On April 14, 2016, the Department of the Interior’s Bureau of Safety & Environmental Enforcement (BSEE) released the “Final Rule” version of the offshore well control rule (WCR). This regulation impacts the entire U.S. offshore industry, and PESA worked with member companies to ensure that the perspective of oilfield equipment manufacturers was presented.
As a result industry engagement, including technical input provided by PESA member companies operating under the PESA “Well Control Rule Working Group,” the final version of the regulation includes changes in some significant areas from the proposal released in 2015. The regulation incorporates, with some notable departures, industry standards such as AIP Standard 53 covering blowout preventers (BOPs).
Highlights of revisions directly impacting PESA members include:
- Removal of the “1.5 times volume capacity” requirement for all surface accumulators and allowing for use of shared capacity for subsea accumulator. The initial proposal to significantly increase accumulator requirements would have resulted in significant unintended safety and operational consequences.
- Allowing for additional study of “shear-all but the drill bit” technology instead of mandating this technology within ten years. Significant technical work remains in this area to ensure that the it is technically feasible; further study by BSEE will allow for greater collaboration with OEMs.
- The draft rule would have required an “all at once” inspection of the BOP and components every give years. In the Final Rule, the inspection requirement will allow for a staggered inspection for each component. Pressure testing by the operator will be required at least once every 14 days.
- Use of a “BSEE-Approved Verification Organization” or BAVO is still required, with the requirement to use a BAVO occurring one year after BSEE publishes a BAVO list. However, until that requirement is effective, operators must use an independent third party to carry out the tasks of a BAVO.
A major focus area for the drilling contractor and operator community was a proposed requirement that drilling margins be kept at 0.5 pounds per gallon. While the 0.5 ppg requirement remains the default, the Final Rule outlines an alternative that allows for a lower margin following BSEE approval of a justified request. The rule’s provisions regarding real time monitoring were also revised, with the proposal’s requirement for monitoring “all aspects of BOP systems” was modified to be more specific to the drilling operation.
In general, the Final Rule does provide more clarity on terminology and language. This was also a major source of input by PESA members as they work to manufacture equipment that meets both regulatory and safety demands. While some of the implementation timelines were extended, others, remain as short as 90 days.
The implementation of this regulation, especially the differences with industry standards, will require continued engagement between PESA members and BSEE. While regulations provide a great deal of detail, the agency will also be issuing guidance to its District staff.
PESA’s Well Control Rule Working Group continues to review the rule and may provide additional information to PESA members in the future. If you have questions about the final regulation, which can be reviewed online here, do not hesitate to contact PESA’s VP of Operations & External Affairs Ryan Bowley at firstname.lastname@example.org.