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BSEE working on new BOP regulations Agency holds meeting with government, operator, drilling company, manufacturer participation to gather data on blowout preventers Kristen Nelson Petroleum News
The U.S. Department of the Interior’s Bureau of Safety and Environmental Enforcement, BSEE, held a technical forum May 22 on next-generation blowout preventer and control systems. The forum’s five panels included representatives from government, industry, trade associations, equipment manufacturers, consultants, training companies and blowout preventer, or BOP, monitoring companies.
Interior said in a statement that the purpose was to allow industry and other stakeholders an opportunity to provide input and feedback to BSEE on additional steps the agency may take to increase BOP safety. The department said that during the past two years BSEE has already taken steps to improve testing and certification requirements for blowout preventers.
The changes come as a result of the failure of the BOP on the Deepwater Horizon semi-submersible drilling rig to seal a subsea well at the Macondo prospect in the Gulf of Mexico in April of 2010, resulting in 11 deaths in a fire and explosion which destroyed the rig and led to the worst offshore oil spill in U.S. history.
The forum began with overviews by administration officials. A summary of those presentations follows. Information from the forum is available on BSEE’s website at www.bsee.gov and will be the subject of stories in Petroleum News in June.
Back in business Secretary of the Interior Ken Salazar called the forum an attempt to move forward on what should be done with the next generation of blowout preventers. He said today, little more than two years after the beginning of the spill, the Gulf of Mexico is back with production and exploration.
There was a six-month pause, he said, but statistics demonstrate that the Gulf is back, with about a third of all domestic oil coming from the Gulf of Mexico today and rigs at a higher number on average than during 2009.
The permitting program is moving forward, he said, with 67 deepwater permits issued in the last 12 months. There was a record Gulf lease sale in December and another sale is scheduled for June, Salazar said.
As a result of discussions with Mexico, they are following the protocols developed in the U.S., which is important because Mexico will move into deepwater drilling, he said.
Salazar said he wants to make sure that the lessons from the Deepwater Horizon and Macondo are not forgotten.
He said “we can never be cautious enough,” and noted that before Macondo people thought “we were safe” in the Gulf of Mexico, but that spill did happen and he said Interior wants to make sure it doesn’t happen again — and if it does, that “we’re ready to move in quickly.”
Rulemaking Deputy Secretary of the Interior David Hayes said the forum was being held because Interior wants help from stakeholders in putting together the best proposal for a new regulation for BOPs. He said Interior had planned to do an advanced notice of rulemaking for new BOP regulations, but it would have taken many months to get to a proposed rule.
Hayes said Interior has a good idea of where it wants to go with BOP regulations based on the National Academy of Engineering report on Macondo, which along with the joint investigative report pointed to some serious issues with the BOP at Macondo.
He said Interior is looking for at least four things in regulations: a BOP needs to be able to cut and seal the drill pipe; better maintenance is needed; better sensors are needed to show what’s happening at the wellhead; and everyone working with a BOP needs to be fully and properly trained.
Safety at all levels BSEE Director Jim Watson, who was the U.S. Coast Guard on scene coordinator for the Macondo response, said he wants safety at all levels and at all times — from the bottom of the well to the top of the derrick. The BSEE mission, he said, is to ensure integrity from the depths to the delivery point of hydrocarbons back on shore, and at all levels of organizations.
Watson said new BOP requirements to date include third-party verification that blind-shear rams and BOP stacks will work in accordance with regulations, American Petroleum Institute standards and best practices; requirements for subsea secondary intervention with ROVs, remote operated vehicles; a bottom hole test of the blind shear rams; crew training requirements; and qualifications for third-parties the companies use.
BSEE has also put into place rules for drilling safety and workplace safety; focused on oil spill response plans and well containment; and will complete the final drilling safety rule and safety management systems rule in the coming year.
For the BOP rulemaking, Watson said BSEE will put out a notice of proposed rulemaking based on input from the forum and input the agency has already received from experts in industry and government.
BSEE will also be looking at risks on the production side and at life-cycle analysis — that’s the “all-times” piece of the requirements, he said, with a proposed rule on production safety systems and lifecycle analysis to be out in the next year.
Lessons of Macondo Tom Hunter, chair of the Ocean Energy Safety Advisory Committee, chartered in February 2011 to advise the secretary of the Interior through the BSEE director on issues related to offshore energy safety, is a former head of Sandia National Laboratories and was the lead on the federal scientific team that worked with BP to develop and analyze solutions to the Macondo oil spill.
Hunter said the BOP at Macondo was not a self-revealing system and that much data needed for response was not available.
Functions of a BOP, he said, include availability at the push of a button during drilling; self-assessing and diagnosing; repeatable responses; upgradable; repairable; understandable; and affordable.
Response from the BOP needs to be instant, Hunter said, whether an event is small or major, but also needs to be controllable because you might want to shut a well in slowly.
If there is a major event, it needs to be clear what’s going on; all elements need to be fully diagnosable; all internals need to be observable; and there need to be opportunities for measurement.
If containment becomes necessary, flow needs to be measurable; there needs to be redundant self-capping capability; and there has to be “sheer certainty” including the capability to clear obstructions if necessary.
Hunter said fundamental design principles include: 100 percent availability; totally controllable; completely diagnosable; sheer certainty; sheer closure backup; and it has to be obtainable — you can’t just have complicated drawings and, he noted, there is a significant backlog of orders today.
Christopher Smith, deputy assistant secretary for oil and natural gas in the Department of Energy, a member of the Ocean Energy Safety Advisory Committee, spoke to the lives lost in the Deepwater Horizon tragedy, and noted that the BOP was just one piece of the puzzle. The BOP is interlinked with a lot of other complex factors that led to the disaster, he said, including issues such as well design, cementing and organizational and procedural issues.
Smith also addressed the issue of having useful information about what was happening subsea available on the rig. He was one of two designated federal officials for the National Commission on the BP Deepwater Horizon Oil Spill and Offshore Drilling and said that during hearings the commission spent three or four hours looking at one chart.
Smith said it wasn’t something that would help the person on the rig interpret what was going on in real time.
On the BOP, he said the commission had a lot of discussion on why the pipe buckled and said the need to understand how a BOP needs to operate under emergency conditions is clear.
Smith said there is a natural tendency in D.C. for agencies to operate individually, but said in this case there was “seamless cooperation” between Interior and Energy.
He said the Department of Energy was working to ensure its research is consistent with the challenges faced by rule makers at the Department of Interior, and also said ongoing collaboration with industry will be necessary to make sure agencies are keeping up with innovation.
See additional stories from the forum in the June 3 and June 10 issues of Petroleum News.
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