to certify casing and cementing plans.
The trade organization National Ocean Industries Association took issue with Salazar’s promise of a ‘dynamic’ regulatory environment. ‘That sounds good,’ NOIA president and former Minerals Management Service director Randall Luthi said in a statement released shortly after the moratorium was lifted. ‘In reality, however, it introduces another level of uncertainty to a regulatory process that has come to be less predictable than in many under-developed nations around the globe.’
The BOEM – formerly MMS – has released a set of FAQs to help clear up uncertainty over new regulations, and will likely refine the definitions further as the drilling permit approval process picks up speed. But some requirements remain vague: ‘The new rule puts emphasis on making sure ROV operators are properly trained,’ Kropla says. ‘Again, that’s not that well defined.’
The FAQs did indicate that BOP certification cannot be done by a contractor’s in-house engineering staff, Kropla says. ‘It could be done by one of the classification societies like DNV or ABS; it could be done by someone who is an API-authorized service center.’
DNV did step forward in October to issue a ‘recommended practice’ for the recertification of subsea BOP stacks that offers a guide through requirements and technical details. The company has had a similar set of guidelines for recertification of well control equipment on the Norwegian OCS for several years.
The auto-shear and deadman systems requirements for dynamically positioned rigs may not be that onerous. ‘A lot of DP rigs have these already,’ Kropla says. One provision that has generated a lot of concern, however, is the requirement for blind shear cutting capabilities. There was speculation early in the BP Macondo disaster that the shear ram may have struck the tool joint in the drillstring and thus been unable to sever the pipe. ‘The industry’s looking at different ways to identify where tool joints are in a drilling string, but that technology is not commonly used in drilling operations right now,’ he says.
As the rule stands now, ‘it doesn’t appear that [BOP] configurations will have to be altered much,’ Kropla says. ‘If [contractors] can show through some testing procedures that the BOP is capable of shearing the drill pipe that is to be used in the project, and they have an independent third-party certification of the equipment, they should be okay right now. What the future holds, we’re not entirely sure.’
Several items that were in Salazar’s 27 May safety report were not included in the new regulations, but could emerge in later refinement of the rules, he says.
One major change could be a requirement for double shear rams to provide a guard against tool joint interference; if future regulations require a considerable amount of space between the rams, the added weight and size could strain the hoisting and deck space capacity of some rigs, Kropla says.
‘For some of the older rigs, it’s going to be quite a bit of an issue to accommodate that extra space,’ he says. ‘If you do have a rather large [double shear ram] spacing requirement, that can cause real estate problems, especially on older rigs. You’re adding additional weight to the subsea stack that could affect the working deck load of the vessel and its hoisting equipment. And you may need a place to store the thing or otherwise accommodate it. The newer rigs are not going to have such a problem with this, because they are larger and were designed with bigger stacks in mind, but rigs built prior to late or mid-1990s might have an issue with it. If it becomes a regulation, it could prompt the exodus of older rigs.’
The safety rules make mandatory a previously voluntary option of having a safety case for floating drilling operations on the outer continental shelf – essentially, a risk management program that goes beyond the required safety and environmental management system (Sems), Kropla says. The joint industry task force set up after the Macondo incident recommended a companion document to the safety case, a well construction interface document: ‘a sort of risk management program for the well itself,’ Kropla says, and similar to what is required in the UK. ‘We anticipate that that’s one of the things that will probably be included in future rulemaking,’ he says.
In the end, the BP disaster’s legacy could include the move toward a more standardized approach to safety and regulation around the world.
‘One of the issues for contractors is that this is not really just a Gulf of Mexico situation,’ Kropla says. ‘A lot of international regulators and operators are taking a look at what is happening here in the Gulf of Mexico, and what happens here could frame the requirements for operating elsewhere.’ OE
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