April 2016 well control rule

152 Pages·2016·2.77 MB·English

Vol. 81 Friday,
No. 83 April 29, 2016
Part III
Department of the Interior
Bureau of Safety and Environmental Enforcement
30 CFR Part 250
Oil and Gas and Sulfur Operations in the Outer Continental Shelf—Blowout
Preventer Systems and Well Control; Final Rule
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25888 Federal Register/Vol. 81, No. 83/Friday, April 29, 2016/Rules and Regulations
DEPARTMENT OF THE INTERIOR APM Application for Permit to Modify RIA Regulatory Impact Analysis
BAST Best Available and Safest RIN Regulation Identifier Number
Bureau of Safety and Environmental Technologies ROT Remotely Operated Tools
Enforcement BAVO BSEE-Approved Verification ROV Remotely-Operated Vehicle
Organization RP Recommended Practice
BOP Blowout Preventer RTM Real-Time Monitoring
30 CFR Part 250
BOEM Bureau of Ocean Energy SBA Small Business Administration
[Docket ID: BSEE–2015–0002; 15XE1700DX Management SBREFA Small Business Regulatory
EEEE500000 EX1SF0000.DAQ000] BSEE Bureau of Safety and Environmental Enforcement Fairness Act of 1996
Enforcement SCCE Source Control and Containment
RIN 1014–AA11 BSR Blind Shear Ram Equipment
CFR Code of Federal Regulations Secretary Secretary of the Interior
Oil and Gas and Sulfur Operations in CVA Certified Verification Agent SEM Subsea Electronic Module
the Outer Continental Shelf—Blowout DHS Department of Homeland Security SEMS Safety and Environmental
Preventer Systems and Well Control DOCD Development Operations Management Systems
Coordination Document SIMOPS Simultaneous Operations
AGENCY: Bureau of Safety and DOI Department of the Interior Spec. Specification
Environmental Enforcement, Interior. DPP Development and Production Plan TAR Technical Assessment and Research
ACTION: Final rule. DWOPs Deepwater Operations Plans TBT Agreement Technical Barriers to Trade
ECD Equivalent Circulating Density Agreement
SUMMARY: Bureau of Safety and EDS Emergency Disconnect Sequence TIA Takings Implication Analysis
Environmental Enforcement (BSEE) is E.O. Executive Order TLPs Tension Leg Platforms
EOR End of Operations Report TVD True Vertical Depth
finalizing new regulations to
EP Exploration Plan USCG United States Coast Guard
consolidate into one part the equipment F Fahrenheit VBR Variable Bore Ram
and operational requirements that are FOIA Freedom of Information Act VSL Value of a Statistical Life
found in various subparts of BSEE’s FPSs Floating Production Systems WAR Well Activity Report
regulations pertaining to offshore oil FPSO Floating Production, Storage, and WTO World Trade Organization
and gas drilling, completions, Offloading Unit
workovers, and decommissioning. This FSHR Free Standing Hybrid Risers Executive Summary
final rule focuses on blowout preventer GOM Gulf of Mexico Following the devastating impacts of
GOMR Gulf of Mexico region
(BOP) and well-control requirements, the April 20, 2010, Deepwater Horizon
GPS Global Positioning Systems
including incorporation of industry incident on the Gulf of Mexico (GOM)
HPHT High Pressure High Temperature
standards and revision of existing IC Information Collection and the surrounding states and local
regulations, and adopts reforms in the IEC International Electrotechnical communities, multiple investigations
areas of well design, well control, Commission were conducted to determine the causes
casing, cementing, real-time well ISO International Organization for of the incident and to make
monitoring, and subsea containment. Standardization recommendations to reduce the
The final rule also addresses and JIT Joint Investigation Team likelihood of a similar incident in the
implements multiple recommendations LMRP Lower Marine Riser Package future. The investigative groups
LWC Loss of Well Control
resulting from various investigations of included:
MASP Maximum Anticipated Surface
the Deepwater Horizon incident. This Pressure —Department of the Interior (DOI)/
final rule will also incorporate guidance MAWHP Maximum Anticipated Wellhead Department of Homeland Security
from several Notices to Lessees and Pressure (DHS) Joint Investigation Team;
Operators (NTLs) and revise provisions MIA Mechanical Integrity Assessment —National Commission on the BP
related to drilling, workover, MMS Minerals Management Service Deepwater Horizon Oil Spill and
completion, and decommissioning MODUs Mobile Offshore Drilling Units Offshore Drilling;
operations to enhance safety and NAE National Academy of Engineering —Chief Counsel for the National
NAICS North American Industry
environmental protection. Commission; and
Classification System
DATES: This final rule becomes effective NARA National Archives and Records —National Academy of Engineering.
on July 28, 2016. Compliance with Administration Each investigation outlined several
certain provisions of the final rule, NAS National Academy of Sciences recommendations to improve offshore
however, will be deferred until the National Commission National Commission safety. BSEE evaluated the
times specified in those provisions and on the BP Deepwater Horizon Oil Spill and recommendations and acted on a
as described in Part III of the preamble. Offshore Drilling number of them quickly to improve
The incorporation by reference of NIST National Institute of Standards and offshore operations, while BSEE’s
Technology
certain publications listed in the rule is decision making with respect to other
NTLs Notices to Lessees and Operators
approved by the Director of the Federal recommendations followed additional
NTTAA National Technology Transfer and
Register as of July 28, 2016. Advancement Act input from industry and other
FORFURTHERINFORMATIONCONTACT: Kirk OCS Outer Continental Shelf stakeholders.
Malstrom, Regulations and Standards OCSLA Outer Continental Shelf Lands Act In April 2015, BSEE proposed
Branch, (202) 258–1518, or by email: OEM Original Equipment Manufacturer regulations to, among other things,
OFR Office of Federal Register incorporate industry standards and NTL
[email protected].
ES OIRA Office of Information and Regulatory guidance; consolidate into one part the
RUL SUPPLEMENTARYINFORMATION: Affairs existing equipment and operational
with List of Acronyms and References OMB Office of Management and Budget requirements that are found in various
PROD ANSI American National Standards PpEpsg PProoufnesdssi opnear lg Eanllgoinn eers parts of BSEE’s regulations; to revise
VN1 Institute psi Pounds per square inch and improve existing requirements for
SPT APA Administrative Procedure Act QA/QC Quality Assurance/Quality Control well design and control, casing and
K3 APD Application for Permit to Drill RCD Regional Containment Demonstration cementing; and to add new
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Federal Register/Vol. 81, No. 83/Friday, April 29, 2016/Rules and Regulations 25889
(RTM) and subsea containment. The (2) Revises the requirements for cost-beneficial. The estimated overall
proposed regulations also addressed Deepwater Operations Plans (DWOPs), cost of the rule (outside those costs that
many of the recommendations made by which are required to be submitted to are part of the economic baseline) over
the previously listed investigative BSEE under specific circumstances, to 10 years will be exceeded by the time-
bodies, which found a need to add requirements on free standing savings benefits to the industry resulting
incorporate well-control best practices hybrid risers (FSHR) for use with from the revisions to the former
to advance safety and protection of the floating production, storage, and requirements for BOP pressure testing
environment. BSEE received over 176 offloading units (FPSO). frequency for workovers and
public comments on the proposed rule, (3) Revises 30 CFR part 250, subpart decommissionings. In addition, the final
and considered those comments in D, Oil and Gas Drilling Operations, to rule will also produce benefits to
developing these final regulations. include requirements for: society, both quantifiable and
The requirements in this final rule, —Safe drilling margins; unquantifiable, by reducing the
including the revisions made to the —Wellhead descriptions; probability of well control incidents
proposed regulations, reflect BSEE’s —Casing or liner centralization during involving oil spills.
consideration of the comments and cementing; and
Table of Contents
BSEE’s commitment to address the —Source control and containment.
recommendations made in the (4) Revises subparts E, Oil and Gas I. Background
Deepwater Horizon reports. This final Well-Completion Operations, and F, Oil A. BSEE
B. BSEE Statutory and Regulatory
rulemaking: and Gas Well-Workover Operations, to
Authority and Responsibilities
(1) Incorporates all or designated include requirements for: C. Purpose and Summary of the
portions of the following industry
—Packer and bridge plug design; and Rulemaking
standards: —Production packer setting depth. D. Availability of Incorporated Documents
—American Petroleum Institute (API) for Public Viewing
(5) Revises Subpart Q,
Standard 53, Blowout Prevention E. Summary of Documents Incorporated by
Decommissioning Activities, to include
Reference
Equipment Systems for Drilling Wells,
requirements for: II. Organization of Subpart G
Fourth Edition, November 2012;
—Packer and bridge plug design; III. Discussion of Compliance Dates for the
—API Recommended Practice (RP) —Casing bridge plugs; and Final Rule
2RD—Design of Risers for Floating —Decommissioning applications and IV. Issues Not Considered in this Rulemaking
Production Systems and Tension-Leg V. Discussion of Final Rule Requirements
reports.
Platforms, First Edition, June 1998; A. Summary of Key Regulatory Provisions
Reaffirmed May 2006, Errata June (6) Adds new subpart G, Well B. Summary of Significant Differences
2009; Operations and Equipment, and moves Between the Proposed and Final Rules
—API Specification (Spec.) Q1— existing requirements that were 1. Safe drilling margin
2. Accumulator systems
Specification for Quality Management duplicated in subparts D, E, F, and Q
3. BOP 5-year major inspection
System Requirements for into new subpart G including: 4. Real-time monitoring (RTM)
Manufacturing Organizations for the —Rig and equipment movement reports; 5. Potential increased severing capability
Petroleum and Natural Gas Industry, —RTM; and 6. BOP pressure testing interval
Eighth Edition, December 2007, —Revised BOP requirements; including: C. Other Differences Between the Proposed
Effective Date: June 15, 2008; —Design and manufacture/quality and Final Rules
—American National Standards assurance; VI. Discussion of Public Comments on the
Proposed Rule
Institute (ANSI)/API Specification —Accumulator system capabilities and
A. Requests for Extension of the Proposed
(Spec.) 11D1, Packers and Bridge calculations; Rule Comment Period
Plugs Second Edition, Effective Date: —BOP and remotely operated vehicle B. Summary of General Comments on the
January 1, 2010; (ROV) capabilities; Proposed Rule
—API RP 17H, Remotely Operated Tools —BOP functions (e.g., shearing); 1. Comments supporting the proposed rule
and Interfaces on Subsea Production —Improved and consistent testing 2. Legal comments
Systems, First Edition, July 2004, frequencies; 3. Arctic-related comments
Reaffirmed: January 2009; —Maintenance; 4. General comments
—Inspections; 5. Contractor/Operator/Manufacturer
—ANSI/API Spec. 6A, Specification for
—Failure reporting; responsibilities
Wellhead and Christmas Tree 6. Economic analysis comments
—Third-party verification; and
Equipment, Nineteenth Edition, July 7. Clarification of maximum anticipated
—Additional submittals to BSEE,
2004; Effective Date: February 1, 2005; surface pressure (MASP)
including up-to-date schematics.
—ANSI/API Spec. 16A, Specification C. Section-By-Section Summary and
for Drill-through Equipment, Third (7) Incorporates the guidance from Responses to Significant Comments on
Edition, June 2004; several NTLs into subpart G for: the Proposed Rule
VII. Derivation Tables
—API Spec. 16C, Specification for —Global Positioning Systems (GPS) for
VIII. Procedural Matters
Choke and Kill Systems First Edition, Mobile Offshore Drilling Units
Regulatory Planning and Review
January 1993; (MODUs); (Executive Orders (E.O.) 12866 and
—API Spec. 16D, Specification for —Ocean Current Monitoring; 13563))
Control Systems for Drilling Well —Using Alternate Compliance in Safety Regulatory Flexibility Act
ES Control Equipment and Control Systems for Subsea Production Small Business Regulatory Enforcement
RUL Systems for Diverter Equipment, Operations; Fairness Act
with Second Edition, July 2004; and —Standard Reporting Period for the Unfunded Mandates Reform Act of 1995
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25890 Federal Register/Vol. 81, No. 83/Friday, April 29, 2016/Rules and Regulations
Paperwork Reduction Act (PRA) of 1995 operators1perform throughout the OCS. government economic damage claims
National Environmental Policy Act of 1969 These well operations are the primary arising from the Deepwater Horizon
(NEPA) focus of this rulemaking. incident were significant and have been
Data Quality Act
settled for another $5.9 billion.4
Effects on the Nation’s Energy Supply (E.O. C. Purpose and Summary of the
In addition, despite new regulations
13211) Rulemaking
and improvements in industry
I. Background A primary purpose of this rulemaking standards and practices since the
is to prevent future well-control Deepwater Horizon incident, which
A. BSEE
incidents, including major incidents have resulted in progress in certain
BSEE was established on October 1, like the 2010 Deepwater Horizon areas of safety and environmental
2011, as part of a major restructuring of catastrophe. In addition to the loss of 11 protection, loss of well control (LWC)
DOI’s offshore oil and gas regulatory lives, that single event resulted in the incidents are happening at about the
programs to improve the management release of 134 million gallons of oil, same rate five years after that incident
and oversight of, and accountability for, which spread over 43,300 square miles as they were before. In 2013 and 2014,
activities on the Outer Continental Shelf of the GOM and 1,300 miles of shoreline there were 8 and 7 LWC incidents per
(OCS). The Secretary of the Interior in several states. The environmental and year, respectively—a rate on par with
(Secretary) announced the division of other damages caused by the Deepwater pre-Deepwater Horizon LWCs.5Some of
responsibilities of the former Minerals Horizon incident were immense and these LWC incidents have resulted in
Management Service (MMS) among two have had long-lasting and widespread blowouts, such as the 2013 Walter Oil
new bureaus and one office within DOI impacts on the Gulf and the affected and Gas incident that resulted in an
in Secretarial Order No. 3299, issued on states. For example, as part of a explosion and fire on the rig. All 44
May 19, 2010. BSEE, one of the two new settlement agreement between BP and workers were safely evacuated, but the
bureaus, assumed responsibility for Federal and state governments, BP has fire lasted over 72 hours and the rig was
‘‘safety and environmental enforcement agreed to pay over $8 billion for natural completely destroyed, resulting in a
functions including, but not limited to, resources damages caused by the spill financial loss approaching $60 million.
the authority to permit activities, and for the restoration of natural This incident occurred in part due to
inspect, investigate, summon witnesses resources in the Gulf of Mexico region the crew’s inability to identify critical
and [require production of] evidence[;] (GOMR).2Those damages include well control indicators and to the failure
levy penalties; cancel or suspend severe adverse effects on wildlife, of critical well control equipment.6
activities; and oversee safety, response wetlands and other wildlife habitat, Blowouts such as these can lead to
and removal preparedness.’’ (See 76 FR recreation and tourism, and commercial much larger incidents that pose a
64431, October 18, 2011). fishing. The Deepwater Horizon Natural significant risk to human life and can
Resource Damage Assessment (NRDA) cause serious environmental damage.
B. BSEE Statutory and Regulatory
Trustees have determined that ‘‘the Ensuring the integrity of the wellbore
Authority and Responsibilities
ecological scope of impacts from the and maintaining control over the
BSEE derives its authority primarily Deepwater Horizon incident was pressure and fluids during well
from the Outer Continental Shelf Lands unprecedented, with injuries affecting a operations are critical aspects of
Act (OCSLA), 43 U.S.C. 1331–1356a. wide array of linked resources across protecting worker safety and the
Congress enacted OCSLA in 1953, the northern Gulf ecosystem.’’ The environment. The investigations that
authorizing the Secretary of Interior to released oil ‘‘was toxic to a wide range followed the Deepwater Horizon
lease the OCS for mineral development, of organisms, including fish, incident, in particular, documented
and to regulate oil and gas exploration, invertebrates, plankton, birds, turtles, gaps or deficiencies in the OCS
development, and production and mammals . . . [and] caused a wide regulatory programs and made
operations on the OCS. The Secretary array of toxic effects, including death, numerous recommendations for
has delegated authority to perform disease, reduced growth, impaired improvements. Accordingly, on April
certain of these functions to BSEE. reproduction, and physiological 17, 2015, BSEE proposed to consolidate
To carry out its responsibilities, BSEE impairments that made it more difficult its existing well-control rules into one
regulates offshore oil and gas operations for organisms to survive and subpart of the regulations, and to adopt
to enhance the safety of offshore reproduce.’’3In addition, state and local new and revised regulatory
exploration and development of oil and requirements that address many of those
gas on the OCS and to ensure that those 1BSEE’s regulations at 30 CFR part 20 generally recommendations, including those
operations protect the environment and apply to ‘‘a lessee, the owner or holder of operating related to BOP system design,
implement advancements in technology. rights, a designated operator or agent of the lessee(s) performance, and reliability. (See 80 FR
. . .’’ covered by the definition of ‘‘you’’ in
BSEE also conducts onsite inspections 21504.)
§250.105. For convenience, this preamble will refer
to assure compliance with regulations, to all of the regulated entities as ‘‘operators’’ unless
lease terms, and approved plans. otherwise indicated. impacts from the Deepwater Horizon incident may
Detailed information concerning BSEE’s 2A summary and details of the recently approved be found at: http://
regulations and guidance to the offshore natural resources damages settlement between BP www.gulfspillrestoration.noaa.gov/restoration-
and Federal and state governments are available at planning/gulf-plan/.
oil and gas industry may be found on
www.doi.gov/deepwaterhorizon and at http:// 4https://www.justice.gov/enrd/deepwater-
BSEE’s website at: http://www.bsee.gov/ www.justice.gov/enrd/deepwater-horizon. horizon.
Regulations-and-Guidance/index. 3Deepwater Horizon NRDA Trustees, Final 5See http://www.bsee.gov/uploadedFiles/BSEE/
ES BSEE’s regulatory program covers a Programmatic Damage Assessment and Restoration BSEE_Newsroom/Publications_Library/
RUL wide range of facilities and activities, Plan and Final Programmatic Environmental Impact Annual_Report/
with including drilling, completion, Statement, at p. 1–14–1–15. On March 22, 2016, the BSEE%202014%20Annual%20Report.pdf.
D NRDA Trustees issued a Record of Decision setting 6See BSEE, DOI, Investigation of Loss of Well
RO workover, production, pipeline, and forth the basis for the Trustees’ decision to select Control and Fire South Timbalier Area Block 220,
P
N1 decommissioning operations. Drilling, the comprehensive, integrated ecosystem Well. No. A–3 OCS–G24980—23 July 2013 (July
SPTV completion, workover, and rPeEsItSo rSaeticotnio anlst e5r.n5a atinvde 5(d.1e0s)c.r Miboedre i dne Ftainilasl rPeDgaArdRiPn/g 2E0n1fo5r)c, eamt hetntpt/:A//cwcwidwen.btsse_ea.ngdov_/Inucpildoeandtesd/ Files/BSEE/
SK3 decommissioning operations are types the findings of the Federal and state Deepwater Panel_Investigation_Reports/
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Federal Register/Vol. 81, No. 83/Friday, April 29, 2016/Rules and Regulations 25891
Because BOP equipment and systems BSEE may incorporate these standards publications/government-cited-safety-
are critical components of many well into its regulations without republishing documents.7
operations, BSEE recognized that it was the standards in their entirety in the For the convenience of members of
important to collect the best ideas on Code of Federal Regulations (CFR), a the viewing public who may not wish
the prevention of well-control incidents practice known as incorporation by to purchase or view these incorporated
and blowouts to assist in the reference. The legal effect of documents online, they may be
development of the proposed rule. This incorporation by reference is that the inspected at BSEE’s offices, 45600
included the knowledge, skillset, and incorporated standards become Woodland Road, Sterling, Virginia
experience possessed by the offshore oil regulatory requirements. This 20166; phone: [phone]; or at the
and gas industry. Accordingly, BSEE incorporated material, like any other National Archives and Records
participated in meetings, training, and properly issued regulation, has the force Administration (NARA). For
workshops with industry, standards and effect of law, and BSEE holds information on the availability of this
setting organizations, and other operators, lessees and other regulated material at NARA, call 202–741–6030,
stakeholders in developing the proposed parties accountable for complying with or go to: http://www.archives.gov/
rule. (See 80 FR 21508–21509.) the documents incorporated by federal-register/cfr/ibr-locations.html.
The proposed rule discussed in detail reference in our regulations. We
topics such as: currently incorporate by reference over E. Summary of Documents Incorporated
• Implementing many of the 100 consensus standards in BSEE’s by Reference
recommendations related to well- regulations governing offshore oil and
This rulemaking is substantive in
control equipment. gas operations (see 30 CFR 250.198).
• Increasing the performance and Federal regulations, at 1 CFR part 51, terms of the content that is explicitly
reliability of well-control equipment, govern how BSEE and other Federal stated in the rule text itself, and it also
especially BOPs. agencies incorporate various documents incorporates by reference certain
• Improving regulatory oversight over technical standards and specifications
by reference. Agencies may only
the design, fabrication, maintenance, concerning BOPs and well control. A
incorporate a document by reference by
inspection, and repair of critical brief summary of each standard or
publishing in the Federal Register the
equipment. specification follows.
document title, edition, date, author,
• Gaining information on leading and
publisher, identification number, and API Standard 53—Blowout Prevention
lagging indicators of BOP component
other specified information. The Equipment Systems for Drilling Wells
failures, identifying trends in those
Director of the Federal Register must
failures, and using that information to approve each publication incorporated This standard provides requirements
he•lpE pnrseuvreinntg i tnhcaitd tehnet si.n dustry uses bInyc roerfpeorerantcieo nin b ay frienfaelr ernuclee. of a fbolro wthoeu itn pstraelvleantitoinon a neqdu tiepsmtinegn to sf ystems
recognized engineering practices, as document or publication is limited to whose primary functions are to confine
well as innovative technology and the specific edition cited by the agency well fluids to the wellbore, provide
techniques to increase overall safety. in the final rule and approved by the means to add fluid to the wellbore, and
To help ensure the development of Director of the Federal Register. allow controlled volumes to be removed
effective regulations, the proposed rule BSEE incorporates by reference in its from the wellbore. BOP equipment
used a hybrid regulatory approach regulations many oil and gas industry systems are comprised of a combination
incorporating prescriptive requirements, standards in order to require of various components that are covered
where necessary, as well as many compliance with those standards in by this document. Equipment
performance-based requirements. BSEE offshore operations. When a copyrighted arrangements are also addressed. The
recognizes the advantages and publication is incorporated by reference components covered include: BOPs
disadvantages of both approaches and into BSEE regulations, BSEE is obligated including installations for surface and
understands that each approach could to observe and protect that copyright. subsea BOPs; choke and kill lines;
be effective and appropriate for specific BSEE provides members of the public choke manifolds; control systems; and
circumstances. with website addresses where these auxiliary equipment.
A full discussion of these topics,
standards may be accessed for This standard also provides new
along with other background and
viewing—sometimes for free and industry best practices related to the use
regulatory history, is contained in the
sometimes for a fee. Standards of dual shear rams, maintenance and
notice of proposed rulemaking (see 80
development organizations decide testing requirements, and failure
FR 21504), which may be found on
whether to charge a fee. One such reporting.
BSEE’s website at http://www.bsee.gov/
organization, API, provides free online
Regulations-and-Guidance/Regulations- Diverters, shut-in devices, and
public access to review its key industry
In-Development/, and in the public rotating head systems (rotating control
standards, including a broad range of
docket for this rulemaking at: http:// devices) whose primary purpose is to
technical standards. These standards
www.regulations.gov (in the Search box, safely divert or direct flow rather than
represent almost one-third of all API
enter BSEE–2015–0002, then click to confine fluids to the wellbore are not
standards and include all that are safety-
‘‘search’’). addressed. Procedures and techniques
related or are incorporated into Federal
for well control and extreme
D. Availability of Incorporated regulations. Several of those standards
temperature operations are also not
RULES DoBcSuEmEe fnrtesq fuoern Ptulyb ulisce Vs isetwanindga rds (e.g., afirnea iln rcuolrep. oInra ateddd ibtiyo rne fteor tehnec efr iene tohnilsi ne included in this standard.
with codes, specifications, RPs) developed availability of these standards for
D 7To review these standards online, go to the API
RO through a consensus process, facilitated viewing on API’s website, hardcopies publications website at: http://publications.api.org.
N1P by standards development organizations and printable versions are available for You must then log-in or create a new account,
PTV and with input from the oil and gas purchase from API. The API website accept API’s ‘‘Terms and Conditions,’’ click on the
SK3S industry, as a means of establishing address is: http://www.api.org/ ‘a‘pBproliwcasbel De occautemgoernyt s(’e’ .bg.u, t‘t‘oEnx,p alnorda ttihoenn asnedle ct the
asabaliauskas on DVerDatree Sqeup<i1r1e>m20e1n4 ts 1f9o:3r1 a Acptri 2v8i,t 2i0e1s6 onJk tt h23e8 0O01CSP. O 000p00ubFlircma 0t0i0o0n5s-Fsmtat n47d0a1rdSsfm-at n47d0-0staEt:\iFsRt\iFcMs\/29APR2P.SroGdMucti2o9nA’P’)R f2or the standard(s) you wish to review.
25892 Federal Register/Vol. 81, No. 83/Friday, April 29, 2016/Rules and Regulations
API RP 2RD—Design of Risers for design, design verification and systems for diverter equipment are
Floating Production Systems and validation, materials, documentation included in the specification. Control
Tension-Leg Platforms and data control, repair, shipment, and systems for drilling well-control
storage. equipment typically employ stored
This standard addresses structural
energy in the form of pressurized
analysis procedures, design guidelines, ANSI/API Spec. 16A—Specification for
hydraulic fluid (power fluid) to operate
component selection criteria, and Drill-through Equipment
(open and close) the BOP stack
typical designs for all new riser systems
This specification defines components. For deepwater operations,
used on Floating Production Systems
requirements for performance, design, subsea transmission of electric/optical
(FPSs) and Tension-Leg Platforms
materials, testing and inspection, (rather than hydraulic) signals may be
(TLPs). The presence of riser systems
welding, marking, handling, storing and used to shorten response times. The
within an FPS has a direct and often
shipping of BOPs and drill-through failure of these controls to perform as
significant effect on the design of all
equipment used for drilling for oil and designed can result in a major well-
other major equipment subsystems. This
gas. It also defines service conditions in control event. As a result, conformance
RP includes recommendations on: (1)
terms of pressure, temperature and to this specification is critical to
Configurations and components; (2)
wellbore fluids for which the equipment ensuring that the BOPs and related
general design considerations based on
will be designed. This standard is equipment will operate in an
environmental and functional
applicable to, and establishes emergency.
requirements; and (3) materials
requirements for, the following specific
considerations in riser design. ANSI/API Spec. 17D—Design and
equipment: Ram BOPs; ram blocks,
Operation of Subsea Production
API Spec. Q1—Specification for Quality packers and top seals; annular BOPs;
Systems—Subsea Wellhead and Tree
Management System Requirements for annular packing units; hydraulic
Equipment
Manufacturing Organizations for the connectors; drilling spools; adapters;
Petroleum and Natural Gas Industry loose connections; and clamps. This standard provides specifications
Conformance to this standard is for subsea wellheads, mudline
This specification establishes the
necessary to ensure that this critical wellheads, drill-through mudline
minimum quality management system
safety equipment has been designed and wellheads, and both vertical and
requirements for organizations that
manufacture products or provide fabricated in a manner that ensures horizontal subsea trees. These devices
manufacturing-related processes under a reliable performance. are located on the seafloor, and,
therefore, ensuring the safe and reliable
product specification for use in the API Spec. 16C—Specification for Choke
performance of this equipment is
petroleum and natural gas industry. and Kill Systems
extremely important. This document
This standard requires that equipment
This specification was formulated to specifies the associated tooling
be fabricated under a quality
provide for safe and functionally necessary to handle, test and install the
management system that provides for
interchangeable surface and subsea equipment. It also specifies the areas of
continual improvement, emphasizing
choke and kill systems equipment design, material, welding, quality
defect prevention and the reduction of
utilized for drilling oil and gas wells. control (including factory acceptance
variation and waste in the supply chain
This equipment is used during testing), marking, storing and shipping
and from service providers. The goal of
emergencies to circulate out a ‘‘kick’’ for both individual sub-assemblies (used
this specification is to increase
equipment reliability through better and, therefore, the design and to build complete subsea tree
manufacturing controls. fabrication of the components is assemblies) and complete subsea tree
extremely important. This document assemblies.
API Spec. 6A—Specification for provides the minimum requirements for
Wellhead and Christmas Tree performance, design, materials, welding, API RP 17H—Remotely Operated Tools
Equipment testing, inspection, storing and and Interfaces on Subsea Production
Systems
This specification defines minimal shipping. Equipment specific to and
requirements for the design of valves, covered by this specification includes: This RP provides general
wellheads and Christmas tree Actuated valve control lines; articulated recommendations and overall guidance
equipment that is used during drilling choke and kill lines; drilling choke for the design and operation of remotely
and production operations. This actuators; drilling choke control lines, operated tools (ROT) comprising ROT
specification includes requirements exclusive of BOP control lines; and ROV tooling used on offshore
related to dimensional and functional subsurface safety valve control lines; subsea systems. ROT and ROV
interchangeability, design, materials, drilling choke controls; drilling chokes; performance is critical to ensuring safe
testing, inspection, welding, marking, flexible choke and kill lines; union and reliable deepwater operations and
handling, storing, shipment, purchasing, connections; rigid choke and kill lines; this document provides general
repair and remanufacture. and swivel unions. performance guidelines for the
equipment.
ANSI/API Spec. 11D1—Packers and API Spec. 16D—Specification for
Bridge Plugs Control Systems for Drilling Well II. Organization of Subpart G
This specification provides minimum Control Equipment and Control Systems BSEE’s former regulations repeated
requirements and guidelines for packers for Diverter Equipment similar BOP requirements in multiple
RULES aanndd bgarisd ogpee prlautigosn uss. eTdh de opwernfhoromlea innc eo iol f staTnhdiasr sdpse fcoirf iscyasttieomn se stthaabtl iasrhee uss deeds tiogn lIonc tahtiiso nfisn tahl rrouuleg,h BouStE 3E0 i sC cFoRn psoalritd 2a5ti0n. g
with this equipment is often critical to control BOPs and associated valves that these requirements into subpart G
D
RO maintaining control of a well during control well pressure during drilling (which previously had been reserved).
N1P drilling or production operations. This operations. Although diverters are not The final rule will structure subpart G—
V
PT specification provides requirements for considered well-control devices, their Well Operations and Equipment, under
S
K3 the functional specification and controls are often incorporated as part of the following undesignated headings:
S
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Federal Register/Vol. 81, No. 83/Friday, April 29, 2016/Rules and Regulations 25893
—RIG REQUIREMENTS to shear tubing with exterior control years from the publication of the final
—WELL OPERATIONS lines; however, the effective date has rule. As explained in more detail in
—BLOWOUT PREVENTER (BOP) been extended to allow operators to part VI.C, changing the compliance
SYSTEM REQUIREMENTS acquire and install (and, if necessary, date for these new accumulator
—RECORDS AND REPORTING to develop new or alternative) requirements—from the proposed 3
The sections contained within this equipment to meet the requirements. months to the final 5 years from the
new subpart will apply to all drilling, —As required by §§250.731, 250.732, date of publication—will allow
completion, workover, and 250.734, 250.738, and 250.739, sufficient lead time for industry to
decommissioning activities on the OCS, operators must begin using a BSEE- acquire and install additional
unless explicitly stated otherwise. approved verification organization accumulator equipment as necessary
(BAVO) for certain submittals, and will correspond with the
III. Discussion of Compliance Dates for certifications, and verifications.8 timeframe for compliance with the
the Final Rule BSEE will develop and make available final dual shear ram requirements,
BSEE understands that operators may on its public website a list of BAVOs, which is when the additional
need time to comply with certain new consisting of qualified third-party accumulator capacity will most likely
requirements in this final rule. Based on organizations that BSEE determines be needed.
information provided by industry, are capable of performing the —As required in §250.734(a)(1),
drilling rigs are now being built, or were functions specified in this final rule, operators must install dual shear rams
built, pursuant to the same industry and that will help BSEE ensure that on subsea BOPs no later than 5 years
standards BSEE is now incorporating by BOP systems are designed and from the publication of the final rule.
reference (including API Standard 53), maintained during their service life to —As required in §250.733(b)(1), surface
and many have already been retrofitted minimize risk. Industry currently uses BOPs installed on floating facilities 3
independent third-parties to perform
to comply with these industry years after publication of the final rule
verifications similar to the
standards. Furthermore, most drilling must comply with the BOP
certifications and verifications that a
rigs already comply with recognized requirements of §250.734(a)(1).
BAVO will be required to perform
engineering practices and original —As required in §250.734(a)(16),
under this final rule. BSEE is
equipment manufacturer (OEM) operators must install shear rams that
extending the compliance date for the
requirements related to repair and center drill pipe during shearing
use of BAVOs to no later than 1 year
training. operations no later than 7 years from
from the date when BSEE publishes
BSEE has considered the public the publication of the final rule.
the list of BAVOs. BSEE anticipates
comments on the proposed compliance —As required in §250.735(g), operators
that most of the independent third-
dates, as well as relevant information must install remotely-controlled locks
parties currently used by industry
gained during, among other activities, on surface BOP sealing rams no later
under the former regulations will
BSEE’s interactions with stakeholders, than 3 years from publication of the
become BAVOs, significantly
involvement in development of industry final rule.
facilitating compliance with the
standards, and evaluation of current —As required in §250.733(b)(2), for any
requirements to use BAVOs within
technology. Accordingly, BSEE is risers installed 90 days after the date
the one-year timeframe.
setting an effective date of 90 days of the publication of the final rule or
following publication of the final rule, In the interim, however, final later, operators must use dual bore
by which time operators will be §250.732(a) requires that operators use risers for surface BOPs on floating
required to demonstrate compliance independent third-parties to perform the production facilities. The final rule
with most of the final rule’s provisions. certifications, verifications and reports does not require that operators change
BSEE has determined, however, that it that BAVOs must perform no later than the riser configuration for risers that
is appropriate to extend the compliance 1 year after BSEE publishes a BAVO list. were installed on floating facilities
dates for the following new This transitional measure is necessary to before 90 days after the publication
requirements. Detailed explanations for ensure that there is no diminution of the date of the final rule.
these extended compliance dates are safety and environmental protection —As required in §§250.732(b)(1)(i) and
provided in parts V and VI of this currently afforded by the use of 250.734(a)(1)(ii), the BOP must be
document. independent third-parties under the able to shear electric-, wire-, and
—As required in §250.734(a)(15), existing regulations or of the safety and slick-line no later than 2 years after
operators must install a gas bleed line environmental improvements publication of the final rule.
anticipated under the new BAVO
with two valves for the annular
requirements, during the time required IV. Issues Not Considered in This
preventer no later than 2 years from
for BSEE to identify and for operators to Rulemaking
publication of the final rule. BSEE is
extending the timeframe for this use the BAVOs. BSEE is continuing to review and
requirement based on the current —As required in §250.724, operators evaluate additional operational and
level of availability of the required must comply with the RTM equipment issues that are not included
equipment and the time needed to requirements no later than 3 years in this final rulemaking, such as:
install the equipment. This timeframe from the publication of the final rule. —Well-control planning, procedures,
—As required in §250.734(a)(3),
was selected to avoid any rig training, and certification;
S operators are required to have
E downtime. —Major rig equipment;
UL dedicated subsea accumulator
R —As required by §§250.733(a)(1) and —Certification requirements for
with 250.734(a)(1), operators must have the capacity for autoshear and deadman personnel servicing critical
ROD capability to shear and seal tubing functions on subsea BOPs within 5 equipment;
P
N1 with exterior control lines no later —Choke and kill systems;
PTV than 2 years from the publication of 8For example, §250.731(c)(2) requires —Mud gas separators;
S certification and verifacation that all BOPs are
SK3 the final rule. BSEE is aware that designed and tested to maximun anticipated —Wellbore fluid safety practices,
asabaliauskas on DVerDate Sseop<m11e> 2c0u14rr en19t: 3t1e cAhprn 2o8,l 2o0g1y6 isJ kat v23a8i0l0a1bleP O 000c0o0ndFicrtmio 0n0s0. 07 Fmt 4701 Sfmt 4700 E:\FR\FM\29APR2.SGteMsti2n9gA,P aRn2d monitoring;
25894 Federal Register/Vol. 81, No. 83/Friday, April 29, 2016/Rules and Regulations
—Diverter systems with subsea BOPs; reliability and performance of this • Requires additional measures (e.g.,
and equipment. RTM and increased maintenance) to
—Additional severing requirements. • Requires inspection, maintenance, help ensure the functionality and
and repair of BOP-related equipment by operability of the BOP system that will
V. Discussion of Final Rule
appropriately trained personnel; this help reduce the safety and
Requirements
will also increase the reliability of BOP- environmental risks.
Part V.A, which follows, summarizes related equipment.
B. Summary of Significant Differences
and highlights some important
Equipment Failure Reporting/Near-Miss Between the Proposed and Final Rules
requirements of the final rule that were
Reporting—
described in more detail in the proposed After consideration of all relevant and
rule. Some of these provisions received • Requires that operators share significant comments, BSEE made a
no comments during the public information with Original Equipment number of revisions from the proposed
comment period, while other provisions Manufacturers (OEMs) related to the rule in the final rule. We are
were supported or criticized by certain performance of their BOP system highlighting several of these changes
commenters. Part V.B addresses equipment. This sharing of information here because they are significant, and
significant relevant comments on makes it possible for the OEMs to notify because numerous comments addressed
certain proposed provisions and all users of any safety issues that arise these topics. A discussion of the
summarizes changes to those provisions with BOP system equipment. relevant and significant comments and
that BSEE has made in the final rule • Requires that operators report any BSEE’s responses are found in part VI of
based on consideration of those significant problems with BOP or well- this document. The significant revisions
comments. Part V.C summarizes other control equipment to BSEE, so BSEE can made in response to comments include:
changes to the proposed rule that BSEE determine whether information should 1. Safe Drilling Margin—§250.414(c)
has made in the final rule to avoid be provided, in a timely manner, to OCS
ambiguity or confusion, eliminate operators and, if appropriate, to In response to one of the Deepwater
redundancies, correct minor drafting international offshore regulators and Horizon investigation
errors, or otherwise clarify the meaning operators. recommendations—i.e., to better define
safe drilling margins—BSEE proposed to
of the new requirements. Safe Drilling Practices— revise the safe drilling margin portion of
A. Summary of Key Regulatory • Requires maintaining safe drilling the drilling prognosis (i.e., well drilling
Provisions margins and other requirements related procedures) required in an Application
After review of all the relevant public to liners and other downhole equipment for Permit to Drill (APD). Among other
comments received on the proposed to help reduce the likelihood of a major things, BSEE proposed that the ‘‘static
rule, BSEE determined that the well-control event and ensure the downhole mud weight must be a
following proposed revisions will be overall integrity of the well design. minimum of 0.5 pound per gallon (ppg)
included in this final rule. Most of the • Requires monitoring of deepwater below the lesser of the casing shoe
proposed provisions are included and High Pressure High Temperature pressure integrity test or the lowest
without change, while several of the (HPHT) drilling operations from the estimated fracture gradient’’ (‘‘the 0.5
proposed provisions have been revised shore and in real-time. This will allow ppg drilling margin’’). This proposed
in the final rule in response to operators to anticipate and identify requirement was typically part of
comments, as explained in parts V.B issues in a timely manner and to utilize BSEE’s approval parameters during the
and VI of this document. onshore resources to assist in addressing permitting process. However, many
critical issues. commenters expressed concerns that
Shearing Requirements— • Requires daily reports to BSEE strict enforcement of a 0.5 ppg drilling
• Requires BOP shearing performance concerning any leaks associated with margin in all circumstances could cause
testing and results reporting to a BAVO. BOP control systems. This will ensure adverse economic consequences
This will ensure that shearing capability that the bureau is made aware of any because it could effectively require
for existing equipment complies with leaks so it can determine if further setting additional casing strings and
BSEE requirements. action is appropriate. smaller hole sizes and thus, in some
• Requires compliance with the latest • Requires compliance with API RP cases, could make it impossible to reach
industry standards contained in API 17H to standardize ROV hot stab target depths. The commenters
Standard 53. activities. This will allow certain suggested various alternatives to the 0.5
• Requires that operators use two functions of the BOP to be activated ppg requirement, including allowing
shear rams in subsea BOP stacks. remotely. operators to use a risk-based approach
• Requires the use of BOP technology to setting safe drilling margins on a
BOP Testing—
that provides for better shearing case-by-case basis.
performance through the centering of • Requires same pressure testing Typically, 0.5 ppg is an appropriate
the drill pipe in the shear rams. frequency (at least once every 14 days) safe drilling margin for normal drilling
for workover and decommissioning scenarios and has been approved by
Equipment Reliability and
operations as for drilling and BSEE (and thus made a requirement) in
Performance—
completion operations. Pressure test numerous APDs. However, BSEE
• Requires compliance with industry results will aid in predicting future understands that there are some well-
S
E standards, such as relevant provisions of performance of a BOP, and harmonizing specific circumstances where a lower
UL
R API Standard 53, ANSI/API Spec. 6A, testing frequencies for all well drilling margin may be acceptable to
with ANSI/API Spec. 16A, API Spec. 16C, operations will also help streamline the drill a well safely, and BSEE has
D
RO API Spec. 16D, ANSI/API Spec. 17D, BOP function-testing criteria and reduce approved appropriate alternative
P
N1 and API Spec. Q1. BOP operability will the unnecessary repetition every 7 days downhole mud weights as part of a safe
V
PT be improved by establishing minimum of testing in workover and drilling margin in many APDs.
S
K3 design, manufacture, and performance decommissioning operations that could Accordingly, in this final rule, BSEE is
S
asabaliauskas on DVerDatbe aSseep<li1n1>e2s0 1t4h at1 a9:r3e1 Aepsrs 2e8n, 2ti0a1l6 toJ ket n23s8u00r1e thPOe 000p00oseF romp 0e00r0a8tioFnmat l4 7s0a1fetSyfm its 4s7u0e0s. E:\FR\FM\29APR2k.SeGeMpin2g9 AtPhRe2 0.5 ppg drilling margin as
Federal Register/Vol. 81, No. 83/Friday, April 29, 2016/Rules and Regulations 25895
proposed to be the default requirement, the surface and then calculated to standard (API Standard 53) are
but is adding a new paragraph (c)(2) to downhole conditions. Thus, equivalent inconsistent, and that the different
§250.414 that expressly allows the use downhole mud weight can be verified terminology could cause ambiguity and
of an alternative to the 0.5 ppg drilling on the rig as operations are being confusion in efforts to comply with a
margin if the operator submits adequate conducted. final rule. Industry commenters
justification and documentation, BSEE also removed the references to recommended using the terminology
including supplemental data (e.g., offset ECD from this section based on used in the API standard; and
well data, analog data, seismic data, risk comments. For the reasons discussed • That the proposed requirement that
modeling), in the APD. This addition is elsewhere in this preamble (with regard accumulator systems be able to supply
consistent with current BSEE GOMR to §250.413), BSEE determined that pressure to operate all BOP components
practice to allow alternative drilling operators do not need to submit the and shear pipe as the last step in the
margins when justified and estimated ECD in the APD permitting BOP sequence, without assistance from
documented. This change will also process; however, BSEE expects a charging unit, would increase the
provide operators some assurance that operators to continue their normal number of accumulator bottles needed
an alternative drilling margin, other practice of considering ECD while and would require upgraded
than the 0.5 ppg margin, may be used drilling. accumulator system controls.
when appropriate, while helping BSEE The commenters also stated that costs
2. Accumulator Systems
ensure the use of drilling mud with associated with the additional bottles
properties (e.g., density, viscosity, In the proposed rule, BSEE proposed would be significant and that the extra
additives) best suited for a specific well a number of significant changes to weight from additional bottles, given
interval and based on well-specific existing BOP requirements as well as limited deck space availability, could
drilling and geological parameters.9 new requirements for BOPs and cause structural issues with the rig.
This addition to the safe drilling margin associated systems, including new • That the proposed requirements
section will provide increased planning requirements for subsea and surface that the subsea accumulator system be
flexibility when drilling into areas that BOP accumulator systems. (See able to supply pressure to operate all
could require lower safe drilling proposed §§250.734 and 250.735.) The critical BOP components, and that the
margins, such as depleted sands or purpose of the accumulator system and system have dedicated bottles for each
below salt (both common occurrences in these new requirements is to ensure that EDS/autoshear/deadman system(s),
the GOMR), and help avoid the there is sufficient volume and pressure would greatly increase the number of
potential negative consequences of in the accumulator bottles to properly accumulator bottles on the subsea BOP.
requiring a 0.5 ppg margin in all cases. operate BOP components in a specified The commenters stated that the
BSEE is also making other minor timeframe regardless of the location of increased number and weight of
changes to the proposed §250.414(c). the accumulator bottles. Among other accumulator bottles could also cause
Specifically, as suggested by several things, we proposed increasing structural concerns for the BOP frame
commenters, we are replacing the term accumulator capacity to operate all BOP and the rig and that costs associated
‘‘static downhole mud weight’’ with functions; i.e., requiring all surface with the additional bottles would also
‘‘equivalent downhole mud weight,’’ accumulator systems, whether be significant.
and removing the references to associated with surface or subsea BOPs, BSEE reviewed all of the relevant
Equivalent Circulating Density (ECD). to meet the requirements for comments and has made changes to the
Several commenters suggested replacing accumulators servicing surface BOPS proposed surface and subsea
static downhole mud weight with a under the prior regulations (including accumulator requirements in the final
more appropriate term to better define the requirement that the accumulator rule. In this final rule, BSEE is deleting
and assess the mud weight because of system provide 1.5 times the volume of the ‘‘1.5 times volume capacity’’
the difficulty of achieving and verifying fluid capacity necessary to hold closed requirement for all surface
static downhole mud weight during all BOP components). We also proposed accumulators, and instead requiring that
operations. BSEE agrees with this requiring surface accumulator systems all accumulator systems (including
observation. To verify a static downhole to operate under MASP conditions, with those servicing subsea BOPs) meet the
mud weight, the well would need to be the blind shear ram being last in the sizing specifications of API Standard 53.
placed in a static situation. This would BOP sequence, and still have enough The final rule also extends the effective
be done by turning off the pumps and accumulated pressure to allow the BOP date to comply with the new
letting the well sit until it is static; to shear pipe and seal the well. In accumulator requirements (both surface
however, that process can result in addition, we proposed defining critical and subsea) to 5 years; removes the
complications, such as cuttings and functions for BOP operation, and proposed requirement that the surface
debris settling out in the bottom of the requiring dedicated, independent accumulator be able to operate the blind
well and thermal gradients affecting accumulator bottles for emergency shear ram as the last function in the
mud properties. Some of these functions (autoshear/deadman/ BOP sequence; defines ‘‘critical
complications may create additional emergency disconnect sequence (EDS)). functions;’’ and requires dedicated
issues, such as stuck pipe or loss of BSEE received multiple comments on subsea accumulator bottles for autoshear
wellbore integrity. The change from these proposed provisions. Industry and deadman (but not EDS) functions
‘‘static’’ to ‘‘equivalent’’ allows the stakeholders raised concerns with (and and allows those dedicated bottles to be
downhole mud weight to be based on in some cases suggested revisions to) the shared between the autoshear and
S
ULE the mud properties that can be tested at proposed requirements, including the deadman functions.
D with R 9Alternatives to compliance with the 0.5 ppg safe fol•loTwhinatg tchoen pcreorpnos:s ed surface and indBuSsEtEry r seteavnadluaradtesd a nthde dreetleervmanint ed that
RO drilling margin requirement could also be requested subsea accumulator capacity API Standard 53 and API Spec. 16D
P
N1 under existing §250.141, and approved by BSEE if requirements are in conflict with API provide reasonable and appropriate
PTV the criteria of that section are satisfied; but such Standard 53 and API Spec. 16D; methods to ensure proper volumes and
SK3S soeppearraatoter rreeqquueessttss wano ualltde rnnoatt ibvee n ienc ietsss AarPyD i fu annd er • That the terminology in the pressures of appropriate BOP
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25896 Federal Register/Vol. 81, No. 83/Friday, April 29, 2016/Rules and Regulations
volume requirements for surface Subsea accumulator charge normally inspection dates, and requiring those
accumulators to meet the specifications comes from the surface, but in an records to be available on the rig, will
of API Standard 53 will allow for more emergency the connections to the help BSEE to verify that the components
specific assessments of the capacity surface may be lost and/or the were inspected within the required
necessary to address unique operating accumulator may have already operated timeframe and will also assist BSEE’s
conditions, while still ensuring that multiple BOP components, which may review of the documentation, when
there is enough capacity to operate all have reduced the accumulator fluid requested. The final rule requires that
specified BOP components in an pressure needed to successfully shear all of the appropriate components be
emergency. This will significantly and seal. Dedicated bottles for autoshear inspected during the 5-year cycle.
reduce the additional costs identified in and deadman functions would ensure Proper documentation of phased
industry comments, since it eliminates that the subsea accumulator has enough inspections will improve BSEE
the ‘‘1.5 times volume’’ requirement that pressure available to operate those oversight, as compared to current
the proposed rule would have extended emergency systems even if all surface practice, while a phased approach will
to surface accumulators servicing a connections are lost or the volume or avoid the possibility of long rig shut
subsea BOP, and since most pressure in the accumulator system are downs.
accumulator equipment has been depleted. BSEE determined, however,
4. Real-Time Monitoring
designed to meet the API Standard 53 that permitting those functions to share
specifications since that standard was the dedicated accumulator bottles In §250.724 of the proposed rule,
adopted in 2012. would not result in a reduction to safety BSEE proposed to require RTM of
Removing the ‘‘1.5 times volume’’ or environmental protection so long as certain data for well operations that use
requirement and replacing it with the the shared bottles are capable of either a subsea BOP or a BOP on a
volume requirements of API Standard providing enough pressure to operate floating facility, or are conducted in an
53 also will not decrease safety or the emergency functions. By contrast, HPHT environment. Under the
dedicated capacity in a subsea proposed rule, the RTM system would
environmental protection as compared
accumulator for the EDS is not have been required to gather and
to the proposed requirement. BSEE
necessary, since the EDS is serviced ‘‘immediately transmit’’ data on the
determined that the methods for
through the main (surface) accumulator BOP control system, the well’s fluid
calculating the necessary fluid volumes
system by rig personnel. handling systems on the rig, and the
and pressures in the API standard
well’s downhole conditions with the
provide an acceptable amount of usable 3. BOP 5-Year Major Inspection
bottom hole assembly tools (if any) to an
fluid and pressure to operate the
In the proposed rule, BSEE included onshore facility to be monitored by
required components, while still
a provision to require a complete qualified personnel in ‘‘continuous
ensuring the required 200 pounds per
breakdown and inspection of the BOP contact’’ with rig personnel during
square inch (psi) above the pre-charge
and every associated component every 5 operations. In addition, BSEE proposed
pressure. API Standard 53 also
years, as documented by a BAVO, that, after transmission, the RTM data
discusses the need to have 200 psi
which, as proposed, could not be must be preserved and stored at a
remaining on the bottles above the pre-
performed in phased intervals. BSEE designated location, identified in an
charge pressure after operating the BOP
received multiple comments on the 5- APD or APM, and that the location and
components, which would provide a
year inspection interval. Most industry RTM data be made available to BSEE
sufficient margin of error to promote
commenters did not object to a 5-year upon request. Finally, the proposed rule
safety and help prevent environmental
inspection requirement for each BOP would have required immediate
harm from failure of pressure to the
component, provided that the notification to the appropriate BSEE
BOP.
inspections could be staggered, or District Manager of any loss of RTM
Removing the proposed language phased, over time. Commenters capability during operations and would
regarding the blind shear ram being the expressed concern that requiring all have authorized the District Manager to
last in sequence will eliminate components to be inspected at one time require other measures pending
industry’s misimpression that the would put too many rigs out of service, restoration of RTM capabilities.
proposed language would have potentially for long periods of time, BSEE intends for industry to use RTM
mandated that the blind shear ram with substantial economic impacts. as a tool (i.e., as an ‘‘additional pair of
always be the last step in the BOP Based on consideration of the issues eyes’’) to improve safety and
sequence. In addition, BSEE agrees with raised in the comments, BSEE has environmental protection during
the commenters that the proposed revised the final rule in order to allow ongoing well operations, as
language regarding sequencing of the a phased approach for 5-year recommended by several reports on the
blind shear ram is not necessary, as long inspections (e.g., staggered inspection Deepwater Horizon incident. See 80 FR
as the accumulator is able to provide for each component), as long as there is 21520. BSEE does not intend that
sufficient volume of fluid to operate all proper documentation and tracking to onshore personnel monitoring the RTM
the required BOP functions under ensure that BSEE can verify that each data would have operational control
MASP. applicable BOP component has had the over the rig based on the data; rather,
BSEE is also making changes in the major inspection within 5 years. BSEE BSEE intends that onshore personnel
final rule to the subsea accumulator is also adding, for clarification, the could use RTM data to help rig
requirements in response to comments. applicable dates for the starting point of personnel conduct their operations
S
E BSEE is requiring subsea accumulators the 5-year cycle. BSEE is confident that safely and to assist rig personnel in
UL
R to have enough capacity to provide these inspection requirements maintain identifying and evaluating abnormalities
with pressure for critical functions, as the necessary level of safety and and unusual conditions before they
D
RO defined in API Standard 53, and to have environmental protection without become critical issues. In addition,
P
N1 accumulator bottles that are dedicated resulting in unnecessary interference BSEE expects operators to review stored
V
PT to autoshear and deadman functions with scheduling or complications for RTM data after operations are complete
S
K3 (but not EDS), and that may be shared operations. Requiring operator in order to improve well-control
S
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