Oil and Gas and Sulphur Operations in the Outer Continental Shelf-Blowout Preventer Systems and Well Control, 21503-21585 [2015-08587]
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Vol. 80
Friday,
No. 74
April 17, 2015
Part III
Department of the Interior
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Bureau of Safety and Environmental Enforcement
30 CFR Part 250
Oil and Gas and Sulphur Operations in the Outer Continental Shelf—
Blowout Preventer Systems and Well Control; Proposed Rule
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DEPARTMENT OF THE INTERIOR
Bureau of Safety and Environmental
Enforcement
30 CFR Part 250
[Docket ID: BSEE–2015–0002; 15XE1700DX
EEEE500000 EX1SF0000.DAQ000]
RIN 1014–AA11
Oil and Gas and Sulphur Operations in
the Outer Continental Shelf—Blowout
Preventer Systems and Well Control
Bureau of Safety and
Environmental Enforcement (BSEE),
Interior.
ACTION: Proposed rule.
AGENCY:
The Bureau of Safety and
Environmental Enforcement (BSEE)
proposes new regulations in order to
consolidate equipment and operational
requirements that are common to other
subparts pertaining to offshore oil and
gas drilling, completions, workovers,
and decommissioning. This proposed
rule would focus, at this time, on
blowout preventer (BOP) requirements,
including incorporation of industry
standards and revising existing
regulations. The proposed rule would
also include reforms in the areas of well
design, well control, casing, cementing,
real-time well monitoring, and subsea
containment. The proposed rule would
address and implement multiple
recommendations resulting from various
investigations of the Deepwater Horizon
incident. This proposed rule would also
incorporate guidance from several
Notices to Lessees and Operators (NTLs)
and revise provisions related to drilling,
workover, completion, and
decommissioning operations to enhance
safety and environmental protection.
DATES: Submit comments by June 16,
2015. The BSEE may not consider
comments received after this date.
Submit comments to the Office of
Management and Budget (OMB) on the
information collection burden in this
proposed rule by May 18, 2015. This
does not affect the deadline for the
public to comment to BSEE on the
proposed regulations.
ADDRESSES: You may submit comments
on the proposed rulemaking by any of
the following methods. Please use the
Regulation Identifier Number (RIN)
1014–AA11 as an identifier in your
message. See also Public Availability of
Comments under Procedural Matters.
• Electronic comments: https://
www.regulations.gov. In the Search box,
enter BSEE–2015–0002 then click
search. Follow the instructions to
submit public comments and view
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SUMMARY:
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supporting and related materials
available for this rulemaking. We will
post all comments.
• Mail or hand-carry comments to the
Department of the Interior (DOI); Bureau
of Safety and Environmental
Enforcement; Attention: Regulations
and Standards Branch; 45600 Woodland
Road, Sterling, Virginia 20166. Please
reference Blowout Preventer Systems
and Well Control, 1014–AA11 in your
comments and include your name and
return address.
• Send comments on the information
collection in this rule to: OMB, Interior
Desk Officer 1014–NEW, 202–395–5806
(fax); email:
OIRA_submission@omb.eop.gov. Please
also send a copy to BSEE at
regs@bsee.gov, fax number (703)787–
1546, or by the address listed above.
FOR FURTHER INFORMATION CONTACT: Kirk
Malstrom, Regulations and Standards
Branch, 202–258–1518,
Kirk.Malstrom@bsee.gov. To see a copy
of the information collection request
submitted to OMB, go to https://
www.reginfo.gov (select Information
Collection Review, Currently Under
Review).
National Commission National Commission
on the BP Deepwater Horizon Oil Spill and
Offshore Drilling
NTLs Notices to Lessees and Operators
OCS Outer Continental Shelf
OCSLA Outer Continental Shelf Lands Act
OEM Original Equipment Manufacturer
OIRA Office of Information and Regulatory
Affairs
OMB Office of Management and Budget
PE Professional Engineer
psi Pounds per square inch
RFA Regulatory Flexibility Act
RIA Regulatory Impact Analysis
RIN Regulation Identifier Number
ROV Remotely Operated Vehicle
RP Recommended Practice
SBA Small Business Administration
SBREFA Small Business Regulatory
Enforcement Act of 1996
SCCE Source Control and Containment
Equipment
Secretary Secretary of the Interior
SEM Subsea Electronic Module
SEMS Safety and Environmental
Management
Spec. Specification
TAR Technical Assessment and Research
TLP Tension Leg Platform
TVD True Vertical Depth
USCG United States Coast Guard
VSL Value of a Statistical Life
WAR Well Activity Report
SUPPLEMENTARY INFORMATION:
Executive Summary
List of Acronyms and References
ANSI American National Standards
Institute
APD Application for Permit to Drill
API American Petroleum Institute
APM Application for Permit to Modify
BOP Blowout Preventer
BOEM Bureau of Ocean Energy
Management
BSEE Bureau of Safety and Environmental
Enforcement
BSR Blind Shear Ram
CBM Condition-based Maintenance
CVA Certified Verification Agent
DHS Department of Homeland Security
DOI Department of the Interior
DWOP Deepwater Operations Plan
ECD Equivalent Circulating Density
EDS Emergency Disconnect Sequence
E.O. Executive Order
EOR End of Operations Report
F Fahrenheit
FPS Floating Production System
FPSO Floating Production, Storage, and
Offloading Unit
FSHR Free Standing Hybrid Risers
GOM Gulf of Mexico
GPS Global Position Systems
HPHT High Pressure High Temperature
JIT Joint Investigation Team
LMRP Lower Marine Riser Package
MASP Maximum Anticipated Surface
Pressure
MMS Minerals Management Service
MODUs Mobile Offshore Drilling Units
NAE National Academy of Engineering
NAICS North American Industry
Classification System
NARA National Archives and Records
Administration
Following the Deepwater Horizon
incident on April 20, 2010, multiple
investigations were conducted to
determine the causes of the incident and
to make recommendations to reduce the
likelihood of a similar incident in the
future. The investigative groups
included:
—DOI/Department of Homeland
Security (DHS) Joint Investigation
Team;
—National Commission on the BP
Deepwater Horizon Oil Spill and
Offshore Drilling;
—Chief Counsel for the National
Commission; and
—National Academy of Engineering.
Each investigation outlined several
recommendations to improve offshore
safety. The BSEE evaluated the
recommendations and acted on a
number of them quickly to improve
offshore operations while other
recommendations required additional
input from industry and other
stakeholders. The requirements in this
proposed rule are based on
recommendations made by the
previously listed investigative bodies,
which found a need to enhance wellcontrol best practices to advance safety
and protection of the environment.
This proposed rulemaking would:
(1) Incorporate the following industry
standards:
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—American Petroleum Institute (API)
Standard 53, Blowout Prevention
Equipment Systems for Drilling Wells;
—American National Standards
Institute (ANSI)/API Specification
(Spec.) 11D1, Packers and Bridge
Plugs; and
—API Recommended Practice (RP) 17H,
Remotely Operated Tools and
Interfaces on Subsea Production
Systems.
As related to BOP systems:
—ANSI/API Spec. 6A, Specification for
Wellhead and Christmas Tree
Equipment;
—ANSI/API Spec. 16A, Specification
for Drill-through Equipment;
—API Spec. 16C, Specification for
Choke and Kill Systems;
—API Spec. 16D, Specification for
Control Systems for Drilling Well
Control Equipment and Control
Systems for Diverter Equipment; and
—ANSI/API Spec. 17D, Design and
Operation of Subsea Production
Systems—Subsea Wellhead and Tree
Equipment.
(2) Revise the requirements for
Deepwater Operations Plan (DWOP)
which are required to be submitted to
BSEE, to include requirements on free
standing hybrid risers (FSHR) for use
with floating production, storage, and
offloading units (FPSO).
(3) Revise sections in 30 CFR part 250
Subpart D, Oil and Gas Drilling
Operations, to include requirements for:
—Submittal of equivalent circulating
density (ECD) with the Application
for Permit to Drill (APD);
—Safe drilling margin;
—Wellhead description;
—Casing or liner centralization during
cementing; and
—Source control and containment.
(4) Revise sections in Subparts E, Oil
and Gas Well-Completion Operations,
and F, Oil and Gas Well-Workover
Operations, to include requirements for:
—Packer and bridge plug design, and
—Production packer setting depth.
(5) Revise sections in Subpart Q,
Decommissioning Activities, to include
requirements for:
—Packer and bridge plug design,
—Casing bridge plugs, and
—Decommissioning applications and
reports.
(6) Add new Subpart G, Well
Operations and Equipment, and move
common requirements from Subparts D,
E, F, and Q into new Subpart G.
Include new requirements in Subpart
G for:
—Rig and equipment movement reports,
—Real-time monitoring, and
—Revised BOP requirements, including:
—Design and manufacture/quality
assurance;
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—Accumulator system capabilities and
calculations;
—BOP and remotely operated vehicle
(ROV) capabilities;
—BOP functions (e.g., shearing);
—Improved and consistent testing
frequencies;
—Maintenance;
—Inspections;
—Failure reporting;
—Third-party verification; and
—Additional submittals to BSEE
including up-to-date schematics.
(7) Incorporate the guidance from
several Notices to Lessees and Operators
(NTLs) into Subpart G for:
—Global Position Systems (GPS) for
Mobile Offshore Drilling Units
(MODUs);
—Ocean Current Monitoring;
—Using Alternate Compliance in Safety
Systems for Subsea Production
Operations;
—Standard Reporting Period for the
Well Activity Report (WAR); and
—Information to include in the WARs
and End of Operation Reports
(EOR).
Table of Contents
I. Background
BSEE Statutory and Regulatory Authority
Availability of Incorporated Documents for
Public Viewing
Summary of Documents Incorporated by
Reference
Deepwater Horizon Investigations
Recommendations on BOPs
Stakeholder Participation
BSEE Response to Recommendations and
Additional Considerations
II. Organization of Subpart G
III. Effective Date of a Final Rule
IV. Future Plans for Subpart G
V. Section-By-Section Discussion Appendix
VI. Derivation Tables
VII. Procedural Matters
I. Background
BSEE
In relation to oil and gas exploration,
development, and production
operations on the Outer Continental
Shelf (OCS), the Bureau of Safety and
Environmental Enforcement (BSEE)
regulates offshore oil and gas operations
to promote safety, protect the
environment, and conserve offshore oil
and gas resources. The BSEE was
established on October 1, 2011, as part
of a major restructuring of DOI’s
offshore oil and gas regulatory programs
to improve the management, oversight,
and accountability of activities on the
OCS. The Secretary of the Interior
(Secretary) announced the new division
of responsibilities of the former
Minerals Management Service (MMS)
into two new bureaus and one office
within DOI in Secretarial Order No.
3299, issued on May 19, 2010. The
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BSEE, one of the two new bureaus,
assumed responsibility for ‘‘safety and
environmental enforcement functions
including, but not limited to, the
authority to permit activities, inspect,
investigate, summon witnesses and
[require production of] evidence[;] levy
penalties; cancel or suspend activities;
and oversee safety, response and
removal preparedness’’ (76 FR 64432,
October 18, 2011).
BSEE Statutory and Regulatory
Authority
The BSEE derives its authority
primarily from the Outer Continental
Shelf Lands Act (OCSLA), 43 U.S.C.
1331–1356a. Congress enacted OCSLA
in 1953, establishing Federal control
over the OCS and authorizing the
Secretary to regulate oil and gas
exploration, development, and
production operations on the OCS. The
Secretary has authorized BSEE to
perform these functions under 30 CFR
250.101.
To carry out its responsibilities, BSEE
regulates offshore oil and gas operations
to enhance the safety of offshore
exploration and development of oil and
gas on the OCS and to ensure that those
operations protect the environment and
implement advancements in technology.
The BSEE also conducts onsite
inspections to assure compliance with
regulations, lease terms, and approved
plans. Detailed information concerning
BSEE’s regulations and guidance to the
offshore oil and gas industry may be
found on BSEE’s Web site at: https://
www.bsee.gov/Regulations-andGuidance/index.aspx.
The BSEE regulatory program
regulates a wide range of facilities and
activities, including drilling,
completion, workover, production,
pipeline, and decommissioning
operations. Drilling, completion, and
workover operations are types of well
operations offshore operators perform
throughout the OCS from fixed and
floating facilities. These well operations
are the primary topic of this proposed
rulemaking.
Ensuring the integrity of the wellbore
and maintaining control over the
pressure and fluids during well
operations are critical aspects of
protecting worker safety and the
environment. The investigations that
followed the Deepwater Horizon
incident documented gaps or
deficiencies in the OCS regulatory
programs and made recommendations
for improvements. The objective of this
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rulemaking is to address many of these
recommendations, especially those
related to BOP system design,
performance, and reliability.
The BOP equipment and systems are
critical components of many well
operations. The BOP systems can be the
last defense against a release of
hydrocarbons into the environment,
when all other forms of well control
have failed (e.g., the drilling fluid
program). The BOPs may be the last line
of defense in preventing release of gas
that is volatile and considered to be an
extreme safety hazard to rig personnel
(uncontrolled gas releases can lead to
explosions). The primary purpose of
BOP systems is to prevent the
uncontrolled release of hydrocarbons in
an emergency situation by mechanically
closing valves or rams that block the
flow of fluid from the well. In some
situations, this may require shear rams
on the BOP stack to sever the drill pipe
before the well can be sealed.
The BOP equipment and systems have
increased in complexity as the industry
moves into deeper water and develops
reservoirs with pressures greater than
15,000 pounds per square inch (psi) or
temperatures greater than 350 degrees
Fahrenheit (F). Reservoirs with these
conditions are considered high pressure
high temperature (HPHT). Most of the
BOPs that are used in deep water
operations (400 to 10,000 feet) are
located on the seabed, which presents
technological and operational
challenges. Additionally, HPHT
operations create special metallurgical
and design issues.
In this rulemaking, BSEE intends to:
• Implement many of the
recommendations related to wellcontrol equipment and fill gaps in the
regulatory program.
• Increase the performance and
reliability of well-control equipment,
especially BOPs.
• Improve regulatory oversight over
the design, fabrication, maintenance,
inspection, and repair of critical
equipment.
• Gain information on leading and
lagging indicators of BOP component
failures, identify trends in those
failures, and help prevent accidents.
• Ensure that the industry uses
recognized engineering practices, as
well as innovative technology and
techniques to increase overall safety.
of the public with Web site addresses
where these standards may be accessed
for viewing—sometimes for free and
sometimes for a fee. Standardsdeveloping organizations decide
whether to charge a fee. The API
provides free online public access to key
industry standards, including a broad
range of technical standards. These free
standards represent almost one-third of
all API standards and include all that
are safety-related or have been or are
proposed to be incorporated into
Federal regulations, including the
standards in this rule. These standards
are available for online review, and
hardcopies and printable versions will
continue to be available for purchase.
We are proposing to incorporate certain
API standards. The API Web site
address is: https://www.api.org/
publications-standards-and-statistics/
publications/government-cited-safetydocuments.
For the convenience of the viewing
public, who may not wish to purchase
or view these proposed documents
online, they may be inspected at BSEE,
45600 Woodland Road, Sterling,
Virginia 20166; phone: 703–787–1665;
or at the National Archives and Records
Administration (NARA). For
information on the availability of this
material at NARA, call 202–741–6030,
or go to: https://www.archives.gov/
federal-register/cfr/ibr-locations.html.
These documents, if incorporated in
the final rule, would continue to be
made available to the public for viewing
when requested. Specific information
on where these documents can be
inspected or obtained can be found at 30
CFR 250.198, Documents incorporated
by reference.
Availability of Incorporated Documents
for Public Viewing
When a copyrighted technical
industry standard is incorporated by
reference into our regulations, BSEE is
obligated to observe and protect that
copyright. The BSEE provides members
API Standard 53—Blowout Prevention
Equipment Systems for Drilling Wells
This standard is to provide
requirements for the installation and
testing of blowout prevention
equipment systems whose primary
functions are to confine well fluids to
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Summary of Documents Incorporated by
Reference
This rulemaking is substantive in
terms of the content that is explicitly
stated in the rule text itself, but it also
incorporates by reference some very
technical, detailed standards and
specifications in the topic of blowout
preventers and well control. In their
aggregate this represents one of the most
substantial rulemakings in the history of
the BSEE and its predecessor
organizations. A brief summary, based
on the descriptions in each standard or
specification, is provided in the text that
follows.
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the wellbore, provide means to add
fluid to the wellbore, and allow
controlled volumes to be removed from
the wellbore. Blowout preventer
equipment systems are comprised of a
combination of various components that
are covered by this document.
Equipment arrangements are also
addressed. The components covered
include:
Blowout preventers (BOPs) including
installations for surface and subsea
BOPs;
Choke and kill lines;
Choke manifolds;
Control systems; and
Auxiliary equipment.
This document provides new industry
best practices related to:
The use of double shear rams
Maintenance and testing
requirements.
Failure Reporting
Diverters, shut-in devices, and
rotating head systems (rotating control
devices) whose primary purpose is to
safely divert or direct flow rather than
to confine fluids to the wellbore are not
addressed. Procedures and techniques
for well control and extreme
temperature operations are also not
included in this standard.
API Recommended Practice 2RD—
Design of Risers for Floating Production
Systems and Tension-Leg Platforms
This document addresses structural
analysis procedures, design guidelines,
component selection criteria, and
typical designs for all new riser systems
used on Floating Production Systems
(FPSs and Tension-Leg Platforms
(TLPs). The presence of riser systems
within an FPS has a direct and often
significant effect on the design of all
other major equipment subsystems. This
RP includes recommendations on: (1)
Configurations and components, (2)
general design considerations based on
environmental and functional
requirements, and (3) materials
considerations in riser design.
API Specification Q1—Specification for
Quality Management System
Requirements for Manufacturing
Organizations for the Petroleum and
Natural Gas Industry
This specification establishes the
minimum quality management system
requirements for organizations that
manufacture products or provide
manufacturing-related processes under a
product specification for use in the
petroleum and natural gas industry.
This document requires that equipment
be fabricated under a quality
management system that provides for
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continual improvement, emphasizing
defect prevention and the reduction of
variation and waste in the supply chain
and from service providers. The goal of
this specification is to increase
equipment reliability through better
manufacturing controls.
API Specification 6A—Specification for
Wellhead and Christmas Tree
Equipment
This specification defines minimal
requirements for the design of valves,
wellheads and Christmas tree
equipment that is used during drilling
and production operations. This
specification includes requirements
related to dimensional and functional
interchangeability, design, materials,
testing, inspection, welding, marking,
handling, storing, shipment, purchasing,
repair and remanufacture.
ANSI/API Specification 11D1—Packers
and Bridge Plugs
This specification provides minimum
requirements and guidelines for packers
and bridge plugs used downhole in oil
and gas operations. The performance of
this equipment is often critical to
maintaining control of a well during
drilling or production operations. This
specification provides requirements for
the functional specification and
technical specification, including
design, design verification and
validation, materials, documentation
and data control, repair, shipment, and
storage.
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ANSI/API Specification 16A—
Specification for Drill-Through
Equipment
This specification defines
requirements for performance, design,
materials, testing and inspection,
welding, marking, handling, storing and
shipping of BOPs and drill-through
equipment used for drilling for oil and
gas. It also defines service conditions in
terms of pressure, temperature and
wellbore fluids for which the equipment
will be designed. This standard is
applicable to and establishes
requirements for the following specific
equipment: ram blowout preventers;
ram blocks, packers and top seals;
annular blowout preventers; annular
packing units; hydraulic connectors;
drilling spools; adapters; loose
connections; and clamps.
Conformance to this standard is
necessary to ensure that this critical
safety equipment has been designed and
fabricated in a manner that ensures
reliable performance.
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API Specification 16C—Specification
for Choke and Kill Systems
This specification was formulated to
provide for safe and functionally
interchangeable surface and subsea
choke and kill systems equipment
utilized for drilling oil and gas wells.
This equipment is used during
emergencies to circulate out a ‘‘kick’’
and therefore, the design and fabrication
of the components is extremely
important. The technical content in the
document provides the minimum
requirements for performance, design,
materials, welding, testing, inspection,
storing and shipping. Equipment
specific to and covered by this
specification includes:
Actuated valve control lines;
Articulated choke & kill line;
Drilling choke actuators;
Drilling choke control lines, exclusive
of BOP control lines;
Subsurface safety valve control lines;
Drilling choke controls;
Drilling chokes;
Flexible choke and kill lines;
Union connections;
Rigid choke and kill lines; and
Swivel unions.
API Specification 16D—Specification
for Control Systems for Drilling Well
Control Equipment and Control Systems
for Diverter Equipment
This specification establishes design
standards for systems that are used to
control BOPs and associated valves that
control well pressure during drilling
operations. Although diverters are not
considered well control devices, their
controls are often incorporated as part of
the BOP control system. Thus, control
systems for diverter equipment are
included in the specification. Control
systems for drilling well control
equipment typically employ stored
energy in the form of pressurized
hydraulic fluid (power fluid) to operate
(open and close) the BOP stack
components. For deepwater operations,
transmission subsea of electric/optical
(rather than hydraulic) signals may be
used to short response times. The failure
of these controls to perform as designed
can result in a major well control event.
As a result, conformance to this
specification is critical to ensuring that
the BOPs and related equipment will
operate in an emergency.
ANSI/API Specification 17D—Design
and Operation of Subsea Production
Systems—Subsea Wellhead and Tree
Equipment
This specification provides
specifications for subsea wellheads,
mudline wellheads, drill-through
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mudline wellheads and both vertical
and horizontal subsea trees. These
devices are located on the seafloor, and
therefore, ensuring the safe and reliable
performance of this equipment is
extremely important. This document
specifies the associated tooling
necessary to handle, test and install the
equipment. It also specifies the areas of
design, material, welding, quality
control (including factory acceptance
testing), marking, storing and shipping
for both individual sub-assemblies (used
to build complete subsea tree
assemblies) and complete subsea tree
assemblies.
API Recommended Practice 17H—
Remotely Operated Tools and Interfaces
on Subsea Production Systems
This recommended practice has been
prepared to provide general
recommendations and overall guidance
for the design and operation of remotely
operated tools (ROT) comprising ROT
and ROV tooling used on offshore
subsea systems. ROT and ROV
performance is critical to ensuring safe
and reliable deepwater operations and
this document provides general
performance guidelines for the
equipment.
Deepwater Horizon Investigations
This section discusses relevant
investigations that have significant
bearing on this proposed rulemaking.
DOI/DHS Investigation
The joint DOI/DHS investigation
started on April 27, 2010, when the
Secretaries of DOI and DHS convened a
joint investigation team (JIT) comprised
of staff from the MMS and the U.S.
Coast Guard (USCG). The JIT held seven
public hearings and heard testimony
from more than 80 witnesses. The DOI
JIT issued a report on September 14,
2011, entitled, REPORT REGARDING
THE CAUSES OF THE APRIL 20, 2010
MACONDO WELL BLOWOUT, which
included its findings, conclusions, and
recommendations.
National Commission
On May 22, 2010, President Barack
Obama announced the creation of the
National Commission on the BP
Deepwater Horizon Oil Spill and
Offshore Drilling (National
Commission), an independent, nonpartisan entity. The President charged
the National Commission to determine
the causes of the disaster, to make
recommendations for improvement to
the country’s ability to respond to spills,
and to recommend reforms to make
offshore energy production safer. The
National Commission published its final
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report on January 11, 2011, entitled,
DEEP WATER, The Gulf Oil Disaster
and the Future of Offshore Drilling.
Chief Counsel for the National
Commission
Given the factual and technical
complexity of some of the underlying
causes of the blowout, the National
Commission’s Chief Counsel issued a
separate report setting forth in greater
detail its findings and conclusions
regarding the technical, managerial, and
regulatory aspects of the blowout. The
report contains findings and
conclusions about the loss of well
control, and also contains
recommendations to industry and
government to enhance well design. The
Chief Counsel’s report was published on
February 17, 2011, and is entitled,
Macondo: The Gulf Oil Disaster.
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National Academy of Engineering
At the request of DOI, a National
Academy of Engineering (NAE)/
National Research Council committee
examined the probable causes of the
Deepwater Horizon explosion, fire, and
oil spill in order to identify measures for
preventing similar harm in the future.
The final report was released December
14, 2011, and is entitled, Macondo WellDeepwater Horizon Blowout. The final
report provides findings about the
causes of the loss of well control and the
failure of the BOP to prevent release of
hydrocarbons and offers
recommendations to industry and
government that would strengthen
oversight of deepwater wells, enhance
system safety, and improve cementing
practices and the technical skills of
industry and regulatory staff.
Recommendations on BOPs
Each of the previously discussed
investigations resulted in reports that
contained recommendations to improve
offshore safety. One consistent element
in each of the investigations was the
recognition that additional requirements
related to BOPs and well-control
equipment are needed. The following
list contains some of the
recommendations on BOPs and related
equipment from the various
investigations:
—The BSEE should consider
promulgating regulations that require
operators/contractors to have the
capability to monitor the subsea
electronic module (SEM) battery(ies)
from the drilling rig, to ensure that
there is sufficient battery power to
operate the system.
—The BSEE should consider requiring
standardization of: Remotely
Operated Vehicle (ROV) intervention
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panels, ROV intervention capabilities,
and maximum closing times when
using an ROV; ROV hot stab and
receptacles per API RP 17H; and hot
stab designs between drilling and
production operations.
—The BSEE should consider requiring a
blind-shear ram design that
incorporates improved pipe-centering
in the shear ram.
—The BSEE should make effective use
of industry standards and best
practice guidelines used by other
countries with the recognition that
standards need to be updated and
revised continually.
—The BSEE should improve reporting
of safety-related incidents and require
the reporting of near-misses to assist
in accident prevention and to improve
standards.
—The BSEE should develop
standardized requirements for the
training and certification of key
industry personnel.
—The BSEE should rely on independent
organizations to verify and certify
compliance with critical designs and
required processes.
—The BSEE should ensure that the
general well design includes a review
of fitness of the components for the
intended use.
—The BSEE should consider
promulgating regulations that would
require operators to report leaks
associated with BOP control systems.
—The BSEE should consider
promulgating regulations that would
require real-time, remote capture of
drilling data and BOP function data.
—The BSEE should require
improvement of the instrumentation
on BOP systems so that the
functionality and condition of the
BOP can be monitored continuously.
—The BSEE should consider regulations
that address a reasonable margin of
safety between the ECD and the
pressure that would cause wellbore
fracturing.
—The BSEE should establish testing and
maintenance requirements for BOPs
to ensure operability and increased
reliability appropriate to the
environment and application.
—The BSEE should require
improvement of the design
capabilities of the BOP systems so
that they can shear and seal all
combinations of pipe under all
possible conditions of load from the
pipe and from the well flow, and so
that there would always be a
shearable section of the drill pipe in
front of a blind-shear ram in the BOP.
—The BSEE should require
demonstration of the performance of
the design capabilities of BOPs and
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require that they be independently
certified on a regular basis by test or
other means.
Stakeholder Participation
Since the Deepwater Horizon
incident, BSEE has made it a priority to
participate in meetings, training, and
workshops with industry, standards
organizations, and other stakeholders.
The BSEE recognized that it was
important to collect the best ideas on
the prevention of well-control incidents
and blowouts to assist in the
development of this proposed rule. This
includes the knowledge and skillset that
industry has, and BSEE wants to benefit
from that experience to improve the
safety of all operations on the OCS.
Therefore, on May 22, 2012, BSEE
hosted a public offshore energy safety
forum that brought together Federal
decision-makers, industry, academia,
and other stakeholders to discuss
additional steps that BSEE and the
industry might take to continue to
improve the reliability and safety of
BOPs. This public forum provided
industry experts, Federal decisionmakers, and the public the opportunity
for free and open dialogue. Discussion
panels consisted of representatives from
government organizations, trade
associations, equipment manufacturers,
offshore operators, consultants, training
companies, and others. During the
forum, five separate panels discussed
the following BOP topics:
—BOP technology needs identified by
Deepwater Horizon investigations;
—Real-time technologies that can aid in
diagnostics and kick detection;
—Design requirements needed to
provide assurance that BOPs would
cut casing or drill pipe and seal a well
effectively;
—Manufacturing, testing, maintenance,
and certification requirements needed
to ensure operability and reliability of
BOP equipment; and
—Training and certification needs for
industry personnel operating or
maintaining BOPs.
You can find additional information
about the forum, including
presentations and transcripts, on the
BSEE Web page at: https://www.bsee.gov/
BSEE-Newsroom/BSEE-News-Briefs/
2012/BSEE-Hosts-BOP-Forum-in-DC. In
the year following this forum, BSEE has
also received significant input and
specific recommendations from industry
groups, operators, equipment
manufacturers, and environmental
organizations on each of these items.
For example, BSEE has actively
participated in the following, among
other events:
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—The API Exploration & Production
Standards Conference on Oilfield
Equipment and Materials;
—The Ocean Energy Safety Institute risk
forum;
—The Offshore Well Control Equipment
Forum, organized by API, January 30,
2014;
—The International Regulators Forum;
—Various standards committees and
sub-committees for standards
development (e.g., API Committee on
Standardization of Oilfield Equipment
and Material Subcommittee 16 on
Drilling Well Control Equipment);
—The BSEE and industry assessments
of current technology involving
research that BSEE is funding; and
—The BSEE sponsored standards
workshops—November 2012 and
January 2014.
The BSEE has considered this input
in developing this proposed rulemaking
and has reviewed studies and research
on this topic.
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BSEE Response to Recommendations
and Additional Considerations
The BSEE evaluated all
recommendations from the investigative
bodies and public input and determined
that the agency needs to update
regulations related to the prevention of
blowouts. The prevention of blowouts,
either through precautionary measures
or by operation of a BOP, is a critical
priority for BSEE. The BSEE therefore
focused this rulemaking on updating
and revising current well-control
regulations.
Several of the recommendations
related to BSEE’s regulatory programs
were already implemented in
rulemakings following the Deepwater
Horizon incident. The following items
are included in this proposed rule and
arise out of the investigation reports or
from other third-party
recommendations.
Shearing Requirements
The BSEE regulations currently
require that a BOP stack include a blind
shear ram. A blind shear ram is
designed to cut drill pipe in the well
and shut in the well in an emergency
well control situation. In order for a
blind shear ram to shut in a well where
drill pipe is across the BOP, it must be
capable of shearing the drill pipe and
there are known mechanical and design
limitations that may prevent this from
occurring. As demonstrated by the
Deepwater Horizon incident, the failure
of equipment to perform reliably can
result in a major safety and/or
environmental event.
Prior to the Deepwater Horizon
incident, MMS commissioned the
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following research on shearing
capabilities: Technical Assessment &
Research (TAR) Project 383,
Performance of Deepwater BOP
Equipment During Well-control Events;
TAR Project 408, Development of a
Blowout Intervention Method and
Dynamic Kill Simulated for Blowouts
Occurring Ultra-Deepwater; TAR Project
431, Evaluation of Secondary
Intervention Methods in Well-control;
TAR Project 455, Review of Shear Ram
Capabilities; and TAR Project 463,
Evaluation of Sheer Ram Capabilities.
This research can be found at https://
www.bsee.gov/Technology-andResearch/Technology-AssessmentPrograms/Categories/Drilling/. The
research indicated that there was a large
amount of uncertainty related to the
shearing capability of existing BOPs.
These reports documented that there
were inconsistent and inadequate
testing protocols used by manufacturers
to demonstrate shearing capability, a
failure to share shearing data that would
allow for a better understanding of
shearing capability, and a concern that
not all operators and drilling contractors
are aware of the limitations of the
equipment they are using.
Following the Deepwater Horizon
incident, the Agency received
recommendations from multiple
investigations and studies concerning
the need for new and more rigorous
requirements and technologies to ensure
that drilling components can be severed
and a well safely shut-in during an
emergency. The BSEE is proposing a
series of new requirements to address
the gaps that were identified in these
reports, incorporate recent industry
standards, and assist in the adoption of
improved technology through
performance-based requirements.
Some of the limitations of current
designs are well known. Industry
acknowledges that BOP equipment
would not shear drill collars, heavy
weight drill pipe, or drill pipe tool
joints. This inability to shear all of the
components in the drill string can create
significant complications in an
emergency situation and increase the
likelihood of a catastrophic event
occurring. As the industry continues to
develop more technically challenging
resources, shearing and sealing become
more difficult for several reasons,
including:
—The improvements in drill pipe
properties, particularly increased
material strength and ductility, result
in higher forces being required to
shear the drill pipe in the future.
—Increased water depths, in
combination with drilling fluid
density and shut-in pressure,
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contribute to a BOP having to generate
additional force to successfully shear.
The BSEE believes that the current
testing protocols and verification
procedures must be strengthened to
ensure that the capabilities of shearing
equipment are clearly understood and
demonstrated. Furthermore, on a longer
term basis, the overall performance of
this equipment must improve to ensure
that it can operate in an emergency
situation and can successfully shear a
drill stem. In this rule, BSEE is
proposing to accomplish these
objectives through the following:
—Require operators to assure that
shearing capability for existing
equipment complies with BSEE
requirements related to shearing by
performing tests and providing
detailed results to a BSEE-approved
verification organization. This
organization would perform an
independent engineering review of
the test protocols and data and ensure
that the testing would provide
reasonable assurances that the
equipment would perform as
designed on drill pipe of specific
mechanical and physical properties
and under the operating conditions
relevant to the particular well at
which the equipment will be used.
The BSEE expects that the
independent engineering review
would be based on recognized
engineering practices. To become a
BSEE-approved verification
organization, organizations would
need to submit documentation for
BSEE approval describing the
applicable qualifications and
experience. This engineering review
process would assist in developing
more standardized testing protocols,
increase data sharing within the
industry, and provide information for
future BSEE determinations of best
available and safest technologies
under section 21 of OSCLA, 43 U.S.C.
1347. The BSEE anticipates that
industry would play an important role
in this process by developing rigorous
testing procedures and protocols for
organizations that perform the testing.
—Require compliance with the latest
industry standards contained in API
Standard 53. In addition to these
industry standards, BSEE would also
include a requirement that operators
use two shear rams in subsea BOP
stacks. The use of double shear rams
would increase the likelihood that a
drill string can be sheared by ensuring
that a shearable component is
opposite a shear ram. In this proposed
rulemaking, BSEE will not propose
adopting the provision in API
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Standard 53 that operators can ‘‘opt
out’’ of this double shear ram
requirement for moored rigs. If there
are unique circumstances that prevent
the use of two shear rams, operators
would be able to apply for the use of
alternative procedures or equipment
under § 250.141.
—Require the use of BOP technology
that provides for better shearing
performance through the centering of
the drill pipe in the shear rams. A
number of investigations 1 have found
that the shear rams did not
completely cut the drill pipe in the
Deepwater Horizon. This occurred
because the drill pipe was not
centered within the stack. The BSEE
is aware of at least one BOP
equipment manufacturer that
currently has pipe centering
technology available and proposes to
require the use of pipe centering
within 7 years after the publication of
the final rule to encourage further
technological development.
Equipment Reliability and Performance
Prior to the Deepwater Horizon
incident, the industry’s guidance
document for the operation of BOPs was
API RP 53—Recommended Practices for
Blowout Prevention Equipment Systems
for Drilling Wells, Third Edition, March
1, 1997 (Reaffirmed September 1, 2004).
The BSEE currently incorporates only
specific sections of this document in
existing regulations, including sections
related to maintenance, inspection, and
accumulator systems. Following the
Deepwater Horizon incident, industry
recognized the need to enhance BOP
guidance and concluded that it was
necessary to completely rewrite API RP
53 and upgrade the document from an
RP to a standard. The BSEE participated
in the development of the industry
standard and is proposing to incorporate
the newly published standard into its
regulations. Additionally, other key
industry standards concerning this type
of equipment would be incorporated by
reference.
The BSEE concluded that
incorporating new API Standard 53
provisions into its regulations would
allow for better regulatory oversight and
would ensure improved BOP design and
operability. The BSEE believes that the
incorporation of this document, and
other key industry standards, such as
ANSI/API Spec. 6A, ANSI/API Spec.
16A, API Spec. 16C, API Spec. 16D,
ANSI/API Spec. 17D, and API Spec. Q1,
would establish minimum design,
manufacture, and performance baselines
for this equipment and is essential to
1 See
DOI JIT investigation recommendation, D6.
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ensure the reliability and performance
of this equipment. The BSEE anticipates
that BOP equipment that meets these
new requirements, along with several
supplemental requirements (such as
requiring blind-shear rams that
incorporate improved pipe-centering
designs), would perform in a more
reliable manner.
The BSEE believes that the reliability
of BOP-related equipment would also
increase if its inspection, maintenance,
and repair are performed by highlytrained personnel. Operators are
currently required by BSEE regulations
to ensure that all personnel are properly
trained. The BSEE proposes to add
requirements that specify that these
personnel be qualified and trained
pursuant to original equipment
manufacturer (OEM) recommendations,
unless otherwise specified by BSEE. The
BSEE encourages industry to develop
standards and certification programs for
these personnel.
Third-Party Verification
Regulatory oversight of the lifecycle of
BOP equipment, ranging from design,
installation, inspection, testing,
maintenance, and repair, presents a
variety of logistical and technical
challenges, especially because the
equipment might be used at multiple
locations. In several sections of the
proposed regulations, BSEE would
require third-party verification of the
design, maintenance, inspection,
testing, and repair of BOP systems and
equipment by a BSEE-approved entity.
We believe that the use of third-party
verification organizations would help
BSEE ensure that these systems are
designed and maintained during their
entire service life to minimize risk. For
subsea BOPs or BOPs used in HPHT
applications, we are proposing that
BSEE-approved verification
organizations submit reports verifying
compliance with these new
requirements. This verification would
provide BSEE with reasonable assurance
that the equipment is fit for service as
intended.
The BSEE is also proposing an
additional qualification and verification
process for BOP(s) and related
equipment used in HPHT wells. The
verification must be specific to the
conditions of the particular well at
which the BOP(s) will be used. This
verification process is needed because
there are currently no engineering
standards for the design, fabrication,
and testing of equipment used in HPHT
conditions. The use of a BSEE-approved
verification organization would provide
an additional layer of review and
verification during the development and
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operation of the equipment. It would be
the responsibility of the operator to
clearly demonstrate to the BSEEapproved verification organization and
BSEE that the equipment was designed
for the HPHT conditions specific to the
well, and will perform in a reliable
manner during its service life under
those conditions. To become a BSEEapproved verification organization, the
organization would have to submit
documentation for approval describing
the organization’s applicable
qualifications and experience.
Failure Reporting/Near-Miss Reporting
Several of the standards that BSEE
proposes to incorporate by reference
contain failure reporting processes that
ensure that operators share information
with OEMs related to the performance
of their equipment. This sharing of
information makes it possible for the
OEMs to notify users of any safety
issues that arise. In 2009, the industry
provided the MMS with a BOP
reliability study that specifically noted
the importance of ANSI/API Spec. 16A,
Annex F, and referred to this
requirement as ‘‘an excellent practice
that assists manufacturers in identifying
problems that occur in the operation
and maintenance of their projects.’’ The
BSEE agrees with this statement and is
including this requirement in the
proposed regulations.
Because the same equipment designs
are often used by multiple operators,
ensuring the timely reporting of this
type of data can play an important role
in preventing future incidents. The need
for a formalized process for
disseminating information to the
industry was clearly demonstrated
following the December 2012 failures of
certain bolts used in BOPs and wellhead
connectors in the Gulf of Mexico
(GOM). Subsequent investigations
revealed that although these failures had
occurred over a period of years, most of
the industry was not aware of the safety
issues. The BSEE is proposing that the
operators report any significant
problems with BOP or well-control
equipment to BSEE to ensure that this
information can be provided in a timely
manner to OCS operators and the
international community. In the long
term, BSEE would continue to
encourage industry to develop a
comprehensive and formalized method
of collecting, analyzing, and
disseminating failure data involving
critical equipment.
Safe Drilling Practices
The proposed regulations include
new requirements related to the
maintenance of safe drilling margins
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consistent with the recommendations
arising out of Deepwater Horizon
investigations. The BSEE also proposes
to add requirements related to liners
and other downhole equipment. We
believe that these requirements would
help to reduce the likelihood of a major
well-control event occurring and ensure
the overall integrity of the well design.
The proposed rule would require that
operators have the capability to monitor
deepwater and HPHT drilling
operations from the shore and in real
time. This would allow operators to
anticipate and identify issues in a
timely manner and to utilize onshore
resources to assist in addressing critical
issues. It would allow BSEE greater
visibility of operations so BSEE may
focus on specific critical operations for
additional oversight.
The BSEE also proposes a
requirement that designated operators
report leaks associated with BOP control
systems on the daily report, in the WAR,
and directly to the District Manager.
This requirement would ensure that the
agency is made aware of any leaks and
may determine if agency action is
appropriate.
The proposed regulation would
include requirements concerning ROV
operations, including the adoption of
API RP 17H to standardize ROV hot stab
activities. An ROV hot stab is a high
pressure subsea connector used to
connect the ROV into the BOP system.
An ROV hot stab is basically comprised
of two parts:
—A valve; and
—A tool that connects onto the valve
and controls the valve.
The valve is usually placed on the
subsea BOP stack panel, and is
accessible for an ROV to insert the tool
and activate certain functions on the
BOP.
BOP Testing
In response to public input related to
the value of pressure testing in
predicting future performance of a BOP
and industry concerns about the
operational safety issues associated with
performing these tests, BSEE proposes
to modify the BOP testing frequency for
workover and decommissioning
operations. The BSEE proposes to
change the current 7 day BOP testing
interval for workover (current
§ 250.617(b)) and decommissioning
(current § 250.1707(b)) operations to 14
days, which is consistent with the
testing frequency requirements
(reference current § 250.447(b) and
250.517(a)) for drilling and completion
operations. Some drilling, completion,
workover, and decommissioning
operations use the same rigs and BOP
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systems; therefore, to ensure
consistency among different operations
involving the same equipment, BSEE
proposes to harmonize the requirements
for that type of equipment. Harmonizing
the testing frequency would streamline
the BOP function-testing criteria and
increase safety by reducing repetition of
operations, such as pulling out of the
hole and running in the hole, that pose
operational safety issues, therefore
limiting the exposure of potential risks
to offshore personnel. This may also
have a positive effect on overall
equipment durability and reliability.
A benefit of this provision would be
a cost saving to industry. We estimated
the total cost savings to industry from
this provision to be $150,000,000 per
year (see the economic analysis for more
detailed information). Based upon
existing available data and the
timeframes of the economic analysis,
the cost savings benefits of the proposed
rule would result in benefits greater
than the identified quantitative costs of
the rule. The BSEE is requesting
comments on whether the proposed
BOP testing interval should be 7 days,
14 days (as proposed), or 21 days for all
types of operations including drilling,
completions, workovers, and
decommissioning. The BSEE is also
requesting comments on the specific
cost implications of each testing interval
to further its consideration of the issue.
For more information on the costs and
benefits of the proposed rule, refer to
the economic analysis.
In addition to cost savings benefits,
BSEE’s economic analysis also
considers benefits from potential
reductions in oil spills and reduced
fatalities. The BSEE is requiring
additional measures (e.g. real-time
monitoring and increased maintenance)
that help ensure the functionality and
operability of the BOP system and,
therefore, will reduce the risks of spills
and fatalities.
The BSEE is also soliciting comments
on the use of pressure and functional
tests during drilling operations to verify
performance, the adequacy of current
and proposed testing requirements, and
the identification of risks associated
with increasing or decreasing the testing
frequency.
II. Organization of Subpart G
The BSEE determined that the most
effective way to communicate consistent
requirements for BOPs across all well
operations (drilling, completion,
workover, and decommissioning) is to
consolidate those common requirements
in one location. The current regulations
repeat similar BOP requirements in
multiple locations throughout 30 CFR
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21511
part 250. The BSEE is proposing to
consolidate these requirements into
Subpart G, which is currently reserved.
This would allow better flexibility,
efficiency, and consistency in future
rulemaking. The proposed rule would
structure proposed Subpart G—Well
Operations and Equipment, under the
following undesignated headings:
—GENERAL REQUIREMENTS
—RIG REQUIREMENTS
—WELL OPERATIONS
—BLOWOUT PREVENTER (BOP)
SYSTEM REQUIREMENTS
—RECORDS AND REPORTING
The sections contained within this
new subpart would apply to all drilling,
completion, workover, and
decommissioning activities, unless
explicitly stated otherwise.
III. Effective Date of a Final Rule
The BSEE understands that operators
may need time to comply with certain
requirements proposed in this rule. The
BSEE is taking into consideration the
amount of time needed to meet the
requirements for the installation of
double shear rams and new certification
requirements. Based on information
provided by industry, all new drilling
rigs are already being built, pursuant to
the same industry standards BSEE now
proposes to adopt (including API
Standard 53), and many have already
been retrofitted to comply with these
industry standards. Furthermore, most
already comply with recognized
engineering practices and OEM
requirements related to repair and
training. The BSEE evaluated the
proposed requirements in this proposed
rule and seeks to set reasonable effective
dates for those requirements based on
information gained during, among other
activities, interaction with stakeholders,
involvement with development of
industry standards, and evaluation of
current technology. The BSEE proposes
an effective date of 3 months following
publication of the final rule. Operators
would be required to demonstrate
compliance with most of the proposed
requirements at that time, with the
exception of the following more
extended timeframes:
—Operators would be required to
comply with the real-time monitoring
requirements within 3 years from the
publication of the final rule.
—Operators would be required to install
double shear rams on subsea BOPs
and on surface BOPs on floating
facilities within 5 years from the
publication of the final rule.
—Operators would be required to install
shear rams that center drill pipe
during shearing operations within 7
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years from the publication of the final
rule.
The BSEE is soliciting comments
about the proposed compliance dates for
the requirements in this proposed rule
to ensure the dates are appropriate. The
BSEE is specifically soliciting comments
on whether the 3-month, 3-year, 5-year,
and 7-year compliance dates are
appropriate and achievable. The BSEE is
also specifically soliciting comments on
whether the proposed requirements can
be met sooner than the proposed
compliance dates (e.g., 5 years after
publication of the final rule for
centering drill pipe), and the anticipated
costs for meeting these proposed
compliance dates. Please provide
justification for your responses.
Note that BSEE still retains the
discretion under § 250.141 to authorize
alternate procedures or equipment that
provide an equivalent level of safety and
environmental protection.
IV. Future Plans for Subpart G
In future rulemaking, BSEE intends to
include additional regulatory
requirements for operations and
equipment in Subpart G, such as:
—Well-control planning, procedures,
training, and certification;
—Major rig equipment;
—Certification requirements for
personnel servicing critical
equipment;
—Choke and kill systems;
—Mud gas separators;
—Wellbore fluid safety practices,
testing, and monitoring;
—Diverter systems with subsea BOPs;
and
—Coiled tubing, snubbing, and wireline
units.
The BSEE is also researching other
topics that would be appropriate for
inclusion into this new subpart in future
rulemakings.
V. Section-By-Section Discussion
Subpart A—General
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What does this part do? (§ 250.102)
This section would be revised to add
references for Subpart G to (b)(1), (11),
(12), and (13) and also add new
paragraph (b)(19) to the table. This
would be added so the public will know
that they can find requirements about
well operations and equipment in
proposed Subpart G.
What must I do to protect health, safety,
property, and the environment?
(§ 250.107)
Paragraph (a) of this section would be
revised to include a general
performance-based requirement that
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operators utilize recognized engineering
practices that reduce risks to the lowest
level practicable during activities
covered by the regulations and conduct
all activities pursuant to the applicable
lease, plan, or permit terms or
conditions of approval. Recognized
engineering practices may be drawn
from established codes, industry
standards, published peer-reviewed
technical reports or industry
recommended practices, and similar
documents applicable to engineering,
design, fabrication, installation,
operation, inspection, repair, and
maintenance activities. This risk
reduction objective is used in other
regulatory programs and is consistent
with BSEE’s goal of taking a more riskbased approach in its regulations. This
risk reduction principle has also been
included in a recently published
industry document (API Bulletin 97)
which addresses drilling, completion,
and workover activities.
Proposed paragraph (e) would be
added to clarify BSEE’s authority to
issue orders when necessary to protect
health, safety, property, or the
environment. The first sentence
authorizes BSEE to issue orders to
ensure compliance with the regulations.
The second sentence clarifies that BSEE
may order that operations of a
component or facility be shut-in because
of a threat of serious, irreparable, or
immediate harm to health, safety,
property, or the environment posed by
those operations or because the
operations violate law, including a
regulation, order, or provision of a lease,
plan, or permit.
Service fees. (§ 250.125)
This table in this section would be
revised to reflect the correct citation for
payment of the service fee relating to
DWOPs.
Documents incorporated by reference.
(§ 250.198)
This section would be revised to
update citations of currently
incorporated documents and to
incorporate new documents. Changes to
this section would include:
—Revising paragraph (h)(51) to update
cross-references to the sections
incorporating API RP 2RD, Design of
Risers for Floating Production
Systems (FPSs) and Tension-Leg
Platforms (TLPs);
—Removing the incorporation of API RP
53 in paragraph (h)(63) and in its
place incorporating new API Standard
53, Blowout Prevention Equipment
Systems for Drilling Wells, Fourth
Edition (with the exception of the optout provision);
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—Revising paragraph (h)(68) to update
cross-references to the sections
incorporating API Spec. Q1,
Specification for Quality Programs for
the Petroleum, Petrochemical and
Natural Gas Industry;
—Revising paragraph (h)(70) to update
cross-references to the sections
incorporating ANSI/API Spec. 6A,
Specification for Wellhead and
Christmas Tree Equipment;
—Adding new paragraph (h)(89) to
incorporate ANSI/API Spec. 11D1,
Packers and Bridge Plugs;
—Adding new paragraph (h)(90) to
incorporate ANSI/API Spec. 16A,
Specification for Drill-through
Equipment;
—Adding new paragraph (h)(91) to
incorporate API Spec. 16C,
Specification for Choke and Kill
Systems;
—Adding new paragraph (h)(92) to
incorporate API Spec. 16D,
Specification for Control Systems for
Drilling Well Control Equipment and
Control Systems for Diverter
Equipment;
—Adding new paragraph (h)(93) to
incorporate ANSI/API Spec. 17D,
Design and Operation of Subsea
Production Systems—Subsea
Wellhead and Tree Equipment;
—Adding new paragraph (h)(94) to
incorporate ANSI/API RP 17H,
Remotely Operated Vehicle Interfaces
on Subsea Production Systems.
Paperwork Reduction Act statements—
information collection. (§ 250.199)
This section would be revised by:
—Changing all the OMB Control
Numbers from the 1010 numbering
system to BSEE’s new 1014
numbering system;
—Rewording for plain language the
reasons that BSEE collects the
information and how it is used; and
—Adding paragraphs for APDs,
Application for Permit to Modify
(APM), and Subpart G in the table to
identify the basis for the information
collection.
Subpart B—Plans and Information
What must the Deepwater Operations
Plan (DWOP) contain? (§ 250.292)
The proposed rule would re-designate
existing paragraph (p) to (q) and add a
new paragraph (p). Proposed new
paragraph (p) would specify FSHR
requirements within the DWOP. The
FSHRs are used in combination with
FPSOs. The use of FPSOs is relatively
new to the GOM. There is only one
FPSO currently operating in the GOM;
however, the use of FPSOs is expected
to increase in the next few years.
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the operator would need to follow the
requirements of this subpart and the
applicable requirements of proposed
Subpart G.
Subpart D—Oil and Gas Drilling
Operations
tkelley on DSK3SPTVN1PROD with PROPOSALS2
Currently, BSEE approves the use of
FPSOs and associated FSHRs through
the DWOP process, but has no
regulations specifically addressing the
use of FSHRs. Proposed paragraph (p)
would outline what BSEE requires in a
DWOP that proposes the use of FSHRs.
The new requirements would include
submission of the following:
—Detailed descriptions and drawings of
the FSHR buoy and tether system;
—Information on the design, fabrication,
and installation of the FSHR buoy and
tether system, including pressure
ratings, fatigue life, and yield
strengths;
—A description of how the operator met
the design requirements, load cases,
and allowable stresses for each load
case according to API RP 2RD, RP for
Design of Risers for FPSs and TLPs;
—Detailed information regarding the
tether system used to connect the
FSHR to a buoyancy air can;
—Descriptions of the monitoring system
and a monitoring plan to monitor the
pipeline FSHR and tether for fatigue,
stress, and any other abnormal
condition (e.g., corrosion) that may
negatively impact the riser or tether;
and
—Documentation that the tether system
and connection accessories for the
pipeline FSHR have been certified by
an approved classification society or
equivalent and verified by the
Certified Verification Agent (CVA) as
required in current Subpart I and
clarified in BSEE NTL 2007–G14,
Pipeline Risers Subject to the Platform
Verification Program.
What must my description of well
drilling design criteria address?
(§ 250.413)
General Requirements. (§ 250.400)
The proposed rule, would revise this
entire section including the section
heading. The current section entitled,
Who is subject to the requirements of
this subpart? is not necessary because
the subject matter is sufficiently covered
under § 250.146, which states that
lessees, operators, and the person
actually performing the activity to
which a requirement applies are jointly
and severally responsible for complying
with the regulations.
The new proposed language would
require drilling operations to be done in
a safe manner to protect against harm or
damage to life (including fish and other
aquatic life), property, natural resources
of the OCS, including any mineral
deposits (in areas leased and not
leased), the National security or defense,
or the marine, coastal, or human
environment. The new section would
also clarify that for drilling operations,
This section would revise paragraph
(g) to include the maximum ECD on the
pore pressure/fracture gradient plot. The
ECD is the effective density exerted by
a circulating fluid against the formation
that takes into account the pressure
drop in the annulus. The ECD is an
important parameter in avoiding kicks
and losses, particularly in wells that
have a narrow window between the
fracture gradient and pore pressure.
This information is necessary for proper
well drilling design and for BSEE to
better review the drilling program.
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What must I do to keep wells under
control? (§ 250.401)
This section would be removed and
reserved. The content of this section
would be moved to proposed § 250.703.
When and how must I secure a well?
(§ 250.402)
This section would be removed and
reserved. The content of this section
would be moved to proposed § 250.720.
What drilling unit movements must I
report? (§ 250.403)
This section would be removed and
reserved. The content of this section
would be moved to proposed § 250.712.
What additional safety measures must I
take when I conduct drilling operations
on a platform that has producing wells
or has other hydrocarbon flow?
(§ 250.406)
This section would be removed and
reserved. The content of this section
would be moved to proposed § 250.723.
What information must I submit with
my application? (§ 250.411)
This section would be revised by
separating the diverter and BOP
descriptions in the table containing
regulatory cross-references for
descriptions of APD information, and
updating the cross-references to include
proposed Subpart G.
What must my drilling prognosis
include? (§ 250.414)
This section would revise paragraphs
(c), (h), and (i) and add new paragraphs
(j) and (k).
Paragraph (c) of this section would be
revised to better define the safe drilling
margin requirements. The planned safe
drilling margins would be required to be
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21513
between the proposed drilling fluid
weights and the estimated pore
pressures and the lesser of estimated
fracture gradients or casing shoe
pressure integrity test. The safe drilling
margins would also have to meet the
following conditions:
—Static downhole mud weight must be
greater than estimated pore pressure;
—Static downhole mud weight must be
a minimum of one-half pound per
gallon below the lesser of the casing
shoe pressure integrity test or the
lowest estimated fracture gradient;
—The ECD must be below the lesser of
the casing shoe pressure integrity test
or the lowest estimated fracture
gradient;
—When determining the pore pressure
and lowest estimated fracture gradient
for a specific interval, related hole
behavior must be considered (e.g.,
pressures, influx/loss of fluids, and
fluid types).
Changes to better define safe drilling
margins are partially based on the
information revealed during
investigations of the Deepwater Horizon
incident.2 Safe drilling margins are used
to determine the downhole fluid
program and ensure fluid densities are
capable of controlling the estimated
pore pressure and formation fluids
while not fracturing the formations.
With clearer requirements for safe
drilling margins, operators would be
able to better understand BSEE
requirements and design fluid programs
accordingly.
Paragraphs (h) and (i) would be
revised with only minor wording
changes.
New paragraph (j) would be added to
require that the drilling prognosis
include the type of wellhead and liner
hanger systems to be installed and a
descriptive schematic. The descriptive
schematic would include, among other
information, pressure ratings,
dimensions, valves, load shoulders, and
locking mechanism, if applicable. This
information would assist BSEE in its
review of the APD, and assist staff in
ensuring that the wellhead and liner
hanger systems are adequate for the
proposed use.
New paragraph (k) would be added to
require submittal of any additional
information required by the District
Manager.
What must my casing and cementing
programs include? (§ 250.415)
Paragraph (a) of this section would be
revised to include casing information
for all sections of each casing interval.
Operators would also need to include
2 See
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bit depths (including measured and true
vertical depth (TVD)), and locations of
any installed rupture disks and indicate
either the collapse or burst ratings.
Requiring this information for all
sections for each casing interval would
make design calculations and submittals
more accurate and provide a complete
representation of the well.
What must I include in the diverter
description? (§ 250.416)
This heading and section would be
revised to remove the BOP descriptions
and leave the diverter descriptions. The
BOP descriptions would be moved to
new Subpart G in proposed §§ 250.730,
250.731, and 250.732. The diverter
requirements would remain unchanged.
What must I provide if I plan to use a
mobile offshore drilling unit (MODU)?
(§ 250.417)
This section would be removed and
reserved. The content of this section
would be moved to proposed § 250.713.
tkelley on DSK3SPTVN1PROD with PROPOSALS2
What additional information must I
submit with my APD? (§ 250.418)
Paragraph (g) of this section would be
revised to require operators to seek
approval for plans to wash out or
displace cement to facilitate casing
removal upon well abandonment. The
request would need to include a
description of how far below the
mudline the operator proposes to
displace cement and how the operator
will visually monitor returns. This
proposed change would provide
information that would assist BSEE in
its review of the APD.
What well casing and cementing
requirements must I meet? (§ 250.420)
The introductory language in this
section would be revised to require that
applicable casing and cementing
requirements in proposed Subpart G
must also be followed.
Existing paragraph (a)(6) would be
renumbered as paragraph (a)(7). New
paragraph (a)(6) would be added to
require adequate centralization to help
ensure proper cementation. Multiple
Deepwater Horizon investigations
discussed the use of centralizers, which
are devices that maintain the casing or
liner in the center of the wellbore to
help ensure efficient placement of
cement around the casing string. If an
operator cements casing off-center, the
wellbore may not be properly sealed.
New paragraph (b)(4) would be added to
specify that if casing is needed that
differs from what was approved in the
APD, the operator would have to contact
the appropriate District Manager and
receive approval before installing the
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different casing. This addition is
necessary to ensure the casing is
suitable for the well conditions and for
BSEE to have the most up-to-date
wellbore information.
Paragraph (c) would be renumbered
and revised by adding a new paragraph
(c)(2). New paragraph (c)(2) would
require the use of a weighted fluid to
maintain an overbalanced hydrostatic
pressure during the cement setting time,
except when cementing casings or liners
in riserless hole sections. This proposed
change would enhance wellbore
stability during cementing.
The use of a weighted fluid is
particularly important because most
well-control events occur due to
inadequately weighted fluids in the
hole, as well as inadequate volume of
fluid to hold back the pressures in the
well. A weighted fluid has a greater
density than seawater. As the density of
the weighted fluid increases, it exerts a
greater hydrostatic pressure, thereby
minimizing the potential for the well to
flow.
What are the casing and cementing
requirements by type of casing string?
(§ 250.421)
Paragraph (b) of the table in this
section would be revised to specify that
if oil, gas, or unexpected formation
pressure is encountered, the operator
would have to set conductor casing
immediately and set it above the
encountered zone, even if it is before the
planned casing point. This proposed
change would ensure that conductor
casing is not placed across a
hydrocarbon zone.
Paragraph (f) of the table in this
section would be revised to disallow the
use of liners as conductor casing. When
a liner is used as conductor casing, a
portion of the drive pipe is exposed to
wellbore pressure, and BSEE does not
accept drive pipe as a pressure-rated
component. By prohibiting the use of
liners as conductor casing, BSEE would
ensure that the drive pipe is not
exposed to wellbore pressures.
What are the requirements for casing
and liner installation? (§ 250.423)
This section would be revised as
follows:
—Change the heading to more
accurately reflect corresponding
changes within the section.
—Remove the pressure testing and
negative pressure testing
requirements. The pressure testing
requirements would be found in
proposed § 250.721.
—Add information to clarify that liner
latching mechanisms, if applicable,
would need to be engaged upon
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successfully installing and cementing
the casing string or liner.
This last addition would reinforce the
importance that liners are properly
secured in place to ensure wellbore
integrity. The requirements for latching
and lockdown mechanisms were also a
topic of discussion in the DOI JIT
Deepwater Horizon investigation.
What are the requirements for prolonged
drilling operations? (§ 250.424)
This section would be removed and
reserved. The content of this section
would be moved to in proposed
§ 250.722.
What are the requirements for pressure
testing liners? (§ 250.425)
This section would be removed and
reserved. The content of this section
would be moved to proposed § 250.721.
What are the recordkeeping
requirements for casing and liner
pressure tests? (§ 250.426)
This section would be removed and
reserved. The content of this section
would be moved to proposed § 250.746.
What are the requirements for pressure
integrity tests? (§ 250.427)
Paragraph (b) would be revised to
clarify that operators must maintain the
drilling margins as described in
§ 250.414.
What must I do in certain cementing
and casing situations? (§ 250.428)
Paragraph (b) of the table in this
section would be revised to require
District Manager approval for hole
interval drilling depth changes greater
than 100 feet TVD, and submittal of a
professional engineer (PE) certification,
certifying that the PE reviewed and
approved the proposed changes. This
requirement would assist BSEE in
verifying the actual well conditions.
This new requirement would also
ensure proper PE review of associated
changes.
Paragraph (c) of the table in this
section would be revised to clarify
requirements concerning what actions
must be taken if there is an indication
of an inadequate cement job. There are
many indicators of an inadequate
cement job. These include lost returns,
no returns to the mudline or failure to
reach the expected height for the
specific cement job, cement channeling,
abnormal pressures, or failure of
equipment. If any of these indicators, or
others, are encountered during the
cement job, then action must be taken
to ensure the cement job is adequate.
Such actions may include running a
temperature survey, running a cement
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evaluation log (such as an ultrasonic or
equivalent bond log), or a combination
of these or other techniques to check
cement integrity by verifying the top of
cement, density, condition, bond, etc. If
the cement job is determined to be
adequate, the results of the cement job
determination would be submitted to
the District Manager in the WAR.
Paragraph (d) of the table in this
section would be revised to clarify that
if an operator has an inadequate cement
job, the District Manager would have to
review and approve all proposed
remedial actions, unless immediate
actions must be taken to ensure the
safety of the crew or to prevent a wellcontrol event. If the operator needs to
take immediate action, a description
would be required to be submitted to
the District Manager once the action is
completed. The paragraph would also
clarify that any changes to the well
program would require PE certification
and would need to meet any other
requirements imposed by the District
Manager.
New paragraph (k) would be added to
the table in this section and would add
clarification concerning the use of
valves on drive pipes during cementing
operations for the conductor casing,
surface casing, or liner, and require the
following to assist BSEE in assessing the
structural integrity of the well:
tkelley on DSK3SPTVN1PROD with PROPOSALS2
—The operator would include a
description in the APD of the plan to
use a valve that includes a schematic
of the valve and height above the
water line.
—The valve would be remotely operated
and full opening with visual
observation while taking returns.
—The person in charge of observing
returns would be in communication
with the drill floor.
—The operator would record in the
daily report and in the WAR if cement
returns were observed; and
—If cement returns were not observed,
the operator would have to contact
the District Manager and obtain
approval of proposed plans to locate
the top of cement, before continuing
with operations.
These proposed additions in
paragraph (k) would help BSEE assess
the well’s structural integrity and verify
cement suitability to the mudline.
The overall changes to this section
would help BSEE assess actual well
operations and conditions, and also
would help ensure proper design with
additional PE review.
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What are the general requirements for
BOP systems and system components?
(§ 250.440)
This section would be removed and
reserved. The content of this section
would be moved to proposed § 250.730.
What must I do in certain situations
involving BOP equipment or systems?
(§ 250.451)
What are the requirements for a surface
BOP stack? (§ 250.441)
This section would be removed and
reserved. The content of this section
would be moved to proposed §§ 250.733
and 250.735.
What safe practices must the drilling
fluid program follow? (§ 250.456)
What are the requirements for a subsea
BOP system? (§ 250.442)
This section would be removed and
reserved. The content of this section
would be moved to proposed § 250.734.
What associated systems and related
equipment must all BOP systems
include? (§ 250.443)
This section would be removed and
reserved. The content of this section
would be moved to proposed
§§ 250.733, 250.734, and 250.735.
What are the choke manifold
requirements? (§ 250.444)
This section would be removed and
reserved. The content of this section
would be moved to proposed § 250.736.
What are the requirements for kelly
valves, inside BOPs, and drill-string
safety valves? (§ 250.445)
This section would be removed and
reserved. The content of this section
would be moved to proposed § 250.736.
What are the BOP maintenance and
inspection requirements? (§ 250.446)
This section would be removed and
reserved. The content of this section
would be moved to proposed § 250.739.
When must I pressure test the BOP
system? (§ 250.447)
This section would be removed and
reserved. The content of this section
would be moved to proposed § 250.737.
What are the BOP pressure tests
requirements? (§ 250.448)
This section would be removed and
reserved. The content of this section
would be moved to proposed § 250.737.
What additional BOP testing
requirements must I meet? (§ 250.449)
This section would be removed and
reserved. The content of this section
would be moved to proposed § 250.737.
What are the recordkeeping
requirements for BOP tests? (§ 250.450)
This section would be removed and
reserved. The content of this section
would be moved to proposed § 250.746.
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This section would be removed and
reserved. The content of this section
would be moved to proposed § 250.738.
This section would remove paragraph
(j) and re-designate the other
paragraphs. The content of current
paragraph (j) would be moved to
proposed § 250.720 to clarify that this
requirement applies to drilling,
workover, completion, and
abandonment operations.
What are the source control and
containment requirements? (§ 250.462)
This section and heading would be
entirely revised. The existing content of
this section entitled, What are the
requirements for well-control drills?
would be moved to proposed §§ 250.710
and 250.711.
This proposed new section would add
requirements for the operator to
demonstrate the ability to control or
contain a blowout event at the sea floor.
This section would apply to operations
using a subsea BOP or a surface BOP on
a floating facility.
Paragraph (a) would require the
operator to determine its source control
and containment capabilities by
evaluating the performance of the well
design to determine if a full shut-in can
be achieved without reservoir fluids
broaching the sea floor. Based on this
evaluation, if the well can only be
partially shut-in, then the operator
would be required to establish the
ability to flow and capture any residual
fluids to a surface production and
storage system.
Paragraph (b) would require that
operators have access to, and the ability
to deploy, Source Control and
Containment Equipment (SCCE)
necessary to regain control of the well.
The SCCE means the capping stack, cap
and flow system, containment dome,
and/or other subsea and surface devices,
equipment, and vessels whose collective
purpose is to control a spill source and
stop the flow of fluids into the
environment or to contain fluids
escaping into the environment. This
equipment would need to include, but
not be limited to:
—Subsea containment and capture
equipment, including containment
domes and capping stacks;
—Subsea utility equipment, including
hydraulic power, hydrate control, and
dispersant injection equipment;
—Riser systems;
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—ROVs;
—Capture vessels;
—Support vessels; and
—Storage facilities.
Paragraph (c) would require submittal
of a description of the source control
and containment capabilities before
BSEE would approve an APD. The
submittal to the Regional Supervisor
would need to include the following:
—The source control and containment
capabilities for controlling and
containing a blowout event at the
seafloor,
—A discussion of the determination
required by paragraph (a), and
—Information showing that the operator
has access to, and the ability to
deploy, all equipment necessary to
regain control of the well.
Paragraph (d) would require that
operators contact the District Manager
and Regional Supervisor for
reevaluation of the source control and
containment capabilities if there are any
well design changes or if any of the
approved SCCE is out of service.
Paragraph (e) would outline the
maintenance, inspection, and testing
requirements of certain identified
containment equipment as follows:
Equipment
Requirements
Additional information
(1) Capping stacks .......................
(i) Function test all pressure holding critical components on a quarterly frequency (not to exceed 104
days),
(ii) Pressure test pressure holding critical components on a bi-annual basis, but not later than 210
days from the last pressure test. All pressure testing must be witnessed by BSEE and a BSEE-approved verification organization,
(iii) Notify BSEE at least 21 days prior to commencing any pressure testing.
(i) Meet or exceed the requirements set forth in 30
CFR 250.800 through 250.808, Subpart H.
(ii) Have all equipment unique to containment operations available for inspection at all times.
Have all equipment unique to containment operations available for inspection at all times,
Pressure holding critical components are those components that will experience wellbore pressure
during a shut-in after being functioned.
Pressure holding critical components are those components that will experience wellbore pressure
during a shut-in. These components include, but
are not limited to: all blind rams, wellhead connectors, and outlet valves.
(2) Production safety systems
used for flow and capture operations.
tkelley on DSK3SPTVN1PROD with PROPOSALS2
(3) Subsea utility equipment .........
All of these changes in this section are
necessary for BSEE to properly assess an
operator’s ability to access and deploy
appropriate equipment sufficient to
control and contain a blowout subsea.
The Deepwater Horizon incident
demonstrated a need for the capabilities
to control and contain subsea blowouts.
Following the Deepwater Horizon
incident, operators did not resume
certain drilling operations on the OCS
until successfully demonstrating their
ability to control and contain a subsea
blowout. Industry quickly developed
the capabilities and equipment, and
satisfactorily demonstrated to BSEE the
equipment capabilities to ensure subsea
blowout control and containment.
The BSEE is considering applying the
requirements of this section to other
operations besides those that use a
subsea BOP or surface BOP on a floating
facility. Specifically, BSEE is soliciting
comments on whether the source
control and containment requirements
should be applicable to wells drilled in
shallow water. Please provide reasons
for your position. If your comment
addresses anticipated costs associated
with such a requirement, please provide
any available supporting data.
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Subsea utility equipment includes, but is not limited
to: hydraulic power sources, debris removal, hydrate control equipment, and dispersant injection
equipment.
When must I submit an Application for
Permit to Modify (APM) or an End of
Operations Report to BSEE? (§ 250.465)
Paragraph (b)(3) would be revised to
clarify that if there is a:
—Revision to the drilling plan;
—Major drilling equipment change; or
—Plugback,
operators would have to submit an EOR,
Form BSEE–0125, as required in
proposed § 250.744, within 30 days after
completing the work. This would help
ensure that BSEE has the current well
information.
What records must I keep? (§ 250.466)
This section would be removed and
reserved. The content of this section
would be moved to proposed § 250.740.
How long must I keep records?
(§ 250.467)
This section would be removed and
reserved. The content of this section
would be moved to proposed § 250.741.
What other well records could I be
required to submit? (§ 250.469)
This section would be removed and
reserved. The content of this section
would be moved to proposed § 250.745.
Subpart E—Oil and Gas WellCompletion Operations
General requirements. (§ 250.500)
This section would be revised to add
a requirement to follow the applicable
requirements of new Subpart G in
addition to Subpart E. With the
development of new Subpart G, BSEE
would consolidate similar requirements
regarding drilling, workover,
completion, and decommissioning
activities into a separate subpart. It is
BSEE’s intention to include additional
regulations regarding similar operations
and equipment in the new Subpart G in
future regulations.
This section would also be revised to
replace the word ‘‘shall’’ with ‘‘must.’’
This change would clarify that the
provision is mandatory.
What well records am I required to
submit? (§ 250.468)
Equipment movement. (§ 250.502)
This section would be removed and
reserved. The content of this section
would be moved to proposed § 250.723.
This section would be removed and
reserved. The content of this section
would be moved to proposed §§ 250.742
and 250.743.
Crew instructions. (§ 250.506)
This section would be removed and
reserved. The content of this section
would be moved to proposed § 250.710.
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Well-control fluids, equipment, and
operations. (§ 250.514)
Paragraph (d) would be removed and
its content would be moved to proposed
§ 250.720.
What BOP information must I submit?
(§ 250.515)
This section would be removed and
reserved. The content of this section
would be moved to proposed §§ 250.731
and 250.732.
Blowout prevention equipment.
(§ 250.516)
This section would be removed and
reserved. The content of this section
would be moved to proposed
§§ 250.730, 250.733, 250.734, 250.735,
and 250.736.
Blowout preventer system tests,
inspections, and maintenance.
(§ 250.517)
This section would be removed and
reserved. The content of this section
would be moved to proposed
§§ 250.711, 250.737, 250.738, 250.739,
and 250.746.
completion, and decommissioning
activities. It is BSEE’s intention to
include additional regulations regarding
similar operations and equipment in
new Subpart G in future regulations.
This section would also be revised to
replace the word ‘‘shall’’ with ‘‘must.’’
This change would clarify that the
provision is mandatory.
Equipment movement. (§ 250.602)
This section would be removed and
reserved. The content of this section
would be moved to proposed § 250.723.
Crew instructions. (§ 250.606)
This section would be removed and
reserved. The content of this section
would be moved to proposed § 250.710.
Well-control fluids, equipment, and
operations. (§ 250.614)
Paragraph (d) would be removed and
its content would be moved to proposed
§ 250.720.
What BOP information must I submit?
(§ 250.615)
This section would be removed and
reserved. The content of this section
would be moved to proposed §§ 250.731
and 250.732.
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New paragraph (e) would add packer
and bridge plug requirements for when
operators pull and reinstall packers and
bridge plugs, including:
—Adherence to newly incorporated API
Spec. 11D1, Packers and Bridge Plugs;
—Production packer setting depth to
allow for a sufficient column of
weighted fluid for hydrostatic control
of the well; and
—Production packer setting depth
criteria.
This new paragraph would codify
existing BSEE policy to ensure
consistent permitting. The incorporation
of API Spec. 11D1 would enhance
packer and bridge plug reinstallation
and ensure conformance to industry
specifications and good industry
practices not previously covered in
BSEE regulations.
New paragraph (f) would require, in
the APM, a description and calculation
of how the production packer setting
depth was determined.
Subpart G—Well Operations and
Equipment
This section would be revised by
removing paragraph (b), redesignating
the rest of the paragraphs to reflect the
removal of paragraph (b), and adding
new paragraphs (e) and (f) to clarify
packer and bridge plug requirements.
The content of paragraph (b) would be
moved to proposed § 250.722 and would
clarify that these requirements apply to
drilling, workover, completion, and
abandonment operations.
New paragraph (e) would add packer
and bridge plug requirements including:
—Adherence to newly incorporated API
Spec. 11D1, Packers and Bridge Plugs;
—Production packer setting depth to
allow for a sufficient column of
weighted fluid for hydrostatic control
of the well; and
—Production packer setting depth
criteria.
New paragraph (f) would require, in
your APM, a description and
calculations of how the production
packer setting depth was determined.
Coiled tubing and snubbing operations.
(§ 250.616)
The section would be revised by
renaming the section heading to ‘‘Coiled
tubing and snubbing operations,’’
removing paragraphs (a) through (e),
and re-designating paragraphs (f)
through (h) as (a) through (c). The
content of existing paragraphs (a)
through (e) would be moved to
proposed §§ 250.730 and 250.733
through 250.736.
This part of the section-by-section
will not address any regulatory
provisions that BSEE proposes to move
without change from existing subparts
to the new subpart G because the
proposed moves in regulatory text are
discussed above. However, this portion
of the section-by-section will explain
existing language that BSEE proposes to
revise or add as new provisions.
General Requirements
Subpart F—Oil and Gas Well-Workover
Operations
Tubing and wellhead equipment.
(§ 250.619)
General requirements. (§ 250.600)
This section would be revised by
removing paragraph (b), redesignating
the rest of the paragraphs to reflect the
removal of paragraph (b), and adding
new paragraphs (e) and (f) to clarify
packer and bridge plug requirements.
The content of paragraph (b) would be
moved to proposed § 250.722.
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Tubing and wellhead equipment.
(§ 250.518)
This section would be revised to add
the requirement to follow the applicable
provisions of new Subpart G in addition
to Subpart F. With the new
development of Subpart G, BSEE is
consolidating similar requirements
regarding drilling, workover,
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Blowout preventer system testing,
records, and drills. (§ 250.617)
This section would be removed and
reserved. The content of this section
would be moved to proposed
§§ 250.711, 250.737, and 250.746.
What are my BOP inspection and
maintenance requirements? (§ 250.618)
This section would be removed and
reserved. The content of this section
would be moved to proposed § 250.739.
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What operations and equipment does
this subpart cover? (§ 250.700)
This proposed section explains that
new Subpart G would apply to drilling,
completion, workover, and
decommissioning activities and
equipment. New Subpart G would
contain common requirements for these
activities. Every section in Subpart G
would be applicable to drilling,
completion, workover, and
decommissioning activities, unless
explicitly stated otherwise.
May I use alternate procedures or
equipment during operations?
(§ 250.701)
Content in this proposed section is
similar to existing § 250.408. This
proposed section would explain that
operators may seek approval to use
alternate procedures or equipment
following the process set forth in
§ 250.141. This section would also
specify that the proposed alternate
procedures and equipment must be
discussed in the APD or APM. This
section would make the information in
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§ 250.408 applicable to all operations
covered by this subpart.
May I obtain departures from these
requirements? (§ 250.702)
The content of this proposed section
is similar to existing § 250.409. This
proposed section would explain that
operators may request departures from
the regulations in this subpart by using
the procedure set forth in § 250.142.
Also, this section would clarify what
would be required for the departure
request. Another addition to this section
would require that the departure request
be discussed in the APD or APM.
What must I do to keep wells under
control? (§ 250.703)
The content of this proposed section
was moved from existing § 250.401.
Language in this section would be
revised to ensure applicability to all
operations covered under this subpart,
and to require the use of equipment that
is designed, tested, and rated for the
most extreme conditions to which the
equipment will be exposed while in
service. This section would also require
that personnel be trained according to
the provisions of Subparts O and S.
These subparts outline minimum
training requirements. The BSEE
expects personnel performing
operations to be trained and
knowledgeable of their required actions
and duties.
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Rig Requirements
What instructions must be given to
personnel engaged in well operations?
(§ 250.710)
The content of this proposed section
was moved from existing §§ 250.462,
250.506, and 250.606. This section
would require personnel engaged in
well operations to be instructed in
safety requirements, possible hazards,
and general safety considerations as
required by Subpart S, prior to engaging
in operations.
This proposed section would clarify
that the well-control plan must contain
instructions for personnel about the use
of each well-control component of the
BOP system, and include procedures for
shearing pipe and sealing the wellbore
in the event of a well control or
emergency situation before maximum
anticipated surface pressure (MASP)
conditions are reached. These changes
would establish better proficiency for
personnel using well-control
equipment.
What are the requirements for wellcontrol drills? (§ 250.711)
The content of this proposed section
was moved from existing §§ 250.462,
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250.517(f), 250.617(c), and 250.1707(c).
This section would add minor revisions
to make the requirement applicable to
all drilling, completion, workover, and
decommissioning operations covered
under this subpart. This section would
also clarify that the same drill may not
be repeated consecutively. These
proposed changes would establish better
proficiency for personnel using wellcontrol equipment.
What rig unit movements must I report?
(§ 250.712)
The content of this proposed section
was moved from existing § 250.403 with
the following revisions and additions:
Paragraph (a) would be revised to add
rig movement reporting requirements
for all rig units moving on and off
locations. Rig units include MODUs,
platform rigs, snubbing units, wire-line
units used for non-routine operations,
and coiled tubing units. This paragraph
would make rig movement reporting
requirements applicable to all rigs
conducting operations covered under
proposed Subpart G. The deadline for
notifying the District Manager about rig
movements, using the Rig Movement
Notification Report (Form BSEE–0144),
would increase from 24 to 72 hours.
This proposed change would allow
BSEE to better anticipate upcoming
operations and coordinate applicable
permitting.
Paragraph (a)(2) would be revised to
clarify that if operators anticipate
moving off location less than 72 hours
after initially moving onto location, the
anticipated movement schedule may be
included on Form BSEE–0144. This
clarification would be necessary if you
have, for example, coiled tubing and
batch operations and there is not
enough time to submit the rig movement
72 hours in advance. Form BSEE–0144
has been revised from its current
version to reflect changes based on the
proposed rule. Revised Form BSEE–
0144 is included in the Appendix to this
proposed rule.
Existing paragraph (c) would be
replaced with a new paragraph (c)
requiring notifications if a MODU or
platform rig is to be warm or cold
stacked. The notifications for MODUs or
platform rigs would include:
—Where the rig is coming from;
—Location where it would be
positioned;
—If it would be manned or unmanned;
and
—Any changes in the stacking location.
Proposed paragraph (c) would also
allow BSEE to have a better
understanding of where MODUs and
platform rigs are located in case of
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emergency situations possibly affecting
surrounding infrastructure.
New paragraph (d) would require
notification to the appropriate District
Manager of any construction, repairs, or
modifications associated with the
drilling package made to the MODU or
platform rig, prior to resuming
operations after stacking.
New paragraph (e) would also require
notification to the District Manager if a
drilling rig enters OCS waters regarding
where the drilling rig is coming from.
The BSEE expects that this notification
would provide information about the
last location where the drilling rig was
conducting operations, or the shipyard
location if it is coming from a shipyard,
for either a new build or repair. This
notification would assist BSEE in
verifying the location and movement of
the rigs. This notification would also
help BSEE verify rig fitness and
documentation requirements to allow
the rig to conduct operations on the
OCS as outlined in proposed § 250.713.
New paragraph (f) would clarify that
if the anticipated date for initially
moving on or off location changes by
more than 24 hours, an updated Rig
Movement Notification Report (Form
BSEE–0144) would be required. This
revision would clarify to operators
when a revision or update would be
required.
What must I provide if I plan to use a
mobile offshore drilling unit (MODU) or
lift boat for well operations? (§ 250.713)
The content of this proposed section
would be moved from existing
§ 250.417. This section would make the
requirements applicable to all
operations covered under this subpart.
Revised paragraph (g) would add
current monitoring requirements.
Current monitoring is discussed in
BSEE NTL 2009–G02, Ocean Current
Monitoring. These proposed changes
would help provide better consistency
in permits. Upon publication of the final
rule, BSEE would rescind BSEE NTL
2009–G02.
Do I have to develop a dropped objects
plan? (§ 250.714)
This section would codify some of the
language from BSEE NTL 2009–G36,
Using Alternate Compliance in Safety
Systems for Subsea Production
Operations, to help avoid prolonged
damage to subsea infrastructure and aid
operators’ and BSEE’s response to a
dropped object.
This proposed new section would
outline the requirements for developing
a dropped objects plan. This proposed
section would be applicable to all
floating rig units in an area with subsea
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infrastructure. This section would
specify the requirements of a dropped
objects plans. The plan would be
required to include:
—A description and plot of the path the
rig would take while running and
pulling the riser;
—A plat showing the location of any
subsea wells, production equipment,
pipelines, and any other identified
debris;
—Modeling of a dropped object’s path
for various material forms, such as a
tubular (e.g., riser or casing) and box
(e.g., BOP or tree) with consideration
given to metocean conditions;
—A description of communications,
procedures, and delegated authorities
established with the production host
facility to shut-in any active subsea
wells, equipment, or pipelines in the
event of a dropped object; and
—Any additional information required
by the District Manager.
Do I need a global positioning system
(GPS) for MODUs and jack-ups?
(§ 250.715)
This proposed new section would
codify existing BSEE NTL 2013–G01,
Global Positioning System (GPS) for
Mobile Offshore Drilling Units
(MODUs). The proposed requirements
for GPSs include:
—Providing a robust and reliable means
of monitoring the position and
tracking the path in real-time if the
MODU or jack-up moves from its
location during a severe storm;
—Installing and protecting the tracking
system’s equipment to minimize the
risk of the system being disabled;
—Placing the GPS transponders in
different locations for redundancy to
minimize risk of system failure;
—Capability of transmitting data for at
least 7 days after a storm has passed;
—Recording the GPS location data if the
MODU or jack-up is moved off
location in the event of a storm; and
—Providing BSEE with real-time access
to the MODU or jack-up location data.
The BSEE would use the GPS data in
emergency situations to minimize
potential damage to the offshore
infrastructure.
Well Operations
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When and how must I secure a well?
(§ 250.720)
The content of this proposed section
would be moved from existing
§§ 250.402, 250.456(j), 250.514(d),
250.614(d), and 250.1709, and would
contain the following revisions and
additions:
Paragraph (a) would add that the
District Manager must be notified when
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operations are interrupted. This
paragraph would also add an example to
the list of events that would warrant
interruption of operations (currently in
§ 250.402(a)). Specifically, if there is any
observed flow outside the well’s casing,
operators would have to interrupt
operations. The requirement to interrupt
operations for the additional event of
observing flow outside the well’s casing
would protect against a failure of the
well’s structural foundation and a
possible environmental incident. The
requirement to notify the District
Manager would give BSEE awareness of
interrupted operations and allow for
appropriate regulatory response. This
paragraph would also require a negative
test in accordance with proposed
§ 250.721 to ensure wellbore and barrier
integrity before removing a subsea BOP
stack or surface BOP stack on a mudline
suspension well.
Paragraph (a)(2) would also clarify
that if there is not enough time to install
the required barriers or if special
circumstances occur, the District
Manager may approve alternate
procedures or barriers in accordance
with § 250.141. Some options that could
be considered include the use of:
—Blind or blind-shear rams;
—Pipe rams and an inside BOP (if
hydrocarbons are not exposed in the
open hole);
—A drill string hang-off tool; and/or
—Storm packers.
This section would help ensure that
during the events previously discussed,
the well would be properly secured.
New paragraph (b) would be added to
consolidate the content of existing
§§ 250.456(j), 250.514(d), 250.614(d),
and 250.1709.
What are the requirements for pressure
testing casing and liners? (§ 250.721)
The content of this proposed section
would be moved from existing
§§ 250.423 and 250.425, and would
include the following revisions and
additions:
Paragraph (a) would increase the
minimum test pressure specification for
conductor casing, excluding subsea
wellheads, from 200 psi in existing
regulations (§ 250.423(a)(2)) to 250 psi.
Paragraph (b) would require operators
to test each drilling liner and liner-lap
before any further operations are
continued in the well.
Paragraph (c) would contain
requirements for testing each
production liner and liner-lap.
Paragraph (d) would clarify that the
District Manager may approve or require
other casing test pressures.
Proposed new paragraph (e) would
add the requirement that operators
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21519
follow additional pressure test
requirements when they plan to
produce a well. If a well would be fully
cased and cemented, the operator would
have to pressure test the well to the
maximum anticipated shut-in tubing
pressure before perforating the casing or
liner. If a well would be an open-hole
completion, the operator would have to
pressure test the entire well to the
maximum anticipated shut-in tubing
pressure before drilling the open-hole
section of the well.
Proposed paragraph (f) would add a
requirement for a PE certification of
proposed plans to provide a proper seal
if there is an unsatisfactory pressure
test.
Proposed paragraph (g) would require
a negative pressure test on all wells that
use a subsea BOP stack or wells with
mudline suspension systems and
outline the requirements for those tests.
What are the requirements for prolonged
operations in a well? (§ 250.722)
The content of this proposed section
would be moved from existing
§§ 250.424, 250.518(b), and 250.619(b),
with revisions made to clarify the
requirements for well integrity for
operations continuing longer than 30
days from the previous casing test. If
well integrity has deteriorated to a level
below minimum safety factors, this
section would require repairs or
installation of additional casing and
subsequent pressure testing, as
approved by the District Manager. To
obtain approval, a PE certification must
be provided showing that he or she
reviewed and approved the proposed
changes. The results of the pressure test
would be submitted to the appropriate
District Manager. These changes help
ensure a proper wellbore integrity
determination to allow operations to
continue.
What additional safety measures must I
take when I conduct operations on a
platform that has producing wells or has
other hydrocarbon flow? (§ 250.723)
This proposed section would reflect a
combination of existing §§ 250.406,
250.502, and 250.602.
Paragraph (b) would be modified from
existing § 250.406(a) to clarify that the
emergency shutdown station would be
for the production system. This revision
would ensure that rig units would be
able to shut-in the production system of
the host facility.
Paragraphs (d) and (e) would make
minor revisions to clarify applicability
to all operations covered under
proposed Subpart G and to divide the
paragraphs to make them easier to read
and understand.
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What are the real-time monitoring
requirements? (§ 250.724)
Blowout Preventer (BOP) System
Requirements
This proposed new section would
include a requirement covering realtime monitoring by onshore personnel
of the BOP system, fluid handling
system of the rig, and downhole
conditions. This section would be
added, in part, based on multiple
recommendations from various
Deepwater Horizon investigation
reports. Having the real-time data
available to onshore personnel would
increase the level of oversight
throughout operations. Onshore
personnel could review data and help
rig personnel conduct operations in a
safe manner. Also, onshore personnel
would be able to assist the rig crew in
identifying and evaluating abnormalities
or unusual conditions while conducting
operations. This section would require
that BSEE be provided access to the
real-time monitoring facility, upon
request. Operators would also be
required to record and retain the data at
an onshore location for recordkeeping
purposes and to make it accessible to
BSEE upon request. If real-time
monitoring capability is lost during
operations, the operator would be
required to immediately notify the
District Manager, who may require other
measures until the real-time monitoring
capability is restored.
The BSEE is considering expanding
the requirements of this section to other
operations, not only those conducted
with a subsea BOP or a surface BOP on
a floating facility or on any BOP
operating in an HPHT environment. The
BSEE is specifically soliciting comments
on whether the real-time monitoring
should be required for all well
operations, including shallow water
shelf operations. Please provide reasons
for your position. If your comment
addresses anticipated costs associated
with such a requirement, please provide
any available supporting data.
What are the general requirements for
BOP systems and system components?
(§ 250.730)
This proposed section would reflect a
combination of existing §§ 250.416,
250.440, 250.516, 250.616, and 250.1706
and would also include the following
revisions and additions:
—Require compliance with API
Standard 53, ANSI/API Spec. 6A,
ANSI/API Spec. 16A, API Spec. 16C,
API Spec. 16D, ANSI/API Spec. 17D,
and API Spec. Q1.
—Clarify that the working-pressure
rating of each BOP component must
exceed the MASP as defined for their
operation, such as drilling,
completion, or workover. For a subsea
BOP, the MASP would be taken at the
mudline.
—Add a new performance measure for
operators which would require the
BOP to be able to meet anticipated
wellbore conditions and still be able
to perform its expected function of
sealing the well.
Proposed paragraph (a) would require
compliance with the following API and
ANSI/API documents:
API Standard 53—BOP system and
components would have to be designed,
installed, maintained, inspected, tested,
and used according to API Standard 53.
The API Standard 53 would be
incorporated into the regulations;
however, if there is a conflict between
API Standard 53 and these regulations,
operators would have to follow the
requirements of these regulations (i.e.,
BSEE is requiring that surface BOPs on
floating facilities have the same dual
shearing requirement as subsea BOPs;
API Standard 53 allows for an opt out
of this standard with a risk assessment
that is not included in the proposed
rule). Currently, BSEE regulations only
incorporate select sections of API RP 53
(accumulators, maintenance, and
inspections). By incorporating new API
Standard 53, BSEE would greatly
enhance the BOP requirements. As
previously discussed in the Background
section, API Standard 53 is the latest
industry consensus standard to update
and enhance BOP requirements. After
the Deepwater Horizon incident,
multiple investigations focused on the
BOP stack. Every investigation made
multiple recommendations to improve
the performance and regulation of BOPs.
Industry recognized the need to update
the previous edition of API RP 53.
During the process of updating API RP
53, industry determined that the
document needed more substantive
content and needed to be raised from an
RP to an industry standard. The current
API Standard 53 contains the industry
consensus standards concerning
engineering and operating practices
regarding BOP reliability and use.
Included in API Standard 53 is a list of
normative references (industry
standards) that are indispensable to
fully utilizing API Standard 53 and to
ensure safe and reliable equipment. The
normative references include:
—ANSI/API Spec. 6A, Specification for
Wellhead and Christmas Tree
Equipment;
—API Spec. 16A, Specification for Drillthrough Equipment;
—ANSI/API Spec. 16C, Specification for
Choke and Kill Systems;
—API Spec. 16D, Specification for
Control Systems for Drilling Wellcontrol Equipment and Control
Systems for Diverter Equipment; and
—ANSI/API Spec. 17D, Design and
Operation of Subsea Production
Systems—Subsea Wellhead and Tree
Equipment.
Sections of these industry standards
apply to BOP systems. The BSEE
specifically proposes to incorporate
these standards into the regulations as
applied to BOP systems to emphasize
their significance and make clear the
industry standards that must be
followed. The BSEE is also requesting
comments concerning whether any
sections of these documents should not
be incorporated by reference.
For general reference, the following
table shows relevant topics from each of
these industry standards. This table is
not a complete list of applicable
sections, but is intended to show how
these sections interact with API
Standard 53.
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Industry standard
Applicable topics in API standard 53 (but not limited to):
ANSI/API Spec. 6A, Specification for Wellhead and Christmas Tree
Equipment;
Flanges and hubs, Bolting and clamps, Gaskets, Choke and kill lines,
Equipment marking and storage, Equipment modifications, Maintenance and testing.
Flanges and hubs, Bolting and clamps, Gaskets, Choke and kill lines,
Equipment marking and storage, Maintenance and testing.
Choke manifolds, Choke and kill lines.
Control systems, Maintenance and testing. Electro-hydraulic and multiplex control systems, Auxiliary equipment, Accumulators.
API Spec. 16A, Specification for Drill-through Equipment;
ANSI/API Spec. 16C, Specification for Choke and Kill Systems;
API Spec. 16D, Specification for Control Systems for Drilling Well-control Equipment and Control Systems for Diverter Equipment;
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Applicable topics in API standard 53 (but not limited to):
ANSI/API Spec. 17D, Design and Operation of Subsea Production Systems — Subsea Wellhead and Tree Equipment;
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Industry standard
Flanges and hubs, Bolting and clamps, Choke and kill lines, Equipment
marking and storage, Maintenance and testing.
Paragraph (a)(3) would require that
pipe and variable bore rams be capable
of closing and sealing on drill pipe,
workstrings, or tubing under MASP
with the proposed regulator settings of
the BOP control system. This new
paragraph would help ensure the BOP
control regulator set points are sufficient
to ensure closure and sealing of the pipe
rams.
Paragraph (a)(4) would require a
current set of approved schematics to be
on the rig and at an onshore location. It
would also require that if there are any
modifications to the BOP or control
system that will change your
schematics, operations would be
suspended until the operator obtains
approval of the new schematics from the
District Manager.
Paragraph (b) would require that
operators design, fabricate, maintain,
and repair the BOP system pursuant to
the requirements contained in this
subpart, OEM recommendations unless
otherwise directed by BSEE, and
recognized engineering practices.
Personnel performing any repair or
maintenance would be required to
follow any OEM training or certification
recommendations unless otherwise
directed by BSEE.
Paragraph (c) would adopt the failure
reporting procedures contained in
certain API documents. The BSEE
would add specific time frames for the
completion of these procedures
consistent with other previously
incorporated API standards and add a
requirement that BSEE be notified of
any changes to operating or repair
procedures adopted to address or in
response to a failure. This would allow
BSEE to notify the industry and
international community of any
significant safety issues related to
equipment design, and potentially
prevent future incidents.
Paragraph (d) would require that if an
operator plans to use a BOP stack
manufactured after the effective date of
the final rule, the operator must use one
manufactured pursuant to API Spec. Q1,
Specification for Quality Management
System Requirements for Manufacturing
Organizations for the Petroleum and
Natural Gas Industry. Currently, BSEE
uses API Spec. Q1 in association with
the manufacture of safety and pollution
prevention equipment. The API Spec.
Q1 outlines the requirements for
development of a quality management
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system that provides for continual
improvement, emphasizing defect
prevention and the reduction of
variation. This quality management
system facilitates consistent and reliable
manufacture. Also added to this section
is the option to seek approval to use
quality assurance programs other than
API Spec. Q1.
The BSEE requests comments
concerning whether other industry
standards should be incorporated into
the regulations that ensure that BOP
equipment performs as designed during
its service life.
What information must I submit for BOP
systems and system components?
(§ 250.731)
This proposed section would reflect a
combination of existing §§ 250.416,
250.515, 250.615, and 250.1705 with the
following revisions and additions:
The introductory text would reflect
that the requirements of BOP
description submittals would apply to
APDs, APMs, and other required
submittals. The introductory text would
also clarify that the BOP descriptions
would not have to be resubmitted with
any subsequent permit application or
submittal after the initial application
that BSEE approved or accepted when
the operator moved onto location unless
the operator makes changes to what was
initially approved or the operator moves
off location from that well. This
introductory text would also clarify that
if the operator is not required to
resubmit the BOP information in
subsequent applications, then the
operator must document why the
submittal is not required—in other
words, the operator would need to
reference the previously approved or
accepted application or submittal and
state that no changes have been made.
The information required under this
section would increase the quality of
submitted documents and enhance
BSEE’s review and permitting process.
Paragraph (a) would require
submission of the following new BOP
descriptions:
—Pressure ratings of BOP equipment;
—Both surface and corresponding
subsea pressures for a subsea BOP
test;
—Rated capacities of the fluid-gas
separator system;
—Control fluid volumes needed to
operate each component;
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—Control system pressure and regulator
settings needed to achieve an effective
seal of each ram BOP under MASP;
—Number and volume of accumulator
bottles and bottle banks (for subsea
BOPs, include both surface and
subsea bottles);
—Accumulator pre-charge calculations
(for a subsea BOP system, include
both the surface and subsea
calculations);
—All locking devices; and
—Control fluid volume calculations for
the accumulator system (for a subsea
BOP system, include both the surface
and subsea volumes).
Submission of these descriptions
would enhance BSEE’s review and
understanding of the entire BOP system.
Paragraph (b) would add the
following new schematic drawing
requirements:
—Labeling the control system alarms
and set points;
—Including all locking devices;
—Including control station locations;
—Labeling the type of shear ram(s), size
range for variable bore ram(s), size of
any fixed ram(s), size of choke and
kill lines, and size of subsea BOP gas
bleed line(s); and
—Including a cross-section of the riser
for a subsea BOP system showing
number size, and labeling of all
control, supply, choke, and kill lines
down to the BOP.
Paragraph (c) would reflect content
from existing § 250.416(e) and require
submission of the following
certifications by a BSEE-approved
verification organization verifying that:
—Test data clearly demonstrates the
shear ram(s) will shear the drill pipe
at the water depth as required in
§ 250.732;
—The BOP was designed, tested, and
maintained to perform at the most
extreme anticipated conditions; and
—The accumulator system has sufficient
fluid to function the BOP system
without assistance from the charging
system.
Paragraph (d) would require
additional certification if an operator
uses a subsea BOP, a BOP in an HPHT
environment, or a surface BOP on a
floating facility. The certification would
include verification of the following:
—The BOP stack is designed for the
specific equipment on the rig and for
the specific well design;
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—The BOP stack has not been
compromised or damaged from
previous service; and
—The BOP stack will operate in the
conditions in which it will be used.
The BSEE is considering expanding
the requirements of this paragraph to all
BOPs. The BSEE is specifically
soliciting comments on whether this
certification requirement should be
applied to all well operations, including
shallow water shelf operations and
operations with surface BOPs. Please
provide reasons for your position. If
your comment addresses anticipated
costs associated with such a
requirement, please provide any
available supporting data.
Paragraph (e) would be entirely new
for subsea BOPs. This paragraph would
require a listing of the functions with
sequences and timing of autoshear,
deadman, and emergency disconnect
sequence (EDS) systems. These
emergency systems were the topic of
many Deepwater Horizon investigations
and multiple associated
recommendations. It is BSEE’s position
that submission of this additional
information would improve BSEE’s
ability to oversee the use of these
critical systems.
Paragraph (f) would add a
certification requirement stating that the
Mechanical Integrity Assessment Report
required in proposed § 250.732(d) has
been submitted within the past 12
months for a subsea BOP, a BOP being
used in an HPHT environment as
defined in § 250.807, or a surface BOP
on a floating facility.
The items covered under this section
have not been routinely submitted to
BSEE or obtained by the operators
charged with responsibility to maintain
well control, and BSEE believes these
items are important to fully understand
the entire BOP system and to verify that
it would perform in an acceptable
manner.
What are the BSEE-approved
verification organization requirements
for BOP systems and system
components? (§ 250.732)
This proposed section would reflect a
combination of existing §§ 250.416,
250.515, 250.615, and 250.1705, along
with new requirements. This proposed
section is necessary to ensure that BSEE
receives accurate information regarding
BOP systems so that BSEE may ensure
the system is appropriate for the
proposed use. The third-party
verification and documentation by a
BSEE-approved verification
organization would enhance the BSEE
review during the permitting process.
The objective is to have this equipment
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monitored during its entire lifecycle by
an independent third-party to verify
compliance with BSEE requirements,
OEM recommendations, and recognized
engineering practices. The BSEE
believes that the importance and
complexity of BOP systems and the fact
that they might be operated at various
worldwide locations throughout their
service life warrants a thorough and
regular assessment of the systems and
verification that design, installation,
maintenance, inspection, and repair
activities are documented and traceable.
The list of approved verification
organizations would be limited to those
that can clearly demonstrate the
capability to perform this
comprehensive detailed technical
analysis.
Paragraph (a) would clarify that BSEE
will maintain a list of BSEE-approved
verification organizations, and also
outline criteria to become a BSEEapproved verification organization.
Paragraph (b) would be applicable to
any operation that requires any type of
BOP, and would require verification of
shear testing, pressure integrity testing,
and calculations for shearing and
sealing pressures for all pipe to be used.
Each of these verifications must
demonstrate outlined specific
requirements.
Paragraph (c) would require a special
verification process for BOP and related
equipment being used in HPHT
environments because the design
conditions required for an HPHT
environment exceed the limits of
existing engineering standards. The use
of a BSEE-approved verification body
would provide BSEE with an additional
layer of review and verification at all
steps in the development process. The
paragraph makes it clear that the
operator has the burden of clearly
demonstrating the reliability of the
equipment through a comprehensive
review of the design, testing, and
fabrication process.
Paragraph (d) would require an
annual submittal of a Mechanical
Integrity Assessment Report for a subsea
BOP, a BOP used in HPHT environment,
or a surface BOP on a floating facility.
This paragraph would outline the
requirements of a Mechanical Integrity
Assessment report.
Paragraph (e) would require operators
to make all documentation that supports
the requirements of this section
available to BSEE upon request.
The BSEE believes that using a thirdparty to verify the testing and
qualification of BOP equipment would
ensure consistent results and provide a
reasonable assurance of the performance
of this equipment. Based on previous
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studies available on the Web site of
BSEE’s Technology Assessment Program
(available at: https://www.bsee.gov/
Technology-and-Research/TechnologyAssessment-Programs/Index), BSEE
believes that the development of more
rigorous industry testing protocols is
critical to demonstrating the
performance of BOP equipment.
The BSEE requests comments on the
following issues associated with this
section:
—On the issue of standardized test
protocols and whether there are any
specific procedures that should be
considered for adoption.
—On the importance of applying forces
in tension or compression during the
actual shearing tests.
—On what criteria should be used to
qualify a BSEE-approved verification
organization and whether OEMs
should be considered for the program.
—On the issue of updating test
protocols and criteria used by
verification organizations, given the
likelihood of future improvements to
BOP technology.
What are the requirements for a surface
BOP stack? (§ 250.733)
This proposed section would be a
combination of existing §§ 250.441,
250.443, 250.516, 250.616, and 250.1706
with the following revisions and
additions:
Paragraph (a) would contain revisions
clarifying its applicability to all
operations covered under Subpart G.
Paragraph (a) would also clarify that
the blind-shear rams would have to be
able to shear the drill pipe, workstring,
tubing, and any electric-, wire-, or slickline. If the blind-shear ram could not cut
and seal electric-, wire-, or slick-line
under MASP, an alternative cutting
device would be required on the rig
floor during operations that require their
use, to cut the wire before closing the
BOP. This requirement would be
necessary to ensure that there are means
to cut the wire in the hole, even if it is
an external cutting device.
Paragraph (b) would codify BSEE
policy and would:
—Clarify that when using a surface BOP
on a floating production facility:
—the same BOP requirements apply as
in § 250.734(a)(1), and
—a dual bore riser configuration would
be required for risers installed after
the effective date of this rule before
drilling or operating in any hole
section or interval where
hydrocarbons may be exposed to the
well;
—Require risers to meet the design
requirements of API RP 2RD;
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—Clarify that the annulus between the
risers must be monitored during
operations;
—Require a description of the
monitoring plan in the APD or APM,
including how you would secure the
well if a leak is detected; and
—Clarify that the inner riser for a dual
riser configuration is subject to the
requirements for testing the casing or
liner.
API Standard 53 does not impose dual
shear requirements for surface BOPs on
floating facilities; however, this
proposed rule would require dual
shears. If there is any conflict between
the documents incorporated by
reference and these regulations, the
operator would be required to follow
these regulations.
Proposed paragraph (c) would contain
content from current § 250.443(c) for
surface BOP stacks to contain one side
outlet for a choke line and one side
outlet for a kill line. There would be a
new requirement that the outlet valves
must hold pressure from both
directions.
Existing § 250.441(d) would not be
carried forward to proposed § 250.733
because it is unnecessary to state that
the regulations covered under this
subpart are required.
Proposed paragraph (d) would contain
content from a portion of existing
§ 250.443(d). An addition, this
paragraph would require that the outlet
valves must be full-bore, full-opening.
This would prevent leaks into and out
of the BOP stacks.
Proposed paragraph (e) would require
installation of hydraulically operated
locks.
Proposed Paragraph (f) would add
specific requirements for a surface BOP
used in HPHT environments, if
operations are suspended to make
repairs to any part of the BOP system.
The BSEE is considering requiring the
same dual shear ram requirements in
proposed § 250.734(a)(1) for BOPs used
in HPHT environments. The BSEE is
requesting comments on requiring dual
shear rams for BOPs used in HPHT
environments, and how long it would
take to comply with the dual shear
requirement for BOPs used in HPHT
environments. If your comment
addresses anticipated costs associated
with such a requirement, please provide
any available supporting data.
What are the requirements for a subsea
BOP system? (§ 250.734)
This proposed section would reflect a
combination of existing §§ 250.442,
250.443, 250.516, 250.616, and
250.1706.
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Proposed paragraph (a)(1) would
require two BOPs equipped with shear
rams. This new requirement would
correspond to API Standard 53, and
would increase the shearing capabilities
of a BOP stack. This paragraph would
also clarify that both shear rams would
have to be able to shear at any point
along the tubular body of any drill pipe
(excluding tool joints, bottom-hole tools,
and bottom hole assemblies, which
include heavy-weight pipe or collars),
workstring, and tubing, as well as be
able to shear the liner casing landing
string, shear sub on subsea test tree, and
any electric-, wire-, or slick-line in the
hole under MASP. At least one shear
ram would have to be capable of sealing
the wellbore under MASP after
shearing. Any non-sealing shear rams
would have to be installed below the
sealing shear rams. These requirements
would help ensure that shearing the
pipe and sealing the wellbore could be
achieved.
Proposed paragraph (a)(3) would
clarify that the accumulator capacity
would have to be located subsea to
provide closure of the BOP components
and operate critical functions in case of
a loss of the power fluid connection to
the surface. The critical functions and
components would be defined as each
shear ram, choke and kill side outlet
valves, one pipe ram, and lower marine
riser package (LMRP) disconnect. This
paragraph would also require that the
subsea accumulator system have the
capability of delivering fluid to each
ROV function i.e., flying leads. The
accumulator would be required to have
dedicated independent bottles for the
autoshear, deadman, and EDS systems.
The subsea accumulator would have to
be capable of performing under MASP.
These new requirements would ensure
that the subsea accumulators would be
able to provide fluid to each ROV
function. The reference to API RP 53 in
current § 250.442(c) would not be
carried forward to the proposed
paragraph.
Proposed paragraph (a)(4) would
include requirements that the ROV
would have to be able to perform critical
BOP functions, including opening and
closing each shear ram, choke and kill
side outlet valves, all pipe rams, and the
LMRP disconnect under MASP
conditions. This paragraph would also
include a new requirement that the ROV
panels must be compliant with API RP
17H.
Proposed paragraph (a)(5) would
require communication between the
ROV crew and the rig personnel familiar
with the BOP. This communication
would help ROV crews perform proper
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operations and better determine
appropriate BOP conditions.
Proposed paragraph (a)(6) would
include requirements of an autoshear,
deadman, and EDS system for
dynamically positioned rigs, and
autoshear and deadman systems for
moored rigs. This paragraph would also
require each emergency function to
include both shear rams closing under
MASP. The sequencing of each
emergency function would have to
provide for the lower shear ram
beginning closure before the upper
shear ram would begin closure. Also,
the control system for the emergency
functions would be required to be a failsafe design, and each step in the logic
would have to be independent of the
previous step being completed. These
revisions to the emergency functions
would help provide the best means to
carry out the intended functions. In the
past, some BOP systems have only
included one shear ram in the
emergency functions, and these
additions would ensure including both
shear rams in those functions.
Proposed paragraph (a)(7) would add
acoustic system requirements similar to
current § 250.442(f)(3). The revision
puts the acoustic system option into its
own designated paragraph. It would
expand what must be provided to the
BSEE District Manager if an acoustic
system is to be used for a subsea BOP.
Proposed paragraph (a)(12) would be
revised to connect this paragraph to
§ 250.720(b). This revision would clarify
the intent of this existing regulation and
ensure that procedures are submitted for
review and approval in permits.
Proposed paragraph (a)(14) would
revise a current requirements from
§§ 250.443(c) and (d), 250.516, 250.616,
and 250.1706. The proposed rule would
require subsea BOPs to contain two side
outlets for the choke line and two side
outlets for the kill line. Each side outlet
would be required to have two full-bore,
full-opening valves. The proposed
section would require these valves to be
pressure-holding from both directions.
This section would also require a side
outlet below each sealing shear ram.
Operators may have a pipe ram or rams
between the shearing ram and side
outlet. This would enhance well-control
capability for subsea BOPs.
Proposed paragraph (a)(15) would
require operators to install a gas bleed
line with two valves for the annular
preventer. If dual annulars would be
installed with one on the LMRP and one
on the lower BOP stack, each annular
would have to have a gas bleed line. The
two valves would need to be able to
hold pressure from both directions.
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Proposed paragraph (a)(16) would
require subsea BOP systems to have
mechanisms capable of:
—Positioning the entire pipe, including
connection, completely within the
area of the shearing blade necessary to
ensure shearing would occur any time
the shear rams are activated. This
mechanism could not be another ram
BOP or annular preventer;
—Mitigating compression of the pipe
stub between the shearing rams. (This
provision was added based upon
multiple Deepwater Horizon
investigation recommendations; the
blind shear ram (BSR) could not fully
close and seal because the drill pipe
was forced to the side of the wellbore
and outside of the BSR cutting
surface); and
—Monitoring the subsea electronic
module batteries in the BOP control
pods.
New paragraph (b) would codify BSEE
policy and require that if operations are
suspended to make repairs to the BOP,
operations would have to be stopped at
a safe downhole location. This section
would also require that before resuming
operations, the operator would need to
do the following:
—Submit a revised permit with a report
from a BSEE-approved verification
organization documenting the repairs
and that the BOP is fit for service;
—Perform a new BOP test upon relatch;
and
—Receive approval from the District
Manager.
Paragraph (b) would help BSEE ensure
the BOPs have proper verification after
repairs and that BSEE would be aware
of the repairs.
New paragraph (c) would codify BSEE
policy. Additions to this section would
provide that if an operator plans to drill
a new well with a subsea BOP, the
operator does not need to submit with
its APD the verifications required by
this subpart for the open water drilling
operation. However, before drilling out
the surface casing, the operator would
be required to submit for approval a
revised APD, including the third-party
verifications required in this subpart.
This paragraph would allow operators
to perform certain operations prior to
verification to facilitate the timing and
scheduling of work.
The BSEE is also soliciting specific
comments on the following possible
additional requirements:
—Under proposed paragraph (a)(1)(ii) of
this section, requiring that both shear
rams be able to shear the appropriate
area for the casing landing string. Also
please comment on whether there
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would be utility in installing the nonsealing shear ram above the sealing
shear ram, and how it would affect
the sequence of ram closure;
—Under proposed paragraph (a)(16) of
this section, requiring a position
indicator for each ram BOP, wellhead
connector, and LMRP connector. The
position indicator would have to be
viewable by the ROV during
operations and in the event of a
disconnect of the LMRP; and
—Under proposed paragraph (a)(16) of
this section, requiring sensing and
displaying pressure within the BOP.
This mechanism would have to be
viewable by the ROV during
operations and in the event of a
disconnect of the LMRP.
These proposed requirements are in
part based on various Deepwater
Horizon investigation
recommendations.3 These proposed
requirements would help identify the
status of various BOP components
under emergency situations to assist in
emergency well control. If your
comment addresses anticipated costs
associated with any of the above
requirements, please provide any
available supporting data.
The BSEE is also soliciting comments
on whether there are other options
besides the use of shear rams to provide
redundant shearing capability while
ensuring the same level of safety and
environmental protection.
What associated systems and related
equipment must all BOP systems
include? (§ 250.735)
This proposed section would reflect a
combination of existing §§ 250.441,
250.443, 250.516, 250.616, and
250.1706.
Proposed paragraph (a) would contain
content from existing § 250.441(c), with
the following changes:
—Clarification that the requirements are
for a surface accumulator system;
—Clarification that the system would
have to operate all BOP functions,
including shearing pipe and sealing
the well against MASP without
assistance from a charging system;
and
—Clarification that these provisions
would apply to all BOP systems, not
just surface BOP stacks.
This revision would clarify existing
regulations and ensure the BOP system
3 For example, BOP position indicator and
display of pressures—National Oil Spill
Commission recommendation D4; Centering pipe
for shearing—DOI JIT recommendation D6; ROV
functions and capabilities—Offshore Energy Safety
Advisory Committee recommendation 07;
Monitoring Subsea electronic module batteries—
DOI JIT recommendation D2.
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is capable of operating all critical
functions.
Proposed paragraph (b) would add
that the independent power source must
possess sufficient capability to close and
hold closed all BOP components under
MASP.
Proposed paragraph (e) would add
that the kill line must be installed
beneath at least one pipe ram.
What are the requirements for choke
manifolds, kelly valves, inside BOPs,
and drill string safety valves?
(§ 250.736)
This proposed section would reflect a
combination of existing §§ 250.444,
250.445, 250.516, 250.616, 250.1707,
with minor edits to clarify applicability
to all operations covered under this
subpart.
What are the BOP system testing
requirements? (§ 250.737)
This proposed section would reflect a
combination of existing §§ 250.447,
250.448, 250.449, 250.517, 250.617,
250.1707, and be revised as follows:
Proposed paragraph (a) would
reorganize pressure testing frequency
requirements into one section. A new
provision would be added that the
District Manager may require more
frequent testing for the BOP system if
conditions or BOP performance warrant.
Additionally, by consolidating the
pressure test requirements for drilling,
workovers, completions, and
decommissioning into one section,
BSEE would revise the workover and
decommissioning BOP testing frequency
to be consistent with the 14-day
frequency for drilling and completions.
Some operations use the same rigs and
BOP systems; therefore, to ensure
consistency among different operations
involving the same equipment, BSEE
proposes harmonizing the requirements
for that type of equipment. Also, BOP
equipment that meets the new
requirements of this proposed rule
would perform in a more reliable
manner and provide additional
assurances that wells can be safely shutin when necessary. The BSEE requests
comments on whether this increase in
equipment reliability justifies
expanding the workover and
decommissioning BOP testing
frequency.
Proposed paragraph (b) would add a
table to organize pressure testing
requirements. Paragraph (b)(1) would be
for a low-pressure test, and the required
test pressure range would increase 50
psi to be between 250 to 350 psi.
Paragraph (b)(2) would add highpressure test requirements for BSR-type
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BOPs, outside of all choke and kill sideoutlet valves (and annular gas-bleed
valves for subsea BOP), and inside of all
choke and kill side-outlet valves below
the uppermost ram. Paragraph (b)(3)
would add high-pressure test
requirements for inside of choke or kill
valves (and annular gas bleed valves for
subsea BOP) above the uppermost ram
BOP and would clarify test pressure
procedures.
Proposed paragraph (c) would require
that each test must hold pressure for 5
minutes, which must be recorded on a
4-hour chart. This would allow the chart
to display enough line curvature length
to detect a leak during the test.
Proposed paragraph (d) would be
reorganized into a table and additional
testing requirements would be added.
Revisions to the existing testing
requirements would be:
Proposed paragraph (d)(1) would add
a reference to the testing requirements
in API Standard 53. Operators would be
required to follow all testing
requirements covered in API Standard
53, unless testing requirements conflict
with BSEE regulations, in which case
operators would be required to follow
BSEE regulations.
Proposed paragraph (d)(2) would add
requirements to use water to test a
surface BOP system. This paragraph
would also require that operators submit
test procedures in their APD or APM for
District Manager approval and contact
the District Manager at least 72 hours
prior to beginning the test to allow a
BSEE representative to witness testing.
Proposed paragraph (d)(3) would
require that operators submit stump test
procedures for a subsea BOP system in
their APD or APM for District Manager
approval and require that stump tests
follow the pressure test procedures set
forth in paragraphs (b) and (c).
Proposed paragraph (d)(4) would
outline the requirements for performing
the initial subsea BOP test on the
seafloor.
Proposed paragraph (d)(5) would
expand testing requirements for two
BOP control stations. The operator
would be required to designate the
control stations as primary and
secondary and function-test each station
weekly. The control station used to
perform the pressure test would be
required to be alternated between each
pressure test. For a subsea BOP, the
operator would be required to rotate the
pods between each control station
during the weekly function tests and
alternate the pod used for pressure
testing between each pressure test. If
additional control stations are installed,
they would have to be tested every 14
days.
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Proposed paragraph (d)(7) would be a
new requirement to pressure test
annular type BOPs against the smallest
pipe in use.
Proposed paragraph (d)(10) would be
a new requirement to function test BSR
BOPs every 14 days. This requirement
would align the timing of the function
and pressure tests.
Proposed paragraph (d)(12) would
expand criteria for ROV testing to
include testing and verifying closure
capability of all intervention functions
of the subsea BOP. These new
provisions include requirements that:
—Each ROV must be fully compatible
with the BOP stack ROV intervention
panels;
—Operators must submit test
procedures, including how they will
test each ROV intervention function;
and
—Operators must document all test
results and make them available to
BSEE upon request.
Proposed paragraph (d)(13) would
expand requirements for function
testing autoshear, deadman, and EDS
systems on subsea BOPs. The test
procedures must be submitted for
District Manager approval, and the
proposed rule would require that the
procedures include:
—Schematics of the circuitry of the
system that would be used during an
autoshear or deadman event;
—The approved schematics of the BOP
control system with the actions and
sequence of events that would take
place; and
—How the ROV would be used during
the well-control operations.
Prior to conducting the test, the well
is to be in a secure configuration with
appropriate barriers. The testing of the
deadman system on the seafloor would
have to indicate the discharge pressure
of the subsea accumulator system
throughout the test. During the initial
test of the deadman system, the operator
would need to have the ability to
quickly disconnect the LMRP. The
operators would also have to submit the
quick-disconnect procedures with the
deadman test procedures in the APD or
APM. The BSR(s) would need to be
pressure tested according to paragraphs
(b) and (c) of this section. The operator
would have to include in its procedure
a description of how it plans to verify
closure of a casing shear ram if
installed. All test results would have to
be documented and submitted to BSEE
upon request.
Proposed paragraph (e) would require
that operators notify BSEE at least 72
hours in advance of any shear ram tests
in which the operators will shear pipe.
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21525
This would allow better scheduling for
BSEE personnel to witness these tests.
What must I do in certain situations
involving BOP equipment or systems?
(§ 250.738)
This proposed section would be a
combination of existing §§ 250.451 and
250.517. Additional requirements
would be added as follows:
As recommended by the DOI JIT
investigation recommendation E2,
proposed paragraph (a) would require
the operator to notify the District
Manager of any problems or
irregularities, including leaks, if BOP
equipment does not hold the required
pressure during testing.
Proposed paragraph (b) would require
the operator to receive approval from
the District Manager prior to resuming
operations after replacing, repairing, or
reconfiguring the BOP system. To obtain
approval, the operator would have to
submit a report from a BSEE-approved
verification organization attesting that
the BOP system is fit for service. Any
repair or replacement parts would have
to be manufactured under a quality
assurance program and would have to
meet or exceed the performance of the
original part produced by the OEM.
Proposed paragraph (d) would require
the operator to notify the District
Manager of any problems or
irregularities, including leaks, if a BOP
control station or pod does not function
properly and suspend operations until
the station or pod operates properly.
Proposed paragraph (e) would be
revised to clarify that two sets of pipe
rams must be capable of sealing around
the smaller size pipe to be consistent
with §§ 250.733(a) and 250.734(a)(1),
which require the capability to close
and seal on the tubular body of any drill
pipe, workstring, and tubing.
Proposed paragraph (f) would add
new requirements if the operator
proposes to install casing rams or casing
shear rams in a surface BOP stack. The
ram bonnets would have to test to the
rated working pressure or MASP plus
500 psi and be tested before running
casing. The BOP would still need to be
capable of sealing the well after the
casing is sheared. If the installation
would be a change from the approved
APM or APD, the operator must notify
and receive approval from the District
Manager.
Proposed paragraph (i) would require
that, after pipe or casing is sheared
either intentionally or unintentionally,
the operator would have to retrieve,
inspect, and test the BOP as well as
submit a report to the District Manager
from a BSEE-approved verification
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body, stating that the BOP is fit to return
to service.
Proposed paragraph (j) would add a
requirement that an operator must have
a minimum of two barriers in place
prior to removal of the BOP stack. The
District Manager would have to approve
the two barriers and may require
additional barriers prior to removal.
This requirement is consistent with
similar requirements in current
§ 250.420(b)(3), and is necessary to
ensure that the well is placed in a safe
condition prior to BOP removal.
Proposed paragraph (k) would add
new requirements for re-establishing
power to a BOP stack after a deadman
or autoshear activation. Prior to reestablishing power, the operator would
have to examine the system to
determine if the possibility exists for the
BSR opening immediately upon reestablishing power to the BOP stack. If
this is a possibility, the opening
function would have to be placed in the
block position before power is reestablished to the stack. The operator
would have to contact the District
Manager to receive approval of
procedures for re-establishing power
and functions prior to latching up the
BOP stack or re-establishing power to
the stack.
Proposed paragraph (l) would
establish requirements for test rams. The
initial BOP test after latch-up would
have to be done with a test tool, and the
wellhead/BOP connection would have
to be tested to the maximum ram-test
pressure approved for the well in the
APD or APM. All hydraulically operated
BOP components would have to
function as designed during the well
connection test.
Proposed paragraph (m) would add
requirements for additional well-control
equipment that operators may use, but
which are not required in this subpart.
The operator would have to request
approval from the appropriate District
Manager, submit a report from a BSEEapproved verification organization on
the design and suitability of the
equipment for its intended use, and
submit any other information required
by the District Manager. The District
Manager may impose requirements
concerning the equipment’s capabilities,
operation, and testing.
Proposed paragraph (n) would clarify
that pipe and variable bore rams that
have no current utility and would not be
used for well-control purposes would
not have to be pressure and function
tested, until they are intended to be
used during operations. Operators
would have to indicate which pipe and
variable bore rams meet this criteria in
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their APD or APM and label those rams
on all BOP control panels.
Proposed paragraph (o) would include
new requirements applicable to
redundant well-control components in
BOP systems that are in addition to
components required in Subpart G. If
any redundant component fails a test,
you must submit a report from a BSEEapproved verification organization that
describes the failure and confirms that
there is no impact on the BOP that will
make it unfit for well-control purposes.
This report would have to be submitted
to the District Manager, and operators
may not resume operations until they
receive the District Manager’s approval.
The District Manager may require
operators to submit additional
information before approving continued
operations.
Proposed paragraph (p) would add
new requirements that operators would
have to meet if they need to position the
bottom hole assembly across the BOP
for tripping or any other operations,
including:
—Ensuring that the well is stable at least
30 minutes before positioning the
bottom hole assembly across the BOP,
and
—Including in the well-control plan
(required by proposed § 250.710(b))
procedures for immediately removing
the bottom hole assembly from across
the BOP in the event of a well control
or emergency situation before
exceeding MASP conditions. This
would ensure that the operational
conditions would not exceed the BOP
design specifications.
What are the BOP maintenance and
inspection requirements? (§ 250.739)
This proposed section would reflect a
combination of existing §§ 250.446,
250.517, 250.618, and 250.1708 with the
following revisions:
Proposed paragraph (a) would add
that the BOP maintenance and
inspections must meet or exceed OEM
recommendations, recognized
engineering practices, and industry
standards incorporated by reference into
the regulations, including all provisions
in API Standard 53. In the past, BSEE
has only required compliance with
select sections of API RP 53. By
incorporating the updated edition (API
Standard 53), BSEE would increase the
overall maintenance and inspection
requirements.
Proposed paragraph (b) would be a
new requirement that details the
procedures for a complete breakdown
and inspection of the BOP and every
associated component every 5 years.
This paragraph would also clarify that
the complete breakdown and inspection
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may not be performed in phased
intervals. Also, during this complete
breakdown and inspection, a BSEEapproved verification organization
would have to be present documenting
the inspection and any problems
encountered and produce a detailed
report. This independent third-party
report would have to be available to
BSEE upon request. The BSEE is aware
that, in the past, various components of
BOP stacks have not had this type of
inspection for more than 10 years.
However, BSEE feels it is essential to
ensure that every component on the
BOP stack has a complete breakdown
and detailed inspection every 5 years.
Proposed paragraph (c) would revise
the subsea BOP inspection requirement
to include visual inspection of the
wellhead and remove the word
‘‘television.’’
Proposed paragraph (d) would require
that the personnel who maintain,
inspect, or repair BOPs or other critical
components meet the qualifications and
training criteria specified by the OEM
and that such maintenance, inspection,
and repair be undertaken in accordance
with recognized engineering practices.
This provision is necessary to ensure
that any personnel working on BOPs are
properly qualified to perform any
maintenance, inspections, or repairs.
Proposed paragraph (e) would require
that all records be made available to
BSEE upon request. This provision
would also require operators to ensure,
by contract or otherwise, that a rig
owner maintains BOP records on the rig
for 2 years from the date the records are
created or longer if directed by BSEE.
Also, all design, maintenance,
inspection, and repair records must be
maintained at an onshore location for
the service life of the equipment.
Records and Reporting
What records must I keep? (§ 250.740)
This proposed section would include
content from existing § 250.466 and
would make the requirements
applicable to all operations covered
under this subpart. This section would
also include recordkeeping of all tests
conducted and real-time monitoring
data gathered during operations.
How long must I keep records?
(§ 250.741)
This proposed section would contain
content from existing § 250.467 with
minor edits to clarify applicability to all
operations covered under this subpart.
This section would also include how
long records for real-time monitoring
data must be kept.
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What well records am I required to
submit? (§ 250.742)
This proposed section would contain
some content from existing § 250.468.
The remainder of the existing § 250.468
would be included in proposed
§ 250.743.
What are the well activity reporting
requirements? (§ 250.743)
This proposed section would include
content from existing paragraphs (b) and
(c) of existing § 250.468, BSEE NTL
2009–G20, Standard Reporting Period
for the Well Activity Report, and BSEE
NTL 2009–G21, Standard Conditions of
Approval for Well Activities with the
following changes:
Proposed paragraph (a) would clarify
the well activity reporting timeframe for
the GOM OCS Region as currently set
forth in NTL 2009–G20. This new
revision would help clarify when to
submit the WARs (Form BSEE–0133)
and accompanying Form BSEE–0133S,
Open Hole Data Report. The District
Manager may require more frequent
submittal of the WAR on a case-by-case
basis.
Proposed paragraph (c) would be
revised to include in the WAR,
information from NTL 2009–G21
describing the operations conducted,
any abnormal or significant events that
affect the permitted operation, verbal
approvals, the wells as-built drawings,
casing fluid weights, shoe tests, test
pressures at surface conditions, and
status of the well at the end of the
reporting period. The final WAR would
include the date operations finished.
This paragraph would also require
describing the returns for casing
cementing operations. This data would
provide BSEE with accurate information
regarding the operations and well
conditions and verify the operator’s
compliance with past approvals.
Upon final publication of this rule,
BSEE will rescind any NTLs that are
superseded by this section in the final
rule.
tkelley on DSK3SPTVN1PROD with PROPOSALS2
What are the end of operation reporting
requirements? (§ 250.744)
This proposed section would combine
provisions from existing §§ 250.465,
250.1712, 250.1717, and NTL 2009–G21,
Standard Conditions of Approval for
Well Activities, and include
clarifications concerning the contents of
the EOR (Form BSEE–0125). This
information would provide BSEE with
important well data and provide a better
understanding of the operations and
well conditions.
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What other well records could I be
required to submit? (§ 250.745)
This proposed section would reflect
content from existing § 250.469.
What are the recordkeeping
requirements for casing, liner, and BOP
tests, and inspections of BOP systems
and marine risers? (§ 250.746)
This proposed section would reflect a
combination of existing §§ 250.426,
250.450, 250.517, 250.617, and
250.1707, with the following revisions:
Proposed paragraph (b) would add the
requirement for the designated rig or
contractor representative (e.g., the
offshore installation manager) and
pump operator to sign and date the
pressure charts and reports as correct in
addition to the onsite lessee
representative (e.g., the company man).
Proposed paragraph (d) would be
clarify that identification of the pods
would not apply to coiled tubing and
snubbing units.
Proposed paragraph (e) would clarify
that any leaks observed during testing or
observed from the control station are
considered irregularities and would
have to be reported to BSEE. Operations
would have to be suspended until BSEE
grants approval to continue. This
revision would allow BSEE to be
notified of the BOP irregularities to help
determine BOP operability.
Proposed paragraph (f) would add the
timeframe for keeping the records for a
minimum of 2 years after completion of
the operation and require that the
records would have to be made
available to BSEE upon request. The
BSEE would be able to use this data as
a tool to verify the operator’s
compliance with past approvals and
regulations.
Subpart P—Sulphur Operations
Well-control drills (§ 250.1612)
This section would update the
reference for the drilling crew
requirements under proposed § 250.711.
21527
help BSEE verify that wells have been
properly plugged in accordance with
API Spec. 11D1.
Paragraph (f) would be revised to add
reference to the requirements of new
Subpart G. This would make Subpart G
applicable to decommissioning.
When must I submit decommissioning
applications and reports? (§ 250.1704)
Paragraph (g) would be revised by
removing current paragraphs (g)(2),
(g)(4), and (g)(6) and the associated
instructions in the third column, as well
as by revising the numbering of current
paragraphs (g)(3) and (g)(5) to (g)(2) and
(g)(3), respectively, and by updating the
applicable citations. Proposed
paragraph (h) would be added to state
the requirements for when to submit the
EOR, making it clear when operators
would have to submit the EOR versus an
APM.
What BOP information must I submit?
(§ 250.1705)
This section would be removed and
reserved. The content of this section
would be moved to proposed §§ 250.731
and 250.732.
Coiled tubing and snubbing operations.
(§ 250.1706)
Paragraphs (a) through (e) would be
moved to proposed §§ 250.730, 250.733,
250.734, and 250.735. The section
heading would be renamed from, What
are the requirements for blowout
prevention equipment? to Coiled tubing
and snubbing operations. Remaining
paragraphs (f) through (h) would be
redesignated as (a) through (c).
What are the requirements for blowout
preventer system testing, records, and
drills? (§ 250.1707)
This section would be removed and
reserved. The content of this section
would be moved to proposed
§§ 250.711, 250.736, 250.737, and
250.746.
Subpart Q—Decommissioning Activities
What are my BOP inspection and
maintenance requirements? (§ 250.1708)
What are the general requirements for
decommissioning? (§ 250.1703)
This section would be revised as
follows:
Paragraph (b) would include a new
requirement that all packers and bridge
plugs would have to comply with API
Spec. 11D1, which would help ensure
that packers and bridge plugs conform
to design, manufacture, and testing
criteria to increase reliability and to
ensure appropriate use of the
equipment. Currently, BSEE does not
have specific guidelines for packers and
bridge plugs, and this addition would
This section would be removed and
reserved. The content of this section
would be moved to proposed § 250.739.
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What are my well-control fluid
requirements? (§ 250.1709)
This section would be removed and
reserved. The content of this section
would be moved to proposed § 250.720.
How must I permanently plug a well?
(§ 250.1715)
Paragraph (a)(3)(iii)(B) of this section
would be revised to add that a ‘‘casing’’
bridge plug would be set 50 to 100 feet
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above the top of the perforated interval.
Adding the word ‘‘casing,’’ clarifies the
plug requirements for the applicable
scenario. The BSEE has been contacted
by multiple companies requesting
clarification of this type of requirement.
The BSEE believes that the proposed
addition of ‘‘casing’’ adequately
addresses the concerns stated by
industry participants and explains the
correct intention of this proposed
section.
After I permanently plug a well, what
information must I submit? (§ 250.1717)
This section would be removed and
reserved. The content of this section
would be moved to proposed § 250.744.
If I temporarily abandon a well that I
plan to re-enter, what must I do?
(§ 250.1721)
This section would remove existing
paragraph (g) and redesignate paragraph
(h) as (g). The content of existing
paragraph (g) would be required by
proposed § 250.744.
Additional Comments Solicited
In addition to the input previously
requested, BSEE requests public
comment on the following issues.
BSEE has estimated the daily rig rates
and made assumptions based on that
estimation. The BSEE is soliciting
comments on the appropriateness of the
values presented and is further
requesting corresponding data to
substantiate any comments. The BSEE
can use this data to update the values
in the final rule. The following chart
shows the daily operating costs used
within the economic analysis.
(1) Rig Daily Operating Rates
Throughout the proposed rule and
corresponding economic analysis, the
Rig type
Estimated daily operating cost
Rigs that utilize a subsea BOP (e.g. drillships, semi-submersibles) ........................................................................
Rigs that utilize a surface BOP (e.g. jack-ups, lift boats) .........................................................................................
tkelley on DSK3SPTVN1PROD with PROPOSALS2
(2) Failure of Equipment Reporting and
Information Dissemination
Several of the standards that are being
incorporated by reference include a
process for the reporting of failures of
equipment back to the OEM. The BSEE
proposes to adopt these processes and
add a requirement that BSEE be notified
of major issues that require a design
change. This notification would help to
ensure that the domestic and
international communities are able to
react quickly to address potential safety
issues.
Because identical equipment designs
are often used by multiple operators,
ensuring the timely reporting of failures
involving critical equipment can assist
in identifying trends and play an
important role preventing future
incidents. The BSEE believes that a
more formalized method of collecting,
analyzing, and disseminating failure
data is warranted, especially for
equipment failures that do not result in
a reportable incident. The need for this
type of program was clearly
demonstrated following the December
2012 failures of certain bolts in the
GOM. Subsequent investigations
revealed that although these failures had
been occurring over a period of years,
most of the industry was not aware of
the safety issues. Even after safety alerts
were issued by BSEE and the OEM,
some operators claimed that the amount
and quality of data that was released
was not sufficient. The BSEE has
received comments from the industry
stating that legal and commercial
barriers discouraged the voluntary
reporting of this type of data.
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The BSEE requests comments on
whether this information should be
provided to the agency or a third-party
to ensure the timely analysis and widespread communication of the data. For
example, are there programs in other
industries that could serve as a model
for reporting failure of OCS equipment?
Are there third-party organizations that
would be good candidates for collecting
and analyzing information and issuing
safety alerts? What type of data should
be collected and disseminated? How
should information on international
operations be collected and
disseminated?
(3) Maintenance and Training
Preventative and remedial
maintenance is critical to maintaining a
satisfactory level of reliability during
the operational life of critical
equipment. A lifecycle management
approach toward safety critical
equipment is especially important as the
industry moves into the development of
deepwater and HPHT reservoirs. More
rigorous inspection, maintenance, and
repair practices and methods may be
needed to ensure the reliable
performance of this equipment in these
environments.
The BSEE requests comments on
whether there are any additional
standards or practices related to the
repair and maintenance of this
equipment that should be considered by
BSEE. The BSEE has completed a major
study related to maintenance,
inspection and test activities, and
management systems. The BSEE
requests information on any work that is
being conducted by the industry to
develop industry standards concerning
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$1,000,000
200,000
these activities. The BSEE also requests
comments on whether there are
predictive maintenance techniques or
risk-based maintenance approaches that
should be used to supplement the
proposed requirements.
The proposed regulation requires the
use of real-time monitoring systems for
operations with a subsea BOP stack or
involving HPHT environments. The
BSEE requests comments on the use of
continuous remote monitoring and
diagnostic analysis of critical equipment
using condition-based maintenance
(CBM). With CBM, critical equipment
can be monitored and maintenance
actions performed based on information
collected through constant real-time
monitoring of critical equipment. These
systems may provide early warning of
potential problems that could be
addressed before costly and dangerous
catastrophic failures. The BSEE believes
that these systems may help to verify
the integrity of the overall system
during drilling operations in a more
timely and efficient manner.
The BSEE believes that it is important
that components and replacement parts
for critical equipment meet quality
design and engineering standards that
ensure that this equipment operates
safely and as originally designed during
its service life. Additionally, the
equipment must be repaired and
maintained by highly trained personnel
that understand the OEM design and
repair standards. These requirements
are implicit in the Safety and
Environmental Management Systems
(SEMS) requirements contained in
existing BSEE regulations. The BSEE
requests comments on what type of
training and certification programs
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should be required for personnel
working on this critical equipment. Are
there training and certification programs
being used in other industries that can
serve as a model for the OCS personnel?
How should repairs being performed
outside U.S. waters be monitored? Are
there any existing oil and gas training
and certification programs that should
be incorporated into the regulations?
tkelley on DSK3SPTVN1PROD with PROPOSALS2
(4) Verification of BOP Performance
The BSEE believes that the proposed
requirements would provide the agency
with additional assurance related to the
overall reliability of equipment in the
future. The industry and BSEE currently
rely on function and hydrostatic tests to
verify the performance of BOP
equipment in the field. These tests have
traditionally been the primary method
of verifying the capability of in-service
equipment.
In recent years, the industry has
raised concerns related to benefits of
pressure and functional testing of
subsea BOPs versus the costs and
potential operational issues. The BSEE
requests comments on the adequacy of
the current functional and pressure test
requirements in predicting the
performance of this equipment in
subsequent drilling operations. Under
what circumstances or environments
should the testing frequency be
increased or decreased? Are there
additional technologies, processes, or
procedures that can be used to
supplement existing requirements and
provide additional assurances related to
the performance of this equipment?
The latest industry study on BOP
reliability and testing frequency was
submitted to the MMS in 2009. What
type of additional research and data
collection is needed or has already been
conducted to verify the reliability of this
equipment? Can the combination of
real-time monitoring and condition
based maintenance justify reduced
pressure testing? Does testing too
frequently result in a shorter BOP
operational lifespan?
Please provide supporting reasons
and data for your responses.
(5) Increased Severing Capability
The BSEE is proposing a variety of
requirements that will increase the
likelihood that a BOP will be able to
severe a drill string in an emergency
situation to shut-in the well and prevent
a catastrophic blowout.4 However, there
4 See recommendations of Offshore Energy Safety
Advisory Committee, August 2012 meeting,
available at: https://www.bsee.gov/uploadedFiles/
BSEE/About_BSEE/Public_Engagement/Ocean_
Energy_Safety_Advisory_Committee/OESC%20
Recommendations%20August%202012%20
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are a variety of components in the drill
string (e.g., drill collars) that cannot be
severed using technology that is
currently being used in offshore
operations. Accordingly, BSEE is
considering including the following
requirement in § 250.734 of the final
rule for subsea BOPs:
You must install technology that is capable
of severing any components of the drill string
(excluding drill bits). You must install this
technology within 10 years from the
publication of the final rule.
Such a severing requirement would
provide additional protection against
the potential loss of well control by
requiring that operators install
supplemental technology that ensures
all components of a drill string,
including those components that cannot
be sheared with current shear rams,
could be severed in an emergency to
allow the well to be safely shut-in. The
operator would have the flexibility to
develop or select the technology and
equipment to accomplish this
performance-based requirement. The
BSEE is aware of at least one candidate
technology that is currently being
evaluated and believes that other
innovative or improved technologies
would be developed to accomplish this
objective, if such a requirement is
adopted in the final rule. The industry
has demonstrated that it has the
financial resources and technical
expertise to develop the innovative
technology needed to explore and
produce oil and gas resources in
challenging deepwater and HTHP
environments.5
In addition, BSEE is considering
whether to also make this type of
Meeting%20Chairman%20Letter%20to%20BSEE
%20101512.pdf.
5 For example, soon after the Deepwater Horizon
incident, several of the largest oil companies
created the Marine Well Containment Co., and
agreed to spend $1billion to develop and build new
containment technology for deepwater drilling. See
https://www.npr.org/2011/04/19/135513456/oilfirms-seek-to-prove-they-can-contain-spills. In
addition, BP initiated ‘‘Project 20K’’—a major
research and development initiative involving
Maersk Drilling and other companies—to develop
new technologies, within a decade, for drilling
safely in deepwater under HPHT conditions. See
https://www.maersk.com/en/the-maersk-group/
about-us/maersk-post/2014-5/pushingtechnological-boundaries. Similarly, McMoran has
already invested over $1.2 billion in deepwater
drilling sites in the GOM and is working with
researchers and manufacturers to develop heavy
duty BOPs and make other necessary technological
advances. See https://www.forbes.com/sites/
christopherhelman/2013/05/08/mcmoran-givesupdate-on-davy-jones-the-1-billion-ultradeep-well/;
https://www.spe.org/tech/2012/04/highpressurehigh-temperature-challenges/. See also
https://www.shell.com/global/aboutshell/majorprojects-2/perdido/unlocking-energy.html (Shell
uses innovative, first-of-its-kind technology to
produce ultra-deep Perdido well).
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21529
requirement applicable to surface BOPs
in § 250.733 in the final rule. The BSEE
is requesting comments on the following
issues:
—Please comment on whether BSEE
should include a severing provision
for subsea BOPs in the final rule, as
previously described. If BSEE does so,
please address whether that
requirement should also apply to
surface BOPs, given the number of
blowouts involving surface stacks.
—What incentives or other actions
could be used to assist in the
development and implementation of
this technology? What should BSEE’s
role, if any, be in this development
process?
—If BSEE includes a severing provision
in the final rule, what would be an
appropriate effective date for such a
requirement? In particular, please
comment on whether 10 years would
be appropriate to develop technology
that could meet the severing
requirement, or whether the
timeframe for development of such
technology and for compliance with
the requirement could be shortened
(e.g., to 5 years).
Please provide an explanation and
data with your responses.
The BSEE is unable to locate any
applicable comparative cost estimates or
other data to estimate the labor or other
costs to industry that would be
associated with the installation of
technology capable of severing any
components of the drill string
(excluding drill bits). Also, assessing or
quantifying the potential benefits that
could arise from the reduction of risks
over the 10-year period covered by the
economic analysis for this proposed rule
would require additional data.
Accordingly, BSEE is also requesting
comments on the following issues
associated with this potential severing
provision:
—Please provide comments on any costs
related to the development and
installation of technology that would
be needed to satisfy this type of
performance-based requirement
within 10 years. Assuming the final
rule includes such a provision, how
should BSEE include such costs in the
final economic analysis for this
rulemaking, given that the analysis
uses a 10-year period to estimate all
costs and benefits?
—What would be the costs of
developing and installing appropriate
technology to meet such a severing
requirement in 5 years? If it would not
be feasible to comply with this
requirement in 5 years, what would
be the incremental increase in costs of
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any implementation deadline between
5 years and 10 years?
—How much would a severing
requirement, whether applicable only
to subsea BOPs or to subsea and
surface BOPs, reduce the risk or
consequences of a blowout? If BSEE
includes such a requirement in the
final rule, to be effective 10 years after
the final rule takes effect, how could
BSEE estimate the benefits of such
risk reduction given that those
benefits would not be realized until
after the 10-year economic analysis
period used in this proposed rule? If
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BSEE included such a severing
requirement with a shorter time
period for compliance (e.g., 5 years
from the final rule effective date), how
could BSEE estimate the potential risk
reduction benefits?
—Please describe any alternative
method (other than the potential
severing requirement) to protect
against the potential loss of well
control. Please discuss whether such
an alternative would be more or less
costly than the proposed requirement.
Please explain your conclusions and
provide supporting information.
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Appendix
The following appendix will not
appear in the Code of Federal
Regulations. Appendix A is included in
this proposed rule so we may solicit
your comments on proposed revisions
to an existing form for use in reporting
some of the information required in
proposed subpart G.
Appendix—Department of the
Interior—Form BSEE–0144, ‘‘Rig
Movement Notification Report.’’
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21531
RIG MOVEMENT NOTIFICATION REPORT
U. S. Department of the Interior
OMB Control Number 1014-NEW
OMB Approval Expires: xx/xx/xxxx
Bureau of Safety & Environmental Enforcement
Use this form to report the movement (including skids, stacking, and moving in or out of the
OCS) of all rig units include MODUs, platform rigs, snubbing units, wire-line units used for
non-routine operations, and coiled tubing units. If the rig is moving from one location to
another, you may show this by completing the information for both rig departure and rig arrival
on the same form. It is preferred by BSEE that the report information be submitted utilizing the
BSEE eWell web based system at
or you have the option to e-mail or
telefax (see page 2 for contact information) to the appropriate BSEE Office(s) at least 72 hours
before ou move the ri .
GENERAL INFORMATION
I Lease Operator
Report Date
Rig Type: Barge ___ Coiled Tubing Unit ___
Rig Name
Drill Ship
Jackup
Snubbing Unit
Platform
Semisubmersible
Submersible - - - Wire-Line Unit - - -
IRig Telephone Number
Rig Representative
RIG ARRIVAL INFORMATION
Work Scheduled: Drilling ___ Workover ___ Completion ___ TA ___ PA - - -
Rig Arrival Date
Other (specify)
Is rig new to OCS?
Yes
No
Location where rig came from:
--------------------------------------------
Well API Number (10 digits)
Well Name
Expected Duration of Well Operations
Well Surface
Location
Information
Structure Location
Information
Area Name
Block
No.
Lease
No.
Latitude
Longitude(Optional)
(Optional)
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Is Well Adjacent to
If Yes, Identify Structure Distance from Structure
Structure?
No
(Optional)
Yes
Remarks (Include size and extent of the mooring system and number of lighted and unlighted buoys
deployed) (Optional)
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Federal Register / Vol. 80, No. 74 / Friday, April 17, 2015 / Proposed Rules
RIG DEPARTURE INFORMATION
Rig Departure Date
IWell Status:
Well API Number (10 digits)
Completed ___
Well Name
DSI
TA - - -
---
PA - - -
Is Rig Being Skidded on the Platform?
Yes - - No - - -
Well Surface
Area Name
Block
Latitude
Lease
Location
No.
(Optional)
No.
Information
Area Clearance
Is Area Clear of
If No, Explain
Obstructions?
Information
(Optional)
Yes
No
Remarks (Include any significant en route movements) (Optional)
Longitude(Optional)
RIG STACKING INFORMATION
Rig Arrival Date
Manned (warm)
Any modifications,
repairs, or
construction:
Rig Departure Date
Un-manned (cold)
Date of
Modifications,
repairs, or
construction
Location:
Area Name
Block No.
Latitude(Optional)
Longitude
(Optional)
Yes
No
Area Clearance
Is Area Clear of Obstructions?
If No, Explain
Information
Yes--- No
roptional)
Remarks (Explain any modifications, repairs, or construction.)
CERTIFICATION: I certify that the information submitted above is complete and accurate to the
best of my knowledge. I understand that making a false statement may subject me to criminal
penalties under 18 U.S.C. 1001.
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Date:
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Name and Title:
Federal Register / Vol. 80, No. 74 / Friday, April 17, 2015 / Proposed Rules
BILLING CODE 4310–VH–C
—The organization and content of the
proposed revisions.
VI. Derivation Tables
The following tables are intended to
provide information about the
derivation of proposed requirements in
Subparts A, B, D, E, F, proposed G, P,
and Q. These tables provide guidance
on the following:
—The destination of various current
requirements.
Current regulations section
These tables do not provide definitive
or exhaustive guidance, and should be
used in conjunction with the section-bysection discussion and regulatory text of
this proposed rule.
The following sections in 30 CFR part
250, subparts D, E, F, and Q have either
been [Removed and/or Reserved]
according to the following table.
Proposed rule section
21533
Subpart
Removed and/or Reserved in 30
CFR Part 250
D ..........
401, 402, 403, 406, 417, 424, 425,
426, 440 through 451, 466
through 469.
502, 506, 515 through 517.
602, 606, 615, 617, 618.
1705, 1707 through 1709, 1717.
E ...........
F ...........
Q ..........
The proposed rule would make
changes as outlined in the following
table:
Nature of change
Subpart A
250.102(b) .....................................
250.107(a)(3), (a)(4); (e) ...............
250.125(a)(2) ...................................
250.198(h) .......................................
250.125(a)(2) .................................
250.198(h) .....................................
250.199(e) .......................................
250.199(e) .....................................
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Added reference to new subpart G.
Added the use of recognized industry practices and BSEE-issued orders.
Revised (2) to reflect the redesignation of 250.292(q).
Updated citations in (h)(51), (68), (70); removed the RP and added in
its place the Standard in (h)(63); added new (h)(89–94).
Updated OMB control numbers and reword, for plain language, the
reasons BSEE collects the data. And added paragraphs for APDs,
APMs, and Subpart G.
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250.102(b) .......................................
NEW ................................................
21534
Federal Register / Vol. 80, No. 74 / Friday, April 17, 2015 / Proposed Rules
Current regulations section
Proposed rule section
Nature of change
Subpart B
250.292(p) .......................................
NEW ................................................
250.292(q) .....................................
250.292(p) .....................................
Redesignated.
New section that specifies FSHR requirements within the DWOP.
Subpart D
250.400 ...........................................
250.400 ..........................................
250.401
250.402
250.403
250.406
250.411
250.703
250.720
250.712
250.723
250.411
...........................................
...........................................
...........................................
...........................................
...........................................
..........................................
..........................................
..........................................
..........................................
..........................................
250.413(g) .....................................
250.414 ..........................................
250.415(a) .......................................
250.415(a) .....................................
250.416 ...........................................
250.417 ...........................................
250.418(g) .......................................
250.416(a), (b); 250.730; 250.731;
250.732.
250.713 ..........................................
250.418(g) .....................................
250.420 ...........................................
250.420 ..........................................
250.421 ...........................................
250.421(b) and (f) ..........................
250.423 ...........................................
250.423 ..........................................
250.423(a) and (c) ..........................
250.424 ...........................................
250.425 ...........................................
250.426 ...........................................
250.427(b) .......................................
250.721 ..........................................
250.722 ..........................................
250.721 ..........................................
250.746 ..........................................
250.427(b) .....................................
250.428 ...........................................
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250.413(g) .......................................
250.414 ...........................................
250.428 ..........................................
250.440 ...........................................
250.441 ...........................................
250.442 ...........................................
250.443 ...........................................
250.443(c) and (d) ..........................
250.444 ...........................................
250.445 ...........................................
250.446 ...........................................
250.447 ...........................................
250.448 ...........................................
250.449 ...........................................
250.450 ...........................................
250.451 ...........................................
250.456(k) .......................................
250.730 ..........................................
250.733; 250.735 ...........................
250.734 ..........................................
250.734; 250.735 ...........................
250.733 ..........................................
250.736 ..........................................
250.736 ..........................................
250.739 ..........................................
250.737 ..........................................
250.737 ..........................................
250.737 ..........................................
250.746 ..........................................
250.738 ..........................................
250.456(j) .......................................
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Revised section heading and requirements to encompass General
Requirements for drilling and clarify that Subpart G has applicable
requirements as well.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
Revised to separate the diverter and the BOP descriptions; updating
citations.
Revised to add the phrase ECD.
Revised paragraphs (c), (h), (i); added new paragraphs (j) and (k) to
help ensure the well’s structural integrity and submission of any additional information required by the District Manager.
Revised paragraph (a) for casing information in all sections for each
casing interval.
Revised to remove only the BOP descriptions in the regulatory text
and section heading.
Removed—similar language found in new Subpart G.
Revised to include a description of how far below the mudline the operator proposes to displace cement in the request for approval; revised citation.
Revised the introductory paragraph to include applicable casing and
cementing requirements in Subpart G; added new paragraph (a)(6)
to require adequate centralization to ensure proper cementation;
added new paragraph (b)(4) requiring District Manager approval
before installing a different casing than what was approved in the
APD; modified paragraph (c) requiring the use of a weighted fluid.
Revised paragraph (b) so casing would have to be set immediately
and set above the encountered zone, even if it is before the
planned casing point if oil or gas or unexpected formation pressure
arises. Revised paragraph (f) to no longer allow liners to be installed as conductor casing.
Revised the section heading and removed the pressure testing and
negative pressure testing requirements; added clarification about
latching mechanisms. Edited the remaining paragraphs of 250.423
for organization.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
Revised paragraph (b) to clarify that operators must maintain two
drilling margins.
Revised paragraphs (b) through (d). Paragraph (b) requires approval
for hole interval drilling depth changes greater than 100 ft. TVD,
and the submittal of a PE certification that the certifying PE reviewed and approved the proposed changes; paragraph (c) clarifies requirements when there is any indication of an inadequate cement job; and paragraph (d) clarifies that if there is an inadequate
cement job, the District Manager has to review and approve all remedial actions; that the changes to the well program are reviewed,
approved, and certified by a PE; and any other requirements of the
District Manager. New paragraph (k) adds requirements concerning
the use of values on drive pipe during cementing operations.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
Redesignated.
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21535
Current regulations section
Proposed rule section
Nature of change
250.456(j) ........................................
NEW ................................................
250.720 ..........................................
250.462 ..........................................
250.462 ...........................................
250.710 and 250.711 ....................
250.465(b)(3) ...................................
250.465(b)(3) .................................
250.466 ...........................................
250.467 ...........................................
250.468(a) .......................................
250.468(b) and (c) ..........................
250.469 ...........................................
250.740
250.741
250.742
250.743
250.745
Removed—similar language found in new Subpart G.
New section heading and requirements to demonstrate deepwater
well containment.
Removed heading and requirements for well- control drills—similar
language found in new Subpart G.
This paragraph was revised to update the citation for the EOR form,
BSEE–0125.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
..........................................
..........................................
..........................................
..........................................
..........................................
Subpart E
250.500 ...........................................
250.500 ..........................................
250.502 ...........................................
250.506 ...........................................
250.514(d) .......................................
250.515 ...........................................
250.516 ...........................................
250.518 ...........................................
250.723 ..........................................
250.710 ..........................................
250.720 ..........................................
250.731; 250.732 ...........................
250.730;
250.733;
250.734;
250.735; 250.736.
250.711;
250.737,
250.738,
250.739; 250.746.
250.518(e), (f) ................................
250.518(b) .......................................
250.722 ..........................................
250.517 ...........................................
Revised section heading and requirements to encompass General
Requirements and direct compliance with new Subpart G where
applicable.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
Removed paragraph (b) and redesignated the remaining paragraphs.
Added new paragraphs (e) and (f) to add API Spec. 11D1, packer
and bridge plug requirements, and a description of calculations of
packer setting depth.
Redesignated and revised to include additional requirements for prolonged operations.
Subpart F
250.600 ...........................................
250.600 ..........................................
250.602 ...........................................
250.606 ...........................................
250.614(d) .......................................
250.615 ...........................................
250.616(a) through (e) ....................
250.616(f) through (h) .....................
250.617 ...........................................
250.618 ...........................................
250.619 ...........................................
250.723 ..........................................
250.710 ..........................................
250.720 ..........................................
250.731; 250.732 ...........................
250.730;
250.733;
250.734;
250.735; 250.736.
250.616(a) through (c) ...................
250.711; 250.737; 250.746 ...........
250.739 ..........................................
250.619 ..........................................
250.619(b) .......................................
250.722 ..........................................
Revised section heading and requirements to encompass General
Requirements and direct compliance with new Subpart G where
applicable.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
Redesignated with no changes made to regulatory text.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart G.
Removed paragraph (b) and redesignated the section. Added new
paragraphs (e) and (f) to add packers and bridge plug requirements, API Spec. 11D1, and a description of calculations of packer
setting depth.
Redesignated and revised to include additional requirements for prolonged operations.
New Subpart G
General requirements
NEW ................................................
250.700 ..........................................
250.408 ...........................................
250.409 ...........................................
250.401 ...........................................
250.701 ..........................................
250.702 ..........................................
250.703 ..........................................
New section describing what operations and equipment are subject to
the requirements.
Similar language pertaining to alternative procedures or equipment.
Similar language pertaining to departures.
Similar language containing requirements to keep wells under control.
tkelley on DSK3SPTVN1PROD with PROPOSALS2
Rig Requirements
250.462; 250.506; 250.606 .............
250.710 ..........................................
250.462;
250.517;
250.617;
250.1707.
250.403 ...........................................
250.711 ..........................................
250.712 ..........................................
250.417 ...........................................
250.713 ..........................................
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Similar language was revised and incorporated into this
instructions for rig personnel.
Similar language was revised and incorporated into this
well-control drills.
Similar language was revised and incorporated into this
rig movement notifications.
Similar language was revised and incorporated into this
MODUs or lift boat requirements for well operations.
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section about
section about
section about
section about
21536
Federal Register / Vol. 80, No. 74 / Friday, April 17, 2015 / Proposed Rules
Current regulations section
Proposed rule section
Nature of change
NEW ................................................
NEW ................................................
250.714 ..........................................
250.715 ..........................................
New section about dropped objects plans.
New section about GPS for MODUs and jack-ups.
Well Operations
250.402; 250.456(j); 250.514(d);
250.614(d); 250.1709.
250.423(a), (c); 250.425 .................
250.720 ..........................................
250.721 ..........................................
250.424; 250.518; 250.619 .............
250.722 ..........................................
250.406; 250.502; 250.602 .............
250.723 ..........................................
NEW ................................................
250.724 ..........................................
Similar language was revised and incorporated into this section about
securing a well.
Similar language was revised and incorporated into this section about
pressure testing casing and liners.
Similar language was revised and incorporated into this section pertaining to prolonged well operations.
Similar language from 250.406, 250.502, and 250.602 was revised
and incorporated into this section relating to safety measures on a
platform producing wells or other hydrocarbon flow.
New section relating to real-time monitoring requirements.
Blowout Preventer (BOP) System Requirements
250.416;
250.440;
250.516;
250.616(a) through (e); 250.1706.
250.416;
250.515;
250.615;
250.1705.
250.730 ..........................................
250.416;
250.515;
250.1705.
250.615;
250.732 ..........................................
250.441; 250.443(c), (d); 250.516;
250.616(a) through (e); 250.1706.
250.733 ..........................................
250.442; 250.443(c), (d); 250.516;
250.616(a) through (e); 250.1706.
250.734 ..........................................
250.441;
250.443;
250.616; 250.1706.
250.516;
250.735 ..........................................
250.444;
250.445;
250.516;
250.616(a) through (e); 250.1707.
250.736 ..........................................
250.447;
250.448;
250.449;
250.517; 250.617; 250.1707.
250.737 ..........................................
250.451 and 250.517 ......................
250.738 ..........................................
250.446;
250.517;
250.1708.
250.739 ..........................................
250.618;
250.731 ..........................................
Similar language was revised and incorporated into this section about
general requirements for BOP systems and their components.
Similar language was revised and incorporated into this section about
submittal requirements for information about BOP systems and
their components.
Similar language was revised and incorporated into this section relating to third-party information for BOP systems and their components.
Similar language was revised and incorporated into this section and
new language was added relating to requirements for a surface
BOP stack.
Similar language was revised and incorporated into this section and
new language was added relating to requirements for a subsea
BOP system.
Similar language was revised and incorporated to this section and
new language was added relating to equipment and systems all
BOPs must have.
Similar language was revised and incorporated into this section pertaining to requirements for choke manifolds, kelly valves, inside
BOPs, and drill string safety valves.
Added new language and similar language was revised and incorporated into this section relating to BOP system testing requirements.
Added new language and similar language was revised and incorporated into this section for situations arising involving BOP equipment or systems.
Similar language was revised and incorporated into this section pertaining to BOP maintenance and inspection requirements.
Records and Reporting
250.466 ...........................................
250.467 ...........................................
250.740 ..........................................
250.741 ..........................................
250.468(a) .......................................
250.468(b) and (c) ..........................
250.742 ..........................................
250.743 ..........................................
250.465; 250.1712; 250.1717 .........
250.744 ..........................................
250.469 ...........................................
250.426;
250.450;
250.517;
250.617; 250.1707.
250.745 ..........................................
250.746 ..........................................
Redesignated and revised the types of records to keep.
Redesignated and added records relating to real-time monitoring
data.
Redesignated.
Redesignated and revised to include more requirements for the well
activity reporting.
Redesignated and revised to include additional end of operation reporting requirements.
Redesignated and revised to update references.
Similar language was revised and incorporated into this section pertaining to record-keeping for casing, liner, and BOP tests.
Subpart P
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250.1612 .........................................
250.1612 ........................................
Revised to update references.
Subpart Q
250.1703 .........................................
250.1703 ........................................
250.1704 .........................................
250.1704 ........................................
250.1705 .........................................
250.731, 250.732 ...........................
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Revised paragraph (b) to have new packers and bridge plug requirements, including API Spec. 11D1. Revised paragraph (e); Redesignated existing paragraph (f) as (g); and added a new paragraph (f)
to follow the applicable requirements of Subpart G.
Revised paragraphs (g) and added new paragraph (h) about APMs
and EORs.
Removed—similar language found in new Subpart G.
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Current regulations section
Proposed rule section
250.1706(a) through (e) ..................
250.730; 250.733, 250.734, and
250.735.
250.1706(a) through (c) .................
250.711,
250.736,
250.737,
250.746.
250.739 ..........................................
250.720 ..........................................
250.1715(a)(3)(iii)(B) .....................
250.744 ..........................................
250.744 ..........................................
250.1721(g) ...................................
250.1706(f) through (h) ...................
250.1707 .........................................
250.1708 .........................................
250.1709 .........................................
250.1715(a)(3)(iii)(B) .......................
250.1717 .........................................
250.1721(g) .....................................
250.1721(h) .....................................
tkelley on DSK3SPTVN1PROD with PROPOSALS2
VII. Procedural Matters
Nature of change
Removed—similar language found in new Subpart G.
Revised the section heading; redesignated.
Removed—similar language found in new Subpart G.
Removed—similar language found in new Subpart
Removed—similar language found in new Subpart
Added the word ‘‘casing.’’
Removed—similar language found in new Subpart
Removed—similar language found in new Subpart
Redesignated and text remains unchanged.
—Materially alters the budgetary
impacts of entitlement grants, user
fees, loan programs, or the rights and
obligations of recipients thereof; or
—Raises novel legal or policy issues
arising out of legal mandates, the
President’s priorities, or the
principles set forth in E.O. 12866.
Regulatory Planning and Review
(Executive Orders (E.O.) 12866 and
13563))
E.O. 12866 provides that the Office of
Information and Regulatory Affairs
(OIRA) in the OMB will review all
significant rules. To determine if this
proposed rulemaking is a significant
rule, BSEE had an outside contractor
prepare an economic analysis to assess
the anticipated costs and potential
benefits of the proposed rulemaking.
The following discussion summarizes
the economic analysis; a complete copy
of the economic analysis can be viewed
at www.Regulations.gov (use the
keyword/ID ‘‘BSEE–2015–0002’’).
Changes to Federal regulations must
undergo several types of economic
analyses. First, E.O.s 12866 and 13563
direct agencies to assess the costs and
benefits of regulatory alternatives and, if
regulation is necessary, to select a
regulatory approach that maximizes net
benefits (including potential economic,
environmental, public health, and safety
effects; distributive impacts; and
equity). Under E.O. 12866, an agency
must determine whether a regulatory
action is significant and, therefore,
subject to the requirements of the E.O.
and review by OMB. Section 3(f) of E.O.
12866 defines a ‘‘significant regulatory
action’’ as any regulatory action that is
likely to result in a rule that:
—Has an annual effect on the economy
of $100 million or more, or adversely
affects in a material way the economy,
a sector of the economy, productivity,
competition, jobs, the environment,
public health or safety, or state, local,
or tribal governments or communities
(also referred to as ‘‘economically
significant’’);
—Creates serious inconsistency or
otherwise interferes with an action
taken or planned by another agency;
As previously explained, BSEE has
identified a need to amend the existing
well-control regulations to ensure that
oil and gas operations on the OCS are
conducted in a safe and
environmentally responsible manner. In
particular, BSEE considers the proposed
rule necessary to reduce the likelihood
of any oil or gas blowout, which can
lead to the loss of life, serious injuries,
and harm to the environment. As was
evidenced by the Deepwater Horizon
incident (which began with a blowout at
the Macondo well) on April 20, 2010,
blowouts can result in catastrophic
consequences.6 The government and
industry conducted multiple
investigations to determine the cause of
the Deepwater Horizon incident; many
of these investigations identified BOP
performance as a concern. The BSEE
convened Federal decision-makers and
stakeholders from the OCS industry,
academia, and other entities at a public
forum on offshore energy safety on May
22, 2012, to discuss ways to address this
concern. The investigations and the
forum resulted in a set of
recommendations to enhance safety and
environmental protection of offshore
6 For example, any approximation of cost would
incorporate catastrophic spills such as the
Deepwater Horizon incident. The cost to BP of
cleanup operations for the Deepwater Horizon
incident has been estimated at more than $14
billion. In addition to cleanup costs, BP has paid
over $14 billion to Federal, State, and local
governments as well as private parties for economic
claims and other expenses. See ‘‘Deepwater Horizon
Oil Spill: Recent Activities and Ongoing
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The BSEE has determined that the
proposed rule is a significant
rulemaking within the definition of E.O.
12866 because the estimated annual
costs or benefits would exceed $100
million in at least 1 year of the 10-year
analysis period. Accordingly, OMB has
reviewed this proposed regulation.
1. Need for Regulation
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G.
G.
G.
G.
operations by improving BOP
performance.
As the agency charged with oversight
of offshore operations conducted on the
OCS, BSEE seeks to improve safety and
mitigate risks associated with such
operations. After careful consideration
of the various investigations conducted
after the Deepwater Horizon incident
and industry’s responses to the incident,
BSEE has determined that the
requirements contained in this proposed
rule are critical to address risks
associated with offshore operations.
BSEE has determined that the wellcontrol regulations needed to be
updated to incorporate some of these
recommendations. Other
recommendations are being studied for
consideration in future rulemakings.
The proposed rule would create a new
Subpart G in 30 CFR part 250 to
consolidate requirements for drilling,
completion, workover, and
decommissioning operations.
Consolidating the requirements would
improve efficiency and consistency of
the regulations and allow for flexibility
in future rulemakings. The proposed
rule would also revise provisions in
Subparts D, E, F, and Q of part 250 to
address concerns raised in the
investigations, internally within BSEE,
and at the public forum. Finally, the
proposed rule would incorporate API
Standard 53 to ensure better BOP
operability and more robust regulatory
oversight.
2. Alternatives
The BSEE has considered three
regulatory alternatives:
(1) Promulgate the requirements
contained within the proposed rule,
including increasing the BOP testing
frequency for workover and
decommissioning operations from the
current requirement of once every 7
days to the proposed requirement of
Developments,’’ J. Ramseur & C. Hagerty (2014),
Congressional Research Office, available at: https://
www.fas.org/sgp/crs/misc/R42942.pdf.
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once every 14 days. The following chart
identifies the BOP testing changes
related to Alternative 1:
BOP PRESSURE TESTING
Operation
Current testing frequency
Drilling/Completions ............................................................................................
Workover/Decommissioning ...............................................................................
Once every 14 days ................
Once every 7 days ..................
(2) Promulgate the requirements
contained within the proposed rule with
a change to the required frequency of
BOP pressure testing from the existing
regulatory requirements (i.e., once every
7 or 14 days depending upon the type
of operation) to once every 21 days for
all operations. The following chart
Proposed testing frequency
Once every 14 days.
Once every 14 days.
identifies the BOP testing changes
related to Alternative 2:
BOP PRESSURE TESTING
Operation
Current testing frequency
Proposed testing frequency
(alternative 1)
Drilling/Completions ......................................
Workover/Decommissioning .........................
Once every 14 days ................
Once every 7 days ..................
Once every 14 days ................
Once every 14 days ................
Alternative 2 testing frequency
Once every 21 days.
Once every 21 days.*
* Includes change from current 7 days to proposed 14 days
tkelley on DSK3SPTVN1PROD with PROPOSALS2
(3) Take no regulatory action and
continue to rely on existing well-control
regulations in combination with permit
conditions, DWOPs, operator prudence,
and industry standards.
By taking no regulatory action, BSEE
would leave unaddressed most of the
concerns and recommendations that
were raised 7 regarding the safety of
offshore oil and gas operations and the
potential for another event with
consequences similar to those of the
Deepwater Horizon incident.
Alternative 2 was not selected
because BSEE is lacking critical data on
testing frequency and equipment
reliability. This issue may be considered
in the final rulemaking if BSEE receives
sufficient data to support Alternative 2.
The BSEE has elected to move
forward with Alternative 1—the
proposed rule—which would
incorporate recommendations provided
by government, industry, academia and
other stakeholders, as well as API
Standard 53. In addition to addressing
concerns and aligning with industry
standards, BSEE is functioning in a
prudent capacity with this proposed
rule by advancing several of the more
critical capabilities beyond current
industry standards based on internal
knowledge and experience. The
7 See the DOI JIT report, REPORT REGARDING
THE CAUSES OF THE APRIL 20, 2010 MACONDO
WELL BLOWOUT, September 14, 2011.; The
National Commission final report, DEEP WATER,
The Gulf Oil Disaster and the Future of Offshore
Drilling, January 11, 2011; The Chief Counsel for
the National Commission report, Macondo The Gulf
Oil Disaster, February 17, 2011; National Academy
of Engineering final report, Macondo WellDeepwater Horizon Blowout, December 14, 2011;
BSEE public offshore energy safety forum, May 22,
2012.
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proposed rule would also improve
efficiency and consistency of the
regulations and allow for flexibility in
future rulemakings.
The BSEE is requesting comments on
how long it would take to come into
compliance with the proposed rule as
well as any other alternatives BSEE may
reasonably consider, including
alternatives to the specific provisions
contained in the proposed rule.
3. Economic Analysis
The BSEE’s economic analysis
evaluated the expected impacts of the
proposed rule compared with the
baseline. The baseline refers to current
industry practice in accordance with
existing regulations, industry permits,
DWOPs, and industry standards with
which operators already comply.8
Impacts that exist as part of the baseline
were not considered costs or benefits of
the proposed rule. Thus, the cost
analysis evaluates only activities and
capital investments required by the
proposed rule that represent a change
from the baseline. These estimated
compliance costs are discussed more
specifically in the associated full initial
regulatory impact analysis (RIA), which
can be viewed at www.regulations.gov
(use the keyword/ID ‘‘BSEE–2015–
0002’’).
The analysis covers 10 years (2015
through 2024) to ensure it encompasses
the significant costs and benefits likely
to result from this proposed rule. A 108 BSEE considers compliance with permits,
DWOPs, and industry standards to be ‘‘selfimplementing,’’ as addressed in Section E.2 of OMB
Circular A–4, ‘‘Regulatory Analysis’’ (2003), and
thus includes these costs in the baseline.
PO 00000
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year period was used for this analysis
because of the uncertainty associated
with predicting industry’s activities and
the advancement of technical
capabilities beyond 10 years. It is very
difficult to predict, plan, or project costs
associated with technological
innovation due to unknown
technological or business constraints
that could drive a product into
mainstream adoption or into
obsolescence. The regulated community
itself has difficulty conducting business
modeling beyond a 10-year time frame.
Over time, the costs associated with a
particular new technology may drop
because of various supply and demand
factors, causing the technology to be
more broadly adopted. In other cases, an
existing technology may be replaced by
a lower-cost alternative as business
needs may drive technological
innovation. Extrapolating costs and
benefits beyond this 10-year time frame
would produce more ambiguous results
and therefore be disadvantageous in
determining actual costs and benefits
likely to result from this proposed rule.
The BSEE concluded that this 10-year
analysis period provides the best overall
ability to forecast reliable costs and
benefits likely to result from this
proposed rule. When summarizing the
costs and benefits, we present the
estimated annual effects, as well as the
10-year discounted totals using discount
rates of 3 and 7 percent, per OMB
Circular A–4, ‘‘Regulatory Analysis.’’
The BSEE welcomes comments on
this analysis, including potential
sources of data or information on the
costs and benefits of this proposed rule.
The BSEE quantified and monetized the
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costs, using 2013 data, of all the
provisions in the proposed rule
determined to result in a change
compared to the baseline,
including:xs112
—Additional information in the
description of well-drilling design
criteria;
—Additional information in the drilling
prognosis;
—Prohibition of a liner as conductor
casing;
—Additional capping stack testing
requirements;
—Additional information in the APM
for installed packers;
—Additional information in the APM
for pulled and reinstalled packers;
—Rig movement reporting;
—Fitness requirements for MODUs and
lift boats;
—Foundation requirements for MODUs
and lift boats;
—Monitoring of well operations with a
subsea BOP;
—Additional documentation and
certification requirements for BOP
systems and system components;
—Additional information in the APD,
APM, or other submittal for BOP
systems and system components;
—Submission of a Mechanical Integrity
Assessment Report by a BSEEapproved verification body;
—New surface BOP system
requirements;
—New subsea BOP system
requirements;
—New surface accumulator system
requirements;
— Chart recorders;
— Notification and procedures
requirements for testing of surface
BOP systems;
— Alternating BOP control station
function testing;
— ROV intervention function testing;
autoshear, deadman, and EDS
function testing on subsea BOPs;
— Approval for well-control equipment
not covered in Subpart G;
— Breakdown and inspection of BOP
system and components;
— Additional recordkeeping for realtime monitoring; and
— Industry familiarization with the new
rule.
The BSEE estimated the benefits
derived from time savings associated
with § 250.737(d)(10) of the proposed
rule and the benefits derived from the
reduction in oil spills and fatalities
using the incident-reducing potential of
the proposed rule as a whole. The
largest time savings benefits would
result from proposed § 250.737 (d)(10),
which would streamline the BOP
function testing criteria and increase the
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intervals between this testing. Although
we also consider benefits from potential
reductions in oil spills and reduced
fatalities, the time savings benefits of
the proposed rule result in benefits
greater than the costs of the rule to the
extent that those costs could be
quantified. In other words, based upon
existing available data, the proposed
rule is cost-beneficial when only the
benefits resulting from time savings are
considered.9
The same is true of Alternative 2. A
larger time savings benefit would result
from changing the BOP pressure testing
interval for workover and
decommissioning from 7 days to 14
days plus increasing the BOP pressure
testing interval for all operations
(including drilling, completions,
workovers, and decommissioning) from
14 days to 21 days. This alternative
would result in additional time savings
to industry by decreasing the number of
required tests per year for operators.
This time savings would result in
greater net benefits to operators.
We did not, however, include reduced
trip time to perform BOP testing in the
calculations of savings for Alternative
2.10 Drilling trip time depends on
factors such as well depth, hole size,
mud weight, the amount of open hole,
hole conditions, surge and swab
pressure, borehole deviation, bottom
hole assembly configuration, hoisting
capacity, type of rigs, and crew
efficiency. BSEE is not aware of any
analysis of offshore operations that
provides reasonable estimates of average
trip time that could be used for the
purpose of this calculation. In addition,
it is common practice in the GOM to
perform BOP tests earlier than the
required interval whenever operational
opportunities become available (i.e.,
whenever there is no drill pipe across
the BOPs due to the need to change drill
bits). This practice would reduce the
overall benefits from this alternative.
BSEE requests comments and data on
both of these issues to assist in the
assessment of the overall benefits of this
alternative.
The proposed rule also would reduce
the probability of oil spills, and the
9 Moreover, the analysis of Alternatives 1 and 2
did not consider potential benefits related to
extended equipment life and reduced well control
risks arising from fewer pressure tests and fewer
trips out of the hole.
10 Trip time refers to the time needed to stop
drilling or workover operations, remove or raise the
drill/work string from the well, and then lower the
string back to the bottom of the well to restart
operations. A trip is often made to change a dull
drill bit and/or to perform the pressure test or BOP
test. During some deep drilling situations, the trip
time may equal or exceed the on-bottom drilling
time.
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21539
provisions with the highest costs to
industry (such as real-time monitoring
of well operations and alternating BOP
control station function testing) will
have the largest impact on reducing the
risk of spills. If the proposed rule
reduces the risk of incidents, benefits
would result from the avoided costs
associated with oil spills related to
personal injuries, natural resource
damages, lost hydrocarbons, spill
containment and cleanup, and lost
recreational use and lost profits from
commercial fishing. The magnitude of
these benefits, however, is dependent
on the effectiveness of the proposed rule
in reducing the number of incidents,
which is uncertain.
To estimate the potential benefits of
the proposed rule associated with
reducing the risk of incidents, we
examined historical data from the BSEE
oil spill database, which contains
information for spills greater than 10
barrels of oil for the GOM and Pacific
regions. Based upon an analysis of the
BSEE oil spill database during the
period between 1964 and 2010, BSEE
identified 27 blowouts associated with
oil spills greater than 10 barrels 11 and
used this data within the economic
analysis (see the initial RIA for
details).12 Blowouts that resulted in
uncontrolled flow of gas, damage to a
rig, and/or harm to personnel (but not
oil spills over 10 barrels) are not
reflected in this analysis.13 Accordingly,
the benefits and the overall risk
reduction associated with this proposed
rule may be understated. The BSEE is
specifically soliciting comments on any
data and costs associated with any
blowout that did not result in an oils
spill greater than 10 barrels, and how to
include that information within the
economic analysis.
The actual reduction in the risk of oil
spills to be achieved by the proposed
rule cannot be determined. Although a
sensitivity analysis was conducted for
levels of risk reduction from 0 to 20
percent, our economic analysis used a 1
percent risk reduction because it
11 See https://www.bsee.gov/Inspection-andEnforcement/Accidents-and-Incidents/Spills/.
12 BSEE based the analysis on the historical oil
spill database for the period between 1964 and
2010, but recognizes that significant regulatory and
technological improvements have taken place since
1964. If BSEE limited the analysis to the period
1988 (when the Department’s offshore regulatory
program was comprehensively overhauled) through
2010, the potential benefits from this reduction of
risk would be substantially greater, due to the
impact of the Deepwater Horizon costs over such a
shorter time period.
13 Previous MMS studies indicate a total of 126
blowouts during drilling operations on the OCS
between 1971 and 2006. These blowouts resulted in
26 fatalities, 63 injuries, damage to facilities and
equipment, and the release of hydrocarbons.
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represents BSEE’s best expert judgment
of the lower bound of risk reduction that
could result from the proposed rule.14
We multiplied the annual number of
spilled barrels of oil (the total number
of barrels spilled in the incidents
divided by 46.945 years) by 1 percent to
estimate the expected annual reduction
in barrels of oil spilled associated with
the proposed rule.
We then multiplied the annual
reduction in spilled barrels of oil by the
social and private cost of a spilled barrel
of oil, which is estimated at $3,599 per
barrel. This estimate was derived from
the Bureau of Ocean Energy
Management (BOEM) ‘‘Economic
Analysis Methodology for the Five Year
OCS Oil and Gas Leasing Program for
2012–2017’’ (2012) (the BOEM Case
Study),15 and includes costs associated
with natural resource damages, the
value of lost hydrocarbons, and spill
cleanup and containment.16 We used a
natural resource damage cost of $642
per barrel and a cleanup and
containment cost of $2,857 per barrel as
estimated for the GOM in the BOEM
Case Study. Consistent with the BOEM
Case Study, we used a value of lost
hydrocarbons per barrel of $100. The
BSEE recognizes the uncertainty
associated with projecting the price of
oil during the 10-year period of analysis
and thus includes a sensitivity analysis
in the initial RIA for the price of oil.
In addition to the time savings and
risk reduction benefits, the proposed
rule has other benefits. Due to
difficulties in measuring and
monetizing these benefits, BSEE does
not offer a quantitative assessment of
them. The BSEE has used a conservative
approach in the valuation of an oil spill,
including only selected costs of such a
spill. For example, although the analysis
captures the environmental damage
associated with a spill, the analysis is
limited because it only considers the
environmental amenities that
researchers could identify and
monetize. Therefore, the resulting
benefits of avoiding a spill should be
considered as a lower-bound estimate of
the true benefit to society that results
from decreasing the risk of oil spills.
Exhibit 1 displays the net benefits of
the proposed rule under the assumption
that the reduction in the risk of
incidents is 1 percent. Although the
analysis presents these benefit estimates
based on our lower bound assumption
of potential risk reduction, there is
uncertainty around the level of risk
reduction the proposed rule would
actually achieve. Accordingly, it is
reasonably possible that the actual
benefits realized from the reductions in
spill incidents will be different from
those assessed in this analysis.
Nonetheless, as discussed above, the
proposed rule is cost-justified on the
basis of time savings alone.
EXHIBIT 1—NET BENEFITS
[At a 1-percent risk reduction from the proposed rule] 1
Total benefits
(alternative 1)
Year
Total benefits
(alternative 2)
Total costs
Net benefits
(alternative 1)
Net benefits
(alternative 2)
2012 dollars/year
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
.................................................
.................................................
.................................................
.................................................
.................................................
.................................................
.................................................
.................................................
.................................................
.................................................
$153,988,977
153,988,977
153,988,977
153,988,977
153,988,977
153,988,977
153,988,977
153,988,977
153,988,977
153,988,977
$528,988,977
528,988,977
528,988,977
528,988,977
528,988,977
528,988,977
528,988,977
528,988,977
528,988,977
528,988,977
$164,862,782
77,431,590
77,431,590
77,431,590
77,431,590
98,931,590
77,431,590
77,431,590
77,431,590
77,431,590
($10,873,805)
76,557,387
76,557,387
76,557,387
76,557,387
55,057,387
76,557,387
76,557,387
76,557,387
76,557,387
$364,126,195
451,557,387
451,557,387
451,557,387
451,557,387
430,057,387
451,557,387
451,557,387
451,557,387
451,557,387
Undiscounted 10-year total ....................
10-Year Total with 3% discounting ........
10-Year Total with 7% discounting ........
1,539,889,771
1,313,557,210
1,081,554,137
5,289,889,771
4,512,383,273
3,715,397,215
883,247,090
763,397,731
639,884,837
656,642,682
550,159,479
441,669,301
4,406,642,682
3,748,985,543
3,075,512,378
10-year Average ....................................
Annualized with 3% discounting ............
Annualized with 7% discounting ............
153,988,977
153,988,977
153,988,977
528,988,977
528,988,977
528,988,977
88,324,709
89,493,503
91,105,205
65,664,268
64,495,474
62,883,772
440,664,268
439,495,474
437,883,772
1
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
Totals may not add because of rounding.
4. Sensitivity Analysis
tkelley on DSK3SPTVN1PROD with PROPOSALS2
This section presents sensitivity
analysis of the potential benefits of the
proposed rule that could result from
varying the following factors:
14 Several recent studies have estimated the
probabilities of blowout failures under a wide range
of circumstances. See, e.g., ‘‘Blowout Preventer
(BOP) Failure Event and Maintenance, Inspection
and Test (MIT) Data,’’ American Bureau of Shipping
and ABSG Consulting, under BSEE contract
M11PC00027 (June 2013); ‘‘Deepwater Horizon
Blowout Preventer Failure Analysis: Report to the
U.S. Chemical Safety and Hazard Investigation
Board,’’ Engineering Services (2014). Given this
accumulated knowledge of failure likelihoods, and
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(a) The level of risk reduction of oil
spills achieved by the proposed rule;
(b) The level of risk reduction of
fatalities achieved by the proposed rule;
and
(c) The price of a barrel of oil (i.e., the
value of lost hydrocarbons).
Exhibit 2 presents the total 10-year
benefits and net benefits under a range
of possible annual risk reduction levels
for oil spills from 0 to 20 percent. The
analysis of how those likelihoods would be reduced
by the proposed rule, BSEE has determined that 1
percent is a reasonable lower-bound of risk
reduction that could occur as a result of the
proposed rule.
15 The BOEM Case Study presents seven separate
cost categories to estimate the impact of a
catastrophic spill, including natural resource
damages, as well as impacts on recreation and
commercial fishing. The BOEM Case Study is
available at: https://www.boem.gov/uploadedFiles/
BOEM/Oil_and_Gas_Energy_Program/Leasing/Five_
Year_Program/2012–2017_Five_Year_Program/
PFP%20EconMethodology.pdf.
16 The BOEM Case Study presents per-barrel costs
associated with a catastrophic event. We use this
estimate because the BOEM Case Study represents
a recent estimate for the costs associated with an
oil spill that reflects data from the Deepwater
Horizon incident.
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proposed rule is expected to have
positive net benefits for the full range of
risk reduction levels.
In addition to the time savings and
the prevention of oil spills, the
proposed rule is anticipated to reduce
the risk of fatalities to rig workers. The
oil and gas extraction industry is
characterized by a relatively small
percentage of the national workforce,
21541
but with a fatality rate that is higher
than the rate for most industries.
EXHIBIT 2—NET BENEFITS UNDER DIFFERENT RISK REDUCTION LEVELS 1
Annual risk
reduction (%)
Annual benefits
Benefits
(7% discounting)
Benefits
(3% discounting)
Net benefits
(undiscounted)
Net benefits
(7% discounting)
Net benefits
(3% discounting)
Total 10-Year
0 ...........................
1 ...........................
2 ...........................
3 ...........................
4 ...........................
5 ...........................
6 ...........................
7 ...........................
8 ...........................
9 ...........................
10 .........................
11 .........................
12 .........................
13 .........................
14 .........................
15 .........................
16 .........................
17 .........................
18 .........................
19 .........................
20 .........................
1
$0
3,988,977
7,977,954
11,966,931
15,955,909
19,944,886
23,933,863
27,922,840
31,911,817
35,900,794
39,889,771
43,878,749
47,867,726
51,856,703
55,845,680
59,834,657
63,823,634
67,812,611
71,801,589
75,790,566
79,779,543
$1,053,537,231
1,081,554,137
1,109,571,044
1,137,587,950
1,165,604,856
1,193,621,762
1,221,638,669
1,249,655,575
1,277,672,481
1,305,689,387
1,333,706,294
1,361,723,200
1,389,740,106
1,417,757,012
1,445,773,919
1,473,790,825
1,501,807,731
1,529,824,637
1,557,841,544
1,585,858,450
1,613,875,356
$1,279,530,426
1,313,557,210
1,347,583,994
1,381,610,778
1,415,637,562
1,449,664,346
1,483,691,131
1,517,717,915
1,551,744,699
1,585,771,483
1,619,798,267
1,653,825,051
1,687,851,836
1,721,878,620
1,755,905,404
1,789,932,188
1,823,958,972
1,857,985,756
1,892,012,541
1,926,039,325
1,960,066,109
$616,752,910
656,642,682
696,532,453
736,422,225
776,311,996
816,201,768
856,091,539
895,981,311
935,871,082
975,760,854
1,015,650,625
1,055,540,397
1,095,430,168
1,135,319,939
1,175,209,711
1,215,099,482
1,254,989,254
1,294,879,025
1,334,768,797
1,374,658,568
1,414,548,340
$413,652,394
441,669,301
469,686,207
497,703,113
525,720,019
553,736,926
581,753,832
609,770,738
637,787,644
665,804,551
693,821,457
721,838,363
749,855,269
777,872,176
805,889,082
833,905,988
861,922,894
889,939,801
917,956,707
945,973,613
973,990,519
$516,132,695
550,159,479
584,186,263
618,213,047
652,239,832
686,266,616
720,293,400
754,320,184
788,346,968
822,373,752
856,400,537
890,427,321
924,454,105
958,480,889
992,507,673
1,026,534,457
1,060,561,242
1,094,588,026
1,128,614,810
1,162,641,594
1,196,668,378
For Alternative 1, the proposed rule.
considered in addition to the benefits of
the rule included in the analysis
presented above (assuming a 1 percent
risk reduction in the probability of
incidents involving oil spills). The
benefits of occupational risk reduction
are usually measured using the value of
Exhibit 3 presents the resulting total
10-year fatality risk reduction benefit
across a range of risk reduction values
from 0 to 20 percent. The exhibit also
presents the undiscounted and
discounted 10-year total net benefits
when fatality risk reduction is
a statistical life (VSL). The BSEE used
a VSL of $8.4 million to estimate the
avoided costs associated with a
reduction in the fatality rate 17 (see
initial RIA for details of VSL
calculations).
EXHIBIT 3—MONETIZED BENEFITS FROM AVERTED FATALITIES W/NET BENEFITS 1
Fatality risk
reduction benefit
Fatality risk reduction
(%)
Undiscounted
Net benefits of
proposed rule
without fatality risk
reduction (at a 1percent risk
reduction)
Net benefits of proposed rule with fatality risk reduction
(at a 1-percent risk reduction)
Undiscounted
3% Discounting
7% Discounting
Undiscounted
tkelley on DSK3SPTVN1PROD with PROPOSALS2
Total 10-year
0
1
2
3
4
5
6
7
.............................................................
.............................................................
.............................................................
.............................................................
.............................................................
.............................................................
.............................................................
.............................................................
$0
269,142
538,285
807,427
1,076,569
1,345,712
1,614,854
1,883,996
17 Between 1964 and 2010, there were 27
blowouts with oil spills greater than 10 barrels.
Only two of these events resulted in fatalities: the
1984 blowout and the 2010 Deepwater Horizon
incident that resulted in 4 and 11 fatalities,
respectively. Based on the 47-year period from 1964
to 2010, the average number of fatalities was
approximately 0.320 annually (15/46.945). Using a
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Jkt 235001
$656,642,682
656,642,682
656,642,682
656,642,682
656,642,682
656,642,682
656,642,682
656,642,682
$656,642,682
656,911,824
657,180,967
657,450,109
657,719,251
657,988,393
658,257,536
658,526,678
VSL of $8,423,301, the average value of fatalities is
$2,691,423 per year (0.320 × $8,423,301). Therefore,
each 1 percent reduction in the risk of a fatality
results in a risk reduction benefit of $26,914 (1
percent × $2,691,423). Note that this calculation
likely understates the benefits associated with
fatality risk reduction because blowouts that did not
result in an oil spill greater than 10 barrels were not
PO 00000
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$550,159,479
550,389,063
550,618,647
550,848,231
551,077,814
551,307,398
551,536,982
551,766,566
$441,669,301
441,858,335
442,047,369
442,236,403
442,425,438
442,614,472
442,803,506
442,992,541
part of the database used for this analysis. Previous
MMS studies indicate a total of 126 blowouts
during drilling operations on the OCS between 1971
and 2006. These blowouts resulted in 26 fatalities,
63 injuries, damage to facilities and equipment, and
the release of hydrocarbons. Accounting for any
additional fatalities would increase the fatality risk
reduction benefits.
E:\FR\FM\17APP2.SGM
17APP2
21542
Federal Register / Vol. 80, No. 74 / Friday, April 17, 2015 / Proposed Rules
EXHIBIT 3—MONETIZED BENEFITS FROM AVERTED FATALITIES W/NET BENEFITS 1—Continued
Fatality risk
reduction benefit
Fatality risk reduction
(%)
Undiscounted
Net benefits of
proposed rule
without fatality risk
reduction (at a 1percent risk
reduction)
Net benefits of proposed rule with fatality risk reduction
(at a 1-percent risk reduction)
Undiscounted
3% Discounting
7% Discounting
Undiscounted
Total 10-year
8 .............................................................
9 .............................................................
10 ...........................................................
11 ...........................................................
12 ...........................................................
13 ...........................................................
14 ...........................................................
15 ...........................................................
16 ...........................................................
17 ...........................................................
18 ...........................................................
19 ...........................................................
20 ...........................................................
1 For
2,153,139
2,422,281
2,691,423
2,960,565
3,229,708
3,498,850
3,767,992
4,037,135
4,306,277
4,575,419
4,844,562
5,113,704
5,382,846
656,642,682
656,642,682
656,642,682
656,642,682
656,642,682
656,642,682
656,642,682
656,642,682
656,642,682
656,642,682
656,642,682
656,642,682
656,642,682
658,795,820
659,064,963
659,334,105
659,603,247
659,872,390
660,141,532
660,410,674
660,679,817
660,948,959
661,218,101
661,487,244
661,756,386
662,025,528
551,996,150
552,225,734
552,455,318
552,684,901
552,914,485
553,144,069
553,373,653
553,603,237
553,832,821
554,062,405
554,291,988
554,521,572
554,751,156
443,181,575
443,370,609
443,559,644
443,748,678
443,937,712
444,126,746
444,315,781
444,504,815
444,693,849
444,882,884
445,071,918
445,260,952
445,449,986
Alternative 1, the proposed rule.
As an additional sensitivity analysis,
we estimated the net benefits of the
proposed rule for different assumptions
regarding the value of lost
hydrocarbons. In the analysis presented
above, BSEE used $100 per barrel for the
value of lost hydrocarbons in the event
of a spill. To reflect the fluctuations in
the price of a barrel of oil that may
occur during the 10-year analysis
period, we also estimated the net
benefits of the proposed rule for two
alternative price scenarios: $50/barrel
and $130/barrel. Exhibit 4 presents the
results, which indicate that the price of
oil has a very limited impact on the net
benefits of the proposed rule.
EXHIBIT 4—NET BENEFITS UNDER THREE OIL PRICE SCENARIOS
[At a 1-percent risk reduction from the proposed rule]
Year
$50/barrel
$100/barrel
$130/barrel
(2012 dollars/year)
............................................................................................................
............................................................................................................
............................................................................................................
............................................................................................................
............................................................................................................
............................................................................................................
............................................................................................................
............................................................................................................
............................................................................................................
............................................................................................................
($10,928,596)
76,502,597
76,502,597
76,502,597
76,502,597
55,002,597
76,502,597
76,502,597
76,502,597
76,502,597
($10,873,805)
76,557,387
76,557,387
76,557,387
76,557,387
55,057,387
76,557,387
76,557,387
76,557,387
76,557,387
($10,840,931)
76,590,262
76,590,262
76,590,262
76,590,262
55,090,262
76,590,262
76,590,262
76,590,262
76,590,262
Undiscounted 10-year total ..................................................................................
10-Year Total with 3% discounting ......................................................................
10-Year Total with 7% discounting ......................................................................
656,094,777
549,692,105
441,284,475
656,642,682
550,159,479
441,669,301
656,971,425
550,439,903
441,900,196
10-year Average ..................................................................................................
Annualized with 3% discounting ..........................................................................
Annualized with 7% discounting ..........................................................................
tkelley on DSK3SPTVN1PROD with PROPOSALS2
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
65,609,478
64,440,684
62,828,982
65,664,268
64,495,474
62,883,772
65,697,142
64,528,349
62,916,646
BSEE has concluded, after
consideration of the impacts of the
proposed rule, that the societal benefits
would justify the societal costs.
E.O. 13563 reaffirms the principles of
E.O. 12866 while calling for
improvements in the Nation’s regulatory
system to promote predictability, to
reduce uncertainty, and to use the best,
most innovative, and least burdensome
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tools for achieving regulatory ends. The
E.O. directs agencies to consider
regulatory approaches that reduce
burdens and maintain flexibility and
freedom of choice for the public where
these approaches are relevant, feasible,
and consistent with regulatory
objectives. The E.O. 13563 emphasizes
further that regulations must be based
on the best available science and that
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the rulemaking process must allow for
public participation and an open
exchange of ideas. The BSEE engineers
and technical staff have and will
continue to work to ensure that this
proposed rulemaking is based on sound
engineering principles and considers
options identified through research,
coordination with standardsdevelopment organizations, and
E:\FR\FM\17APP2.SGM
17APP2
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Federal Register / Vol. 80, No. 74 / Friday, April 17, 2015 / Proposed Rules
interaction with the OCS industry.
Thus, we have developed this rule in a
manner consistent with these
requirements.
In addition, BSEE is considering
whether to use probabilistic risk
assessment methodology—including
event trees, statistical information (e.g.,
failure rates of valves), probabilities,
uncertainties, and assumptions—that
potentially could help inform BSEE’s
final decision on the proposed
regulation. Further details about a
potential probabilistic risk assessment
approach are provided in the initial
RIA. The BSEE is interested in the
public’s views on the potential
advantages and disadvantages to
development of a probabilistic risk
assessment model for this rulemaking.
We specifically seek comments on the
following issues:
(a) What would be the potential
advantages and disadvantages if BSEE
were to move to risk-informed decisions
in this proposed rule through the use of
methods such as probabilistic risk
assessments and event trees?
(b) Given that there are a significant
number of offshore drilling operations
with different types of rig construction
and drilling plans, if BSEE were to use
event trees in risk reduction
assessments, how much detail would
such event trees need so that they
would be representative of the affected
operators and best inform stakeholders
and decision makers? Commenters
should provide examples of benefits and
costs of any suggested level of detail and
explain why that detail would be
appropriate.
(c) Describe any completed, ongoing
or planned activities, not associated
with BSEE, that would provide
information beneficial to the potential
development of a probabilistic risk
assessment approach for this
rulemaking, including any analyses
identifying areas of significant risk or
uncertainties. If you do so, provide
timelines for the activity, if not already
completed; indicate whether the activity
will be peer-reviewed; and explain how
it could be used in the potential
development of a probabilistic risk
assessment approach.
(d) Describe any other planned or
ongoing data collection efforts that
could provide relevant information
useful in the potential development of
probabilistic risk assessment models for
offshore oil and gas activities. If there
are no such efforts at this time, how
could such a data collection program be
developed?
(e) What challenges and concerns
would there be to industry providing
data to inform and help BSEE decide
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whether to engage in probabilistic risk
assessment modeling for this proposed
rule? What are ways that the challenges
and concerns could be mitigated?
The BSEE is also requesting
comments on other ways to improve
this economic analysis. The BSEE is
specifically requesting comments on the
following issues:
(a) Which provisions of the proposed
rule are most, or least, likely to reduce
the risk of a well control incident?
(b) For each proposed rule provision:
(1) For what kinds of well control
incidents (e.g., hydrocarbon leakage
through annulus cement barrier,
weather-related incident, collision)
would the provision reduce risk?
(2) By what mechanism would the
provision reduce risk (e.g., reduction of
the rate of failure of a particular
technology)?
(c) What risk reduction level (or range
of risk reduction levels) would the
individual provisions achieve?
Please provide supporting data and
studies to support your comments.
Regulatory Flexibility Act
The DOI certifies that this proposed
rule is likely to have a significant
economic effect on a substantial number
of small entities as defined under the
Regulatory Flexibility Act, 5 U.S.C. 601
et seq. (RFA).
The RFA, at 5 U.S.C. 603, requires
agencies to prepare a regulatory
flexibility analysis to determine whether
a regulation would have a significant
economic impact on a substantial
number of small entities. Further, under
the Small Business Regulatory
Enforcement Fairness Act of 1996, 5
U.S.C. 801 (SBREFA), an agency is
required to produce compliance
guidance for small entities if the rule
would have a significant economic
impact. For the reasons explained in
this section, BSEE believes that this
proposed rule would likely have a
significant economic impact on a
substantial number of small entities
and, therefore, a regulatory flexibility
analysis is required by the RFA. This
Initial Regulatory Flexibility Analysis
assesses the impact of this proposed
rule on small entities, as defined by the
applicable Small Business
Administration (SBA) size standards.
1. Description of the Reasons That
Action by the Agency Is Being
Considered
The BSEE identified a need to amend
the existing well-control regulations to
improve the capability of the oil and gas
industry to ensure that oil and gas
operations on the OCS are safe and
protect the environment. In particular,
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21543
BSEE considers the proposed rule
necessary to reduce the likelihood of all
oil and gas blowouts, which can lead to
the loss of life, serious injuries, and
harm to the environment. As was
evidenced by the Deepwater Horizon
incident (which began with a blowout at
the Macondo well) on April 20, 2010,
blowouts can result in catastrophic
consequences. Government and
industry conducted multiple
investigations to determine the cause of
the Deepwater Horizon incident; many
of these investigations identified BOP
performance as a concern. The BSEE
convened Federal decision-makers and
stakeholders from the OCS industry,
academia, and other entities at a public
forum on offshore energy safety on May
22, 2012, to discuss ways to address this
concern. The investigations and the
forum resulted in a set of
recommendations to improve wellcontrol operations, including BOP
performance.
The BSEE determined that the wellcontrol regulations needed to be
updated to incorporate some of these
recommendations while others are being
studied for consideration in future
rulemakings. The proposed rule would
create a new Subpart G in 30 CFR part
250 to consolidate the requirements for
drilling, completion, workover, and
decommissioning operations.
Consolidating these requirements would
improve the efficiency and consistency
of the regulations and would allow for
flexibility in future rulemakings. The
proposed rule would also revise existing
provisions throughout Subparts A, B, D,
E, F, P, and Q of part 250 to address
concerns raised in the Deepwater
Horizon investigations. Finally, the
proposed rule would incorporate API
Standard 53 to ensure better BOP
performance and operability and more
robust regulatory oversight.
2. Description and Estimated Number of
Small Entities Regulated
Small entities, as defined by the RFA,
consist of small businesses, small
organizations, and small governmental
jurisdictions. We have not identified
any small organizations or small
government jurisdictions that the rule
will impact, so this analysis focuses on
impacts to small businesses (hereafter
referred to as ‘‘small entities’’). A small
entity is one that is independently
owned and operated and which is not
dominant in its field of operation.18 The
definition of small business varies from
industry to industry in order to properly
reflect industry size differences.
18 See
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5 U.S.C. 601.
17APP2
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tkelley on DSK3SPTVN1PROD with PROPOSALS2
The proposed rule would affect
operators and holders of Federal oil and
gas leases, as well as right-of-way
holders, in the OCS. This includes about
130 businesses with active operations.
Businesses that operate under this rule
fall under the SBA’s North American
Industry Classification System (NAICS)
codes 211111 (Crude Petroleum and
Natural Gas Extraction) and 213111
(Drilling Oil and Gas Wells). For these
NAICS classifications, a small business
is defined as one with fewer than 500
employees. Based on these criteria,
approximately 90 (69 percent) of the
businesses operating on the OCS are
considered small and the rest are
considered large businesses. The BSEE
considers that a rule has an impact on
a ‘‘substantial number of small entities’’
when the total number of small entities
impacted by the rule is equal to or
exceeds 10 percent of the relevant
universe of small entities in a given
industry. Therefore, BSEE expects that
the proposed rule would affect a
substantial number of small entities.
The BSEE is using the estimated 130
businesses based on activity at the time
this economic analysis was developed.
The 130 businesses represent the best
assessment of the total businesses
operating in this arena at the time the
economic analysis was developed. The
BSEE recognizes that this number is a
dynamic number and can fluctuate;
however, BSEE determined that this
number of businesses was appropriate
for this rulemaking. The BSEE is
requesting comments on the use of the
active business numbers, and other
ways to quantify the changing number
of businesses.
3. Description and Estimate of
Compliance Requirements
The BSEE has estimated the
incremental costs for small operators,
lease holders, and right-of-way holders
in the offshore oil and natural gas
production industry. Costs already
incurred as a result of current industry
practice in accordance with existing
regulations, industry permits, DWOPs,
and API industry standards with which
operators already comply were not
considered as costs of this rule because
they are part of the baseline.19 As
described in section 5 below, BSEE
considered three alternatives.
Alternative 2 results in a time-savings
benefit to industry but no additional
19 API standards are developed by industry
members and technical experts in open meetings
based on a consensus process. They contain the
baseline requirements that the industry has deemed
necessary to operate in a safe and reliable manner
and are often incorporated into commercial
contracts between contractors and operators.
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21:10 Apr 16, 2015
Jkt 235001
costs to industry, and thus the costs
presented below are the same for
Alternatives 1 and 2. We have estimated
the costs of the following provisions of
the rule:
—Additional information in the
description of well drilling design
criteria;
—Additional information in the drilling
prognosis;
—Prohibition of a liner as conductor
casing;
—Additional capping stack testing
requirements;
—Additional information in the APM
for installed packers;
—Additional information in the APM
for pulled and reinstalled packers;
—Rig movement reporting;
—Fitness requirements for MODUs and
lift boats;
—Foundation requirements for MODUs
and lift boats;
—Monitoring of well operations with a
subsea BOP;
—Additional documentation and
verification requirements for BOP
systems and system components;
—Additional information in the APD,
APM, or other submittal for BOP
systems and system components;
—Submission by the operator of a
Mechanical Integrity Assessment
Report completed by a BSEEapproved verification organization;
—New surface BOP system
requirements;
—New subsea BOP system
requirements;
—New surface accumulator system
requirements;
—Chart recorders;
—Notification and procedure
requirements for testing of surface
BOP systems;
—Alternating BOP control station
function testing;
—ROV intervention function testing;
—Autoshear, deadman, and EDS
function testing on subsea BOPs;
—Approval for well-control equipment
not covered in Subpart G;
—Breakdown and inspection of BOP
system and components;
—Additional recordkeeping for realtime monitoring; and
—Industry familiarization with the new
rule.
These requirements and their
associated costs to the OCS industry and
government are presented in the
sections below.20
(a) Additional information in the
description of well drilling design
criteria.
20 Sums presented in the sections below may not
equal the sums of the costs identified in this section
because of rounding.
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Section 250.413(g) of the proposed
rule would require information on the
ECD to be included in the description of
the well drilling design criteria. The
ECD is an important parameter in
avoiding fracturing the formation or
compromising the casing shoe integrity,
which could lead to erratic pressures
and uncontrolled flows (e.g., formation
kicks) emanating from a well reservoir
during drilling. This information is
necessary to better review the well
drilling design and drilling program.
The requirement to include information
on the ECD in the well drilling design
criteria would result in an average
annual labor cost to industry of $218 per
entity.21
(b) Additional information in the
drilling prognosis.
Section 250.414 of the proposed rule
would require the OCS industry to
provide additional information in the
drilling prognosis. New paragraph (j)
would require the drilling prognosis to
identify the type of wellhead system to
be installed with a descriptive
schematic, which should include
pressure ratings, dimensions, valves,
load shoulders, and locking mechanism,
if applicable. The requirement to
include additional information in the
drilling prognosis (submitted as part of
the APD) would result in an average
annual labor cost to industry of $54 per
entity.22
(c) Prohibition of a liner as conductor
casing.
Section 250.421(f) would be revised to
no longer allow a liner to be installed
as conductor casing. This would ensure
that the drive pipe would not be
exposed to wellbore pressures during
drilling in subsequent hole sections.
21 We assumed that industry staff (mid-level
engineer) would spend one hour per well to include
the additional information in the well drilling
design criteria. Industry already complies with this
new requirement as part of its design practice for
most wells drilled. To be conservative, however, we
assumed that this requirement would result in a
new cost for all wells drilled per year (320). We
multiplied the number of industry staff hours per
well by the average hourly compensation rate for a
mid-level industry engineer ($88.38) and by the
average number of wells drilled per year to obtain
an average annual labor cost to industry of $28,282
(1 × $88.38 × 320). We then divided the average
annual labor cost by the number of entities (130) to
obtain an average annual labor cost per entity of
$218 ($28,282 ÷ 130).
22 We assumed that industry staff (a mid-level
engineer) would spend 0.25 hours to include the
additional information in the drilling prognosis for
a well. We multiplied the number of industry staff
hours per well by the average hourly compensation
rate for a mid-level industry engineer ($88.38) and
the average number of wells drilled per year (320)
to obtain the average annual labor cost to industry
of $7,070 (0.25 × $88.38 × 320). We then divided
the average annual labor cost by the number of
entities (130) to obtain an average annual labor cost
per entity of $54 ($7,070 ÷ 130).
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This provision would result in an
average annual equipment and labor
cost to industry of $6,115 per entity.23
(d) Additional capping stack testing
requirements.
Proposed § 250.462 would address
source control and containment
requirements. New paragraph (e)(1)
would detail requirements for the
testing of capping stacks. New
requirements include the function
testing of all critical components on a
quarterly basis and the pressure testing
of pressure holding critical components
on a bi-annual basis. These new
requirements would help ensure that
operators are able to contain a subsea
blowout. These new testing
requirements would result in an average
annual equipment and service cost to
industry of $615 per entity.24
(e) Additional information in the
APM for installed packers.
Proposed paragraphs (e) and (f) in
§ 250.518 would clarify requirements for
installed packers and bridge plugs and
require additional information in the
APM, including descriptions and
calculations for determining production
packer setting depth. These new
requirements would codify existing
BSEE policy to ensure consistent
permitting. It is expected that operators
already comply with the design
specifications included in this section
because this is the only established
industry standard. Thus, the depth
setting calculation is the only
requirement that would impose a new
23 We estimated that approximately one percent
of drilled wells currently have a liner as conductor
casing (approximately one percent of 320 wells, or
three wells), based on input provided in submittals
to BSEE. To calculate the average annual equipment
cost, we assumed that the average cost of the casing
joints and wellhead per well would be $65,000. We
multiplied the equipment cost per well by the
number of affected wells to yield an average
equipment cost of $195,000 ($65,000 × 3). We
assumed that industry staff (rig crew) would spend
one day to install the new equipment on a well. We
then multiplied the number of industry staff days
per well by the average labor cost for a rig crew per
day ($200,000) and by the number of affected wells
to obtain an estimated average annual labor cost to
industry of $600,000 ($200,000 × 3) for this
requirement. Summing the equipment and labor
costs yields a total average annual cost to industry
of $795,000 for this requirement. We divided the
average annual equipment and labor cost by the
number of entities (130) to obtain an average annual
equipment and labor cost per entity of $6,115
($795,000 ÷ 130).
24 We assumed that the quarterly equipment and
service costs of testing for capping stacks would be
$5,000 per test. Additionally, we assumed that 4
capping stacks would be tested quarterly (or a total
of 16 annual tests performed). We multiplied the
costs per test by the number of annual tests in order
to determine a total annual equipment and service
cost to industry of $80,000 (16 × $5,000). We
divided the annual equipment and service cost to
industry by the number of entities (130) to obtain
an average annual equipment and service cost per
entity of $615 ($80,000 ÷ 130).
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cost beyond the current baseline. The
required calculations would be
submitted for every well that is
completed where tubing is installed.
The requirement to include additional
information in the APM would result in
an average annual labor cost to industry
of $44 per entity.25
(f) Additional information in the APM
for pulled and reinstalled packers.
In § 250.619, new paragraphs (e) and
(f) would clarify requirements for pulled
and reinstalled packers and bridge plugs
and would require additional
descriptions and calculations in the
APM regarding production packer
setting depth. These new requirements
would codify existing BSEE policy to
ensure consistent permitting. It is
expected that operators already comply
with the design specifications included
in this section because this is the only
established industry standard. The
depth setting calculation is the only
requirement that would impose a new
cost beyond the current baseline. The
required calculations would be
submitted for every well that is worked
over where tubing is pulled and then
reinstalled. The requirement to include
additional information in the APM
would result in an average annual labor
cost increase to industry of $172 per
entity.26
(g) Rig movement reporting.
Proposed § 250.712 would list the
requirements for reporting movement of
rig units to the BSEE District Manager.
Paragraph (a) would extend the rig
movement reporting requirements to all
rig units conducting operations covered
under this subpart, including MODUs,
platform rigs, snubbing units, wire-line
25 We assumed that industry staff (a mid-level
engineer) would spend 0.25 hours to include the
additional information in the APM for a well. We
assumed that APMs would be submitted for an
average of 260 wells with installed packers per year.
We multiplied the number of industry staff hours
per well by the average hourly compensation rate
for a mid-level industry engineer ($88.38) and by
the estimated number of wells with installed
packers for which an APM would be submitted per
year to estimate an average annual labor cost to
industry of $5,745 (0.25 × $88.38 × 260). We
divided the average annual labor cost by the
number of entities (130) to obtain an average annual
labor cost per entity of $44 ($5,745 ÷ 130).
26 We assumed that industry staff (a mid-level
engineer) would spend 0.25 hours to include the
additional information in the APM for a well. We
also assumed that APMs would be submitted for an
average of 1,010 wells with pulled and reinstalled
packers per year. We multiplied the number of
industry staff hours per well by the average hourly
compensation rate for a mid-level industry engineer
($88.38) and the estimated number of wells with
pulled and reinstalled packers for which an APM
would be submitted per year to obtain an average
annual labor cost to industry of $22,316 (0.25 ×
$88.38 × 1,010). We divided the average annual
labor cost by the number of entities (130) to obtain
an average annual labor cost per entity of $172
($22,316 ÷ 130).
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units used for non-routine operations,
and coiled tubing units. Paragraphs (c)
and (e) are new and would require
notification if a MODU or platform rig
is to be warm or cold stacked or if a
drilling rig would enter or leave the
OCS. Paragraph (f) would be revised to
clarify that, if the anticipated date for
initially moving on or off location were
to change by more than 24 hours, an
updated Rig Movement Notification
Report would be required.
Currently, rig movement reports are
only required for drilling operations, but
the proposed rule would require
operators to submit rig movement
reports for other operations as well,
including cases when rigs are stacked or
would enter or leave the OCS. These
changes would allow BSEE to better
anticipate upcoming operations, locate
MODUs and platform rigs in case of
emergency, and verify rig fitness. The
requirement to notify BSEE of rig unit
movement would result in an average
annual labor cost to industry of $19 per
entity.27
(h) Fitness requirements for MODUs
and lift boats.
Proposed § 250.713(a) would add a
requirement that operators provide
fitness information for a MODU or lift
boat for workovers, completions, and
decommissioning. Operators must
provide information and data to
demonstrate the drilling unit’s
capability to perform at the proposed
drilling location. This information must
include the most extreme environmental
and operational conditions that the unit
is designed to withstand, including the
minimum air gap necessary for both
hurricane and non-hurricane seasons. If
sufficient environmental information
and data are not available at the time the
APD is submitted, the BSEE District
Manager may approve the APD, but
would require operators to collect and
report this information during
operations. Under this circumstance, the
District Manager would have the right to
revoke the approval of the APD, if
information collected during operations
shows that the drilling unit is not
capable of performing at the proposed
location. This requirement would result
27 We assumed that industry staff (administrative)
would spend five minutes (0.08 hours) to submit a
movement report and that industry would submit
an average of 1,000 movement reports per year. We
multiplied the number of industry staff hours per
report by the average hourly compensation rate for
an administrative staff ($29.82) and the average
number of reports per year to obtain an average
annual labor cost to industry of $2,485 (0.0833 ×
$29.82 × 1,000). We divided the average annual
labor cost by the number of entities (130) to obtain
an average annual labor cost per entity of $19
($2,485 ÷ 130).
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in an average annual labor cost to
industry of $340 per entity.28
(i) Foundation requirements for
MODUs and lift boats.
Proposed § 250.713(b) would
introduce a requirement for foundation
requirements for workovers,
completions, and decommissioning.
Operators must provide information to
show that site-specific soil and
oceanographic conditions would be
capable of supporting the proposed rig
unit. If operators provide sufficient sitespecific information in the Exploration
Plan (EP), Development and Production
Plan (DPP), or Development Operations
Coordination Document (DOCD)
submitted to BOEM, operators may
reference that information. The District
Manager may require operators to
conduct additional surveys and soil
borings before approving the APD, if
additional information is needed to
make a determination that the
conditions would be capable of
supporting the rig unit or equipment
installed on a subsea wellhead. For
moored rigs, operators must submit a
plan of the rigs anchor pattern approved
in the EP, DPP, or DOCD in the APD or
APM. This requirement would result in
an average annual labor cost to industry
of $340 per entity.29
(j) Real-time monitoring of well
operations.
Proposed § 250.724 is a new section
that lists requirements for:
—Monitoring well operations on rigs
that have a subsea BOP, surface BOP
on a floating facility, and rigs
operating in HPHT reservoirs; and
—Storing data at a designated onshore
location, as listed in the APD or APM.
In order to comply with this section,
the OCS industry would incur annual
equipment and labor costs associated
28 We assumed that industry staff (a mid-level
engineer) would spend 0.5 hours per APM to
provide the additional information and that an
average of 1,000 APMs would be affected per year.
We multiplied the number of industry staff hours
per APM by the average hourly compensation rate
for a mid-level industry engineer ($88.38) and by
the estimated number of APMs affected per year to
obtain an average annual labor cost to industry of
$44,190 (0.5 × $88.38 × 1,000). We divided the
average annual labor cost by the number of entities
(130) to obtain an average annual labor cost per
entity of $340 ($44,190 ÷ 130).
29 We assumed that industry staff (a mid-level
engineer) would spend 0.5 hours per APM to
provide the additional information and that an
average of 1,000 APMs would be affected per year.
We multiplied the number of industry staff hours
per APM by the average hourly compensation rate
for a mid-level industry engineer ($88.38) and by
the estimated number of APMs affected per year to
obtain an average annual labor cost to industry of
$44,190 (0.5 × $88.38 × 1,000). We divided the
average annual labor cost by the number of entities
(130) to obtain an average annual labor cost per
entity of $340 ($44,190 ÷ 130).
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with gathering, transmitting, and storing
data. The costs associated with these
new data collection and storage
requirements would include an average
annual equipment and labor cost of
$311,538 per entity. The BSEE requests
feedback related to the costs of
compliance with monitoring of well
operations with a subsea BOP.30
(k) Additional documentation and
verification requirements for BOP
systems and system components.
Proposed § 250.730 would list general
requirements for BOP systems and
system components and additions to the
section would describe new
documentation and verification
requirements. Proposed § 250.731(c)
would require verification by a BSEEapproved verification organization of
specified aspects of equipment design,
equipment tests, shear tests, and
pressure integrity tests; and all
certification documentation must be
made available to BSEE. Proposed
§ 250.732(c) would require a
comprehensive review by a BSEEapproved verification organization of
BOP and related equipment being
proposed for use in HPHT service.
Proposed § 250.730(d) would require
that quality management systems for
BOP stacks be certified by an entity that
meets the requirements of ISO 17011.
Additionally, operators may submit a
request for approval of equipment
manufactured under quality assurance
programs other than API Spec. Q1. The
BSEE may approve such a request,
provided the operator submits relevant
information about the alternative
program. Costs associated with these
new documentation and certification
requirements would include an average
annual equipment and labor cost of
$13,706 per entity. The BSEE requests
feedback related to the costs of
compliance with these documentation
30 We assumed that the average costs per day and
the average operational days per year would be the
same for rigs with subsea BOPs and rigs operating
in HPHT reservoirs. Additionally, we assumed that
a rig operates for 270 days per year (three
operations per year and three months per operation)
and that the average cost per day to perform
continuous monitoring would be $5,000, including
equipment and labor. We estimated that half of the
rigs with subsea BOPs already conduct this
monitoring. Thus, only half of rigs with subsea
BOPs (20 rigs) would incur a new cost to comply
with these requirements. Similarly, we assumed
that 10 of the rigs operating in HPHT reservoirs
would incur a new cost to comply with these
requirements. We multiplied the time that the rig
is operational per year by the average cost per day
to perform monitoring and by the number of
affected rigs to obtain an average annual equipment
and labor cost to industry of $40.5 million (270 ×
$5,000 × 30). We divided the average annual
equipment and labor cost by the number of entities
(130) to obtain average an average annual
equipment and labor cost per entity of $311,538
($40,500,000 ÷ 130).
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and certification requirements for BOP
systems and system components.31
(l) Additional information in the APD,
APM, or other submittals for BOP
systems and system components.
Proposed § 250.731 would list the
descriptions of BOP systems and system
components that must be included in
the applicable APD, APM, or other
submittal for a well. Paragraph (a)
would require the submittal to include
descriptions of the rated capacities for
the fluid-gas separator system, control
fluid volumes, control system pressure
to achieve a seal of each ram BOP,
number of accumulator bottles and
bottle banks, and control fluid volume
calculations for the accumulator system.
Paragraph (b) would add schematic
drawing requirements, including
labeling for the control system alarms
and set points, control stations, and
riser cross section. New paragraph (e)
would require a listing of the functions
with sequences and timing of autoshear,
deadman, and EDS for subsea BOPs. For
subsea BOPs, surface BOPs on a floating
facility, and BOPs operating under
HPHT conditions, new paragraph (f)
would require submission of a
certification that a Mechanical Integrity
Assessment Report has been submitted
within the past 12 months. New
paragraph (c) would include a change in
required certifications. The paragraph
would require submission of
certifications from a BSEE approved
verification organization (rather than a
‘‘qualified third-party’’) that:
—Test data would demonstrate that the
shear ram(s) would shear the drill
31 For proposed § 250.731(c), we assumed that the
one-time equipment and service costs to industry
would be $40,000. We estimated that 320 wells
would incur a new cost to comply with these
requirements. We multiplied the one-time cost of
equipment and service by the number of affected
wells to obtain the total one-time equipment and
service cost to industry of $12,800,000 ($40,000 ×
320), resulting in an average annual cost of
$1,280,000 to industry. For § 250.732(c), we
assumed that the annual costs would be $50,000,
including equipment and service. We estimated that
10 wells would incur a new cost to comply with
these requirements. We multiplied the annual cost
of equipment and service by the number of affected
wells to obtain an average annual equipment and
service cost to industry of $500,000 ($50,000 × 10).
For § 250.730(d), we assumed that a mid-level
industry engineer would spend 2 hours to submit
a request. We multiplied the compensation rate for
a mid-level industry engineer ($88.38) by the
number of hours to complete the submission and
then multiplied this annual cost by the total
number of wells (10) to determine the annual cost
to industry of $1,768 (2 $88.38 × 10). The average
annual cost to industry associated with these
requirements is $1,781,768 ($1,280,000 + $500,000
+ $1,768). We divided this average annual
equipment and labor cost by the number of entities
(130) to obtain average an average annual
equipment and labor cost per entity of $13,706
($1,781,768 ÷ 130).
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pipe at the water depth (per proposed
§ 250.732(b)),
—The BOP would be designed, tested,
and maintained to perform at the most
extreme anticipated conditions; and
—The accumulator systems would have
sufficient fluid to function the BOP
system without assistance from the
charging system.
These proposed requirements would
be necessary to enhance BSEE’s review
of the BOP system and its emergency
systems, which were the topic of many
of the recommendations of the
Deepwater Horizon investigation
reports. These requirements would be
necessary to help BSEE verify that the
accumulator system would have
sufficient fluid to function the BOP
system without assistance from the
charging system. The proposed
requirements to provide additional
documentation about the BOP system
and system components in the APD,
APM, or other submittal would result in
an average annual labor cost to industry
of $218 per entity.32 The BSEE was
unable to locate any applicable data or
comparative cost estimates, and
therefore was unable to determine a
definitive cost estimate for the annual
costs to industry associated with the
change in the required independent
third-party verifications referenced in
new paragraph (a). The BSEE requests
feedback from the public and industry
on costs associated with the change in
the verification requirements.
(m) Submission of a Mechanical
Integrity Assessment Report by a BSEEapproved verification organization.
Proposed § 250.732(d) would include
new requirements on the submission of
a Mechanical Integrity Assessment
Report on the BOP stack and systems.
New paragraph (d) would outline the
requirements for this report, which must
be completed by a BSEE-approved
verification organization and submitted
by the operator for operations that
would require the use of a subsea BOP,
a surface BOP on a floating facility, or
a BOP that is being used in HPHT
operations. Proposed new § 250.731(f)
would require certification in the
applicable permit stating that this report
has been submitted within the past 12
months. The third-party reporting
32 We assumed that industry staff (a mid-level
engineer) would spend one hour to include
additional information in the APD, APM, or other
submittal for a well. We multiplied the number of
industry staff hours per well by the average hourly
compensation rate for a mid-level industry engineer
($88.38) and by the average number of wells drilled
per year (320) to obtain an average annual labor cost
to industry of $28,282 (1 × $88.38 × 320). We
divided the average annual labor cost by the
number of entities (130) to obtain an average annual
labor cost per entity of $218 ($28,282 ÷ 130).
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would enhance the BSEE review and
permitting process and would ensure
that BSEE is aware of repairs or other
changes to the operating BOPs. These
reporting requirements would result in
new costs to industry consisting of
capital and labor costs for creating
reports and submitting them to BSEE.
The analysis estimated an average
annual cost to industry of $37,032 per
entity.33
(n) New surface BOP requirements.
Proposed § 250.733 would include
new requirements for surface BOP
stacks. New paragraph (e) would require
that hydraulically operated locks are
installed with surface BOPs. The BSEE
was unable to locate any applicable data
or comparative cost estimates and
therefore was unable to determine a
definitive cost estimate for the labor and
equipment costs to industry associated
with the installation of hydraulically
operated locks. The BSEE requests
feedback related to the costs of
compliance with this new surface BOP
stack requirement.
(o) New subsea BOP system
requirements.
Proposed § 250.734 would include
new requirements for subsea BOP
systems, based on recommendations
from the Deepwater Horizon
investigations. Paragraph (a) would
require that BOPs be equipped with two
shear rams and would outline the
requirements for the shear rams. These
additions would assist in emergency
well-control planning. The BSEE
recognizes that the equipment and labor
costs associated with these new subsea
BOP system requirements would be
case-specific. For example, the costs
would depend on the age of the rig and
BOP system, the BOP system type, and
the size of the rig, among other factors.
The costs associated with the shear
ram requirements in paragraph (a)
would include an average one-time
compliance cost to industry of $384,615
per entity.34 The BSEE welcomes
33 For capital costs, we assumed an annual cost
of $15,000 for each well which results in an annual
capital cost of $4.8 million ($15,000 × 320). For
labor costs, we assumed that industry staff (a midlevel engineer) would spend a half hour to prepare
a report for each well. We multiplied the number
of industry staff hours per well by the average
hourly compensation rate for a mid-level industry
engineer ($88.38) and by the average number of
wells drilled per year (320) to obtain an average
annual labor cost to industry of $14,141 (0.5 ×
$88.38 × 320). The average annual labor and capital
cost to industry. associated with these requirements
is $4,814,141 ($4,800,000 + $14,141). We divided
the average annual labor and capital cost to
industry by the number of entities (130) to obtain
an average annual labor and capital cost per entity
of $37,032 ($4,814,141 ÷ 130).
34 API Standard 53 includes the requirements
under new paragraph (a) for all rigs with the
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feedback related to the costs of
compliance with these new technology
requirements.
(p) New surface accumulator system
requirements.
Proposed § 250.735(a) would list new
requirements for the surface
accumulator system of a BOP. The
surface accumulator system must
operate all BOP functions against MASP
with 200 psi above pre-charge without
use of the charging system. This
revision would ensure that the BOP
system would be capable of operating
all critical functions. The requirement
that the surface accumulator system
would operate all functions for all BOP
systems would result in a one-time
equipment and labor cost to industry of
$21,713 per entity.35
(q) Chart recorders.
Proposed § 250.737(c) would address
BOP testing and introduce a
requirement that each test must hold the
required pressure for five minutes while
using a four-hour chart. This would
allow the chart to detect a leak during
the test. This testing requirement would
result in a one-time equipment and
labor cost to industry of $1,388 per
entity.36
exception of moored rigs. We estimated that 5
moored rigs would be affected and that the one-time
capital compliance cost associated with these shear
ram requirements would be $10,000,000 per rig. To
calculate the total one-time capital costs to
industry, we multiplied the equipment cost per rig
by the number of affected rigs to yield a total cost
to industry of $50,000,000 ($10,000,000 × 5). We
divided the average one-time equipment and labor
cost by the number of entities (130) to obtain an
average one-time cost per entity of $384,615
($50,000,000 ÷ 130).
35 We assumed that the average cost of the
additional equipment needed to meet the
requirements would be $25,000 per rig. It is
unknown how many rigs already comply; thus, we
made a conservative assumption that all rigs would
be affected (90 rigs). We multiplied the equipment
cost per rig by the number of affected rigs to obtain
an estimated one-time equipment cost of $2.25
million ($25,000 × 90). For the one-time labor cost
to industry, it was estimated that one to three days
of industry time would be required per rig to install
the new equipment. To be conservative, we
assumed that industry staff (a mid-level engineer)
would spend 72 hours to install the new equipment
on a rig. We multiplied the number of industry staff
hours per rig by the average hourly compensation
rate for a mid-level industry engineer ($88.38) and
by the number of affected rigs to obtain an
estimated one-time labor cost to industry of
$572,702 (72 × $88.38 × 90). Summing the
equipment and labor costs resulted in a total onetime cost to industry of $2,822,708. We divided the
one-time equipment and labor cost by the number
of entities (130) to obtain a one-time equipment and
labor cost per entity of $21,713 ($2,822,708 ÷ 130).
36 We assumed that each rig would require a chart
recorder for an average cost of $2,000 per rig. We
multiplied the average equipment cost per rig by
the total number of rigs (90) to obtain an estimated
one-time equipment cost to industry of $180,000
($2,000 × 90). We assumed that industry staff (rig
crew) would spend five minutes (0.08 hours) per rig
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(r) Notification and procedure
requirements for testing of surface BOP
systems.
Proposed § 250.737(d)(2) would
expand notification and procedure
requirements regarding the use of water
to test a surface BOP system. This
notification and procedure requirement
would result in an average annual labor
cost to industry of $41 per entity.37
(s) Alternating BOP control station
function testing.
Proposed § 250.737(d)(5) would
expand the requirements for function
testing BOP control stations. It would
require that the operator designate the
BOP control stations as primary and
secondary and alternate function testing
of each station weekly. This testing
requirement would result in an average
operations cost to industry of $192,308
per entity.38 The BSEE requests
feedback related to the costs of
compliance with alternating BOP
control station function testing.
(t) ROV intervention function testing.
Proposed § 250.737(d)(12) would
include requirements for testing ROV
intervention functions to include testing
to install the equipment. We multiplied the number
of industry staff hours per rig by the average hourly
compensation rate for a rig crew staff ($56.80) and
by the total number of rigs to obtain an estimated
one-time labor cost to industry of $426 (0.0833 ×
$56.80 × 90). Summing the equipment and labor
costs resulted in a total one-time cost to industry
of $180,426. We divided the one-time equipment
and labor cost by the number of entities (130) to
obtain a one-time equipment and labor cost per
entity of $1,388 ($180,426 ÷ 130).
37 We assumed that a mid-level industry engineer
would spend 1 additional hour on a submittal as
a result of these expanded requirements. We
multiplied the compensation rate for a mid-level
industry engineer ($88.38) by the number of hours
to complete the submission and then multiplied
this annual cost by the total number of submittals
(60) to determine the annual cost to industry of
$5,303 (1 × $88.38 × 60). We divided the average
annual labor cost by the number of entities (130) to
obtain an average annual labor cost per entity of $41
($5,303 ÷ 130).
38 We assumed that testing would require 0.5 days
per rig per year (two hours every two weeks for
three months). Because subsea and surface BOPs
rigs have different daily rig operating costs, we
performed separate calculations for the costs for
subsea and surface BOP rigs. For subsea BOP rigs,
we multiplied the time required to conduct the
testing per rig by the average daily rig operating cost
for subsea BOP rigs ($1 million) and by the number
of subsea BOP rigs (40) for an average annual cost
of $20 million for subsea BOP rigs (0.5 × $1 million
× 40). For surface BOP rigs, we multiplied the time
required to conduct the testing per rig by the
average daily rig operating cost for surface BOP rigs
($200,000) and by the number of surface BOP rigs
(50) for an average annual cost of $5 million for
surface BOP rigs (0.5 × $200,000 × 50). Summing
the average annual costs for subsea BOP rigs and
surface BOP rigs resulted in an average annual
operations cost to industry associated with this
provision of $25 million. We divided the average
annual operations cost to industry by the number
of entities (130) to obtain an average annual
operations cost per entity of $192,308 ($25,000,000
÷ 130).
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and verifying the closure of all ROV
intervention functions on a subsea BOP.
The operator would have to test and
verify closure of the selected ram. This
testing requirement would result in an
average annual operations cost to
industry of $3,205 per entity.39
(u) Autoshear, deadman, and EDS
system function testing on subsea BOPs.
Proposed § 250.737(d)(13) would
expand the requirements for function
testing of autoshear, deadman, and EDSs
on subsea BOPs. It would require that
the test procedures submitted for BSEE
District Manager approval include a
schematic of the circuitry of the system,
the approved schematics of the BOP
control system, and a description of
how the ROV would be used during the
operation. It would also outline the
requirements for the deadman system
test, including a requirement that the
testing must indicate the discharge
pressure of the subsea accumulator
system throughout the test (per
proposed § 250.737(d)(13)). It would
require that the blind-shear rams be
tested to verify closure. The operator
must document the plan to verify
closure of the casing shear ram, if
installed, as well as all test results.
These documentation and testing
requirements would result in an average
one-time equipment cost to industry of
$769 per entity and an average annual
operations cost of $38,462 per entity.40
(v) Approval for well-control
equipment not covered in Subpart G.
Proposed § 250.738 would describe
the required actions for specified
situations involving BOP equipment or
39 We assumed that it would take five minutes per
well to conduct the testing and that 120 wells
would be affected (40 subsea BOP rigs with three
wells per rig). We multiplied the time diverted for
testing in a day 0.003472 (5 min ÷ 60 min ÷ 24
hours) by the daily operating cost per rig
($1,000,000) and by the estimated number of wells
affected per year to obtain an average annual
operations cost to industry of $416,667 (0.03 × 120
× $1,000,000). We divided the average annual
operations cost by the number of entities (130) to
obtain an average annual operations cost per entity
of $3,205 ($416,667 ÷ 130).
40 We assumed that the average cost of the sensing
device would be $2,500 per rig. We multiplied the
equipment cost by the total number of subsea BOP
rigs (40) to obtain the one-time equipment cost to
industry of $100,000 ($2,500 × 40). We divided the
equipment cost by the number of entities (130) to
obtain a one-time equipment cost per entity of $769
($100,000 ÷ 130). We assumed that it would take
one hour per well to perform the testing and
documentation tasks required by this provision, and
that each subsea BOP rig would be affected (40
subsea rigs). We multiplied the time diverted for
testing in a day 0.125 (1 hour ÷ 24 hours) by the
daily operating cost per rig ($1,000,000) and by the
estimated number of rigs affected per year to obtain
an average annual operations cost to industry of $5
million (0.125 × 40 × $1,000,000). We divided the
average annual operations cost by the number of
entities (130) to obtain an average annual operations
cost per entity of $38,462 ($5,000,000 ÷ 130).
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systems. Paragraphs (b), (i), and (o)
would include requirements for reports
from verification organizations. Reports
previously required to be prepared by a
‘‘qualified third-party’’ under these
sections would be required to be
prepared by a ‘‘BSEE-approved
verification organization.’’ Proposed
§ 250.738(m) would include a similar
change and introduce a requirement that
an operator request approval from the
BSEE District Manager to use wellcontrol equipment not covered in
Subpart G. The operator must submit a
report from a BSEE-approved
verification organization, as well as any
other information required by the
District Manager. This approval request
requirement would result in an average
annual labor cost to industry of
approximately $1 per entity.41 The
BSEE was unable to locate any
applicable data or comparative cost
estimates and therefore was unable to
determine a definitive cost estimate for
the annual costs to industry associated
with the third-party verification. The
BSEE welcomes feedback from the
public or industry on costs associated
with the third-party verification
requirements.
(w) Breakdown and inspection of the
BOP system and components.
Proposed § 250.739(b) would
introduce a requirement for a complete
breakdown and inspection of the BOP
and every associated component every 5
years. During this complete breakdown
and inspection, a BSEE-approved
verification organization must
document the inspection and any
problems encountered. This BSEEapproved verification organization’s
report must be available to BSEE upon
request. This additional requirement
would be necessary to ensure that the
components on the BOP stack are
regularly inspected. In the past, BSEE
has, in some cases, seen components of
BOP stacks go more than 10 years
without this type of inspection. This
inspection and documentation
requirement would result in an average
cost to industry to obtain third-party
reports of $165,385 per entity during the
year of inspection, which would occur
41 We assumed that industry staff (a mid-level
engineer) would spend 0.5 hours to submit an
equipment approval request and report. We also
assumed that industry would submit a request and
report for an average of two deepwater rigs per year.
We multiplied the number of industry staff hours
per submission by the average hourly compensation
rate for a mid-level industry engineer ($88.38) and
the average number of submissions per year to
obtain an average annual labor cost to industry of
$88 (0.5 × $88.38 × 2). We divided the average
annual labor cost by the number of entities (130) to
obtain an average annual labor cost per entity of $1
($88 ÷ 130).
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once every 5 years or twice during the
10-year analysis period.42 We assumed
that costs would be incurred in year 1
and year 6 of the 10-year analysis
period.
(x) Additional recordkeeping for realtime monitoring.
Proposed §§ 250.740(a) and
§ 250.741(b) would introduce
requirements for additional
recordkeeping of real-time monitoring
data for well operations. These
additional records would require an
average additional annual labor cost to
industry of $14 per entity.43
(y) Industry familiarization with new
regulations.
When the new regulation takes effect,
operators would need to read and
interpret the rule. Through this review,
operators would familiarize themselves
with the structure of the new rule and
identify any new provisions relevant to
their operations. Operators would
evaluate whether any new action must
be taken to achieve compliance with the
rule. Reviewing the new regulations
would require staff time, representing
an average one-time labor cost on
industry of $216 per entity.44
(z) Total Cost Burden for Small
Entities.
The BSEE’s calculations indicate that
the total cost burden of this proposed
rule would be $6,783,880 per affected
small entity over 10 years, which yields
an average annual cost of $678,388, as
presented in Exhibit 4. Four provisions
comprise approximately 85 percent of
the cost to small entities:
—Monitoring of well operations with a
subsea BOP;
—Alternating BOP control station
function testing;
—Autoshear, deadman, and EDS system
function testing on subsea BOPs; and
—New subsea BOP system
requirements.
Exhibit 5 displays estimates of costs
to small entities as a percentage of
revenues.45 In 8 of the 10 years in the
analysis period, the proposed rule
represents a cost of $595,628 per entity.
In the first year, costs would be higher
at $1,268,175 per entity as a result of the
one-time equipment and inspection
costs. In year 6, small entities would
incur the costs from BOP major
inspections, which would be performed
every 5 years.
The costs of the rule as a proportion
of small entity revenue range from 1.30
percent in most years to 2.78 percent in
the first year. The BSEE considers that
a rule has a ‘‘significant economic
impact’’ when the total annual cost
associated with the rule is equal to or
exceeds 1 percent of annual revenue.
Thus, the rule is expected to have a
significant economic impact on the
average participating small operators,
lease holders, and pipeline right-of-way
holders. Thus, BSEE concluded that this
proposed rule will have a significant
economic impact on a substantial
number of small entities.
EXHIBIT 4—PER ENTITY COST OF THE PROPOSED RULE BY PROVISION 1
Total 10 year cost
per entity
(undiscounted)
tkelley on DSK3SPTVN1PROD with PROPOSALS2
(a) Additional information in the description of well drilling design criteria ...............
(b) Additional information in the drilling prognosis ....................................................
(c) Prohibition of a liner as conductor casing ............................................................
(d) Additional capping stack testing requirements ....................................................
(e) Additional information in the APM for installed packers ......................................
(f) Additional information in the APM for pulled and reinstalled packers ..................
(g) Rig movement reporting .......................................................................................
(h) and (i) Information on MODUs, including lift boats .............................................
(j) Real-time monitoring of well operations ................................................................
(k) Additional documentation and certification requirements for BOP systems and
system components ...............................................................................................
(l) Additional information in the APD, APM, or other submittal for BOP systems
and system components ........................................................................................
(m) Submission of a Mechanical Integrity Assessment Report by a BSEE-approved verification organization .............................................................................
(n) New surface BOP requirements ..........................................................................
(o) New subsea BOP system requirements 2 ............................................................
(p) New surface accumulator system requirements ..................................................
(q) Chart recorders ....................................................................................................
(r) Use water to test surface BOP system ................................................................
42 For subsea BOP rigs, we assumed that
equipment and labor cost would be $350,000 per
rig. We multiplied the total number of subsea BOP
rigs (40) by the equipment and labor cost to obtain
an inspection-year cost of $14 million ($350,000 ×
40), which occurs every 5 years for subsea BOP rigs.
For surface BOP rigs, we assumed that equipment
and labor cost would be $150,000 per rig. We
multiplied the total number of surface BOP rigs (50)
by the equipment and labor cost to obtain an
inspection-year cost of $7.5 million ($150,000 × 50),
which occurs every 5 years for surface BOP rigs.
The sum of subsea and surface BOP costs are $21.5
million during the year of inspection. We divided
this total cost by the number of entities (130) to
obtain an average cost of inspection per entity of
$165,385 ($21,500,000 ÷ 130).
43 We assumed that industry staff (administrative
staff) would spend 0.5 hours to submit a report. We
multiplied the number of industry staff hours per
submission by the average hourly compensation
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Percent of total
cost
$2,176
544
61,154
6,154
442
1,717
191
6,799
3,115,385
$218
$54
6,115
615
44
172
19
680
311,538
0.03
0.01
0.90
0.09
0.01
0.03
0.00
0.10
45.92
137,059
13,706
2.02
2,176
218
0.03
370,319
37,032
Data not available; requesting comments
384,615
38,462
21,713
2,171
1,388
139
408
41
rate for administrative staff ($29.82) and then
multiplied this annual cost by the number of
affected wells (120, based on the assumption of
three wells per subsea BOP rig) to obtain an average
annual labor cost to industry of $1,789 (0.5 × $29.82
× 120). We divided the average annual labor cost
to industry by the number of entities (130) to obtain
an average annual labor cost per entity of $14
($1,789 ÷ 130).
44 We assumed that industry staff (a professional
engineer, supervisory) would spend two hours to
review the new regulation. The average hourly wage
rate for a professional engineer (supervisory) is
$76.00, based on BSEE’s Supporting Statement A
(BSEE Production Safety Systems). We multiplied
this wage rate by the private sector loaded wage
factor of 1.42 to account for employee benefits,
resulting in a loaded average hourly compensation
rate of $107.92. We assumed that an industry staff
would review the new regulation at each of the 130
field offices. We multiplied the number of hours per
PO 00000
Average annual
cost per entity
(undiscounted)
5.46
5.67
0.32
0.02
0.01
review by the average hourly compensation rate and
by the number of field offices, resulting in an
estimated one-time labor cost to industry of $28,059
(2 × $107.92 × 130). We divided the one-time labor
cost by the number of entities (130) to obtain an
average one-time labor cost of $216 ($28,059 ÷ 130).
45 The source for the estimated small business
revenue is the RIA for the BSEE Final Rulemaking
‘‘Increased Safety Measures for Energy
Development on the Outer Continental Shelf’’ (77
FR 50856; August 22, 2012). The data in the source
document is from the Office of Natural Resources
Revenue. The RIA can be viewed here: https://
www.regulations.gov/#!documentDetail;D=BSEE2012-0002-0047. The data source reports the total
2009 small company revenue to be $4,113,000,000.
We calculated the average revenue per small
business by dividing the total small business
revenue by the number of small businesses subject
to the rule ($4,113,000,000/90 operators) to obtain
an average of $45,700,000 per operator.
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EXHIBIT 4—PER ENTITY COST OF THE PROPOSED RULE BY PROVISION 1—Continued
Total 10 year cost
per entity
(undiscounted)
Average annual
cost per entity
(undiscounted)
Percent of total
cost
(s)Alternating BOP control station function testing ...................................................
(t) ROV intervention function testing .........................................................................
(u) Autoshear, deadman, and EDS system function testing on subsea BOPs ........
(v) Approval for well-control equipment not covered in Subpart G ...........................
(w) Breakdown and inspection of BOP system and components .............................
(x) Record-keeping for real-time monitoring ..............................................................
(y) Industry familiarization with the new rule .............................................................
1,923,077
32,051
385,385
7
330,769
138
216
192,308
3,205
38,538
1
33,077
14
22
28.35
0.47
5.68
0.00
4.88
0.00
0.00
Total ....................................................................................................................
6,783,880
678,388
100.00
1
Totals may not add because of rounding.
This is a lower-bound estimate of the costs of this provision; BSEE seeks comment on costs that we were unable to estimate (see section 4
above for details).
2
EXHIBIT 5—ANNUAL COST AND REVENUE PER ENTITY
Year
2016–2019 (each
year the same)
2015
Annual Industry Cost Stream for Proposed Rule a .................
Total Entities b .........................................................................
Average Annual Cost per Entity c = a ÷ b ..............................
Average Annual Revenue for Small Entities 1 d ......................
Cost from Proposed Rule as a Percentage of Annual Revenue e = c ÷ d ......................................................................
2021–2024 (each
year the same)
2020
$164,728,509
130
1,268,175
45,700,000
$77,297,317
130
595,628
45,700,000
$98,797,317
130
761,012
45,700,000
$77,297,317
130
595,628
45,700,000
2.78%
1.30%
1.67%
1.30%
1 The source for this estimate is the RIA for the BSEE Final Rulemaking ‘‘Increased Safety Measures for Energy Development on the Outer
Continental Shelf’’ (77 CFR 50856; August 22, 2012). The data in the source document is from the Office of Natural Resource Revenue. The
RIA can be viewed here: https://www.regulations.gov/#!documentDetail;D=BSEE-2012-0002-0047. The data source reports the total 2009 small
company revenue to be $4,113,000,000. We calculated the average revenue per small business by dividing the total small business revenue by
the number of small businesses subject to the rule ($4,113,000,000/90) to obtain an average of $45,700,000 per operator.
4. Identification of All Relevant Federal
Rules That May Duplicate, Overlap, or
Conflict With the Proposed Rule
The proposed rule does not conflict
with any relevant federal rules or
duplicate or overlap with any Federal
rules in any way that would
unnecessarily add cumulative
regulatory burdens on small entities
without any gain in regulatory benefits.
However, BSEE requests comments
identifying any federal rules that may
duplicate, overlap, or conflict with the
proposed rule.
5. Description of Significant
Alternatives to the Proposed Rule
BSEE has considered three
alternatives:
BSEE has considered three regulatory
alternatives:
(1) Promulgate the requirements
contained within the proposed rule,
including increasing the BOP testing
frequency for workover and
decommissioning operations from
current 7 day to proposed 14 day testing
frequency. The following chart
identifies the BOP testing changes
related to Alternative 1:
BOP PRESSURE TESTING
Current testing
frequency
Operation
Drilling/Completions .....................................................................................................................................
Workover/Decommissioning ........................................................................................................................
(2) Promulgate the requirements
contained within the proposed rule with
a change to the required frequency of
BOP pressure testing from the existing
regulatory requirements (e.g., 7 or 14
days depending upon the type of
operation) to 21 days for all operations.
The following chart identifies the BOP
14 days
7 days
Proposed testing
frequency
14 days
14 days
testing changes related to Alternative 2;
or
tkelley on DSK3SPTVN1PROD with PROPOSALS2
BOP PRESSURE TESTING
Current testing
frequency
Operation
Drilling/Completions ...................................................................................................
Workover/Decommissioning ......................................................................................
Proposed testing
frequency (Alternative 1)
14 days
7 days
14 days
14 days
* includes change from current 7 days to proposed 14 days
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Alternative 2 testing frequency
21 days
21 days*
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Federal Register / Vol. 80, No. 74 / Friday, April 17, 2015 / Proposed Rules
(3) Take no regulatory action and
continue to rely on existing BOP
regulations in combination with permit
conditions, Deep Water Operations
Plans (DWOPs), operator prudence, and
industry standards.
Alternative 2 results in a time-savings
benefit to industry but no additional
costs to industry, and thus the costs are
the same for Alternatives 1 and 2. By
taking no regulatory action in
Alternative 3, BSEE would leave
unaddressed most of the concerns and
recommendations that were raised
regarding the safety of offshore oil and
gas operations and the potential for
another event with consequences
similar to those of the Deepwater
Horizon incident.46
Alternative 2 was not selected
because BSEE is lacking critical data on
testing frequency and equipment
reliability. This issue may be considered
in the final rulemaking if BSEE receives
sufficient data to support Alternative 2.
The BSEE has elected to move
forward with Alternative 1, the
proposed rule, which would address
recommendations provided by
government, industry, academia, and
other stakeholders as well as
incorporate API Standard 53. In
addition to addressing concerns and
aligning with industry standards, BSEE
is functioning in a prudent capacity
with this proposed rule by advancing
several of the more critical capabilities
beyond current industry standards. The
proposed rule would also improve
efficiency and consistency of the
regulations and allow for flexibility in
future rulemakings.
The operating risk for small
companies to incur safety or
environmental accidents is not
necessarily lower than it is for larger
companies. Offshore operations are
highly technical and can be hazardous.
Adverse consequences in the event of
incidents are similar regardless of the
operator’s size. The proposed rule
would reduce risk for entities of all
sizes. Nonetheless, BSEE is requesting
comment on the time it would take to
comply with the proposed rule and the
costs of these proposed policies on
small entities, with the goal of ensuring
thorough consideration and discussion
at the final rule stage. The BSEE
specifically requests comments on the
burden estimates discussed above as
well as information on regulatory
alternatives that would reduce the
burden on small entities (e.g., different
compliance requirements for small
entities, alternative testing requirements
46 See
sources listed in n. 6.
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and periods, and exemption from
regulatory requirements).
Small Business Regulatory Enforcement
Fairness Act
The proposed rule is a major rule
under the Small Business Regulatory
Enforcement Fairness Act, 5 U.S.C. 801
et seq. This proposed rule:
(1) Would have an annual effect on
the economy of $100 million or more.
(2) Would cause a major increase in
costs or prices for consumers,
individual industries, Federal, State, or
local government agencies, or
geographic regions.
(3) Would not have significant
adverse effects on competition,
employment, investment, productivity,
innovation, or the ability of U.S.-based
enterprises to compete with foreignbased enterprises.
The requirements would apply to all
entities operating on the OCS regardless
of company designation as a small
business. For more information on costs
affecting small businesses, see the RFA
discussion.
Unfunded Mandates Reform Act of 1995
This proposed rule would not impose
an unfunded mandate on State, local, or
tribal governments or the private sector
of more than $100 million per year. The
proposed rule would not have a
significant or unique effect on State,
local, or tribal governments or the
private sector. A statement containing
the information required by the
Unfunded Mandates Reform Act, 2
U.S.C. 1501 et seq., is not required.
Takings Implication Assessment (E.O.
12630)
Under the criteria in E.O. 12630, this
proposed rule does not have significant
takings implications. The proposed rule
is not a governmental action capable of
interference with constitutionally
protected property rights. A Takings
Implication Assessment is not required.
Federalism (E.O. 13132)
Under the criteria in E.O. 13132, this
proposed rule does not have federalism
implications. This proposed rule would
not substantially and directly affect the
relationship between the Federal and
State governments. To the extent that
State and local governments have a role
in OCS activities, this proposed rule
would not affect that role. A federalism
assessment is not required.
Civil Justice Reform (E.O. 12988)
This rule complies with the
requirements of E.O. 12988.
Specifically, this rule:
(1) Meets the criteria of section 3(a)
requiring that all regulations be
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21551
reviewed to eliminate errors and
ambiguity and be written to minimize
litigation; and
(2) Meets the criteria of section 3(b)(2)
requiring that all regulations be written
in clear language and contain clear legal
standards.
Consultation With Indian Tribes (E.O.
13175)
Under the criteria in E.O. 13175, we
have evaluated this proposed rule and
determined that it has no substantial
direct effects on federally recognized
Indian tribes. The BSEE is committed to
regular and meaningful consultation
and collaboration with tribes on policy
decisions that have tribal implications.
The BSEE will consult with any tribe
that requests consultation about this
proposed rule.
Paperwork Reduction Act (PRA) of 1995
This proposed rule contains
collections of information that will be
submitted to OMB for review and
approval under the PRA, 44 U.S.C. 3501
et seq. As part of its continuing effort to
reduce paperwork and burdens on
respondents, BSEE invites the public
and other Federal agencies to comment
on any aspect of the reporting and
recordkeeping burden. If you wish to
comment on the information collection
(IC) aspects of this proposed rule, you
may send your comments directly to
OMB and send a copy of your comments
to the Regulations and Standards
Branch (see the ADDRESSES section of
this proposed rule). Please reference 30
CFR part 250, subpart G, Blowout
Preventer Systems and Well Control,
1014–NEW, in your comments. To see a
copy of the information collection
request submitted to OMB, go to
https://www.reginfo.gov (select
Information Collection Review,
Currently Under Review); or you may
obtain a copy of the supporting
statement for the new collection of
information by contacting the Bureau’s
Information Collection Clearance Officer
at (703) 787–1607.
The PRA provides that an agency may
not conduct or sponsor, and a person is
not required to respond to, a collection
of information unless it displays a
currently valid OMB control number.
The OMB is required to make a decision
concerning the collection of information
contained in these proposed regulations
30–60 days after publication of this
document in the Federal Register.
Therefore, a comment to OMB is best
assured of being fully considered if
OMB receives it by May 18, 2015. This
does not affect the deadline for the
public to comment to BSEE on the
proposed regulations.
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The title of the collection of
information for this rule is 30 CFR 250,
Subpart G, Blowout Preventer Systems
and Well Control (Proposed
Rulemaking). The proposed regulations
concern BOP system requirements,
maintaining well control among others,
and the information is used in BSEE’s
efforts to regulate oil and gas operations
on the OCS to protect life and the
environment, conserve natural
resources, and prevent waste.
Potential respondents comprise
Federal OCS oil, gas, and sulphur
operators and lessees. Responses to this
collection of information are mandatory,
or are required to obtain or retain a
benefit; they are also submitted on
occasion, daily and weekly (during
drilling operations), monthly, quarterly,
biennially, and as a result of situations
encountered depending upon the
requirement. The IC does not include
questions of a sensitive nature. The
BSEE will protect proprietary
information according to the Freedom of
Information Act (5 U.S.C. 552) and DOI
implementing regulations (43 CFR 2), 30
CFR part 252, OCS Oil and Gas
Information Program, and 30 CFR
250.197, Data and information to be
made available to the public or for
limited inspection.
This proposed rule affects Subpart A
(1014–0022, expiration 8/31/2017);
Subpart B (1014–0024, expiration 12/
31/2015); Applications for Permits to
Drill (1014–0025, expiration 4/30/17);
Applications for Permits to Modify
(1014–0026, expiration 5/31/17);
Subpart D (1014–0018, expiration 10/
31/17); Subpart E, (1014–0004,
expiration 12/31/16); Subpart F, (1014–
0001, expiration 12/31/16); Subpart P,
(1014–0006, expiration 12/31/16); and
Subpart Q, (1014–0010, expiration 10/
31/16).
This rule would also codify NTL
2013–G01, Global Positioning Systems
(GPS) for Mobile Offshore Drilling Units
(MODUs) (1014–0013, expiration 1/31/
2016).
This rule proposes to create new 30
CFR part 250, subpart G, Well
Operations and Equipment, which will
combine common requirements from
the various other subparts mentioned, as
well as add new requirements. The
following explanations apply to this
section: in the burden table, the OMB
currently approved hour and/non-hour
cost burdens for requirements will be
identified with an asterisk (*); italics
show revision(s) of existing
requirements; and brackets indicate new
requirements.
A vast majority of this proposed rule
contains IC burdens OMB has already
approved (174,686 burden hours* and
$102,500 non-hour cost burdens*). We
are revising some existing requirements
(+ 5,052 burden hours); and adding
[new] regulatory requirements (+
[11,701 burden hours]) for a total of
191,439 burden hours.
The following is a brief explanation of
how the proposed regulatory changes
affect the various subpart and form
burdens:
• Subpart A—transferred the
currently approved burden hours from
Subpart D for BOPs pertaining to
alternative procedures and departures
(12,300 hours*).
• Subpart B—revised the requirement
by adding information to be submitted
with DWOPs pertaining to free standing
hybrid risers (FSHR) (9,000 hours*; + 48
hours).
• APD—added NEW burden hours
pertaining to requirements including,
but not limited to, ECD information,
current monitoring, changes to casing,
etc. (47,800 hours* + [1,122 hours]).
Because the responses remained
unchanged, we did not list the non-hour
costs burdens associated with APDs
since the dollar amount will not change.
• APM—added NEW burden hours
pertaining to requirements including,
but not limited to, descriptions/
calculations of production packer
setting depth, annulus monitoring plan
information, etc. (11,321 hours* +
[1,929 hours]). Because the responses
remained unchanged, we did not list the
non-hour costs burdens associated with
APMs since the dollar amount will not
change.
• Subpart D—
(1) relocated common well operation
and equipment requirements (10,811
hours*).
(2) revised requirements for
additional information relating to safe
drilling margins, well head descriptions,
casing or line centralization during
cementing, submitting any changes to
approved plans, permits, or submittal (+
4,859 hours).
(3) added NEW burden hours
pertaining to requirements relating to,
but not limited to, cementing, source
control and containment capabilities,
etc., (+ [1,923 hours]).
• Subpart G—
(1) relocated burden hours from OMB
currently approved requirements in D,
E, F, P, and Q, that pertain to rig
requirements, well operations, BOP
system requirements, etc., as well as the
hour and non-hour cost burden from
GPS for MODUs (NTL 2013–G01)
(83,454 hours* and $102,500 non-hour
cost burden*).
(2) revised requirements that were
relocated from other subparts in 30 CFR
250 for additional information that may
be needed for properly functioning
acoustic systems, EDS, rating pressure,
etc., and requirements needing approval
by the District Manager (+ [145 hours]).
(3) added NEW requirements
pertaining to, but not limited to, warm
or cold stacking for MODUs, dropped
objects plan, real-time monitoring,
pressure tests, etc., (+ [6,727 hours]).
• Subparts P and Q have only cross
references to new Subpart G or current
Subpart D and have no new associated
burdens.
Once this rule becomes effective,
BSEE will use the approved OMB
control number for the Subpart G
information collection. The affected
remaining subparts discussed in this
rule will have their information
collection burdens adjusted accordingly
through the renewal process.
tkelley on DSK3SPTVN1PROD with PROPOSALS2
BURDEN TABLE
[Current regulations are regular font with an asterisk (*); Italic font show revision(s) of existing requirements; and bracketed text indicates new
requirements]
30 CFR 250 Current
Revision NEW
Reporting and recordkeeping requirement+
(BSEE-Approved Verification Organization =
BAVO)
Hour burden
Average number of
annual responses
Annual burden hours
(rounded)
Subpart A
[107] ...........................
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Burden covered under various 30 CFR 250
regulations (depending on the operational requirement(s)).
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21553
Federal Register / Vol. 80, No. 74 / Friday, April 17, 2015 / Proposed Rules
BURDEN TABLE—Continued
[Current regulations are regular font with an asterisk (*); Italic font show revision(s) of existing requirements; and bracketed text indicates new
requirements]
30 CFR 250 Current
Revision NEW
Reporting and recordkeeping requirement+
(BSEE-Approved Verification Organization =
BAVO)
141; 198; [701;
720(a)(2);
730(d)(1)]; 1612.
Hour burden
Average number of
annual responses
Annual burden hours
(rounded)
Request approval to use new or alternative
procedures, along with supporting documentation if applicable, including BAST not
specifically covered elsewhere in regulatory requirements.
20 ...............................
496 requests ..............
9,920 *
142; 198; 702 .............
Request approval of departure from operating requirements not specifically covered
elsewhere in regulatory requirements,
along with supporting documentation if applicable.
2.5 ..............................
952 requests ..............
2,380 *
Subtotal (A) .........
.........................................................................
....................................
1,448 responses ........
12,300 hours *
12 plans .....................
9,000 *
48
12 responses
....................................
9,000 hours *
48 hours
9,048 hours
Subpart B
287; 291; 292(p) ........
Subtotal (B) .........
Submit DWOP and accompanying/supporting
information. [Provide detailed information/
descriptions pertaining to pipeline free
standing hybrid riser (FSHR)]. Submit documentation for pipeline FSHR certification
and have verified by CVA.
.........................................................................
750 .............................
4 .................................
....................................
Applications for Permit to Drill (APD)
tkelley on DSK3SPTVN1PROD with PROPOSALS2
410–418; [420(a)(7)];
423(c)(1); [428(b),
(k)]; plus various
references in Subparts A, D, E, F, [G
(701; 702; 713(a),
(b), (e), (g); 720(b);
721(g)(4); 724(b);
731; 733(b);734(b),
(c); 737(a)(3),
(b)(2), (b)(3), (d)(2),
(d)(3), (d)(4),
(d)(12), (d)(13);
738(m), (n)]; H; and
P.
Apply for permit to drill APD (Form BSEE–
0123) that includes any/all supporting documentation/evidence (including, but not
limited to, test results, calculations, pressure
integrity,
kill
weight
fluids,
verifications, certifications, procedures, criteria, qualifications, diverter descriptions;
[ECD information]; rig anchor pattern plats;
contingency plan (move off info/[current
monitoring]); description of your BOP and
its components and schematic drawings;
[descriptive schematic (pressure ratings,
dimensions, valves, load shoulders, height
above water line etc.); location of ruptured
disks; description of mudline level to displace cement; how the operator will visually monitor returns; PE certification
showing approval of changes to casing
setting depths; description of source control and containment capabilities; EDS; annulus monitoring plan information; any additional information required by District
Manager]; etc.) and requests for various
approvals required in Subpart D (including
§§ 250.418(g); 427, 428, 432, 460, 490(c))
and submitted via the form; upon request,
make available to BSEE.
114.98 ........................
2.75 ............................
408 applications .........
....................................
46,912 *
1,122
[420(b)(4)]; 428;
465(a)(1);
[721(g)(4); 731;
733(f); 734(b), (c)].
Obtain approval to revise your drilling plan
[changes to the casing], or change major
drilling equipment by submitting a revised
Form BSEE–0123, Application for Permit
to Drill; [include BAVO certification; any
other information required by the District
Manager (on a case-by-case basis)].
1.34 ............................
662 submittals ............
888 *
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17APP2
21554
Federal Register / Vol. 80, No. 74 / Friday, April 17, 2015 / Proposed Rules
BURDEN TABLE—Continued
[Current regulations are regular font with an asterisk (*); Italic font show revision(s) of existing requirements; and bracketed text indicates new
requirements]
30 CFR 250 Current
Revision NEW
Reporting and recordkeeping requirement+
(BSEE-Approved Verification Organization =
BAVO)
Hour burden
Average number of
annual responses
Subtotal (APD) ....
.........................................................................
....................................
....................................
1,070 responses
Annual burden hours
(rounded)
47,800 hours*
[1,122 hours]
48,922 hours
Application for Permit to Modify (APM)
460; 465; plus various
ref in A, D, E 518(f);
F, 619(f); [G, 701;
702; 713(a), (b), (e),
(g); 720(b);
721(g)(4); 724(b);
731; 733(b), (f),
734(b)(1); 737(d)(2),
(d)(3), (d)(4),
(d)(12), (d)(13);
738(m), (n)],; H; P;
and Q 1704(g).
Provide revised plans and the additional supporting information required by the cited
regulations [test results; calculations;
verifications; certifications, procedures;
[descriptions/calculations of production
packer setting depth]; rig anchor pattern
plats; contingency plan (move off info/[current monitoring]); description of your BOP,
its components and schematic drawings;
[annulus monitoring plan information]; criteria; qualifications; etc.] when you submit
an Application for Permit to Modify (APM)
(Form BSEE–0124) to BSEE for approval.
3.377 ..........................
[40 min] ......................
2,893 applications
9,770 *
[1,929]
Subparts D, E, F, H,
P, Q.
Submit Revised APM plans (BSEE–0124).
(This burden represents only the filling out
of the form).
1 .................................
1,551 applications ......
1,551*
.........................................................................
....................................
....................................
11,321 hours *
[1,929 hours]
13,250 hours
Subtotal (APM) ...
4,444 responses
Subpart D
420(b)(3); 465(a)
(b)(3); plus various
ref in A, D, E, F, [G,
721(g)(8); 744]; P;
Q (1704([h]));.
Submit form BSEE–0125 (End-of-Operations
Report (EOR)) and all additional supporting information as required by the cited
regulations; and any additional information
required by the District Manager.
2 .................................
1 .................................
239 submittals
478 *
239
421(b) .........................
Alaska only: Discuss the cement fill level
with the District Manager.
Document all your test results and make
them available to BSEE upon request.
In the GOM OCS Region, submit drilling activity reports weekly (District Manager may
require more frequent submittals on a
case-by-case basis) on Forms BSEE–
0133 (Well Activity Report (WAR)) and
BSEE–0133S (Bore Hole Data) with supporting documentation.
In the Pacific and Alaska Regions during
drilling operations, submit daily drilling reports on Forms BSEE–0133 (Well Activity
Report (WAR)) and BSEE–0133S (Bore
Hole Data) with supporting documentation.
Submit all remedial actions for review and
approval by District Manager (before taking action); and any other requirements of
the District Manager.
Submit descriptions of completed immediate
actions to District Manager (if taken to ensure safety of crew/prevent well-control
event); and any other requirements of the
District Manager.
Submit PE certification of any proposed
changes to your well program; and any
other requirements of the District Manager.
NEW: Maintain daily drilling report (cementing requirements).
1 .................................
1 discussion ...............
1*
0.5 ..............................
300 results .................
150 *
1 .................................
4,160 submittals .........
4,160*
1 .................................
14 wells × 365 days ×
20% year = 1,022.
1,022 *
5 .................................
1,000 submittals .........
5,000 *
5 .................................
564 submittals ............
2,820
4 .................................
450 submittals ............
1,800
[0.5] ............................
[75 reports] .................
[38]
423(c)(2) ....................
428(c)(3); [428(k);
743(a), (c); 746(e)];
plus various references in Subparts
A, D, [G].
428(c)(3); [428(k);
743(b), (c)] plus various references in
Subparts A, D, [G].
428(d) .........................
tkelley on DSK3SPTVN1PROD with PROPOSALS2
428(d) .........................
428(d) .........................
[428(k)] .......................
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Federal Register / Vol. 80, No. 74 / Friday, April 17, 2015 / Proposed Rules
BURDEN TABLE—Continued
[Current regulations are regular font with an asterisk (*); Italic font show revision(s) of existing requirements; and bracketed text indicates new
requirements]
30 CFR 250 Current
Revision NEW
Reporting and recordkeeping requirement+
(BSEE-Approved Verification Organization =
BAVO)
[428(k)] .......................
NEW: If cement returns are not observed,
contact the District Manager to obtain approval before continuing with operations.
NEW: Submit a description of source control
and containment capabilities to the Regional Supervisor for approval.
NEW: Request re-evaluation of your source
containment capabilities from the District
Manager and Regional Supervisor..
NEW: Notify BSEE at least 21 days prior to
pressure testing; needs to be witnessed by
BSEE and a BAVO.
[462(c)] .......................
[462(d)] .......................
[462(e)(1)] ..................
Subtotal (D) ........
.........................................................................
Hour burden
Average number of
annual responses
Annual burden hours
(rounded)
[1] ...............................
[10 requests] ..............
[10]
[8] ...............................
[150 submittals] ..........
[1,200]
[1] ...............................
[600 requests] ............
[600]
[0.5] ............................
[150 notifications] .......
[75]
....................................
6,722 responses ........
1,014 responses ........
[985 responses] .........
8,721 responses ........
10,811 hours*.
4,859 hours
[1,923 hours]
17,593 hours
Subpart E
518(f) ..........................
Include in your APM descriptions and calculations of production packer setting
depth(s).
Burden covered under 1014–0026
0
Burden covered under 1014–0026
0
Subpart F
619(f) ..........................
Include in your APM descriptions and calculations of production packer setting
depth(s).
Subpart G
General Requirements
[701; 720(a);
730(d)(1)]
[(250.141)].
[702] [(250.142)] ........
Request alternative procedures or equipment
from District Manager; along with any supporting documentation/information required.
Request departures from District Manager;
include justification; and submit supporting
documentation if applicable.
Burden cover under 1014–0022
0
Burden cover under 1014–0022
0
Rig Requirements
[710(a)] .......................
[710(b); 738(p)] ..........
tkelley on DSK3SPTVN1PROD with PROPOSALS2
[711(b), (c)] ................
[712(a), (b), (f)] ..........
VerDate Sep<11>2014
Instruct crew members in safety requirements of operations—record dates and
times of meetings, include potential hazards; make available to BSEE.
Prepare a well-control drill plan for each well,
including but not limited to procedures,
[EDS], crew assignments, established
times to complete assignments, etc. Keep/
post a copy of the plan on the rig at all
times; post on rig floor/bulletin board.
Record in the daily report: time, date, and
type of drill conducted; time to close diverter or BOP; total time for entire drill.
The BSEE may require you to conduct a
well-control drill during an inspection.
Notify BSEE of all rig movements on or off
locations.
Rig movements reported on Rig Movement
Notification Report (Form BSEE–0144). Including MODUs, platform rigs; snubbing
units, lift boats, wire-line units, and coiled
tubing units 72 hours prior to movement; if
the initial date changes by more than 24
hours, submit updated BSEE–0144.
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0.75 ............................
7,512 meetings ..........
5,634 *
0.5 ..............................
308 plans ...................
154 *
1 .................................
8,320 drills .................
8,320 *
0.1 ..............................
20 notices ..................
2*
0.2 ..............................
151 submittals ............
30 *
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21556
Federal Register / Vol. 80, No. 74 / Friday, April 17, 2015 / Proposed Rules
BURDEN TABLE—Continued
[Current regulations are regular font with an asterisk (*); Italic font show revision(s) of existing requirements; and bracketed text indicates new
requirements]
30 CFR 250 Current
Revision NEW
Reporting and recordkeeping requirement+
(BSEE-Approved Verification Organization =
BAVO)
[712(c), (e)] ................
NEW: Notify District Manager if MODU or
platform rig is to be warm or cold stacked
on Form BSEE–0144; notify District Manager where the rig is coming from when
entering OCS waters.
NEW: Prior to resuming operations, report to
District Manager any construction repairs
or modifications that were made to the
MODU or rig.
[712(d)] .......................
Hour burden
Average number of
annual responses
[0.5] ............................
[25 notifications] .........
[13]
[2] ...............................
[10 responses] ...........
[20]
[713] ...........................
Submit MODU or lift boat information if being
used for well operations with your APD/
APM.
[713(a), (b)] ................
Collect and report additional information on a
case-by-case basis if sufficient information
is not available.
[713(b)] .......................
Reference to Exploration Plan, Development
and Production Plan, and Development
Operations Coordination Document (30
CFR 550, Subpart B).
Submit 3rd party review of drilling unit according to 30 CFR 250, Subpart I.
Burden covered under 1010–0151
0
Burden covered under 1014–0011
0
[713(c)(2); (417(c)(2))]
Have a Contingency Plan that addresses design and operating limitations of MODU or
lift boat.
Burden covered under 1014–0025
0
[713(d) (417(d))] .........
Submit current certificate of inspection/compliance from USCG and classification; submit documentation of operational limitations by a classification societ.
Burden covered under 1014–0025
0
[714] ...........................
NEW: Develop and implement dropped objects plan with supporting documentation/
information; any additional information required by the District Manager; make
available to BSEE upon request.
[40] .............................
[40 plans] ...................
[715] NTL ...................
GPS for MODUs ............................................
0.25 ............................
1 rig.
1—Notify BSEE with tracking/locator data
access and supporting information; notify
BSEE Hurricane Response Team as soon
as operator is aware a rig has moved off
location.
....................................
1 notification
[713(c)(1)] ..................
Burden covered under 1014–0025 for APD;
and 1014–0026 for APM
Annual burden hours
(rounded)
5 .................................
30 reports ...................
0
150 *
[1,600]
1*
20 devices per year for replacement and/or new × $325.00 = $6,500 *
3—Pay monthly tracking fee for GPS devices already placed on MODUs/rig..
40 rigs × $50/month = ($600/year per 1 rig) = $24,000 *
4—Rent GPS devices and pay monthly
tracking fee per rig.
tkelley on DSK3SPTVN1PROD with PROPOSALS2
2–Install and protect tracking/locator devices—(these are replacement GPS devices or new rigs).
40 rigs @$1,800 per year = $72,000 *
16,313 responses ......
[105 responses] .........
16,418 responses ......
Subtotal (G—Rig
Req.).
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14,141 hours *
[1,783 hours]
15,924 hours
$102,500 Non-hour cost burdens *
17APP2
21557
Federal Register / Vol. 80, No. 74 / Friday, April 17, 2015 / Proposed Rules
BURDEN TABLE—Continued
[Current regulations are regular font with an asterisk (*); Italic font show revision(s) of existing requirements; and bracketed text indicates new
requirements]
30 CFR 250 Current
Revision NEW
Reporting and recordkeeping requirement+
(BSEE-Approved Verification Organization =
BAVO)
Hour burden
Average number of
annual responses
Annual burden hours
(rounded)
Well Operations
[720(a)] .......................
NEW: Notify and obtain approval from the
District Manager when interrupting operations before getting off the well.
[720(a)(2)] ..................
Request approval to use alternate procedures/barriers.
Burden covered under 1014–0022
0
[720(b)] .......................
Submit with your APD or APM reasons for
displacing kill-weight fluid with detailed
step-by-step written procedures how to
displace the fluids, shear pipe procedures,
etc.
Burden covered under 1014–0025 for APD;
and 1014–0026 for APM
0
[721(d), (f), (g)] ..........
Submit to the District Manager for approval
plans to re-cement, repair, or run additional casing/liner for proper seal, along
with PE certification of proposed plans.
The District Manager may require you to
perform additional pressure tests.
[721(g)(4)] ..................
Submit test procedures and criteria for a
successful test with APD/APM; if changes
made to procedures, submit changes with
revised APD or APM.
[721(g)(5)] ..................
Document all your test results and make
them available to BSEE upon request.
Contact the appropriate BSEE District Manager immediately if you have any indication of a failed negative pressure test; submit a description of the corrective action
taken; and receive approval from the appropriate BSEE District Manager for the
retest.
[721(g)(6)] ..................
[721(g)(8); 744(a)] ......
Submit Form BSEE–0125, EOR ....................
[722] ...........................
Caliper, pressure test, or evaluate casing;
submit evaluation results report including
calculations; obtain approval before repairing or installing additional casing [(including PE Certification.)]; or resuming operations (every 30 days during prolonged
drilling).
[ Perform a pressure test after repairs made/
casing installed and report results.
Request exceptions prior to moving rig(s) or
related equipment.
NEW: Immediately transmit real-time monitoring data onshore during operations or in
HPHT reservoirs; store and monitor by
qualified personnel.
[722(b)(3)] ..................
[723(d)] .......................
[724] ...........................
tkelley on DSK3SPTVN1PROD with PROPOSALS2
[724(b)] .......................
NEW: List designated location where realtime data will be stored and monitored in
your APD or APM; make location and data
accessible to BSEE upon request.
[5] ...............................
0.5 ..............................
00:02 Apr 17, 2015
88 requests ................
Burden covered under 1014–0025 for APD;
and 1014–0026 for APM.
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44 *
0
1,340 results ..............
1,005 *
1 .................................
14 notifications ...........
14 *
Burden covered under 1014–0018
0
3 .................................
247 reports .................
741 *
[1] ...............................
[300 results] ...............
[300]
1.5 ..............................
845 requests ..............
1,268 *
[12] .............................
[50 submittals] ............
[600]
Burden covered under 1014–0025 for APD;
and 1014–0026 for APM
2,534 responses ........
[500 responses] .........
3,034 responses ........
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0.75 ............................
Subtotal (G—Well
Op.).
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[150 notifications] .......
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0
3,072 hours *
[1,650 hours]
4,722 hours
21558
Federal Register / Vol. 80, No. 74 / Friday, April 17, 2015 / Proposed Rules
BURDEN TABLE—Continued
[Current regulations are regular font with an asterisk (*); Italic font show revision(s) of existing requirements; and bracketed text indicates new
requirements]
30 CFR 250 Current
Revision NEW
Reporting and recordkeeping requirement+
(BSEE-Approved Verification Organization =
BAVO)
Hour burden
Average number of
annual responses
Annual burden hours
(rounded)
BOP System Requirements
[730; 731; 732] ...........
Submit BOP descriptions with your applicable APD or APM; third-party verification
and supporting information/documentation.
[730(a)(4)] ..................
NEW: Maintain current set of approved schematic drawings on the rig and an onshore
location; obtain District Manager approval
to resume operations if any modifications
or changes are made.
NEW: Provide written report to manufacturer
within 30 days of identifying equipment
failure.
NEW: Initiate investigation and analysis within 60 days to determine cause of equipment failure; provide the manufacturer a
copy of analysis report.
NEW: Report the design change/modified
procedures in writing to BSEE, OORP;
within 30 days of manufacturer’s notification.
NEW: Request for alternate to API Spec. Q1
to BSEE, OORP.
[730(c)(1)] ..................
[730(c)(2)] ..................
[730(c)(3)] ..................
[730(d)(2)] ..................
[731] ...........................
Resubmit BOP system component documentation in your APD or APM when information changes or moved off location from
well.
[732(a)] .......................
NEW: Submit all relevant information to
nominate a verification organization for
BSEE approval.
NEW: Submit BAVO verification and all supporting documentation related to this section (such as, but not limited to sharing
testing, pressure integrity testing, calculations, etc.).
NEW: Submit verifications showing the
BAVO conducted a comprehensive review
of the BOP and related equipment for
HPHT wells as listed in this section; submit verifications to the District Manager
and Regional Supervisor before beginning
operations in an HPHT environment.
NEW: Submit Mechanical Integrity Assessment Report (completed by a BAVO) to
BSEE, OORP; report must include all requirements listed in this section; make all
documentation available to BSEE upon request.
[732(b)] .......................
[732(c)] .......................
[732(d), (e)] ................
Burden covered under 1014–0025 for APD;
and 1014–0026 for APM
0
[24] .............................
[10 requests] ..............
[240]
[2] ...............................
[30 reports] .................
[60]
[5] ...............................
[30 reports] .................
[150]
[5] ...............................
[2 reports] ...................
[10]
[5] ...............................
[1 response] ...............
[5]
Burden covered under 1014–0025 for APD;
and 1014–0026 for APM.
0
[5] ...............................
[5 submittals] ..............
[25]
[10] .............................
[150 Verifications] ......
[1,500]
[10] .............................
[10 wells] ....................
[100]
[10] .............................
[90 reports] .................
[900]
NEW: Describe in your APD or APM your
annulus monitoring plan.
[734(a)(7)] ..................
tkelley on DSK3SPTVN1PROD with PROPOSALS2
[733(b)(2)] ..................
Demonstrate that any acoustic control system will function properly in proposed environment and conditions; submit any additional information requested.
5 .................................
1 .................................
1 validation .................
10 submittals ..............
5*
10
[734(a)(9); 738(n)] ......
Label all functions on all panels ....................
1.5 ..............................
33 panels ...................
50 *
[734(a)(10)] ................
Develop written procedures for operating the
BOP stack and LMRP and minimum
knowledge requirements for personnel authorized to operate and maintain BOP
components.
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Burden covered under 1014–0018
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0
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Federal Register / Vol. 80, No. 74 / Friday, April 17, 2015 / Proposed Rules
BURDEN TABLE—Continued
[Current regulations are regular font with an asterisk (*); Italic font show revision(s) of existing requirements; and bracketed text indicates new
requirements]
30 CFR 250 Current
Revision NEW
Reporting and recordkeeping requirement+
(BSEE-Approved Verification Organization =
BAVO)
[734(b), (c)] ................
Submit a revised APD/APM with BAVO [documenting repairs; before drilling out surface casing]; perform a new BOP test
upon relatch, etc.; receive approval from
the District Manager.
Burden covered under 1014–0025 for APD;
and 1014–0026 for APM
0
[737(a)(3), (a)(4);
(b)(2), (b)(3); (d)(2)(4), (d)(12), (d)(13)].
In your APD: submit stump, initial, or pressure tests; and subsea BOP procedures
and supporting relevant data/information;
indicate which casing string and liner met
the criteria of this section; quick disconnect procedures with your deadman
test procedures, etc. Obtain District Manager approval of appropriate test pressures; may require more frequent testing
on your BOP; or if you test annular BOP
less than 70 percent.
Burden covered under 1014–0025
0
[737(c); 746(a), (b),
(c), (d)].
Record the time, date, and results of all
pressure tests, actuations, and inspections
of the BOP system, system components,
and marine riser in the daily report; onsite
representative certify and sign/date reports, etc.; document sequential order of
BOP, closing times, auxiliary testing, pressure, and duration of each test.
7.75 ............................
4,457 results ..............
34,542 *
[737(d)(2), (d)(3),
(d)(4) (d)(12);].
Notify District Manager at least 72 hours
prior to pressure stump/initial tests on
seafloor; if BSEE rep unable to witness
test, provide results to BSEE within 72
hours after completion; document all ROV
intervention function test results; make
available to BSEE upon request.
0.25 ............................
5.5 ..............................
186 notifications .........
1,239 results ..............
47 *
6,815 *
[737(d)(13)] ................
Document all autoshear, EDS, and deadman
on your subsea BOP systems function test
results; make available to BSEE upon request.
0.5 ..............................
1 .................................
2,520 submittals .........
120 responses ...........
1,260 *
120
[737(e)] .......................
Provide 72 hour advance notice of location
of shearing ram tests or inspections; allow
BSEE access to witness testing, inspections, and information verification.
NEW/Revised: Requires District Manager
Approval:
(a), (d); 746(e) Report problems, issues,
leaks;.
(b) Put well in a safe condition; .....................
(b) Prior to resuming operations for new/repaired/reconfigured BOP.
(g) Your well control places demands above
its rating pressure;
(j) Two barriers in place prior to BOP removal.
NEW: Submit a report/verification from
BAVO that BOP is fit for service if have to
repair, replace, or reconfigure a BOP.
NEW: Notify the District Manager of BOP
configuration changes.
NEW: Demonstrate your well-control procedures will not place demands above its
rated working pressure.
NEW: Contact District Manager for approval
prior to latching up the BOP stack or reestablishing power.
0.25 ............................
136 notices ................
34 *
[0.5] ............................
[25 requests] ..............
[13]
[1] ...............................
[25 requests] ..............
[25]
[1] ...............................
0.25 ............................
[25 requests] ..............
200 requests ..............
[25]
50 *
1 .................................
15 requests ................
15
[1] ...............................
[1 request] ..................
[1]
[0.5] ............................
[50 submittals] ............
[25]
[0.5] ............................
[15 submittals] ............
[8]
[1] ...............................
[15 submittals] ............
[15]
[1] ...............................
[2 requests] ................
[2]
[738; 746(e)] ..............
tkelley on DSK3SPTVN1PROD with PROPOSALS2
[738(b), (i)] .................
[738(f)] ........................
[738(g)] .......................
[738(k)] .......................
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Federal Register / Vol. 80, No. 74 / Friday, April 17, 2015 / Proposed Rules
BURDEN TABLE—Continued
[Current regulations are regular font with an asterisk (*); Italic font show revision(s) of existing requirements; and bracketed text indicates new
requirements]
30 CFR 250 Current
Revision NEW
Reporting and recordkeeping requirement+
(BSEE-Approved Verification Organization =
BAVO)
[738(m)] ......................
NEW: Request approval in your APD or
APM to utilize any other well-control equipment.
[738(m)] ......................
NEW: Request approval from District Manager to utilize any other well-control equipment; include report from BAVO on the
equipment design and suitability; any other
documentation/information required by District Manager.
[738(n)] .......................
NEW: Include in your APD or APM which
pipe/variable bore rams meet the criteria.
[738(o)] .......................
NEW: Submit report to the District Manager
prepared by BAVO describing failure of redundant control and confirming no impact
to the BOP that makes it unfit for well control purposes; receive approval to continue
operations; submit any additional information requested by the District Manager.
Document BOP maintenance and inspection
procedures used; record results of BOP inspections and maintenance actions; maintain BOP records for 2 years or longer if
directed on the rig; maintain design, maintenance, inspection, and repair records for
the life of the equipment; make available
to BSEE upon request.
NEW: Assemble a detailed report compiled
by a BAVO documenting the once every
5-year inspection, including any problems
and corrections; make available to BSEE
upon request.
[739] ...........................
[739(b)] .......................
Subtotal (G—
BOP SR).
.........................................................................
Hour burden
Average number of
annual responses
Burden covered under 1014–0025 for APD;
and 1014–0026 for APM
[2] ...............................
[10 requests] ..............
Burden covered under 1014–0025 for APD;
and 1014–0026 for APM
Annual burden hours
(rounded)
0
[20]
0
[1] ...............................
[15 submittals] ............
[15]
9.75 ............................
350 records ................
3,413 *
[5] ...............................
[21 reports] .................
[105]
....................................
9,122 responses ........
145 responses ...........
[532 responses] .........
9,799 responses ........
46,216 hours *
145 hours
[3,244 hours]
49,605 hours
Records and Reporting Requirement
Maintain a daily report and accurate records
for each well onsite during operation [such
items in the daily report include, but are
not limited to, [date, time, type of drill], test
results, actuations, inspection of the BOP
system, system component, signoff approvals, etc.]; and any information required
by the District Manager.
25 min ........................
[1] ...............................
312 reports .................
[25 responses] ...........
130 *
[25]
[740; 741] ...................
tkelley on DSK3SPTVN1PROD with PROPOSALS2
[740; 711(b); 738(c);
745; 746].
Retain drilling records for 90 days after drilling is complete; retain casing/liner pressure, diverter, BOP tests [and real-time
data monitoring] for 2 years; retain well
completion/well workover until well is permanently plugged/abandoned or lease is
assigned; the records must contain appropriate information and any other information required by the District Manager.
2.15 ............................
[1] ...............................
3,460 records .............
[25 responses] ...........
7,439 *
[25]
[742] NTL ...................
Record and submit well logs and surveys run
in the wellbore and/or charts of well logging operations.
3 .................................
281 logs/surveys ........
843 *
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Federal Register / Vol. 80, No. 74 / Friday, April 17, 2015 / Proposed Rules
BURDEN TABLE—Continued
[Current regulations are regular font with an asterisk (*); Italic font show revision(s) of existing requirements; and bracketed text indicates new
requirements]
30 CFR 250 Current
Revision NEW
Reporting and recordkeeping requirement+
(BSEE-Approved Verification Organization =
BAVO)
Record and submit directional and verticalwell surveys..
Record and submit velocity profiles and surveys..
Record and submit core analyses. ................
Hour burden
Average number of
annual responses
Annual burden hours
(rounded)
1 .................................
281 reports .................
281 *
1 .................................
55 reports ...................
55 *
1 .................................
150 analyses ..............
150 *
[743(a), (c)] ................
In the GOM OCS Region, submit Well Activity Reports (WARs) weekly (District Manager may require more frequent submittals
on case-by-case basis) on BSEE–0133
and BSEE–0133S (Open Hole Data Report) with supporting information described
in this section; any additional information
required by the District Manager.
Burden covered under 1014–0018
0
[743(b), (c)] ................
In the Pacific and Alaska OCS Regions during operations, submit WARs daily
(BSEE–0133 and BSEE–0133S); with supporting information described in this section; any additional information required by
the District Manager.
Burden covered under 1014–0018
0
[744] ...........................
Submit form BSEE–0125, EOR .....................
Burden covered under 1014–0018
0
[745]; NTL ..................
Submit copies of well records; paleontological interpretations; service company reports; and other reports or records of operations to BSEE as requested.
Record the time, date, and results of all casing and liner presser tests.
Retain all records pertaining to tests, actuations, and inspections at the facility; retain all the records listed in this section for
a period of 2 years at the facility, at the
lessee’s field office nearest the OCS facility, or at another location conveniently
available to BSEE; make all the records
available to BSEE upon request.
[746] ...........................
[746(f)] ........................
Subtotal (G—Rec.
& Rpt. Req.).
.........................................................................
1.5 ..............................
308 submissions ........
462 *
2 .................................
4,160 results ..............
8,320 *
1.5 ..............................
1,563 records .............
2,345 *
....................................
10,570 responses ......
[50 responses] ...........
10,620 responses ......
20,025 hours *
[50 hours]
20,075 hours.
Subpart P
1612 ...........................
Request exception from 30 CFR 250.711 requirements.
Burden covered under 1014–0006
0
Subpart Q
Submit Forms BSEE–0124 and BSEE–0125;
include all supporting documentation/information.
Burden covered under 1014–0018 for BSEE–
0125; and 1014–0026 for BSEE–0124
0
Current burden ...
Revised burden ..
[NEW burden] .....
tkelley on DSK3SPTVN1PROD with PROPOSALS2
1704(g), [(h)] ..............
.........................................................................
.........................................................................
.........................................................................
....................................
....................................
....................................
52,235 responses ......
1,159 responses ........
[2,172 responses] ......
174,686 hours *
5,052 hours
[11,701 hours]
.........................................................................
....................................
55,566 Responses .....
191,439 Hours
Grand Total
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Federal Register / Vol. 80, No. 74 / Friday, April 17, 2015 / Proposed Rules
BURDEN TABLE—Continued
[Current regulations are regular font with an asterisk (*); Italic font show revision(s) of existing requirements; and bracketed text indicates new
requirements]
30 CFR 250 Current
Revision NEW
Reporting and recordkeeping requirement+
(BSEE-Approved Verification Organization =
BAVO)
Hour burden
Average number of
annual responses
Annual burden hours
(rounded)
$102,500 Non-Hour Cost Burden
* Indicates burdens are covered under one of the following OMB approved control numbers: 1014–0022, Subpart A; 1014–0024, Subpart B;
1014–0018, Subpart D; 1014–0004, Subpart E; 1014–0001, Subpart F; 1014–0006, Subpart P; 1014–0010, Subpart Q; 1014–0013, GPS for
MODUs; 1014–0025, APDs; or 1014–0026, APMs.
+ In the future BSEE will be allowing the option of electronic reporting for certain requirements.
The BSEE specifically solicits
comments on the following:
(1) Is the IC necessary or useful for us
to perform properly;
(2) Is the proposed burden accurate;
(3) Do you have any suggestions that
will enhance the quality, usefulness,
and clarity of the information to be
collected; and
(4) Can we minimize the burden on
the respondents.
In addition, the PRA requires agencies
to also estimate the non-hour cost
burden to respondents or recordkeepers
resulting from the collection of
information. Therefore, if you have
other than hour burden costs to
generate, maintain, and disclose this
information, you should comment and
provide your total capital and startup
cost components or annual operation,
maintenance, and purchase of service
components. Generally, your estimate
should not include costs incurred for
reasons other than to provide
information or keep records for the
government; or as part of customary and
usual business or private practices. For
further information on this burden, refer
to 5 CFR 1320.3(b)(1) and (2), or contact
the BSEE Bureau Information Collection
Clearance Officer.
tkelley on DSK3SPTVN1PROD with PROPOSALS2
National Environmental Policy Act of
1969 (NEPA)
We prepared a draft environmental
assessment that concludes that this
proposed rule would not have a
significant impact on the quality of the
environment under NEPA. A copy of the
draft Environmental Assessment can be
viewed at www.regulations.gov (use the
keyword/ID BSEE–2015–0002). We will
consider any new information we
receive during the public comment
period for the proposed rule that may
inform our analysis of the potential
environmental impacts of the rule.
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Data Quality Act
In developing this rule, we did not
conduct or use a study, experiment, or
survey requiring peer review under the
Data Quality Act (Pub. L. 106–554, app.
C § 515, 114 Stat. 2763, 2763A–153–
154).
Effects on the Nation’s Energy Supply
(E.O. 13211)
This rule is not a significant energy
action under the definition in E.O.
13211. Although the proposed rule is a
significant regulatory action under E.O.
12866, it is not likely to have a
significant adverse effect on the supply,
distribution, or use of energy. A
Statement of Energy Effects is not
required.
Clarity of This Regulation
We are required by E.O. 12866, E.O.
12988, and by the Presidential
Memorandum of June 1, 1998, to write
all rules in plain language. This means
that each rule we publish must:
(1) Be logically organized;
(2) Use the active voice to address
readers directly;
(3) Use clear language rather than
jargon;
(4) Be divided into short sections and
sentences; and
(5) Use lists and tables wherever
possible.
If you feel that we have not met these
requirements, send us comments by one
of the methods listed in the ADDRESSES
section. To better help us revise the
rule, your comments should be as
specific as possible. For example, you
should tell us the numbers of the
sections or paragraphs that you find
unclear, which sections or sentences are
too long, the sections where you feel
lists or tables would be useful, etc.
personal identifying information in your
comment, you should be aware that
your entire comment—including your
personal identifying information—may
be made publicly available at any time.
While you can ask us in your comment
to withhold your personal identifying
information from public review, we
cannot guarantee that we will be able to
do so.
List of Subjects in 30 CFR Part 250
Administrative practice and
procedure, Continental shelf,
Environmental impact statements,
Environmental protection, Incorporation
by reference, Oil and gas exploration,
Penalties, Public lands—mineral
resources, Public lands—rights-of-way,
Reporting and recordkeeping
requirements, Sulphur.
Dated: April 9, 2015.
Janice M. Schneider,
Assistant Secretary—Land and Minerals
Management.
For the reasons stated in the
preamble, the Bureau of Safety and
Environmental Enforcement (BSEE) is
proposing to amend 30 CFR part 250 as
follows:
PART 250—OIL AND GAS AND
SULPHUR OPERATIONS IN THE
OUTER CONTINENTAL SHELF
1. The authority citation for part 250
continues to read as follows:
■
Authority: 30 U.S.C. 1751, 31 U.S.C. 9701,
43 U.S.C. 1334.
2. In § 250.102, revise paragraphs
(b)(1) and (b)(11) through (13) and add
paragraph (b)(19) to read as follows:
■
Public Availability of Comments
§ 250.102
What does this part do?
Before including your address, phone
number, email address, or other
*
*
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(b) * * *
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*
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Federal Register / Vol. 80, No. 74 / Friday, April 17, 2015 / Proposed Rules
TABLE—WHERE TO FIND INFORMATION FOR CONDUCTING OPERATIONS
For information about . . .
Refer to . . .
(1) Applications for permit to drill (APD) ...........................................................................................................
30 CFR 250, subparts D and G.
*
*
*
*
*
(11) Oil and gas well-completion operations ....................................................................................................
(12) Oil and gas well-workover operations .......................................................................................................
(13) Decommissioning activities ........................................................................................................................
*
*
30 CFR 250, subparts E and G.
30 CFR 250, subparts F and G.
30 CFR 250, subparts G and Q.
*
*
*
*
*
(19) Well operations and equipment .................................................................................................................
*
*
30 CFR 250, subpart G.
3. Amend § 250.107 by:
a. Removing the word ‘‘and’’ from the
end of paragraph (a)(1);
■ b. Removing the period from the end
of paragraph (a)(2) and adding in its
place a semicolon; and
■ c. Adding paragraphs (a)(3) and (4)
and (e).
The additions read as follows:
■
■
§ 250.107 What must I do to protect health,
safety, property, and the environment?
(a) * * *
(3) Utilizing recognized engineering
practices that reduce risks to the lowest
level practicable when conducting
design, fabrication, installation,
operation, inspection, repair, and
maintenance activities; and
(4) Complying with all lease, plan,
and permit terms and conditions.
*
*
*
*
*
(e) The BSEE may issue orders to
ensure compliance with this part,
including but not limited to, orders to
produce and submit records and to
inspect, repair, and or replace
equipment. The BSEE may also issue
orders to shut-in operations of a
component or facility because of a threat
of serious, irreparable, or immediate
harm to health, safety, property, or the
environment posed by those operations
or because the operations violate law,
including a regulation, order, or
provision of a lease, plan, or permit.
■ 4. In § 250.125, revise the table in
paragraph (a) to read as follows:
§ 250.125
Service fees.
(a) * * *
Service—processing of the following:
Fee amount
(1) Suspension of Operations/Suspension of Production
(SOO/SOP) Request.
(2) Deepwater Operations Plan (DWOP) .........................
(3) Application for Permit to Drill (APD); Form BSEE–
0123.
(4) Application for Permit to Modify (APM); Form BSEE–
0124.
$2,123 .............................................................................
§ 250.171(e).
$3,599 .............................................................................
$2,113 for initial applications only; no fee for revisions
§ 250.292(q).
§ 250.410(d); § 250.513(b);
§ 250.1617(a).
§ 250.465(b); § 250.513(b);
§ 250.613(b);
§ 250.1618(a);
§ 250.1704(g).
§ 250.802(e).
(5) New Facility Production Safety System Application
for facility with more than 125 components.
tkelley on DSK3SPTVN1PROD with PROPOSALS2
(6) New Facility Production Safety System Application
for facility with 25–125 components.
(7) New Facility Production Safety System Application
for facility with fewer than 25 components.
(8) Production Safety System Application—Modification
with more than 125 components reviewed.
(9) Production Safety System Application—Modification
with 25–125 components reviewed.
(10) Production Safety System Application—Modification
with fewer than 25 components reviewed.
(11) Platform Application—Installation—Under the Platform Verification Program.
(12) Platform Application—Installation—Fixed Structure
Under the Platform Approval Program.
(13) Platform Application—Installation—Caisson/Well
Protector.
(14) Platform Application—Modification/Repair ................
(15) New Pipeline Application (Lease Term) ....................
(16) Pipeline Application—Modification (Lease Term) .....
(17) Pipeline Application—Modification (ROW) ................
(18) Pipeline Repair Notification .......................................
(19) Pipeline Right-of-Way (ROW) Grant Application ......
(20) Pipeline Conversion of Lease Term to ROW ...........
(21) Pipeline ROW Assignment ........................................
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30 CFR citation
$125 ................................................................................
$5,426 A component is a piece of equipment or ancillary system that is protected by one or more of the
safety devices required by API RP 14C (as incorporated by reference in § 250.198); $14,280 additional fee will be charged if BSEE deems it necessary to visit a facility offshore, and $7,426 to visit a
facility in a shipyard.
$1,314 Additional fee of $8,967 will be charged if BSEE
deems it necessary to visit a facility offshore, and
$5,141 to visit a facility in a shipyard.
$652 ................................................................................
§ 250.802(e).
§ 250.802(e).
$605 ................................................................................
§ 250.802(e).
$217 ................................................................................
§ 250.802(e).
$92 ..................................................................................
§ 250.802(e).
$22,734 ...........................................................................
§ 250.905(l).
$3,256 .............................................................................
§ 250.905(l).
$1,657 .............................................................................
§ 250.905(l)
$3,884 .............................................................................
$3,541 .............................................................................
$2,056 .............................................................................
$4,169 .............................................................................
$388 ................................................................................
$2,771 .............................................................................
$236 ................................................................................
$201 ................................................................................
§ 250.905(l).
§ 250.1000(b).
§ 250.1000(b).
§ 250.1000(b).
§ 250.1008(e).
§ 250.1015(a).
§ 250.1015(a).
§ 250.1018(b).
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Service—processing of the following:
Fee amount
30 CFR citation
(22) 500 Feet From Lease/Unit Line Production Request
(23) Gas Cap Production Request ...................................
(24) Downhole Commingling Request ..............................
(25) Complex Surface Commingling and Measurement
Application.
$3,892
$4,953
$5,779
$4,056
(26) Simple Surface Commingling and Measurement Application.
$1,371 .............................................................................
(27) Voluntary Unitization Proposal or Unit Expansion ....
(28) Unitization Revision ...................................................
(29) Application to Remove a Platform or Other Facility
(30) Application to Decommission a Pipeline (Lease
Term).
(31) Application to Decommission a Pipeline (ROW) ......
$12,619 ...........................................................................
$896 ................................................................................
$4,684 .............................................................................
$1,142 .............................................................................
5. Amend § 250.198 by revising
paragraphs (h)(51), (63), (68), and (70)
and adding paragraphs (h)(89) through
(94) to read as follows:
■
§ 250.198 Documents incorporated by
reference.
*
*
*
*
*
(h) * * *
(51) API RP 2RD, Design of Risers for
Floating Production Systems (FPSs) and
Tension-Leg Platforms (TLPs), First
Edition, June 1998; Reaffirmed May
2006, Errata June 2009; incorporated by
reference at §§ 250.292, 250.733,
250.800, 250.901, and 250.1002;
*
*
*
*
*
(63) API Standard 53, Blowout
Prevention Equipment Systems for
Drilling Wells, Fourth Edition,
November 2012; incorporated by
reference at §§ 250.730, 250.737, and
250.739;
*
*
*
*
*
(68) ANSI/API Spec. Q1, Specification
for Quality Programs for the Petroleum,
Petrochemical and Natural Gas Industry,
ISO TS 29001:2007 (Identical),
Petroleum, petrochemical and natural
gas industries—Sector specific
requirements—Requirements for
product and service supply
organizations, Eighth Edition, December
2007, Effective Date: June 15, 2008;
incorporated by reference at §§ 250.730
and 250.806;
*
*
*
*
*
.............................................................................
.............................................................................
.............................................................................
.............................................................................
$2,170 .............................................................................
(70) ANSI/API Spec. 6A, Specification
for Wellhead and Christmas Tree
Equipment, Nineteenth Edition, July
2004; Effective Date: February 1, 2005;
Contains API Monogram Annex as Part
of U.S. National Adoption; ISO
10423:2003 (Modified), Petroleum and
natural gas industries—Drilling and
production equipment—Wellhead and
Christmas tree equipment; Errata 1,
September 2004, Errata 2, April 2005,
Errata 3, June 2006, Errata 4, August
2007, Errata 5, May 2009; Addendum 1,
February 2008; Addendum 2, 3, and 4,
December 2008; incorporated by
reference at §§ 250.730, 250.806, and
250.1002;
*
*
*
*
*
(89) ANSI/API Spec. 11D1, Packers
and Bridge Plugs, ISO 14310:2008
(Identical), Petroleum and natural gas
industries—Downhole equipment—
Packers and bridge plugs, Second
Edition, Effective Date: January 1, 2010;
incorporated by reference at §§ 250.518,
250.619, and 250.1703;
(90) ANSI/API Spec. 16A,
Specification for Drill-through
Equipment, Third Edition, June 2004;
incorporated by reference at § 250.730;
(91) ANSI/API Spec. 16C,
Specification for Choke and Kill
Systems, First Edition, January 1993;
incorporated by reference at § 250.730;
(92) API Spec. 16D, Specification for
Control Systems for Drilling Well
control Equipment and Control Systems
tkelley on DSK3SPTVN1PROD with PROPOSALS2
30 CFR subpart, title and/or BSEE Form
(OMB Control No.)
(2) Subpart B, Plans and Information (1014–0024) .................................
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for Diverter Equipment, Second Edition,
July 2004; incorporated by reference at
§ 250.730;
(93) ANSI/API Spec. 17D, Design and
Operation of Subsea Production
Systems—Subsea Wellhead and Tree
Equipment, Second Edition; May 2011;
ISO 13628–4 (Identical), Design and
operation of subsea production systemsPart 4: Subsea wellhead and tree
equipment; incorporated by reference at
§ 250.730; and
(94) ANSI/API RP 17H, Remotely
Operated Vehicle Interfaces on Subsea
Production Systems, ISO 13628–8:2002
(Identical), Petroleum and natural gas
industries—Design and operation of
subsea production systems—Part 8:
Remotely Operated Vehicle (ROV)
interfaces on subsea production
systems, First Edition, July 2004,
Reaffirmed: January 2009; incorporated
by reference at § 250.734.
*
*
*
*
*
■ 6. In § 250.199, revise paragraph (e) to
read as follows:
§ 250.199 Paperwork Reduction Act
statements—information collection.
*
*
*
*
*
(e) BSEE is collecting this information
for the reasons given in the following
table:
BSEE collects this information and uses it to:
(1) Subpart A, General (1014–0022), including Forms BSEE–0132,
Evacuation Statistics; BSEE–0143, Facility/Equipment Damage Report; BSEE–1832, Notification of Incidents of Noncompliance.
VerDate Sep<11>2014
§ 250.1156(a).
§ 250.1157.
§ 250.1158(a).
§ 250.1202(a);
§ 250.1203(b);
§ 250.1204(a).
§ 250.1202(a);
§ 250.1203(b);
§ 250.1204(a).
§ 250.1303(d).
§ 250.1303(d).
§ 250.1727.
§ 250.1751(a) or
§ 250.1752(a).
§ 250.1751(a) or
§ 250.1752(a).
Fmt 4701
(i) Determine that activities on the OCS comply with statutory and regulatory requirements; are safe and protect the environment; and result in diligent development and production on OCS leases.
(ii) Support the unproved and proved reserve estimation, resource assessment, and fair market value determinations.
(iii) Assess damage and project any disruption of oil and gas production from the OCS after a major natural occurrence.
Evaluate Deepwater Operations Plans for compliance with statutory
and regulatory requirements.
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30 CFR subpart, title and/or BSEE Form
(OMB Control No.)
BSEE collects this information and uses it to:
(3) Subpart C, Pollution Prevention and Control (1014–0023) ................
(4) Subpart D, Oil and Gas and Drilling Operations (1014–0018), including Forms BSEE–0125, End of Operations Report; BSEE–0133,
Well Activity Report; and BSEE–0133S, Open Hole Data Report.
(5) Subpart E, Oil and Gas Well-Completion Operations (1014–0004) ..
(6) Subpart F, Oil and Gas Well Workover Operations (1014–0001) .....
(7) Subpart G, Blowout Preventer Systems (1014-xxxx), including Form
BSEE–0144, Rig Movement Notification Report.
(8) Subpart H, Oil and Gas Production Safety Systems (1014–0003) ....
(9) Subpart I, Platforms and Structures (1014–0011) ..............................
(10) Subpart J, Pipelines and Pipeline Rights-of-Way (1014–0016), including Form BSEE–0149, Assignment of Federal OCS Pipeline
Right-of-Way Grant.
(11) Subpart K, Oil and Gas Production Rates (1014–0019), including
Forms BSEE–0126, Well Potential Test Report and BSEE–0128,
Semiannual Well Test Report.
(12) Subpart L, Oil and Gas Production Measurement, Surface Commingling, and Security (1014–0002).
(13) Subpart M, Unitization (1014–0015) .................................................
(14) Subpart N, Remedies and Penalties ................................................
(15) Subpart O, Well Control and Production Safety Training (1014–
0008).
(16) Subpart P, Sulphur Operations (1014–0006) ...................................
(17) Subpart Q, Decommissioning Activities (1014–0010) ......................
tkelley on DSK3SPTVN1PROD with PROPOSALS2
(18) Subpart S, Safety and Environmental Management Systems
(1014–0017), including Form BSEE–0131, Performance Measures
Data.
(19) Application for Permit to Drill (APD, Revised APD), Form BSEE–
0123; and Supplemental APD Information Sheet, Form BSEE–
0123S, and all supporting documentation (1014–0025).
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(i) Evaluate measures to prevent unauthorized discharge of pollutants
into the offshore waters.
(ii) Ensure action is taken to control pollution.
(i) Evaluate the equipment and procedures to be used in drilling operations on the OCS.
(ii) Ensure that drilling operations meet statutory and regulatory requirements.
(i) Evaluate the equipment and procedures to be used in well-completion operations on the OCS.
(ii) Ensure that well-completion operations meet statutory and regulatory requirements.
(i) Evaluate the equipment and procedures to be used during wellworkover operations on the OCS.
(ii) Ensure that well-workover operations meet statutory and regulatory
requirements.
(i) Evaluate the equipment and procedures to be used during well drilling, completion, workover, and abandonment operations on the
OCS.
(ii) Ensure that well operations meet statutory and regulatory requirements.
(i) Evaluate the equipment and procedures that will be used during production operations on the OCS.
(ii) Ensure that production operations meet statutory and regulatory requirements.
(i) Evaluate the design, fabrication, and installation of platforms on the
OCS.
(ii) Ensure the structural integrity of platforms installed on the OCS.
(i) Evaluate the design, installation, and operation of pipelines on the
OCS.
(ii) Ensure that pipeline operations meet statutory and regulatory requirements.
(i) Evaluate production rates for hydrocarbons produced on the OCS.
(ii) Ensure economic maximization of ultimate hydrocarbon recovery.
(i) Evaluate the measurement of production, commingling of hydrocarbons, and site security plans.
(ii) Ensure that produced hydrocarbons are measured and commingled
to provide for accurate royalty payments and security.
(i) Evaluate the unitization of leases.
(ii) Ensure that unitization prevents waste, conserves natural resources, and protects correlative rights.
(The requirements in subpart N are exempt from the Paperwork Reduction Act of 1995 according to 5 CFR 1320.4).
(i) Evaluate training program curricula for OCS workers, course schedules, and attendance.
(ii) Ensure that training programs are technically accurate and sufficient
to meet statutory and regulatory requirements, and that workers are
properly trained.
(i) Evaluate sulphur exploration and development operations on the
OCS.
(ii) Ensure that OCS sulphur operations meet statutory and regulatory
requirements and will result in diligent development and production
of sulphur leases.
Ensure that decommissioning activities, site clearance, and platform or
pipeline removal are properly performed to meet statutory and regulatory requirements and do not conflict with other users of the OCS.
(i) Evaluate operators’ policies and procedures to assure safety and
environmental protection while conducting OCS operations (including
those operations conducted by contractor and subcontractor personnel).
(ii) Evaluate Performance Measures Data relating to risk and number
of accidents, injuries, and oil spills during OCS activities.
(i) Evaluate and approve the adequacy of the equipment, materials,
and/or procedures that the lessee or operator plans to use during
drilling.
(ii) Ensure that applicable OCS operations meet statutory and regulatory requirements.
Sfmt 4702
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30 CFR subpart, title and/or BSEE Form
(OMB Control No.)
BSEE collects this information and uses it to:
(20) Application for Permit to Modify (APM), Form BSEE–0124, and
supporting documentation (1014–0026).
7. Amend § 250.292 by:
a. Removing the word ‘‘and’’ from the
end of paragraph (o);
■ b. Redesignating paragraph (p) as (q);
and
■ c. Adding new paragraph (p).
The addition reads as follows:
■
■
§ 250.292
What must the DWOP contain?
*
*
*
*
*
(p) If you propose to use a pipeline
free standing hybrid riser (FSHR) that
utilizes a critical chain, wire rope, or
synthetic tether to connect the top of the
riser to a buoyancy air can, provide the
following information in your DWOP in
the discussions required by paragraphs
(f) and (g) of this section:
(1) A detailed description and
drawings of the FSHR, buoy and the
tether system;
(2) Detailed information on the
design, fabrication, and installation of
the FSHR, buoy and tether system,
including pressure ratings, fatigue life,
and yield strengths;
(3) A description of how you met the
design requirements, load cases, and
allowable stresses for each load case
according to API RP 2RD (as
incorporated by reference in § 250.198);
(4) Detailed information regarding the
tether system used to connect the FSHR
to a buoyancy air can;
(5) Descriptions of your monitoring
system and monitoring plan to monitor
the pipeline FSHR and tether for fatigue,
stress, and any other abnormal
condition (e.g., corrosion) that may
negatively impact the riser or tether; and
(6) Documentation that the tether
system and connection accessories for
the pipeline FSHR have been certified
by an approved classification society or
equivalent and verified by the CVA
required in Subpart I; and
*
*
*
*
*
■ 8. Revise § 250.400 to read as follows:
tkelley on DSK3SPTVN1PROD with PROPOSALS2
§ 250.400
General Requirements.
Drilling operations must be conducted
in a safe manner to protect against harm
or damage to life (including fish and
other aquatic life), property, natural
resources of the Outer Continental Shelf
(OCS), including any mineral deposits
(in areas leased and not leased), the
National security or defense, or the
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(i) Evaluate and approve the adequacy of the equipment, materials,
and/or procedures that the lessee or operator plans to use during
drilling and to evaluate well plan modifications and changes in major
equipment.
(ii) Ensure that applicable OCS operations meet statutory and regulatory requirements.
marine, coastal, or human environment.
In addition to the requirements of this
subpart, you must also follow the
applicable requirements of Subpart G.
§ §§ 250.401 through 250.403
and Reserved]
[Removed
9a. Remove and reserve §§ 250.401
through 250.403, and 250.406.
■
§ § 250.406
[Removed and Reserved]
9b. Remove and reserve § 250.406.
10. Revise § 250.411 to read as
follows:
■
■
§ 250.411 What information must I submit
with my application?
In addition to forms BSEE–0123 and
BSEE–0123S, you must include the
information required in this subpart and
Subpart G, including the following:
Information that you
must include with an APD
(a) Plat that shows locations of
the proposed well ..................
(b) Design criteria used for the
proposed well ........................
(c) Drilling prognosis .................
(d) Casing and cementing programs ....................................
(e) Diverter systems descriptions .......................................
(f) BOP system descriptions .....
(g) Requirements for using an
MODU, and ...........................
(h) Additional information .........
Where
to find
a description
§ 250.412
§ 250.413
§ 250.414
§ 250.415
§ 250.416
§ 250.731
§ 250.713
§ 250.418
11. In § 250.413, revise paragraph (g)
to read as follows:
■
§ 250.413 What must my description of
well drilling design criteria address?
*
*
*
*
*
(g) A single plot containing curves for
estimated pore pressures, formation
fracture gradients, proposed drilling
fluid weights, maximum equivalent
circulating density, and casing setting
depths in true vertical measurements;
*
*
*
*
*
■ 12. Amend § 250.414 by revising
paragraphs (c), (h), and (i) and adding
paragraphs (j) and (k) to read as follows:
§ 250.414
include?
What must my drilling prognosis
*
*
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*
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*
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(c) Planned safe drilling margins
between proposed drilling fluid weights
and the estimated pore pressures, and
proposed drilling fluid weights and the
lesser of estimated fracture gradients or
casing shoe pressure integrity test. Your
safe drilling margins must meet the
following conditions:
(1) Static downhole mud weight must
be greater than estimated pore pressure;
(2) Static downhole mud weight must
be a minimum of one-half pound per
gallon below the lesser of the casing
shoe pressure integrity test or the lowest
estimated fracture gradient;
(3) The equivalent circulating density
must be below the lesser of the casing
shoe pressure integrity test or the lowest
estimated fracture gradient; and
(4) When determining the pore
pressure and lowest estimated fracture
gradient for a specific interval, you must
consider related hole behavior
observations.
*
*
*
*
*
(h) A list and description of all
requests for using alternate procedures
or departures from the requirements of
this subpart in one place in the APD.
You must explain how the alternate
procedures afford an equal or greater
degree of protection, safety, or
performance, or why the departures are
requested;
(i) Projected plans for well testing
(refer to § 250.460);
(j) The type of wellhead system and
liner hanger system to be installed and
a descriptive schematic, which includes
but is not limited to pressure ratings,
dimensions, valves, load shoulders, and
locking mechanisms, if applicable; and
(k) Any additional information
required by the District Manager.
■ 13. In § 250.415, revise paragraph (a)
to read as follows:
§ 250.415 What must my casing and
cementing programs include?
*
*
*
*
*
(a) The following well design
information:
(1) Hole sizes;
(2) Bit depths (including measured
and true vertical depth (TVD));
(3) Casing information including
sizes, weights, grades, collapse and
burst values, types of connection, and
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setting depths (measured and TVD) for
all sections of each casing interval; and
(4) Locations of any installed rupture
disks (indicate if burst or collapse and
rating);
*
*
*
*
*
■ 14. Revise § 250.416 to read as
follows:
§ 250.416 What must I include in the
diverter description?
You must include in the diverter
descriptions:
(a) A description of the diverter
system and its operating procedures;
(b) A schematic drawing of the
diverter system (plan and elevation
views) that shows:
(1) The size of the annular BOP
installed in the diverter housing;
(2) Spool outlet internal diameter(s);
(3) Diverter-line lengths and
diameters; burst strengths and radius of
curvature at each turn; and
(4) Valve type, size working pressure
rating, and location.
§ 250.417
[Removed and Reserved]
15. Remove and reserve § 250.417.
■ 16. In § 250.418, revise paragraph (g)
to read as follows:
■
§ 250.418 What additional information
must I submit with my APD?
*
*
*
*
*
(g) A request for approval if you plan
to wash out or displace cement to
facilitate casing removal upon well
abandonment. Your request must
include a description of how far below
the mudline you propose to displace
cement and how you will visually
monitor returns;
*
*
*
*
*
■ 17. Amend § 250.420 by:
■ a. Revising the introductory text and
paragraph (a)(5);
■ b. Redesignating paragraph (a)(6) as
(a)(7);
■ c. Adding new paragraph (a)(6) and
paragraph (b)(4); and
■ d. Revising paragraph (c).
The revisions and additions read as
follows:
§ 250.420 What well casing and cementing
requirements must I meet?
You must case and cement all wells.
Your casing and cementing programs
must meet the applicable requirements
of this subpart and of subpart G.
(a) * * *
(5) Support unconsolidated
sediments;
(6) Provide adequate centralization to
ensure proper cementation; and
*
*
*
*
*
(b) * * *
(4) If you need to substitute a different
size, grade, or weight of casing than
what was approved in your APD, you
must contact the District Manager for
approval prior to installing the casing.
*
*
*
*
*
(c) Cementing requirements. (1) You
must design and conduct your
cementing jobs so that cement
composition, placement techniques, and
waiting times ensure that the cement
placed behind the bottom 500 feet of
casing attains a minimum compressive
strength of 500 psi before drilling out
the casing or before commencing
completion operations.
(2) You must use a weighted fluid to
maintain an overbalanced hydrostatic
pressure during the cement setting time,
except when cementing casings or liners
in riserless hole sections.
■ 18. In § 250.421, revise paragraphs (b)
and (f) to read as follows:
§ 250.421 What are the casing and
cementing requirements by type of casing
string?
*
*
*
*
*
Casing type
Casing requirements
Cementing requirements
*
(b) Conductor ...
*
*
*
Design casing and select setting depths based on relevant
engineering and geologic factors. These factors include the
presence or absence of hydrocarbons, potential hazards,
and water depths.
Set casing immediately before drilling into formations known
to contain oil or gas. If you encounter oil or gas or unexpected formation pressure before the planned casing point,
you must set casing immediately and set it above the encountered zone.
*
*
*
Use enough cement to fill the calculated annular space back
to the mudline.
Verify annular fill by observing cement returns. If you cannot
observe cement returns, use additional cement to ensure
fill-back to the mudline.
For drilling on an artificial island or when using a well cellar,
you must discuss the cement fill level with the District Manager.
*
(f) Liners ...........
*
*
*
If you use a liner as surface casing, you must set the top of
the liner at least 200 feet above the previous casing/liner
shoe.
If you use a liner as an intermediate string below a surface
string or production casing below an intermediate string,
you must set the top of the liner at least 100 feet above the
previous casing shoe.
You may not use a liner as conductor casing ..........................
*
*
*
Same as cementing requirements for specific casing types.
For example, a liner used as intermediate casing must be
cemented according to the cementing requirements for intermediate casing.
19. Revise § 250.423 to read as
follows:
tkelley on DSK3SPTVN1PROD with PROPOSALS2
■
§ 250.423 What are the requirements for
casing and liner installation?
You must ensure proper installation
of casing in the subsea wellhead or liner
in the liner hanger.
(a) You must ensure that the latching
mechanisms or lock down mechanisms
are engaged upon successfully installing
and cementing the casing string.
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(b) If you run a liner that has a
latching mechanism or lock down
mechanism, you must ensure that the
latching mechanisms or lock down
mechanisms are engaged upon
successfully installing and cementing
the liner.
(c) You must perform a pressure test
on the casing seal assembly to ensure
proper installation of casing or liner.
You must perform this test for the
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intermediate and production casing
strings or liners.
(1) You must submit for approval with
your APD, test procedures and criteria
for a successful test.
(2) You must document all your test
results and make them available to
BSEE upon request.
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§§ 250.424 through 250.426
Reserved]
[Removed and
20. Remove and reserve §§ 250.424
through 250.426.
■ 21. In § 250.427, revise paragraph (b)
to read as follows:
■
§ 250.427 What are the requirements for
pressure integrity tests?
*
*
*
*
*
(b) While drilling, you must maintain
the safe drilling margins identified in
§ 250.414. When you cannot maintain
the safe margins, you must suspend
drilling operations and remedy the
situation.
■ 22. In § 250.428, revise paragraphs (b)
through (d) and add paragraph (k) to
read as follows:
§ 250.428 What must I do in certain
cementing and casing situations?
*
*
*
*
If you encounter the following situation:
Then you must .
*
*
*
(b) Need to change casing setting depths or hole interval
drilling depth (for a BHA with an under-reamer, this
means bit depth) more than 100 feet true vertical depth
(TVD) from the approved APD due to conditions encountered during drilling operations.
(c) Have indication of inadequate cement job (such as
lost returns, no cement returns to mudline or expected
height, cement channeling, or failure of equipment).
*
*
*
*
Submit those changes to the District Manager for approval and include a certification
by a professional engineer (PE) that he or she reviewed and approved the proposed changes.
(d) Inadequate cement job .................................................
*
*
*
(k) Plan to use a valve on the drive pipe during cementing operations for the conductor casing, surface casing,
or liner.
§ § 250.440 through 250.451
and Reserved]
[Removed
23. Remove the undesignated center
heading ‘‘Blowout Preventer (BOP)
System Requirements’’ and remove and
reserve §§ 250.440 through 250.451.
■
§ 250.456
[Amended]
24. Amend § 250.456:
a. In paragraph (i), by adding the word
‘‘and’’ after the semi-colon
■ b. By removing paragraph (j); and
■ c. By redesignating paragraph (k) as
(j).
■ 25. Revise § 250.462 to read as
follows.
tkelley on DSK3SPTVN1PROD with PROPOSALS2
■
■
§ 250.462 What are the source control and
containment requirements?
For drilling operations using a subsea
BOP or surface BOP on a floating
facility, you must have the ability to
control or contain a blowout event at the
sea floor.
(a) To determine your required source
control and containment capabilities
you must do the following:
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.
*
.
(1) Locate the top of cement by: (i) Running a temperature survey; (ii) Running a cement evaluation log; or (iii) Using a combination of these techniques.
(2) Determine if your cement job is inadequate. If your cement job is determined to
be inadequate, refer to paragraph (d) of this section.
(3) If your cement job is determined to be adequate, report the results to the District
Manager in your submitted WAR.
Take remedial actions. The District Manager must review and approve all remedial
actions before you may take them, unless immediate actions must be taken to ensure the safety of the crew or to prevent a well-control event. If you complete any
immediate action to ensure the safety of the crew or to prevent a well-control
event, submit a description of the action to the District Manager when that action is
complete. Any changes to the well program will require submittal of a certification
by a professional engineer (PE) certifying that he or she reviewed and approved
the proposed changes, and must meet any other requirements of the District Manager.
*
*
*
*
Include a description of the plan in your APD. Your description must include a schematic of the valve and height above the water line. The valve must be remotely
operated and full opening with visual observation while taking returns. The person
in charge of observing returns must be in communication with the drill floor. You
must record in your daily report and in the WAR if cement returns were observed.
If cement returns are not observed, you must contact the District Manager and obtain approval of proposed plans to locate the top of cement before continuing with
operations.
(1) Consider a scenario of the wellbore
fully evacuated to reservoir fluids, with
no restrictions in the well.
(2) Evaluate the performance of the
well as designed to determine if a full
shut-in can be achieved without having
reservoir fluids broach to the sea floor.
If your evaluation indicates that the well
can only be partially shut-in, then you
must determine your ability to flow and
capture the residual fluids to a surface
production and storage system.
(b) You must have access to and
ability to deploy Source Control and
Containment Equipment (SCCE)
necessary to regain control of the well.
SCCE means the capping stack, cap and
flow system, containment dome, and/or
other subsea and surface devices,
equipment, and vessels whose collective
purpose is to control a spill source and
stop the flow of fluids into the
environment or to contain fluids
escaping into the environment. This
equipment must include, but is not
limited to, the following:
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(1) Subsea containment and capture
equipment, including containment
domes and capping stacks;
(2) Subsea utility equipment,
including hydraulic power, hydrate
control, and dispersant injection
equipment;
(3) Riser systems;
(4) Remotely operated vehicles
(ROVs);
(5) Capture vessels;
(6) Support vessels; and
(7) Storage facilities.
(c) You must submit a description of
your source control and containment
capabilities to the Regional Supervisor
and receive approval before BSEE will
approve your APD, Form BSEE–0123.
The description of your containment
capabilities must contain the following:
(1) Your source control and
containment capabilities for controlling
and containing a blowout event at the
seafloor,
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(2) A discussion of the determination
required in paragraph (a) of this section,
and
(3) Information showing that you have
access to and ability to deploy all
equipment required by paragraph (b) of
this section.
(d) You must contact the District
Manager and Regional Supervisor for
reevaluation of your source control and
containment capabilities if your:
(1) Well design changes, or
(2) Approved source control and
containment equipment is out of
service.
21569
(e) You must maintain, test, and
inspect the source control and
containment equipment identified in
the following table according to these
requirements:
Equipment
Requirements, you must:
Additional information
(1) Capping stacks ...............
(i) Function test all pressure holding critical components
on a quarterly frequency (not to exceed 104 days between tests).
(ii) Pressure test pressure holding critical components
on a bi-annual basis, but not later than 210 days
from the last pressure test. All pressure testing must
be witnessed by BSEE and a BSEE- approved
verification organization.
(iii) Notify BSEE at least 21 days prior to commencing
any pressure testing.
(i) Meet or exceed the requirements set forth in 30 CFR
250.800–250.808, Subpart H.
(ii) Have all equipment unique to containment operations available for inspection at all times..
Have all equipment unique to containment operations
available for inspection at all times.
Pressure holding critical components are those components that will experience wellbore pressure during a
shut-in after being functioned.
Pressure holding critical components are those components that will experience wellbore pressure during a
shut-in. These components include, but are not limited to: All blind rams, wellhead connectors, and outlet valves.
(2) Production Safety Systems used for flow and
capture operations.
(3) Subsea utility equipment
§ 250.514
26. In § 250.465, revise paragraph
(b)(3) to read as follows:
■
[Amended]
30. In § 250.514, remove paragraph
(d).
■
§ 250.465 When must I submit an
Application for Permit to Modify (APM) or
an End of Operations Report to BSEE?
§§ 250.515 through 250.517
Reserved]
*
■
*
*
*
*
(b) * * *
(3) Within 30 days after completing
this work, you must submit an End of
Operations Report (EOR), Form BSEE–
0125, as required under § 250.744.
§§ 250.466 through 250.469
Reserved]
[Removed and
27. Remove and reserve §§ 250.466
through 250.469.
■ 28. Revise § 250.500 to read as
follows:
■
§ 250.500
tkelley on DSK3SPTVN1PROD with PROPOSALS2
Subsea utility equipment includes, but is not limited to:
Hydraulic power sources, debris removal, hydrate
control equipment, and dispersant injection equipment.
[Removed and
29. Remove and reserve §§ 250.502
and 250.506.
■
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Tubing and wellhead equipment.
*
Well-completion operations must be
conducted in a manner to protect
against harm or damage to life
(including fish and other aquatic life),
property, natural resources of the OCS,
including any mineral deposits (in areas
leased and not leased), the National
security or defense, or the marine,
coastal, or human environment. In
addition to the requirements of this
subpart, you must also follow the
applicable requirements of Subpart G.
§ 250.600
31. Remove and reserve §§ 250.515
through 250.517.
■ 32. Amend § 250.518 by:
■ a. Removing paragraph (b);
■ b. Redesignating paragraphs (c)
through (e) as paragraphs (b) through
(d); and
■ c. Adding new paragraph (e) and
paragraph (f).
The additions read as follows:
§ 250.518
General requirements.
§§ 250.502 and 250.506
Reserved]
[Removed and
*
*
*
*
(e) Installed packers and bridge plugs
must meet the following:
(1) All packers and bridge plugs must
comply with API Spec. 11D1 (as
incorporated by reference in § 250.198);
(2) During well completion
operations, the production packer must
be set at a depth that will allow for a
column of weighted fluids to be placed
above the packer that will exert a
hydrostatic force greater than or equal to
the force created by the reservoir
pressure below the packer;
(3) The production packer must be set
as close as practically possible to the
perforated interval; and
(4) The production packer must be set
at a depth that is within the cemented
interval of the selected casing section.
(f) Your APM must include a
description and calculations for how
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you determined the production packer
setting depth.
■ 33. Revise § 250.600 to read as
follows:
General requirements.
Well-workover operations must be
conducted in a manner to protect
against harm or damage to life
(including fish and other aquatic life),
property, natural resources of the Outer
Continental Shelf (OCS) including any
mineral deposits (in areas leased and
not leased), the National security or
defense, or the marine, coastal, or
human environment. In addition to the
requirements of this subpart, you must
also follow the applicable requirements
of subpart G.
§ 250.602
■
34a. Remove and reserve § 250.602.
§ 250.606
■
[Removed and Reserved]
[Removed and Reserved]
34b. Remove and reserve § 250.606.
§ 250.614
[Amended]
35. In § 250.614, remove paragraph
(d).
■
§ 250.615
[Removed and Reserved]
36. Remove and reserve § 250.615.
37. Amend § 250.616 by:
a. Revising the section heading;
b. Removing paragraphs (a) through
(e); and
■ c. Redesignating paragraphs (f)
through (h) as paragraphs (a) through
(c).
The revision reads as follows:
■
■
■
■
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Well Operations
250.720 When and how must I secure a
well?
250.721 What are the requirements for
pressure testing casing and liners?
250.722 What are the requirements for
prolonged operations in a well?
250.723 What additional safety measures
must I take when I conduct operations
on a platform that has producing wells
or has other hydrocarbon flow?
250.724 What are the real-time monitoring
requirements?
§ 250.616 Coiled tubing and snubbing
operations.
*
*
*
*
§§ 250.617 and 250.618
Reserved]
*
[Removed and
38. Remove and reserve §§ 250.617
and 250.618.
■ 39. Amend § 250.619 by:
■ a. Removing paragraph (b);
■ b. Redesignating paragraphs (c)
through (e) as paragraphs (b) through
(d); and
■ c. Adding new paragraph (e) and
paragraph (f).
The additions read as follows;
■
§ 250.619
Tubing and wellhead equipment.
*
*
*
*
*
(e) If you pull and reinstall packers
and bridge plugs, you must meet the
following:
(1) All packers and bridge plugs must
comply with API Spec. 11D1 (as
incorporated by reference in § 250.198);
(2) The production packer must be set
at a depth that will allow for a column
of weighted fluids to be placed above
the packer during well completion
operations that will exert a hydrostatic
force greater than or equal to the force
created by the reservoir pressure below
the packer;
(3) The production packer must be set
as close as practically possible to the
perforated interval; and
(4) The production packer must be set
at a depth that is within the cemented
interval of the selected casing section.
(f) Your APM must include a
description and calculations for how
you determined the production packer
setting depth.
■ 40. Add subpart G to read as follows:
Subpart G—Well Operations and Equipment
tkelley on DSK3SPTVN1PROD with PROPOSALS2
General Requirements
Sec.
250.700 What operations and equipment
does this subpart cover?
250.701 May I use alternate procedures or
equipment during operations?
250.702 May I obtain departures from these
requirements?
250.703 What must I do to keep wells under
control?
Rig Requirements
250.710 What instructions must be given to
personnel engaged in well operations?
250.711 What are the requirements for wellcontrol drills?
250.712 What rig unit movements must I
report?
250.713 What must I provide if I plan to use
a mobile offshore drilling unit (MODU)
or lift boat for well operations?
250.714 Do I have to develop a dropped
objects plan?
250.715 Do I need a global positioning
system (GPS) for MODUs and jack-ups?
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Blowout Preventer (BOP) System
Requirements
250.730 What are the general requirements
for BOP systems and system
components?
250.731 What information must I submit for
BOP systems and system components?
250.732 What are the BSEE-approved
verification organization requirements
for BOP systems and system
components?
250.733 What are the requirements for a
surface BOP stack?
250.734 What are the requirements for a
subsea BOP system?
250.735 What associated systems and
related equipment must all BOP systems
include?
250.736 What are the requirements for
choke manifolds, kelly valves inside
BOPs, and drill string safety valves?
250.737 What are the BOP system testing
requirements?
250.738 What must I do in certain
situations involving BOP equipment or
systems?
250.739 What are the BOP maintenance and
inspection requirements?
Records and Reporting
250.740 What records must I keep?
250.741 How long must I keep records?
250.742 What well records am I required to
submit?
250.743 What are the well activity reporting
requirements?
250.744 What are the end of operation
reporting requirements?
250.745 What other well records could I be
required to submit?
250.746 What are the recordkeeping
requirements for casing, liner, and BOP
tests, and inspections of BOP systems
and marine risers?
Subpart G—Well Operations and
Equipment
General Requirements
§ 250.700 What operations and equipment
does this subpart cover?
This subpart covers operations and
equipment associated with drilling,
completion, workover, and
decommissioning activities. This
subpart includes regulations applicable
to drilling, completion, workover, and
decommissioning activities in addition
to applicable regulations contained in
subparts D, E, F, and Q of this part
unless explicitly stated otherwise.
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§ 250.701 May I use alternate procedures
or equipment during operations?
You may use alternate procedures or
equipment during operations after
receiving approval as described in
§ 250.141 of this part. You must identify
and discuss your proposed alternate
procedures or equipment in your
Application for Permit to Drill (APD)
(Form BSEE–0123) (see § 250.414(h)) or
your Application for Permit to Modify
(APM) (Form BSEE–0124). Procedures
for obtaining approval of alternate
procedures or equipment are described
in § 250.141 of this part.
§ 250.702 May I obtain departures from
these requirements?
You may apply for a departure from
these requirements as described in
§ 250.142. Your request must include a
justification showing why the departure
is necessary. You must identify and
discuss the departure you are requesting
in your APD (see § 250.414(h)) or your
APM.
§ 250.703 What must I do to keep wells
under control?
You must take the necessary
precautions to keep wells under control
at all times, including:
(a) Use recognized engineering
practices that reduce risks to the lowest
level practicable when monitoring and
evaluating well conditions and to
minimize the potential for the well to
flow or kick;
(b) Have a person onsite during
operations who represents your interests
and can fulfill your responsibilities;
(c) Ensure that the toolpusher,
operator’s representative, or a member
of the rig crew maintains continuous
surveillance on the rig floor from the
beginning of operations until the well is
completed or abandoned, unless you
have secured the well with blowout
preventers (BOPs), bridge plugs, cement
plugs, or packers;
(d) Use personnel trained according to
the provisions of Subparts O and S;
(e) Use and maintain equipment and
materials necessary to ensure the safety
and protection of personnel, equipment,
natural resources, and the environment;
and
(f) Use equipment that has been
designed, tested, and rated for the most
extreme service conditions to which it
will be exposed while in service.
Rig Requirements
§ 250.710 What instructions must be given
to personnel engaged in well operations?
Prior to engaging in well operations,
personnel must be instructed in:
(a) Date and time of safety meetings.
The safety requirements for the
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operations to be performed, possible
hazards to be encountered, and general
safety considerations to protect
personnel, equipment, and the
environment as required by subpart S of
this part. Date and time of safety
meetings must be recorded and
available at the facility for review by
BSEE representatives.
(b) Well control. You must prepare a
well-control plan for each well. Each
well-control plan must contain
instructions for personnel about the use
of each well-control component of your
BOP, procedures that describe how
personnel will seal the wellbore and
shear pipe before maximum anticipated
surface pressure (MASP) conditions are
exceeded, assignments for each crew
member, and a schedule for completion
of each assignment. You must keep a
copy of your well-control plan on the rig
at all times, and make it available to
BSEE upon request. You must post a
copy of the well-control plan on the rig
floor.
tkelley on DSK3SPTVN1PROD with PROPOSALS2
§ 250.711 What are the requirements for
well-control drills?
You must conduct a weekly wellcontrol drill with all personnel engaged
in well operations. Your drill must
familiarize personnel engaged in well
operations with their roles and
functions so that they can perform their
duties promptly and efficiently as
outlined in the well-control plan
required by § 250.710.
(a) Timing of drills. You must conduct
each drill during a period of activity
that minimizes the risk to operations.
The timing of your drills must cover a
range of different operations, including
drilling with a diverter, on-bottom
drilling, and tripping. The same drill
may not be repeated consecutively.
(b) Recordkeeping requirements. For
each drill, you must record the
following in the daily report:
(1) Date, time, and type of drill
conducted;
(2) The amount of time it took to be
ready to close the diverter or use each
well-control component of BOP system;
and
(3) The total time to complete the
entire drill.
(c) A BSEE ordered drill. A BSEE
representative may require you to
conduct a well-control drill during a
BSEE inspection. The BSEE
representative will consult with your
onsite representative before requiring
the drill.
§ 250.712
report?
What rig unit movements must I
(a) You must report the movement of
all rig units on and off locations to the
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21:10 Apr 16, 2015
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District Manager using Form BSEE–
0144, Rig Movement Notification
Report. Rig units include MODUs,
platform rigs, snubbing units, wire-line
units used for non-routine operations,
and coiled tubing units. You must
inform the District Manager 72 hours
before:
(1) The arrival of a rig unit on
location;
(2) The movement of a rig unit to
another slot. For movements that will
occur less than 72 hours after initially
moving onto location (e.g., coiled tubing
and batch operations), you may include
your anticipated movement schedule on
Form BSEE–0144; or
(3) The departure of a rig unit from
the location.
(b) You must provide the District
Manager with the rig name, lease
number, well number, and expected
time of arrival or departure.
(c) If a MODU or platform rig is to be
warm or cold stacked, you must inform
the District Manager;
(1) Where the MODU or platform rig
is coming from;
(2) The location of where the MODU
or platform rig will be positioned;
(3) Whether the MODU or platform rig
will be manned or unmanned; and
(4) If the location for stacking the
MODU or platform rig changes.
(d) Prior to resuming operations after
stacking, you must notify the
appropriate District Manager of any
construction, repairs, or modifications
associated with the drilling package
made to the MODU or platform rig;
(e) If a drilling rig is entering OCS
waters, you must inform the District
Manager where the drilling rig is
coming from.
(f) If you change your anticipated date
for initially moving on or off location by
more than 24 hours, you must submit an
updated Form BSEE–0144, Rig
Movement Notification Report.
§ 250.713 What must I provide if I plan to
use a mobile offshore drilling unit (MODU)
or lift boat for well operations?
If you plan to use a MODU or lift boat
for well operations, you must provide:
(a) Fitness requirements. Information
and data to demonstrate the capability
to perform at the proposed location.
This information must include the most
extreme environmental and operational
conditions that the unit is designed to
withstand, including the minimum air
gap necessary for both hurricane and
non-hurricane seasons. If sufficient
environmental information and data are
not available at the time you submit
your APD or APM, the District Manager
may approve your APD or APM, but
require you to collect and report this
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21571
information during operations. Under
this circumstance, the District Manager
has the right to revoke the approval of
the APD or APM if information
collected during operations shows that
the MODU or lift boat is not capable of
performing at the proposed location.
(b) Foundation requirements.
Information to show that site-specific
soil and oceanographic conditions are
capable of supporting the proposed
MODU or lift boat. If you provided
sufficient site-specific information in
your EP, DPP, or DOCD submitted to
BOEM, you may reference that
information. The District Manager may
require you to conduct additional
surveys and soil borings before
approving the APD or APM if additional
information is needed to make a
determination that the conditions are
capable of supporting the MODU, lift
boat, or equipment installed on a subsea
wellhead. For moored rigs, you must
submit a plat of the rigs’ anchor pattern
approved in your EP, DPP, or DOCD in
your APD or APM.
(c) For frontier areas. (1) If the design
of the MODU or lift boat you plan to use
in a frontier area is unique or has not
been proven for use in the proposed
environment, the District Manager may
require you to submit a third-party
review of the MODU or lift boat design.
If required, you must obtain a thirdparty review of your MODU or lift boat
similar to the process outlined in
§§ 250.915 through 250.918. You may
submit this information before
submitting an APD or APM.
(2) If you plan to conduct operations
in a frontier area, you must have a
contingency plan that addresses design
and operating limitations of the MODU
or lift boat. Your plan must identify the
actions necessary to maintain safety and
prevent damage to the environment.
Actions must include the suspension,
curtailment, or modification of
operations to remedy various
operational or environmental situations
(e.g., vessel motion, riser offset, anchor
tensions, wind speed, wave height,
currents, icing or ice-loading, settling,
tilt or lateral movement, resupply
capability).
(d) Additional documentation. You
must provide the current Certificate of
Inspection (for US Flagged vessels) or
Certificate of Compliance (for Foreign
Flagged vessels) from the USCG and
Certificate of Classification. You must
also provide current documentation of
any operational limitations imposed by
an appropriate classification society.
(e) Dynamically positioned rig unit. If
you use a dynamically positioned
MODU, you must include in your APD
or APM your contingency plan for
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moving off location in an emergency
situation. Your plan must include, but
not be limited to, such emergency
events caused by storms, currents,
station-keeping failure, power failure,
and loss of well control. The District
Manager may require your plan to
include additional events and
information.
(f) Inspection of unit. The MODU or
lift boat must be available for inspection
by the District Manager before
commencing operations and at any time
during operations.
(g) Current Monitoring. For water
depths greater than 400 meters (1,312
feet), you must include in your APD or
APM:
(1) A description of the specific
current speeds that will cause you to
implement rig shutdown, move-off
procedures, or both; and
(2) A discussion of the specific
measures you will take to curtail rig
operations and move off location when
such currents are encountered. You may
use criteria such as current velocities,
riser angles, watch circles, and
remaining rig power to describe when
these procedures or measures will be
implemented.
§ 250.714 Do I have to develop a dropped
objects plan?
If you use a floating rig unit in an area
with subsea infrastructure, you must
develop a dropped objects plan and
make it available to BSEE upon request.
This plan must be updated as the
infrastructure on the seafloor changes.
Your plan must include:
(a) A description and plot of the path
the rig will take while running and
pulling the riser;
(b) A plat showing the location of any
subsea wells, production equipment,
pipelines, and any other identified
debris;
(c) Modeling of a dropped object’s
path with consideration given to
metocean conditions for various
material forms, such as a tubular (e.g.,
riser or casing) and box (e.g., BOP or
tree);
(d) Communications, procedures, and
delegated authorities established with
the production host facility to shut-in
any active subsea wells, equipment, or
pipelines in the event of a dropped
object; and
(e) Any additional information
required by the District Manager.
§ 250.715 Do I need a global positioning
system (GPS) for MODUs and jack-ups?
All jack-up and moored MODUs must
have a minimum of two functioning
GPS transponders at all times, and you
must provide to BSEE real-time access
to the GPS data prior to each hurricane
season.
(a) The GPS must be capable of
monitoring the position and tracking the
path in real-time if the moored MODU
or jack-up moves from its location
during a severe storm.
(b) You must install and protect the
tracking system’s equipment to
minimize the risk of the system being
disabled.
(c) You must place the GPS
transponders in different locations for
redundancy to minimize risk of system
failure.
(d) Each GPS transponder must be
capable of transmitting data for at least
7 days after a storm has passed.
(e) If the MODU is moved off location
in the event of a storm, you must
immediately begin to record the GPS
location data.
(f) Contact the Regional Office and
allow real-time access to the MODU or
jack-up location data. When you contact
the Regional Office, provide the
following:
(1) Name of the lessee and operator
with contact information;
(2) Rig/facility/platform name;
(3) Initial date and time; and
(4) How you will provide GPS realtime access.
Well Operations
§ 250.720
well?
When and how must I secure a
(a) Whenever you interrupt
operations, you must notify the District
Manager. Before moving off the well,
you must have two independent barriers
installed, at least one of which must be
a mechanical barrier, as approved by the
tkelley on DSK3SPTVN1PROD with PROPOSALS2
Casing type
(b) You must test each drilling liner
and liner-lap to a pressure at least equal
to the anticipated leak off pressure of
the formation below that liner shoe, or
subsequent liner shoes if set. You must
21:10 Apr 16, 2015
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§ 250.721 What are the requirements for
pressure testing casing and liners?
(a) You must test each casing string
that extends to the wellhead according
to the following table:
Minimum test pressure
(1) Drive or Structural, ..............................................................................
(2) Conductor, excluding subsea wellheads. ...........................................
(3) Surface, Intermediate, and Production, ..............................................
VerDate Sep<11>2014
District Manager. You must install the
barriers at appropriate depths within a
properly cemented casing string or liner.
Before removing a subsea BOP stack or
surface BOP stack on a mudline
suspension well, you must conduct a
negative pressure test in accordance
with § 250.721.
(1) The events that would cause you
to interrupt operations and notify the
District Manager include, but are not
limited to, the following:
(i) Evacuation of the rig crew;
(ii) Inability to keep the rig on
location;
(iii) Repair to major rig or well-control
equipment; or
(iv) Observed flow outside the well’s
casing (e.g., shallow water flow or
bubbling).
(2) The District Manager may approve
alternate procedures or barriers in
accordance with § 250.141 if you do not
have time to install the required barriers
or if special circumstances occur.
(b) Before you displace kill-weight
fluid from the wellbore and/or riser,
thereby creating an underbalanced state,
you must obtain approval from the
BSEE District Manager. To obtain
approval, you must submit with your
APD or APM your reasons for displacing
the kill-weight fluid and provide
detailed step-by-step written procedures
describing how you will safely displace
these fluids. The step-by-step
displacement procedures must address
the following:
(1) Number and type of independent
barriers, as described in § 250.420(b)(3),
that are in place for each flow path that
requires such barriers,
(2) Tests you will conduct to ensure
integrity of independent barriers,
(3) BOP procedures you will use
while displacing kill-weight fluids, and
(4) Procedures you will use to monitor
the volumes and rates of fluids entering
and leaving the wellbore.
Not required.
250 psi.
70 percent of its minimum internal yield.
conduct this test before you continue
operations in the well.
(c) You must test each production
liner and liner-lap to a minimum of 500
psi above the formation fracture
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pressure at the casing shoe into which
the liner is lapped.
(d) The District Manager may approve
or require other casing test pressures.
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(e) If you plan to produce a well, you
must:
(1) For a well that is fully cased and
cemented, pressure test the entire well
to maximum anticipated shut-in tubing
pressure before perforating the casing or
liner; or
(2) For an open-hole completion,
pressure test the entire well to
maximum anticipated shut-in tubing
pressure before you drill the open-hole
section.
(f) You may not resume operations
until you obtain a satisfactory pressure
test. If the pressure declines more than
10 percent in a 30-minute test, or if
there is another indication of a leak, you
must submit to the District Manager for
approval your proposed plans to recement, repair the casing or liner, or run
additional casing/liner to provide a
proper seal. Your submittal must
include a PE certification of your
proposed plans.
(g) You must perform a negative
pressure test on all wells that use a
subsea BOP stack or wells with mudline
suspension systems.
(1) You must perform a negative
pressure test on your final casing string
or liner. This test must be conducted
after setting your second barrier just
above the shoe track, but prior to
conducting any completion operations.
(2) You must perform a negative test
prior to unlatching the BOP at any point
in the well. The negative test must be
performed on those components, at a
minimum, that will be exposed to the
negative differential pressure that will
occur when the BOP is disconnected.
(3) The District Manager may require
you to perform additional negative
pressure tests on other casing strings or
liners (e.g., intermediate casing string or
liner) or on wells with a surface BOP
stack.
(4) You must submit for approval with
your APD or APM, test procedures and
criteria for a successful negative test. If
any of your test procedures or criteria
for a successful test change, you must
submit for approval the changes in a
revised APD or APM.
(5) You must document all your test
results and make them available to
BSEE upon request.
(6) If you have any indication of a
failed negative pressure test, such as,
but not limited to, pressure buildup or
observed flow, you must immediately
investigate the cause. If your
investigation confirms that a failure
occurred during the negative pressure
test, you must:
(i) Correct the problem and
immediately notify the appropriate
BSEE District Manager; and
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(ii) Submit a description of the
corrective action taken and receive
approval from the appropriate BSEE
District Manager for the retest.
(7) You must have two barriers in
place, as described in § 250.420(b)(3), at
any time and for any well, prior to
performing the negative pressure test.
(8) You must include documentation
of the successful negative pressure test
in the End-of-Operations Report (Form
BSEE–0125).
§ 250.722 What are the requirements for
prolonged operations in a well?
If wellbore operations continue
within a casing or liner for more than
30 days from the previous pressure test
of the well’s casing or liner, you must:
(a) Stop operations as soon as
practicable, and evaluate the effects of
the prolonged operations on continued
operations and the life of the well. At a
minimum, you must:
(1) Evaluate the well’s casing with
either a pressure test, caliper tool, or
imaging tool. On a case-by-case basis the
District Manager may require a specific
method of evaluation; and
(2) Report the results of your
evaluation to the District Manager and
obtain approval of those results before
resuming operations. Your report must
include calculations that show the
well’s integrity is above the minimum
safety factors.
(b) If well integrity has deteriorated to
a level below minimum safety factors,
you must:
(1) Obtain approval from the District
Manager to begin repairs or install
additional casing. To obtain approval,
you must also provide a PE certification
showing that he or she reviewed and
approved the proposed changes;
(2) Repair the casing or run another
casing string; and
(3) Perform a pressure test after the
repairs are made or additional casing is
installed and report the results to the
District Manager as specified in
§ 250.721.
§ 250.723 What additional safety measures
must I take when I conduct operations on
a platform that has producing wells or has
other hydrocarbon flow?
You must take the following safety
measures when you conduct operations
with a rig unit or lift boat on or jackedup over a platform with producing wells
or that has other hydrocarbon flow:
(a) The movement of rig units and
related equipment on and off a platform
or from well to well on the same
platform, including rigging up and
rigging down, must be conducted in a
safe manner;
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(b) You must install an emergency
shutdown station for the production
system near the rig operator’s console;
(c) You must shut-in all producible
wells located in the affected wellbay
below the surface and at the wellhead
when:
(1) You move a rig unit or related
equipment on and off a platform. This
includes rigging up and rigging down
activities within 500 feet of the affected
platform;
(2) You move or skid a rig unit
between wells on a platform; or
(3) A MODU or lift boat moves within
500 feet of a platform. You may resume
production once the MODU or lift boat
is in place, secured, and ready to begin
operations.
(d) All wells in the same well-bay
which are capable of producing
hydrocarbons must be shut-in below the
surface with a pump-through-type
tubing plug and at the surface with a
closed master valve prior to moving rig
units and related equipment unless
otherwise approved by the District
Manager.
(1) A closed surface-controlled
subsurface safety valve of the pumpthrough-type may be used in lieu of the
pump-through-type tubing plug
provided that the surface control has
been locked out of operation.
(2) The well to which a rig unit or
related equipment is to be moved must
be equipped with a back-pressure valve
prior to removing the tree and installing
and testing the BOP system.
(3) The well from which a rig unit or
related equipment is to be moved must
be equipped with a back pressure valve
prior to removing the BOP system and
installing the production tree.
(e) Coiled tubing units, snubbing
units, or wireline units may be moved
onto and off of a platform without
shutting in wells.
§ 250.724 What are the real-time
monitoring requirements?
(a) When conducting well operations
with a subsea BOP or surface BOP on a
floating facility or when operating in an
HPHT environment you must, within 3
years of publication of the final rule,
gather and monitor real-time well data
using an independent, automatic, and
continuous monitoring system capable
of recording, storing, and transmitting
all aspects of:
(1) The BOP control system;
(2) The well’s fluid handling systems
on the rig; and
(3) The well’s downhole conditions
with the bottom hole assembly tools (if
any tools are installed).
(b) You must immediately transmit
these data as they are gathered to a
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designated onshore location during
operations where they must be
monitored by qualified personnel who
must be in continuous contact with rig
personnel during operations. After
operations, you must preserve and store
this data at a designated location for
recordkeeping purposes as required in
§§ 250.740 and 250.741. You must
designate the location where the data
will be stored and monitored during
operations in your APD or APM. The
location and the data must be made
accessible to BSEE upon request.
(c) If you lose any real-time
monitoring capability during operations
covered by this section, you must
immediately notify the District Manager.
The District Manager may require other
measures until real-time monitoring
capability is restored.
Blowout Preventer (BOP) System
Requirements
§ 250.730 What are the general
requirements for BOP systems and system
components?
tkelley on DSK3SPTVN1PROD with PROPOSALS2
(a) You must design, install, maintain,
inspect, test, and use the BOP system
and system components to ensure well
control. The working-pressure rating of
each BOP component must exceed
MASP as defined for the operation. For
a subsea BOP, the MASP must be taken
at the mudline. The BOP system
includes the BOP stack, control system,
and any other associated system(s) and
equipment. The BOP system and
individual components must be able to
perform their expected functions and be
compatible with each other. Each ram
(excluding casing shear/supershear)
must be capable of closing and sealing
the wellbore at all times, including
under flowing conditions as defined for
the operation and specific well
conditions, without losing ram closure
time and sealing integrity due to the
corrosiveness, volume, and abrasiveness
of any fluids in the wellbore that you
may encounter. Your BOP system must
meet the following requirements:
(1) The BOP requirements of API
Standard 53 (incorporated by reference
in § 250.198) and the requirements of
§§ 250.733 through 250.739. If there is a
conflict between API Standard 53 and
the requirements of this subpart, you
must follow the requirements of this
subpart.
(2) The following industry standards
(all incorporated by reference in
§ 250.198):
(i) ANSI/API Spec. 6A;
(ii) ANSI/API Spec. 16A;
(iii) ANSI/API Spec. 16C;
(iv) API Spec. 16D; and
(v) ANSI/API Spec. 17D.
(3) For surface and subsea BOPs, the
pipe and variable bore rams installed in
the BOP stack must be capable of
effectively closing and sealing on the
tubular body of any drill pipe,
workstring, and tubing in the hole under
MASP, as defined for the operation,
with the proposed regulator settings of
the BOP control system.
(4) The current set of approved
schematic drawings must be available
on the rig and at an onshore location. If
you make any modifications to the BOP
or control system that will change your
BSEE-approved schematic drawings,
you must suspend operations until you
obtain approval from the District
Manager.
(b) You must design, fabricate,
maintain, and repair your BOP system
according to the requirements contained
in this subpart, OEM recommendations
unless otherwise directed by BSEE, and
recognized engineering practices. The
training and qualification of repair and
maintenance personnel must meet or
exceed any OEM training
recommendations unless otherwise
directed by BSEE.
(c) You must follow the failure
reporting procedures contained in API
Standard 53, ANSI/API Spec. 6A, and
ANSI/API Spec 16A, and:
(1) You must provide a written report
of equipment failure to the
manufacturer of such equipment within
30 days after the discovery and
identification of the failure.
(2) You must ensure that an
investigation and a failure analysis are
initiated within 60 days of the failure to
determine the cause of the failure. If the
investigation and analysis are performed
by an entity other than the
manufacturer, you must ensure that the
manufacturer receives a copy of the
analysis.
(3) If the equipment manufacturer
notifies you that it has changed the
design of the equipment that failed, or
if you have changed operating or repair
procedures as a result of a failure, then
you must, within 30 days of such notice
or change, report the design change or
modified procedures in writing to the
Chief, Office of Offshore Regulatory
Programs; Bureau of Safety and
Environmental Enforcement; HE 3314;
45600 Woodland Road, Sterling,
Virginia 20166.
(d) If you plan to use a BOP stack
manufactured after the effective date of
this regulation, you must use one
manufactured pursuant to an API Spec.
Q1 (as incorporated by reference in
§ 250.198) quality management system.
Such quality management system must
be certified by an entity that meets the
requirements of ISO 17011.
(1) The BSEE may consider accepting
equipment manufactured under quality
assurance programs other than API
Spec. Q1, provided you submit a request
to BSEE containing relevant information
about the alternative program and
receive BSEE approval under § 250.141.
(2) You must submit this request to
the Chief, Office of Offshore Regulatory
Programs; Bureau of Safety and
Environmental Enforcement; HE 3314:
45600 Woodland Road, Sterling,
Virginia 20166.
§ 250.731 What information must I submit
for BOP systems and system components?
For any operation that requires the
use of a BOP, you must include the
information listed in this section with
your applicable APD, APM, or other
submittal. You are required to submit
this information only once for each
well, unless the information changes
from what you provided in an earlier
approved submission or you have
moved off location from the well. After
you have submitted this information for
a particular well, subsequent APMs or
other submittals for the well should
reference the approved submittal
containing the information required by
this section and confirm that the
information remains accurate and that
you have not moved off location from
that well. If the information changes or
you have moved off location from the
well, you must submit updated
information in your next submission.
You must submit:
Including:
(a) A complete description of the BOP system and system components,
(1) Pressure ratings of BOP equipment;
(2) Proposed BOP test pressures (for subsea BOPs, include both surface and corresponding subsea pressures);
(3) Rated capacities for liquid and gas for the fluid-gas separator system;
(4) Control fluid volumes needed to close, seal, and open each component;
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You must submit:
Including:
(b) Schematic drawings, ...........................................................................
(c) Certification by a BSEE-approved verification organization,
(d) Additional certification by a BSEE-approved verification organization, if you use a subsea BOP, a BOP in an HPHT environment as
defined in § 250.807, or a surface BOP on a floating facility,
(e) If you are using a subsea BOP, descriptions of autoshear,
deadman, and emergency disconnect sequence (EDS) systems,
(f) Certification stating that the Mechanical Integrity Assessment Report
required in § 250.732(d) has been submitted within the past 12
months for a subsea BOP, a BOP being used in an HPHT environment as defined in § 250.807, or a surface BOP on a floating facility.
tkelley on DSK3SPTVN1PROD with PROPOSALS2
§ 250.732 What are the BSEE-approved
verification organization requirements for
BOP systems and system components?
(a) The BSEE will maintain a list of
BSEE-approved verification
organizations that you may use. For an
organization to become a BSEE
approved verification organization, it
must submit the following information
to the Chief, Office of Regulatory
Programs: Bureau of Safety and
Environmental Enforcement: 45600
Woodland Road, Sterling, Virginia,
20166, for BSEE review and approval:
21575
(5) Control system pressure and regulator settings needed to achieve
an effective seal of each ram BOP under MASP as defined for the
operation;
(6) Number and volume of accumulator bottles and bottle banks (for
subsea BOP, include both surface and subsea bottles);
(7) Accumulator pre-charge calculations (for subsea BOP, include both
surface and subsea calculations);
(8) All locking devices; and
(9) Control fluid volume calculations for the accumulator system (for a
subsea BOP system, include both the surface and subsea volumes).
(1) The inside diameter of the BOP stack,
(2) Number and type of preventers (including blade type for shear
ram(s)),
(3) All locking devices,
(4) Size range for variable bore ram(s),
(5) Size of fixed ram(s),
(6) All control systems with all alarms and set points labeled, including
pods,
(7) Location and size of choke and kill lines (and gas bleed line(s) for
subsea BOP),
(8) Associated valves of the BOP system,
(9) Control station locations, and
(10) A cross-section of the riser for a subsea BOP system showing
number, size, and labeling of all control, supply, choke, and kill lines
down to the BOP.
Verification that:
(1) Test data clearly demonstrates the shear ram(s) will shear the drill
pipe at the water depth as required in § 250.732;
(2) The BOP was designed, tested, and maintained to perform at the
most extreme anticipated conditions; and
(3) The accumulator system has sufficient fluid to function the BOP
system without assistance from the charging system.
Verification that:
(1) The BOP stack is designed for the specific equipment on the rig
and for the specific well design;
(2) The BOP stack has not been compromised or damaged from previous service; and
(3) The BOP stack will operate in the conditions in which it will be
used.
A listing of the functions with their sequences and timing.
(1) Previous experience in verification
or in the design, fabrication,
installation, repair, or major
modification of BOPs and related
systems and equipment;
(2) Technical capabilities;
(3) Size and type of organization;
(4) In-house availability of, or access
to, appropriate technology. This should
include computer programs, hardware,
and testing materials and equipment;
(5) Ability to perform the verification
functions for projects considering
current commitments;
(6) Previous experience with BSEE
requirements and procedures; and
(7) Any additional information that
may be relevant to BSEE’s review.
(b) Prior to beginning any operation
requiring the use of any BOP, you must
submit verification by a BSEE-approved
verification organization and supporting
documentation as required by this
paragraph to the appropriate District
Manager and Regional Supervisor.
You must submit verification and documentation related to:
That:
(1) Shear testing, ......................................................................................
(i) Demonstrates that the BOP will shear the drill pipe and any electric-,
wire-, and slick-line to be used in the well;
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You must submit verification and documentation related to:
(2) Pressure integrity testing, and ............................................................
(3) Calculations. ........................................................................................
(c) For wells in an HPHT
environment, as defined by § 250.807(b),
you must submit verification by a BSEEapproved verification organization that
the verification organization conducted
a comprehensive review of the BOP
That:
(ii) Demonstrates the use of test protocols and analysis that represent
recognized engineering practices for ensuring the repeatability and
reproducibility of the tests, and that the testing was performed by a
facility that meets generally accepted quality assurance standards;
(iii) Provides a reasonable representation of field applications, taking
into consideration the physical and mechanical properties of the drill
pipe;
(iv) Ensures testing was performed on the outermost edges of the
shearing blades of the positioning mechanism as required in
§ 250.734(a)(16);
(v) Demonstrates the shearing capacity of the BOP equipment to the
physical and mechanical properties of the drill pipe; and
(vi) Includes all testing results.
(i) Shows that testing is conducted immediately after the shearing
tests;
(ii) Demonstrates that the equipment will seal at the rated working
pressure of the BOP for 30 minutes; and
(iii) Includes all test results.
Include shearing and sealing pressures for all pipe to be used in the
well including corrections for MASP.
system and related equipment you
propose to use. You must provide the
BSEE-approved verification
organization access to any facility
associated with the BOP system or
related equipment during the review
process. You must submit the
verifications required by this paragraph
to the appropriate District Manager and
Regional Supervisor before you begin
any operations in an HPHT environment
with the proposed equipment.
You must submit:
Including:
tkelley on DSK3SPTVN1PROD with PROPOSALS2
(1) Verification that the verification organization conducted a detailed
review of the design package to ensure that all critical components
and systems meet recognized engineering practices,
(2) Verification that the designs of individual components and the overall system have been proven in a testing process that demonstrates
the performance and reliability of the equipment in a manner that is
repeatable and reproducible,
(3) Verification that the BOP equipment will perform as designed in the
temperature, pressure, and environment that will be encountered,
and
(4) Verification that the fabrication, manufacture, and assembly of individual components and the overall system uses recognized engineering practices and quality control and assurance mechanisms.
(d) Once every 12 months, you must
submit a Mechanical Integrity
Assessment Report for a subsea BOP, a
BOP being used in an HPHT
environment as defined in § 250.807, or
a surface BOP on a floating facility. This
report must be completed by a BSEEapproved verification organization. You
must submit this report to the Chief,
Office of Regulatory Programs: Bureau
of Safety and Environmental
Enforcement: 45600 Woodland Road,
Sterling, Virginia, 20166. This report
must include:
(1) A determination that the BOP
stack and system meets or exceeds all
BSEE regulatory requirements, industry
standards incorporated into this
subpart, and recognized engineering
practices.
(2) Verification that complete
documentation of the equipment’s
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(i) Identification of all reasonable potential modes of failure, and
(ii) Evaluation of the design verification tests. The design verification
tests must assess the equipment for the identified potential modes of
failure.
For the quality control and assurance mechanisms, complete material
and quality controls over all contractors, subcontractors, distributors,
and suppliers at every stage in the fabrication, manufacture, and assembly process.
service life exists that demonstrates that
the BOP stack has not been
compromised or damaged during
previous service.
(3) A description of all inspection,
repair and maintenance records
reviewed, and verification that all
repairs, replacement parts, and
maintenance meet regulatory
requirements, recognized engineering
practices, and OEM specifications.
(4) A description of records reviewed
related to any modifications to the
equipment and verification that any
such changes do not adversely affect the
equipment’s capability to perform as
designed or invalidate test results.
(5) A description of the Safety and
Environmental Management Systems
(SEMS) plans reviewed related to
assurance of quality and mechanical
integrity of critical equipment and
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verification that the plans are
comprehensive and fully implemented.
(6) Verification that the qualification
and training of inspection, repair, and
maintenance personnel for the BOP
systems meet recognized engineering
practices and OEM requirements.
(7) A description of all records
reviewed covering OEM safety alerts, all
failure reports, and verification that any
design or maintenance issues have been
completely identified and corrected.
(8) A comprehensive assessment of
the overall system and verification that
all components (including mechanical,
hydraulic, electrical, and software) are
compatible.
(9) Verification that documentation
exists concerning the traceability of the
fabrication, repair, and maintenance of
all critical components.
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(10) Verification of use of a formal
maintenance tracking system to ensure
that corrective maintenance and
scheduled maintenance is implemented
in a timely manner.
(11) Identification of gaps or
deficiencies related to inspection and
maintenance procedures and
documentation, documentation of any
deferred maintenance, and verification
of the completion of corrective action
plans.
(12) Verification that any inspection,
maintenance, or repair work meets the
manufacturer’s design and material
specifications.
(13) Verification of written procedures
for operating the BOP stack and LMRP
(including proper techniques to prevent
accidental disconnection of these
components) and minimum knowledge
requirements for personnel authorized
to operate and maintain BOP
components.
(14) Recommendations, if any, for
how to improve the fabrication,
installation, operation, maintenance,
inspection, and repair of the equipment.
(e) You must make all documentation
that supports the requirements of this
section available to BSEE upon request.
§ 250.733 What are the requirements for a
surface BOP stack?
(a) When you drill or conduct
operations with a surface BOP stack,
you must install the BOP system before
drilling or conducting operations to
deepen the well below the surface
casing and after the well is deepened
below the surface casing point. The
surface BOP stack must include at least
four remote-controlled, hydraulically
operated BOPs, consisting of one
annular BOP, one BOP equipped with
blind-shear rams, and two BOPs
equipped with pipe rams.
(1) The blind-shear rams must be
capable of shearing at any point along
the tubular body of any drill pipe
(excluding tool joints, bottom-hole tools,
and bottom hole assemblies that include
heavy-weight pipe or collars),
workstring, tubing, and any electric-,
wire-, and slick-line that is in the hole
and sealing the wellbore after shearing.
If your blind-shear rams are unable to
cut any electric-, wire-, or slick-line
under MASP as defined for the
operation and seal the wellbore, you
must use an alternative cutting device
capable of shearing the lines before
closing the BOP. This device must be
available on the rig floor during
operations that require their use.
(2) The two BOPs equipped with pipe
rams must be capable of closing and
sealing on the tubular body of any drill
pipe, workstring, and tubing under
MASP, as defined for the operation,
excluding the bottom hole assembly that
includes heavy-weight pipe or collars,
and bottom-hole tools.
(b) If you plan to use a surface BOP
on a floating production facility you
must:
(1) Follow the BOP requirements in
§ 250.734(a)(1). You must comply with
this requirement within 5 years from the
publication of the final rule.
(2) Use a dual bore riser configuration,
for risers installed after the effective
date of this rule, before drilling or
operating in any hole section or interval
where hydrocarbons are, or may be,
exposed to the well. The dual bore riser
must meet the design requirements of
API RP 2RD (as incorporated by
reference in § 250.198) including
appropriate design for the most extreme
anticipated operating and
environmental conditions.
(i) For a dual bore riser configuration,
the annulus between the risers must be
monitored during operations. You must
describe in your APD or APM your
annulus monitoring plan and how you
will secure the well in the event a leak
is detected.
(ii) The inner riser for a dual riser
configuration is subject to the
requirements for testing the casing or
liner at § 250.721.
(c) You must install separate side
outlets on the BOP stack for the kill and
21577
choke lines. If your stack does not have
side outlets, you must install a drilling
spool with side outlets. The outlet
valves must hold pressure from both
directions.
(d) You must install a choke and a kill
line on the BOP stack. You must equip
each line with two full-bore, fullopening valves, one of which must be
remote-controlled. On the kill line, you
may install a check valve and a manual
valve instead of the remote-controlled
valve. To use this configuration, both
manual valves must be readily
accessible and you must install the
check valve between the manual valves
and the pump.
(e) You must install hydraulically
operated locks.
(f) For a surface BOP used in HPHT
environments, if operations are
suspended to make repairs to any part
of the BOP system, you must stop
operations at a safe downhole location.
Before resuming operations you must:
(1) Submit a revised APD or APM
including documentation of the repairs
and a certification from a BSEEapproved verification organization
stating that they reviewed the repairs,
and that the BOP is fit for service; and
(2) Receive approval from the District
Manager.
§ 250.734 What are the requirements for a
subsea BOP system?
(a) When you drill or conduct
operations with a subsea BOP system,
you must install the BOP system before
drilling to deepen the well below the
surface casing or conducting operations
if the well is already deepened beyond
the surface casing point. The District
Manager may require you to install a
subsea BOP system before drilling or
conducting operations below the
conductor casing if proposed casing
setting depths or local geology indicate
the need. The following table outlines
your requirements.
Additional requirements
(1) Have at least five remote-controlled, hydraulically operated BOPs;
tkelley on DSK3SPTVN1PROD with PROPOSALS2
When operating with a subsea BOP system, you must:
You must have at least one annular BOP, two BOPs equipped with
pipe rams, and two BOPs equipped with shear rams. For the two
shear ram requirement, you must comply with this requirement within
5 years from the publication of the final rule.
(i) Both BOPs equipped with pipe rams must be capable of closing and
sealing on the tubular body of any drill pipe, workstring, and tubing
under MASP, as defined for the operation, excluding the bottom hole
assembly that includes heavy-weight pipe or collars, and bottom-hole
tools.
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When operating with a subsea BOP system, you must:
Additional requirements
(ii) Both shear rams must be capable of shearing at any point along
the tubular body of any drill pipe (excluding tool joints, bottom-hole
tools, and bottom hole assemblies that includes heavy-weight pipe or
collars), workstring, tubing, appropriate area for the liner or casing
landing string, shear sub on subsea test tree, and any electric-, wire, slick-line in the hole under MASP. At least one shear ram must be
capable of sealing the wellbore after shearing under MASP conditions as defined for the operation. Any non-sealing shear rams must
be installed below the sealing shear rams.
(2) Have an operable dual-pod control system to ensure proper and
independent operation of the BOP system;
(3) Have the accumulator capacity located subsea, to provide fast closure of the BOP components and to operate all critical functions in
case of a loss of the power fluid connection to the surface;
(4) Have a subsea BOP stack equipped with remotely operated vehicle
(ROV) intervention capability;
(5) Maintain an ROV and have a trained ROV crew on each rig unit on
a continuous basis once BOP deployment has been initiated from
the rig until recovered to the surface. The crew must examine all
ROV related well-control equipment (both surface and subsea) to ensure that it is properly maintained and capable of shutting in the well
during emergency operations;
(6) Provide autoshear, deadman, and EDS systems for dynamically positioned rigs; provide autoshear and deadman systems for moored
rigs;
tkelley on DSK3SPTVN1PROD with PROPOSALS2
(7) Demonstrate that any acoustic control system will function in the
proposed environment and conditions;
(8) Have operational or physical barrier(s) on BOP control panels to
prevent accidental disconnect functions;
(9) Clearly label all control panels for the subsea BOP system;
(10) Develop and use a management system for operating the BOP
system, including the prevention of accidental or unplanned disconnects of the system;
(11) Establish minimum requirements for personnel authorized to operate critical BOP equipment;
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The accumulator capacity must:
(i) Function each required shear ram, choke and kill side outlet valves,
one pipe ram, and disconnect the LMRP.
(ii) Have the capability of delivering fluid to each ROV function i.e., flying leads.
(iii) Have dedicated independent bottles for the autoshear, deadman,
and EDS systems.
(iv) Perform under MASP conditions as defined for the operation.
The ROV must be capable of performing critical functions, including
opening and closing each shear ram, choke and kill side outlet
valves, all pipe rams, and LMRP disconnect under MASP conditions
as defined for the operation. The ROV panels on the BOP and
LMRP must be compliant with API RP 17H (as incorporated by reference in § 250.198).
The crew must be trained in the operation of the ROV. The training
must include simulator training on stabbing into an ROV intervention
panel on a subsea BOP stack. The ROV crew must be in communication with designated rig personnel who are knowledgeable about
the BOP’s capabilities.
(i) Autoshear system means a safety system that is designed to automatically shut-in the wellbore in the event of a disconnect of the
LMRP. This is considered a rapid discharge system.
(ii) Deadman system means a safety system that is designed to automatically shut-in the wellbore in the event of a simultaneous absence
of hydraulic supply and signal transmission capacity in both subsea
control pods. This is considered a rapid discharge system.
(iii) Emergency Disconnect Sequence (EDS) system means a safety
system that is designed to be manually activated to shut-in the
wellbore and disconnect the LMRP in the event of an emergency situation. This is considered a rapid discharge system.
(iv) Each emergency function must close at a minimum, two shear
rams in sequence and be capable of performing their expected
shearing and sealing action under MASP conditions as defined for
the operation.
(v) Your sequencing must allow a sufficient delay for closing the upper
shear ram after beginning closure of the lower shear ram to provide
for maximum shearing efficiency.
(vi) The control system for the emergency functions must be a fail-safe
design, and the logic must provide for the subsequent step to be
independent from the previous step having to be completed.
If you choose to install an acoustic control system in addition to the
autoshear, deadman, and EDS requirements, you must demonstrate
to the District Manager, as part of the information submitted under
§ 250.731, that the acoustic system will function in the proposed environment and conditions. The District Manager may require additional information.
Incorporate enable buttons on control panels to ensure two-handed operation for all critical functions.
Label other BOP control panels such as hydraulic control panel.
The management system must include written procedures for operating
the BOP stack and LMRP (including proper techniques to prevent
accidental disconnection of these components) and minimum knowledge requirements for personnel authorized to operate and maintain
BOP components.
Personnel must have:
(i) Training in deepwater well-control theory and practice according to
the requirements of Subpart O; and
(ii) A comprehensive knowledge of BOP hardware and control systems.
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When operating with a subsea BOP system, you must:
Additional requirements
(12) Before removing the marine riser, displace the fluid in the riser
with seawater;
You must maintain sufficient hydrostatic pressure or take other suitable
precautions to compensate for the reduction in pressure and to
maintain a safe and controlled well condition. You must follow the requirements of § 250.720(b).
Your well cellar must be deep enough to ensure that the top of the
stack is below the deepest probable ice-scour depth.
(i) If your stack does not have side outlets, you must install a drilling
spool with side outlets.
(ii) Each side outlet must have two full-bore, full-opening valves.
(iii) The valves must hold pressure from both directions and must be
remote-controlled.
(iv) You must install a side outlet below each sealing shear ram. You
may have a pipe ram or rams between the shearing ram and side
outlet.
(i) The valves must hold pressure from both directions;
(ii) If you have dual annulars, where one annular is on the LMRP and
one annular is on the lower BOP stack, you must install a gas bleed
line on each annular.
(i) A mechanism coupled with each shear ram to position the entire
pipe, including connection, completely within the area of the shearing
blade and ensure shearing will occur any time the shear rams are
activated. This mechanism cannot be another ram BOP or annular
preventer, but you may use those during a planned shear. You must
install this mechanism within 7 years from the publication of the final
rule;
(ii) The ability to mitigate compression of the pipe stub between the
shearing rams when both shear rams are closed;
(iii) If your control pods contain a subsea electronic module with batteries, a mechanism for personnel on the rig to monitor the state of
charge of the subsea electronic module batteries in the BOP control
pods.
(13) Install the BOP stack in a well cellar when in an ice-scour area;
(14) Install at least two side outlets for a choke line and two side outlets for a kill line;
(15) Install a gas bleed line with two valves for the annular preventer; ..
(16) Use a BOP system that has the following mechanisms and capabilities:
tkelley on DSK3SPTVN1PROD with PROPOSALS2
(b) If operations are suspended to
make repairs to any part of the subsea
BOP system, you must stop operations
at a safe downhole location. Before
resuming operations you must:
(1) Submit a revised permit with a
verification report from a BSEEapproved verification organization
documenting the repairs and that the
BOP is fit for service;
(2) Perform a new BOP test in
accordance with §§ 250.737 and 250.738
upon relatch including deadman and
ROV intervention; and
(3) Receive approval from the District
Manager.
(c) If you plan to drill a new well with
a subsea BOP, you do not need to
submit with your APD the verifications
required by this subpart for the open
water drilling operation. Before drilling
out the surface casing, you must submit
for approval a revised APD, including
the verifications required in this
subpart.
§ 250.735 What associated systems and
related equipment must all BOP systems
include?
All BOP systems must include the
following associated systems and
related equipment:
(a) A surface accumulator system that
provides 1.5 times the volume of fluid
capacity necessary to close and hold
closed all BOP components against
MASP. The system must operate under
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MASP conditions as defined for the
operation. You must be able to operate
all BOP functions without assistance
from a charging system, with the blind
shear ram being the last in the sequence,
and still have enough pressure to shear
pipe and seal the well with a minimum
pressure of 200 psi remaining on the
bottles above the precharge pressure. If
you supply the accumulator regulators
by rig air and do not have a secondary
source of pneumatic supply, you must
equip the regulators with manual
overrides or other devices to ensure
capability of hydraulic operations if rig
air is lost;
(b) An automatic backup to the
primary accumulator-charging system.
The power source must be independent
from the power source for the primary
accumulator-charging system. The
independent power source must possess
sufficient capability to close and hold
closed all BOP components under
MASP conditions as defined for the
operation;
(c) At least two full BOP control
stations. One station must be on the rig
floor. You must locate the other station
in a readily accessible location away
from the rig floor;
(d) The choke line(s) installed above
the bottom well-control ram;
(e) The kill line that may be installed
below the bottom ram, but it must be
installed beneath at least one pipe ram;
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(f) A fill-up line above the uppermost
BOP;
(g) Hydraulically operated locking
devices installed on the sealing ramtype BOPs; and
(h) A wellhead assembly with a rated
working pressure that exceeds the
maximum anticipated wellhead
pressure.
§ 250.736 What are the requirements for
choke manifolds, kelly valves, inside BOPs,
and drill string safety valves?
(a) Your BOP system must include a
choke manifold that is suitable for the
anticipated surface pressures,
anticipated methods of well control, the
surrounding environment, and the
corrosiveness, volume, and abrasiveness
of drilling fluids and well fluids that
you may encounter.
(b) Choke manifold components must
have a rated working pressure at least as
great as the rated working pressure of
the ram BOPs. If your choke manifold
has buffer tanks downstream of choke
assemblies, you must install isolation
valves on any bleed lines.
(c) Valves, pipes, flexible steel hoses,
and other fittings upstream of the choke
manifold must have a rated working
pressure at least as great as the rated
working pressure of the ram BOPs.
(d) You must use the following BOP
equipment with a rated working
pressure and temperature of at least as
great as the working pressure and
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temperature of the ram BOP during all
operations:
(1) A kelly valve installed below the
swivel (upper kelly valve);
(2) A kelly valve installed at the
bottom of the kelly (lower kelly valve).
You must be able to strip the lower kelly
valve through the BOP stack;
(3) If you operate with a mud motor
and use drill pipe instead of a kelly, one
kelly valve installed above, and one
strippable kelly valve installed below,
the joint of pipe used in place of a kelly;
(4) On a top-drive system equipped
with a remote-controlled valve, a
strippable kelly-type valve installed
below the remote-controlled valve;
(5) An inside BOP in the open
position located on the rig floor. You
must be able to install an inside BOP for
each size connection in the pipe;
(6) A drill string safety valve in the
open position located on the rig floor.
You must have a drill-string safety valve
available for each size connection in the
pipe;
(7) When running casing, a safety
valve in the open position available on
You must conduct a .
.
the rig floor to fit the casing string being
run in the hole;
(8) All required manual and remotecontrolled kelly valves, drill-string
safety valves, and comparable-type
valves (i.e., kelly-type valve in a topdrive system) that are essentially full
opening; and
(9) A wrench to fit each manual valve.
Each wrench must be readily accessible
to the drilling crew.
§ 250.737 What are the BOP system
testing requirements?
Your BOP system (this includes the
choke manifold, kelly valves, inside
BOP, and drill string safety valve) must
meet the following testing requirements:
(a) Pressure test frequency. You must
pressure test your BOP system:
(1) When installed;
(2) Before 14 days have elapsed since
your last BOP pressure test, or 30 days
since your last blind-shear ram BOP
pressure test. You must begin to test
your BOP system before midnight on the
14th day (or 30th day for your blindshear rams) following the conclusion of
the previous test;
.
(3) Before drilling out each string of
casing or a liner. You may omit this
pressure test requirement if you did not
remove the BOP stack to run the casing
string or liner, the required BOP test
pressures for the next section of the hole
are not greater than the test pressures for
the previous BOP test, and the time
elapsed between tests has not exceeded
14 days (or 30 days for blind-shear
rams). You must indicate in your APD
which casing strings and liners meet
these criteria;
(4) The District Manager may require
more frequent testing if conditions or
your BOP performance warrants.
(b) Pressure test procedures. When
you pressure test the BOP system, you
must conduct a low-pressure test and a
high-pressure test for each BOP
component. You must begin each test by
conducting the low-pressure test then
transition to the high-pressure test. Each
individual pressure test must hold
pressure long enough to demonstrate the
tested component(s) holds the required
pressure. The table in this paragraph
outlines your pressure test
requirements.
According to the following procedures .
(1) Low-pressure test ...............................................................................
(2) High-pressure test for blind-shear ram-type BOPs, ram-type BOPs,
the choke manifold, outside of all choke and kill side outlet valves
(and annular gas bleed valves for subsea BOP), inside of all choke
and kill side outlet valves below uppermost ram, and other BOP
components.
(3) High-pressure test for annular-type BOPs, inside of choke or kill
valves (and annular gas bleed valves for subsea BOP) above the uppermost ram BOP.
(c) Duration of pressure test. Each test
must hold the required pressure for 5
minutes, which must be recorded on a
chart not exceeding 4 hours. However,
for surface BOP systems and surface
equipment of a subsea BOP system, a 3minute test duration is acceptable if
.
.
All low-pressure tests must be between 250 and 350 psi. Any initial
pressure above 350 psi must be bled back to a pressure between
250 and 350 psi before starting the test. If the initial pressure exceeds 500 psi, you must bleed back to zero and reinitiate the test.
The high-pressure test must equal the rated working pressure of the
equipment or be 500 psi greater than your calculated MASP, as defined for the operation for the applicable section of hole. Before you
may test BOP equipment to the MASP plus 500 psi, the District
Manager must have approved those test pressures in your APD.
The high pressure test must equal 70 percent of the rated working
pressure of the equipment or be 500 psi greater than your calculated
MASP, as defined for the operation for the applicable section of hole.
Before you may test BOP equipment to the MASP plus 500 psi, the
District Manager must have approved those test pressures in your
APD.
recorded on a chart not exceeding 4
hours, or on a digital recorder. The
recorded test pressures must be within
the middle half of the chart range, i.e.,
cannot be within the lower or upper
one-fourth of the chart range. If the
equipment does not hold the required
pressure during a test, you must correct
the problem and retest the affected
component(s).
(d) Additional test requirements. You
must meet the following additional BOP
testing requirements:
tkelley on DSK3SPTVN1PROD with PROPOSALS2
You must . . .
Additional requirements . . .
(1) Follow the testing requirements of API Standard 53 (as incorporated in § 250.198).
(2) Use water to test a surface BOP system. ..........................................
If there is a conflict between API Standard 53 testing requirements and
this section, you must follow the requirements of this section.
(i) You must submit test procedures with your APD or APM for District
Manager approval.
(ii) Contact the District Manager at least 72 hours prior to beginning the
test to allow BSEE representative(s) to witness testing. If BSEE representative(s) are unable to witness testing, you must provide the
test results to the appropriate District Manager within 72 hours after
completion of the tests.
(i) You must use water to conduct this test. You may use drilling fluids
to conduct subsequent tests of a subsea BOP system.
(3) Stump test a subsea BOP system before installation. .......................
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You must . . .
Additional requirements . . .
(4) Perform an initial subsea BOP test. ...................................................
(5) Alternate tests between control stations and pods. ...........................
(6) Pressure test variable bore-pipe ram BOPs against the largest and
smallest sizes of pipe in use, excluding the bottom hole assembly
that includes heavy-weight pipe or collars and bottom-hole tools.
(7) Pressure test annular type BOPs against the smallest pipe in use.
(8) Pressure test affected BOP components following the disconnection
or repair of any well-pressure containment seal in the wellhead or
BOP stack assembly.
(9) Function test annular and pipe/variable bore ram BOPs every 7
days between pressure tests.
(10) Function test blind-shear ram BOPs every 14 days.
(11) Actuate safety valves assembled with proper casing connections
before running casing.
(12) Test and verify closure capability of all ROV intervention functions
on your subsea BOP.
tkelley on DSK3SPTVN1PROD with PROPOSALS2
(13) Function test autoshear, deadman, and EDS systems separately
on your subsea BOP stack during the stump test. The District Manager may require additional testing of the emergency systems. You
must also test the deadman system and verify closure of the shearing rams during the initial test on the seafloor.
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(ii) You must submit test procedures with your APD or APM for District
Manager approval.
(iii) Contact the District Manager at least 72 hours prior to beginning
the stump test to allow BSEE representative(s) to witness testing. If
BSEE representative(s) are unable to witness testing, you must provide the test results to the appropriate District Manager within 72
hours after completion of the tests.
(iv) You must test and verify closure of all ROV intervention functions
on your subsea BOP stack during the stump test.
(v) You must follow (b) and (c) of this section.
(i) You must perform the initial subsea BOP test on the seafloor within
30 days of the stump test.
(ii) You must submit test procedures with your APD or APM for District
Manager approval.
(iii) You must pressure test well-control rams according to (b) and (c)
of this section.
(iv) You must notify the District Manager at least 72 hours prior to beginning the initial subsea test for the BOP system to allow BSEE
representative(s) to witness testing.
(v) You must test and verify closure of at least one set of rams during
the initial subsea test through a ROV hot stab. You must pressure
test the selected rams according to (b) and (c) of this section.
(i) For two complete BOP control stations:
(A) Designate a primary and secondary station, and both stations must
be function-tested weekly,
(B) The control station used for the pressure test must be alternated
between pressure tests, and
(C) For a subsea BOP, the pods must be rotated between control stations during weekly function testing, and the pod used for pressure
testing must be alternated between pressure tests.
(ii) Any additional control stations must be function tested every 14
days.
(i) Each ROV must be fully compatible with the BOP stack ROV intervention panels.
(ii) You must submit test procedures, including how you will test each
ROV intervention function, with your APD or APM for District Manager approval.
(iii) You must document all your test results and make them available
to BSEE upon request.
(i) You must submit test procedures with your APD or APM for District
Manager approval. The procedures for these function tests must include the schematics of the actual controls and circuitry of the system that will be used during an actual autoshear or deadman event.
(ii) The procedures must also include the actions and sequence of
events that take place on the approved schematics of the BOP control system and describe specifically how the ROV will be utilized
during this operation.
(iii) When you conduct the initial deadman system test on the seafloor,
you must ensure the well is secure and, if hydrocarbons have been
present, appropriate barriers are in place to isolate hydrocarbons
from the wellhead. You must also have an ROV on bottom during
the test.
(iv) The testing of the deadman system on the seafloor must indicate
the discharge pressure of the subsea accumulator system throughout the test.
(v) For the function test of the deadman system during the initial test
on the seafloor, you must have the ability to quickly disconnect the
LMRP should the rig experience a loss of station-keeping event. You
must include your quick-disconnect procedures with your deadman
test procedures.
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You must . . .
Additional requirements . . .
(vi) You must pressure test the blind-shear ram(s) according to (b) and
(c) of this section.
(vii) If a casing shear ram is installed, you must describe how you will
verify closure of the ram.
(viii) You must document all your test results and make them available
to BSEE upon request.
(e) Prior to conducting any shear ram
tests in which you will shear pipe, you
must notify the BSEE District Manager
at least 72 hours in advance, to ensure
that a representative of BSEE will have
access to the location to witness any
testing.
§ 250.738 What must I do in certain
situations involving BOP equipment or
systems?
The table in this section describes
actions that you must take when certain
situations occur with BOP systems.
If you encounter the following situation:
Then you must . . .
(a) BOP equipment does not hold the required pressure during a test;
Correct the problem and retest the affected equipment. You must report any problems or irregularities, including any leaks, to the District
Manager and on the daily report as required in § 250.746.
(1) First place the well in a safe, controlled condition as approved by
the District Manager (e.g., before drilling out a casing shoe or after
setting a cement plug, bridge plug, or a packer).
(2) Any repair or replacement parts must be manufactured under a
quality assurance program and must meet or exceed the performance of the original part produced by the OEM.
(3) You must receive approval from the District Manager prior to resuming operations with the new, repaired, or reconfigured BOP. You
must submit a report from a BSEE-approved verification organization
to the District Manager certifying that the BOP is fit for service.
Record the reason for postponing the test in the daily report and conduct the required BOP test on the first trip out of the hole.
Suspend operations until that station or pod is operable. You must report any problems or irregularities, including any leaks, to the District
Manager.
Install two or more sets of conventional or variable-bore pipe rams in
the BOP stack to provide for the following: two sets of rams must be
capable of sealing around the larger-size drill string and two sets of
pipe rams must be capable of sealing around the smaller size pipe,
excluding the bottom hole assembly that includes heavy weight pipe
or collars and bottom-hole tools.
Test the ram bonnets before running casing to the rated working pressure or MASP plus 500 psi. The BOP must also provide for sealing
the well after casing is sheared. If this installation was not included
in your approved permit, and changes the BOP configuration approved in the APD or APM, you must notify and receive approval
from the District Manager.
Demonstrate that your well-control procedures or the anticipated well
conditions will not place demands above its rated working pressure
and obtain approval from the District Manager.
Install the BOP stack in a well cellar. The well cellar must be deep
enough to ensure that the top of the stack is below the deepest
probable ice-scour depth.
Retrieve, physically inspect, and conduct a full pressure test of the
BOP stack after the situation is fully controlled. You must submit to
the District Manager a report from a BSEE-approved verification organization certifying that the BOP is fit to return to service.
Have a minimum of two barriers in place prior to BOP removal. You
must obtain approval from the District Manager of the two barriers
prior to removal and the District Manager may require additional barriers.
Place the blind-shear ram opening function in the block position prior to
re-establishing power to the stack. Contact the District Manager and
receive approval of procedures for re-establishing power and functions prior to latching up the BOP stack or re-establishing power to
the stack.
Conduct the initial BOP test after latching up using a test tool, and test
the wellhead/BOP connection to the maximum pressure for the approved ram test for the well. All hydraulically operated BOP components must also be functioned during the well connection test.
(b) Need to repair, replace, or reconfigure a surface or subsea BOP
system;
(c) Need to postpone a BOP test due to well-control problems such as
lost circulation, formation fluid influx, or stuck pipe;.
(d) BOP control station or pod that does not function properly; ..............
(e) Plan to operate with a tapered string; ................................................
(f) Plan to install casing rams or casing shear rams in a surface BOP
stack;.
(g) Plan to use an annular BOP with a rated working pressure less
than the anticipated surface pressure;.
(h) Plan to use a subsea BOP system in an ice-scour area; ..................
(i) You activate any shear ram and pipe or casing is sheared; ...............
tkelley on DSK3SPTVN1PROD with PROPOSALS2
(j) Need to remove the BOP stack; ..........................................................
(k) In the event of a deadman or autoshear activation, if there is a possibility of the blind-shear ram opening immediately upon re-establishing power to the BOP stack;
(l) If a test ram is to be used; ...................................................................
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If you encounter the following situation:
Then you must . . .
(m) Plan to utilize any other well-control equipment (e.g., but not limited
to, subsea isolation device, subsea accumulator module, or gas handler) that is in addition to the equipment required in this subpart;
Contact the District Manager and request approval in your APD or
APM. Your request must include a report from a BSEE-approved
verification organization on the equipment’s design and suitability for
its intended use as well as any other information required by the District Manager. The District Manager may impose any conditions regarding the equipment’s capabilities, operation, and testing.
Indicate in your APD or APM which pipe/variable bore rams meet
these criteria and clearly label them on all BOP control panels. You
do not need to function test or pressure test pipe/variable bore rams
having no current utility, and that will not be used for well-control
purposes, until such time as they are intended to be used during operations.
Comply with all testing, maintenance, and inspection requirements in
this subpart that are applicable to those well-control components. If
any redundant component fails a test, you must submit a report from
a BSEE-approved verification organization that describes the failure,
and confirms that there is no impact on the BOP that will make it
unfit for well-control purposes. You must submit this report to the
District Manager and receive approval before resuming operations.
The District Manager may require additional information.
Ensure that the well has been stable for a minimum of 30 minutes prior
to positioning the bottom hole assembly across the BOP. You must
have, as part of your well-control plan required by § 250.710, procedures that enable the immediate removal of the bottom hole assembly from across the BOP in the event of a well control or emergency
situation (for dynamically positioned rigs, your plan must also include
steps for when the EDS must be activated) before MASP conditions
are reached as defined for the operation.
(n) You have pipe/variable bore rams that have no current utility or
well-control purposes;
(o) You install redundant components for well control in your BOP system that are in addition to the required components of this subpart
(e.g., pipe/variable bore rams, shear rams, annular preventers, gas
bleed lines, and choke/kill side outlets or lines);
(p) Need to position the bottom hole assembly, including heavy-weight
pipe or collars, and bottom-hole tools across the BOP for tripping or
any other operations.
tkelley on DSK3SPTVN1PROD with PROPOSALS2
§ 250.739 What are the BOP maintenance
and inspection requirements?
(a) You must maintain and inspect
your BOP system to ensure that the
equipment functions as designed. The
BOP maintenance and inspections must
meet or exceed any OEM
recommendations, recognized
engineering practices, and industry
standards incorporated by reference into
the regulations of this subpart,
including API Standard 53
(incorporated by reference in § 250.198).
You must document how you met or
exceeded the provisions of API
Standard 53, maintain complete records
to ensure the traceability of all critical
components beginning at fabrication,
and record the results of your BOP
inspections and maintenance actions.
You must make all records available to
BSEE upon request.
(b) A complete breakdown and
detailed physical inspection of the BOP
and every associated system and
component must be performed every 5
years. This complete breakdown and
inspection may not be performed in
phased intervals. A BSEE-approved
verification organization is required to
be present during the inspection and
must compile a detailed report
documenting the inspection, including
descriptions of any problems and how
they were corrected. You must make
this report available to BSEE upon
request.
(c) You must visually inspect your
surface BOP system on a daily basis.
You must visually inspect your subsea
BOP system, marine riser, and wellhead
at least once every 3 days if weather and
sea conditions permit. You may use
cameras to inspect subsea equipment.
(d) You must ensure that all personnel
maintaining, inspecting, or repairing
BOPs, or critical components of the BOP
system, meet the qualification and
training criteria specified by the OEMs
and recognized engineering practices.
(e) You must make all records
available to BSEE upon request. You
must ensure that the rig owner
maintains your BOP maintenance,
inspection, and repair records on the rig
for 2 years from the date the records are
created or for a longer period if directed
by BSEE. You must maintain all design,
maintenance, inspection, and repair
records at an onshore location for the
service life of the equipment.
Records and Reporting
§ 250.740
What records must I keep?
You must keep a daily report
consisting of complete, legible, and
accurate records for each well. You
must keep records onsite while well
operations continue. After completion
of operations, you must keep all
operation and other well records for the
time periods shown in § 250.741 at a
location of your choice, except as
required in § 250.746. The records must
contain complete information on all of
the following:
(a) Well operations, all testing
conducted, and any real-time
monitoring data;
(b) Descriptions of formations
penetrated;
(c) Content and character of oil, gas,
water, and other mineral deposits in
each formation;
(d) Kind, weight, size, grade, and
setting depth of casing;
(e) All well logs and surveys run in
the wellbore;
(f) Any significant malfunction or
problem; and
(g) All other information required by
the District Manager.
§ 250.741
How long must I keep records?
You must keep records for the time
periods shown in the following table.
You must keep records relating to . . .
Until . . .
(a) Drilling; ................................................................................................
(b) Casing and liner pressure tests, diverter tests, BOP tests, and realtime monitoring data;
90 days after you complete operations.
2 years after the completion of operations.
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You must keep records relating to . . .
Until . . .
(c) Completion of a well or of any workover activity that materially alters the completion configuration or affects a hydrocarbon-bearing
zone.
You permanently plug and abandon the well or until you assign the
lease and forward the records to the assignee.
§ 250.742 What well records am I required
to submit?
You must submit to BSEE copies of
logs or charts of electrical, radioactive,
sonic, and other well logging operations;
directional and vertical well surveys;
velocity profiles and surveys; and
analysis of cores. Each Region will
provide specific instructions for
submitting well logs and surveys.
tkelley on DSK3SPTVN1PROD with PROPOSALS2
§ 250.743 What are the well activity
reporting requirements?
(a) For operations in the BSEE GOM
OCS Region, you must submit Form
BSEE–0133, Well Activity Report
(WAR), to the District Manager on a
weekly basis. The reporting week is
defined as beginning on Sunday (12
a.m.) and ending on the following
Saturday (11:59 p.m.). This reporting
week corresponds to a week (Sunday
through Saturday) on a standard
calendar. Report any well operations
that extend past the end of this weekly
reporting period on the next weekly
report. The reporting period for the
weekly report is never longer than 7
days, but could be less than 7 days for
the first reporting period and the last
reporting period for a particular well
operation. Submit each WAR and
accompanying Form BSEE–0133S, Open
Hole Data Report, to the BSEE GOM
OCS Region no later than close of
business on the Friday immediately
after the closure of the reporting week.
The District Manager may require more
frequent submittal of the WAR on a
case-by-case basis.
(b) For operations in the Pacific or
Alaska OCS Regions, you must submit
Form BSEE–0133, WAR, to the District
Manager on a daily basis.
(c) The WAR must include a
description of the operations conducted,
any abnormal or significant events that
affect the permitted operation each day
within the report from the time you
begin operations to the time you end
operations, any verbal approval
received, the well’s as-built drawings,
casing, fluid weights, shoe tests, test
pressures at surface conditions, and any
other information required by the
District Manager. For casing cementing
operations, indicate type of returns (i.e.,
full, partial, or none). If partial or no
returns are observed, you must indicate
how you determined the top of cement.
For each report, indicate the operation
status for the well at the end of the
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21:10 Apr 16, 2015
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reporting period. On the final WAR,
indicate the status of the well
(completed, temporarily abandoned,
permanently abandoned, or drilling
suspended) and the date you finished
such operations.
§ 250.744 What are the end of operation
reporting requirements?
(a) Within 30 days after completing
operations, except routine operations as
defined in § 250.601, you must submit
Form BSEE–0125, End of Operations
Report (EOR), to the District Manager.
The EOR must include a listing, with
top and bottom depths, of all
hydrocarbon zones and other zones of
porosity encountered with any cored
intervals; details on any drill-stem and
formation tests conducted;
documentation of successful negative
pressure testing on wells that use a
subsea BOP stack or wells with mudline
suspension systems; and an updated
schematic of the full wellbore
configuration. The schematic must be
clearly labeled and show all applicable
top and bottom depths, locations and
sizes of all casings, cut casing or stubs,
casing perforations, casing rupture discs
(indicate if burst or collapse and rating),
cemented intervals, cement plugs,
mechanical plugs, perforated zones,
completion equipment, production and
isolation packers, alternate completions,
tubing, landing nipples, subsurface
safety devices, and any other
information required by the District
Manager. The EOR must indicate the
status of the well (completed,
temporarily abandoned, permanently
abandoned, or drilling suspended) and
the date of the well status designation.
The wells’ status date is subject to the
following:
(1) For surface well operations and
riserless subsea operations, the
operations end date is subject to the
discretion of the District Manager; and
(2) For subsea well operations, the
operations end date is considered to be
the date the BOP is disconnected from
the wellhead unless otherwise specified
by the District Manager.
(b) You must submit public
information copies of Form BSEE–0125
according to § 250.186(b).
§ 250.745 What other well records could I
be required to submit?
The District Manager or Regional
Supervisor may require you to submit
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copies of any or all of the following well
records:
(a) Well records as specified in
§ 250.740;
(b) Paleontological interpretations or
reports identifying microscopic fossils
by depth and/or washed samples of drill
cuttings that you normally maintain for
paleontological determinations. The
Regional Supervisor may issue a Notice
to Lessees that sets forth the manner,
timeframe, and format for submitting
this information;
(c) Service company reports on
cementing, perforating, acidizing,
testing, or other similar services; or
(d) Other reports and records of
operations.
§ 250.746 What are the recordkeeping
requirements for casing, liner, and BOP
tests, and inspections of BOP systems and
marine risers?
You must record the time, date, and
results of all casing and liner pressure
tests. You must also record pressure
tests, actuations, and inspections of the
BOP system, system components, and
marine riser in the daily report
described in § 250.740. In addition, you
must:
(a) Record test pressures on pressure
charts;
(b) Require your onsite lessee
representative, designated rig or
contractor representative, and pump
operator to sign and date the pressure
charts and daily reports as correct;
(c) Document on the daily report the
sequential order of BOP and auxiliary
equipment testing and the pressure and
duration of each test. For subsea BOP
systems, you must also record the
closing times for annular and ram BOPs.
You may reference a BOP test plan if it
is available at the facility;
(d) Identify on the daily report the
control station and pod used during the
test (identifying the pod does not apply
to coiled tubing and snubbing units);
(e) Identify on the daily report any
problems or irregularities observed
during BOP system testing and record
actions taken to remedy the problems or
irregularities. Any leaks associated with
the BOP or control system during testing
are considered problems or irregularities
and must be reported immediately to
the District Manager, and documented
in the WAR. If any problems or
irregularities are observed during
testing, operations must be suspended
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until the District Manager determines
that you may continue; and
(f) Retain all records, including
pressure charts, daily reports, and
referenced documents pertaining to
tests, actuations, and inspections at the
facility for the duration of the operation.
After completion of the operation, you
must retain all the records listed in this
section for a period of 2 years at the
facility. You must also retain the records
at the lessee’s field office nearest the
facility or at another location available
to BSEE. You must make all the records
available to BSEE upon request.
■ 41. Revise § 250.1612 to read as
follows:
§ 250.1612
Well-control drills.
Well-control drills must be conducted
for each drilling crew in accordance
with the requirements set forth in
§ 250.711 of this part or as approved by
the District Manager.
■ 42. Amend § 250.1703 by:
■ a. Revising paragraphs (b) and (e);
■ b. Redesignating paragraph (f) as
paragraph (g); and
■ c. Adding a new paragraph (f).
The revisions and addition read as
follows:
§ 250.1703 What are the general
requirements for decommissioning?
*
*
*
*
*
(b) Permanently plug all wells. All
packers and bridge plugs must comply
Decommissioning applications and reports
*
*
*
(1) Before you temporarily abandon or permanently plug a well or zone,
(h) Form BSEE–0125, End of Operations Report (EOR);
§ 250.1705
[Removed and Reserved]
44. Remove and reserve § 250.1705.
45. Amend § 250.1706 by:
■ a. Revising the section heading;
■ b. Removing paragraphs (a) through
(e); and
■ c. Redesignating paragraph (f) through
(h) as paragraphs (a) through (c). The
revision reads as follows:
■
■
§ 250.1706 Coiled tubing and snubbing
operations.
*
tkelley on DSK3SPTVN1PROD with PROPOSALS2
§ 250.1704 When must I submit
decommissioning applications and reports?
*
*
*
When to submit
*
*
(g) Form BSEE–0124, Application for Permit to
Modify (APM). The submission of your APM
must be accompanied by payment of the
service fee listed in § 250.125;
with API Spec. 11D1 (as incorporated by
reference in § 250.198);
*
*
*
*
*
(e) Clear the seafloor of all
obstructions created by your lease and
pipeline right-of-way operations;
(f) Follow all applicable requirements
of subpart G; and
*
*
*
*
*
■ 43. Amend § 250.1704 by revising
paragraph (g) and adding paragraph (h)
to read as follows:
*
*
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*
*
21:10 Apr 16, 2015
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[Removed
*
*
Include information required under
§§ 250.1712 and 250.1721.
(ii) When using a BOP for abandonment operations, include information required under
§ 250.731.
Refer to § 250.1722(a).
(i)
Refer to § 250.1723.
Include
information
§ 250.1722(d).
Include
information
§ 250.1743(a).
§ 250.1717
§ 250.1715
well?
§ 250.1721
How must I permanently plug a
*
*
*
*
(a) * * *
(3) * * *
(iii) * * *
(B) A casing bridge plug set 50 to 100
feet above the top of the perforated
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required
under
required
under
interval and at least 50 feet of cement on
top of the bridge plug;
*
*
*
*
*
46. Remove and reserve §§ 250.1707
through 250.1709.
■ 47. In § 250.1715, revise paragraph
(a)(3)(iii)(B) to read as follows:
■
*
*
Instructions
(2) Before you install a subsea protective device,
(3) Before you remove any casing stub or mud
line suspension equipment and any subsea
protective device,
(1) Within 30 days after you complete a protective device trawl test,
(2) Within 30 days after you complete site
clearance verification activities,
§§ 250.1707 through 250.1709
and Reserved]
*
■
[Removed and Reserved]
48. Remove and reserve § 250.1717.
[Amended]
49. Amend § 250.1721 by removing
paragraph (g) and redesignating
paragraph (h) as paragraph (g).
■
[FR Doc. 2015–08587 Filed 4–13–15; 4:15 pm]
BILLING CODE 4310–VH–P
E:\FR\FM\17APP2.SGM
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Agencies
- DEPARTMENT OF THE INTERIOR
- Bureau of Safety and Environmental Enforcement
[Federal Register Volume 80, Number 74 (Friday, April 17, 2015)]
[Proposed Rules]
[Pages 21503-21585]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2015-08587]
[[Page 21503]]
Vol. 80
Friday,
No. 74
April 17, 2015
Part III
Department of the Interior
-----------------------------------------------------------------------
Bureau of Safety and Environmental Enforcement
-----------------------------------------------------------------------
30 CFR Part 250
Oil and Gas and Sulphur Operations in the Outer Continental Shelf--
Blowout Preventer Systems and Well Control; Proposed Rule
Federal Register / Vol. 80 , No. 74 / Friday, April 17, 2015 /
Proposed Rules
[[Page 21504]]
-----------------------------------------------------------------------
DEPARTMENT OF THE INTERIOR
Bureau of Safety and Environmental Enforcement
30 CFR Part 250
[Docket ID: BSEE-2015-0002; 15XE1700DX EEEE500000 EX1SF0000.DAQ000]
RIN 1014-AA11
Oil and Gas and Sulphur Operations in the Outer Continental
Shelf--Blowout Preventer Systems and Well Control
AGENCY: Bureau of Safety and Environmental Enforcement (BSEE),
Interior.
ACTION: Proposed rule.
-----------------------------------------------------------------------
SUMMARY: The Bureau of Safety and Environmental Enforcement (BSEE)
proposes new regulations in order to consolidate equipment and
operational requirements that are common to other subparts pertaining
to offshore oil and gas drilling, completions, workovers, and
decommissioning. This proposed rule would focus, at this time, on
blowout preventer (BOP) requirements, including incorporation of
industry standards and revising existing regulations. The proposed rule
would also include reforms in the areas of well design, well control,
casing, cementing, real-time well monitoring, and subsea containment.
The proposed rule would address and implement multiple recommendations
resulting from various investigations of the Deepwater Horizon
incident. This proposed rule would also incorporate guidance from
several Notices to Lessees and Operators (NTLs) and revise provisions
related to drilling, workover, completion, and decommissioning
operations to enhance safety and environmental protection.
DATES: Submit comments by June 16, 2015. The BSEE may not consider
comments received after this date. Submit comments to the Office of
Management and Budget (OMB) on the information collection burden in
this proposed rule by May 18, 2015. This does not affect the deadline
for the public to comment to BSEE on the proposed regulations.
ADDRESSES: You may submit comments on the proposed rulemaking by any of
the following methods. Please use the Regulation Identifier Number
(RIN) 1014-AA11 as an identifier in your message. See also Public
Availability of Comments under Procedural Matters.
Electronic comments: https://www.regulations.gov. In the
Search box, enter BSEE-2015-0002 then click search. Follow the
instructions to submit public comments and view supporting and related
materials available for this rulemaking. We will post all comments.
Mail or hand-carry comments to the Department of the
Interior (DOI); Bureau of Safety and Environmental Enforcement;
Attention: Regulations and Standards Branch; 45600 Woodland Road,
Sterling, Virginia 20166. Please reference Blowout Preventer Systems
and Well Control, 1014-AA11 in your comments and include your name and
return address.
Send comments on the information collection in this rule
to: OMB, Interior Desk Officer 1014-NEW, 202-395-5806 (fax); email:
OIRA_submission@omb.eop.gov. Please also send a copy to BSEE at
regs@bsee.gov, fax number (703)787-1546, or by the address listed
above.
FOR FURTHER INFORMATION CONTACT: Kirk Malstrom, Regulations and
Standards Branch, 202-258-1518, Kirk.Malstrom@bsee.gov. To see a copy
of the information collection request submitted to OMB, go to https://www.reginfo.gov (select Information Collection Review, Currently Under
Review).
SUPPLEMENTARY INFORMATION:
List of Acronyms and References
ANSI American National Standards Institute
APD Application for Permit to Drill
API American Petroleum Institute
APM Application for Permit to Modify
BOP Blowout Preventer
BOEM Bureau of Ocean Energy Management
BSEE Bureau of Safety and Environmental Enforcement
BSR Blind Shear Ram
CBM Condition-based Maintenance
CVA Certified Verification Agent
DHS Department of Homeland Security
DOI Department of the Interior
DWOP Deepwater Operations Plan
ECD Equivalent Circulating Density
EDS Emergency Disconnect Sequence
E.O. Executive Order
EOR End of Operations Report
F Fahrenheit
FPS Floating Production System
FPSO Floating Production, Storage, and Offloading Unit
FSHR Free Standing Hybrid Risers
GOM Gulf of Mexico
GPS Global Position Systems
HPHT High Pressure High Temperature
JIT Joint Investigation Team
LMRP Lower Marine Riser Package
MASP Maximum Anticipated Surface Pressure
MMS Minerals Management Service
MODUs Mobile Offshore Drilling Units
NAE National Academy of Engineering
NAICS North American Industry Classification System
NARA National Archives and Records Administration
National Commission National Commission on the BP Deepwater Horizon
Oil Spill and Offshore Drilling
NTLs Notices to Lessees and Operators
OCS Outer Continental Shelf
OCSLA Outer Continental Shelf Lands Act
OEM Original Equipment Manufacturer
OIRA Office of Information and Regulatory Affairs
OMB Office of Management and Budget
PE Professional Engineer
psi Pounds per square inch
RFA Regulatory Flexibility Act
RIA Regulatory Impact Analysis
RIN Regulation Identifier Number
ROV Remotely Operated Vehicle
RP Recommended Practice
SBA Small Business Administration
SBREFA Small Business Regulatory Enforcement Act of 1996
SCCE Source Control and Containment Equipment
Secretary Secretary of the Interior
SEM Subsea Electronic Module
SEMS Safety and Environmental Management
Spec. Specification
TAR Technical Assessment and Research
TLP Tension Leg Platform
TVD True Vertical Depth
USCG United States Coast Guard
VSL Value of a Statistical Life
WAR Well Activity Report
Executive Summary
Following the Deepwater Horizon incident on April 20, 2010,
multiple investigations were conducted to determine the causes of the
incident and to make recommendations to reduce the likelihood of a
similar incident in the future. The investigative groups included:
--DOI/Department of Homeland Security (DHS) Joint Investigation Team;
--National Commission on the BP Deepwater Horizon Oil Spill and
Offshore Drilling;
--Chief Counsel for the National Commission; and
--National Academy of Engineering.
Each investigation outlined several recommendations to improve
offshore safety. The BSEE evaluated the recommendations and acted on a
number of them quickly to improve offshore operations while other
recommendations required additional input from industry and other
stakeholders. The requirements in this proposed rule are based on
recommendations made by the previously listed investigative bodies,
which found a need to enhance well-control best practices to advance
safety and protection of the environment.
This proposed rulemaking would:
(1) Incorporate the following industry standards:
[[Page 21505]]
--American Petroleum Institute (API) Standard 53, Blowout Prevention
Equipment Systems for Drilling Wells;
--American National Standards Institute (ANSI)/API Specification
(Spec.) 11D1, Packers and Bridge Plugs; and
--API Recommended Practice (RP) 17H, Remotely Operated Tools and
Interfaces on Subsea Production Systems.
As related to BOP systems:
--ANSI/API Spec. 6A, Specification for Wellhead and Christmas Tree
Equipment;
--ANSI/API Spec. 16A, Specification for Drill-through Equipment;
--API Spec. 16C, Specification for Choke and Kill Systems;
--API Spec. 16D, Specification for Control Systems for Drilling Well
Control Equipment and Control Systems for Diverter Equipment; and
--ANSI/API Spec. 17D, Design and Operation of Subsea Production
Systems--Subsea Wellhead and Tree Equipment.
(2) Revise the requirements for Deepwater Operations Plan (DWOP)
which are required to be submitted to BSEE, to include requirements on
free standing hybrid risers (FSHR) for use with floating production,
storage, and offloading units (FPSO).
(3) Revise sections in 30 CFR part 250 Subpart D, Oil and Gas
Drilling Operations, to include requirements for:
--Submittal of equivalent circulating density (ECD) with the
Application for Permit to Drill (APD);
--Safe drilling margin;
--Wellhead description;
--Casing or liner centralization during cementing; and
--Source control and containment.
(4) Revise sections in Subparts E, Oil and Gas Well-Completion
Operations, and F, Oil and Gas Well-Workover Operations, to include
requirements for:
--Packer and bridge plug design, and
--Production packer setting depth.
(5) Revise sections in Subpart Q, Decommissioning Activities, to
include requirements for:
--Packer and bridge plug design,
--Casing bridge plugs, and
--Decommissioning applications and reports.
(6) Add new Subpart G, Well Operations and Equipment, and move
common requirements from Subparts D, E, F, and Q into new Subpart G.
Include new requirements in Subpart G for:
--Rig and equipment movement reports,
--Real-time monitoring, and
--Revised BOP requirements, including:
--Design and manufacture/quality assurance;
--Accumulator system capabilities and calculations;
--BOP and remotely operated vehicle (ROV) capabilities;
--BOP functions (e.g., shearing);
--Improved and consistent testing frequencies;
--Maintenance;
--Inspections;
--Failure reporting;
--Third-party verification; and
--Additional submittals to BSEE including up-to-date schematics.
(7) Incorporate the guidance from several Notices to Lessees and
Operators (NTLs) into Subpart G for:
--Global Position Systems (GPS) for Mobile Offshore Drilling Units
(MODUs);
--Ocean Current Monitoring;
--Using Alternate Compliance in Safety Systems for Subsea Production
Operations;
--Standard Reporting Period for the Well Activity Report (WAR); and
--Information to include in the WARs and End of Operation Reports
(EOR).
Table of Contents
I. Background
BSEE Statutory and Regulatory Authority
Availability of Incorporated Documents for Public Viewing
Summary of Documents Incorporated by Reference
Deepwater Horizon Investigations
Recommendations on BOPs
Stakeholder Participation
BSEE Response to Recommendations and Additional Considerations
II. Organization of Subpart G
III. Effective Date of a Final Rule
IV. Future Plans for Subpart G
V. Section-By-Section Discussion Appendix
VI. Derivation Tables
VII. Procedural Matters
I. Background
BSEE
In relation to oil and gas exploration, development, and production
operations on the Outer Continental Shelf (OCS), the Bureau of Safety
and Environmental Enforcement (BSEE) regulates offshore oil and gas
operations to promote safety, protect the environment, and conserve
offshore oil and gas resources. The BSEE was established on October 1,
2011, as part of a major restructuring of DOI's offshore oil and gas
regulatory programs to improve the management, oversight, and
accountability of activities on the OCS. The Secretary of the Interior
(Secretary) announced the new division of responsibilities of the
former Minerals Management Service (MMS) into two new bureaus and one
office within DOI in Secretarial Order No. 3299, issued on May 19,
2010. The BSEE, one of the two new bureaus, assumed responsibility for
``safety and environmental enforcement functions including, but not
limited to, the authority to permit activities, inspect, investigate,
summon witnesses and [require production of] evidence[;] levy
penalties; cancel or suspend activities; and oversee safety, response
and removal preparedness'' (76 FR 64432, October 18, 2011).
BSEE Statutory and Regulatory Authority
The BSEE derives its authority primarily from the Outer Continental
Shelf Lands Act (OCSLA), 43 U.S.C. 1331-1356a. Congress enacted OCSLA
in 1953, establishing Federal control over the OCS and authorizing the
Secretary to regulate oil and gas exploration, development, and
production operations on the OCS. The Secretary has authorized BSEE to
perform these functions under 30 CFR 250.101.
To carry out its responsibilities, BSEE regulates offshore oil and
gas operations to enhance the safety of offshore exploration and
development of oil and gas on the OCS and to ensure that those
operations protect the environment and implement advancements in
technology. The BSEE also conducts onsite inspections to assure
compliance with regulations, lease terms, and approved plans. Detailed
information concerning BSEE's regulations and guidance to the offshore
oil and gas industry may be found on BSEE's Web site at: https://www.bsee.gov/Regulations-and-Guidance/index.aspx.
The BSEE regulatory program regulates a wide range of facilities
and activities, including drilling, completion, workover, production,
pipeline, and decommissioning operations. Drilling, completion, and
workover operations are types of well operations offshore operators
perform throughout the OCS from fixed and floating facilities. These
well operations are the primary topic of this proposed rulemaking.
Ensuring the integrity of the wellbore and maintaining control over
the pressure and fluids during well operations are critical aspects of
protecting worker safety and the environment. The investigations that
followed the Deepwater Horizon incident documented gaps or deficiencies
in the OCS regulatory programs and made recommendations for
improvements. The objective of this
[[Page 21506]]
rulemaking is to address many of these recommendations, especially
those related to BOP system design, performance, and reliability.
The BOP equipment and systems are critical components of many well
operations. The BOP systems can be the last defense against a release
of hydrocarbons into the environment, when all other forms of well
control have failed (e.g., the drilling fluid program). The BOPs may be
the last line of defense in preventing release of gas that is volatile
and considered to be an extreme safety hazard to rig personnel
(uncontrolled gas releases can lead to explosions). The primary purpose
of BOP systems is to prevent the uncontrolled release of hydrocarbons
in an emergency situation by mechanically closing valves or rams that
block the flow of fluid from the well. In some situations, this may
require shear rams on the BOP stack to sever the drill pipe before the
well can be sealed.
The BOP equipment and systems have increased in complexity as the
industry moves into deeper water and develops reservoirs with pressures
greater than 15,000 pounds per square inch (psi) or temperatures
greater than 350 degrees Fahrenheit (F). Reservoirs with these
conditions are considered high pressure high temperature (HPHT). Most
of the BOPs that are used in deep water operations (400 to 10,000 feet)
are located on the seabed, which presents technological and operational
challenges. Additionally, HPHT operations create special metallurgical
and design issues.
In this rulemaking, BSEE intends to:
Implement many of the recommendations related to well-
control equipment and fill gaps in the regulatory program.
Increase the performance and reliability of well-control
equipment, especially BOPs.
Improve regulatory oversight over the design, fabrication,
maintenance, inspection, and repair of critical equipment.
Gain information on leading and lagging indicators of BOP
component failures, identify trends in those failures, and help prevent
accidents.
Ensure that the industry uses recognized engineering
practices, as well as innovative technology and techniques to increase
overall safety.
Availability of Incorporated Documents for Public Viewing
When a copyrighted technical industry standard is incorporated by
reference into our regulations, BSEE is obligated to observe and
protect that copyright. The BSEE provides members of the public with
Web site addresses where these standards may be accessed for viewing--
sometimes for free and sometimes for a fee. Standards-developing
organizations decide whether to charge a fee. The API provides free
online public access to key industry standards, including a broad range
of technical standards. These free standards represent almost one-third
of all API standards and include all that are safety-related or have
been or are proposed to be incorporated into Federal regulations,
including the standards in this rule. These standards are available for
online review, and hardcopies and printable versions will continue to
be available for purchase. We are proposing to incorporate certain API
standards. The API Web site address is: https://www.api.org/publications-standards-and-statistics/publications/government-cited-safety-documents.
For the convenience of the viewing public, who may not wish to
purchase or view these proposed documents online, they may be inspected
at BSEE, 45600 Woodland Road, Sterling, Virginia 20166; phone: 703-787-
1665; or at the National Archives and Records Administration (NARA).
For information on the availability of this material at NARA, call 202-
741-6030, or go to: https://www.archives.gov/federal-register/cfr/ibr-locations.html.
These documents, if incorporated in the final rule, would continue
to be made available to the public for viewing when requested. Specific
information on where these documents can be inspected or obtained can
be found at 30 CFR 250.198, Documents incorporated by reference.
Summary of Documents Incorporated by Reference
This rulemaking is substantive in terms of the content that is
explicitly stated in the rule text itself, but it also incorporates by
reference some very technical, detailed standards and specifications in
the topic of blowout preventers and well control. In their aggregate
this represents one of the most substantial rulemakings in the history
of the BSEE and its predecessor organizations. A brief summary, based
on the descriptions in each standard or specification, is provided in
the text that follows.
API Standard 53--Blowout Prevention Equipment Systems for Drilling
Wells
This standard is to provide requirements for the installation and
testing of blowout prevention equipment systems whose primary functions
are to confine well fluids to the wellbore, provide means to add fluid
to the wellbore, and allow controlled volumes to be removed from the
wellbore. Blowout preventer equipment systems are comprised of a
combination of various components that are covered by this document.
Equipment arrangements are also addressed. The components covered
include:
Blowout preventers (BOPs) including installations for surface and
subsea BOPs;
Choke and kill lines;
Choke manifolds;
Control systems; and
Auxiliary equipment.
This document provides new industry best practices related to:
The use of double shear rams
Maintenance and testing requirements.
Failure Reporting
Diverters, shut-in devices, and rotating head systems (rotating
control devices) whose primary purpose is to safely divert or direct
flow rather than to confine fluids to the wellbore are not addressed.
Procedures and techniques for well control and extreme temperature
operations are also not included in this standard.
API Recommended Practice 2RD--Design of Risers for Floating Production
Systems and Tension-Leg Platforms
This document addresses structural analysis procedures, design
guidelines, component selection criteria, and typical designs for all
new riser systems used on Floating Production Systems (FPSs and
Tension-Leg Platforms (TLPs). The presence of riser systems within an
FPS has a direct and often significant effect on the design of all
other major equipment subsystems. This RP includes recommendations on:
(1) Configurations and components, (2) general design considerations
based on environmental and functional requirements, and (3) materials
considerations in riser design.
API Specification Q1--Specification for Quality Management System
Requirements for Manufacturing Organizations for the Petroleum and
Natural Gas Industry
This specification establishes the minimum quality management
system requirements for organizations that manufacture products or
provide manufacturing-related processes under a product specification
for use in the petroleum and natural gas industry. This document
requires that equipment be fabricated under a quality management system
that provides for
[[Page 21507]]
continual improvement, emphasizing defect prevention and the reduction
of variation and waste in the supply chain and from service providers.
The goal of this specification is to increase equipment reliability
through better manufacturing controls.
API Specification 6A--Specification for Wellhead and Christmas Tree
Equipment
This specification defines minimal requirements for the design of
valves, wellheads and Christmas tree equipment that is used during
drilling and production operations. This specification includes
requirements related to dimensional and functional interchangeability,
design, materials, testing, inspection, welding, marking, handling,
storing, shipment, purchasing, repair and remanufacture.
ANSI/API Specification 11D1--Packers and Bridge Plugs
This specification provides minimum requirements and guidelines for
packers and bridge plugs used downhole in oil and gas operations. The
performance of this equipment is often critical to maintaining control
of a well during drilling or production operations. This specification
provides requirements for the functional specification and technical
specification, including design, design verification and validation,
materials, documentation and data control, repair, shipment, and
storage.
ANSI/API Specification 16A--Specification for Drill-Through Equipment
This specification defines requirements for performance, design,
materials, testing and inspection, welding, marking, handling, storing
and shipping of BOPs and drill-through equipment used for drilling for
oil and gas. It also defines service conditions in terms of pressure,
temperature and wellbore fluids for which the equipment will be
designed. This standard is applicable to and establishes requirements
for the following specific equipment: ram blowout preventers; ram
blocks, packers and top seals; annular blowout preventers; annular
packing units; hydraulic connectors; drilling spools; adapters; loose
connections; and clamps.
Conformance to this standard is necessary to ensure that this
critical safety equipment has been designed and fabricated in a manner
that ensures reliable performance.
API Specification 16C--Specification for Choke and Kill Systems
This specification was formulated to provide for safe and
functionally interchangeable surface and subsea choke and kill systems
equipment utilized for drilling oil and gas wells. This equipment is
used during emergencies to circulate out a ``kick'' and therefore, the
design and fabrication of the components is extremely important. The
technical content in the document provides the minimum requirements for
performance, design, materials, welding, testing, inspection, storing
and shipping. Equipment specific to and covered by this specification
includes:
Actuated valve control lines;
Articulated choke & kill line;
Drilling choke actuators;
Drilling choke control lines, exclusive of BOP control lines;
Subsurface safety valve control lines;
Drilling choke controls;
Drilling chokes;
Flexible choke and kill lines;
Union connections;
Rigid choke and kill lines; and
Swivel unions.
API Specification 16D--Specification for Control Systems for Drilling
Well Control Equipment and Control Systems for Diverter Equipment
This specification establishes design standards for systems that
are used to control BOPs and associated valves that control well
pressure during drilling operations. Although diverters are not
considered well control devices, their controls are often incorporated
as part of the BOP control system. Thus, control systems for diverter
equipment are included in the specification. Control systems for
drilling well control equipment typically employ stored energy in the
form of pressurized hydraulic fluid (power fluid) to operate (open and
close) the BOP stack components. For deepwater operations, transmission
subsea of electric/optical (rather than hydraulic) signals may be used
to short response times. The failure of these controls to perform as
designed can result in a major well control event. As a result,
conformance to this specification is critical to ensuring that the BOPs
and related equipment will operate in an emergency.
ANSI/API Specification 17D--Design and Operation of Subsea Production
Systems--Subsea Wellhead and Tree Equipment
This specification provides specifications for subsea wellheads,
mudline wellheads, drill-through mudline wellheads and both vertical
and horizontal subsea trees. These devices are located on the seafloor,
and therefore, ensuring the safe and reliable performance of this
equipment is extremely important. This document specifies the
associated tooling necessary to handle, test and install the equipment.
It also specifies the areas of design, material, welding, quality
control (including factory acceptance testing), marking, storing and
shipping for both individual sub-assemblies (used to build complete
subsea tree assemblies) and complete subsea tree assemblies.
API Recommended Practice 17H--Remotely Operated Tools and Interfaces on
Subsea Production Systems
This recommended practice has been prepared to provide general
recommendations and overall guidance for the design and operation of
remotely operated tools (ROT) comprising ROT and ROV tooling used on
offshore subsea systems. ROT and ROV performance is critical to
ensuring safe and reliable deepwater operations and this document
provides general performance guidelines for the equipment.
Deepwater Horizon Investigations
This section discusses relevant investigations that have
significant bearing on this proposed rulemaking.
DOI/DHS Investigation
The joint DOI/DHS investigation started on April 27, 2010, when the
Secretaries of DOI and DHS convened a joint investigation team (JIT)
comprised of staff from the MMS and the U.S. Coast Guard (USCG). The
JIT held seven public hearings and heard testimony from more than 80
witnesses. The DOI JIT issued a report on September 14, 2011, entitled,
REPORT REGARDING THE CAUSES OF THE APRIL 20, 2010 MACONDO WELL BLOWOUT,
which included its findings, conclusions, and recommendations.
National Commission
On May 22, 2010, President Barack Obama announced the creation of
the National Commission on the BP Deepwater Horizon Oil Spill and
Offshore Drilling (National Commission), an independent, non-partisan
entity. The President charged the National Commission to determine the
causes of the disaster, to make recommendations for improvement to the
country's ability to respond to spills, and to recommend reforms to
make offshore energy production safer. The National Commission
published its final
[[Page 21508]]
report on January 11, 2011, entitled, DEEP WATER, The Gulf Oil Disaster
and the Future of Offshore Drilling.
Chief Counsel for the National Commission
Given the factual and technical complexity of some of the
underlying causes of the blowout, the National Commission's Chief
Counsel issued a separate report setting forth in greater detail its
findings and conclusions regarding the technical, managerial, and
regulatory aspects of the blowout. The report contains findings and
conclusions about the loss of well control, and also contains
recommendations to industry and government to enhance well design. The
Chief Counsel's report was published on February 17, 2011, and is
entitled, Macondo: The Gulf Oil Disaster.
National Academy of Engineering
At the request of DOI, a National Academy of Engineering (NAE)/
National Research Council committee examined the probable causes of the
Deepwater Horizon explosion, fire, and oil spill in order to identify
measures for preventing similar harm in the future. The final report
was released December 14, 2011, and is entitled, Macondo Well-Deepwater
Horizon Blowout. The final report provides findings about the causes of
the loss of well control and the failure of the BOP to prevent release
of hydrocarbons and offers recommendations to industry and government
that would strengthen oversight of deepwater wells, enhance system
safety, and improve cementing practices and the technical skills of
industry and regulatory staff.
Recommendations on BOPs
Each of the previously discussed investigations resulted in reports
that contained recommendations to improve offshore safety. One
consistent element in each of the investigations was the recognition
that additional requirements related to BOPs and well-control equipment
are needed. The following list contains some of the recommendations on
BOPs and related equipment from the various investigations:
--The BSEE should consider promulgating regulations that require
operators/contractors to have the capability to monitor the subsea
electronic module (SEM) battery(ies) from the drilling rig, to ensure
that there is sufficient battery power to operate the system.
--The BSEE should consider requiring standardization of: Remotely
Operated Vehicle (ROV) intervention panels, ROV intervention
capabilities, and maximum closing times when using an ROV; ROV hot stab
and receptacles per API RP 17H; and hot stab designs between drilling
and production operations.
--The BSEE should consider requiring a blind-shear ram design that
incorporates improved pipe[hyphen]centering in the shear ram.
--The BSEE should make effective use of industry standards and best
practice guidelines used by other countries with the recognition that
standards need to be updated and revised continually.
--The BSEE should improve reporting of safety-related incidents and
require the reporting of near-misses to assist in accident prevention
and to improve standards.
--The BSEE should develop standardized requirements for the training
and certification of key industry personnel.
--The BSEE should rely on independent organizations to verify and
certify compliance with critical designs and required processes.
--The BSEE should ensure that the general well design includes a review
of fitness of the components for the intended use.
--The BSEE should consider promulgating regulations that would require
operators to report leaks associated with BOP control systems.
--The BSEE should consider promulgating regulations that would require
real[hyphen]time, remote capture of drilling data and BOP function
data.
--The BSEE should require improvement of the instrumentation on BOP
systems so that the functionality and condition of the BOP can be
monitored continuously.
--The BSEE should consider regulations that address a reasonable margin
of safety between the ECD and the pressure that would cause wellbore
fracturing.
--The BSEE should establish testing and maintenance requirements for
BOPs to ensure operability and increased reliability appropriate to the
environment and application.
--The BSEE should require improvement of the design capabilities of the
BOP systems so that they can shear and seal all combinations of pipe
under all possible conditions of load from the pipe and from the well
flow, and so that there would always be a shearable section of the
drill pipe in front of a blind-shear ram in the BOP.
--The BSEE should require demonstration of the performance of the
design capabilities of BOPs and require that they be independently
certified on a regular basis by test or other means.
Stakeholder Participation
Since the Deepwater Horizon incident, BSEE has made it a priority
to participate in meetings, training, and workshops with industry,
standards organizations, and other stakeholders. The BSEE recognized
that it was important to collect the best ideas on the prevention of
well-control incidents and blowouts to assist in the development of
this proposed rule. This includes the knowledge and skillset that
industry has, and BSEE wants to benefit from that experience to improve
the safety of all operations on the OCS.
Therefore, on May 22, 2012, BSEE hosted a public offshore energy
safety forum that brought together Federal decision-makers, industry,
academia, and other stakeholders to discuss additional steps that BSEE
and the industry might take to continue to improve the reliability and
safety of BOPs. This public forum provided industry experts, Federal
decision-makers, and the public the opportunity for free and open
dialogue. Discussion panels consisted of representatives from
government organizations, trade associations, equipment manufacturers,
offshore operators, consultants, training companies, and others. During
the forum, five separate panels discussed the following BOP topics:
--BOP technology needs identified by Deepwater Horizon investigations;
--Real-time technologies that can aid in diagnostics and kick
detection;
--Design requirements needed to provide assurance that BOPs would cut
casing or drill pipe and seal a well effectively;
--Manufacturing, testing, maintenance, and certification requirements
needed to ensure operability and reliability of BOP equipment; and
--Training and certification needs for industry personnel operating or
maintaining BOPs.
You can find additional information about the forum, including
presentations and transcripts, on the BSEE Web page at: https://www.bsee.gov/BSEE-Newsroom/BSEE-News-Briefs/2012/BSEE-Hosts-BOP-Forum-in-DC. In the year following this forum, BSEE has also received
significant input and specific recommendations from industry groups,
operators, equipment manufacturers, and environmental organizations on
each of these items. For example, BSEE has actively participated in the
following, among other events:
[[Page 21509]]
--The API Exploration & Production Standards Conference on Oilfield
Equipment and Materials;
--The Ocean Energy Safety Institute risk forum;
--The Offshore Well Control Equipment Forum, organized by API, January
30, 2014;
--The International Regulators Forum;
--Various standards committees and sub-committees for standards
development (e.g., API Committee on Standardization of Oilfield
Equipment and Material Subcommittee 16 on Drilling Well Control
Equipment);
--The BSEE and industry assessments of current technology involving
research that BSEE is funding; and
--The BSEE sponsored standards workshops--November 2012 and January
2014.
The BSEE has considered this input in developing this proposed
rulemaking and has reviewed studies and research on this topic.
BSEE Response to Recommendations and Additional Considerations
The BSEE evaluated all recommendations from the investigative
bodies and public input and determined that the agency needs to update
regulations related to the prevention of blowouts. The prevention of
blowouts, either through precautionary measures or by operation of a
BOP, is a critical priority for BSEE. The BSEE therefore focused this
rulemaking on updating and revising current well-control regulations.
Several of the recommendations related to BSEE's regulatory
programs were already implemented in rulemakings following the
Deepwater Horizon incident. The following items are included in this
proposed rule and arise out of the investigation reports or from other
third-party recommendations.
Shearing Requirements
The BSEE regulations currently require that a BOP stack include a
blind shear ram. A blind shear ram is designed to cut drill pipe in the
well and shut in the well in an emergency well control situation. In
order for a blind shear ram to shut in a well where drill pipe is
across the BOP, it must be capable of shearing the drill pipe and there
are known mechanical and design limitations that may prevent this from
occurring. As demonstrated by the Deepwater Horizon incident, the
failure of equipment to perform reliably can result in a major safety
and/or environmental event.
Prior to the Deepwater Horizon incident, MMS commissioned the
following research on shearing capabilities: Technical Assessment &
Research (TAR) Project 383, Performance of Deepwater BOP Equipment
During Well-control Events; TAR Project 408, Development of a Blowout
Intervention Method and Dynamic Kill Simulated for Blowouts Occurring
Ultra-Deepwater; TAR Project 431, Evaluation of Secondary Intervention
Methods in Well-control; TAR Project 455, Review of Shear Ram
Capabilities; and TAR Project 463, Evaluation of Sheer Ram
Capabilities. This research can be found at https://www.bsee.gov/Technology-and-Research/Technology-Assessment-Programs/Categories/Drilling/. The research indicated that there was a large amount of
uncertainty related to the shearing capability of existing BOPs. These
reports documented that there were inconsistent and inadequate testing
protocols used by manufacturers to demonstrate shearing capability, a
failure to share shearing data that would allow for a better
understanding of shearing capability, and a concern that not all
operators and drilling contractors are aware of the limitations of the
equipment they are using.
Following the Deepwater Horizon incident, the Agency received
recommendations from multiple investigations and studies concerning the
need for new and more rigorous requirements and technologies to ensure
that drilling components can be severed and a well safely shut-in
during an emergency. The BSEE is proposing a series of new requirements
to address the gaps that were identified in these reports, incorporate
recent industry standards, and assist in the adoption of improved
technology through performance-based requirements.
Some of the limitations of current designs are well known. Industry
acknowledges that BOP equipment would not shear drill collars, heavy
weight drill pipe, or drill pipe tool joints. This inability to shear
all of the components in the drill string can create significant
complications in an emergency situation and increase the likelihood of
a catastrophic event occurring. As the industry continues to develop
more technically challenging resources, shearing and sealing become
more difficult for several reasons, including:
--The improvements in drill pipe properties, particularly increased
material strength and ductility, result in higher forces being required
to shear the drill pipe in the future.
--Increased water depths, in combination with drilling fluid density
and shut-in pressure, contribute to a BOP having to generate additional
force to successfully shear.
The BSEE believes that the current testing protocols and
verification procedures must be strengthened to ensure that the
capabilities of shearing equipment are clearly understood and
demonstrated. Furthermore, on a longer term basis, the overall
performance of this equipment must improve to ensure that it can
operate in an emergency situation and can successfully shear a drill
stem. In this rule, BSEE is proposing to accomplish these objectives
through the following:
--Require operators to assure that shearing capability for existing
equipment complies with BSEE requirements related to shearing by
performing tests and providing detailed results to a BSEE-approved
verification organization. This organization would perform an
independent engineering review of the test protocols and data and
ensure that the testing would provide reasonable assurances that the
equipment would perform as designed on drill pipe of specific
mechanical and physical properties and under the operating conditions
relevant to the particular well at which the equipment will be used.
The BSEE expects that the independent engineering review would be based
on recognized engineering practices. To become a BSEE-approved
verification organization, organizations would need to submit
documentation for BSEE approval describing the applicable
qualifications and experience. This engineering review process would
assist in developing more standardized testing protocols, increase data
sharing within the industry, and provide information for future BSEE
determinations of best available and safest technologies under section
21 of OSCLA, 43 U.S.C. 1347. The BSEE anticipates that industry would
play an important role in this process by developing rigorous testing
procedures and protocols for organizations that perform the testing.
--Require compliance with the latest industry standards contained in
API Standard 53. In addition to these industry standards, BSEE would
also include a requirement that operators use two shear rams in subsea
BOP stacks. The use of double shear rams would increase the likelihood
that a drill string can be sheared by ensuring that a shearable
component is opposite a shear ram. In this proposed rulemaking, BSEE
will not propose adopting the provision in API
[[Page 21510]]
Standard 53 that operators can ``opt out'' of this double shear ram
requirement for moored rigs. If there are unique circumstances that
prevent the use of two shear rams, operators would be able to apply for
the use of alternative procedures or equipment under Sec. 250.141.
--Require the use of BOP technology that provides for better shearing
performance through the centering of the drill pipe in the shear rams.
A number of investigations \1\ have found that the shear rams did not
completely cut the drill pipe in the Deepwater Horizon. This occurred
because the drill pipe was not centered within the stack. The BSEE is
aware of at least one BOP equipment manufacturer that currently has
pipe centering technology available and proposes to require the use of
pipe centering within 7 years after the publication of the final rule
to encourage further technological development.
---------------------------------------------------------------------------
\1\ See DOI JIT investigation recommendation, D6.
---------------------------------------------------------------------------
Equipment Reliability and Performance
Prior to the Deepwater Horizon incident, the industry's guidance
document for the operation of BOPs was API RP 53--Recommended Practices
for Blowout Prevention Equipment Systems for Drilling Wells, Third
Edition, March 1, 1997 (Reaffirmed September 1, 2004). The BSEE
currently incorporates only specific sections of this document in
existing regulations, including sections related to maintenance,
inspection, and accumulator systems. Following the Deepwater Horizon
incident, industry recognized the need to enhance BOP guidance and
concluded that it was necessary to completely rewrite API RP 53 and
upgrade the document from an RP to a standard. The BSEE participated in
the development of the industry standard and is proposing to
incorporate the newly published standard into its regulations.
Additionally, other key industry standards concerning this type of
equipment would be incorporated by reference.
The BSEE concluded that incorporating new API Standard 53
provisions into its regulations would allow for better regulatory
oversight and would ensure improved BOP design and operability. The
BSEE believes that the incorporation of this document, and other key
industry standards, such as ANSI/API Spec. 6A, ANSI/API Spec. 16A, API
Spec. 16C, API Spec. 16D, ANSI/API Spec. 17D, and API Spec. Q1, would
establish minimum design, manufacture, and performance baselines for
this equipment and is essential to ensure the reliability and
performance of this equipment. The BSEE anticipates that BOP equipment
that meets these new requirements, along with several supplemental
requirements (such as requiring blind-shear rams that incorporate
improved pipe-centering designs), would perform in a more reliable
manner.
The BSEE believes that the reliability of BOP-related equipment
would also increase if its inspection, maintenance, and repair are
performed by highly-trained personnel. Operators are currently required
by BSEE regulations to ensure that all personnel are properly trained.
The BSEE proposes to add requirements that specify that these personnel
be qualified and trained pursuant to original equipment manufacturer
(OEM) recommendations, unless otherwise specified by BSEE. The BSEE
encourages industry to develop standards and certification programs for
these personnel.
Third-Party Verification
Regulatory oversight of the lifecycle of BOP equipment, ranging
from design, installation, inspection, testing, maintenance, and
repair, presents a variety of logistical and technical challenges,
especially because the equipment might be used at multiple locations.
In several sections of the proposed regulations, BSEE would require
third-party verification of the design, maintenance, inspection,
testing, and repair of BOP systems and equipment by a BSEE-approved
entity. We believe that the use of third-party verification
organizations would help BSEE ensure that these systems are designed
and maintained during their entire service life to minimize risk. For
subsea BOPs or BOPs used in HPHT applications, we are proposing that
BSEE-approved verification organizations submit reports verifying
compliance with these new requirements. This verification would provide
BSEE with reasonable assurance that the equipment is fit for service as
intended.
The BSEE is also proposing an additional qualification and
verification process for BOP(s) and related equipment used in HPHT
wells. The verification must be specific to the conditions of the
particular well at which the BOP(s) will be used. This verification
process is needed because there are currently no engineering standards
for the design, fabrication, and testing of equipment used in HPHT
conditions. The use of a BSEE-approved verification organization would
provide an additional layer of review and verification during the
development and operation of the equipment. It would be the
responsibility of the operator to clearly demonstrate to the BSEE-
approved verification organization and BSEE that the equipment was
designed for the HPHT conditions specific to the well, and will perform
in a reliable manner during its service life under those conditions. To
become a BSEE-approved verification organization, the organization
would have to submit documentation for approval describing the
organization's applicable qualifications and experience.
Failure Reporting/Near-Miss Reporting
Several of the standards that BSEE proposes to incorporate by
reference contain failure reporting processes that ensure that
operators share information with OEMs related to the performance of
their equipment. This sharing of information makes it possible for the
OEMs to notify users of any safety issues that arise. In 2009, the
industry provided the MMS with a BOP reliability study that
specifically noted the importance of ANSI/API Spec. 16A, Annex F, and
referred to this requirement as ``an excellent practice that assists
manufacturers in identifying problems that occur in the operation and
maintenance of their projects.'' The BSEE agrees with this statement
and is including this requirement in the proposed regulations.
Because the same equipment designs are often used by multiple
operators, ensuring the timely reporting of this type of data can play
an important role in preventing future incidents. The need for a
formalized process for disseminating information to the industry was
clearly demonstrated following the December 2012 failures of certain
bolts used in BOPs and wellhead connectors in the Gulf of Mexico (GOM).
Subsequent investigations revealed that although these failures had
occurred over a period of years, most of the industry was not aware of
the safety issues. The BSEE is proposing that the operators report any
significant problems with BOP or well-control equipment to BSEE to
ensure that this information can be provided in a timely manner to OCS
operators and the international community. In the long term, BSEE would
continue to encourage industry to develop a comprehensive and
formalized method of collecting, analyzing, and disseminating failure
data involving critical equipment.
Safe Drilling Practices
The proposed regulations include new requirements related to the
maintenance of safe drilling margins
[[Page 21511]]
consistent with the recommendations arising out of Deepwater Horizon
investigations. The BSEE also proposes to add requirements related to
liners and other downhole equipment. We believe that these requirements
would help to reduce the likelihood of a major well-control event
occurring and ensure the overall integrity of the well design.
The proposed rule would require that operators have the capability
to monitor deepwater and HPHT drilling operations from the shore and in
real time. This would allow operators to anticipate and identify issues
in a timely manner and to utilize onshore resources to assist in
addressing critical issues. It would allow BSEE greater visibility of
operations so BSEE may focus on specific critical operations for
additional oversight.
The BSEE also proposes a requirement that designated operators
report leaks associated with BOP control systems on the daily report,
in the WAR, and directly to the District Manager. This requirement
would ensure that the agency is made aware of any leaks and may
determine if agency action is appropriate.
The proposed regulation would include requirements concerning ROV
operations, including the adoption of API RP 17H to standardize ROV hot
stab activities. An ROV hot stab is a high pressure subsea connector
used to connect the ROV into the BOP system. An ROV hot stab is
basically comprised of two parts:
--A valve; and
--A tool that connects onto the valve and controls the valve.
The valve is usually placed on the subsea BOP stack panel, and is
accessible for an ROV to insert the tool and activate certain functions
on the BOP.
BOP Testing
In response to public input related to the value of pressure
testing in predicting future performance of a BOP and industry concerns
about the operational safety issues associated with performing these
tests, BSEE proposes to modify the BOP testing frequency for workover
and decommissioning operations. The BSEE proposes to change the current
7 day BOP testing interval for workover (current Sec. 250.617(b)) and
decommissioning (current Sec. 250.1707(b)) operations to 14 days,
which is consistent with the testing frequency requirements (reference
current Sec. 250.447(b) and 250.517(a)) for drilling and completion
operations. Some drilling, completion, workover, and decommissioning
operations use the same rigs and BOP systems; therefore, to ensure
consistency among different operations involving the same equipment,
BSEE proposes to harmonize the requirements for that type of equipment.
Harmonizing the testing frequency would streamline the BOP function-
testing criteria and increase safety by reducing repetition of
operations, such as pulling out of the hole and running in the hole,
that pose operational safety issues, therefore limiting the exposure of
potential risks to offshore personnel. This may also have a positive
effect on overall equipment durability and reliability.
A benefit of this provision would be a cost saving to industry. We
estimated the total cost savings to industry from this provision to be
$150,000,000 per year (see the economic analysis for more detailed
information). Based upon existing available data and the timeframes of
the economic analysis, the cost savings benefits of the proposed rule
would result in benefits greater than the identified quantitative costs
of the rule. The BSEE is requesting comments on whether the proposed
BOP testing interval should be 7 days, 14 days (as proposed), or 21
days for all types of operations including drilling, completions,
workovers, and decommissioning. The BSEE is also requesting comments on
the specific cost implications of each testing interval to further its
consideration of the issue. For more information on the costs and
benefits of the proposed rule, refer to the economic analysis.
In addition to cost savings benefits, BSEE's economic analysis also
considers benefits from potential reductions in oil spills and reduced
fatalities. The BSEE is requiring additional measures (e.g. real-time
monitoring and increased maintenance) that help ensure the
functionality and operability of the BOP system and, therefore, will
reduce the risks of spills and fatalities.
The BSEE is also soliciting comments on the use of pressure and
functional tests during drilling operations to verify performance, the
adequacy of current and proposed testing requirements, and the
identification of risks associated with increasing or decreasing the
testing frequency.
II. Organization of Subpart G
The BSEE determined that the most effective way to communicate
consistent requirements for BOPs across all well operations (drilling,
completion, workover, and decommissioning) is to consolidate those
common requirements in one location. The current regulations repeat
similar BOP requirements in multiple locations throughout 30 CFR part
250. The BSEE is proposing to consolidate these requirements into
Subpart G, which is currently reserved. This would allow better
flexibility, efficiency, and consistency in future rulemaking. The
proposed rule would structure proposed Subpart G--Well Operations and
Equipment, under the following undesignated headings:
--GENERAL REQUIREMENTS
--RIG REQUIREMENTS
--WELL OPERATIONS
--BLOWOUT PREVENTER (BOP) SYSTEM REQUIREMENTS
--RECORDS AND REPORTING
The sections contained within this new subpart would apply to all
drilling, completion, workover, and decommissioning activities, unless
explicitly stated otherwise.
III. Effective Date of a Final Rule
The BSEE understands that operators may need time to comply with
certain requirements proposed in this rule. The BSEE is taking into
consideration the amount of time needed to meet the requirements for
the installation of double shear rams and new certification
requirements. Based on information provided by industry, all new
drilling rigs are already being built, pursuant to the same industry
standards BSEE now proposes to adopt (including API Standard 53), and
many have already been retrofitted to comply with these industry
standards. Furthermore, most already comply with recognized engineering
practices and OEM requirements related to repair and training. The BSEE
evaluated the proposed requirements in this proposed rule and seeks to
set reasonable effective dates for those requirements based on
information gained during, among other activities, interaction with
stakeholders, involvement with development of industry standards, and
evaluation of current technology. The BSEE proposes an effective date
of 3 months following publication of the final rule. Operators would be
required to demonstrate compliance with most of the proposed
requirements at that time, with the exception of the following more
extended timeframes:
--Operators would be required to comply with the real-time monitoring
requirements within 3 years from the publication of the final rule.
--Operators would be required to install double shear rams on subsea
BOPs and on surface BOPs on floating facilities within 5 years from the
publication of the final rule.
--Operators would be required to install shear rams that center drill
pipe during shearing operations within 7
[[Page 21512]]
years from the publication of the final rule.
The BSEE is soliciting comments about the proposed compliance dates
for the requirements in this proposed rule to ensure the dates are
appropriate. The BSEE is specifically soliciting comments on whether
the 3-month, 3-year, 5-year, and 7-year compliance dates are
appropriate and achievable. The BSEE is also specifically soliciting
comments on whether the proposed requirements can be met sooner than
the proposed compliance dates (e.g., 5 years after publication of the
final rule for centering drill pipe), and the anticipated costs for
meeting these proposed compliance dates. Please provide justification
for your responses.
Note that BSEE still retains the discretion under Sec. 250.141 to
authorize alternate procedures or equipment that provide an equivalent
level of safety and environmental protection.
IV. Future Plans for Subpart G
In future rulemaking, BSEE intends to include additional regulatory
requirements for operations and equipment in Subpart G, such as:
--Well-control planning, procedures, training, and certification;
--Major rig equipment;
--Certification requirements for personnel servicing critical
equipment;
--Choke and kill systems;
--Mud gas separators;
--Wellbore fluid safety practices, testing, and monitoring;
--Diverter systems with subsea BOPs; and
--Coiled tubing, snubbing, and wireline units.
The BSEE is also researching other topics that would be appropriate
for inclusion into this new subpart in future rulemakings.
V. Section-By-Section Discussion
Subpart A--General
What does this part do? (Sec. 250.102)
This section would be revised to add references for Subpart G to
(b)(1), (11), (12), and (13) and also add new paragraph (b)(19) to the
table. This would be added so the public will know that they can find
requirements about well operations and equipment in proposed Subpart G.
What must I do to protect health, safety, property, and the
environment? (Sec. 250.107)
Paragraph (a) of this section would be revised to include a general
performance-based requirement that operators utilize recognized
engineering practices that reduce risks to the lowest level practicable
during activities covered by the regulations and conduct all activities
pursuant to the applicable lease, plan, or permit terms or conditions
of approval. Recognized engineering practices may be drawn from
established codes, industry standards, published peer-reviewed
technical reports or industry recommended practices, and similar
documents applicable to engineering, design, fabrication, installation,
operation, inspection, repair, and maintenance activities. This risk
reduction objective is used in other regulatory programs and is
consistent with BSEE's goal of taking a more risk-based approach in its
regulations. This risk reduction principle has also been included in a
recently published industry document (API Bulletin 97) which addresses
drilling, completion, and workover activities.
Proposed paragraph (e) would be added to clarify BSEE's authority
to issue orders when necessary to protect health, safety, property, or
the environment. The first sentence authorizes BSEE to issue orders to
ensure compliance with the regulations. The second sentence clarifies
that BSEE may order that operations of a component or facility be shut-
in because of a threat of serious, irreparable, or immediate harm to
health, safety, property, or the environment posed by those operations
or because the operations violate law, including a regulation, order,
or provision of a lease, plan, or permit.
Service fees. (Sec. 250.125)
This table in this section would be revised to reflect the correct
citation for payment of the service fee relating to DWOPs.
Documents incorporated by reference. (Sec. 250.198)
This section would be revised to update citations of currently
incorporated documents and to incorporate new documents. Changes to
this section would include:
--Revising paragraph (h)(51) to update cross-references to the sections
incorporating API RP 2RD, Design of Risers for Floating Production
Systems (FPSs) and Tension-Leg Platforms (TLPs);
--Removing the incorporation of API RP 53 in paragraph (h)(63) and in
its place incorporating new API Standard 53, Blowout Prevention
Equipment Systems for Drilling Wells, Fourth Edition (with the
exception of the opt-out provision);
--Revising paragraph (h)(68) to update cross-references to the sections
incorporating API Spec. Q1, Specification for Quality Programs for the
Petroleum, Petrochemical and Natural Gas Industry;
--Revising paragraph (h)(70) to update cross-references to the sections
incorporating ANSI/API Spec. 6A, Specification for Wellhead and
Christmas Tree Equipment;
--Adding new paragraph (h)(89) to incorporate ANSI/API Spec. 11D1,
Packers and Bridge Plugs;
--Adding new paragraph (h)(90) to incorporate ANSI/API Spec. 16A,
Specification for Drill-through Equipment;
--Adding new paragraph (h)(91) to incorporate API Spec. 16C,
Specification for Choke and Kill Systems;
--Adding new paragraph (h)(92) to incorporate API Spec. 16D,
Specification for Control Systems for Drilling Well Control Equipment
and Control Systems for Diverter Equipment;
--Adding new paragraph (h)(93) to incorporate ANSI/API Spec. 17D,
Design and Operation of Subsea Production Systems--Subsea Wellhead and
Tree Equipment;
--Adding new paragraph (h)(94) to incorporate ANSI/API RP 17H, Remotely
Operated Vehicle Interfaces on Subsea Production Systems.
Paperwork Reduction Act statements--information collection. (Sec.
250.199)
This section would be revised by:
--Changing all the OMB Control Numbers from the 1010 numbering system
to BSEE's new 1014 numbering system;
--Rewording for plain language the reasons that BSEE collects the
information and how it is used; and
--Adding paragraphs for APDs, Application for Permit to Modify (APM),
and Subpart G in the table to identify the basis for the information
collection.
Subpart B--Plans and Information
What must the Deepwater Operations Plan (DWOP) contain? (Sec. 250.292)
The proposed rule would re-designate existing paragraph (p) to (q)
and add a new paragraph (p). Proposed new paragraph (p) would specify
FSHR requirements within the DWOP. The FSHRs are used in combination
with FPSOs. The use of FPSOs is relatively new to the GOM. There is
only one FPSO currently operating in the GOM; however, the use of FPSOs
is expected to increase in the next few years.
[[Page 21513]]
Currently, BSEE approves the use of FPSOs and associated FSHRs through
the DWOP process, but has no regulations specifically addressing the
use of FSHRs. Proposed paragraph (p) would outline what BSEE requires
in a DWOP that proposes the use of FSHRs. The new requirements would
include submission of the following:
--Detailed descriptions and drawings of the FSHR buoy and tether
system;
--Information on the design, fabrication, and installation of the FSHR
buoy and tether system, including pressure ratings, fatigue life, and
yield strengths;
--A description of how the operator met the design requirements, load
cases, and allowable stresses for each load case according to API RP
2RD, RP for Design of Risers for FPSs and TLPs;
--Detailed information regarding the tether system used to connect the
FSHR to a buoyancy air can;
--Descriptions of the monitoring system and a monitoring plan to
monitor the pipeline FSHR and tether for fatigue, stress, and any other
abnormal condition (e.g., corrosion) that may negatively impact the
riser or tether; and
--Documentation that the tether system and connection accessories for
the pipeline FSHR have been certified by an approved classification
society or equivalent and verified by the Certified Verification Agent
(CVA) as required in current Subpart I and clarified in BSEE NTL 2007-
G14, Pipeline Risers Subject to the Platform Verification Program.
Subpart D--Oil and Gas Drilling Operations
General Requirements. (Sec. 250.400)
The proposed rule, would revise this entire section including the
section heading. The current section entitled, Who is subject to the
requirements of this subpart? is not necessary because the subject
matter is sufficiently covered under Sec. 250.146, which states that
lessees, operators, and the person actually performing the activity to
which a requirement applies are jointly and severally responsible for
complying with the regulations.
The new proposed language would require drilling operations to be
done in a safe manner to protect against harm or damage to life
(including fish and other aquatic life), property, natural resources of
the OCS, including any mineral deposits (in areas leased and not
leased), the National security or defense, or the marine, coastal, or
human environment. The new section would also clarify that for drilling
operations, the operator would need to follow the requirements of this
subpart and the applicable requirements of proposed Subpart G.
What must I do to keep wells under control? (Sec. 250.401)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. 250.703.
When and how must I secure a well? (Sec. 250.402)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. 250.720.
What drilling unit movements must I report? (Sec. 250.403)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. 250.712.
What additional safety measures must I take when I conduct drilling
operations on a platform that has producing wells or has other
hydrocarbon flow? (Sec. 250.406)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. 250.723.
What information must I submit with my application? (Sec. 250.411)
This section would be revised by separating the diverter and BOP
descriptions in the table containing regulatory cross-references for
descriptions of APD information, and updating the cross-references to
include proposed Subpart G.
What must my description of well drilling design criteria address?
(Sec. 250.413)
This section would revise paragraph (g) to include the maximum ECD
on the pore pressure/fracture gradient plot. The ECD is the effective
density exerted by a circulating fluid against the formation that takes
into account the pressure drop in the annulus. The ECD is an important
parameter in avoiding kicks and losses, particularly in wells that have
a narrow window between the fracture gradient and pore pressure. This
information is necessary for proper well drilling design and for BSEE
to better review the drilling program.
What must my drilling prognosis include? (Sec. 250.414)
This section would revise paragraphs (c), (h), and (i) and add new
paragraphs (j) and (k).
Paragraph (c) of this section would be revised to better define the
safe drilling margin requirements. The planned safe drilling margins
would be required to be between the proposed drilling fluid weights and
the estimated pore pressures and the lesser of estimated fracture
gradients or casing shoe pressure integrity test. The safe drilling
margins would also have to meet the following conditions:
--Static downhole mud weight must be greater than estimated pore
pressure;
--Static downhole mud weight must be a minimum of one-half pound per
gallon below the lesser of the casing shoe pressure integrity test or
the lowest estimated fracture gradient;
--The ECD must be below the lesser of the casing shoe pressure
integrity test or the lowest estimated fracture gradient;
--When determining the pore pressure and lowest estimated fracture
gradient for a specific interval, related hole behavior must be
considered (e.g., pressures, influx/loss of fluids, and fluid types).
Changes to better define safe drilling margins are partially based
on the information revealed during investigations of the Deepwater
Horizon incident.\2\ Safe drilling margins are used to determine the
downhole fluid program and ensure fluid densities are capable of
controlling the estimated pore pressure and formation fluids while not
fracturing the formations. With clearer requirements for safe drilling
margins, operators would be able to better understand BSEE requirements
and design fluid programs accordingly.
---------------------------------------------------------------------------
\2\ See DOI JIT investigation recommendation, A3.
---------------------------------------------------------------------------
Paragraphs (h) and (i) would be revised with only minor wording
changes.
New paragraph (j) would be added to require that the drilling
prognosis include the type of wellhead and liner hanger systems to be
installed and a descriptive schematic. The descriptive schematic would
include, among other information, pressure ratings, dimensions, valves,
load shoulders, and locking mechanism, if applicable. This information
would assist BSEE in its review of the APD, and assist staff in
ensuring that the wellhead and liner hanger systems are adequate for
the proposed use.
New paragraph (k) would be added to require submittal of any
additional information required by the District Manager.
What must my casing and cementing programs include? (Sec. 250.415)
Paragraph (a) of this section would be revised to include casing
information for all sections of each casing interval. Operators would
also need to include
[[Page 21514]]
bit depths (including measured and true vertical depth (TVD)), and
locations of any installed rupture disks and indicate either the
collapse or burst ratings. Requiring this information for all sections
for each casing interval would make design calculations and submittals
more accurate and provide a complete representation of the well.
What must I include in the diverter description? (Sec. 250.416)
This heading and section would be revised to remove the BOP
descriptions and leave the diverter descriptions. The BOP descriptions
would be moved to new Subpart G in proposed Sec. Sec. 250.730,
250.731, and 250.732. The diverter requirements would remain unchanged.
What must I provide if I plan to use a mobile offshore drilling unit
(MODU)? (Sec. 250.417)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. 250.713.
What additional information must I submit with my APD? (Sec. 250.418)
Paragraph (g) of this section would be revised to require operators
to seek approval for plans to wash out or displace cement to facilitate
casing removal upon well abandonment. The request would need to include
a description of how far below the mudline the operator proposes to
displace cement and how the operator will visually monitor returns.
This proposed change would provide information that would assist BSEE
in its review of the APD.
What well casing and cementing requirements must I meet? (Sec.
250.420)
The introductory language in this section would be revised to
require that applicable casing and cementing requirements in proposed
Subpart G must also be followed.
Existing paragraph (a)(6) would be renumbered as paragraph (a)(7).
New paragraph (a)(6) would be added to require adequate centralization
to help ensure proper cementation. Multiple Deepwater Horizon
investigations discussed the use of centralizers, which are devices
that maintain the casing or liner in the center of the wellbore to help
ensure efficient placement of cement around the casing string. If an
operator cements casing off-center, the wellbore may not be properly
sealed. New paragraph (b)(4) would be added to specify that if casing
is needed that differs from what was approved in the APD, the operator
would have to contact the appropriate District Manager and receive
approval before installing the different casing. This addition is
necessary to ensure the casing is suitable for the well conditions and
for BSEE to have the most up-to-date wellbore information.
Paragraph (c) would be renumbered and revised by adding a new
paragraph (c)(2). New paragraph (c)(2) would require the use of a
weighted fluid to maintain an overbalanced hydrostatic pressure during
the cement setting time, except when cementing casings or liners in
riserless hole sections. This proposed change would enhance wellbore
stability during cementing.
The use of a weighted fluid is particularly important because most
well-control events occur due to inadequately weighted fluids in the
hole, as well as inadequate volume of fluid to hold back the pressures
in the well. A weighted fluid has a greater density than seawater. As
the density of the weighted fluid increases, it exerts a greater
hydrostatic pressure, thereby minimizing the potential for the well to
flow.
What are the casing and cementing requirements by type of casing
string? (Sec. 250.421)
Paragraph (b) of the table in this section would be revised to
specify that if oil, gas, or unexpected formation pressure is
encountered, the operator would have to set conductor casing
immediately and set it above the encountered zone, even if it is before
the planned casing point. This proposed change would ensure that
conductor casing is not placed across a hydrocarbon zone.
Paragraph (f) of the table in this section would be revised to
disallow the use of liners as conductor casing. When a liner is used as
conductor casing, a portion of the drive pipe is exposed to wellbore
pressure, and BSEE does not accept drive pipe as a pressure-rated
component. By prohibiting the use of liners as conductor casing, BSEE
would ensure that the drive pipe is not exposed to wellbore pressures.
What are the requirements for casing and liner installation? (Sec.
250.423)
This section would be revised as follows:
--Change the heading to more accurately reflect corresponding changes
within the section.
--Remove the pressure testing and negative pressure testing
requirements. The pressure testing requirements would be found in
proposed Sec. 250.721.
--Add information to clarify that liner latching mechanisms, if
applicable, would need to be engaged upon successfully installing and
cementing the casing string or liner.
This last addition would reinforce the importance that liners are
properly secured in place to ensure wellbore integrity. The
requirements for latching and lockdown mechanisms were also a topic of
discussion in the DOI JIT Deepwater Horizon investigation.
What are the requirements for prolonged drilling operations? (Sec.
250.424)
This section would be removed and reserved. The content of this
section would be moved to in proposed Sec. 250.722.
What are the requirements for pressure testing liners? (Sec. 250.425)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. 250.721.
What are the recordkeeping requirements for casing and liner pressure
tests? (Sec. 250.426)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. 250.746.
What are the requirements for pressure integrity tests? (Sec. 250.427)
Paragraph (b) would be revised to clarify that operators must
maintain the drilling margins as described in Sec. 250.414.
What must I do in certain cementing and casing situations? (Sec.
250.428)
Paragraph (b) of the table in this section would be revised to
require District Manager approval for hole interval drilling depth
changes greater than 100 feet TVD, and submittal of a professional
engineer (PE) certification, certifying that the PE reviewed and
approved the proposed changes. This requirement would assist BSEE in
verifying the actual well conditions. This new requirement would also
ensure proper PE review of associated changes.
Paragraph (c) of the table in this section would be revised to
clarify requirements concerning what actions must be taken if there is
an indication of an inadequate cement job. There are many indicators of
an inadequate cement job. These include lost returns, no returns to the
mudline or failure to reach the expected height for the specific cement
job, cement channeling, abnormal pressures, or failure of equipment. If
any of these indicators, or others, are encountered during the cement
job, then action must be taken to ensure the cement job is adequate.
Such actions may include running a temperature survey, running a cement
[[Page 21515]]
evaluation log (such as an ultrasonic or equivalent bond log), or a
combination of these or other techniques to check cement integrity by
verifying the top of cement, density, condition, bond, etc. If the
cement job is determined to be adequate, the results of the cement job
determination would be submitted to the District Manager in the WAR.
Paragraph (d) of the table in this section would be revised to
clarify that if an operator has an inadequate cement job, the District
Manager would have to review and approve all proposed remedial actions,
unless immediate actions must be taken to ensure the safety of the crew
or to prevent a well-control event. If the operator needs to take
immediate action, a description would be required to be submitted to
the District Manager once the action is completed. The paragraph would
also clarify that any changes to the well program would require PE
certification and would need to meet any other requirements imposed by
the District Manager.
New paragraph (k) would be added to the table in this section and
would add clarification concerning the use of valves on drive pipes
during cementing operations for the conductor casing, surface casing,
or liner, and require the following to assist BSEE in assessing the
structural integrity of the well:
--The operator would include a description in the APD of the plan to
use a valve that includes a schematic of the valve and height above the
water line.
--The valve would be remotely operated and full opening with visual
observation while taking returns.
--The person in charge of observing returns would be in communication
with the drill floor.
--The operator would record in the daily report and in the WAR if
cement returns were observed; and
--If cement returns were not observed, the operator would have to
contact the District Manager and obtain approval of proposed plans to
locate the top of cement, before continuing with operations.
These proposed additions in paragraph (k) would help BSEE assess
the well's structural integrity and verify cement suitability to the
mudline.
The overall changes to this section would help BSEE assess actual
well operations and conditions, and also would help ensure proper
design with additional PE review.
What are the general requirements for BOP systems and system
components? (Sec. 250.440)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. 250.730.
What are the requirements for a surface BOP stack? (Sec. 250.441)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. Sec. 250.733 and 250.735.
What are the requirements for a subsea BOP system? (Sec. 250.442)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. 250.734.
What associated systems and related equipment must all BOP systems
include? (Sec. 250.443)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. Sec. 250.733, 250.734, and
250.735.
What are the choke manifold requirements? (Sec. 250.444)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. 250.736.
What are the requirements for kelly valves, inside BOPs, and drill-
string safety valves? (Sec. 250.445)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. 250.736.
What are the BOP maintenance and inspection requirements? (Sec.
250.446)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. 250.739.
When must I pressure test the BOP system? (Sec. 250.447)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. 250.737.
What are the BOP pressure tests requirements? (Sec. 250.448)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. 250.737.
What additional BOP testing requirements must I meet? (Sec. 250.449)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. 250.737.
What are the recordkeeping requirements for BOP tests? (Sec. 250.450)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. 250.746.
What must I do in certain situations involving BOP equipment or
systems? (Sec. 250.451)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. 250.738.
What safe practices must the drilling fluid program follow? (Sec.
250.456)
This section would remove paragraph (j) and re-designate the other
paragraphs. The content of current paragraph (j) would be moved to
proposed Sec. 250.720 to clarify that this requirement applies to
drilling, workover, completion, and abandonment operations.
What are the source control and containment requirements? (Sec.
250.462)
This section and heading would be entirely revised. The existing
content of this section entitled, What are the requirements for well-
control drills? would be moved to proposed Sec. Sec. 250.710 and
250.711.
This proposed new section would add requirements for the operator
to demonstrate the ability to control or contain a blowout event at the
sea floor. This section would apply to operations using a subsea BOP or
a surface BOP on a floating facility.
Paragraph (a) would require the operator to determine its source
control and containment capabilities by evaluating the performance of
the well design to determine if a full shut-in can be achieved without
reservoir fluids broaching the sea floor. Based on this evaluation, if
the well can only be partially shut-in, then the operator would be
required to establish the ability to flow and capture any residual
fluids to a surface production and storage system.
Paragraph (b) would require that operators have access to, and the
ability to deploy, Source Control and Containment Equipment (SCCE)
necessary to regain control of the well. The SCCE means the capping
stack, cap and flow system, containment dome, and/or other subsea and
surface devices, equipment, and vessels whose collective purpose is to
control a spill source and stop the flow of fluids into the environment
or to contain fluids escaping into the environment. This equipment
would need to include, but not be limited to:
--Subsea containment and capture equipment, including containment domes
and capping stacks;
--Subsea utility equipment, including hydraulic power, hydrate control,
and dispersant injection equipment;
--Riser systems;
[[Page 21516]]
--ROVs;
--Capture vessels;
--Support vessels; and
--Storage facilities.
Paragraph (c) would require submittal of a description of the
source control and containment capabilities before BSEE would approve
an APD. The submittal to the Regional Supervisor would need to include
the following:
--The source control and containment capabilities for controlling and
containing a blowout event at the seafloor,
--A discussion of the determination required by paragraph (a), and
--Information showing that the operator has access to, and the ability
to deploy, all equipment necessary to regain control of the well.
Paragraph (d) would require that operators contact the District
Manager and Regional Supervisor for reevaluation of the source control
and containment capabilities if there are any well design changes or if
any of the approved SCCE is out of service.
Paragraph (e) would outline the maintenance, inspection, and
testing requirements of certain identified containment equipment as
follows:
------------------------------------------------------------------------
Additional
Equipment Requirements information
------------------------------------------------------------------------
(1) Capping stacks............. (i) Function test Pressure holding
all pressure critical
holding critical components are
components on a those components
quarterly that will
frequency (not to experience
exceed 104 days), wellbore pressure
during a shut-in
after being
functioned.
(ii) Pressure test Pressure holding
pressure holding critical
critical components are
components on a bi- those components
annual basis, but that will
not later than 210 experience
days from the last wellbore pressure
pressure test. All during a shut-in.
pressure testing These components
must be witnessed include, but are
by BSEE and a BSEE- not limited to:
approved all blind rams,
verification wellhead
organization, connectors, and
outlet valves.
(iii) Notify BSEE
at least 21 days
prior to
commencing any
pressure testing.
(2) Production safety systems (i) Meet or exceed ..................
used for flow and capture the requirements
operations. set forth in 30
CFR 250.800
through 250.808,
Subpart H.
(ii) Have all
equipment unique
to containment
operations
available for
inspection at all
times..
(3) Subsea utility equipment... Have all equipment Subsea utility
unique to equipment
containment includes, but is
operations not limited to:
available for hydraulic power
inspection at all sources, debris
times, removal, hydrate
control
equipment, and
dispersant
injection
equipment.
------------------------------------------------------------------------
All of these changes in this section are necessary for BSEE to
properly assess an operator's ability to access and deploy appropriate
equipment sufficient to control and contain a blowout subsea. The
Deepwater Horizon incident demonstrated a need for the capabilities to
control and contain subsea blowouts. Following the Deepwater Horizon
incident, operators did not resume certain drilling operations on the
OCS until successfully demonstrating their ability to control and
contain a subsea blowout. Industry quickly developed the capabilities
and equipment, and satisfactorily demonstrated to BSEE the equipment
capabilities to ensure subsea blowout control and containment.
The BSEE is considering applying the requirements of this section
to other operations besides those that use a subsea BOP or surface BOP
on a floating facility. Specifically, BSEE is soliciting comments on
whether the source control and containment requirements should be
applicable to wells drilled in shallow water. Please provide reasons
for your position. If your comment addresses anticipated costs
associated with such a requirement, please provide any available
supporting data.
When must I submit an Application for Permit to Modify (APM) or an End
of Operations Report to BSEE? (Sec. 250.465)
Paragraph (b)(3) would be revised to clarify that if there is a:
--Revision to the drilling plan;
--Major drilling equipment change; or
--Plugback,
operators would have to submit an EOR, Form BSEE-0125, as required in
proposed Sec. 250.744, within 30 days after completing the work. This
would help ensure that BSEE has the current well information.
What records must I keep? (Sec. 250.466)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. 250.740.
How long must I keep records? (Sec. 250.467)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. 250.741.
What well records am I required to submit? (Sec. 250.468)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. Sec. 250.742 and 250.743.
What other well records could I be required to submit? (Sec. 250.469)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. 250.745.
Subpart E--Oil and Gas Well-Completion Operations
General requirements. (Sec. 250.500)
This section would be revised to add a requirement to follow the
applicable requirements of new Subpart G in addition to Subpart E. With
the development of new Subpart G, BSEE would consolidate similar
requirements regarding drilling, workover, completion, and
decommissioning activities into a separate subpart. It is BSEE's
intention to include additional regulations regarding similar
operations and equipment in the new Subpart G in future regulations.
This section would also be revised to replace the word ``shall''
with ``must.'' This change would clarify that the provision is
mandatory.
Equipment movement. (Sec. 250.502)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. 250.723.
Crew instructions. (Sec. 250.506)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. 250.710.
[[Page 21517]]
Well-control fluids, equipment, and operations. (Sec. 250.514)
Paragraph (d) would be removed and its content would be moved to
proposed Sec. 250.720.
What BOP information must I submit? (Sec. 250.515)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. Sec. 250.731 and 250.732.
Blowout prevention equipment. (Sec. 250.516)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. Sec. 250.730, 250.733,
250.734, 250.735, and 250.736.
Blowout preventer system tests, inspections, and maintenance. (Sec.
250.517)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. Sec. 250.711, 250.737,
250.738, 250.739, and 250.746.
Tubing and wellhead equipment. (Sec. 250.518)
This section would be revised by removing paragraph (b),
redesignating the rest of the paragraphs to reflect the removal of
paragraph (b), and adding new paragraphs (e) and (f) to clarify packer
and bridge plug requirements. The content of paragraph (b) would be
moved to proposed Sec. 250.722 and would clarify that these
requirements apply to drilling, workover, completion, and abandonment
operations.
New paragraph (e) would add packer and bridge plug requirements
including:
--Adherence to newly incorporated API Spec. 11D1, Packers and Bridge
Plugs;
--Production packer setting depth to allow for a sufficient column of
weighted fluid for hydrostatic control of the well; and
--Production packer setting depth criteria.
New paragraph (f) would require, in your APM, a description and
calculations of how the production packer setting depth was determined.
Subpart F--Oil and Gas Well-Workover Operations
General requirements. (Sec. 250.600)
This section would be revised to add the requirement to follow the
applicable provisions of new Subpart G in addition to Subpart F. With
the new development of Subpart G, BSEE is consolidating similar
requirements regarding drilling, workover, completion, and
decommissioning activities. It is BSEE's intention to include
additional regulations regarding similar operations and equipment in
new Subpart G in future regulations.
This section would also be revised to replace the word ``shall''
with ``must.'' This change would clarify that the provision is
mandatory.
Equipment movement. (Sec. 250.602)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. 250.723.
Crew instructions. (Sec. 250.606)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. 250.710.
Well-control fluids, equipment, and operations. (Sec. 250.614)
Paragraph (d) would be removed and its content would be moved to
proposed Sec. 250.720.
What BOP information must I submit? (Sec. 250.615)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. Sec. 250.731 and 250.732.
Coiled tubing and snubbing operations. (Sec. 250.616)
The section would be revised by renaming the section heading to
``Coiled tubing and snubbing operations,'' removing paragraphs (a)
through (e), and re-designating paragraphs (f) through (h) as (a)
through (c). The content of existing paragraphs (a) through (e) would
be moved to proposed Sec. Sec. 250.730 and 250.733 through 250.736.
Blowout preventer system testing, records, and drills. (Sec. 250.617)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. Sec. 250.711, 250.737, and
250.746.
What are my BOP inspection and maintenance requirements? (Sec.
250.618)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. 250.739.
Tubing and wellhead equipment. (Sec. 250.619)
This section would be revised by removing paragraph (b),
redesignating the rest of the paragraphs to reflect the removal of
paragraph (b), and adding new paragraphs (e) and (f) to clarify packer
and bridge plug requirements. The content of paragraph (b) would be
moved to proposed Sec. 250.722.
New paragraph (e) would add packer and bridge plug requirements for
when operators pull and reinstall packers and bridge plugs, including:
--Adherence to newly incorporated API Spec. 11D1, Packers and Bridge
Plugs;
--Production packer setting depth to allow for a sufficient column of
weighted fluid for hydrostatic control of the well; and
--Production packer setting depth criteria.
This new paragraph would codify existing BSEE policy to ensure
consistent permitting. The incorporation of API Spec. 11D1 would
enhance packer and bridge plug reinstallation and ensure conformance to
industry specifications and good industry practices not previously
covered in BSEE regulations.
New paragraph (f) would require, in the APM, a description and
calculation of how the production packer setting depth was determined.
Subpart G--Well Operations and Equipment
This part of the section-by-section will not address any regulatory
provisions that BSEE proposes to move without change from existing
subparts to the new subpart G because the proposed moves in regulatory
text are discussed above. However, this portion of the section-by-
section will explain existing language that BSEE proposes to revise or
add as new provisions.
General Requirements
What operations and equipment does this subpart cover? (Sec.
250.700)
This proposed section explains that new Subpart G would apply to
drilling, completion, workover, and decommissioning activities and
equipment. New Subpart G would contain common requirements for these
activities. Every section in Subpart G would be applicable to drilling,
completion, workover, and decommissioning activities, unless explicitly
stated otherwise.
May I use alternate procedures or equipment during operations? (Sec.
250.701)
Content in this proposed section is similar to existing Sec.
250.408. This proposed section would explain that operators may seek
approval to use alternate procedures or equipment following the process
set forth in Sec. 250.141. This section would also specify that the
proposed alternate procedures and equipment must be discussed in the
APD or APM. This section would make the information in
[[Page 21518]]
Sec. 250.408 applicable to all operations covered by this subpart.
May I obtain departures from these requirements? (Sec. 250.702)
The content of this proposed section is similar to existing Sec.
250.409. This proposed section would explain that operators may request
departures from the regulations in this subpart by using the procedure
set forth in Sec. 250.142. Also, this section would clarify what would
be required for the departure request. Another addition to this section
would require that the departure request be discussed in the APD or
APM.
What must I do to keep wells under control? (Sec. 250.703)
The content of this proposed section was moved from existing Sec.
250.401. Language in this section would be revised to ensure
applicability to all operations covered under this subpart, and to
require the use of equipment that is designed, tested, and rated for
the most extreme conditions to which the equipment will be exposed
while in service. This section would also require that personnel be
trained according to the provisions of Subparts O and S. These subparts
outline minimum training requirements. The BSEE expects personnel
performing operations to be trained and knowledgeable of their required
actions and duties.
Rig Requirements
What instructions must be given to personnel engaged in well
operations? (Sec. 250.710)
The content of this proposed section was moved from existing
Sec. Sec. 250.462, 250.506, and 250.606. This section would require
personnel engaged in well operations to be instructed in safety
requirements, possible hazards, and general safety considerations as
required by Subpart S, prior to engaging in operations.
This proposed section would clarify that the well-control plan must
contain instructions for personnel about the use of each well-control
component of the BOP system, and include procedures for shearing pipe
and sealing the wellbore in the event of a well control or emergency
situation before maximum anticipated surface pressure (MASP) conditions
are reached. These changes would establish better proficiency for
personnel using well-control equipment.
What are the requirements for well-control drills? (Sec. 250.711)
The content of this proposed section was moved from existing
Sec. Sec. 250.462, 250.517(f), 250.617(c), and 250.1707(c). This
section would add minor revisions to make the requirement applicable to
all drilling, completion, workover, and decommissioning operations
covered under this subpart. This section would also clarify that the
same drill may not be repeated consecutively. These proposed changes
would establish better proficiency for personnel using well-control
equipment.
What rig unit movements must I report? (Sec. 250.712)
The content of this proposed section was moved from existing Sec.
250.403 with the following revisions and additions:
Paragraph (a) would be revised to add rig movement reporting
requirements for all rig units moving on and off locations. Rig units
include MODUs, platform rigs, snubbing units, wire-line units used for
non-routine operations, and coiled tubing units. This paragraph would
make rig movement reporting requirements applicable to all rigs
conducting operations covered under proposed Subpart G. The deadline
for notifying the District Manager about rig movements, using the Rig
Movement Notification Report (Form BSEE-0144), would increase from 24
to 72 hours. This proposed change would allow BSEE to better anticipate
upcoming operations and coordinate applicable permitting.
Paragraph (a)(2) would be revised to clarify that if operators
anticipate moving off location less than 72 hours after initially
moving onto location, the anticipated movement schedule may be included
on Form BSEE-0144. This clarification would be necessary if you have,
for example, coiled tubing and batch operations and there is not enough
time to submit the rig movement 72 hours in advance. Form BSEE-0144 has
been revised from its current version to reflect changes based on the
proposed rule. Revised Form BSEE-0144 is included in the Appendix to
this proposed rule.
Existing paragraph (c) would be replaced with a new paragraph (c)
requiring notifications if a MODU or platform rig is to be warm or cold
stacked. The notifications for MODUs or platform rigs would include:
--Where the rig is coming from;
--Location where it would be positioned;
--If it would be manned or unmanned; and
--Any changes in the stacking location.
Proposed paragraph (c) would also allow BSEE to have a better
understanding of where MODUs and platform rigs are located in case of
emergency situations possibly affecting surrounding infrastructure.
New paragraph (d) would require notification to the appropriate
District Manager of any construction, repairs, or modifications
associated with the drilling package made to the MODU or platform rig,
prior to resuming operations after stacking.
New paragraph (e) would also require notification to the District
Manager if a drilling rig enters OCS waters regarding where the
drilling rig is coming from. The BSEE expects that this notification
would provide information about the last location where the drilling
rig was conducting operations, or the shipyard location if it is coming
from a shipyard, for either a new build or repair. This notification
would assist BSEE in verifying the location and movement of the rigs.
This notification would also help BSEE verify rig fitness and
documentation requirements to allow the rig to conduct operations on
the OCS as outlined in proposed Sec. 250.713.
New paragraph (f) would clarify that if the anticipated date for
initially moving on or off location changes by more than 24 hours, an
updated Rig Movement Notification Report (Form BSEE-0144) would be
required. This revision would clarify to operators when a revision or
update would be required.
What must I provide if I plan to use a mobile offshore drilling unit
(MODU) or lift boat for well operations? (Sec. 250.713)
The content of this proposed section would be moved from existing
Sec. 250.417. This section would make the requirements applicable to
all operations covered under this subpart.
Revised paragraph (g) would add current monitoring requirements.
Current monitoring is discussed in BSEE NTL 2009-G02, Ocean Current
Monitoring. These proposed changes would help provide better
consistency in permits. Upon publication of the final rule, BSEE would
rescind BSEE NTL 2009-G02.
Do I have to develop a dropped objects plan? (Sec. 250.714)
This section would codify some of the language from BSEE NTL 2009-
G36, Using Alternate Compliance in Safety Systems for Subsea Production
Operations, to help avoid prolonged damage to subsea infrastructure and
aid operators' and BSEE's response to a dropped object.
This proposed new section would outline the requirements for
developing a dropped objects plan. This proposed section would be
applicable to all floating rig units in an area with subsea
[[Page 21519]]
infrastructure. This section would specify the requirements of a
dropped objects plans. The plan would be required to include:
--A description and plot of the path the rig would take while running
and pulling the riser;
--A plat showing the location of any subsea wells, production
equipment, pipelines, and any other identified debris;
--Modeling of a dropped object's path for various material forms, such
as a tubular (e.g., riser or casing) and box (e.g., BOP or tree) with
consideration given to metocean conditions;
--A description of communications, procedures, and delegated
authorities established with the production host facility to shut-in
any active subsea wells, equipment, or pipelines in the event of a
dropped object; and
--Any additional information required by the District Manager.
Do I need a global positioning system (GPS) for MODUs and jack-ups?
(Sec. 250.715)
This proposed new section would codify existing BSEE NTL 2013-G01,
Global Positioning System (GPS) for Mobile Offshore Drilling Units
(MODUs). The proposed requirements for GPSs include:
--Providing a robust and reliable means of monitoring the position and
tracking the path in real-time if the MODU or jack-up moves from its
location during a severe storm;
--Installing and protecting the tracking system's equipment to minimize
the risk of the system being disabled;
--Placing the GPS transponders in different locations for redundancy to
minimize risk of system failure;
--Capability of transmitting data for at least 7 days after a storm has
passed;
--Recording the GPS location data if the MODU or jack-up is moved off
location in the event of a storm; and
--Providing BSEE with real-time access to the MODU or jack-up location
data.
The BSEE would use the GPS data in emergency situations to minimize
potential damage to the offshore infrastructure.
Well Operations
When and how must I secure a well? (Sec. 250.720)
The content of this proposed section would be moved from existing
Sec. Sec. 250.402, 250.456(j), 250.514(d), 250.614(d), and 250.1709,
and would contain the following revisions and additions:
Paragraph (a) would add that the District Manager must be notified
when operations are interrupted. This paragraph would also add an
example to the list of events that would warrant interruption of
operations (currently in Sec. 250.402(a)). Specifically, if there is
any observed flow outside the well's casing, operators would have to
interrupt operations. The requirement to interrupt operations for the
additional event of observing flow outside the well's casing would
protect against a failure of the well's structural foundation and a
possible environmental incident. The requirement to notify the District
Manager would give BSEE awareness of interrupted operations and allow
for appropriate regulatory response. This paragraph would also require
a negative test in accordance with proposed Sec. 250.721 to ensure
wellbore and barrier integrity before removing a subsea BOP stack or
surface BOP stack on a mudline suspension well.
Paragraph (a)(2) would also clarify that if there is not enough
time to install the required barriers or if special circumstances
occur, the District Manager may approve alternate procedures or
barriers in accordance with Sec. 250.141. Some options that could be
considered include the use of:
--Blind or blind-shear rams;
--Pipe rams and an inside BOP (if hydrocarbons are not exposed in the
open hole);
--A drill string hang-off tool; and/or
--Storm packers.
This section would help ensure that during the events previously
discussed, the well would be properly secured.
New paragraph (b) would be added to consolidate the content of
existing Sec. Sec. 250.456(j), 250.514(d), 250.614(d), and 250.1709.
What are the requirements for pressure testing casing and liners?
(Sec. 250.721)
The content of this proposed section would be moved from existing
Sec. Sec. 250.423 and 250.425, and would include the following
revisions and additions:
Paragraph (a) would increase the minimum test pressure
specification for conductor casing, excluding subsea wellheads, from
200 psi in existing regulations (Sec. 250.423(a)(2)) to 250 psi.
Paragraph (b) would require operators to test each drilling liner
and liner-lap before any further operations are continued in the well.
Paragraph (c) would contain requirements for testing each
production liner and liner-lap.
Paragraph (d) would clarify that the District Manager may approve
or require other casing test pressures.
Proposed new paragraph (e) would add the requirement that operators
follow additional pressure test requirements when they plan to produce
a well. If a well would be fully cased and cemented, the operator would
have to pressure test the well to the maximum anticipated shut-in
tubing pressure before perforating the casing or liner. If a well would
be an open-hole completion, the operator would have to pressure test
the entire well to the maximum anticipated shut-in tubing pressure
before drilling the open-hole section of the well.
Proposed paragraph (f) would add a requirement for a PE
certification of proposed plans to provide a proper seal if there is an
unsatisfactory pressure test.
Proposed paragraph (g) would require a negative pressure test on
all wells that use a subsea BOP stack or wells with mudline suspension
systems and outline the requirements for those tests.
What are the requirements for prolonged operations in a well? (Sec.
250.722)
The content of this proposed section would be moved from existing
Sec. Sec. 250.424, 250.518(b), and 250.619(b), with revisions made to
clarify the requirements for well integrity for operations continuing
longer than 30 days from the previous casing test. If well integrity
has deteriorated to a level below minimum safety factors, this section
would require repairs or installation of additional casing and
subsequent pressure testing, as approved by the District Manager. To
obtain approval, a PE certification must be provided showing that he or
she reviewed and approved the proposed changes. The results of the
pressure test would be submitted to the appropriate District Manager.
These changes help ensure a proper wellbore integrity determination to
allow operations to continue.
What additional safety measures must I take when I conduct operations
on a platform that has producing wells or has other hydrocarbon flow?
(Sec. 250.723)
This proposed section would reflect a combination of existing
Sec. Sec. 250.406, 250.502, and 250.602.
Paragraph (b) would be modified from existing Sec. 250.406(a) to
clarify that the emergency shutdown station would be for the production
system. This revision would ensure that rig units would be able to
shut-in the production system of the host facility.
Paragraphs (d) and (e) would make minor revisions to clarify
applicability to all operations covered under proposed Subpart G and to
divide the paragraphs to make them easier to read and understand.
[[Page 21520]]
What are the real-time monitoring requirements? (Sec. 250.724)
This proposed new section would include a requirement covering
real-time monitoring by onshore personnel of the BOP system, fluid
handling system of the rig, and downhole conditions. This section would
be added, in part, based on multiple recommendations from various
Deepwater Horizon investigation reports. Having the real-time data
available to onshore personnel would increase the level of oversight
throughout operations. Onshore personnel could review data and help rig
personnel conduct operations in a safe manner. Also, onshore personnel
would be able to assist the rig crew in identifying and evaluating
abnormalities or unusual conditions while conducting operations. This
section would require that BSEE be provided access to the real-time
monitoring facility, upon request. Operators would also be required to
record and retain the data at an onshore location for recordkeeping
purposes and to make it accessible to BSEE upon request. If real-time
monitoring capability is lost during operations, the operator would be
required to immediately notify the District Manager, who may require
other measures until the real-time monitoring capability is restored.
The BSEE is considering expanding the requirements of this section
to other operations, not only those conducted with a subsea BOP or a
surface BOP on a floating facility or on any BOP operating in an HPHT
environment. The BSEE is specifically soliciting comments on whether
the real-time monitoring should be required for all well operations,
including shallow water shelf operations. Please provide reasons for
your position. If your comment addresses anticipated costs associated
with such a requirement, please provide any available supporting data.
Blowout Preventer (BOP) System Requirements
What are the general requirements for BOP systems and system
components? (Sec. 250.730)
This proposed section would reflect a combination of existing
Sec. Sec. 250.416, 250.440, 250.516, 250.616, and 250.1706 and would
also include the following revisions and additions:
--Require compliance with API Standard 53, ANSI/API Spec. 6A, ANSI/API
Spec. 16A, API Spec. 16C, API Spec. 16D, ANSI/API Spec. 17D, and API
Spec. Q1.
--Clarify that the working-pressure rating of each BOP component must
exceed the MASP as defined for their operation, such as drilling,
completion, or workover. For a subsea BOP, the MASP would be taken at
the mudline.
--Add a new performance measure for operators which would require the
BOP to be able to meet anticipated wellbore conditions and still be
able to perform its expected function of sealing the well.
Proposed paragraph (a) would require compliance with the following
API and ANSI/API documents:
API Standard 53--BOP system and components would have to be
designed, installed, maintained, inspected, tested, and used according
to API Standard 53. The API Standard 53 would be incorporated into the
regulations; however, if there is a conflict between API Standard 53
and these regulations, operators would have to follow the requirements
of these regulations (i.e., BSEE is requiring that surface BOPs on
floating facilities have the same dual shearing requirement as subsea
BOPs; API Standard 53 allows for an opt out of this standard with a
risk assessment that is not included in the proposed rule). Currently,
BSEE regulations only incorporate select sections of API RP 53
(accumulators, maintenance, and inspections). By incorporating new API
Standard 53, BSEE would greatly enhance the BOP requirements. As
previously discussed in the Background section, API Standard 53 is the
latest industry consensus standard to update and enhance BOP
requirements. After the Deepwater Horizon incident, multiple
investigations focused on the BOP stack. Every investigation made
multiple recommendations to improve the performance and regulation of
BOPs. Industry recognized the need to update the previous edition of
API RP 53. During the process of updating API RP 53, industry
determined that the document needed more substantive content and needed
to be raised from an RP to an industry standard. The current API
Standard 53 contains the industry consensus standards concerning
engineering and operating practices regarding BOP reliability and use.
Included in API Standard 53 is a list of normative references (industry
standards) that are indispensable to fully utilizing API Standard 53
and to ensure safe and reliable equipment. The normative references
include:
--ANSI/API Spec. 6A, Specification for Wellhead and Christmas Tree
Equipment;
--API Spec. 16A, Specification for Drill-through Equipment;
--ANSI/API Spec. 16C, Specification for Choke and Kill Systems;
--API Spec. 16D, Specification for Control Systems for Drilling Well-
control Equipment and Control Systems for Diverter Equipment; and
--ANSI/API Spec. 17D, Design and Operation of Subsea Production
Systems--Subsea Wellhead and Tree Equipment.
Sections of these industry standards apply to BOP systems. The BSEE
specifically proposes to incorporate these standards into the
regulations as applied to BOP systems to emphasize their significance
and make clear the industry standards that must be followed. The BSEE
is also requesting comments concerning whether any sections of these
documents should not be incorporated by reference.
For general reference, the following table shows relevant topics
from each of these industry standards. This table is not a complete
list of applicable sections, but is intended to show how these sections
interact with API Standard 53.
------------------------------------------------------------------------
Applicable topics in API
Industry standard standard 53 (but not limited
to):
------------------------------------------------------------------------
ANSI/API Spec. 6A, Specification for Flanges and hubs, Bolting and
Wellhead and Christmas Tree Equipment; clamps, Gaskets, Choke and
kill lines, Equipment marking
and storage, Equipment
modifications, Maintenance and
testing.
API Spec. 16A, Specification for Drill- Flanges and hubs, Bolting and
through Equipment; clamps, Gaskets, Choke and
kill lines, Equipment marking
and storage, Maintenance and
testing.
ANSI/API Spec. 16C, Specification for Choke manifolds, Choke and kill
Choke and Kill Systems; lines.
API Spec. 16D, Specification for Control systems, Maintenance
Control Systems for Drilling Well- and testing. Electro-hydraulic
control Equipment and Control Systems and multiplex control systems,
for Diverter Equipment; Auxiliary equipment,
Accumulators.
[[Page 21521]]
ANSI/API Spec. 17D, Design and Flanges and hubs, Bolting and
Operation of Subsea Production Systems clamps, Choke and kill lines,
-- Subsea Wellhead and Tree Equipment; Equipment marking and storage,
Maintenance and testing.
------------------------------------------------------------------------
Paragraph (a)(3) would require that pipe and variable bore rams be
capable of closing and sealing on drill pipe, workstrings, or tubing
under MASP with the proposed regulator settings of the BOP control
system. This new paragraph would help ensure the BOP control regulator
set points are sufficient to ensure closure and sealing of the pipe
rams.
Paragraph (a)(4) would require a current set of approved schematics
to be on the rig and at an onshore location. It would also require that
if there are any modifications to the BOP or control system that will
change your schematics, operations would be suspended until the
operator obtains approval of the new schematics from the District
Manager.
Paragraph (b) would require that operators design, fabricate,
maintain, and repair the BOP system pursuant to the requirements
contained in this subpart, OEM recommendations unless otherwise
directed by BSEE, and recognized engineering practices. Personnel
performing any repair or maintenance would be required to follow any
OEM training or certification recommendations unless otherwise directed
by BSEE.
Paragraph (c) would adopt the failure reporting procedures
contained in certain API documents. The BSEE would add specific time
frames for the completion of these procedures consistent with other
previously incorporated API standards and add a requirement that BSEE
be notified of any changes to operating or repair procedures adopted to
address or in response to a failure. This would allow BSEE to notify
the industry and international community of any significant safety
issues related to equipment design, and potentially prevent future
incidents.
Paragraph (d) would require that if an operator plans to use a BOP
stack manufactured after the effective date of the final rule, the
operator must use one manufactured pursuant to API Spec. Q1,
Specification for Quality Management System Requirements for
Manufacturing Organizations for the Petroleum and Natural Gas Industry.
Currently, BSEE uses API Spec. Q1 in association with the manufacture
of safety and pollution prevention equipment. The API Spec. Q1 outlines
the requirements for development of a quality management system that
provides for continual improvement, emphasizing defect prevention and
the reduction of variation. This quality management system facilitates
consistent and reliable manufacture. Also added to this section is the
option to seek approval to use quality assurance programs other than
API Spec. Q1.
The BSEE requests comments concerning whether other industry
standards should be incorporated into the regulations that ensure that
BOP equipment performs as designed during its service life.
What information must I submit for BOP systems and system components?
(Sec. 250.731)
This proposed section would reflect a combination of existing
Sec. Sec. 250.416, 250.515, 250.615, and 250.1705 with the following
revisions and additions:
The introductory text would reflect that the requirements of BOP
description submittals would apply to APDs, APMs, and other required
submittals. The introductory text would also clarify that the BOP
descriptions would not have to be resubmitted with any subsequent
permit application or submittal after the initial application that BSEE
approved or accepted when the operator moved onto location unless the
operator makes changes to what was initially approved or the operator
moves off location from that well. This introductory text would also
clarify that if the operator is not required to resubmit the BOP
information in subsequent applications, then the operator must document
why the submittal is not required--in other words, the operator would
need to reference the previously approved or accepted application or
submittal and state that no changes have been made. The information
required under this section would increase the quality of submitted
documents and enhance BSEE's review and permitting process.
Paragraph (a) would require submission of the following new BOP
descriptions:
--Pressure ratings of BOP equipment;
--Both surface and corresponding subsea pressures for a subsea BOP
test;
--Rated capacities of the fluid-gas separator system;
--Control fluid volumes needed to operate each component;
--Control system pressure and regulator settings needed to achieve an
effective seal of each ram BOP under MASP;
--Number and volume of accumulator bottles and bottle banks (for subsea
BOPs, include both surface and subsea bottles);
--Accumulator pre-charge calculations (for a subsea BOP system, include
both the surface and subsea calculations);
--All locking devices; and
--Control fluid volume calculations for the accumulator system (for a
subsea BOP system, include both the surface and subsea volumes).
Submission of these descriptions would enhance BSEE's review and
understanding of the entire BOP system.
Paragraph (b) would add the following new schematic drawing
requirements:
--Labeling the control system alarms and set points;
--Including all locking devices;
--Including control station locations;
--Labeling the type of shear ram(s), size range for variable bore
ram(s), size of any fixed ram(s), size of choke and kill lines, and
size of subsea BOP gas bleed line(s); and
--Including a cross-section of the riser for a subsea BOP system
showing number size, and labeling of all control, supply, choke, and
kill lines down to the BOP.
Paragraph (c) would reflect content from existing Sec. 250.416(e)
and require submission of the following certifications by a BSEE-
approved verification organization verifying that:
--Test data clearly demonstrates the shear ram(s) will shear the drill
pipe at the water depth as required in Sec. 250.732;
--The BOP was designed, tested, and maintained to perform at the most
extreme anticipated conditions; and
--The accumulator system has sufficient fluid to function the BOP
system without assistance from the charging system.
Paragraph (d) would require additional certification if an operator
uses a subsea BOP, a BOP in an HPHT environment, or a surface BOP on a
floating facility. The certification would include verification of the
following:
--The BOP stack is designed for the specific equipment on the rig and
for the specific well design;
[[Page 21522]]
--The BOP stack has not been compromised or damaged from previous
service; and
--The BOP stack will operate in the conditions in which it will be
used.
The BSEE is considering expanding the requirements of this
paragraph to all BOPs. The BSEE is specifically soliciting comments on
whether this certification requirement should be applied to all well
operations, including shallow water shelf operations and operations
with surface BOPs. Please provide reasons for your position. If your
comment addresses anticipated costs associated with such a requirement,
please provide any available supporting data.
Paragraph (e) would be entirely new for subsea BOPs. This paragraph
would require a listing of the functions with sequences and timing of
autoshear, deadman, and emergency disconnect sequence (EDS) systems.
These emergency systems were the topic of many Deepwater Horizon
investigations and multiple associated recommendations. It is BSEE's
position that submission of this additional information would improve
BSEE's ability to oversee the use of these critical systems.
Paragraph (f) would add a certification requirement stating that
the Mechanical Integrity Assessment Report required in proposed Sec.
250.732(d) has been submitted within the past 12 months for a subsea
BOP, a BOP being used in an HPHT environment as defined in Sec.
250.807, or a surface BOP on a floating facility.
The items covered under this section have not been routinely
submitted to BSEE or obtained by the operators charged with
responsibility to maintain well control, and BSEE believes these items
are important to fully understand the entire BOP system and to verify
that it would perform in an acceptable manner.
What are the BSEE-approved verification organization requirements for
BOP systems and system components? (Sec. 250.732)
This proposed section would reflect a combination of existing
Sec. Sec. 250.416, 250.515, 250.615, and 250.1705, along with new
requirements. This proposed section is necessary to ensure that BSEE
receives accurate information regarding BOP systems so that BSEE may
ensure the system is appropriate for the proposed use. The third-party
verification and documentation by a BSEE-approved verification
organization would enhance the BSEE review during the permitting
process. The objective is to have this equipment monitored during its
entire lifecycle by an independent third-party to verify compliance
with BSEE requirements, OEM recommendations, and recognized engineering
practices. The BSEE believes that the importance and complexity of BOP
systems and the fact that they might be operated at various worldwide
locations throughout their service life warrants a thorough and regular
assessment of the systems and verification that design, installation,
maintenance, inspection, and repair activities are documented and
traceable.
The list of approved verification organizations would be limited to
those that can clearly demonstrate the capability to perform this
comprehensive detailed technical analysis.
Paragraph (a) would clarify that BSEE will maintain a list of BSEE-
approved verification organizations, and also outline criteria to
become a BSEE-approved verification organization.
Paragraph (b) would be applicable to any operation that requires
any type of BOP, and would require verification of shear testing,
pressure integrity testing, and calculations for shearing and sealing
pressures for all pipe to be used. Each of these verifications must
demonstrate outlined specific requirements.
Paragraph (c) would require a special verification process for BOP
and related equipment being used in HPHT environments because the
design conditions required for an HPHT environment exceed the limits of
existing engineering standards. The use of a BSEE-approved verification
body would provide BSEE with an additional layer of review and
verification at all steps in the development process. The paragraph
makes it clear that the operator has the burden of clearly
demonstrating the reliability of the equipment through a comprehensive
review of the design, testing, and fabrication process.
Paragraph (d) would require an annual submittal of a Mechanical
Integrity Assessment Report for a subsea BOP, a BOP used in HPHT
environment, or a surface BOP on a floating facility. This paragraph
would outline the requirements of a Mechanical Integrity Assessment
report.
Paragraph (e) would require operators to make all documentation
that supports the requirements of this section available to BSEE upon
request.
The BSEE believes that using a third-party to verify the testing
and qualification of BOP equipment would ensure consistent results and
provide a reasonable assurance of the performance of this equipment.
Based on previous studies available on the Web site of BSEE's
Technology Assessment Program (available at: https://www.bsee.gov/Technology-and-Research/Technology-Assessment-Programs/Index), BSEE
believes that the development of more rigorous industry testing
protocols is critical to demonstrating the performance of BOP
equipment.
The BSEE requests comments on the following issues associated with
this section:
--On the issue of standardized test protocols and whether there are any
specific procedures that should be considered for adoption.
--On the importance of applying forces in tension or compression during
the actual shearing tests.
--On what criteria should be used to qualify a BSEE-approved
verification organization and whether OEMs should be considered for the
program.
--On the issue of updating test protocols and criteria used by
verification organizations, given the likelihood of future improvements
to BOP technology.
What are the requirements for a surface BOP stack? (Sec. 250.733)
This proposed section would be a combination of existing Sec. Sec.
250.441, 250.443, 250.516, 250.616, and 250.1706 with the following
revisions and additions:
Paragraph (a) would contain revisions clarifying its applicability
to all operations covered under Subpart G.
Paragraph (a) would also clarify that the blind-shear rams would
have to be able to shear the drill pipe, workstring, tubing, and any
electric-, wire-, or slick-line. If the blind-shear ram could not cut
and seal electric-, wire-, or slick-line under MASP, an alternative
cutting device would be required on the rig floor during operations
that require their use, to cut the wire before closing the BOP. This
requirement would be necessary to ensure that there are means to cut
the wire in the hole, even if it is an external cutting device.
Paragraph (b) would codify BSEE policy and would:
--Clarify that when using a surface BOP on a floating production
facility:
--the same BOP requirements apply as in Sec. 250.734(a)(1), and
--a dual bore riser configuration would be required for risers
installed after the effective date of this rule before drilling or
operating in any hole section or interval where hydrocarbons may be
exposed to the well;
--Require risers to meet the design requirements of API RP 2RD;
[[Page 21523]]
--Clarify that the annulus between the risers must be monitored during
operations;
--Require a description of the monitoring plan in the APD or APM,
including how you would secure the well if a leak is detected; and
--Clarify that the inner riser for a dual riser configuration is
subject to the requirements for testing the casing or liner.
API Standard 53 does not impose dual shear requirements for surface
BOPs on floating facilities; however, this proposed rule would require
dual shears. If there is any conflict between the documents
incorporated by reference and these regulations, the operator would be
required to follow these regulations.
Proposed paragraph (c) would contain content from current Sec.
250.443(c) for surface BOP stacks to contain one side outlet for a
choke line and one side outlet for a kill line. There would be a new
requirement that the outlet valves must hold pressure from both
directions.
Existing Sec. 250.441(d) would not be carried forward to proposed
Sec. 250.733 because it is unnecessary to state that the regulations
covered under this subpart are required.
Proposed paragraph (d) would contain content from a portion of
existing Sec. 250.443(d). An addition, this paragraph would require
that the outlet valves must be full-bore, full-opening. This would
prevent leaks into and out of the BOP stacks.
Proposed paragraph (e) would require installation of hydraulically
operated locks.
Proposed Paragraph (f) would add specific requirements for a
surface BOP used in HPHT environments, if operations are suspended to
make repairs to any part of the BOP system. The BSEE is considering
requiring the same dual shear ram requirements in proposed Sec.
250.734(a)(1) for BOPs used in HPHT environments. The BSEE is
requesting comments on requiring dual shear rams for BOPs used in HPHT
environments, and how long it would take to comply with the dual shear
requirement for BOPs used in HPHT environments. If your comment
addresses anticipated costs associated with such a requirement, please
provide any available supporting data.
What are the requirements for a subsea BOP system? (Sec. 250.734)
This proposed section would reflect a combination of existing
Sec. Sec. 250.442, 250.443, 250.516, 250.616, and 250.1706.
Proposed paragraph (a)(1) would require two BOPs equipped with
shear rams. This new requirement would correspond to API Standard 53,
and would increase the shearing capabilities of a BOP stack. This
paragraph would also clarify that both shear rams would have to be able
to shear at any point along the tubular body of any drill pipe
(excluding tool joints, bottom-hole tools, and bottom hole assemblies,
which include heavy-weight pipe or collars), workstring, and tubing, as
well as be able to shear the liner casing landing string, shear sub on
subsea test tree, and any electric-, wire-, or slick-line in the hole
under MASP. At least one shear ram would have to be capable of sealing
the wellbore under MASP after shearing. Any non-sealing shear rams
would have to be installed below the sealing shear rams. These
requirements would help ensure that shearing the pipe and sealing the
wellbore could be achieved.
Proposed paragraph (a)(3) would clarify that the accumulator
capacity would have to be located subsea to provide closure of the BOP
components and operate critical functions in case of a loss of the
power fluid connection to the surface. The critical functions and
components would be defined as each shear ram, choke and kill side
outlet valves, one pipe ram, and lower marine riser package (LMRP)
disconnect. This paragraph would also require that the subsea
accumulator system have the capability of delivering fluid to each ROV
function i.e., flying leads. The accumulator would be required to have
dedicated independent bottles for the autoshear, deadman, and EDS
systems. The subsea accumulator would have to be capable of performing
under MASP. These new requirements would ensure that the subsea
accumulators would be able to provide fluid to each ROV function. The
reference to API RP 53 in current Sec. 250.442(c) would not be carried
forward to the proposed paragraph.
Proposed paragraph (a)(4) would include requirements that the ROV
would have to be able to perform critical BOP functions, including
opening and closing each shear ram, choke and kill side outlet valves,
all pipe rams, and the LMRP disconnect under MASP conditions. This
paragraph would also include a new requirement that the ROV panels must
be compliant with API RP 17H.
Proposed paragraph (a)(5) would require communication between the
ROV crew and the rig personnel familiar with the BOP. This
communication would help ROV crews perform proper operations and better
determine appropriate BOP conditions.
Proposed paragraph (a)(6) would include requirements of an
autoshear, deadman, and EDS system for dynamically positioned rigs, and
autoshear and deadman systems for moored rigs. This paragraph would
also require each emergency function to include both shear rams closing
under MASP. The sequencing of each emergency function would have to
provide for the lower shear ram beginning closure before the upper
shear ram would begin closure. Also, the control system for the
emergency functions would be required to be a fail-safe design, and
each step in the logic would have to be independent of the previous
step being completed. These revisions to the emergency functions would
help provide the best means to carry out the intended functions. In the
past, some BOP systems have only included one shear ram in the
emergency functions, and these additions would ensure including both
shear rams in those functions.
Proposed paragraph (a)(7) would add acoustic system requirements
similar to current Sec. 250.442(f)(3). The revision puts the acoustic
system option into its own designated paragraph. It would expand what
must be provided to the BSEE District Manager if an acoustic system is
to be used for a subsea BOP.
Proposed paragraph (a)(12) would be revised to connect this
paragraph to Sec. 250.720(b). This revision would clarify the intent
of this existing regulation and ensure that procedures are submitted
for review and approval in permits.
Proposed paragraph (a)(14) would revise a current requirements from
Sec. Sec. 250.443(c) and (d), 250.516, 250.616, and 250.1706. The
proposed rule would require subsea BOPs to contain two side outlets for
the choke line and two side outlets for the kill line. Each side outlet
would be required to have two full-bore, full-opening valves. The
proposed section would require these valves to be pressure-holding from
both directions. This section would also require a side outlet below
each sealing shear ram. Operators may have a pipe ram or rams between
the shearing ram and side outlet. This would enhance well-control
capability for subsea BOPs.
Proposed paragraph (a)(15) would require operators to install a gas
bleed line with two valves for the annular preventer. If dual annulars
would be installed with one on the LMRP and one on the lower BOP stack,
each annular would have to have a gas bleed line. The two valves would
need to be able to hold pressure from both directions.
[[Page 21524]]
Proposed paragraph (a)(16) would require subsea BOP systems to have
mechanisms capable of:
--Positioning the entire pipe, including connection, completely within
the area of the shearing blade necessary to ensure shearing would occur
any time the shear rams are activated. This mechanism could not be
another ram BOP or annular preventer;
--Mitigating compression of the pipe stub between the shearing rams.
(This provision was added based upon multiple Deepwater Horizon
investigation recommendations; the blind shear ram (BSR) could not
fully close and seal because the drill pipe was forced to the side of
the wellbore and outside of the BSR cutting surface); and
--Monitoring the subsea electronic module batteries in the BOP control
pods.
New paragraph (b) would codify BSEE policy and require that if
operations are suspended to make repairs to the BOP, operations would
have to be stopped at a safe downhole location. This section would also
require that before resuming operations, the operator would need to do
the following:
--Submit a revised permit with a report from a BSEE-approved
verification organization documenting the repairs and that the BOP is
fit for service;
--Perform a new BOP test upon relatch; and
--Receive approval from the District Manager.
Paragraph (b) would help BSEE ensure the BOPs have proper verification
after repairs and that BSEE would be aware of the repairs.
New paragraph (c) would codify BSEE policy. Additions to this
section would provide that if an operator plans to drill a new well
with a subsea BOP, the operator does not need to submit with its APD
the verifications required by this subpart for the open water drilling
operation. However, before drilling out the surface casing, the
operator would be required to submit for approval a revised APD,
including the third-party verifications required in this subpart. This
paragraph would allow operators to perform certain operations prior to
verification to facilitate the timing and scheduling of work.
The BSEE is also soliciting specific comments on the following
possible additional requirements:
--Under proposed paragraph (a)(1)(ii) of this section, requiring that
both shear rams be able to shear the appropriate area for the casing
landing string. Also please comment on whether there would be utility
in installing the non-sealing shear ram above the sealing shear ram,
and how it would affect the sequence of ram closure;
--Under proposed paragraph (a)(16) of this section, requiring a
position indicator for each ram BOP, wellhead connector, and LMRP
connector. The position indicator would have to be viewable by the ROV
during operations and in the event of a disconnect of the LMRP; and
--Under proposed paragraph (a)(16) of this section, requiring sensing
and displaying pressure within the BOP. This mechanism would have to be
viewable by the ROV during operations and in the event of a disconnect
of the LMRP.
These proposed requirements are in part based on various Deepwater
Horizon investigation recommendations.\3\ These proposed requirements
would help identify the status of various BOP components under
emergency situations to assist in emergency well control. If your
comment addresses anticipated costs associated with any of the above
requirements, please provide any available supporting data.
---------------------------------------------------------------------------
\3\ For example, BOP position indicator and display of
pressures--National Oil Spill Commission recommendation D4;
Centering pipe for shearing--DOI JIT recommendation D6; ROV
functions and capabilities--Offshore Energy Safety Advisory
Committee recommendation 07; Monitoring Subsea electronic module
batteries--DOI JIT recommendation D2.
---------------------------------------------------------------------------
The BSEE is also soliciting comments on whether there are other
options besides the use of shear rams to provide redundant shearing
capability while ensuring the same level of safety and environmental
protection.
What associated systems and related equipment must all BOP systems
include? (Sec. 250.735)
This proposed section would reflect a combination of existing
Sec. Sec. 250.441, 250.443, 250.516, 250.616, and 250.1706.
Proposed paragraph (a) would contain content from existing Sec.
250.441(c), with the following changes:
--Clarification that the requirements are for a surface accumulator
system;
--Clarification that the system would have to operate all BOP
functions, including shearing pipe and sealing the well against MASP
without assistance from a charging system; and
--Clarification that these provisions would apply to all BOP systems,
not just surface BOP stacks.
This revision would clarify existing regulations and ensure the BOP
system is capable of operating all critical functions.
Proposed paragraph (b) would add that the independent power source
must possess sufficient capability to close and hold closed all BOP
components under MASP.
Proposed paragraph (e) would add that the kill line must be
installed beneath at least one pipe ram.
What are the requirements for choke manifolds, kelly valves, inside
BOPs, and drill string safety valves? (Sec. 250.736)
This proposed section would reflect a combination of existing
Sec. Sec. 250.444, 250.445, 250.516, 250.616, 250.1707, with minor
edits to clarify applicability to all operations covered under this
subpart.
What are the BOP system testing requirements? (Sec. 250.737)
This proposed section would reflect a combination of existing
Sec. Sec. 250.447, 250.448, 250.449, 250.517, 250.617, 250.1707, and
be revised as follows:
Proposed paragraph (a) would reorganize pressure testing frequency
requirements into one section. A new provision would be added that the
District Manager may require more frequent testing for the BOP system
if conditions or BOP performance warrant. Additionally, by
consolidating the pressure test requirements for drilling, workovers,
completions, and decommissioning into one section, BSEE would revise
the workover and decommissioning BOP testing frequency to be consistent
with the 14-day frequency for drilling and completions. Some operations
use the same rigs and BOP systems; therefore, to ensure consistency
among different operations involving the same equipment, BSEE proposes
harmonizing the requirements for that type of equipment. Also, BOP
equipment that meets the new requirements of this proposed rule would
perform in a more reliable manner and provide additional assurances
that wells can be safely shut-in when necessary. The BSEE requests
comments on whether this increase in equipment reliability justifies
expanding the workover and decommissioning BOP testing frequency.
Proposed paragraph (b) would add a table to organize pressure
testing requirements. Paragraph (b)(1) would be for a low-pressure
test, and the required test pressure range would increase 50 psi to be
between 250 to 350 psi. Paragraph (b)(2) would add high-pressure test
requirements for BSR-type
[[Page 21525]]
BOPs, outside of all choke and kill side-outlet valves (and annular
gas-bleed valves for subsea BOP), and inside of all choke and kill
side-outlet valves below the uppermost ram. Paragraph (b)(3) would add
high-pressure test requirements for inside of choke or kill valves (and
annular gas bleed valves for subsea BOP) above the uppermost ram BOP
and would clarify test pressure procedures.
Proposed paragraph (c) would require that each test must hold
pressure for 5 minutes, which must be recorded on a 4-hour chart. This
would allow the chart to display enough line curvature length to detect
a leak during the test.
Proposed paragraph (d) would be reorganized into a table and
additional testing requirements would be added. Revisions to the
existing testing requirements would be:
Proposed paragraph (d)(1) would add a reference to the testing
requirements in API Standard 53. Operators would be required to follow
all testing requirements covered in API Standard 53, unless testing
requirements conflict with BSEE regulations, in which case operators
would be required to follow BSEE regulations.
Proposed paragraph (d)(2) would add requirements to use water to
test a surface BOP system. This paragraph would also require that
operators submit test procedures in their APD or APM for District
Manager approval and contact the District Manager at least 72 hours
prior to beginning the test to allow a BSEE representative to witness
testing.
Proposed paragraph (d)(3) would require that operators submit stump
test procedures for a subsea BOP system in their APD or APM for
District Manager approval and require that stump tests follow the
pressure test procedures set forth in paragraphs (b) and (c).
Proposed paragraph (d)(4) would outline the requirements for
performing the initial subsea BOP test on the seafloor.
Proposed paragraph (d)(5) would expand testing requirements for two
BOP control stations. The operator would be required to designate the
control stations as primary and secondary and function-test each
station weekly. The control station used to perform the pressure test
would be required to be alternated between each pressure test. For a
subsea BOP, the operator would be required to rotate the pods between
each control station during the weekly function tests and alternate the
pod used for pressure testing between each pressure test. If additional
control stations are installed, they would have to be tested every 14
days.
Proposed paragraph (d)(7) would be a new requirement to pressure
test annular type BOPs against the smallest pipe in use.
Proposed paragraph (d)(10) would be a new requirement to function
test BSR BOPs every 14 days. This requirement would align the timing of
the function and pressure tests.
Proposed paragraph (d)(12) would expand criteria for ROV testing to
include testing and verifying closure capability of all intervention
functions of the subsea BOP. These new provisions include requirements
that:
--Each ROV must be fully compatible with the BOP stack ROV intervention
panels;
--Operators must submit test procedures, including how they will test
each ROV intervention function; and
--Operators must document all test results and make them available to
BSEE upon request.
Proposed paragraph (d)(13) would expand requirements for function
testing autoshear, deadman, and EDS systems on subsea BOPs. The test
procedures must be submitted for District Manager approval, and the
proposed rule would require that the procedures include:
--Schematics of the circuitry of the system that would be used during
an autoshear or deadman event;
--The approved schematics of the BOP control system with the actions
and sequence of events that would take place; and
--How the ROV would be used during the well-control operations.
Prior to conducting the test, the well is to be in a secure
configuration with appropriate barriers. The testing of the deadman
system on the seafloor would have to indicate the discharge pressure of
the subsea accumulator system throughout the test. During the initial
test of the deadman system, the operator would need to have the ability
to quickly disconnect the LMRP. The operators would also have to submit
the quick-disconnect procedures with the deadman test procedures in the
APD or APM. The BSR(s) would need to be pressure tested according to
paragraphs (b) and (c) of this section. The operator would have to
include in its procedure a description of how it plans to verify
closure of a casing shear ram if installed. All test results would have
to be documented and submitted to BSEE upon request.
Proposed paragraph (e) would require that operators notify BSEE at
least 72 hours in advance of any shear ram tests in which the operators
will shear pipe. This would allow better scheduling for BSEE personnel
to witness these tests.
What must I do in certain situations involving BOP equipment or
systems? (Sec. 250.738)
This proposed section would be a combination of existing Sec. Sec.
250.451 and 250.517. Additional requirements would be added as follows:
As recommended by the DOI JIT investigation recommendation E2,
proposed paragraph (a) would require the operator to notify the
District Manager of any problems or irregularities, including leaks, if
BOP equipment does not hold the required pressure during testing.
Proposed paragraph (b) would require the operator to receive
approval from the District Manager prior to resuming operations after
replacing, repairing, or reconfiguring the BOP system. To obtain
approval, the operator would have to submit a report from a BSEE-
approved verification organization attesting that the BOP system is fit
for service. Any repair or replacement parts would have to be
manufactured under a quality assurance program and would have to meet
or exceed the performance of the original part produced by the OEM.
Proposed paragraph (d) would require the operator to notify the
District Manager of any problems or irregularities, including leaks, if
a BOP control station or pod does not function properly and suspend
operations until the station or pod operates properly.
Proposed paragraph (e) would be revised to clarify that two sets of
pipe rams must be capable of sealing around the smaller size pipe to be
consistent with Sec. Sec. 250.733(a) and 250.734(a)(1), which require
the capability to close and seal on the tubular body of any drill pipe,
workstring, and tubing.
Proposed paragraph (f) would add new requirements if the operator
proposes to install casing rams or casing shear rams in a surface BOP
stack. The ram bonnets would have to test to the rated working pressure
or MASP plus 500 psi and be tested before running casing. The BOP would
still need to be capable of sealing the well after the casing is
sheared. If the installation would be a change from the approved APM or
APD, the operator must notify and receive approval from the District
Manager.
Proposed paragraph (i) would require that, after pipe or casing is
sheared either intentionally or unintentionally, the operator would
have to retrieve, inspect, and test the BOP as well as submit a report
to the District Manager from a BSEE-approved verification
[[Page 21526]]
body, stating that the BOP is fit to return to service.
Proposed paragraph (j) would add a requirement that an operator
must have a minimum of two barriers in place prior to removal of the
BOP stack. The District Manager would have to approve the two barriers
and may require additional barriers prior to removal. This requirement
is consistent with similar requirements in current Sec. 250.420(b)(3),
and is necessary to ensure that the well is placed in a safe condition
prior to BOP removal.
Proposed paragraph (k) would add new requirements for re-
establishing power to a BOP stack after a deadman or autoshear
activation. Prior to re-establishing power, the operator would have to
examine the system to determine if the possibility exists for the BSR
opening immediately upon re-establishing power to the BOP stack. If
this is a possibility, the opening function would have to be placed in
the block position before power is re-established to the stack. The
operator would have to contact the District Manager to receive approval
of procedures for re-establishing power and functions prior to latching
up the BOP stack or re-establishing power to the stack.
Proposed paragraph (l) would establish requirements for test rams.
The initial BOP test after latch-up would have to be done with a test
tool, and the wellhead/BOP connection would have to be tested to the
maximum ram-test pressure approved for the well in the APD or APM. All
hydraulically operated BOP components would have to function as
designed during the well connection test.
Proposed paragraph (m) would add requirements for additional well-
control equipment that operators may use, but which are not required in
this subpart. The operator would have to request approval from the
appropriate District Manager, submit a report from a BSEE-approved
verification organization on the design and suitability of the
equipment for its intended use, and submit any other information
required by the District Manager. The District Manager may impose
requirements concerning the equipment's capabilities, operation, and
testing.
Proposed paragraph (n) would clarify that pipe and variable bore
rams that have no current utility and would not be used for well-
control purposes would not have to be pressure and function tested,
until they are intended to be used during operations. Operators would
have to indicate which pipe and variable bore rams meet this criteria
in their APD or APM and label those rams on all BOP control panels.
Proposed paragraph (o) would include new requirements applicable to
redundant well-control components in BOP systems that are in addition
to components required in Subpart G. If any redundant component fails a
test, you must submit a report from a BSEE-approved verification
organization that describes the failure and confirms that there is no
impact on the BOP that will make it unfit for well-control purposes.
This report would have to be submitted to the District Manager, and
operators may not resume operations until they receive the District
Manager's approval. The District Manager may require operators to
submit additional information before approving continued operations.
Proposed paragraph (p) would add new requirements that operators
would have to meet if they need to position the bottom hole assembly
across the BOP for tripping or any other operations, including:
--Ensuring that the well is stable at least 30 minutes before
positioning the bottom hole assembly across the BOP, and
--Including in the well-control plan (required by proposed Sec.
250.710(b)) procedures for immediately removing the bottom hole
assembly from across the BOP in the event of a well control or
emergency situation before exceeding MASP conditions. This would ensure
that the operational conditions would not exceed the BOP design
specifications.
What are the BOP maintenance and inspection requirements? (Sec.
250.739)
This proposed section would reflect a combination of existing
Sec. Sec. 250.446, 250.517, 250.618, and 250.1708 with the following
revisions:
Proposed paragraph (a) would add that the BOP maintenance and
inspections must meet or exceed OEM recommendations, recognized
engineering practices, and industry standards incorporated by reference
into the regulations, including all provisions in API Standard 53. In
the past, BSEE has only required compliance with select sections of API
RP 53. By incorporating the updated edition (API Standard 53), BSEE
would increase the overall maintenance and inspection requirements.
Proposed paragraph (b) would be a new requirement that details the
procedures for a complete breakdown and inspection of the BOP and every
associated component every 5 years. This paragraph would also clarify
that the complete breakdown and inspection may not be performed in
phased intervals. Also, during this complete breakdown and inspection,
a BSEE-approved verification organization would have to be present
documenting the inspection and any problems encountered and produce a
detailed report. This independent third-party report would have to be
available to BSEE upon request. The BSEE is aware that, in the past,
various components of BOP stacks have not had this type of inspection
for more than 10 years. However, BSEE feels it is essential to ensure
that every component on the BOP stack has a complete breakdown and
detailed inspection every 5 years.
Proposed paragraph (c) would revise the subsea BOP inspection
requirement to include visual inspection of the wellhead and remove the
word ``television.''
Proposed paragraph (d) would require that the personnel who
maintain, inspect, or repair BOPs or other critical components meet the
qualifications and training criteria specified by the OEM and that such
maintenance, inspection, and repair be undertaken in accordance with
recognized engineering practices. This provision is necessary to ensure
that any personnel working on BOPs are properly qualified to perform
any maintenance, inspections, or repairs.
Proposed paragraph (e) would require that all records be made
available to BSEE upon request. This provision would also require
operators to ensure, by contract or otherwise, that a rig owner
maintains BOP records on the rig for 2 years from the date the records
are created or longer if directed by BSEE. Also, all design,
maintenance, inspection, and repair records must be maintained at an
onshore location for the service life of the equipment.
Records and Reporting
What records must I keep? (Sec. 250.740)
This proposed section would include content from existing Sec.
250.466 and would make the requirements applicable to all operations
covered under this subpart. This section would also include
recordkeeping of all tests conducted and real-time monitoring data
gathered during operations.
How long must I keep records? (Sec. 250.741)
This proposed section would contain content from existing Sec.
250.467 with minor edits to clarify applicability to all operations
covered under this subpart. This section would also include how long
records for real-time monitoring data must be kept.
[[Page 21527]]
What well records am I required to submit? (Sec. 250.742)
This proposed section would contain some content from existing
Sec. 250.468. The remainder of the existing Sec. 250.468 would be
included in proposed Sec. 250.743.
What are the well activity reporting requirements? (Sec. 250.743)
This proposed section would include content from existing
paragraphs (b) and (c) of existing Sec. 250.468, BSEE NTL 2009-G20,
Standard Reporting Period for the Well Activity Report, and BSEE NTL
2009-G21, Standard Conditions of Approval for Well Activities with the
following changes:
Proposed paragraph (a) would clarify the well activity reporting
timeframe for the GOM OCS Region as currently set forth in NTL 2009-
G20. This new revision would help clarify when to submit the WARs (Form
BSEE-0133) and accompanying Form BSEE-0133S, Open Hole Data Report. The
District Manager may require more frequent submittal of the WAR on a
case-by-case basis.
Proposed paragraph (c) would be revised to include in the WAR,
information from NTL 2009-G21 describing the operations conducted, any
abnormal or significant events that affect the permitted operation,
verbal approvals, the wells as-built drawings, casing fluid weights,
shoe tests, test pressures at surface conditions, and status of the
well at the end of the reporting period. The final WAR would include
the date operations finished. This paragraph would also require
describing the returns for casing cementing operations. This data would
provide BSEE with accurate information regarding the operations and
well conditions and verify the operator's compliance with past
approvals.
Upon final publication of this rule, BSEE will rescind any NTLs
that are superseded by this section in the final rule.
What are the end of operation reporting requirements? (Sec. 250.744)
This proposed section would combine provisions from existing
Sec. Sec. 250.465, 250.1712, 250.1717, and NTL 2009-G21, Standard
Conditions of Approval for Well Activities, and include clarifications
concerning the contents of the EOR (Form BSEE-0125). This information
would provide BSEE with important well data and provide a better
understanding of the operations and well conditions.
What other well records could I be required to submit? (Sec. 250.745)
This proposed section would reflect content from existing Sec.
250.469.
What are the recordkeeping requirements for casing, liner, and BOP
tests, and inspections of BOP systems and marine risers? (Sec.
250.746)
This proposed section would reflect a combination of existing
Sec. Sec. 250.426, 250.450, 250.517, 250.617, and 250.1707, with the
following revisions:
Proposed paragraph (b) would add the requirement for the designated
rig or contractor representative (e.g., the offshore installation
manager) and pump operator to sign and date the pressure charts and
reports as correct in addition to the onsite lessee representative
(e.g., the company man).
Proposed paragraph (d) would be clarify that identification of the
pods would not apply to coiled tubing and snubbing units.
Proposed paragraph (e) would clarify that any leaks observed during
testing or observed from the control station are considered
irregularities and would have to be reported to BSEE. Operations would
have to be suspended until BSEE grants approval to continue. This
revision would allow BSEE to be notified of the BOP irregularities to
help determine BOP operability.
Proposed paragraph (f) would add the timeframe for keeping the
records for a minimum of 2 years after completion of the operation and
require that the records would have to be made available to BSEE upon
request. The BSEE would be able to use this data as a tool to verify
the operator's compliance with past approvals and regulations.
Subpart P--Sulphur Operations
Well-control drills (Sec. 250.1612)
This section would update the reference for the drilling crew
requirements under proposed Sec. 250.711.
Subpart Q--Decommissioning Activities
What are the general requirements for decommissioning? (Sec. 250.1703)
This section would be revised as follows:
Paragraph (b) would include a new requirement that all packers and
bridge plugs would have to comply with API Spec. 11D1, which would help
ensure that packers and bridge plugs conform to design, manufacture,
and testing criteria to increase reliability and to ensure appropriate
use of the equipment. Currently, BSEE does not have specific guidelines
for packers and bridge plugs, and this addition would help BSEE verify
that wells have been properly plugged in accordance with API Spec.
11D1.
Paragraph (f) would be revised to add reference to the requirements
of new Subpart G. This would make Subpart G applicable to
decommissioning.
When must I submit decommissioning applications and reports? (Sec.
250.1704)
Paragraph (g) would be revised by removing current paragraphs
(g)(2), (g)(4), and (g)(6) and the associated instructions in the third
column, as well as by revising the numbering of current paragraphs
(g)(3) and (g)(5) to (g)(2) and (g)(3), respectively, and by updating
the applicable citations. Proposed paragraph (h) would be added to
state the requirements for when to submit the EOR, making it clear when
operators would have to submit the EOR versus an APM.
What BOP information must I submit? (Sec. 250.1705)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. Sec. 250.731 and 250.732.
Coiled tubing and snubbing operations. (Sec. 250.1706)
Paragraphs (a) through (e) would be moved to proposed Sec. Sec.
250.730, 250.733, 250.734, and 250.735. The section heading would be
renamed from, What are the requirements for blowout prevention
equipment? to Coiled tubing and snubbing operations. Remaining
paragraphs (f) through (h) would be redesignated as (a) through (c).
What are the requirements for blowout preventer system testing,
records, and drills? (Sec. 250.1707)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. Sec. 250.711, 250.736,
250.737, and 250.746.
What are my BOP inspection and maintenance requirements? (Sec.
250.1708)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. 250.739.
What are my well-control fluid requirements? (Sec. 250.1709)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. 250.720.
How must I permanently plug a well? (Sec. 250.1715)
Paragraph (a)(3)(iii)(B) of this section would be revised to add
that a ``casing'' bridge plug would be set 50 to 100 feet
[[Page 21528]]
above the top of the perforated interval. Adding the word ``casing,''
clarifies the plug requirements for the applicable scenario. The BSEE
has been contacted by multiple companies requesting clarification of
this type of requirement. The BSEE believes that the proposed addition
of ``casing'' adequately addresses the concerns stated by industry
participants and explains the correct intention of this proposed
section.
After I permanently plug a well, what information must I submit? (Sec.
250.1717)
This section would be removed and reserved. The content of this
section would be moved to proposed Sec. 250.744.
If I temporarily abandon a well that I plan to re-enter, what must I
do? (Sec. 250.1721)
This section would remove existing paragraph (g) and redesignate
paragraph (h) as (g). The content of existing paragraph (g) would be
required by proposed Sec. 250.744.
Additional Comments Solicited
In addition to the input previously requested, BSEE requests public
comment on the following issues.
(1) Rig Daily Operating Rates
Throughout the proposed rule and corresponding economic analysis,
the BSEE has estimated the daily rig rates and made assumptions based
on that estimation. The BSEE is soliciting comments on the
appropriateness of the values presented and is further requesting
corresponding data to substantiate any comments. The BSEE can use this
data to update the values in the final rule. The following chart shows
the daily operating costs used within the economic analysis.
------------------------------------------------------------------------
Estimated daily operating
Rig type cost
------------------------------------------------------------------------
Rigs that utilize a subsea BOP (e.g. $1,000,000
drillships, semi-submersibles)...........
Rigs that utilize a surface BOP (e.g. jack- 200,000
ups, lift boats).........................
------------------------------------------------------------------------
(2) Failure of Equipment Reporting and Information Dissemination
Several of the standards that are being incorporated by reference
include a process for the reporting of failures of equipment back to
the OEM. The BSEE proposes to adopt these processes and add a
requirement that BSEE be notified of major issues that require a design
change. This notification would help to ensure that the domestic and
international communities are able to react quickly to address
potential safety issues.
Because identical equipment designs are often used by multiple
operators, ensuring the timely reporting of failures involving critical
equipment can assist in identifying trends and play an important role
preventing future incidents. The BSEE believes that a more formalized
method of collecting, analyzing, and disseminating failure data is
warranted, especially for equipment failures that do not result in a
reportable incident. The need for this type of program was clearly
demonstrated following the December 2012 failures of certain bolts in
the GOM. Subsequent investigations revealed that although these
failures had been occurring over a period of years, most of the
industry was not aware of the safety issues. Even after safety alerts
were issued by BSEE and the OEM, some operators claimed that the amount
and quality of data that was released was not sufficient. The BSEE has
received comments from the industry stating that legal and commercial
barriers discouraged the voluntary reporting of this type of data.
The BSEE requests comments on whether this information should be
provided to the agency or a third-party to ensure the timely analysis
and wide-spread communication of the data. For example, are there
programs in other industries that could serve as a model for reporting
failure of OCS equipment? Are there third-party organizations that
would be good candidates for collecting and analyzing information and
issuing safety alerts? What type of data should be collected and
disseminated? How should information on international operations be
collected and disseminated?
(3) Maintenance and Training
Preventative and remedial maintenance is critical to maintaining a
satisfactory level of reliability during the operational life of
critical equipment. A lifecycle management approach toward safety
critical equipment is especially important as the industry moves into
the development of deepwater and HPHT reservoirs. More rigorous
inspection, maintenance, and repair practices and methods may be needed
to ensure the reliable performance of this equipment in these
environments.
The BSEE requests comments on whether there are any additional
standards or practices related to the repair and maintenance of this
equipment that should be considered by BSEE. The BSEE has completed a
major study related to maintenance, inspection and test activities, and
management systems. The BSEE requests information on any work that is
being conducted by the industry to develop industry standards
concerning these activities. The BSEE also requests comments on whether
there are predictive maintenance techniques or risk-based maintenance
approaches that should be used to supplement the proposed requirements.
The proposed regulation requires the use of real-time monitoring
systems for operations with a subsea BOP stack or involving HPHT
environments. The BSEE requests comments on the use of continuous
remote monitoring and diagnostic analysis of critical equipment using
condition-based maintenance (CBM). With CBM, critical equipment can be
monitored and maintenance actions performed based on information
collected through constant real-time monitoring of critical equipment.
These systems may provide early warning of potential problems that
could be addressed before costly and dangerous catastrophic failures.
The BSEE believes that these systems may help to verify the integrity
of the overall system during drilling operations in a more timely and
efficient manner.
The BSEE believes that it is important that components and
replacement parts for critical equipment meet quality design and
engineering standards that ensure that this equipment operates safely
and as originally designed during its service life. Additionally, the
equipment must be repaired and maintained by highly trained personnel
that understand the OEM design and repair standards. These requirements
are implicit in the Safety and Environmental Management Systems (SEMS)
requirements contained in existing BSEE regulations. The BSEE requests
comments on what type of training and certification programs
[[Page 21529]]
should be required for personnel working on this critical equipment.
Are there training and certification programs being used in other
industries that can serve as a model for the OCS personnel? How should
repairs being performed outside U.S. waters be monitored? Are there any
existing oil and gas training and certification programs that should be
incorporated into the regulations?
(4) Verification of BOP Performance
The BSEE believes that the proposed requirements would provide the
agency with additional assurance related to the overall reliability of
equipment in the future. The industry and BSEE currently rely on
function and hydrostatic tests to verify the performance of BOP
equipment in the field. These tests have traditionally been the primary
method of verifying the capability of in-service equipment.
In recent years, the industry has raised concerns related to
benefits of pressure and functional testing of subsea BOPs versus the
costs and potential operational issues. The BSEE requests comments on
the adequacy of the current functional and pressure test requirements
in predicting the performance of this equipment in subsequent drilling
operations. Under what circumstances or environments should the testing
frequency be increased or decreased? Are there additional technologies,
processes, or procedures that can be used to supplement existing
requirements and provide additional assurances related to the
performance of this equipment?
The latest industry study on BOP reliability and testing frequency
was submitted to the MMS in 2009. What type of additional research and
data collection is needed or has already been conducted to verify the
reliability of this equipment? Can the combination of real-time
monitoring and condition based maintenance justify reduced pressure
testing? Does testing too frequently result in a shorter BOP
operational lifespan?
Please provide supporting reasons and data for your responses.
(5) Increased Severing Capability
The BSEE is proposing a variety of requirements that will increase
the likelihood that a BOP will be able to severe a drill string in an
emergency situation to shut-in the well and prevent a catastrophic
blowout.\4\ However, there are a variety of components in the drill
string (e.g., drill collars) that cannot be severed using technology
that is currently being used in offshore operations. Accordingly, BSEE
is considering including the following requirement in Sec. 250.734 of
the final rule for subsea BOPs:
---------------------------------------------------------------------------
\4\ See recommendations of Offshore Energy Safety Advisory
Committee, August 2012 meeting, available at: https://www.bsee.gov/uploadedFiles/BSEE/About_BSEE/Public_Engagement/Ocean_Energy_Safety_Advisory_Committee/OESC%20Recommendations%20August%202012%20Meeting%20Chairman%20Letter%20to%20BSEE%20101512.pdf.
You must install technology that is capable of severing any
components of the drill string (excluding drill bits). You must
install this technology within 10 years from the publication of the
---------------------------------------------------------------------------
final rule.
Such a severing requirement would provide additional protection
against the potential loss of well control by requiring that operators
install supplemental technology that ensures all components of a drill
string, including those components that cannot be sheared with current
shear rams, could be severed in an emergency to allow the well to be
safely shut-in. The operator would have the flexibility to develop or
select the technology and equipment to accomplish this performance-
based requirement. The BSEE is aware of at least one candidate
technology that is currently being evaluated and believes that other
innovative or improved technologies would be developed to accomplish
this objective, if such a requirement is adopted in the final rule. The
industry has demonstrated that it has the financial resources and
technical expertise to develop the innovative technology needed to
explore and produce oil and gas resources in challenging deepwater and
HTHP environments.\5\
---------------------------------------------------------------------------
\5\ For example, soon after the Deepwater Horizon incident,
several of the largest oil companies created the Marine Well
Containment Co., and agreed to spend $1billion to develop and build
new containment technology for deepwater drilling. See https://www.npr.org/2011/04/19/135513456/oil-firms-seek-to-prove-they-can-contain-spills. In addition, BP initiated ``Project 20K''--a major
research and development initiative involving Maersk Drilling and
other companies--to develop new technologies, within a decade, for
drilling safely in deepwater under HPHT conditions. See https://www.maersk.com/en/the-maersk-group/about-us/maersk-post/2014-5/pushing-technological-boundaries. Similarly, McMoran has already
invested over $1.2 billion in deepwater drilling sites in the GOM
and is working with researchers and manufacturers to develop heavy
duty BOPs and make other necessary technological advances. See
https://www.forbes.com/sites/christopherhelman/2013/05/08/mcmoran-gives-update-on-davy-jones-the-1-billion-ultradeep-well/; https://www.spe.org/tech/2012/04/high-pressurehigh-temperature-challenges/.
See also https://www.shell.com/global/aboutshell/major-projects-2/perdido/unlocking-energy.html (Shell uses innovative, first-of-its-
kind technology to produce ultra-deep Perdido well).
---------------------------------------------------------------------------
In addition, BSEE is considering whether to also make this type of
requirement applicable to surface BOPs in Sec. 250.733 in the final
rule. The BSEE is requesting comments on the following issues:
--Please comment on whether BSEE should include a severing provision
for subsea BOPs in the final rule, as previously described. If BSEE
does so, please address whether that requirement should also apply to
surface BOPs, given the number of blowouts involving surface stacks.
--What incentives or other actions could be used to assist in the
development and implementation of this technology? What should BSEE's
role, if any, be in this development process?
--If BSEE includes a severing provision in the final rule, what would
be an appropriate effective date for such a requirement? In particular,
please comment on whether 10 years would be appropriate to develop
technology that could meet the severing requirement, or whether the
timeframe for development of such technology and for compliance with
the requirement could be shortened (e.g., to 5 years).
Please provide an explanation and data with your responses.
The BSEE is unable to locate any applicable comparative cost
estimates or other data to estimate the labor or other costs to
industry that would be associated with the installation of technology
capable of severing any components of the drill string (excluding drill
bits). Also, assessing or quantifying the potential benefits that could
arise from the reduction of risks over the 10-year period covered by
the economic analysis for this proposed rule would require additional
data. Accordingly, BSEE is also requesting comments on the following
issues associated with this potential severing provision:
--Please provide comments on any costs related to the development and
installation of technology that would be needed to satisfy this type of
performance-based requirement within 10 years. Assuming the final rule
includes such a provision, how should BSEE include such costs in the
final economic analysis for this rulemaking, given that the analysis
uses a 10-year period to estimate all costs and benefits?
--What would be the costs of developing and installing appropriate
technology to meet such a severing requirement in 5 years? If it would
not be feasible to comply with this requirement in 5 years, what would
be the incremental increase in costs of
[[Page 21530]]
any implementation deadline between 5 years and 10 years?
--How much would a severing requirement, whether applicable only to
subsea BOPs or to subsea and surface BOPs, reduce the risk or
consequences of a blowout? If BSEE includes such a requirement in the
final rule, to be effective 10 years after the final rule takes effect,
how could BSEE estimate the benefits of such risk reduction given that
those benefits would not be realized until after the 10-year economic
analysis period used in this proposed rule? If BSEE included such a
severing requirement with a shorter time period for compliance (e.g., 5
years from the final rule effective date), how could BSEE estimate the
potential risk reduction benefits?
--Please describe any alternative method (other than the potential
severing requirement) to protect against the potential loss of well
control. Please discuss whether such an alternative would be more or
less costly than the proposed requirement.
Please explain your conclusions and provide supporting information.
Appendix
The following appendix will not appear in the Code of Federal
Regulations. Appendix A is included in this proposed rule so we may
solicit your comments on proposed revisions to an existing form for use
in reporting some of the information required in proposed subpart G.
Appendix--Department of the Interior--Form BSEE-0144, ``Rig Movement
Notification Report.''
[[Page 21531]]
[GRAPHIC] [TIFF OMITTED] TP17AP15.005
[[Page 21532]]
[GRAPHIC] [TIFF OMITTED] TP17AP15.006
[[Page 21533]]
[GRAPHIC] [TIFF OMITTED] TP17AP15.007
BILLING CODE 4310-VH-C
VI. Derivation Tables
The following tables are intended to provide information about the
derivation of proposed requirements in Subparts A, B, D, E, F, proposed
G, P, and Q. These tables provide guidance on the following:
--The destination of various current requirements.
--The organization and content of the proposed revisions.
These tables do not provide definitive or exhaustive guidance, and
should be used in conjunction with the section-by-section discussion
and regulatory text of this proposed rule.
The following sections in 30 CFR part 250, subparts D, E, F, and Q
have either been [Removed and/or Reserved] according to the following
table.
------------------------------------------------------------------------
Removed and/or Reserved in 30
Subpart CFR Part 250
------------------------------------------------------------------------
D...................................... 401, 402, 403, 406, 417, 424,
425, 426, 440 through 451, 466
through 469.
E...................................... 502, 506, 515 through 517.
F...................................... 602, 606, 615, 617, 618.
Q...................................... 1705, 1707 through 1709, 1717.
------------------------------------------------------------------------
The proposed rule would make changes as outlined in the following
table:
------------------------------------------------------------------------
Proposed rule
Current regulations section section Nature of change
------------------------------------------------------------------------
Subpart A
------------------------------------------------------------------------
250.102(b).................... 250.102(b)....... Added reference to
new subpart G.
NEW........................... 250.107(a)(3), Added the use of
(a)(4); (e). recognized industry
practices and BSEE-
issued orders.
250.125(a)(2)................. 250.125(a)(2).... Revised (2) to
reflect the
redesignation of
250.292(q).
250.198(h).................... 250.198(h)....... Updated citations in
(h)(51), (68), (70);
removed the RP and
added in its place
the Standard in
(h)(63); added new
(h)(89-94).
250.199(e).................... 250.199(e)....... Updated OMB control
numbers and reword,
for plain language,
the reasons BSEE
collects the data.
And added paragraphs
for APDs, APMs, and
Subpart G.
------------------------------------------------------------------------
[[Page 21534]]
Subpart B
------------------------------------------------------------------------
250.292(p).................... 250.292(q)....... Redesignated.
NEW........................... 250.292(p)....... New section that
specifies FSHR
requirements within
the DWOP.
------------------------------------------------------------------------
Subpart D
------------------------------------------------------------------------
250.400....................... 250.400.......... Revised section
heading and
requirements to
encompass General
Requirements for
drilling and clarify
that Subpart G has
applicable
requirements as
well.
250.401....................... 250.703.......... Removed--similar
language found in
new Subpart G.
250.402....................... 250.720.......... Removed--similar
language found in
new Subpart G.
250.403....................... 250.712.......... Removed--similar
language found in
new Subpart G.
250.406....................... 250.723.......... Removed--similar
language found in
new Subpart G.
250.411....................... 250.411.......... Revised to separate
the diverter and the
BOP descriptions;
updating citations.
250.413(g).................... 250.413(g)....... Revised to add the
phrase ECD.
250.414....................... 250.414.......... Revised paragraphs
(c), (h), (i); added
new paragraphs (j)
and (k) to help
ensure the well's
structural integrity
and submission of
any additional
information required
by the District
Manager.
250.415(a).................... 250.415(a)....... Revised paragraph (a)
for casing
information in all
sections for each
casing interval.
250.416....................... 250.416(a), (b); Revised to remove
250.730; only the BOP
250.731; 250.732. descriptions in the
regulatory text and
section heading.
250.417....................... 250.713.......... Removed--similar
language found in
new Subpart G.
250.418(g).................... 250.418(g)....... Revised to include a
description of how
far below the
mudline the operator
proposes to displace
cement in the
request for
approval; revised
citation.
250.420....................... 250.420.......... Revised the
introductory
paragraph to include
applicable casing
and cementing
requirements in
Subpart G; added new
paragraph (a)(6) to
require adequate
centralization to
ensure proper
cementation; added
new paragraph (b)(4)
requiring District
Manager approval
before installing a
different casing
than what was
approved in the APD;
modified paragraph
(c) requiring the
use of a weighted
fluid.
250.421....................... 250.421(b) and Revised paragraph (b)
(f). so casing would have
to be set
immediately and set
above the
encountered zone,
even if it is before
the planned casing
point if oil or gas
or unexpected
formation pressure
arises. Revised
paragraph (f) to no
longer allow liners
to be installed as
conductor casing.
250.423....................... 250.423.......... Revised the section
heading and removed
the pressure testing
and negative
pressure testing
requirements; added
clarification about
latching mechanisms.
Edited the remaining
paragraphs of
250.423 for
organization.
250.423(a) and (c)............ 250.721.......... Removed--similar
language found in
new Subpart G.
250.424....................... 250.722.......... Removed--similar
language found in
new Subpart G.
250.425....................... 250.721.......... Removed--similar
language found in
new Subpart G.
250.426....................... 250.746.......... Removed--similar
language found in
new Subpart G.
250.427(b).................... 250.427(b)....... Revised paragraph (b)
to clarify that
operators must
maintain two
drilling margins.
250.428....................... 250.428.......... Revised paragraphs
(b) through (d).
Paragraph (b)
requires approval
for hole interval
drilling depth
changes greater than
100 ft. TVD, and the
submittal of a PE
certification that
the certifying PE
reviewed and
approved the
proposed changes;
paragraph (c)
clarifies
requirements when
there is any
indication of an
inadequate cement
job; and paragraph
(d) clarifies that
if there is an
inadequate cement
job, the District
Manager has to
review and approve
all remedial
actions; that the
changes to the well
program are
reviewed, approved,
and certified by a
PE; and any other
requirements of the
District Manager.
New paragraph (k)
adds requirements
concerning the use
of values on drive
pipe during
cementing
operations.
250.440....................... 250.730.......... Removed--similar
language found in
new Subpart G.
250.441....................... 250.733; 250.735. Removed--similar
language found in
new Subpart G.
250.442....................... 250.734.......... Removed--similar
language found in
new Subpart G.
250.443....................... 250.734; 250.735. Removed--similar
language found in
new Subpart G.
250.443(c) and (d)............ 250.733.......... Removed--similar
language found in
new Subpart G.
250.444....................... 250.736.......... Removed--similar
language found in
new Subpart G.
250.445....................... 250.736.......... Removed--similar
language found in
new Subpart G.
250.446....................... 250.739.......... Removed--similar
language found in
new Subpart G.
250.447....................... 250.737.......... Removed--similar
language found in
new Subpart G.
250.448....................... 250.737.......... Removed--similar
language found in
new Subpart G.
250.449....................... 250.737.......... Removed--similar
language found in
new Subpart G.
250.450....................... 250.746.......... Removed--similar
language found in
new Subpart G.
250.451....................... 250.738.......... Removed--similar
language found in
new Subpart G.
250.456(k).................... 250.456(j)....... Redesignated.
[[Page 21535]]
250.456(j).................... 250.720.......... Removed--similar
language found in
new Subpart G.
NEW........................... 250.462.......... New section heading
and requirements to
demonstrate
deepwater well
containment.
250.462....................... 250.710 and Removed heading and
250.711. requirements for
well- control
drills--similar
language found in
new Subpart G.
250.465(b)(3)................. 250.465(b)(3).... This paragraph was
revised to update
the citation for the
EOR form, BSEE-0125.
250.466....................... 250.740.......... Removed--similar
language found in
new Subpart G.
250.467....................... 250.741.......... Removed--similar
language found in
new Subpart G.
250.468(a).................... 250.742.......... Removed--similar
language found in
new Subpart G.
250.468(b) and (c)............ 250.743.......... Removed--similar
language found in
new Subpart G.
250.469....................... 250.745.......... Removed--similar
language found in
new Subpart G.
------------------------------------------------------------------------
Subpart E
------------------------------------------------------------------------
250.500....................... 250.500.......... Revised section
heading and
requirements to
encompass General
Requirements and
direct compliance
with new Subpart G
where applicable.
250.502....................... 250.723.......... Removed--similar
language found in
new Subpart G.
250.506....................... 250.710.......... Removed--similar
language found in
new Subpart G.
250.514(d).................... 250.720.......... Removed--similar
language found in
new Subpart G.
250.515....................... 250.731; 250.732. Removed--similar
language found in
new Subpart G.
250.516....................... 250.730; 250.733; Removed--similar
250.734; language found in
250.735; 250.736. new Subpart G.
250.517....................... 250.711; 250.737, Removed--similar
250.738, language found in
250.739; 250.746. new Subpart G.
250.518....................... 250.518(e), (f).. Removed paragraph (b)
and redesignated the
remaining
paragraphs. Added
new paragraphs (e)
and (f) to add API
Spec. 11D1, packer
and bridge plug
requirements, and a
description of
calculations of
packer setting
depth.
250.518(b).................... 250.722.......... Redesignated and
revised to include
additional
requirements for
prolonged
operations.
------------------------------------------------------------------------
Subpart F
------------------------------------------------------------------------
250.600....................... 250.600.......... Revised section
heading and
requirements to
encompass General
Requirements and
direct compliance
with new Subpart G
where applicable.
250.602....................... 250.723.......... Removed--similar
language found in
new Subpart G.
250.606....................... 250.710.......... Removed--similar
language found in
new Subpart G.
250.614(d).................... 250.720.......... Removed--similar
language found in
new Subpart G.
250.615....................... 250.731; 250.732. Removed--similar
language found in
new Subpart G.
250.616(a) through (e)........ 250.730; 250.733; Removed--similar
250.734; language found in
250.735; 250.736. new Subpart G.
250.616(f) through (h)........ 250.616(a) Redesignated with no
through (c). changes made to
regulatory text.
250.617....................... 250.711; 250.737; Removed--similar
250.746. language found in
new Subpart G.
250.618....................... 250.739.......... Removed--similar
language found in
new Subpart G.
250.619....................... 250.619.......... Removed paragraph (b)
and redesignated the
section. Added new
paragraphs (e) and
(f) to add packers
and bridge plug
requirements, API
Spec. 11D1, and a
description of
calculations of
packer setting
depth.
250.619(b).................... 250.722.......... Redesignated and
revised to include
additional
requirements for
prolonged
operations.
------------------------------------------------------------------------
New Subpart G
------------------------------------------------------------------------
General requirements
------------------------------------------------------------------------
NEW........................... 250.700.......... New section
describing what
operations and
equipment are
subject to the
requirements.
250.408....................... 250.701.......... Similar language
pertaining to
alternative
procedures or
equipment.
250.409....................... 250.702.......... Similar language
pertaining to
departures.
250.401....................... 250.703.......... Similar language
containing
requirements to keep
wells under control.
------------------------------------------------------------------------
Rig Requirements
------------------------------------------------------------------------
250.462; 250.506; 250.606..... 250.710.......... Similar language was
revised and
incorporated into
this section about
instructions for rig
personnel.
250.462; 250.517; 250.617; 250.711.......... Similar language was
250.1707. revised and
incorporated into
this section about
well-control drills.
250.403....................... 250.712.......... Similar language was
revised and
incorporated into
this section about
rig movement
notifications.
250.417....................... 250.713.......... Similar language was
revised and
incorporated into
this section about
MODUs or lift boat
requirements for
well operations.
[[Page 21536]]
NEW........................... 250.714.......... New section about
dropped objects
plans.
NEW........................... 250.715.......... New section about GPS
for MODUs and jack-
ups.
------------------------------------------------------------------------
Well Operations
------------------------------------------------------------------------
250.402; 250.456(j); 250.720.......... Similar language was
250.514(d); 250.614(d); revised and
250.1709. incorporated into
this section about
securing a well.
250.423(a), (c); 250.425...... 250.721.......... Similar language was
revised and
incorporated into
this section about
pressure testing
casing and liners.
250.424; 250.518; 250.619..... 250.722.......... Similar language was
revised and
incorporated into
this section
pertaining to
prolonged well
operations.
250.406; 250.502; 250.602..... 250.723.......... Similar language from
250.406, 250.502,
and 250.602 was
revised and
incorporated into
this section
relating to safety
measures on a
platform producing
wells or other
hydrocarbon flow.
NEW........................... 250.724.......... New section relating
to real-time
monitoring
requirements.
------------------------------------------------------------------------
Blowout Preventer (BOP) System Requirements
------------------------------------------------------------------------
250.416; 250.440; 250.516; 250.730.......... Similar language was
250.616(a) through (e); revised and
250.1706. incorporated into
this section about
general requirements
for BOP systems and
their components.
250.416; 250.515; 250.615; 250.731.......... Similar language was
250.1705. revised and
incorporated into
this section about
submittal
requirements for
information about
BOP systems and
their components.
250.416; 250.515; 250.615; 250.732.......... Similar language was
250.1705. revised and
incorporated into
this section
relating to third-
party information
for BOP systems and
their components.
250.441; 250.443(c), (d); 250.733.......... Similar language was
250.516; 250.616(a) through revised and
(e); 250.1706. incorporated into
this section and new
language was added
relating to
requirements for a
surface BOP stack.
250.442; 250.443(c), (d); 250.734.......... Similar language was
250.516; 250.616(a) through revised and
(e); 250.1706. incorporated into
this section and new
language was added
relating to
requirements for a
subsea BOP system.
250.441; 250.443; 250.516; 250.735.......... Similar language was
250.616; 250.1706. revised and
incorporated to this
section and new
language was added
relating to
equipment and
systems all BOPs
must have.
250.444; 250.445; 250.516; 250.736.......... Similar language was
250.616(a) through (e); revised and
250.1707. incorporated into
this section
pertaining to
requirements for
choke manifolds,
kelly valves, inside
BOPs, and drill
string safety
valves.
250.447; 250.448; 250.449; 250.737.......... Added new language
250.517; 250.617; 250.1707. and similar language
was revised and
incorporated into
this section
relating to BOP
system testing
requirements.
250.451 and 250.517........... 250.738.......... Added new language
and similar language
was revised and
incorporated into
this section for
situations arising
involving BOP
equipment or
systems.
250.446; 250.517; 250.618; 250.739.......... Similar language was
250.1708. revised and
incorporated into
this section
pertaining to BOP
maintenance and
inspection
requirements.
------------------------------------------------------------------------
Records and Reporting
------------------------------------------------------------------------
250.466....................... 250.740.......... Redesignated and
revised the types of
records to keep.
250.467....................... 250.741.......... Redesignated and
added records
relating to real-
time monitoring
data.
250.468(a).................... 250.742.......... Redesignated.
250.468(b) and (c)............ 250.743.......... Redesignated and
revised to include
more requirements
for the well
activity reporting.
250.465; 250.1712; 250.1717... 250.744.......... Redesignated and
revised to include
additional end of
operation reporting
requirements.
250.469....................... 250.745.......... Redesignated and
revised to update
references.
250.426; 250.450; 250.517; 250.746.......... Similar language was
250.617; 250.1707. revised and
incorporated into
this section
pertaining to record-
keeping for casing,
liner, and BOP
tests.
------------------------------------------------------------------------
Subpart P
------------------------------------------------------------------------
250.1612...................... 250.1612......... Revised to update
references.
------------------------------------------------------------------------
Subpart Q
------------------------------------------------------------------------
250.1703...................... 250.1703......... Revised paragraph (b)
to have new packers
and bridge plug
requirements,
including API Spec.
11D1. Revised
paragraph (e);
Redesignated
existing paragraph
(f) as (g); and
added a new
paragraph (f) to
follow the
applicable
requirements of
Subpart G.
250.1704...................... 250.1704......... Revised paragraphs
(g) and added new
paragraph (h) about
APMs and EORs.
250.1705...................... 250.731, 250.732. Removed--similar
language found in
new Subpart G.
[[Page 21537]]
250.1706(a) through (e)....... 250.730; 250.733, Removed--similar
250.734, and language found in
250.735. new Subpart G.
250.1706(f) through (h)....... 250.1706(a) Revised the section
through (c). heading;
redesignated.
250.1707...................... 250.711, 250.736, Removed--similar
250.737, 250.746. language found in
new Subpart G.
250.1708...................... 250.739.......... Removed--similar
language found in
new Subpart G.
250.1709...................... 250.720.......... Removed--similar
language found in
new Subpart G.
250.1715(a)(3)(iii)(B)........ 250.1715(a)(3)(ii Added the word
i)(B). ``casing.''
250.1717...................... 250.744.......... Removed--similar
language found in
new Subpart G.
250.1721(g)................... 250.744.......... Removed--similar
language found in
new Subpart G.
250.1721(h)................... 250.1721(g)...... Redesignated and text
remains unchanged.
------------------------------------------------------------------------
VII. Procedural Matters
Regulatory Planning and Review (Executive Orders (E.O.) 12866 and
13563))
E.O. 12866 provides that the Office of Information and Regulatory
Affairs (OIRA) in the OMB will review all significant rules. To
determine if this proposed rulemaking is a significant rule, BSEE had
an outside contractor prepare an economic analysis to assess the
anticipated costs and potential benefits of the proposed rulemaking.
The following discussion summarizes the economic analysis; a complete
copy of the economic analysis can be viewed at www.Regulations.gov (use
the keyword/ID ``BSEE-2015-0002'').
Changes to Federal regulations must undergo several types of
economic analyses. First, E.O.s 12866 and 13563 direct agencies to
assess the costs and benefits of regulatory alternatives and, if
regulation is necessary, to select a regulatory approach that maximizes
net benefits (including potential economic, environmental, public
health, and safety effects; distributive impacts; and equity). Under
E.O. 12866, an agency must determine whether a regulatory action is
significant and, therefore, subject to the requirements of the E.O. and
review by OMB. Section 3(f) of E.O. 12866 defines a ``significant
regulatory action'' as any regulatory action that is likely to result
in a rule that:
--Has an annual effect on the economy of $100 million or more, or
adversely affects in a material way the economy, a sector of the
economy, productivity, competition, jobs, the environment, public
health or safety, or state, local, or tribal governments or communities
(also referred to as ``economically significant'');
--Creates serious inconsistency or otherwise interferes with an action
taken or planned by another agency;
--Materially alters the budgetary impacts of entitlement grants, user
fees, loan programs, or the rights and obligations of recipients
thereof; or
--Raises novel legal or policy issues arising out of legal mandates,
the President's priorities, or the principles set forth in E.O. 12866.
The BSEE has determined that the proposed rule is a significant
rulemaking within the definition of E.O. 12866 because the estimated
annual costs or benefits would exceed $100 million in at least 1 year
of the 10-year analysis period. Accordingly, OMB has reviewed this
proposed regulation.
1. Need for Regulation
As previously explained, BSEE has identified a need to amend the
existing well-control regulations to ensure that oil and gas operations
on the OCS are conducted in a safe and environmentally responsible
manner. In particular, BSEE considers the proposed rule necessary to
reduce the likelihood of any oil or gas blowout, which can lead to the
loss of life, serious injuries, and harm to the environment. As was
evidenced by the Deepwater Horizon incident (which began with a blowout
at the Macondo well) on April 20, 2010, blowouts can result in
catastrophic consequences.\6\ The government and industry conducted
multiple investigations to determine the cause of the Deepwater Horizon
incident; many of these investigations identified BOP performance as a
concern. The BSEE convened Federal decision-makers and stakeholders
from the OCS industry, academia, and other entities at a public forum
on offshore energy safety on May 22, 2012, to discuss ways to address
this concern. The investigations and the forum resulted in a set of
recommendations to enhance safety and environmental protection of
offshore operations by improving BOP performance.
---------------------------------------------------------------------------
\6\ For example, any approximation of cost would incorporate
catastrophic spills such as the Deepwater Horizon incident. The cost
to BP of cleanup operations for the Deepwater Horizon incident has
been estimated at more than $14 billion. In addition to cleanup
costs, BP has paid over $14 billion to Federal, State, and local
governments as well as private parties for economic claims and other
expenses. See ``Deepwater Horizon Oil Spill: Recent Activities and
Ongoing Developments,'' J. Ramseur & C. Hagerty (2014),
Congressional Research Office, available at: https://www.fas.org/sgp/crs/misc/R42942.pdf.
---------------------------------------------------------------------------
As the agency charged with oversight of offshore operations
conducted on the OCS, BSEE seeks to improve safety and mitigate risks
associated with such operations. After careful consideration of the
various investigations conducted after the Deepwater Horizon incident
and industry's responses to the incident, BSEE has determined that the
requirements contained in this proposed rule are critical to address
risks associated with offshore operations. BSEE has determined that the
well-control regulations needed to be updated to incorporate some of
these recommendations. Other recommendations are being studied for
consideration in future rulemakings.
The proposed rule would create a new Subpart G in 30 CFR part 250
to consolidate requirements for drilling, completion, workover, and
decommissioning operations. Consolidating the requirements would
improve efficiency and consistency of the regulations and allow for
flexibility in future rulemakings. The proposed rule would also revise
provisions in Subparts D, E, F, and Q of part 250 to address concerns
raised in the investigations, internally within BSEE, and at the public
forum. Finally, the proposed rule would incorporate API Standard 53 to
ensure better BOP operability and more robust regulatory oversight.
2. Alternatives
The BSEE has considered three regulatory alternatives:
(1) Promulgate the requirements contained within the proposed rule,
including increasing the BOP testing frequency for workover and
decommissioning operations from the current requirement of once every 7
days to the proposed requirement of
[[Page 21538]]
once every 14 days. The following chart identifies the BOP testing
changes related to Alternative 1:
BOP Pressure Testing
----------------------------------------------------------------------------------------------------------------
Operation Current testing frequency Proposed testing frequency
----------------------------------------------------------------------------------------------------------------
Drilling/Completions.......... Once every 14 days..................... Once every 14 days.
Workover/Decommissioning...... Once every 7 days...................... Once every 14 days.
----------------------------------------------------------------------------------------------------------------
(2) Promulgate the requirements contained within the proposed rule
with a change to the required frequency of BOP pressure testing from
the existing regulatory requirements (i.e., once every 7 or 14 days
depending upon the type of operation) to once every 21 days for all
operations. The following chart identifies the BOP testing changes
related to Alternative 2:
BOP Pressure Testing
--------------------------------------------------------------------------------------------------------------------------------------------------------
Proposed testing frequency
Operation Current testing frequency (alternative 1) Alternative 2 testing frequency
--------------------------------------------------------------------------------------------------------------------------------------------------------
Drilling/Completions.......... Once every 14 days..................... Once every 14 days..................... Once every 21 days.
Workover/Decommissioning...... Once every 7 days...................... Once every 14 days..................... Once every 21 days.*
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Includes change from current 7 days to proposed 14 days
(3) Take no regulatory action and continue to rely on existing
well-control regulations in combination with permit conditions, DWOPs,
operator prudence, and industry standards.
By taking no regulatory action, BSEE would leave unaddressed most
of the concerns and recommendations that were raised \7\ regarding the
safety of offshore oil and gas operations and the potential for another
event with consequences similar to those of the Deepwater Horizon
incident.
---------------------------------------------------------------------------
\7\ See the DOI JIT report, REPORT REGARDING THE CAUSES OF THE
APRIL 20, 2010 MACONDO WELL BLOWOUT, September 14, 2011.; The
National Commission final report, DEEP WATER, The Gulf Oil Disaster
and the Future of Offshore Drilling, January 11, 2011; The Chief
Counsel for the National Commission report, Macondo The Gulf Oil
Disaster, February 17, 2011; National Academy of Engineering final
report, Macondo Well-Deepwater Horizon Blowout, December 14, 2011;
BSEE public offshore energy safety forum, May 22, 2012.
---------------------------------------------------------------------------
Alternative 2 was not selected because BSEE is lacking critical
data on testing frequency and equipment reliability. This issue may be
considered in the final rulemaking if BSEE receives sufficient data to
support Alternative 2.
The BSEE has elected to move forward with Alternative 1--the
proposed rule--which would incorporate recommendations provided by
government, industry, academia and other stakeholders, as well as API
Standard 53. In addition to addressing concerns and aligning with
industry standards, BSEE is functioning in a prudent capacity with this
proposed rule by advancing several of the more critical capabilities
beyond current industry standards based on internal knowledge and
experience. The proposed rule would also improve efficiency and
consistency of the regulations and allow for flexibility in future
rulemakings.
The BSEE is requesting comments on how long it would take to come
into compliance with the proposed rule as well as any other
alternatives BSEE may reasonably consider, including alternatives to
the specific provisions contained in the proposed rule.
3. Economic Analysis
The BSEE's economic analysis evaluated the expected impacts of the
proposed rule compared with the baseline. The baseline refers to
current industry practice in accordance with existing regulations,
industry permits, DWOPs, and industry standards with which operators
already comply.\8\ Impacts that exist as part of the baseline were not
considered costs or benefits of the proposed rule. Thus, the cost
analysis evaluates only activities and capital investments required by
the proposed rule that represent a change from the baseline. These
estimated compliance costs are discussed more specifically in the
associated full initial regulatory impact analysis (RIA), which can be
viewed at www.regulations.gov (use the keyword/ID ``BSEE-2015-0002'').
---------------------------------------------------------------------------
\8\ BSEE considers compliance with permits, DWOPs, and industry
standards to be ``self-implementing,'' as addressed in Section E.2
of OMB Circular A-4, ``Regulatory Analysis'' (2003), and thus
includes these costs in the baseline.
---------------------------------------------------------------------------
The analysis covers 10 years (2015 through 2024) to ensure it
encompasses the significant costs and benefits likely to result from
this proposed rule. A 10-year period was used for this analysis because
of the uncertainty associated with predicting industry's activities and
the advancement of technical capabilities beyond 10 years. It is very
difficult to predict, plan, or project costs associated with
technological innovation due to unknown technological or business
constraints that could drive a product into mainstream adoption or into
obsolescence. The regulated community itself has difficulty conducting
business modeling beyond a 10-year time frame. Over time, the costs
associated with a particular new technology may drop because of various
supply and demand factors, causing the technology to be more broadly
adopted. In other cases, an existing technology may be replaced by a
lower-cost alternative as business needs may drive technological
innovation. Extrapolating costs and benefits beyond this 10-year time
frame would produce more ambiguous results and therefore be
disadvantageous in determining actual costs and benefits likely to
result from this proposed rule. The BSEE concluded that this 10-year
analysis period provides the best overall ability to forecast reliable
costs and benefits likely to result from this proposed rule. When
summarizing the costs and benefits, we present the estimated annual
effects, as well as the 10-year discounted totals using discount rates
of 3 and 7 percent, per OMB Circular A-4, ``Regulatory Analysis.''
The BSEE welcomes comments on this analysis, including potential
sources of data or information on the costs and benefits of this
proposed rule. The BSEE quantified and monetized the
[[Page 21539]]
costs, using 2013 data, of all the provisions in the proposed rule
determined to result in a change compared to the baseline,
including:xs112
--Additional information in the description of well-drilling design
criteria;
--Additional information in the drilling prognosis;
--Prohibition of a liner as conductor casing;
--Additional capping stack testing requirements;
--Additional information in the APM for installed packers;
--Additional information in the APM for pulled and reinstalled packers;
--Rig movement reporting;
--Fitness requirements for MODUs and lift boats;
--Foundation requirements for MODUs and lift boats;
--Monitoring of well operations with a subsea BOP;
--Additional documentation and certification requirements for BOP
systems and system components;
--Additional information in the APD, APM, or other submittal for BOP
systems and system components;
--Submission of a Mechanical Integrity Assessment Report by a BSEE-
approved verification body;
--New surface BOP system requirements;
--New subsea BOP system requirements;
--New surface accumulator system requirements;
-- Chart recorders;
-- Notification and procedures requirements for testing of surface BOP
systems;
-- Alternating BOP control station function testing;
-- ROV intervention function testing; autoshear, deadman, and EDS
function testing on subsea BOPs;
-- Approval for well-control equipment not covered in Subpart G;
-- Breakdown and inspection of BOP system and components;
-- Additional recordkeeping for real-time monitoring; and
-- Industry familiarization with the new rule.
The BSEE estimated the benefits derived from time savings
associated with Sec. 250.737(d)(10) of the proposed rule and the
benefits derived from the reduction in oil spills and fatalities using
the incident-reducing potential of the proposed rule as a whole. The
largest time savings benefits would result from proposed Sec. 250.737
(d)(10), which would streamline the BOP function testing criteria and
increase the intervals between this testing. Although we also consider
benefits from potential reductions in oil spills and reduced
fatalities, the time savings benefits of the proposed rule result in
benefits greater than the costs of the rule to the extent that those
costs could be quantified. In other words, based upon existing
available data, the proposed rule is cost-beneficial when only the
benefits resulting from time savings are considered.\9\
---------------------------------------------------------------------------
\9\ Moreover, the analysis of Alternatives 1 and 2 did not
consider potential benefits related to extended equipment life and
reduced well control risks arising from fewer pressure tests and
fewer trips out of the hole.
---------------------------------------------------------------------------
The same is true of Alternative 2. A larger time savings benefit
would result from changing the BOP pressure testing interval for
workover and decommissioning from 7 days to 14 days plus increasing the
BOP pressure testing interval for all operations (including drilling,
completions, workovers, and decommissioning) from 14 days to 21 days.
This alternative would result in additional time savings to industry by
decreasing the number of required tests per year for operators. This
time savings would result in greater net benefits to operators.
We did not, however, include reduced trip time to perform BOP
testing in the calculations of savings for Alternative 2.\10\ Drilling
trip time depends on factors such as well depth, hole size, mud weight,
the amount of open hole, hole conditions, surge and swab pressure,
borehole deviation, bottom hole assembly configuration, hoisting
capacity, type of rigs, and crew efficiency. BSEE is not aware of any
analysis of offshore operations that provides reasonable estimates of
average trip time that could be used for the purpose of this
calculation. In addition, it is common practice in the GOM to perform
BOP tests earlier than the required interval whenever operational
opportunities become available (i.e., whenever there is no drill pipe
across the BOPs due to the need to change drill bits). This practice
would reduce the overall benefits from this alternative. BSEE requests
comments and data on both of these issues to assist in the assessment
of the overall benefits of this alternative.
---------------------------------------------------------------------------
\10\ Trip time refers to the time needed to stop drilling or
workover operations, remove or raise the drill/work string from the
well, and then lower the string back to the bottom of the well to
restart operations. A trip is often made to change a dull drill bit
and/or to perform the pressure test or BOP test. During some deep
drilling situations, the trip time may equal or exceed the on-bottom
drilling time.
---------------------------------------------------------------------------
The proposed rule also would reduce the probability of oil spills,
and the provisions with the highest costs to industry (such as real-
time monitoring of well operations and alternating BOP control station
function testing) will have the largest impact on reducing the risk of
spills. If the proposed rule reduces the risk of incidents, benefits
would result from the avoided costs associated with oil spills related
to personal injuries, natural resource damages, lost hydrocarbons,
spill containment and cleanup, and lost recreational use and lost
profits from commercial fishing. The magnitude of these benefits,
however, is dependent on the effectiveness of the proposed rule in
reducing the number of incidents, which is uncertain.
To estimate the potential benefits of the proposed rule associated
with reducing the risk of incidents, we examined historical data from
the BSEE oil spill database, which contains information for spills
greater than 10 barrels of oil for the GOM and Pacific regions. Based
upon an analysis of the BSEE oil spill database during the period
between 1964 and 2010, BSEE identified 27 blowouts associated with oil
spills greater than 10 barrels \11\ and used this data within the
economic analysis (see the initial RIA for details).\12\ Blowouts that
resulted in uncontrolled flow of gas, damage to a rig, and/or harm to
personnel (but not oil spills over 10 barrels) are not reflected in
this analysis.\13\ Accordingly, the benefits and the overall risk
reduction associated with this proposed rule may be understated. The
BSEE is specifically soliciting comments on any data and costs
associated with any blowout that did not result in an oils spill
greater than 10 barrels, and how to include that information within the
economic analysis.
---------------------------------------------------------------------------
\11\ See https://www.bsee.gov/Inspection-and-Enforcement/Accidents-and-Incidents/Spills/.
\12\ BSEE based the analysis on the historical oil spill
database for the period between 1964 and 2010, but recognizes that
significant regulatory and technological improvements have taken
place since 1964. If BSEE limited the analysis to the period 1988
(when the Department's offshore regulatory program was
comprehensively overhauled) through 2010, the potential benefits
from this reduction of risk would be substantially greater, due to
the impact of the Deepwater Horizon costs over such a shorter time
period.
\13\ Previous MMS studies indicate a total of 126 blowouts
during drilling operations on the OCS between 1971 and 2006. These
blowouts resulted in 26 fatalities, 63 injuries, damage to
facilities and equipment, and the release of hydrocarbons.
---------------------------------------------------------------------------
The actual reduction in the risk of oil spills to be achieved by
the proposed rule cannot be determined. Although a sensitivity analysis
was conducted for levels of risk reduction from 0 to 20 percent, our
economic analysis used a 1 percent risk reduction because it
[[Page 21540]]
represents BSEE's best expert judgment of the lower bound of risk
reduction that could result from the proposed rule.\14\ We multiplied
the annual number of spilled barrels of oil (the total number of
barrels spilled in the incidents divided by 46.945 years) by 1 percent
to estimate the expected annual reduction in barrels of oil spilled
associated with the proposed rule.
---------------------------------------------------------------------------
\14\ Several recent studies have estimated the probabilities of
blowout failures under a wide range of circumstances. See, e.g.,
``Blowout Preventer (BOP) Failure Event and Maintenance, Inspection
and Test (MIT) Data,'' American Bureau of Shipping and ABSG
Consulting, under BSEE contract M11PC00027 (June 2013); ``Deepwater
Horizon Blowout Preventer Failure Analysis: Report to the U.S.
Chemical Safety and Hazard Investigation Board,'' Engineering
Services (2014). Given this accumulated knowledge of failure
likelihoods, and analysis of how those likelihoods would be reduced
by the proposed rule, BSEE has determined that 1 percent is a
reasonable lower-bound of risk reduction that could occur as a
result of the proposed rule.
---------------------------------------------------------------------------
We then multiplied the annual reduction in spilled barrels of oil
by the social and private cost of a spilled barrel of oil, which is
estimated at $3,599 per barrel. This estimate was derived from the
Bureau of Ocean Energy Management (BOEM) ``Economic Analysis
Methodology for the Five Year OCS Oil and Gas Leasing Program for 2012-
2017'' (2012) (the BOEM Case Study),\15\ and includes costs associated
with natural resource damages, the value of lost hydrocarbons, and
spill cleanup and containment.\16\ We used a natural resource damage
cost of $642 per barrel and a cleanup and containment cost of $2,857
per barrel as estimated for the GOM in the BOEM Case Study. Consistent
with the BOEM Case Study, we used a value of lost hydrocarbons per
barrel of $100. The BSEE recognizes the uncertainty associated with
projecting the price of oil during the 10-year period of analysis and
thus includes a sensitivity analysis in the initial RIA for the price
of oil.
---------------------------------------------------------------------------
\15\ The BOEM Case Study presents seven separate cost categories
to estimate the impact of a catastrophic spill, including natural
resource damages, as well as impacts on recreation and commercial
fishing. The BOEM Case Study is available at: https://www.boem.gov/uploadedFiles/BOEM/Oil_and_Gas_Energy_Program/Leasing/Five_Year_Program/2012-2017_Five_Year_Program/PFP%20EconMethodology.pdf.
\16\ The BOEM Case Study presents per-barrel costs associated
with a catastrophic event. We use this estimate because the BOEM
Case Study represents a recent estimate for the costs associated
with an oil spill that reflects data from the Deepwater Horizon
incident.
---------------------------------------------------------------------------
In addition to the time savings and risk reduction benefits, the
proposed rule has other benefits. Due to difficulties in measuring and
monetizing these benefits, BSEE does not offer a quantitative
assessment of them. The BSEE has used a conservative approach in the
valuation of an oil spill, including only selected costs of such a
spill. For example, although the analysis captures the environmental
damage associated with a spill, the analysis is limited because it only
considers the environmental amenities that researchers could identify
and monetize. Therefore, the resulting benefits of avoiding a spill
should be considered as a lower-bound estimate of the true benefit to
society that results from decreasing the risk of oil spills.
Exhibit 1 displays the net benefits of the proposed rule under the
assumption that the reduction in the risk of incidents is 1 percent.
Although the analysis presents these benefit estimates based on our
lower bound assumption of potential risk reduction, there is
uncertainty around the level of risk reduction the proposed rule would
actually achieve. Accordingly, it is reasonably possible that the
actual benefits realized from the reductions in spill incidents will be
different from those assessed in this analysis. Nonetheless, as
discussed above, the proposed rule is cost-justified on the basis of
time savings alone.
Exhibit 1--Net Benefits
[At a 1-percent risk reduction from the proposed rule] \1\
--------------------------------------------------------------------------------------------------------------------------------------------------------
Total benefits Total benefits Net benefits Net benefits
Year (alternative 1) (alternative 2) Total costs (alternative 1) (alternative 2)
--------------------------------------------------------------------------------------------------------------------------------------------------------
2012 dollars/year
--------------------------------------------------------------------------------------------------------------------------------------------------------
1. 2015................................................. $153,988,977 $528,988,977 $164,862,782 ($10,873,805) $364,126,195
2. 2016................................................. 153,988,977 528,988,977 77,431,590 76,557,387 451,557,387
3. 2017................................................. 153,988,977 528,988,977 77,431,590 76,557,387 451,557,387
4. 2018................................................. 153,988,977 528,988,977 77,431,590 76,557,387 451,557,387
5. 2019................................................. 153,988,977 528,988,977 77,431,590 76,557,387 451,557,387
6. 2020................................................. 153,988,977 528,988,977 98,931,590 55,057,387 430,057,387
7. 2021................................................. 153,988,977 528,988,977 77,431,590 76,557,387 451,557,387
8. 2022................................................. 153,988,977 528,988,977 77,431,590 76,557,387 451,557,387
9. 2023................................................. 153,988,977 528,988,977 77,431,590 76,557,387 451,557,387
10. 2024................................................. 153,988,977 528,988,977 77,431,590 76,557,387 451,557,387
----------------------------------------------------------------------------------------------
Undiscounted 10-year total............................... 1,539,889,771 5,289,889,771 883,247,090 656,642,682 4,406,642,682
10-Year Total with 3% discounting........................ 1,313,557,210 4,512,383,273 763,397,731 550,159,479 3,748,985,543
10-Year Total with 7% discounting........................ 1,081,554,137 3,715,397,215 639,884,837 441,669,301 3,075,512,378
----------------------------------------------------------------------------------------------
10-year Average.......................................... 153,988,977 528,988,977 88,324,709 65,664,268 440,664,268
Annualized with 3% discounting........................... 153,988,977 528,988,977 89,493,503 64,495,474 439,495,474
Annualized with 7% discounting........................... 153,988,977 528,988,977 91,105,205 62,883,772 437,883,772
--------------------------------------------------------------------------------------------------------------------------------------------------------
\1\ Totals may not add because of rounding.
4. Sensitivity Analysis
This section presents sensitivity analysis of the potential
benefits of the proposed rule that could result from varying the
following factors:
(a) The level of risk reduction of oil spills achieved by the
proposed rule;
(b) The level of risk reduction of fatalities achieved by the
proposed rule; and
(c) The price of a barrel of oil (i.e., the value of lost
hydrocarbons).
Exhibit 2 presents the total 10-year benefits and net benefits
under a range of possible annual risk reduction levels for oil spills
from 0 to 20 percent. The
[[Page 21541]]
proposed rule is expected to have positive net benefits for the full
range of risk reduction levels.
In addition to the time savings and the prevention of oil spills,
the proposed rule is anticipated to reduce the risk of fatalities to
rig workers. The oil and gas extraction industry is characterized by a
relatively small percentage of the national workforce, but with a
fatality rate that is higher than the rate for most industries.
Exhibit 2--Net Benefits Under Different Risk Reduction Levels \1\
--------------------------------------------------------------------------------------------------------------------------------------------------------
Benefits (7% Benefits (3% Net benefits Net benefits (7% Net benefits (3%
Annual risk reduction (%) Annual benefits discounting) discounting) (undiscounted) discounting) discounting)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Total 10-Year
--------------------------------------------------------------------------------------------------------------------------------------------------------
0..................................... $0 $1,053,537,231 $1,279,530,426 $616,752,910 $413,652,394 $516,132,695
1..................................... 3,988,977 1,081,554,137 1,313,557,210 656,642,682 441,669,301 550,159,479
2..................................... 7,977,954 1,109,571,044 1,347,583,994 696,532,453 469,686,207 584,186,263
3..................................... 11,966,931 1,137,587,950 1,381,610,778 736,422,225 497,703,113 618,213,047
4..................................... 15,955,909 1,165,604,856 1,415,637,562 776,311,996 525,720,019 652,239,832
5..................................... 19,944,886 1,193,621,762 1,449,664,346 816,201,768 553,736,926 686,266,616
6..................................... 23,933,863 1,221,638,669 1,483,691,131 856,091,539 581,753,832 720,293,400
7..................................... 27,922,840 1,249,655,575 1,517,717,915 895,981,311 609,770,738 754,320,184
8..................................... 31,911,817 1,277,672,481 1,551,744,699 935,871,082 637,787,644 788,346,968
9..................................... 35,900,794 1,305,689,387 1,585,771,483 975,760,854 665,804,551 822,373,752
10.................................... 39,889,771 1,333,706,294 1,619,798,267 1,015,650,625 693,821,457 856,400,537
11.................................... 43,878,749 1,361,723,200 1,653,825,051 1,055,540,397 721,838,363 890,427,321
12.................................... 47,867,726 1,389,740,106 1,687,851,836 1,095,430,168 749,855,269 924,454,105
13.................................... 51,856,703 1,417,757,012 1,721,878,620 1,135,319,939 777,872,176 958,480,889
14.................................... 55,845,680 1,445,773,919 1,755,905,404 1,175,209,711 805,889,082 992,507,673
15.................................... 59,834,657 1,473,790,825 1,789,932,188 1,215,099,482 833,905,988 1,026,534,457
16.................................... 63,823,634 1,501,807,731 1,823,958,972 1,254,989,254 861,922,894 1,060,561,242
17.................................... 67,812,611 1,529,824,637 1,857,985,756 1,294,879,025 889,939,801 1,094,588,026
18.................................... 71,801,589 1,557,841,544 1,892,012,541 1,334,768,797 917,956,707 1,128,614,810
19.................................... 75,790,566 1,585,858,450 1,926,039,325 1,374,658,568 945,973,613 1,162,641,594
20.................................... 79,779,543 1,613,875,356 1,960,066,109 1,414,548,340 973,990,519 1,196,668,378
--------------------------------------------------------------------------------------------------------------------------------------------------------
\1\ For Alternative 1, the proposed rule.
Exhibit 3 presents the resulting total 10-year fatality risk
reduction benefit across a range of risk reduction values from 0 to 20
percent. The exhibit also presents the undiscounted and discounted 10-
year total net benefits when fatality risk reduction is considered in
addition to the benefits of the rule included in the analysis presented
above (assuming a 1 percent risk reduction in the probability of
incidents involving oil spills). The benefits of occupational risk
reduction are usually measured using the value of a statistical life
(VSL). The BSEE used a VSL of $8.4 million to estimate the avoided
costs associated with a reduction in the fatality rate \17\ (see
initial RIA for details of VSL calculations).
---------------------------------------------------------------------------
\17\ Between 1964 and 2010, there were 27 blowouts with oil
spills greater than 10 barrels. Only two of these events resulted in
fatalities: the 1984 blowout and the 2010 Deepwater Horizon incident
that resulted in 4 and 11 fatalities, respectively. Based on the 47-
year period from 1964 to 2010, the average number of fatalities was
approximately 0.320 annually (15/46.945). Using a VSL of $8,423,301,
the average value of fatalities is $2,691,423 per year (0.320 x
$8,423,301). Therefore, each 1 percent reduction in the risk of a
fatality results in a risk reduction benefit of $26,914 (1 percent x
$2,691,423). Note that this calculation likely understates the
benefits associated with fatality risk reduction because blowouts
that did not result in an oil spill greater than 10 barrels were not
part of the database used for this analysis. Previous MMS studies
indicate a total of 126 blowouts during drilling operations on the
OCS between 1971 and 2006. These blowouts resulted in 26 fatalities,
63 injuries, damage to facilities and equipment, and the release of
hydrocarbons. Accounting for any additional fatalities would
increase the fatality risk reduction benefits.
Exhibit 3--Monetized Benefits From Averted Fatalities W/Net Benefits \1\
--------------------------------------------------------------------------------------------------------------------------------------------------------
Fatality risk Net benefits of Net benefits of proposed rule with fatality risk
reduction benefit proposed rule reduction (at a 1-percent risk reduction)
------------------- without fatality --------------------------------------------------------
risk reduction
Fatality risk reduction (%) (at a 1-percent
Undiscounted risk reduction) Undiscounted 3% Discounting 7% Discounting
-------------------
Undiscounted
--------------------------------------------------------------------------------------------------------------------------------------------------------
Total 10-year
--------------------------------------------------------------------------------------------------------------------------------------------------------
0........................................................ $0 $656,642,682 $656,642,682 $550,159,479 $441,669,301
1........................................................ 269,142 656,642,682 656,911,824 550,389,063 441,858,335
2........................................................ 538,285 656,642,682 657,180,967 550,618,647 442,047,369
3........................................................ 807,427 656,642,682 657,450,109 550,848,231 442,236,403
4........................................................ 1,076,569 656,642,682 657,719,251 551,077,814 442,425,438
5........................................................ 1,345,712 656,642,682 657,988,393 551,307,398 442,614,472
6........................................................ 1,614,854 656,642,682 658,257,536 551,536,982 442,803,506
7........................................................ 1,883,996 656,642,682 658,526,678 551,766,566 442,992,541
[[Page 21542]]
8........................................................ 2,153,139 656,642,682 658,795,820 551,996,150 443,181,575
9........................................................ 2,422,281 656,642,682 659,064,963 552,225,734 443,370,609
10....................................................... 2,691,423 656,642,682 659,334,105 552,455,318 443,559,644
11....................................................... 2,960,565 656,642,682 659,603,247 552,684,901 443,748,678
12....................................................... 3,229,708 656,642,682 659,872,390 552,914,485 443,937,712
13....................................................... 3,498,850 656,642,682 660,141,532 553,144,069 444,126,746
14....................................................... 3,767,992 656,642,682 660,410,674 553,373,653 444,315,781
15....................................................... 4,037,135 656,642,682 660,679,817 553,603,237 444,504,815
16....................................................... 4,306,277 656,642,682 660,948,959 553,832,821 444,693,849
17....................................................... 4,575,419 656,642,682 661,218,101 554,062,405 444,882,884
18....................................................... 4,844,562 656,642,682 661,487,244 554,291,988 445,071,918
19....................................................... 5,113,704 656,642,682 661,756,386 554,521,572 445,260,952
20....................................................... 5,382,846 656,642,682 662,025,528 554,751,156 445,449,986
--------------------------------------------------------------------------------------------------------------------------------------------------------
\1\ For Alternative 1, the proposed rule.
As an additional sensitivity analysis, we estimated the net
benefits of the proposed rule for different assumptions regarding the
value of lost hydrocarbons. In the analysis presented above, BSEE used
$100 per barrel for the value of lost hydrocarbons in the event of a
spill. To reflect the fluctuations in the price of a barrel of oil that
may occur during the 10-year analysis period, we also estimated the net
benefits of the proposed rule for two alternative price scenarios: $50/
barrel and $130/barrel. Exhibit 4 presents the results, which indicate
that the price of oil has a very limited impact on the net benefits of
the proposed rule.
EXHIBIT 4--Net Benefits Under Three Oil Price Scenarios
[At a 1-percent risk reduction from the proposed rule]
----------------------------------------------------------------------------------------------------------------
Year $50/barrel $100/barrel $130/barrel
----------------------------------------------------------------------------------------------------------------
(2012 dollars/year)
-----------------------------------------------------------
1. 2015............................................ ($10,928,596) ($10,873,805) ($10,840,931)
2. 2016............................................ 76,502,597 76,557,387 76,590,262
3. 2017............................................ 76,502,597 76,557,387 76,590,262
4. 2018............................................ 76,502,597 76,557,387 76,590,262
5. 2019............................................ 76,502,597 76,557,387 76,590,262
6. 2020............................................ 55,002,597 55,057,387 55,090,262
7. 2021............................................ 76,502,597 76,557,387 76,590,262
8. 2022............................................ 76,502,597 76,557,387 76,590,262
9. 2023............................................ 76,502,597 76,557,387 76,590,262
10. 2024............................................ 76,502,597 76,557,387 76,590,262
----------------------------------------------------------------------------------------------------------------
Undiscounted 10-year total.......................... 656,094,777 656,642,682 656,971,425
10-Year Total with 3% discounting................... 549,692,105 550,159,479 550,439,903
10-Year Total with 7% discounting................... 441,284,475 441,669,301 441,900,196
----------------------------------------------------------------------------------------------------------------
10-year Average..................................... 65,609,478 65,664,268 65,697,142
Annualized with 3% discounting...................... 64,440,684 64,495,474 64,528,349
Annualized with 7% discounting...................... 62,828,982 62,883,772 62,916,646
----------------------------------------------------------------------------------------------------------------
BSEE has concluded, after consideration of the impacts of the
proposed rule, that the societal benefits would justify the societal
costs.
E.O. 13563 reaffirms the principles of E.O. 12866 while calling for
improvements in the Nation's regulatory system to promote
predictability, to reduce uncertainty, and to use the best, most
innovative, and least burdensome tools for achieving regulatory ends.
The E.O. directs agencies to consider regulatory approaches that reduce
burdens and maintain flexibility and freedom of choice for the public
where these approaches are relevant, feasible, and consistent with
regulatory objectives. The E.O. 13563 emphasizes further that
regulations must be based on the best available science and that the
rulemaking process must allow for public participation and an open
exchange of ideas. The BSEE engineers and technical staff have and will
continue to work to ensure that this proposed rulemaking is based on
sound engineering principles and considers options identified through
research, coordination with standards-development organizations, and
[[Page 21543]]
interaction with the OCS industry. Thus, we have developed this rule in
a manner consistent with these requirements.
In addition, BSEE is considering whether to use probabilistic risk
assessment methodology--including event trees, statistical information
(e.g., failure rates of valves), probabilities, uncertainties, and
assumptions--that potentially could help inform BSEE's final decision
on the proposed regulation. Further details about a potential
probabilistic risk assessment approach are provided in the initial RIA.
The BSEE is interested in the public's views on the potential
advantages and disadvantages to development of a probabilistic risk
assessment model for this rulemaking. We specifically seek comments on
the following issues:
(a) What would be the potential advantages and disadvantages if
BSEE were to move to risk-informed decisions in this proposed rule
through the use of methods such as probabilistic risk assessments and
event trees?
(b) Given that there are a significant number of offshore drilling
operations with different types of rig construction and drilling plans,
if BSEE were to use event trees in risk reduction assessments, how much
detail would such event trees need so that they would be representative
of the affected operators and best inform stakeholders and decision
makers? Commenters should provide examples of benefits and costs of any
suggested level of detail and explain why that detail would be
appropriate.
(c) Describe any completed, ongoing or planned activities, not
associated with BSEE, that would provide information beneficial to the
potential development of a probabilistic risk assessment approach for
this rulemaking, including any analyses identifying areas of
significant risk or uncertainties. If you do so, provide timelines for
the activity, if not already completed; indicate whether the activity
will be peer-reviewed; and explain how it could be used in the
potential development of a probabilistic risk assessment approach.
(d) Describe any other planned or ongoing data collection efforts
that could provide relevant information useful in the potential
development of probabilistic risk assessment models for offshore oil
and gas activities. If there are no such efforts at this time, how
could such a data collection program be developed?
(e) What challenges and concerns would there be to industry
providing data to inform and help BSEE decide whether to engage in
probabilistic risk assessment modeling for this proposed rule? What are
ways that the challenges and concerns could be mitigated?
The BSEE is also requesting comments on other ways to improve this
economic analysis. The BSEE is specifically requesting comments on the
following issues:
(a) Which provisions of the proposed rule are most, or least,
likely to reduce the risk of a well control incident?
(b) For each proposed rule provision:
(1) For what kinds of well control incidents (e.g., hydrocarbon
leakage through annulus cement barrier, weather-related incident,
collision) would the provision reduce risk?
(2) By what mechanism would the provision reduce risk (e.g.,
reduction of the rate of failure of a particular technology)?
(c) What risk reduction level (or range of risk reduction levels)
would the individual provisions achieve?
Please provide supporting data and studies to support your
comments.
Regulatory Flexibility Act
The DOI certifies that this proposed rule is likely to have a
significant economic effect on a substantial number of small entities
as defined under the Regulatory Flexibility Act, 5 U.S.C. 601 et seq.
(RFA).
The RFA, at 5 U.S.C. 603, requires agencies to prepare a regulatory
flexibility analysis to determine whether a regulation would have a
significant economic impact on a substantial number of small entities.
Further, under the Small Business Regulatory Enforcement Fairness Act
of 1996, 5 U.S.C. 801 (SBREFA), an agency is required to produce
compliance guidance for small entities if the rule would have a
significant economic impact. For the reasons explained in this section,
BSEE believes that this proposed rule would likely have a significant
economic impact on a substantial number of small entities and,
therefore, a regulatory flexibility analysis is required by the RFA.
This Initial Regulatory Flexibility Analysis assesses the impact of
this proposed rule on small entities, as defined by the applicable
Small Business Administration (SBA) size standards.
1. Description of the Reasons That Action by the Agency Is Being
Considered
The BSEE identified a need to amend the existing well-control
regulations to improve the capability of the oil and gas industry to
ensure that oil and gas operations on the OCS are safe and protect the
environment. In particular, BSEE considers the proposed rule necessary
to reduce the likelihood of all oil and gas blowouts, which can lead to
the loss of life, serious injuries, and harm to the environment. As was
evidenced by the Deepwater Horizon incident (which began with a blowout
at the Macondo well) on April 20, 2010, blowouts can result in
catastrophic consequences. Government and industry conducted multiple
investigations to determine the cause of the Deepwater Horizon
incident; many of these investigations identified BOP performance as a
concern. The BSEE convened Federal decision-makers and stakeholders
from the OCS industry, academia, and other entities at a public forum
on offshore energy safety on May 22, 2012, to discuss ways to address
this concern. The investigations and the forum resulted in a set of
recommendations to improve well-control operations, including BOP
performance.
The BSEE determined that the well-control regulations needed to be
updated to incorporate some of these recommendations while others are
being studied for consideration in future rulemakings. The proposed
rule would create a new Subpart G in 30 CFR part 250 to consolidate the
requirements for drilling, completion, workover, and decommissioning
operations. Consolidating these requirements would improve the
efficiency and consistency of the regulations and would allow for
flexibility in future rulemakings. The proposed rule would also revise
existing provisions throughout Subparts A, B, D, E, F, P, and Q of part
250 to address concerns raised in the Deepwater Horizon investigations.
Finally, the proposed rule would incorporate API Standard 53 to ensure
better BOP performance and operability and more robust regulatory
oversight.
2. Description and Estimated Number of Small Entities Regulated
Small entities, as defined by the RFA, consist of small businesses,
small organizations, and small governmental jurisdictions. We have not
identified any small organizations or small government jurisdictions
that the rule will impact, so this analysis focuses on impacts to small
businesses (hereafter referred to as ``small entities''). A small
entity is one that is independently owned and operated and which is not
dominant in its field of operation.\18\ The definition of small
business varies from industry to industry in order to properly reflect
industry size differences.
---------------------------------------------------------------------------
\18\ See 5 U.S.C. 601.
---------------------------------------------------------------------------
[[Page 21544]]
The proposed rule would affect operators and holders of Federal oil
and gas leases, as well as right-of-way holders, in the OCS. This
includes about 130 businesses with active operations. Businesses that
operate under this rule fall under the SBA's North American Industry
Classification System (NAICS) codes 211111 (Crude Petroleum and Natural
Gas Extraction) and 213111 (Drilling Oil and Gas Wells). For these
NAICS classifications, a small business is defined as one with fewer
than 500 employees. Based on these criteria, approximately 90 (69
percent) of the businesses operating on the OCS are considered small
and the rest are considered large businesses. The BSEE considers that a
rule has an impact on a ``substantial number of small entities'' when
the total number of small entities impacted by the rule is equal to or
exceeds 10 percent of the relevant universe of small entities in a
given industry. Therefore, BSEE expects that the proposed rule would
affect a substantial number of small entities.
The BSEE is using the estimated 130 businesses based on activity at
the time this economic analysis was developed. The 130 businesses
represent the best assessment of the total businesses operating in this
arena at the time the economic analysis was developed. The BSEE
recognizes that this number is a dynamic number and can fluctuate;
however, BSEE determined that this number of businesses was appropriate
for this rulemaking. The BSEE is requesting comments on the use of the
active business numbers, and other ways to quantify the changing number
of businesses.
3. Description and Estimate of Compliance Requirements
The BSEE has estimated the incremental costs for small operators,
lease holders, and right-of-way holders in the offshore oil and natural
gas production industry. Costs already incurred as a result of current
industry practice in accordance with existing regulations, industry
permits, DWOPs, and API industry standards with which operators already
comply were not considered as costs of this rule because they are part
of the baseline.\19\ As described in section 5 below, BSEE considered
three alternatives. Alternative 2 results in a time-savings benefit to
industry but no additional costs to industry, and thus the costs
presented below are the same for Alternatives 1 and 2. We have
estimated the costs of the following provisions of the rule:
\19\ API standards are developed by industry members and
technical experts in open meetings based on a consensus process.
They contain the baseline requirements that the industry has deemed
necessary to operate in a safe and reliable manner and are often
incorporated into commercial contracts between contractors and
operators.
---------------------------------------------------------------------------
--Additional information in the description of well drilling design
criteria;
--Additional information in the drilling prognosis;
--Prohibition of a liner as conductor casing;
--Additional capping stack testing requirements;
--Additional information in the APM for installed packers;
--Additional information in the APM for pulled and reinstalled packers;
--Rig movement reporting;
--Fitness requirements for MODUs and lift boats;
--Foundation requirements for MODUs and lift boats;
--Monitoring of well operations with a subsea BOP;
--Additional documentation and verification requirements for BOP
systems and system components;
--Additional information in the APD, APM, or other submittal for BOP
systems and system components;
--Submission by the operator of a Mechanical Integrity Assessment
Report completed by a BSEE-approved verification organization;
--New surface BOP system requirements;
--New subsea BOP system requirements;
--New surface accumulator system requirements;
--Chart recorders;
--Notification and procedure requirements for testing of surface BOP
systems;
--Alternating BOP control station function testing;
--ROV intervention function testing;
--Autoshear, deadman, and EDS function testing on subsea BOPs;
--Approval for well-control equipment not covered in Subpart G;
--Breakdown and inspection of BOP system and components;
--Additional recordkeeping for real-time monitoring; and
--Industry familiarization with the new rule.
These requirements and their associated costs to the OCS industry
and government are presented in the sections below.\20\
---------------------------------------------------------------------------
\20\ Sums presented in the sections below may not equal the sums
of the costs identified in this section because of rounding.
---------------------------------------------------------------------------
(a) Additional information in the description of well drilling
design criteria.
Section 250.413(g) of the proposed rule would require information
on the ECD to be included in the description of the well drilling
design criteria. The ECD is an important parameter in avoiding
fracturing the formation or compromising the casing shoe integrity,
which could lead to erratic pressures and uncontrolled flows (e.g.,
formation kicks) emanating from a well reservoir during drilling. This
information is necessary to better review the well drilling design and
drilling program. The requirement to include information on the ECD in
the well drilling design criteria would result in an average annual
labor cost to industry of $218 per entity.\21\
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\21\ We assumed that industry staff (mid-level engineer) would
spend one hour per well to include the additional information in the
well drilling design criteria. Industry already complies with this
new requirement as part of its design practice for most wells
drilled. To be conservative, however, we assumed that this
requirement would result in a new cost for all wells drilled per
year (320). We multiplied the number of industry staff hours per
well by the average hourly compensation rate for a mid-level
industry engineer ($88.38) and by the average number of wells
drilled per year to obtain an average annual labor cost to industry
of $28,282 (1 x $88.38 x 320). We then divided the average annual
labor cost by the number of entities (130) to obtain an average
annual labor cost per entity of $218 ($28,282 / 130).
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(b) Additional information in the drilling prognosis.
Section 250.414 of the proposed rule would require the OCS industry
to provide additional information in the drilling prognosis. New
paragraph (j) would require the drilling prognosis to identify the type
of wellhead system to be installed with a descriptive schematic, which
should include pressure ratings, dimensions, valves, load shoulders,
and locking mechanism, if applicable. The requirement to include
additional information in the drilling prognosis (submitted as part of
the APD) would result in an average annual labor cost to industry of
$54 per entity.\22\
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\22\ We assumed that industry staff (a mid-level engineer) would
spend 0.25 hours to include the additional information in the
drilling prognosis for a well. We multiplied the number of industry
staff hours per well by the average hourly compensation rate for a
mid-level industry engineer ($88.38) and the average number of wells
drilled per year (320) to obtain the average annual labor cost to
industry of $7,070 (0.25 x $88.38 x 320). We then divided the
average annual labor cost by the number of entities (130) to obtain
an average annual labor cost per entity of $54 ($7,070 / 130).
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(c) Prohibition of a liner as conductor casing.
Section 250.421(f) would be revised to no longer allow a liner to
be installed as conductor casing. This would ensure that the drive pipe
would not be exposed to wellbore pressures during drilling in
subsequent hole sections.
[[Page 21545]]
This provision would result in an average annual equipment and labor
cost to industry of $6,115 per entity.\23\
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\23\ We estimated that approximately one percent of drilled
wells currently have a liner as conductor casing (approximately one
percent of 320 wells, or three wells), based on input provided in
submittals to BSEE. To calculate the average annual equipment cost,
we assumed that the average cost of the casing joints and wellhead
per well would be $65,000. We multiplied the equipment cost per well
by the number of affected wells to yield an average equipment cost
of $195,000 ($65,000 x 3). We assumed that industry staff (rig crew)
would spend one day to install the new equipment on a well. We then
multiplied the number of industry staff days per well by the average
labor cost for a rig crew per day ($200,000) and by the number of
affected wells to obtain an estimated average annual labor cost to
industry of $600,000 ($200,000 x 3) for this requirement. Summing
the equipment and labor costs yields a total average annual cost to
industry of $795,000 for this requirement. We divided the average
annual equipment and labor cost by the number of entities (130) to
obtain an average annual equipment and labor cost per entity of
$6,115 ($795,000 / 130).
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(d) Additional capping stack testing requirements.
Proposed Sec. 250.462 would address source control and containment
requirements. New paragraph (e)(1) would detail requirements for the
testing of capping stacks. New requirements include the function
testing of all critical components on a quarterly basis and the
pressure testing of pressure holding critical components on a bi-annual
basis. These new requirements would help ensure that operators are able
to contain a subsea blowout. These new testing requirements would
result in an average annual equipment and service cost to industry of
$615 per entity.\24\
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\24\ We assumed that the quarterly equipment and service costs
of testing for capping stacks would be $5,000 per test.
Additionally, we assumed that 4 capping stacks would be tested
quarterly (or a total of 16 annual tests performed). We multiplied
the costs per test by the number of annual tests in order to
determine a total annual equipment and service cost to industry of
$80,000 (16 x $5,000). We divided the annual equipment and service
cost to industry by the number of entities (130) to obtain an
average annual equipment and service cost per entity of $615
($80,000 / 130).
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(e) Additional information in the APM for installed packers.
Proposed paragraphs (e) and (f) in Sec. 250.518 would clarify
requirements for installed packers and bridge plugs and require
additional information in the APM, including descriptions and
calculations for determining production packer setting depth. These new
requirements would codify existing BSEE policy to ensure consistent
permitting. It is expected that operators already comply with the
design specifications included in this section because this is the only
established industry standard. Thus, the depth setting calculation is
the only requirement that would impose a new cost beyond the current
baseline. The required calculations would be submitted for every well
that is completed where tubing is installed. The requirement to include
additional information in the APM would result in an average annual
labor cost to industry of $44 per entity.\25\
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\25\ We assumed that industry staff (a mid-level engineer) would
spend 0.25 hours to include the additional information in the APM
for a well. We assumed that APMs would be submitted for an average
of 260 wells with installed packers per year. We multiplied the
number of industry staff hours per well by the average hourly
compensation rate for a mid-level industry engineer ($88.38) and by
the estimated number of wells with installed packers for which an
APM would be submitted per year to estimate an average annual labor
cost to industry of $5,745 (0.25 x $88.38 x 260). We divided the
average annual labor cost by the number of entities (130) to obtain
an average annual labor cost per entity of $44 ($5,745 / 130).
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(f) Additional information in the APM for pulled and reinstalled
packers.
In Sec. 250.619, new paragraphs (e) and (f) would clarify
requirements for pulled and reinstalled packers and bridge plugs and
would require additional descriptions and calculations in the APM
regarding production packer setting depth. These new requirements would
codify existing BSEE policy to ensure consistent permitting. It is
expected that operators already comply with the design specifications
included in this section because this is the only established industry
standard. The depth setting calculation is the only requirement that
would impose a new cost beyond the current baseline. The required
calculations would be submitted for every well that is worked over
where tubing is pulled and then reinstalled. The requirement to include
additional information in the APM would result in an average annual
labor cost increase to industry of $172 per entity.\26\
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\26\ We assumed that industry staff (a mid-level engineer) would
spend 0.25 hours to include the additional information in the APM
for a well. We also assumed that APMs would be submitted for an
average of 1,010 wells with pulled and reinstalled packers per year.
We multiplied the number of industry staff hours per well by the
average hourly compensation rate for a mid-level industry engineer
($88.38) and the estimated number of wells with pulled and
reinstalled packers for which an APM would be submitted per year to
obtain an average annual labor cost to industry of $22,316 (0.25 x
$88.38 x 1,010). We divided the average annual labor cost by the
number of entities (130) to obtain an average annual labor cost per
entity of $172 ($22,316 / 130).
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(g) Rig movement reporting.
Proposed Sec. 250.712 would list the requirements for reporting
movement of rig units to the BSEE District Manager. Paragraph (a) would
extend the rig movement reporting requirements to all rig units
conducting operations covered under this subpart, including MODUs,
platform rigs, snubbing units, wire-line units used for non-routine
operations, and coiled tubing units. Paragraphs (c) and (e) are new and
would require notification if a MODU or platform rig is to be warm or
cold stacked or if a drilling rig would enter or leave the OCS.
Paragraph (f) would be revised to clarify that, if the anticipated date
for initially moving on or off location were to change by more than 24
hours, an updated Rig Movement Notification Report would be required.
Currently, rig movement reports are only required for drilling
operations, but the proposed rule would require operators to submit rig
movement reports for other operations as well, including cases when
rigs are stacked or would enter or leave the OCS. These changes would
allow BSEE to better anticipate upcoming operations, locate MODUs and
platform rigs in case of emergency, and verify rig fitness. The
requirement to notify BSEE of rig unit movement would result in an
average annual labor cost to industry of $19 per entity.\27\
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\27\ We assumed that industry staff (administrative) would spend
five minutes (0.08 hours) to submit a movement report and that
industry would submit an average of 1,000 movement reports per year.
We multiplied the number of industry staff hours per report by the
average hourly compensation rate for an administrative staff
($29.82) and the average number of reports per year to obtain an
average annual labor cost to industry of $2,485 (0.0833 x $29.82 x
1,000). We divided the average annual labor cost by the number of
entities (130) to obtain an average annual labor cost per entity of
$19 ($2,485 / 130).
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(h) Fitness requirements for MODUs and lift boats.
Proposed Sec. 250.713(a) would add a requirement that operators
provide fitness information for a MODU or lift boat for workovers,
completions, and decommissioning. Operators must provide information
and data to demonstrate the drilling unit's capability to perform at
the proposed drilling location. This information must include the most
extreme environmental and operational conditions that the unit is
designed to withstand, including the minimum air gap necessary for both
hurricane and non-hurricane seasons. If sufficient environmental
information and data are not available at the time the APD is
submitted, the BSEE District Manager may approve the APD, but would
require operators to collect and report this information during
operations. Under this circumstance, the District Manager would have
the right to revoke the approval of the APD, if information collected
during operations shows that the drilling unit is not capable of
performing at the proposed location. This requirement would result
[[Page 21546]]
in an average annual labor cost to industry of $340 per entity.\28\
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\28\ We assumed that industry staff (a mid-level engineer) would
spend 0.5 hours per APM to provide the additional information and
that an average of 1,000 APMs would be affected per year. We
multiplied the number of industry staff hours per APM by the average
hourly compensation rate for a mid-level industry engineer ($88.38)
and by the estimated number of APMs affected per year to obtain an
average annual labor cost to industry of $44,190 (0.5 x $88.38 x
1,000). We divided the average annual labor cost by the number of
entities (130) to obtain an average annual labor cost per entity of
$340 ($44,190 / 130).
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(i) Foundation requirements for MODUs and lift boats.
Proposed Sec. 250.713(b) would introduce a requirement for
foundation requirements for workovers, completions, and
decommissioning. Operators must provide information to show that site-
specific soil and oceanographic conditions would be capable of
supporting the proposed rig unit. If operators provide sufficient site-
specific information in the Exploration Plan (EP), Development and
Production Plan (DPP), or Development Operations Coordination Document
(DOCD) submitted to BOEM, operators may reference that information. The
District Manager may require operators to conduct additional surveys
and soil borings before approving the APD, if additional information is
needed to make a determination that the conditions would be capable of
supporting the rig unit or equipment installed on a subsea wellhead.
For moored rigs, operators must submit a plan of the rigs anchor
pattern approved in the EP, DPP, or DOCD in the APD or APM. This
requirement would result in an average annual labor cost to industry of
$340 per entity.\29\
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\29\ We assumed that industry staff (a mid-level engineer) would
spend 0.5 hours per APM to provide the additional information and
that an average of 1,000 APMs would be affected per year. We
multiplied the number of industry staff hours per APM by the average
hourly compensation rate for a mid-level industry engineer ($88.38)
and by the estimated number of APMs affected per year to obtain an
average annual labor cost to industry of $44,190 (0.5 x $88.38 x
1,000). We divided the average annual labor cost by the number of
entities (130) to obtain an average annual labor cost per entity of
$340 ($44,190 / 130).
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(j) Real-time monitoring of well operations.
Proposed Sec. 250.724 is a new section that lists requirements
for:
--Monitoring well operations on rigs that have a subsea BOP, surface
BOP on a floating facility, and rigs operating in HPHT reservoirs; and
--Storing data at a designated onshore location, as listed in the APD
or APM.
In order to comply with this section, the OCS industry would incur
annual equipment and labor costs associated with gathering,
transmitting, and storing data. The costs associated with these new
data collection and storage requirements would include an average
annual equipment and labor cost of $311,538 per entity. The BSEE
requests feedback related to the costs of compliance with monitoring of
well operations with a subsea BOP.\30\
\30\ We assumed that the average costs per day and the average
operational days per year would be the same for rigs with subsea
BOPs and rigs operating in HPHT reservoirs. Additionally, we assumed
that a rig operates for 270 days per year (three operations per year
and three months per operation) and that the average cost per day to
perform continuous monitoring would be $5,000, including equipment
and labor. We estimated that half of the rigs with subsea BOPs
already conduct this monitoring. Thus, only half of rigs with subsea
BOPs (20 rigs) would incur a new cost to comply with these
requirements. Similarly, we assumed that 10 of the rigs operating in
HPHT reservoirs would incur a new cost to comply with these
requirements. We multiplied the time that the rig is operational per
year by the average cost per day to perform monitoring and by the
number of affected rigs to obtain an average annual equipment and
labor cost to industry of $40.5 million (270 x $5,000 x 30). We
divided the average annual equipment and labor cost by the number of
entities (130) to obtain average an average annual equipment and
labor cost per entity of $311,538 ($40,500,000 / 130).
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(k) Additional documentation and verification requirements for BOP
systems and system components.
Proposed Sec. 250.730 would list general requirements for BOP
systems and system components and additions to the section would
describe new documentation and verification requirements. Proposed
Sec. 250.731(c) would require verification by a BSEE-approved
verification organization of specified aspects of equipment design,
equipment tests, shear tests, and pressure integrity tests; and all
certification documentation must be made available to BSEE. Proposed
Sec. 250.732(c) would require a comprehensive review by a BSEE-
approved verification organization of BOP and related equipment being
proposed for use in HPHT service. Proposed Sec. 250.730(d) would
require that quality management systems for BOP stacks be certified by
an entity that meets the requirements of ISO 17011.
Additionally, operators may submit a request for approval of
equipment manufactured under quality assurance programs other than API
Spec. Q1. The BSEE may approve such a request, provided the operator
submits relevant information about the alternative program. Costs
associated with these new documentation and certification requirements
would include an average annual equipment and labor cost of $13,706 per
entity. The BSEE requests feedback related to the costs of compliance
with these documentation and certification requirements for BOP systems
and system components.\31\
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\31\ For proposed Sec. 250.731(c), we assumed that the one-time
equipment and service costs to industry would be $40,000. We
estimated that 320 wells would incur a new cost to comply with these
requirements. We multiplied the one-time cost of equipment and
service by the number of affected wells to obtain the total one-time
equipment and service cost to industry of $12,800,000 ($40,000 x
320), resulting in an average annual cost of $1,280,000 to industry.
For Sec. 250.732(c), we assumed that the annual costs would be
$50,000, including equipment and service. We estimated that 10 wells
would incur a new cost to comply with these requirements. We
multiplied the annual cost of equipment and service by the number of
affected wells to obtain an average annual equipment and service
cost to industry of $500,000 ($50,000 x 10). For Sec. 250.730(d),
we assumed that a mid-level industry engineer would spend 2 hours to
submit a request. We multiplied the compensation rate for a mid-
level industry engineer ($88.38) by the number of hours to complete
the submission and then multiplied this annual cost by the total
number of wells (10) to determine the annual cost to industry of
$1,768 (2 $88.38 x 10). The average annual cost to industry
associated with these requirements is $1,781,768 ($1,280,000 +
$500,000 + $1,768). We divided this average annual equipment and
labor cost by the number of entities (130) to obtain average an
average annual equipment and labor cost per entity of $13,706
($1,781,768 / 130).
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(l) Additional information in the APD, APM, or other submittals for
BOP systems and system components.
Proposed Sec. 250.731 would list the descriptions of BOP systems
and system components that must be included in the applicable APD, APM,
or other submittal for a well. Paragraph (a) would require the
submittal to include descriptions of the rated capacities for the
fluid-gas separator system, control fluid volumes, control system
pressure to achieve a seal of each ram BOP, number of accumulator
bottles and bottle banks, and control fluid volume calculations for the
accumulator system. Paragraph (b) would add schematic drawing
requirements, including labeling for the control system alarms and set
points, control stations, and riser cross section. New paragraph (e)
would require a listing of the functions with sequences and timing of
autoshear, deadman, and EDS for subsea BOPs. For subsea BOPs, surface
BOPs on a floating facility, and BOPs operating under HPHT conditions,
new paragraph (f) would require submission of a certification that a
Mechanical Integrity Assessment Report has been submitted within the
past 12 months. New paragraph (c) would include a change in required
certifications. The paragraph would require submission of
certifications from a BSEE approved verification organization (rather
than a ``qualified third-party'') that:
--Test data would demonstrate that the shear ram(s) would shear the
drill
[[Page 21547]]
pipe at the water depth (per proposed Sec. 250.732(b)),
--The BOP would be designed, tested, and maintained to perform at the
most extreme anticipated conditions; and
--The accumulator systems would have sufficient fluid to function the
BOP system without assistance from the charging system.
These proposed requirements would be necessary to enhance BSEE's
review of the BOP system and its emergency systems, which were the
topic of many of the recommendations of the Deepwater Horizon
investigation reports. These requirements would be necessary to help
BSEE verify that the accumulator system would have sufficient fluid to
function the BOP system without assistance from the charging system.
The proposed requirements to provide additional documentation about the
BOP system and system components in the APD, APM, or other submittal
would result in an average annual labor cost to industry of $218 per
entity.\32\ The BSEE was unable to locate any applicable data or
comparative cost estimates, and therefore was unable to determine a
definitive cost estimate for the annual costs to industry associated
with the change in the required independent third-party verifications
referenced in new paragraph (a). The BSEE requests feedback from the
public and industry on costs associated with the change in the
verification requirements.
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\32\ We assumed that industry staff (a mid-level engineer) would
spend one hour to include additional information in the APD, APM, or
other submittal for a well. We multiplied the number of industry
staff hours per well by the average hourly compensation rate for a
mid-level industry engineer ($88.38) and by the average number of
wells drilled per year (320) to obtain an average annual labor cost
to industry of $28,282 (1 x $88.38 x 320). We divided the average
annual labor cost by the number of entities (130) to obtain an
average annual labor cost per entity of $218 ($28,282 / 130).
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(m) Submission of a Mechanical Integrity Assessment Report by a
BSEE-approved verification organization.
Proposed Sec. 250.732(d) would include new requirements on the
submission of a Mechanical Integrity Assessment Report on the BOP stack
and systems. New paragraph (d) would outline the requirements for this
report, which must be completed by a BSEE-approved verification
organization and submitted by the operator for operations that would
require the use of a subsea BOP, a surface BOP on a floating facility,
or a BOP that is being used in HPHT operations. Proposed new Sec.
250.731(f) would require certification in the applicable permit stating
that this report has been submitted within the past 12 months. The
third-party reporting would enhance the BSEE review and permitting
process and would ensure that BSEE is aware of repairs or other changes
to the operating BOPs. These reporting requirements would result in new
costs to industry consisting of capital and labor costs for creating
reports and submitting them to BSEE. The analysis estimated an average
annual cost to industry of $37,032 per entity.\33\
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\33\ For capital costs, we assumed an annual cost of $15,000 for
each well which results in an annual capital cost of $4.8 million
($15,000 x 320). For labor costs, we assumed that industry staff (a
mid-level engineer) would spend a half hour to prepare a report for
each well. We multiplied the number of industry staff hours per well
by the average hourly compensation rate for a mid-level industry
engineer ($88.38) and by the average number of wells drilled per
year (320) to obtain an average annual labor cost to industry of
$14,141 (0.5 x $88.38 x 320). The average annual labor and capital
cost to industry. associated with these requirements is $4,814,141
($4,800,000 + $14,141). We divided the average annual labor and
capital cost to industry by the number of entities (130) to obtain
an average annual labor and capital cost per entity of $37,032
($4,814,141 / 130).
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(n) New surface BOP requirements.
Proposed Sec. 250.733 would include new requirements for surface
BOP stacks. New paragraph (e) would require that hydraulically operated
locks are installed with surface BOPs. The BSEE was unable to locate
any applicable data or comparative cost estimates and therefore was
unable to determine a definitive cost estimate for the labor and
equipment costs to industry associated with the installation of
hydraulically operated locks. The BSEE requests feedback related to the
costs of compliance with this new surface BOP stack requirement.
(o) New subsea BOP system requirements.
Proposed Sec. 250.734 would include new requirements for subsea
BOP systems, based on recommendations from the Deepwater Horizon
investigations. Paragraph (a) would require that BOPs be equipped with
two shear rams and would outline the requirements for the shear rams.
These additions would assist in emergency well-control planning. The
BSEE recognizes that the equipment and labor costs associated with
these new subsea BOP system requirements would be case-specific. For
example, the costs would depend on the age of the rig and BOP system,
the BOP system type, and the size of the rig, among other factors.
The costs associated with the shear ram requirements in paragraph
(a) would include an average one-time compliance cost to industry of
$384,615 per entity.\34\ The BSEE welcomes feedback related to the
costs of compliance with these new technology requirements.
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\34\ API Standard 53 includes the requirements under new
paragraph (a) for all rigs with the exception of moored rigs. We
estimated that 5 moored rigs would be affected and that the one-time
capital compliance cost associated with these shear ram requirements
would be $10,000,000 per rig. To calculate the total one-time
capital costs to industry, we multiplied the equipment cost per rig
by the number of affected rigs to yield a total cost to industry of
$50,000,000 ($10,000,000 x 5). We divided the average one-time
equipment and labor cost by the number of entities (130) to obtain
an average one-time cost per entity of $384,615 ($50,000,000 / 130).
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(p) New surface accumulator system requirements.
Proposed Sec. 250.735(a) would list new requirements for the
surface accumulator system of a BOP. The surface accumulator system
must operate all BOP functions against MASP with 200 psi above pre-
charge without use of the charging system. This revision would ensure
that the BOP system would be capable of operating all critical
functions. The requirement that the surface accumulator system would
operate all functions for all BOP systems would result in a one-time
equipment and labor cost to industry of $21,713 per entity.\35\
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\35\ We assumed that the average cost of the additional
equipment needed to meet the requirements would be $25,000 per rig.
It is unknown how many rigs already comply; thus, we made a
conservative assumption that all rigs would be affected (90 rigs).
We multiplied the equipment cost per rig by the number of affected
rigs to obtain an estimated one-time equipment cost of $2.25 million
($25,000 x 90). For the one-time labor cost to industry, it was
estimated that one to three days of industry time would be required
per rig to install the new equipment. To be conservative, we assumed
that industry staff (a mid-level engineer) would spend 72 hours to
install the new equipment on a rig. We multiplied the number of
industry staff hours per rig by the average hourly compensation rate
for a mid-level industry engineer ($88.38) and by the number of
affected rigs to obtain an estimated one-time labor cost to industry
of $572,702 (72 x $88.38 x 90). Summing the equipment and labor
costs resulted in a total one-time cost to industry of $2,822,708.
We divided the one-time equipment and labor cost by the number of
entities (130) to obtain a one-time equipment and labor cost per
entity of $21,713 ($2,822,708 / 130).
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(q) Chart recorders.
Proposed Sec. 250.737(c) would address BOP testing and introduce a
requirement that each test must hold the required pressure for five
minutes while using a four-hour chart. This would allow the chart to
detect a leak during the test. This testing requirement would result in
a one-time equipment and labor cost to industry of $1,388 per
entity.\36\
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\36\ We assumed that each rig would require a chart recorder for
an average cost of $2,000 per rig. We multiplied the average
equipment cost per rig by the total number of rigs (90) to obtain an
estimated one-time equipment cost to industry of $180,000 ($2,000 x
90). We assumed that industry staff (rig crew) would spend five
minutes (0.08 hours) per rig to install the equipment. We multiplied
the number of industry staff hours per rig by the average hourly
compensation rate for a rig crew staff ($56.80) and by the total
number of rigs to obtain an estimated one-time labor cost to
industry of $426 (0.0833 x $56.80 x 90). Summing the equipment and
labor costs resulted in a total one-time cost to industry of
$180,426. We divided the one-time equipment and labor cost by the
number of entities (130) to obtain a one-time equipment and labor
cost per entity of $1,388 ($180,426 / 130).
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[[Page 21548]]
(r) Notification and procedure requirements for testing of surface
BOP systems.
Proposed Sec. 250.737(d)(2) would expand notification and
procedure requirements regarding the use of water to test a surface BOP
system. This notification and procedure requirement would result in an
average annual labor cost to industry of $41 per entity.\37\
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\37\ We assumed that a mid-level industry engineer would spend 1
additional hour on a submittal as a result of these expanded
requirements. We multiplied the compensation rate for a mid-level
industry engineer ($88.38) by the number of hours to complete the
submission and then multiplied this annual cost by the total number
of submittals (60) to determine the annual cost to industry of
$5,303 (1 x $88.38 x 60). We divided the average annual labor cost
by the number of entities (130) to obtain an average annual labor
cost per entity of $41 ($5,303 / 130).
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(s) Alternating BOP control station function testing.
Proposed Sec. 250.737(d)(5) would expand the requirements for
function testing BOP control stations. It would require that the
operator designate the BOP control stations as primary and secondary
and alternate function testing of each station weekly. This testing
requirement would result in an average operations cost to industry of
$192,308 per entity.\38\ The BSEE requests feedback related to the
costs of compliance with alternating BOP control station function
testing.
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\38\ We assumed that testing would require 0.5 days per rig per
year (two hours every two weeks for three months). Because subsea
and surface BOPs rigs have different daily rig operating costs, we
performed separate calculations for the costs for subsea and surface
BOP rigs. For subsea BOP rigs, we multiplied the time required to
conduct the testing per rig by the average daily rig operating cost
for subsea BOP rigs ($1 million) and by the number of subsea BOP
rigs (40) for an average annual cost of $20 million for subsea BOP
rigs (0.5 x $1 million x 40). For surface BOP rigs, we multiplied
the time required to conduct the testing per rig by the average
daily rig operating cost for surface BOP rigs ($200,000) and by the
number of surface BOP rigs (50) for an average annual cost of $5
million for surface BOP rigs (0.5 x $200,000 x 50). Summing the
average annual costs for subsea BOP rigs and surface BOP rigs
resulted in an average annual operations cost to industry associated
with this provision of $25 million. We divided the average annual
operations cost to industry by the number of entities (130) to
obtain an average annual operations cost per entity of $192,308
($25,000,000 / 130).
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(t) ROV intervention function testing.
Proposed Sec. 250.737(d)(12) would include requirements for
testing ROV intervention functions to include testing and verifying the
closure of all ROV intervention functions on a subsea BOP. The operator
would have to test and verify closure of the selected ram. This testing
requirement would result in an average annual operations cost to
industry of $3,205 per entity.\39\
---------------------------------------------------------------------------
\39\ We assumed that it would take five minutes per well to
conduct the testing and that 120 wells would be affected (40 subsea
BOP rigs with three wells per rig). We multiplied the time diverted
for testing in a day 0.003472 (5 min / 60 min / 24 hours) by the
daily operating cost per rig ($1,000,000) and by the estimated
number of wells affected per year to obtain an average annual
operations cost to industry of $416,667 (0.03 x 120 x $1,000,000).
We divided the average annual operations cost by the number of
entities (130) to obtain an average annual operations cost per
entity of $3,205 ($416,667 / 130).
---------------------------------------------------------------------------
(u) Autoshear, deadman, and EDS system function testing on subsea
BOPs.
Proposed Sec. 250.737(d)(13) would expand the requirements for
function testing of autoshear, deadman, and EDSs on subsea BOPs. It
would require that the test procedures submitted for BSEE District
Manager approval include a schematic of the circuitry of the system,
the approved schematics of the BOP control system, and a description of
how the ROV would be used during the operation. It would also outline
the requirements for the deadman system test, including a requirement
that the testing must indicate the discharge pressure of the subsea
accumulator system throughout the test (per proposed Sec.
250.737(d)(13)). It would require that the blind-shear rams be tested
to verify closure. The operator must document the plan to verify
closure of the casing shear ram, if installed, as well as all test
results. These documentation and testing requirements would result in
an average one-time equipment cost to industry of $769 per entity and
an average annual operations cost of $38,462 per entity.\40\
---------------------------------------------------------------------------
\40\ We assumed that the average cost of the sensing device
would be $2,500 per rig. We multiplied the equipment cost by the
total number of subsea BOP rigs (40) to obtain the one-time
equipment cost to industry of $100,000 ($2,500 x 40). We divided the
equipment cost by the number of entities (130) to obtain a one-time
equipment cost per entity of $769 ($100,000 / 130). We assumed that
it would take one hour per well to perform the testing and
documentation tasks required by this provision, and that each subsea
BOP rig would be affected (40 subsea rigs). We multiplied the time
diverted for testing in a day 0.125 (1 hour / 24 hours) by the daily
operating cost per rig ($1,000,000) and by the estimated number of
rigs affected per year to obtain an average annual operations cost
to industry of $5 million (0.125 x 40 x $1,000,000). We divided the
average annual operations cost by the number of entities (130) to
obtain an average annual operations cost per entity of $38,462
($5,000,000 / 130).
---------------------------------------------------------------------------
(v) Approval for well-control equipment not covered in Subpart G.
Proposed Sec. 250.738 would describe the required actions for
specified situations involving BOP equipment or systems. Paragraphs
(b), (i), and (o) would include requirements for reports from
verification organizations. Reports previously required to be prepared
by a ``qualified third-party'' under these sections would be required
to be prepared by a ``BSEE-approved verification organization.''
Proposed Sec. 250.738(m) would include a similar change and introduce
a requirement that an operator request approval from the BSEE District
Manager to use well-control equipment not covered in Subpart G. The
operator must submit a report from a BSEE-approved verification
organization, as well as any other information required by the District
Manager. This approval request requirement would result in an average
annual labor cost to industry of approximately $1 per entity.\41\ The
BSEE was unable to locate any applicable data or comparative cost
estimates and therefore was unable to determine a definitive cost
estimate for the annual costs to industry associated with the third-
party verification. The BSEE welcomes feedback from the public or
industry on costs associated with the third-party verification
requirements.
---------------------------------------------------------------------------
\41\ We assumed that industry staff (a mid-level engineer) would
spend 0.5 hours to submit an equipment approval request and report.
We also assumed that industry would submit a request and report for
an average of two deepwater rigs per year. We multiplied the number
of industry staff hours per submission by the average hourly
compensation rate for a mid-level industry engineer ($88.38) and the
average number of submissions per year to obtain an average annual
labor cost to industry of $88 (0.5 x $88.38 x 2). We divided the
average annual labor cost by the number of entities (130) to obtain
an average annual labor cost per entity of $1 ($88 / 130).
---------------------------------------------------------------------------
(w) Breakdown and inspection of the BOP system and components.
Proposed Sec. 250.739(b) would introduce a requirement for a
complete breakdown and inspection of the BOP and every associated
component every 5 years. During this complete breakdown and inspection,
a BSEE-approved verification organization must document the inspection
and any problems encountered. This BSEE-approved verification
organization's report must be available to BSEE upon request. This
additional requirement would be necessary to ensure that the components
on the BOP stack are regularly inspected. In the past, BSEE has, in
some cases, seen components of BOP stacks go more than 10 years without
this type of inspection. This inspection and documentation requirement
would result in an average cost to industry to obtain third-party
reports of $165,385 per entity during the year of inspection, which
would occur
[[Page 21549]]
once every 5 years or twice during the 10-year analysis period.\42\ We
assumed that costs would be incurred in year 1 and year 6 of the 10-
year analysis period.
---------------------------------------------------------------------------
\42\ For subsea BOP rigs, we assumed that equipment and labor
cost would be $350,000 per rig. We multiplied the total number of
subsea BOP rigs (40) by the equipment and labor cost to obtain an
inspection-year cost of $14 million ($350,000 x 40), which occurs
every 5 years for subsea BOP rigs. For surface BOP rigs, we assumed
that equipment and labor cost would be $150,000 per rig. We
multiplied the total number of surface BOP rigs (50) by the
equipment and labor cost to obtain an inspection-year cost of $7.5
million ($150,000 x 50), which occurs every 5 years for surface BOP
rigs. The sum of subsea and surface BOP costs are $21.5 million
during the year of inspection. We divided this total cost by the
number of entities (130) to obtain an average cost of inspection per
entity of $165,385 ($21,500,000 / 130).
---------------------------------------------------------------------------
(x) Additional recordkeeping for real-time monitoring.
Proposed Sec. Sec. 250.740(a) and Sec. 250.741(b) would introduce
requirements for additional recordkeeping of real-time monitoring data
for well operations. These additional records would require an average
additional annual labor cost to industry of $14 per entity.\43\
---------------------------------------------------------------------------
\43\ We assumed that industry staff (administrative staff) would
spend 0.5 hours to submit a report. We multiplied the number of
industry staff hours per submission by the average hourly
compensation rate for administrative staff ($29.82) and then
multiplied this annual cost by the number of affected wells (120,
based on the assumption of three wells per subsea BOP rig) to obtain
an average annual labor cost to industry of $1,789 (0.5 x $29.82 x
120). We divided the average annual labor cost to industry by the
number of entities (130) to obtain an average annual labor cost per
entity of $14 ($1,789 / 130).
---------------------------------------------------------------------------
(y) Industry familiarization with new regulations.
When the new regulation takes effect, operators would need to read
and interpret the rule. Through this review, operators would
familiarize themselves with the structure of the new rule and identify
any new provisions relevant to their operations. Operators would
evaluate whether any new action must be taken to achieve compliance
with the rule. Reviewing the new regulations would require staff time,
representing an average one-time labor cost on industry of $216 per
entity.\44\
---------------------------------------------------------------------------
\44\ We assumed that industry staff (a professional engineer,
supervisory) would spend two hours to review the new regulation. The
average hourly wage rate for a professional engineer (supervisory)
is $76.00, based on BSEE's Supporting Statement A (BSEE Production
Safety Systems). We multiplied this wage rate by the private sector
loaded wage factor of 1.42 to account for employee benefits,
resulting in a loaded average hourly compensation rate of $107.92.
We assumed that an industry staff would review the new regulation at
each of the 130 field offices. We multiplied the number of hours per
review by the average hourly compensation rate and by the number of
field offices, resulting in an estimated one-time labor cost to
industry of $28,059 (2 x $107.92 x 130). We divided the one-time
labor cost by the number of entities (130) to obtain an average one-
time labor cost of $216 ($28,059 / 130).
---------------------------------------------------------------------------
(z) Total Cost Burden for Small Entities.
The BSEE's calculations indicate that the total cost burden of this
proposed rule would be $6,783,880 per affected small entity over 10
years, which yields an average annual cost of $678,388, as presented in
Exhibit 4. Four provisions comprise approximately 85 percent of the
cost to small entities:
--Monitoring of well operations with a subsea BOP;
--Alternating BOP control station function testing;
--Autoshear, deadman, and EDS system function testing on subsea BOPs;
and
--New subsea BOP system requirements.
Exhibit 5 displays estimates of costs to small entities as a
percentage of revenues.\45\ In 8 of the 10 years in the analysis
period, the proposed rule represents a cost of $595,628 per entity. In
the first year, costs would be higher at $1,268,175 per entity as a
result of the one-time equipment and inspection costs. In year 6, small
entities would incur the costs from BOP major inspections, which would
be performed every 5 years.
---------------------------------------------------------------------------
\45\ The source for the estimated small business revenue is the
RIA for the BSEE Final Rulemaking ``Increased Safety Measures for
Energy Development on the Outer Continental Shelf'' (77 FR 50856;
August 22, 2012). The data in the source document is from the Office
of Natural Resources Revenue. The RIA can be viewed here: https://www.regulations.gov/#!documentDetail;D=BSEE-2012-0002-0047. The data
source reports the total 2009 small company revenue to be
$4,113,000,000. We calculated the average revenue per small business
by dividing the total small business revenue by the number of small
businesses subject to the rule ($4,113,000,000/90 operators) to
obtain an average of $45,700,000 per operator.
---------------------------------------------------------------------------
The costs of the rule as a proportion of small entity revenue range
from 1.30 percent in most years to 2.78 percent in the first year. The
BSEE considers that a rule has a ``significant economic impact'' when
the total annual cost associated with the rule is equal to or exceeds 1
percent of annual revenue. Thus, the rule is expected to have a
significant economic impact on the average participating small
operators, lease holders, and pipeline right-of-way holders. Thus, BSEE
concluded that this proposed rule will have a significant economic
impact on a substantial number of small entities.
Exhibit 4--Per Entity Cost of the Proposed Rule by Provision \1\
----------------------------------------------------------------------------------------------------------------
Total 10 year Average annual
cost per entity cost per entity Percent of total
(undiscounted) (undiscounted) cost
----------------------------------------------------------------------------------------------------------------
(a) Additional information in the description of well $2,176 $218 0.03
drilling design criteria..............................
(b) Additional information in the drilling prognosis... 544 $54 0.01
(c) Prohibition of a liner as conductor casing......... 61,154 6,115 0.90
(d) Additional capping stack testing requirements...... 6,154 615 0.09
(e) Additional information in the APM for installed 442 44 0.01
packers...............................................
(f) Additional information in the APM for pulled and 1,717 172 0.03
reinstalled packers...................................
(g) Rig movement reporting............................. 191 19 0.00
(h) and (i) Information on MODUs, including lift boats. 6,799 680 0.10
(j) Real-time monitoring of well operations............ 3,115,385 311,538 45.92
(k) Additional documentation and certification 137,059 13,706 2.02
requirements for BOP systems and system components....
(l) Additional information in the APD, APM, or other 2,176 218 0.03
submittal for BOP systems and system components.......
(m) Submission of a Mechanical Integrity Assessment 370,319 37,032 5.46
Report by a BSEE-approved verification organization...
(n) New surface BOP requirements....................... Data not available; requesting comments
(o) New subsea BOP system requirements \2\............. 384,615 38,462 5.67
(p) New surface accumulator system requirements........ 21,713 2,171 0.32
(q) Chart recorders.................................... 1,388 139 0.02
(r) Use water to test surface BOP system............... 408 41 0.01
[[Page 21550]]
(s)Alternating BOP control station function testing.... 1,923,077 192,308 28.35
(t) ROV intervention function testing.................. 32,051 3,205 0.47
(u) Autoshear, deadman, and EDS system function testing 385,385 38,538 5.68
on subsea BOPs........................................
(v) Approval for well-control equipment not covered in 7 1 0.00
Subpart G.............................................
(w) Breakdown and inspection of BOP system and 330,769 33,077 4.88
components............................................
(x) Record-keeping for real-time monitoring............ 138 14 0.00
(y) Industry familiarization with the new rule......... 216 22 0.00
--------------------------------------------------------
Total.............................................. 6,783,880 678,388 100.00
----------------------------------------------------------------------------------------------------------------
\1\ Totals may not add because of rounding.
\2\ This is a lower-bound estimate of the costs of this provision; BSEE seeks comment on costs that we were
unable to estimate (see section 4 above for details).
Exhibit 5--Annual Cost and Revenue Per Entity
----------------------------------------------------------------------------------------------------------------
2016-2019 (each 2021-2024 (each
Year 2015 year the same) 2020 year the same)
----------------------------------------------------------------------------------------------------------------
Annual Industry Cost Stream for $164,728,509 $77,297,317 $98,797,317 $77,297,317
Proposed Rule a....................
Total Entities b.................... 130 130 130 130
Average Annual Cost per Entity c = a 1,268,175 595,628 761,012 595,628
/ b................................
Average Annual Revenue for Small 45,700,000 45,700,000 45,700,000 45,700,000
Entities \1\ d.....................
Cost from Proposed Rule as a 2.78% 1.30% 1.67% 1.30%
Percentage of Annual Revenue e = c /
d.................................
----------------------------------------------------------------------------------------------------------------
\1\ The source for this estimate is the RIA for the BSEE Final Rulemaking ``Increased Safety Measures for Energy
Development on the Outer Continental Shelf'' (77 CFR 50856; August 22, 2012). The data in the source document
is from the Office of Natural Resource Revenue. The RIA can be viewed here: https://www.regulations.gov/#!documentDetail;D=BSEE-2012-0002-0047. The data source reports the total 2009 small company revenue to be
$4,113,000,000. We calculated the average revenue per small business by dividing the total small business
revenue by the number of small businesses subject to the rule ($4,113,000,000/90) to obtain an average of
$45,700,000 per operator.
4. Identification of All Relevant Federal Rules That May Duplicate,
Overlap, or Conflict With the Proposed Rule
The proposed rule does not conflict with any relevant federal rules
or duplicate or overlap with any Federal rules in any way that would
unnecessarily add cumulative regulatory burdens on small entities
without any gain in regulatory benefits. However, BSEE requests
comments identifying any federal rules that may duplicate, overlap, or
conflict with the proposed rule.
5. Description of Significant Alternatives to the Proposed Rule
BSEE has considered three alternatives:
BSEE has considered three regulatory alternatives:
(1) Promulgate the requirements contained within the proposed rule,
including increasing the BOP testing frequency for workover and
decommissioning operations from current 7 day to proposed 14 day
testing frequency. The following chart identifies the BOP testing
changes related to Alternative 1:
BOP Pressure Testing
------------------------------------------------------------------------
Current testing Proposed testing
Operation frequency frequency
------------------------------------------------------------------------
Drilling/Completions.............. 14 days 14 days
Workover/Decommissioning.......... 7 days 14 days
------------------------------------------------------------------------
(2) Promulgate the requirements contained within the proposed rule
with a change to the required frequency of BOP pressure testing from
the existing regulatory requirements (e.g., 7 or 14 days depending upon
the type of operation) to 21 days for all operations. The following
chart identifies the BOP testing changes related to Alternative 2; or
BOP Pressure Testing
----------------------------------------------------------------------------------------------------------------
Proposed testing
Operation Current testing frequency Alternative 2
frequency (Alternative 1) testing frequency
----------------------------------------------------------------------------------------------------------------
Drilling/Completions................................... 14 days 14 days 21 days
Workover/Decommissioning............................... 7 days 14 days 21 days*
----------------------------------------------------------------------------------------------------------------
* includes change from current 7 days to proposed 14 days
[[Page 21551]]
(3) Take no regulatory action and continue to rely on existing BOP
regulations in combination with permit conditions, Deep Water
Operations Plans (DWOPs), operator prudence, and industry standards.
Alternative 2 results in a time-savings benefit to industry but no
additional costs to industry, and thus the costs are the same for
Alternatives 1 and 2. By taking no regulatory action in Alternative 3,
BSEE would leave unaddressed most of the concerns and recommendations
that were raised regarding the safety of offshore oil and gas
operations and the potential for another event with consequences
similar to those of the Deepwater Horizon incident.\46\
---------------------------------------------------------------------------
\46\ See sources listed in n. 6.
---------------------------------------------------------------------------
Alternative 2 was not selected because BSEE is lacking critical
data on testing frequency and equipment reliability. This issue may be
considered in the final rulemaking if BSEE receives sufficient data to
support Alternative 2.
The BSEE has elected to move forward with Alternative 1, the
proposed rule, which would address recommendations provided by
government, industry, academia, and other stakeholders as well as
incorporate API Standard 53. In addition to addressing concerns and
aligning with industry standards, BSEE is functioning in a prudent
capacity with this proposed rule by advancing several of the more
critical capabilities beyond current industry standards. The proposed
rule would also improve efficiency and consistency of the regulations
and allow for flexibility in future rulemakings.
The operating risk for small companies to incur safety or
environmental accidents is not necessarily lower than it is for larger
companies. Offshore operations are highly technical and can be
hazardous. Adverse consequences in the event of incidents are similar
regardless of the operator's size. The proposed rule would reduce risk
for entities of all sizes. Nonetheless, BSEE is requesting comment on
the time it would take to comply with the proposed rule and the costs
of these proposed policies on small entities, with the goal of ensuring
thorough consideration and discussion at the final rule stage. The BSEE
specifically requests comments on the burden estimates discussed above
as well as information on regulatory alternatives that would reduce the
burden on small entities (e.g., different compliance requirements for
small entities, alternative testing requirements and periods, and
exemption from regulatory requirements).
Small Business Regulatory Enforcement Fairness Act
The proposed rule is a major rule under the Small Business
Regulatory Enforcement Fairness Act, 5 U.S.C. 801 et seq. This proposed
rule:
(1) Would have an annual effect on the economy of $100 million or
more.
(2) Would cause a major increase in costs or prices for consumers,
individual industries, Federal, State, or local government agencies, or
geographic regions.
(3) Would not have significant adverse effects on competition,
employment, investment, productivity, innovation, or the ability of
U.S.-based enterprises to compete with foreign-based enterprises.
The requirements would apply to all entities operating on the OCS
regardless of company designation as a small business. For more
information on costs affecting small businesses, see the RFA
discussion.
Unfunded Mandates Reform Act of 1995
This proposed rule would not impose an unfunded mandate on State,
local, or tribal governments or the private sector of more than $100
million per year. The proposed rule would not have a significant or
unique effect on State, local, or tribal governments or the private
sector. A statement containing the information required by the Unfunded
Mandates Reform Act, 2 U.S.C. 1501 et seq., is not required.
Takings Implication Assessment (E.O. 12630)
Under the criteria in E.O. 12630, this proposed rule does not have
significant takings implications. The proposed rule is not a
governmental action capable of interference with constitutionally
protected property rights. A Takings Implication Assessment is not
required.
Federalism (E.O. 13132)
Under the criteria in E.O. 13132, this proposed rule does not have
federalism implications. This proposed rule would not substantially and
directly affect the relationship between the Federal and State
governments. To the extent that State and local governments have a role
in OCS activities, this proposed rule would not affect that role. A
federalism assessment is not required.
Civil Justice Reform (E.O. 12988)
This rule complies with the requirements of E.O. 12988.
Specifically, this rule:
(1) Meets the criteria of section 3(a) requiring that all
regulations be reviewed to eliminate errors and ambiguity and be
written to minimize litigation; and
(2) Meets the criteria of section 3(b)(2) requiring that all
regulations be written in clear language and contain clear legal
standards.
Consultation With Indian Tribes (E.O. 13175)
Under the criteria in E.O. 13175, we have evaluated this proposed
rule and determined that it has no substantial direct effects on
federally recognized Indian tribes. The BSEE is committed to regular
and meaningful consultation and collaboration with tribes on policy
decisions that have tribal implications. The BSEE will consult with any
tribe that requests consultation about this proposed rule.
Paperwork Reduction Act (PRA) of 1995
This proposed rule contains collections of information that will be
submitted to OMB for review and approval under the PRA, 44 U.S.C. 3501
et seq. As part of its continuing effort to reduce paperwork and
burdens on respondents, BSEE invites the public and other Federal
agencies to comment on any aspect of the reporting and recordkeeping
burden. If you wish to comment on the information collection (IC)
aspects of this proposed rule, you may send your comments directly to
OMB and send a copy of your comments to the Regulations and Standards
Branch (see the ADDRESSES section of this proposed rule). Please
reference 30 CFR part 250, subpart G, Blowout Preventer Systems and
Well Control, 1014-NEW, in your comments. To see a copy of the
information collection request submitted to OMB, go to https://www.reginfo.gov (select Information Collection Review, Currently Under
Review); or you may obtain a copy of the supporting statement for the
new collection of information by contacting the Bureau's Information
Collection Clearance Officer at (703) 787-1607.
The PRA provides that an agency may not conduct or sponsor, and a
person is not required to respond to, a collection of information
unless it displays a currently valid OMB control number. The OMB is
required to make a decision concerning the collection of information
contained in these proposed regulations 30-60 days after publication of
this document in the Federal Register. Therefore, a comment to OMB is
best assured of being fully considered if OMB receives it by May 18,
2015. This does not affect the deadline for the public to comment to
BSEE on the proposed regulations.
[[Page 21552]]
The title of the collection of information for this rule is 30 CFR
250, Subpart G, Blowout Preventer Systems and Well Control (Proposed
Rulemaking). The proposed regulations concern BOP system requirements,
maintaining well control among others, and the information is used in
BSEE's efforts to regulate oil and gas operations on the OCS to protect
life and the environment, conserve natural resources, and prevent
waste.
Potential respondents comprise Federal OCS oil, gas, and sulphur
operators and lessees. Responses to this collection of information are
mandatory, or are required to obtain or retain a benefit; they are also
submitted on occasion, daily and weekly (during drilling operations),
monthly, quarterly, biennially, and as a result of situations
encountered depending upon the requirement. The IC does not include
questions of a sensitive nature. The BSEE will protect proprietary
information according to the Freedom of Information Act (5 U.S.C. 552)
and DOI implementing regulations (43 CFR 2), 30 CFR part 252, OCS Oil
and Gas Information Program, and 30 CFR 250.197, Data and information
to be made available to the public or for limited inspection.
This proposed rule affects Subpart A (1014-0022, expiration 8/31/
2017); Subpart B (1014-0024, expiration 12/31/2015); Applications for
Permits to Drill (1014-0025, expiration 4/30/17); Applications for
Permits to Modify (1014-0026, expiration 5/31/17); Subpart D (1014-
0018, expiration 10/31/17); Subpart E, (1014-0004, expiration 12/31/
16); Subpart F, (1014-0001, expiration 12/31/16); Subpart P, (1014-
0006, expiration 12/31/16); and Subpart Q, (1014-0010, expiration 10/
31/16).
This rule would also codify NTL 2013-G01, Global Positioning
Systems (GPS) for Mobile Offshore Drilling Units (MODUs) (1014-0013,
expiration 1/31/2016).
This rule proposes to create new 30 CFR part 250, subpart G, Well
Operations and Equipment, which will combine common requirements from
the various other subparts mentioned, as well as add new requirements.
The following explanations apply to this section: in the burden table,
the OMB currently approved hour and/non-hour cost burdens for
requirements will be identified with an asterisk (*); italics show
revision(s) of existing requirements; and brackets indicate new
requirements.
A vast majority of this proposed rule contains IC burdens OMB has
already approved (174,686 burden hours* and $102,500 non-hour cost
burdens*). We are revising some existing requirements (+ 5,052 burden
hours); and adding [new] regulatory requirements (+ [11,701 burden
hours]) for a total of 191,439 burden hours.
The following is a brief explanation of how the proposed regulatory
changes affect the various subpart and form burdens:
Subpart A--transferred the currently approved burden hours
from Subpart D for BOPs pertaining to alternative procedures and
departures (12,300 hours*).
Subpart B--revised the requirement by adding information
to be submitted with DWOPs pertaining to free standing hybrid risers
(FSHR) (9,000 hours*; + 48 hours).
APD--added NEW burden hours pertaining to requirements
including, but not limited to, ECD information, current monitoring,
changes to casing, etc. (47,800 hours* + [1,122 hours]). Because the
responses remained unchanged, we did not list the non-hour costs
burdens associated with APDs since the dollar amount will not change.
APM--added NEW burden hours pertaining to requirements
including, but not limited to, descriptions/calculations of production
packer setting depth, annulus monitoring plan information, etc. (11,321
hours* + [1,929 hours]). Because the responses remained unchanged, we
did not list the non-hour costs burdens associated with APMs since the
dollar amount will not change.
Subpart D--
(1) relocated common well operation and equipment requirements
(10,811 hours*).
(2) revised requirements for additional information relating to
safe drilling margins, well head descriptions, casing or line
centralization during cementing, submitting any changes to approved
plans, permits, or submittal (+ 4,859 hours).
(3) added NEW burden hours pertaining to requirements relating to,
but not limited to, cementing, source control and containment
capabilities, etc., (+ [1,923 hours]).
Subpart G--
(1) relocated burden hours from OMB currently approved requirements
in D, E, F, P, and Q, that pertain to rig requirements, well
operations, BOP system requirements, etc., as well as the hour and non-
hour cost burden from GPS for MODUs (NTL 2013-G01) (83,454 hours* and
$102,500 non-hour cost burden*).
(2) revised requirements that were relocated from other subparts in
30 CFR 250 for additional information that may be needed for properly
functioning acoustic systems, EDS, rating pressure, etc., and
requirements needing approval by the District Manager (+ [145 hours]).
(3) added NEW requirements pertaining to, but not limited to, warm
or cold stacking for MODUs, dropped objects plan, real-time monitoring,
pressure tests, etc., (+ [6,727 hours]).
Subparts P and Q have only cross references to new Subpart
G or current Subpart D and have no new associated burdens.
Once this rule becomes effective, BSEE will use the approved OMB
control number for the Subpart G information collection. The affected
remaining subparts discussed in this rule will have their information
collection burdens adjusted accordingly through the renewal process.
Burden Table
[Current regulations are regular font with an asterisk (*); Italic font show revision(s) of existing
requirements; and bracketed text indicates new requirements]
----------------------------------------------------------------------------------------------------------------
Reporting and
recordkeeping
30 CFR 250 Current Revision NEW requirement+ (BSEE- Hour burden Average number of Annual burden
Approved Verification annual responses hours (rounded)
Organization = BAVO)
----------------------------------------------------------------------------------------------------------------
Subpart A
----------------------------------------------------------------------------------------------------------------
[107].......................... NEW: Produce and Burden covered under various 30 CFR 0
submit documents 250 regulations (depending on the
ordered by BSEE to operational requirement(s)).
ensure compliance
with this part.
----------------------------------------------------------------------------------------------------------------
[[Page 21553]]
141; 198; [701; 720(a)(2); Request approval to 20............... 496 requests..... 9,920 *
730(d)(1)]; 1612. use new or
alternative
procedures, along
with supporting
documentation if
applicable, including
BAST not specifically
covered elsewhere in
regulatory
requirements.
----------------------------------------------------------------------------------------------------------------
142; 198; 702.................. Request approval of 2.5.............. 952 requests..... 2,380 *
departure from
operating
requirements not
specifically covered
elsewhere in
regulatory
requirements, along
with supporting
documentation if
applicable.
----------------------------------------------------------------------------------------------------------------
Subtotal (A)............... ...................... ................. 1,448 responses.. 12,300 hours *
----------------------------------------------------------------------------------------------------------------
Subpart B
----------------------------------------------------------------------------------------------------------------
287; 291; 292(p)............... Submit DWOP and 750.............. 12 plans......... 9,000 *
accompanying/ 4................ 48
supporting
information. [Provide
detailed information/
descriptions
pertaining to
pipeline free
standing hybrid riser
(FSHR)]. Submit
documentation for
pipeline FSHR
certification and
have verified by CVA.
----------------------------------------------------------------------------------------------------------------
12 responses 9,000 hours *
48 hours
Subtotal (B)............... ...................... ................. ................. 9,048 hours
----------------------------------------------------------------------------------------------------------------
Applications for Permit to Drill (APD)
----------------------------------------------------------------------------------------------------------------
410-418; [420(a)(7)]; Apply for permit to 114.98........... 408 applications. 46,912 *
423(c)(1); [428(b), (k)]; plus drill APD (Form BSEE- 2.75............. ................. 1,122
various references in Subparts 0123) that includes
A, D, E, F, [G (701; 702; any/all supporting
713(a), (b), (e), (g); 720(b); documentation/
721(g)(4); 724(b); 731; evidence (including,
733(b);734(b), (c); 737(a)(3), but not limited to,
(b)(2), (b)(3), (d)(2), test results,
(d)(3), (d)(4), (d)(12), calculations,
(d)(13); 738(m), (n)]; H; and pressure integrity,
P. kill weight fluids,
verifications,
certifications,
procedures, criteria,
qualifications,
diverter
descriptions; [ECD
information]; rig
anchor pattern plats;
contingency plan
(move off info/
[current
monitoring]);
description of your
BOP and its
components and
schematic drawings;
[descriptive
schematic (pressure
ratings, dimensions,
valves, load
shoulders, height
above water line
etc.); location of
ruptured disks;
description of
mudline level to
displace cement; how
the operator will
visually monitor
returns; PE
certification showing
approval of changes
to casing setting
depths; description
of source control and
containment
capabilities; EDS;
annulus monitoring
plan information; any
additional
information required
by District Manager];
etc.) and requests
for various approvals
required in Subpart D
(including Sec. Sec.
250.418(g); 427,
428, 432, 460,
490(c)) and submitted
via the form; upon
request, make
available to BSEE.
----------------------------------------------------------------------------------------------------------------
[420(b)(4)]; 428; 465(a)(1); Obtain approval to 1.34............. 662 submittals... 888 *
[721(g)(4); 731; 733(f); revise your drilling
734(b), (c)]. plan [changes to the
casing], or change
major drilling
equipment by
submitting a revised
Form BSEE-0123,
Application for
Permit to Drill;
[include BAVO
certification; any
other information
required by the
District Manager (on
a case-by-case
basis)].
----------------------------------------------------------------------------------------------------------------
[[Page 21554]]
Subtotal (APD)............. ...................... ................. ................. 47,800 hours*
[1,122 hours]
1,070 responses 48,922 hours
----------------------------------------------------------------------------------------------------------------
Application for Permit to Modify (APM)
----------------------------------------------------------------------------------------------------------------
460; 465; plus various ref in Provide revised plans 3.377............ 2,893 9,770 *
A, D, E 518(f); F, 619(f); [G, and the additional [40 min]......... applications [1,929]
701; 702; 713(a), (b), (e), supporting
(g); 720(b); 721(g)(4); information required
724(b); 731; 733(b), (f), by the cited
734(b)(1); 737(d)(2), (d)(3), regulations [test
(d)(4), (d)(12), (d)(13); results;
738(m), (n)],; H; P; and Q calculations;
1704(g). verifications;
certifications,
procedures;
[descriptions/
calculations of
production packer
setting depth]; rig
anchor pattern plats;
contingency plan
(move off info/
[current
monitoring]);
description of your
BOP, its components
and schematic
drawings; [annulus
monitoring plan
information];
criteria;
qualifications; etc.]
when you submit an
Application for
Permit to Modify
(APM) (Form BSEE-
0124) to BSEE for
approval.
----------------------------------------------------------------------------------------------------------------
Subparts D, E, F, H, P, Q...... Submit Revised APM 1................ 1,551 1,551*
plans (BSEE-0124). applications.
(This burden
represents only the
filling out of the
form).
----------------------------------------------------------------------------------------------------------------
Subtotal (APM)............. ...................... ................. ................. 11,321 hours *
[1,929 hours]
4,444 responses 13,250 hours
----------------------------------------------------------------------------------------------------------------
Subpart D
----------------------------------------------------------------------------------------------------------------
420(b)(3); 465(a) (b)(3); plus Submit form BSEE-0125 2................ 239 submittals 478 *
various ref in A, D, E, F, [G, (End-of-Operations 1................ 239
721(g)(8); 744]; P; Q Report (EOR)) and all
(1704([h]));. additional supporting
information as
required by the cited
regulations; and any
additional
information required
by the District
Manager.
----------------------------------------------------------------------------------------------------------------
421(b)......................... Alaska only: Discuss 1................ 1 discussion..... 1 *
the cement fill level
with the District
Manager.
423(c)(2)...................... Document all your test 0.5.............. 300 results...... 150 *
results and make them
available to BSEE
upon request.
428(c)(3); [428(k); 743(a), In the GOM OCS Region, 1................ 4,160 submittals. 4,160*
(c); 746(e)]; plus various submit drilling
references in Subparts A, D, activity reports
[G]. weekly (District
Manager may require
more frequent
submittals on a case-
by-case basis) on
Forms BSEE-0133 (Well
Activity Report
(WAR)) and BSEE-0133S
(Bore Hole Data) with
supporting
documentation.
428(c)(3); [428(k); 743(b), In the Pacific and 1................ 14 wells x 365 1,022 *
(c)] plus various references Alaska Regions during days x 20% year
in Subparts A, D, [G]. drilling operations, = 1,022.
submit daily drilling
reports on Forms BSEE-
0133 (Well Activity
Report (WAR)) and
BSEE-0133S (Bore Hole
Data) with supporting
documentation.
428(d)......................... Submit all remedial 5................ 1,000 submittals. 5,000 *
actions for review
and approval by
District Manager
(before taking
action); and any
other requirements of
the District Manager.
428(d)......................... Submit descriptions of 5................ 564 submittals... 2,820
completed immediate
actions to District
Manager (if taken to
ensure safety of crew/
prevent well-control
event); and any other
requirements of the
District Manager.
428(d)......................... Submit PE 4................ 450 submittals... 1,800
certification of any
proposed changes to
your well program;
and any other
requirements of the
District Manager.
[428(k)]....................... NEW: Maintain daily [0.5]............ [75 reports]..... [38]
drilling report
(cementing
requirements).
[[Page 21555]]
[428(k)]....................... NEW: If cement returns [1].............. [10 requests].... [10]
are not observed,
contact the District
Manager to obtain
approval before
continuing with
operations.
[462(c)]....................... NEW: Submit a [8].............. [150 submittals]. [1,200]
description of source
control and
containment
capabilities to the
Regional Supervisor
for approval.
[462(d)]....................... NEW: Request re- [1].............. [600 requests]... [600]
evaluation of your
source containment
capabilities from the
District Manager and
Regional Supervisor..
[462(e)(1)].................... NEW: Notify BSEE at [0.5]............ [150 [75]
least 21 days prior notifications].
to pressure testing;
needs to be witnessed
by BSEE and a BAVO.
----------------------------------------------------------------------------------------------------------------
6,722 responses.. 10,811 hours*.
1,014 responses.. 4,859 hours
[985 responses].. [1,923 hours]
Subtotal (D)............... ...................... ................. 8,721 responses.. 17,593 hours
----------------------------------------------------------------------------------------------------------------
Subpart E
----------------------------------------------------------------------------------------------------------------
518(f)......................... Include in your APM Burden covered under 1014-0026 0
descriptions and
calculations of
production packer
setting depth(s).
----------------------------------------------------------------------------------------------------------------
Subpart F
----------------------------------------------------------------------------------------------------------------
619(f)......................... Include in your APM Burden covered under 1014-0026 0
descriptions and
calculations of
production packer
setting depth(s).
----------------------------------------------------------------------------------------------------------------
Subpart G
----------------------------------------------------------------------------------------------------------------
General Requirements
----------------------------------------------------------------------------------------------------------------
[701; 720(a); 730(d)(1)] Request alternative Burden cover under 1014-0022 0
[(250.141)]. procedures or
equipment from
District Manager;
along with any
supporting
documentation/
information required.
[702] [(250.142)].............. Request departures Burden cover under 1014-0022 0
from District
Manager; include
justification; and
submit supporting
documentation if
applicable.
----------------------------------------------------------------------------------------------------------------
Rig Requirements
----------------------------------------------------------------------------------------------------------------
[710(a)]....................... Instruct crew members 0.75............. 7,512 meetings... 5,634 *
in safety
requirements of
operations--record
dates and times of
meetings, include
potential hazards;
make available to
BSEE.
[710(b); 738(p)]............... Prepare a well-control 0.5.............. 308 plans........ 154 *
drill plan for each
well, including but
not limited to
procedures, [EDS],
crew assignments,
established times to
complete assignments,
etc. Keep/post a copy
of the plan on the
rig at all times;
post on rig floor/
bulletin board.
[711(b), (c)].................. Record in the daily 1................ 8,320 drills..... 8,320 *
report: time, date,
and type of drill
conducted; time to
close diverter or
BOP; total time for
entire drill. The
BSEE may require you
to conduct a well-
control drill during
an inspection.
[712(a), (b), (f)]............. Notify BSEE of all rig 0.1.............. 20 notices....... 2 *
movements on or off
locations.
Rig movements reported 0.2.............. 151 submittals... 30 *
on Rig Movement
Notification Report
(Form BSEE-0144).
Including MODUs,
platform rigs;
snubbing units, lift
boats, wire-line
units, and coiled
tubing units 72 hours
prior to movement; if
the initial date
changes by more than
24 hours, submit
updated BSEE-0144.
[[Page 21556]]
[712(c), (e)].................. NEW: Notify District [0.5]............ [25 [13]
Manager if MODU or notifications].
platform rig is to be
warm or cold stacked
on Form BSEE-0144;
notify District
Manager where the rig
is coming from when
entering OCS waters.
[712(d)]....................... NEW: Prior to resuming [2].............. [10 responses]... [20]
operations, report to
District Manager any
construction repairs
or modifications that
were made to the MODU
or rig.
--------------------------------------
[713].......................... Submit MODU or lift Burden covered under 1014-0025 for 0
boat information if APD; and 1014-0026 for APM
being used for well
operations with your
APD/APM.
--------------------------------------
[713(a), (b)].................. Collect and report 5................ 30 reports....... 150 *
additional
information on a case-
by-case basis if
sufficient
information is not
available.
--------------------------------------
[713(b)]....................... Reference to Burden covered under 1010-0151 0
Exploration Plan,
Development and
Production Plan, and
Development
Operations
Coordination Document
(30 CFR 550, Subpart
B).
[713(c)(1)].................... Submit 3rd party Burden covered under 1014-0011 0
review of drilling
unit according to 30
CFR 250, Subpart I.
--------------------------------------
[713(c)(2); (417(c)(2))]....... Have a Contingency Burden covered under 1014-0025 0
Plan that addresses
design and operating
limitations of MODU
or lift boat.
--------------------------------------
[713(d) (417(d))].............. Submit current Burden covered under 1014-0025 0
certificate of
inspection/compliance
from USCG and
classification;
submit documentation
of operational
limitations by a
classification societ.
----------------------------------------------------------------------------------------------------------------
[714].......................... NEW: Develop and [40]............. [40 plans]....... [1,600]
implement dropped
objects plan with
supporting
documentation/
information; any
additional
information required
by the District
Manager; make
available to BSEE
upon request.
----------------------------------------------------------------------------------------------------------------
[715] NTL...................... GPS for MODUs......... 0.25............. 1 rig............
--------------------------------------------------------------------------------
1--Notify BSEE with ................. 1 notification 1 *
tracking/locator data
access and supporting
information; notify
BSEE Hurricane
Response Team as soon
as operator is aware
a rig has moved off
location.
--------------------------------------------------------------------------------
2-Install and protect 20 devices per year for replacement and/or new x
tracking/locator $325.00 = $6,500 *
devices--(these are
replacement GPS
devices or new rigs).
--------------------------------------------------------------------------------
3--Pay monthly 40 rigs x $50/month = ($600/year per 1 rig) = $24,000 *
tracking fee for GPS
devices already
placed on MODUs/rig..
--------------------------------------------------------------------------------
4--Rent GPS devices 40 rigs @$1,800 per year = $72,000 *
and pay monthly
tracking fee per rig.
----------------------------------------------------------------------------------------------------------------
16,313 responses. 14,141 hours *
[105 responses].. [1,783 hours]
16,418 responses. 15,924 hours
-------------------------------------
Subtotal (G--Rig Req.)..... ...................... ................. $102,500 Non-hour cost burdens *
----------------------------------------------------------------------------------------------------------------
[[Page 21557]]
Well Operations
----------------------------------------------------------------------------------------------------------------
[720(a)]....................... NEW: Notify and obtain [5].............. [150 [750]
approval from the notifications].
District Manager when
interrupting
operations before
getting off the well.
--------------------------------------
[720(a)(2)].................... Request approval to Burden covered under 1014-0022 0
use alternate
procedures/barriers.
--------------------------------------
[720(b)]....................... Submit with your APD Burden covered under 1014-0025 for 0
or APM reasons for APD; and 1014-0026 for APM
displacing kill-
weight fluid with
detailed step-by-step
written procedures
how to displace the
fluids, shear pipe
procedures, etc.
--------------------------------------
[721(d), (f), (g)]............. Submit to the District 0.5.............. 88 requests...... 44 *
Manager for approval
plans to re-cement,
repair, or run
additional casing/
liner for proper
seal, along with PE
certification of
proposed plans. The
District Manager may
require you to
perform additional
pressure tests.
----------------------------------------------------------------------------------------------
[721(g)(4)].................... Submit test procedures Burden covered under 1014-0025 for 0
and criteria for a APD; and 1014-0026 for APM.
successful test with
APD/APM; if changes
made to procedures,
submit changes with
revised APD or APM.
----------------------------------------------------------------------------------------------
[721(g)(5)].................... Document all your test 0.75............. 1,340 results.... 1,005 *
results and make them
available to BSEE
upon request.
[721(g)(6)].................... Contact the 1................ 14 notifications. 14 *
appropriate BSEE
District Manager
immediately if you
have any indication
of a failed negative
pressure test; submit
a description of the
corrective action
taken; and receive
approval from the
appropriate BSEE
District Manager for
the retest.
--------------------------------------
[721(g)(8); 744(a)]............ Submit Form BSEE-0125, Burden covered under 1014-0018 0
EOR.
--------------------------------------
[722].......................... Caliper, pressure 3................ 247 reports...... 741 *
test, or evaluate
casing; submit
evaluation results
report including
calculations; obtain
approval before
repairing or
installing additional
casing [(including PE
Certification.)]; or
resuming operations
(every 30 days during
prolonged drilling).
[722(b)(3)].................... [ Perform a pressure [1].............. [300 results].... [300]
test after repairs
made/casing installed
and report results.
[723(d)]....................... Request exceptions 1.5.............. 845 requests..... 1,268 *
prior to moving
rig(s) or related
equipment.
[724].......................... NEW: Immediately [12]............. [50 submittals].. [600]
transmit real-time
monitoring data
onshore during
operations or in HPHT
reservoirs; store and
monitor by qualified
personnel.
--------------------------------------
[724(b)]....................... NEW: List designated Burden covered under 1014-0025 for 0
location where real- APD; and 1014-0026 for APM
time data will be
stored and monitored
in your APD or APM;
make location and
data accessible to
BSEE upon request.
----------------------------------------------------------------------------------------------------------------
2,534 responses.. 3,072 hours *
[500 responses].. [1,650 hours]
Subtotal (G--Well Op.)..... 3,034 responses.. 4,722 hours
----------------------------------------------------------------------------------------------------------------
[[Page 21558]]
BOP System Requirements
----------------------------------------------------------------------------------------------------------------
[730; 731; 732]................ Submit BOP Burden covered under 1014-0025 for 0
descriptions with APD; and 1014-0026 for APM
your applicable APD
or APM; third-party
verification and
supporting
information/
documentation.
--------------------------------------
[730(a)(4)].................... NEW: Maintain current [24]............. [10 requests].... [240]
set of approved
schematic drawings on
the rig and an
onshore location;
obtain District
Manager approval to
resume operations if
any modifications or
changes are made.
[730(c)(1)].................... NEW: Provide written [2].............. [30 reports]..... [60]
report to
manufacturer within
30 days of
identifying equipment
failure.
[730(c)(2)].................... NEW: Initiate [5].............. [30 reports]..... [150]
investigation and
analysis within 60
days to determine
cause of equipment
failure; provide the
manufacturer a copy
of analysis report.
[730(c)(3)].................... NEW: Report the design [5].............. [2 reports]...... [10]
change/modified
procedures in writing
to BSEE, OORP; within
30 days of
manufacturer's
notification.
[730(d)(2)].................... NEW: Request for [5].............. [1 response]..... [5]
alternate to API
Spec. Q1 to BSEE,
OORP.
--------------------------------------
[731].......................... Resubmit BOP system Burden covered under 1014-0025 for 0
component APD; and 1014-0026 for APM.
documentation in your
APD or APM when
information changes
or moved off location
from well.
--------------------------------------
[732(a)]....................... NEW: Submit all [5].............. [5 submittals]... [25]
relevant information
to nominate a
verification
organization for BSEE
approval.
[732(b)]....................... NEW: Submit BAVO [10]............. [150 [1,500]
verification and all Verifications].
supporting
documentation related
to this section (such
as, but not limited
to sharing testing,
pressure integrity
testing,
calculations, etc.).
[732(c)]....................... NEW: Submit [10]............. [10 wells]....... [100]
verifications showing
the BAVO conducted a
comprehensive review
of the BOP and
related equipment for
HPHT wells as listed
in this section;
submit verifications
to the District
Manager and Regional
Supervisor before
beginning operations
in an HPHT
environment.
[732(d), (e)].................. NEW: Submit Mechanical [10]............. [90 reports]..... [900]
Integrity Assessment
Report (completed by
a BAVO) to BSEE,
OORP; report must
include all
requirements listed
in this section; make
all documentation
available to BSEE
upon request.
--------------------------------------
[733(b)(2)].................... NEW: Describe in your Burden covered under 1014-0025 for 0
APD or APM your APD; and 1014-0026 for APM
annulus monitoring
plan.
----------------------------------------------------------------------------------------------------------------
[734(a)(7)].................... Demonstrate that any 5................ 1 validation..... 5 *
acoustic control 1................ 10 submittals.... 10
system will function
properly in proposed
environment and
conditions; submit
any additional
information requested.
----------------------------------------------------------------------------------------------------------------
[734(a)(9); 738(n)]............ Label all functions on 1.5.............. 33 panels........ 50 *
all panels.
--------------------------------------
[734(a)(10)]................... Develop written Burden covered under 1014-0018 0
procedures for
operating the BOP
stack and LMRP and
minimum knowledge
requirements for
personnel authorized
to operate and
maintain BOP
components.
--------------------------------------
[[Page 21559]]
[734(b), (c)].................. Submit a revised APD/ Burden covered under 1014-0025 for 0
APM with BAVO APD; and 1014-0026 for APM
[documenting repairs;
before drilling out
surface casing];
perform a new BOP
test upon relatch,
etc.; receive
approval from the
District Manager.
--------------------------------------
[737(a)(3), (a)(4); (b)(2), In your APD: submit Burden covered under 1014-0025 0
(b)(3); (d)(2)-(4), (d)(12), stump, initial, or
(d)(13)]. pressure tests; and
subsea BOP procedures
and supporting
relevant data/
information; indicate
which casing string
and liner met the
criteria of this
section; quick
disconnect procedures
with your deadman
test procedures, etc.
Obtain District
Manager approval of
appropriate test
pressures; may
require more frequent
testing on your BOP;
or if you test
annular BOP less than
70 percent.
----------------------------------------------------------------------------------------------
[737(c); 746(a), (b), (c), (d)] Record the time, date, 7.75............. 4,457 results.... 34,542 *
and results of all
pressure tests,
actuations, and
inspections of the
BOP system, system
components, and
marine riser in the
daily report; onsite
representative
certify and sign/date
reports, etc.;
document sequential
order of BOP, closing
times, auxiliary
testing, pressure,
and duration of each
test.
----------------------------------------------------------------------------------------------------------------
[737(d)(2), (d)(3), (d)(4) Notify District 0.25............. 186 notifications 47 *
(d)(12);]. Manager at least 72 5.5.............. 1,239 results.... 6,815 *
hours prior to
pressure stump/
initial tests on
seafloor; if BSEE rep
unable to witness
test, provide results
to BSEE within 72
hours after
completion; document
all ROV intervention
function test
results; make
available to BSEE
upon request.
----------------------------------------------------------------------------------------------------------------
[737(d)(13)]................... Document all 0.5.............. 2,520 submittals. 1,260 *
autoshear, EDS, and 1................ 120 responses.... 120
deadman on your
subsea BOP systems
function test
results; make
available to BSEE
upon request.
----------------------------------------------------------------------------------------------------------------
[737(e)]....................... Provide 72 hour 0.25............. 136 notices...... 34 *
advance notice of
location of shearing
ram tests or
inspections; allow
BSEE access to
witness testing,
inspections, and
information
verification.
[738; 746(e)].................. NEW/Revised: Requires [0.5]............ [25 requests].... [13]
District Manager
Approval:
(a), (d); 746(e) [1].............. [25 requests].... [25]
Report problems,
issues, leaks;.
(b) Put well in a safe [1].............. [25 requests].... [25]
condition;.
(b) Prior to resuming 0.25............. 200 requests..... 50 *
operations for new/
repaired/reconfigured
BOP.
(g) Your well control 1................ 15 requests...... 15
places demands above
its rating pressure;
(j) Two barriers in [1].............. [1 request]...... [1]
place prior to BOP
removal.
[738(b), (i)].................. NEW: Submit a report/ [0.5]............ [50 submittals].. [25]
verification from
BAVO that BOP is fit
for service if have
to repair, replace,
or reconfigure a BOP.
[738(f)]....................... NEW: Notify the [0.5]............ [15 submittals].. [8]
District Manager of
BOP configuration
changes.
[738(g)]....................... NEW: Demonstrate your [1].............. [15 submittals].. [15]
well-control
procedures will not
place demands above
its rated working
pressure.
[738(k)]....................... NEW: Contact District [1].............. [2 requests]..... [2]
Manager for approval
prior to latching up
the BOP stack or re-
establishing power.
--------------------------------------
[[Page 21560]]
[738(m)]....................... NEW: Request approval Burden covered under 1014-0025 for 0
in your APD or APM to APD; and 1014-0026 for APM
utilize any other
well-control
equipment.
--------------------------------------
[738(m)]....................... NEW: Request approval [2].............. [10 requests].... [20]
from District Manager
to utilize any other
well-control
equipment; include
report from BAVO on
the equipment design
and suitability; any
other documentation/
information required
by District Manager.
--------------------------------------
[738(n)]....................... NEW: Include in your Burden covered under 1014-0025 for 0
APD or APM which pipe/ APD; and 1014-0026 for APM
variable bore rams
meet the criteria.
--------------------------------------
[738(o)]....................... NEW: Submit report to [1].............. [15 submittals].. [15]
the District Manager
prepared by BAVO
describing failure of
redundant control and
confirming no impact
to the BOP that makes
it unfit for well
control purposes;
receive approval to
continue operations;
submit any additional
information requested
by the District
Manager.
[739].......................... Document BOP 9.75............. 350 records...... 3,413 *
maintenance and
inspection procedures
used; record results
of BOP inspections
and maintenance
actions; maintain BOP
records for 2 years
or longer if directed
on the rig; maintain
design, maintenance,
inspection, and
repair records for
the life of the
equipment; make
available to BSEE
upon request.
[739(b)]....................... NEW: Assemble a [5].............. [21 reports]..... [105]
detailed report
compiled by a BAVO
documenting the once
every 5-year
inspection, including
any problems and
corrections; make
available to BSEE
upon request.
----------------------------------------------------------------------------------------------------------------
9,122 responses.. 46,216 hours *
145 responses.... 145 hours
[532 responses].. [3,244 hours]
Subtotal (G--BOP SR)....... ...................... ................. 9,799 responses.. 49,605 hours
----------------------------------------------------------------------------------------------------------------
Records and Reporting Requirement
----------------------------------------------------------------------------------------------------------------
[740; 711(b); 738(c); 745; 746] Maintain a daily 25 min........... 312 reports...... 130 *
report and accurate [1].............. [25 responses]... [25]
records for each well
onsite during
operation [such items
in the daily report
include, but are not
limited to, [date,
time, type of drill],
test results,
actuations,
inspection of the BOP
system, system
component, signoff
approvals, etc.]; and
any information
required by the
District Manager.
----------------------------------------------------------------------------------------------------------------
[740; 741]..................... Retain drilling 2.15............. 3,460 records.... 7,439 *
records for 90 days [1].............. [25 responses]... [25]
after drilling is
complete; retain
casing/liner
pressure, diverter,
BOP tests [and real-
time data monitoring]
for 2 years; retain
well completion/well
workover until well
is permanently
plugged/abandoned or
lease is assigned;
the records must
contain appropriate
information and any
other information
required by the
District Manager.
----------------------------------------------------------------------------------------------------------------
[742] NTL...................... Record and submit well 3................ 281 logs/surveys. 843 *
logs and surveys run
in the wellbore and/
or charts of well
logging operations.
--------------------------------------
[[Page 21561]]
Record and submit 1................ 281 reports...... 281 *
directional and
vertical-well
surveys..
Record and submit 1................ 55 reports....... 55 *
velocity profiles and
surveys..
Record and submit core 1................ 150 analyses..... 150 *
analyses..
--------------------------------------
[743(a), (c)].................. In the GOM OCS Region, Burden covered under 1014-0018 0
submit Well Activity
Reports (WARs) weekly
(District Manager may
require more frequent
submittals on case-by-
case basis) on BSEE-
0133 and BSEE-0133S
(Open Hole Data
Report) with
supporting
information described
in this section; any
additional
information required
by the District
Manager.
--------------------------------------
[743(b), (c)].................. In the Pacific and Burden covered under 1014-0018 0
Alaska OCS Regions
during operations,
submit WARs daily
(BSEE-0133 and BSEE-
0133S); with
supporting
information described
in this section; any
additional
information required
by the District
Manager.
--------------------------------------
[744].......................... Submit form BSEE-0125, Burden covered under 1014-0018 0
EOR.
--------------------------------------
[745]; NTL..................... Submit copies of well 1.5.............. 308 submissions.. 462 *
records;
paleontological
interpretations;
service company
reports; and other
reports or records of
operations to BSEE as
requested.
[746].......................... Record the time, date, 2................ 4,160 results.... 8,320 *
and results of all
casing and liner
presser tests.
[746(f)]....................... Retain all records 1.5.............. 1,563 records.... 2,345 *
pertaining to tests,
actuations, and
inspections at the
facility; retain all
the records listed in
this section for a
period of 2 years at
the facility, at the
lessee's field office
nearest the OCS
facility, or at
another location
conveniently
available to BSEE;
make all the records
available to BSEE
upon request.
----------------------------------------------------------------------------------------------------------------
10,570 responses. 20,025 hours *
[50 responses]... [50 hours]
Subtotal (G--Rec. & Rpt. ...................... ................. 10,620 responses. 20,075 hours.
Req.).
----------------------------------------------------------------------------------------------------------------
Subpart P
----------------------------------------------------------------------------------------------------------------
1612........................... Request exception from Burden covered under 1014-0006 0
30 CFR 250.711
requirements.
----------------------------------------------------------------------------------------------------------------
Subpart Q
----------------------------------------------------------------------------------------------------------------
1704(g), [(h)]................. Submit Forms BSEE-0124 Burden covered under 1014-0018 for 0
and BSEE-0125; BSEE-0125; and 1014-0026 for BSEE-
include all 0124
supporting
documentation/
information.
----------------------------------------------------------------------------------------------------------------
Current burden............. ...................... ................. 52,235 responses. 174,686 hours *
Revised burden............. ...................... ................. 1,159 responses.. 5,052 hours
[NEW burden]............... ...................... ................. [2,172 responses] [11,701 hours]
--------------------------------------------------------------------------------
Grand Total............ ...................... ................. 55,566 Responses. 191,439 Hours
[[Page 21562]]
$102,500 Non-Hour Cost Burden
----------------------------------------------------------------------------------------------------------------
* Indicates burdens are covered under one of the following OMB approved control numbers: 1014-0022, Subpart A;
1014-0024, Subpart B; 1014-0018, Subpart D; 1014-0004, Subpart E; 1014-0001, Subpart F; 1014-0006, Subpart P;
1014-0010, Subpart Q; 1014-0013, GPS for MODUs; 1014-0025, APDs; or 1014-0026, APMs.
+ In the future BSEE will be allowing the option of electronic reporting for certain requirements.
The BSEE specifically solicits comments on the following:
(1) Is the IC necessary or useful for us to perform properly;
(2) Is the proposed burden accurate;
(3) Do you have any suggestions that will enhance the quality,
usefulness, and clarity of the information to be collected; and
(4) Can we minimize the burden on the respondents.
In addition, the PRA requires agencies to also estimate the non-
hour cost burden to respondents or recordkeepers resulting from the
collection of information. Therefore, if you have other than hour
burden costs to generate, maintain, and disclose this information, you
should comment and provide your total capital and startup cost
components or annual operation, maintenance, and purchase of service
components. Generally, your estimate should not include costs incurred
for reasons other than to provide information or keep records for the
government; or as part of customary and usual business or private
practices. For further information on this burden, refer to 5 CFR
1320.3(b)(1) and (2), or contact the BSEE Bureau Information Collection
Clearance Officer.
National Environmental Policy Act of 1969 (NEPA)
We prepared a draft environmental assessment that concludes that
this proposed rule would not have a significant impact on the quality
of the environment under NEPA. A copy of the draft Environmental
Assessment can be viewed at www.regulations.gov (use the keyword/ID
BSEE-2015-0002). We will consider any new information we receive during
the public comment period for the proposed rule that may inform our
analysis of the potential environmental impacts of the rule.
Data Quality Act
In developing this rule, we did not conduct or use a study,
experiment, or survey requiring peer review under the Data Quality Act
(Pub. L. 106-554, app. C Sec. 515, 114 Stat. 2763, 2763A-153-154).
Effects on the Nation's Energy Supply (E.O. 13211)
This rule is not a significant energy action under the definition
in E.O. 13211. Although the proposed rule is a significant regulatory
action under E.O. 12866, it is not likely to have a significant adverse
effect on the supply, distribution, or use of energy. A Statement of
Energy Effects is not required.
Clarity of This Regulation
We are required by E.O. 12866, E.O. 12988, and by the Presidential
Memorandum of June 1, 1998, to write all rules in plain language. This
means that each rule we publish must:
(1) Be logically organized;
(2) Use the active voice to address readers directly;
(3) Use clear language rather than jargon;
(4) Be divided into short sections and sentences; and
(5) Use lists and tables wherever possible.
If you feel that we have not met these requirements, send us
comments by one of the methods listed in the ADDRESSES section. To
better help us revise the rule, your comments should be as specific as
possible. For example, you should tell us the numbers of the sections
or paragraphs that you find unclear, which sections or sentences are
too long, the sections where you feel lists or tables would be useful,
etc.
Public Availability of Comments
Before including your address, phone number, email address, or
other personal identifying information in your comment, you should be
aware that your entire comment--including your personal identifying
information--may be made publicly available at any time. While you can
ask us in your comment to withhold your personal identifying
information from public review, we cannot guarantee that we will be
able to do so.
List of Subjects in 30 CFR Part 250
Administrative practice and procedure, Continental shelf,
Environmental impact statements, Environmental protection,
Incorporation by reference, Oil and gas exploration, Penalties, Public
lands--mineral resources, Public lands--rights-of-way, Reporting and
recordkeeping requirements, Sulphur.
Dated: April 9, 2015.
Janice M. Schneider,
Assistant Secretary--Land and Minerals Management.
For the reasons stated in the preamble, the Bureau of Safety and
Environmental Enforcement (BSEE) is proposing to amend 30 CFR part 250
as follows:
PART 250--OIL AND GAS AND SULPHUR OPERATIONS IN THE OUTER
CONTINENTAL SHELF
0
1. The authority citation for part 250 continues to read as follows:
Authority: 30 U.S.C. 1751, 31 U.S.C. 9701, 43 U.S.C. 1334.
0
2. In Sec. 250.102, revise paragraphs (b)(1) and (b)(11) through (13)
and add paragraph (b)(19) to read as follows:
Sec. 250.102 What does this part do?
* * * * *
(b) * * *
[[Page 21563]]
Table--Where To Find Information for Conducting Operations
----------------------------------------------------------------------------------------------------------------
For information about . . . Refer to . . .
----------------------------------------------------------------------------------------------------------------
(1) Applications for permit to drill (APD)...... 30 CFR 250, subparts D and G.
* * * * * * *
(11) Oil and gas well-completion operations..... 30 CFR 250, subparts E and G.
(12) Oil and gas well-workover operations....... 30 CFR 250, subparts F and G.
(13) Decommissioning activities................. 30 CFR 250, subparts G and Q.
* * * * * * *
(19) Well operations and equipment.............. 30 CFR 250, subpart G.
----------------------------------------------------------------------------------------------------------------
0
3. Amend Sec. 250.107 by:
0
a. Removing the word ``and'' from the end of paragraph (a)(1);
0
b. Removing the period from the end of paragraph (a)(2) and adding in
its place a semicolon; and
0
c. Adding paragraphs (a)(3) and (4) and (e).
The additions read as follows:
Sec. 250.107 What must I do to protect health, safety, property, and
the environment?
(a) * * *
(3) Utilizing recognized engineering practices that reduce risks to
the lowest level practicable when conducting design, fabrication,
installation, operation, inspection, repair, and maintenance
activities; and
(4) Complying with all lease, plan, and permit terms and
conditions.
* * * * *
(e) The BSEE may issue orders to ensure compliance with this part,
including but not limited to, orders to produce and submit records and
to inspect, repair, and or replace equipment. The BSEE may also issue
orders to shut-in operations of a component or facility because of a
threat of serious, irreparable, or immediate harm to health, safety,
property, or the environment posed by those operations or because the
operations violate law, including a regulation, order, or provision of
a lease, plan, or permit.
0
4. In Sec. 250.125, revise the table in paragraph (a) to read as
follows:
Sec. 250.125 Service fees.
(a) * * *
------------------------------------------------------------------------
Service--processing of the
following: Fee amount 30 CFR citation
------------------------------------------------------------------------
(1) Suspension of Operations/ $2,123................ Sec.
Suspension of Production (SOO/ 250.171(e).
SOP) Request.
(2) Deepwater Operations Plan $3,599................ Sec.
(DWOP). 250.292(q).
(3) Application for Permit to $2,113 for initial Sec.
Drill (APD); Form BSEE-0123. applications only; no 250.410(d);
fee for revisions. Sec.
250.513(b);
Sec.
250.1617(a).
(4) Application for Permit to $125.................. Sec.
Modify (APM); Form BSEE-0124. 250.465(b);
Sec.
250.513(b);
Sec.
250.613(b);
Sec.
250.1618(a);
Sec.
250.1704(g).
(5) New Facility Production $5,426 A component is Sec.
Safety System Application for a piece of equipment 250.802(e).
facility with more than 125 or ancillary system
components. that is protected by
one or more of the
safety devices
required by API RP
14C (as incorporated
by reference in Sec.
250.198); $14,280
additional fee will
be charged if BSEE
deems it necessary to
visit a facility
offshore, and $7,426
to visit a facility
in a shipyard.
(6) New Facility Production $1,314 Additional fee Sec.
Safety System Application for of $8,967 will be 250.802(e).
facility with 25-125 charged if BSEE deems
components. it necessary to visit
a facility offshore,
and $5,141 to visit a
facility in a
shipyard.
(7) New Facility Production $652.................. Sec.
Safety System Application for 250.802(e).
facility with fewer than 25
components.
(8) Production Safety System $605.................. Sec.
Application--Modification 250.802(e).
with more than 125 components
reviewed.
(9) Production Safety System $217.................. Sec.
Application--Modification 250.802(e).
with 25-125 components
reviewed.
(10) Production Safety System $92................... Sec.
Application--Modification 250.802(e).
with fewer than 25 components
reviewed.
(11) Platform Application-- $22,734............... Sec.
Installation--Under the 250.905(l).
Platform Verification Program.
(12) Platform Application-- $3,256................ Sec.
Installation--Fixed Structure 250.905(l).
Under the Platform Approval
Program.
(13) Platform Application-- $1,657................ Sec.
Installation--Caisson/Well 250.905(l)
Protector.
(14) Platform Application-- $3,884................ Sec.
Modification/Repair. 250.905(l).
(15) New Pipeline Application $3,541................ Sec.
(Lease Term). 250.1000(b).
(16) Pipeline Application-- $2,056................ Sec.
Modification (Lease Term). 250.1000(b).
(17) Pipeline Application-- $4,169................ Sec.
Modification (ROW). 250.1000(b).
(18) Pipeline Repair $388.................. Sec.
Notification. 250.1008(e).
(19) Pipeline Right-of-Way $2,771................ Sec.
(ROW) Grant Application. 250.1015(a).
(20) Pipeline Conversion of $236.................. Sec.
Lease Term to ROW. 250.1015(a).
(21) Pipeline ROW Assignment.. $201.................. Sec.
250.1018(b).
[[Page 21564]]
(22) 500 Feet From Lease/Unit $3,892................ Sec.
Line Production Request. 250.1156(a).
(23) Gas Cap Production $4,953................ Sec. 250.1157.
Request.
(24) Downhole Commingling $5,779................ Sec.
Request. 250.1158(a).
(25) Complex Surface $4,056................ Sec.
Commingling and Measurement 250.1202(a);
Application. Sec.
250.1203(b);
Sec.
250.1204(a).
(26) Simple Surface $1,371................ Sec.
Commingling and Measurement 250.1202(a);
Application. Sec.
250.1203(b);
Sec.
250.1204(a).
(27) Voluntary Unitization $12,619............... Sec.
Proposal or Unit Expansion. 250.1303(d).
(28) Unitization Revision..... $896.................. Sec.
250.1303(d).
(29) Application to Remove a $4,684................ Sec. 250.1727.
Platform or Other Facility.
(30) Application to $1,142................ Sec.
Decommission a Pipeline 250.1751(a) or
(Lease Term). Sec.
250.1752(a).
(31) Application to $2,170................ Sec.
Decommission a Pipeline (ROW). 250.1751(a) or
Sec.
250.1752(a).
------------------------------------------------------------------------
0
5. Amend Sec. 250.198 by revising paragraphs (h)(51), (63), (68), and
(70) and adding paragraphs (h)(89) through (94) to read as follows:
Sec. 250.198 Documents incorporated by reference.
* * * * *
(h) * * *
(51) API RP 2RD, Design of Risers for Floating Production Systems
(FPSs) and Tension-Leg Platforms (TLPs), First Edition, June 1998;
Reaffirmed May 2006, Errata June 2009; incorporated by reference at
Sec. Sec. 250.292, 250.733, 250.800, 250.901, and 250.1002;
* * * * *
(63) API Standard 53, Blowout Prevention Equipment Systems for
Drilling Wells, Fourth Edition, November 2012; incorporated by
reference at Sec. Sec. 250.730, 250.737, and 250.739;
* * * * *
(68) ANSI/API Spec. Q1, Specification for Quality Programs for the
Petroleum, Petrochemical and Natural Gas Industry, ISO TS 29001:2007
(Identical), Petroleum, petrochemical and natural gas industries--
Sector specific requirements--Requirements for product and service
supply organizations, Eighth Edition, December 2007, Effective Date:
June 15, 2008; incorporated by reference at Sec. Sec. 250.730 and
250.806;
* * * * *
(70) ANSI/API Spec. 6A, Specification for Wellhead and Christmas
Tree Equipment, Nineteenth Edition, July 2004; Effective Date: February
1, 2005; Contains API Monogram Annex as Part of U.S. National Adoption;
ISO 10423:2003 (Modified), Petroleum and natural gas industries--
Drilling and production equipment--Wellhead and Christmas tree
equipment; Errata 1, September 2004, Errata 2, April 2005, Errata 3,
June 2006, Errata 4, August 2007, Errata 5, May 2009; Addendum 1,
February 2008; Addendum 2, 3, and 4, December 2008; incorporated by
reference at Sec. Sec. 250.730, 250.806, and 250.1002;
* * * * *
(89) ANSI/API Spec. 11D1, Packers and Bridge Plugs, ISO 14310:2008
(Identical), Petroleum and natural gas industries--Downhole equipment--
Packers and bridge plugs, Second Edition, Effective Date: January 1,
2010; incorporated by reference at Sec. Sec. 250.518, 250.619, and
250.1703;
(90) ANSI/API Spec. 16A, Specification for Drill-through Equipment,
Third Edition, June 2004; incorporated by reference at Sec. 250.730;
(91) ANSI/API Spec. 16C, Specification for Choke and Kill Systems,
First Edition, January 1993; incorporated by reference at Sec.
250.730;
(92) API Spec. 16D, Specification for Control Systems for Drilling
Well control Equipment and Control Systems for Diverter Equipment,
Second Edition, July 2004; incorporated by reference at Sec. 250.730;
(93) ANSI/API Spec. 17D, Design and Operation of Subsea Production
Systems--Subsea Wellhead and Tree Equipment, Second Edition; May 2011;
ISO 13628-4 (Identical), Design and operation of subsea production
systems-Part 4: Subsea wellhead and tree equipment; incorporated by
reference at Sec. 250.730; and
(94) ANSI/API RP 17H, Remotely Operated Vehicle Interfaces on
Subsea Production Systems, ISO 13628-8:2002 (Identical), Petroleum and
natural gas industries--Design and operation of subsea production
systems--Part 8: Remotely Operated Vehicle (ROV) interfaces on subsea
production systems, First Edition, July 2004, Reaffirmed: January 2009;
incorporated by reference at Sec. 250.734.
* * * * *
0
6. In Sec. 250.199, revise paragraph (e) to read as follows:
Sec. 250.199 Paperwork Reduction Act statements--information
collection.
* * * * *
(e) BSEE is collecting this information for the reasons given in
the following table:
------------------------------------------------------------------------
30 CFR subpart, title and/or BSEE Form BSEE collects this information
(OMB Control No.) and uses it to:
------------------------------------------------------------------------
(1) Subpart A, General (1014-0022), (i) Determine that activities
including Forms BSEE-0132, Evacuation on the OCS comply with
Statistics; BSEE-0143, Facility/ statutory and regulatory
Equipment Damage Report; BSEE-1832, requirements; are safe and
Notification of Incidents of protect the environment; and
Noncompliance. result in diligent development
and production on OCS leases.
(ii) Support the unproved and
proved reserve estimation,
resource assessment, and fair
market value determinations.
(iii) Assess damage and project
any disruption of oil and gas
production from the OCS after
a major natural occurrence.
(2) Subpart B, Plans and Information Evaluate Deepwater Operations
(1014-0024). Plans for compliance with
statutory and regulatory
requirements.
[[Page 21565]]
(3) Subpart C, Pollution Prevention and (i) Evaluate measures to
Control (1014-0023). prevent unauthorized discharge
of pollutants into the
offshore waters.
(ii) Ensure action is taken to
control pollution.
(4) Subpart D, Oil and Gas and Drilling (i) Evaluate the equipment and
Operations (1014-0018), including procedures to be used in
Forms BSEE-0125, End of Operations drilling operations on the
Report; BSEE-0133, Well Activity OCS.
Report; and BSEE-0133S, Open Hole Data (ii) Ensure that drilling
Report. operations meet statutory and
regulatory requirements.
(5) Subpart E, Oil and Gas Well- (i) Evaluate the equipment and
Completion Operations (1014-0004). procedures to be used in well-
completion operations on the
OCS.
(ii) Ensure that well-
completion operations meet
statutory and regulatory
requirements.
(6) Subpart F, Oil and Gas Well (i) Evaluate the equipment and
Workover Operations (1014-0001). procedures to be used during
well-workover operations on
the OCS.
(ii) Ensure that well-workover
operations meet statutory and
regulatory requirements.
(7) Subpart G, Blowout Preventer (i) Evaluate the equipment and
Systems (1014-xxxx), including Form procedures to be used during
BSEE-0144, Rig Movement Notification well drilling, completion,
Report. workover, and abandonment
operations on the OCS.
(ii) Ensure that well
operations meet statutory and
regulatory requirements.
(8) Subpart H, Oil and Gas Production (i) Evaluate the equipment and
Safety Systems (1014-0003). procedures that will be used
during production operations
on the OCS.
(ii) Ensure that production
operations meet statutory and
regulatory requirements.
(9) Subpart I, Platforms and Structures (i) Evaluate the design,
(1014-0011). fabrication, and installation
of platforms on the OCS.
(ii) Ensure the structural
integrity of platforms
installed on the OCS.
(10) Subpart J, Pipelines and Pipeline (i) Evaluate the design,
Rights-of-Way (1014-0016), including installation, and operation of
Form BSEE-0149, Assignment of Federal pipelines on the OCS.
OCS Pipeline Right-of-Way Grant. (ii) Ensure that pipeline
operations meet statutory and
regulatory requirements.
(11) Subpart K, Oil and Gas Production (i) Evaluate production rates
Rates (1014-0019), including Forms for hydrocarbons produced on
BSEE-0126, Well Potential Test Report the OCS.
and BSEE-0128, Semiannual Well Test (ii) Ensure economic
Report. maximization of ultimate
hydrocarbon recovery.
(12) Subpart L, Oil and Gas Production (i) Evaluate the measurement of
Measurement, Surface Commingling, and production, commingling of
Security (1014-0002). hydrocarbons, and site
security plans.
(ii) Ensure that produced
hydrocarbons are measured and
commingled to provide for
accurate royalty payments and
security.
(13) Subpart M, Unitization (1014-0015) (i) Evaluate the unitization of
leases.
(ii) Ensure that unitization
prevents waste, conserves
natural resources, and
protects correlative rights.
(14) Subpart N, Remedies and Penalties. (The requirements in subpart N
are exempt from the Paperwork
Reduction Act of 1995
according to 5 CFR 1320.4).
(15) Subpart O, Well Control and (i) Evaluate training program
Production Safety Training (1014-0008). curricula for OCS workers,
course schedules, and
attendance.
(ii) Ensure that training
programs are technically
accurate and sufficient to
meet statutory and regulatory
requirements, and that workers
are properly trained.
(16) Subpart P, Sulphur Operations (i) Evaluate sulphur
(1014-0006). exploration and development
operations on the OCS.
(ii) Ensure that OCS sulphur
operations meet statutory and
regulatory requirements and
will result in diligent
development and production of
sulphur leases.
(17) Subpart Q, Decommissioning Ensure that decommissioning
Activities (1014-0010). activities, site clearance,
and platform or pipeline
removal are properly performed
to meet statutory and
regulatory requirements and do
not conflict with other users
of the OCS.
(18) Subpart S, Safety and (i) Evaluate operators'
Environmental Management Systems (1014- policies and procedures to
0017), including Form BSEE-0131, assure safety and
Performance Measures Data. environmental protection while
conducting OCS operations
(including those operations
conducted by contractor and
subcontractor personnel).
(ii) Evaluate Performance
Measures Data relating to risk
and number of accidents,
injuries, and oil spills
during OCS activities.
(19) Application for Permit to Drill (i) Evaluate and approve the
(APD, Revised APD), Form BSEE-0123; adequacy of the equipment,
and Supplemental APD Information materials, and/or procedures
Sheet, Form BSEE-0123S, and all that the lessee or operator
supporting documentation (1014-0025). plans to use during drilling.
(ii) Ensure that applicable OCS
operations meet statutory and
regulatory requirements.
[[Page 21566]]
(20) Application for Permit to Modify (i) Evaluate and approve the
(APM), Form BSEE-0124, and supporting adequacy of the equipment,
documentation (1014-0026). materials, and/or procedures
that the lessee or operator
plans to use during drilling
and to evaluate well plan
modifications and changes in
major equipment.
(ii) Ensure that applicable OCS
operations meet statutory and
regulatory requirements.
------------------------------------------------------------------------
0
7. Amend Sec. 250.292 by:
0
a. Removing the word ``and'' from the end of paragraph (o);
0
b. Redesignating paragraph (p) as (q); and
0
c. Adding new paragraph (p).
The addition reads as follows:
Sec. 250.292 What must the DWOP contain?
* * * * *
(p) If you propose to use a pipeline free standing hybrid riser
(FSHR) that utilizes a critical chain, wire rope, or synthetic tether
to connect the top of the riser to a buoyancy air can, provide the
following information in your DWOP in the discussions required by
paragraphs (f) and (g) of this section:
(1) A detailed description and drawings of the FSHR, buoy and the
tether system;
(2) Detailed information on the design, fabrication, and
installation of the FSHR, buoy and tether system, including pressure
ratings, fatigue life, and yield strengths;
(3) A description of how you met the design requirements, load
cases, and allowable stresses for each load case according to API RP
2RD (as incorporated by reference in Sec. 250.198);
(4) Detailed information regarding the tether system used to
connect the FSHR to a buoyancy air can;
(5) Descriptions of your monitoring system and monitoring plan to
monitor the pipeline FSHR and tether for fatigue, stress, and any other
abnormal condition (e.g., corrosion) that may negatively impact the
riser or tether; and
(6) Documentation that the tether system and connection accessories
for the pipeline FSHR have been certified by an approved classification
society or equivalent and verified by the CVA required in Subpart I;
and
* * * * *
0
8. Revise Sec. 250.400 to read as follows:
Sec. 250.400 General Requirements.
Drilling operations must be conducted in a safe manner to protect
against harm or damage to life (including fish and other aquatic life),
property, natural resources of the Outer Continental Shelf (OCS),
including any mineral deposits (in areas leased and not leased), the
National security or defense, or the marine, coastal, or human
environment. In addition to the requirements of this subpart, you must
also follow the applicable requirements of Subpart G.
Sec. Sec. Sec. 250.401 through 250.403 [Removed and Reserved]
0
9a. Remove and reserve Sec. Sec. 250.401 through 250.403, and 250.406.
Sec. Sec. 250.406 [Removed and Reserved]
0
9b. Remove and reserve Sec. 250.406.
0
10. Revise Sec. 250.411 to read as follows:
Sec. 250.411 What information must I submit with my application?
In addition to forms BSEE-0123 and BSEE-0123S, you must include the
information required in this subpart and Subpart G, including the
following:
------------------------------------------------------------------------
Where to
Information that you must include with an APD find a
description
------------------------------------------------------------------------
(a) Plat that shows locations of the proposed well......... Sec.
250.412
(b) Design criteria used for the proposed well............. Sec.
250.413
(c) Drilling prognosis..................................... Sec.
250.414
(d) Casing and cementing programs.......................... Sec.
250.415
(e) Diverter systems descriptions.......................... Sec.
250.416
(f) BOP system descriptions................................ Sec.
250.731
(g) Requirements for using an MODU, and.................... Sec.
250.713
(h) Additional information................................. Sec.
250.418
------------------------------------------------------------------------
0
11. In Sec. 250.413, revise paragraph (g) to read as follows:
Sec. 250.413 What must my description of well drilling design
criteria address?
* * * * *
(g) A single plot containing curves for estimated pore pressures,
formation fracture gradients, proposed drilling fluid weights, maximum
equivalent circulating density, and casing setting depths in true
vertical measurements;
* * * * *
0
12. Amend Sec. 250.414 by revising paragraphs (c), (h), and (i) and
adding paragraphs (j) and (k) to read as follows:
Sec. 250.414 What must my drilling prognosis include?
* * * * *
(c) Planned safe drilling margins between proposed drilling fluid
weights and the estimated pore pressures, and proposed drilling fluid
weights and the lesser of estimated fracture gradients or casing shoe
pressure integrity test. Your safe drilling margins must meet the
following conditions:
(1) Static downhole mud weight must be greater than estimated pore
pressure;
(2) Static downhole mud weight must be a minimum of one-half pound
per gallon below the lesser of the casing shoe pressure integrity test
or the lowest estimated fracture gradient;
(3) The equivalent circulating density must be below the lesser of
the casing shoe pressure integrity test or the lowest estimated
fracture gradient; and
(4) When determining the pore pressure and lowest estimated
fracture gradient for a specific interval, you must consider related
hole behavior observations.
* * * * *
(h) A list and description of all requests for using alternate
procedures or departures from the requirements of this subpart in one
place in the APD. You must explain how the alternate procedures afford
an equal or greater degree of protection, safety, or performance, or
why the departures are requested;
(i) Projected plans for well testing (refer to Sec. 250.460);
(j) The type of wellhead system and liner hanger system to be
installed and a descriptive schematic, which includes but is not
limited to pressure ratings, dimensions, valves, load shoulders, and
locking mechanisms, if applicable; and
(k) Any additional information required by the District Manager.
0
13. In Sec. 250.415, revise paragraph (a) to read as follows:
Sec. 250.415 What must my casing and cementing programs include?
* * * * *
(a) The following well design information:
(1) Hole sizes;
(2) Bit depths (including measured and true vertical depth (TVD));
(3) Casing information including sizes, weights, grades, collapse
and burst values, types of connection, and
[[Page 21567]]
setting depths (measured and TVD) for all sections of each casing
interval; and
(4) Locations of any installed rupture disks (indicate if burst or
collapse and rating);
* * * * *
0
14. Revise Sec. 250.416 to read as follows:
Sec. 250.416 What must I include in the diverter description?
You must include in the diverter descriptions:
(a) A description of the diverter system and its operating
procedures;
(b) A schematic drawing of the diverter system (plan and elevation
views) that shows:
(1) The size of the annular BOP installed in the diverter housing;
(2) Spool outlet internal diameter(s);
(3) Diverter-line lengths and diameters; burst strengths and radius
of curvature at each turn; and
(4) Valve type, size working pressure rating, and location.
Sec. 250.417 [Removed and Reserved]
0
15. Remove and reserve Sec. 250.417.
0
16. In Sec. 250.418, revise paragraph (g) to read as follows:
Sec. 250.418 What additional information must I submit with my APD?
* * * * *
(g) A request for approval if you plan to wash out or displace
cement to facilitate casing removal upon well abandonment. Your request
must include a description of how far below the mudline you propose to
displace cement and how you will visually monitor returns;
* * * * *
0
17. Amend Sec. 250.420 by:
0
a. Revising the introductory text and paragraph (a)(5);
0
b. Redesignating paragraph (a)(6) as (a)(7);
0
c. Adding new paragraph (a)(6) and paragraph (b)(4); and
0
d. Revising paragraph (c).
The revisions and additions read as follows:
Sec. 250.420 What well casing and cementing requirements must I meet?
You must case and cement all wells. Your casing and cementing
programs must meet the applicable requirements of this subpart and of
subpart G.
(a) * * *
(5) Support unconsolidated sediments;
(6) Provide adequate centralization to ensure proper cementation;
and
* * * * *
(b) * * *
(4) If you need to substitute a different size, grade, or weight of
casing than what was approved in your APD, you must contact the
District Manager for approval prior to installing the casing.
* * * * *
(c) Cementing requirements. (1) You must design and conduct your
cementing jobs so that cement composition, placement techniques, and
waiting times ensure that the cement placed behind the bottom 500 feet
of casing attains a minimum compressive strength of 500 psi before
drilling out the casing or before commencing completion operations.
(2) You must use a weighted fluid to maintain an overbalanced
hydrostatic pressure during the cement setting time, except when
cementing casings or liners in riserless hole sections.
0
18. In Sec. 250.421, revise paragraphs (b) and (f) to read as follows:
Sec. 250.421 What are the casing and cementing requirements by type
of casing string?
* * * * *
------------------------------------------------------------------------
Casing type Casing requirements Cementing requirements
------------------------------------------------------------------------
* * * * * * *
(b) Conductor.......... Design casing and Use enough cement to
select setting depths fill the calculated
based on relevant annular space back to
engineering and the mudline.
geologic factors. Verify annular fill by
These factors include observing cement
the presence or returns. If you
absence of cannot observe cement
hydrocarbons, returns, use
potential hazards, and additional cement to
water depths. ensure fill-back to
Set casing immediately the mudline.
before drilling into For drilling on an
formations known to artificial island or
contain oil or gas. If when using a well
you encounter oil or cellar, you must
gas or unexpected discuss the cement
formation pressure fill level with the
before the planned District Manager.
casing point, you must
set casing immediately
and set it above the
encountered zone.
* * * * * * *
(f) Liners............. If you use a liner as Same as cementing
surface casing, you requirements for
must set the top of specific casing
the liner at least 200 types. For example, a
feet above the liner used as
previous casing/liner intermediate casing
shoe. must be cemented
If you use a liner as according to the
an intermediate string cementing
below a surface string requirements for
or production casing intermediate casing.
below an intermediate
string, you must set
the top of the liner
at least 100 feet
above the previous
casing shoe.
You may not use a liner
as conductor casing.
------------------------------------------------------------------------
0
19. Revise Sec. 250.423 to read as follows:
Sec. 250.423 What are the requirements for casing and liner
installation?
You must ensure proper installation of casing in the subsea
wellhead or liner in the liner hanger.
(a) You must ensure that the latching mechanisms or lock down
mechanisms are engaged upon successfully installing and cementing the
casing string.
(b) If you run a liner that has a latching mechanism or lock down
mechanism, you must ensure that the latching mechanisms or lock down
mechanisms are engaged upon successfully installing and cementing the
liner.
(c) You must perform a pressure test on the casing seal assembly to
ensure proper installation of casing or liner. You must perform this
test for the intermediate and production casing strings or liners.
(1) You must submit for approval with your APD, test procedures and
criteria for a successful test.
(2) You must document all your test results and make them available
to BSEE upon request.
[[Page 21568]]
Sec. Sec. 250.424 through 250.426 [Removed and Reserved]
0
20. Remove and reserve Sec. Sec. 250.424 through 250.426.
0
21. In Sec. 250.427, revise paragraph (b) to read as follows:
Sec. 250.427 What are the requirements for pressure integrity tests?
* * * * *
(b) While drilling, you must maintain the safe drilling margins
identified in Sec. 250.414. When you cannot maintain the safe margins,
you must suspend drilling operations and remedy the situation.
0
22. In Sec. 250.428, revise paragraphs (b) through (d) and add
paragraph (k) to read as follows:
Sec. 250.428 What must I do in certain cementing and casing
situations?
* * * * *
------------------------------------------------------------------------
If you encounter the following
situation: Then you must . . .
------------------------------------------------------------------------
* * * * * * *
(b) Need to change casing setting Submit those changes to the District
depths or hole interval drilling Manager for approval and include a
depth (for a BHA with an under- certification by a professional
reamer, this means bit depth) engineer (PE) that he or she
more than 100 feet true vertical reviewed and approved the proposed
depth (TVD) from the approved APD changes.
due to conditions encountered
during drilling operations.
(c) Have indication of inadequate (1) Locate the top of cement by: (i)
cement job (such as lost returns, Running a temperature survey; (ii)
no cement returns to mudline or Running a cement evaluation log; or
expected height, cement (iii) Using a combination of these
channeling, or failure of techniques.
equipment). (2) Determine if your cement job is
inadequate. If your cement job is
determined to be inadequate, refer
to paragraph (d) of this section.
(3) If your cement job is determined
to be adequate, report the results
to the District Manager in your
submitted WAR.
(d) Inadequate cement job......... Take remedial actions. The District
Manager must review and approve all
remedial actions before you may
take them, unless immediate actions
must be taken to ensure the safety
of the crew or to prevent a well-
control event. If you complete any
immediate action to ensure the
safety of the crew or to prevent a
well-control event, submit a
description of the action to the
District Manager when that action
is complete. Any changes to the
well program will require submittal
of a certification by a
professional engineer (PE)
certifying that he or she reviewed
and approved the proposed changes,
and must meet any other
requirements of the District
Manager.
* * * * * * *
(k) Plan to use a valve on the Include a description of the plan in
drive pipe during cementing your APD. Your description must
operations for the conductor include a schematic of the valve
casing, surface casing, or liner. and height above the water line.
The valve must be remotely operated
and full opening with visual
observation while taking returns.
The person in charge of observing
returns must be in communication
with the drill floor. You must
record in your daily report and in
the WAR if cement returns were
observed. If cement returns are not
observed, you must contact the
District Manager and obtain
approval of proposed plans to
locate the top of cement before
continuing with operations.
------------------------------------------------------------------------
Sec. Sec. 250.440 through 250.451 [Removed and Reserved]
0
23. Remove the undesignated center heading ``Blowout Preventer (BOP)
System Requirements'' and remove and reserve Sec. Sec. 250.440 through
250.451.
Sec. 250.456 [Amended]
0
24. Amend Sec. 250.456:
0
a. In paragraph (i), by adding the word ``and'' after the semi-colon
0
b. By removing paragraph (j); and
0
c. By redesignating paragraph (k) as (j).
0
25. Revise Sec. 250.462 to read as follows.
Sec. 250.462 What are the source control and containment
requirements?
For drilling operations using a subsea BOP or surface BOP on a
floating facility, you must have the ability to control or contain a
blowout event at the sea floor.
(a) To determine your required source control and containment
capabilities you must do the following:
(1) Consider a scenario of the wellbore fully evacuated to
reservoir fluids, with no restrictions in the well.
(2) Evaluate the performance of the well as designed to determine
if a full shut-in can be achieved without having reservoir fluids
broach to the sea floor. If your evaluation indicates that the well can
only be partially shut-in, then you must determine your ability to flow
and capture the residual fluids to a surface production and storage
system.
(b) You must have access to and ability to deploy Source Control
and Containment Equipment (SCCE) necessary to regain control of the
well. SCCE means the capping stack, cap and flow system, containment
dome, and/or other subsea and surface devices, equipment, and vessels
whose collective purpose is to control a spill source and stop the flow
of fluids into the environment or to contain fluids escaping into the
environment. This equipment must include, but is not limited to, the
following:
(1) Subsea containment and capture equipment, including containment
domes and capping stacks;
(2) Subsea utility equipment, including hydraulic power, hydrate
control, and dispersant injection equipment;
(3) Riser systems;
(4) Remotely operated vehicles (ROVs);
(5) Capture vessels;
(6) Support vessels; and
(7) Storage facilities.
(c) You must submit a description of your source control and
containment capabilities to the Regional Supervisor and receive
approval before BSEE will approve your APD, Form BSEE-0123. The
description of your containment capabilities must contain the
following:
(1) Your source control and containment capabilities for
controlling and containing a blowout event at the seafloor,
[[Page 21569]]
(2) A discussion of the determination required in paragraph (a) of
this section, and
(3) Information showing that you have access to and ability to
deploy all equipment required by paragraph (b) of this section.
(d) You must contact the District Manager and Regional Supervisor
for reevaluation of your source control and containment capabilities if
your:
(1) Well design changes, or
(2) Approved source control and containment equipment is out of
service.
(e) You must maintain, test, and inspect the source control and
containment equipment identified in the following table according to
these requirements:
------------------------------------------------------------------------
Requirements, you Additional
Equipment must: information
------------------------------------------------------------------------
(1) Capping stacks.......... (i) Function test Pressure holding
all pressure critical components
holding critical are those
components on a components that
quarterly frequency will experience
(not to exceed 104 wellbore pressure
days between tests). during a shut-in
after being
functioned.
(ii) Pressure test Pressure holding
pressure holding critical components
critical components are those
on a bi-annual components that
basis, but not will experience
later than 210 days wellbore pressure
from the last during a shut-in.
pressure test. All These components
pressure testing include, but are
must be witnessed not limited to: All
by BSEE and a BSEE- blind rams,
approved wellhead
verification connectors, and
organization. outlet valves.
(iii) Notify BSEE at ....................
least 21 days prior
to commencing any
pressure testing.
(2) Production Safety (i) Meet or exceed ....................
Systems used for flow and the requirements
capture operations. set forth in 30 CFR
250.800-250.808,
Subpart H.
(ii) Have all
equipment unique to
containment
operations
available for
inspection at all
times..
(3) Subsea utility equipment Have all equipment Subsea utility
unique to equipment includes,
containment but is not limited
operations to: Hydraulic power
available for sources, debris
inspection at all removal, hydrate
times. control equipment,
and dispersant
injection
equipment.
------------------------------------------------------------------------
0
26. In Sec. 250.465, revise paragraph (b)(3) to read as follows:
Sec. 250.465 When must I submit an Application for Permit to Modify
(APM) or an End of Operations Report to BSEE?
* * * * *
(b) * * *
(3) Within 30 days after completing this work, you must submit an
End of Operations Report (EOR), Form BSEE-0125, as required under Sec.
250.744.
Sec. Sec. 250.466 through 250.469 [Removed and Reserved]
0
27. Remove and reserve Sec. Sec. 250.466 through 250.469.
0
28. Revise Sec. 250.500 to read as follows:
Sec. 250.500 General requirements.
Well-completion operations must be conducted in a manner to protect
against harm or damage to life (including fish and other aquatic life),
property, natural resources of the OCS, including any mineral deposits
(in areas leased and not leased), the National security or defense, or
the marine, coastal, or human environment. In addition to the
requirements of this subpart, you must also follow the applicable
requirements of Subpart G.
Sec. Sec. 250.502 and 250.506 [Removed and Reserved]
0
29. Remove and reserve Sec. Sec. 250.502 and 250.506.
Sec. 250.514 [Amended]
0
30. In Sec. 250.514, remove paragraph (d).
Sec. Sec. 250.515 through 250.517 [Removed and Reserved]
0
31. Remove and reserve Sec. Sec. 250.515 through 250.517.
0
32. Amend Sec. 250.518 by:
0
a. Removing paragraph (b);
0
b. Redesignating paragraphs (c) through (e) as paragraphs (b) through
(d); and
0
c. Adding new paragraph (e) and paragraph (f).
The additions read as follows:
Sec. 250.518 Tubing and wellhead equipment.
* * * * *
(e) Installed packers and bridge plugs must meet the following:
(1) All packers and bridge plugs must comply with API Spec. 11D1
(as incorporated by reference in Sec. 250.198);
(2) During well completion operations, the production packer must
be set at a depth that will allow for a column of weighted fluids to be
placed above the packer that will exert a hydrostatic force greater
than or equal to the force created by the reservoir pressure below the
packer;
(3) The production packer must be set as close as practically
possible to the perforated interval; and
(4) The production packer must be set at a depth that is within the
cemented interval of the selected casing section.
(f) Your APM must include a description and calculations for how
you determined the production packer setting depth.
0
33. Revise Sec. 250.600 to read as follows:
Sec. 250.600 General requirements.
Well-workover operations must be conducted in a manner to protect
against harm or damage to life (including fish and other aquatic life),
property, natural resources of the Outer Continental Shelf (OCS)
including any mineral deposits (in areas leased and not leased), the
National security or defense, or the marine, coastal, or human
environment. In addition to the requirements of this subpart, you must
also follow the applicable requirements of subpart G.
Sec. 250.602 [Removed and Reserved]
0
34a. Remove and reserve Sec. 250.602.
Sec. 250.606 [Removed and Reserved]
0
34b. Remove and reserve Sec. 250.606.
Sec. 250.614 [Amended]
0
35. In Sec. 250.614, remove paragraph (d).
Sec. 250.615 [Removed and Reserved]
0
36. Remove and reserve Sec. 250.615.
0
37. Amend Sec. 250.616 by:
0
a. Revising the section heading;
0
b. Removing paragraphs (a) through (e); and
0
c. Redesignating paragraphs (f) through (h) as paragraphs (a) through
(c).
The revision reads as follows:
[[Page 21570]]
Sec. 250.616 Coiled tubing and snubbing operations.
* * * * *
Sec. Sec. 250.617 and 250.618 [Removed and Reserved]
0
38. Remove and reserve Sec. Sec. 250.617 and 250.618.
0
39. Amend Sec. 250.619 by:
0
a. Removing paragraph (b);
0
b. Redesignating paragraphs (c) through (e) as paragraphs (b) through
(d); and
0
c. Adding new paragraph (e) and paragraph (f).
The additions read as follows;
Sec. 250.619 Tubing and wellhead equipment.
* * * * *
(e) If you pull and reinstall packers and bridge plugs, you must
meet the following:
(1) All packers and bridge plugs must comply with API Spec. 11D1
(as incorporated by reference in Sec. 250.198);
(2) The production packer must be set at a depth that will allow
for a column of weighted fluids to be placed above the packer during
well completion operations that will exert a hydrostatic force greater
than or equal to the force created by the reservoir pressure below the
packer;
(3) The production packer must be set as close as practically
possible to the perforated interval; and
(4) The production packer must be set at a depth that is within the
cemented interval of the selected casing section.
(f) Your APM must include a description and calculations for how
you determined the production packer setting depth.
0
40. Add subpart G to read as follows:
Subpart G--Well Operations and Equipment
General Requirements
Sec.
250.700 What operations and equipment does this subpart cover?
250.701 May I use alternate procedures or equipment during
operations?
250.702 May I obtain departures from these requirements?
250.703 What must I do to keep wells under control?
Rig Requirements
250.710 What instructions must be given to personnel engaged in well
operations?
250.711 What are the requirements for well-control drills?
250.712 What rig unit movements must I report?
250.713 What must I provide if I plan to use a mobile offshore
drilling unit (MODU) or lift boat for well operations?
250.714 Do I have to develop a dropped objects plan?
250.715 Do I need a global positioning system (GPS) for MODUs and
jack-ups?
Well Operations
250.720 When and how must I secure a well?
250.721 What are the requirements for pressure testing casing and
liners?
250.722 What are the requirements for prolonged operations in a
well?
250.723 What additional safety measures must I take when I conduct
operations on a platform that has producing wells or has other
hydrocarbon flow?
250.724 What are the real-time monitoring requirements?
Blowout Preventer (BOP) System Requirements
250.730 What are the general requirements for BOP systems and system
components?
250.731 What information must I submit for BOP systems and system
components?
250.732 What are the BSEE-approved verification organization
requirements for BOP systems and system components?
250.733 What are the requirements for a surface BOP stack?
250.734 What are the requirements for a subsea BOP system?
250.735 What associated systems and related equipment must all BOP
systems include?
250.736 What are the requirements for choke manifolds, kelly valves
inside BOPs, and drill string safety valves?
250.737 What are the BOP system testing requirements?
250.738 What must I do in certain situations involving BOP equipment
or systems?
250.739 What are the BOP maintenance and inspection requirements?
Records and Reporting
250.740 What records must I keep?
250.741 How long must I keep records?
250.742 What well records am I required to submit?
250.743 What are the well activity reporting requirements?
250.744 What are the end of operation reporting requirements?
250.745 What other well records could I be required to submit?
250.746 What are the recordkeeping requirements for casing, liner,
and BOP tests, and inspections of BOP systems and marine risers?
Subpart G--Well Operations and Equipment
General Requirements
Sec. 250.700 What operations and equipment does this subpart cover?
This subpart covers operations and equipment associated with
drilling, completion, workover, and decommissioning activities. This
subpart includes regulations applicable to drilling, completion,
workover, and decommissioning activities in addition to applicable
regulations contained in subparts D, E, F, and Q of this part unless
explicitly stated otherwise.
Sec. 250.701 May I use alternate procedures or equipment during
operations?
You may use alternate procedures or equipment during operations
after receiving approval as described in Sec. 250.141 of this part.
You must identify and discuss your proposed alternate procedures or
equipment in your Application for Permit to Drill (APD) (Form BSEE-
0123) (see Sec. 250.414(h)) or your Application for Permit to Modify
(APM) (Form BSEE-0124). Procedures for obtaining approval of alternate
procedures or equipment are described in Sec. 250.141 of this part.
Sec. 250.702 May I obtain departures from these requirements?
You may apply for a departure from these requirements as described
in Sec. 250.142. Your request must include a justification showing why
the departure is necessary. You must identify and discuss the departure
you are requesting in your APD (see Sec. 250.414(h)) or your APM.
Sec. 250.703 What must I do to keep wells under control?
You must take the necessary precautions to keep wells under control
at all times, including:
(a) Use recognized engineering practices that reduce risks to the
lowest level practicable when monitoring and evaluating well conditions
and to minimize the potential for the well to flow or kick;
(b) Have a person onsite during operations who represents your
interests and can fulfill your responsibilities;
(c) Ensure that the toolpusher, operator's representative, or a
member of the rig crew maintains continuous surveillance on the rig
floor from the beginning of operations until the well is completed or
abandoned, unless you have secured the well with blowout preventers
(BOPs), bridge plugs, cement plugs, or packers;
(d) Use personnel trained according to the provisions of Subparts O
and S;
(e) Use and maintain equipment and materials necessary to ensure
the safety and protection of personnel, equipment, natural resources,
and the environment; and
(f) Use equipment that has been designed, tested, and rated for the
most extreme service conditions to which it will be exposed while in
service.
Rig Requirements
Sec. 250.710 What instructions must be given to personnel engaged in
well operations?
Prior to engaging in well operations, personnel must be instructed
in:
(a) Date and time of safety meetings. The safety requirements for
the
[[Page 21571]]
operations to be performed, possible hazards to be encountered, and
general safety considerations to protect personnel, equipment, and the
environment as required by subpart S of this part. Date and time of
safety meetings must be recorded and available at the facility for
review by BSEE representatives.
(b) Well control. You must prepare a well-control plan for each
well. Each well-control plan must contain instructions for personnel
about the use of each well-control component of your BOP, procedures
that describe how personnel will seal the wellbore and shear pipe
before maximum anticipated surface pressure (MASP) conditions are
exceeded, assignments for each crew member, and a schedule for
completion of each assignment. You must keep a copy of your well-
control plan on the rig at all times, and make it available to BSEE
upon request. You must post a copy of the well-control plan on the rig
floor.
Sec. 250.711 What are the requirements for well-control drills?
You must conduct a weekly well-control drill with all personnel
engaged in well operations. Your drill must familiarize personnel
engaged in well operations with their roles and functions so that they
can perform their duties promptly and efficiently as outlined in the
well-control plan required by Sec. 250.710.
(a) Timing of drills. You must conduct each drill during a period
of activity that minimizes the risk to operations. The timing of your
drills must cover a range of different operations, including drilling
with a diverter, on-bottom drilling, and tripping. The same drill may
not be repeated consecutively.
(b) Recordkeeping requirements. For each drill, you must record the
following in the daily report:
(1) Date, time, and type of drill conducted;
(2) The amount of time it took to be ready to close the diverter or
use each well-control component of BOP system; and
(3) The total time to complete the entire drill.
(c) A BSEE ordered drill. A BSEE representative may require you to
conduct a well-control drill during a BSEE inspection. The BSEE
representative will consult with your onsite representative before
requiring the drill.
Sec. 250.712 What rig unit movements must I report?
(a) You must report the movement of all rig units on and off
locations to the District Manager using Form BSEE-0144, Rig Movement
Notification Report. Rig units include MODUs, platform rigs, snubbing
units, wire-line units used for non-routine operations, and coiled
tubing units. You must inform the District Manager 72 hours before:
(1) The arrival of a rig unit on location;
(2) The movement of a rig unit to another slot. For movements that
will occur less than 72 hours after initially moving onto location
(e.g., coiled tubing and batch operations), you may include your
anticipated movement schedule on Form BSEE-0144; or
(3) The departure of a rig unit from the location.
(b) You must provide the District Manager with the rig name, lease
number, well number, and expected time of arrival or departure.
(c) If a MODU or platform rig is to be warm or cold stacked, you
must inform the District Manager;
(1) Where the MODU or platform rig is coming from;
(2) The location of where the MODU or platform rig will be
positioned;
(3) Whether the MODU or platform rig will be manned or unmanned;
and
(4) If the location for stacking the MODU or platform rig changes.
(d) Prior to resuming operations after stacking, you must notify
the appropriate District Manager of any construction, repairs, or
modifications associated with the drilling package made to the MODU or
platform rig;
(e) If a drilling rig is entering OCS waters, you must inform the
District Manager where the drilling rig is coming from.
(f) If you change your anticipated date for initially moving on or
off location by more than 24 hours, you must submit an updated Form
BSEE-0144, Rig Movement Notification Report.
Sec. 250.713 What must I provide if I plan to use a mobile offshore
drilling unit (MODU) or lift boat for well operations?
If you plan to use a MODU or lift boat for well operations, you
must provide:
(a) Fitness requirements. Information and data to demonstrate the
capability to perform at the proposed location. This information must
include the most extreme environmental and operational conditions that
the unit is designed to withstand, including the minimum air gap
necessary for both hurricane and non-hurricane seasons. If sufficient
environmental information and data are not available at the time you
submit your APD or APM, the District Manager may approve your APD or
APM, but require you to collect and report this information during
operations. Under this circumstance, the District Manager has the right
to revoke the approval of the APD or APM if information collected
during operations shows that the MODU or lift boat is not capable of
performing at the proposed location.
(b) Foundation requirements. Information to show that site-specific
soil and oceanographic conditions are capable of supporting the
proposed MODU or lift boat. If you provided sufficient site-specific
information in your EP, DPP, or DOCD submitted to BOEM, you may
reference that information. The District Manager may require you to
conduct additional surveys and soil borings before approving the APD or
APM if additional information is needed to make a determination that
the conditions are capable of supporting the MODU, lift boat, or
equipment installed on a subsea wellhead. For moored rigs, you must
submit a plat of the rigs' anchor pattern approved in your EP, DPP, or
DOCD in your APD or APM.
(c) For frontier areas. (1) If the design of the MODU or lift boat
you plan to use in a frontier area is unique or has not been proven for
use in the proposed environment, the District Manager may require you
to submit a third-party review of the MODU or lift boat design. If
required, you must obtain a third-party review of your MODU or lift
boat similar to the process outlined in Sec. Sec. 250.915 through
250.918. You may submit this information before submitting an APD or
APM.
(2) If you plan to conduct operations in a frontier area, you must
have a contingency plan that addresses design and operating limitations
of the MODU or lift boat. Your plan must identify the actions necessary
to maintain safety and prevent damage to the environment. Actions must
include the suspension, curtailment, or modification of operations to
remedy various operational or environmental situations (e.g., vessel
motion, riser offset, anchor tensions, wind speed, wave height,
currents, icing or ice-loading, settling, tilt or lateral movement,
resupply capability).
(d) Additional documentation. You must provide the current
Certificate of Inspection (for US Flagged vessels) or Certificate of
Compliance (for Foreign Flagged vessels) from the USCG and Certificate
of Classification. You must also provide current documentation of any
operational limitations imposed by an appropriate classification
society.
(e) Dynamically positioned rig unit. If you use a dynamically
positioned MODU, you must include in your APD or APM your contingency
plan for
[[Page 21572]]
moving off location in an emergency situation. Your plan must include,
but not be limited to, such emergency events caused by storms,
currents, station-keeping failure, power failure, and loss of well
control. The District Manager may require your plan to include
additional events and information.
(f) Inspection of unit. The MODU or lift boat must be available for
inspection by the District Manager before commencing operations and at
any time during operations.
(g) Current Monitoring. For water depths greater than 400 meters
(1,312 feet), you must include in your APD or APM:
(1) A description of the specific current speeds that will cause
you to implement rig shutdown, move-off procedures, or both; and
(2) A discussion of the specific measures you will take to curtail
rig operations and move off location when such currents are
encountered. You may use criteria such as current velocities, riser
angles, watch circles, and remaining rig power to describe when these
procedures or measures will be implemented.
Sec. 250.714 Do I have to develop a dropped objects plan?
If you use a floating rig unit in an area with subsea
infrastructure, you must develop a dropped objects plan and make it
available to BSEE upon request. This plan must be updated as the
infrastructure on the seafloor changes. Your plan must include:
(a) A description and plot of the path the rig will take while
running and pulling the riser;
(b) A plat showing the location of any subsea wells, production
equipment, pipelines, and any other identified debris;
(c) Modeling of a dropped object's path with consideration given to
metocean conditions for various material forms, such as a tubular
(e.g., riser or casing) and box (e.g., BOP or tree);
(d) Communications, procedures, and delegated authorities
established with the production host facility to shut-in any active
subsea wells, equipment, or pipelines in the event of a dropped object;
and
(e) Any additional information required by the District Manager.
Sec. 250.715 Do I need a global positioning system (GPS) for MODUs
and jack-ups?
All jack-up and moored MODUs must have a minimum of two functioning
GPS transponders at all times, and you must provide to BSEE real-time
access to the GPS data prior to each hurricane season.
(a) The GPS must be capable of monitoring the position and tracking
the path in real-time if the moored MODU or jack-up moves from its
location during a severe storm.
(b) You must install and protect the tracking system's equipment to
minimize the risk of the system being disabled.
(c) You must place the GPS transponders in different locations for
redundancy to minimize risk of system failure.
(d) Each GPS transponder must be capable of transmitting data for
at least 7 days after a storm has passed.
(e) If the MODU is moved off location in the event of a storm, you
must immediately begin to record the GPS location data.
(f) Contact the Regional Office and allow real-time access to the
MODU or jack-up location data. When you contact the Regional Office,
provide the following:
(1) Name of the lessee and operator with contact information;
(2) Rig/facility/platform name;
(3) Initial date and time; and
(4) How you will provide GPS real-time access.
Well Operations
Sec. 250.720 When and how must I secure a well?
(a) Whenever you interrupt operations, you must notify the District
Manager. Before moving off the well, you must have two independent
barriers installed, at least one of which must be a mechanical barrier,
as approved by the District Manager. You must install the barriers at
appropriate depths within a properly cemented casing string or liner.
Before removing a subsea BOP stack or surface BOP stack on a mudline
suspension well, you must conduct a negative pressure test in
accordance with Sec. 250.721.
(1) The events that would cause you to interrupt operations and
notify the District Manager include, but are not limited to, the
following:
(i) Evacuation of the rig crew;
(ii) Inability to keep the rig on location;
(iii) Repair to major rig or well-control equipment; or
(iv) Observed flow outside the well's casing (e.g., shallow water
flow or bubbling).
(2) The District Manager may approve alternate procedures or
barriers in accordance with Sec. 250.141 if you do not have time to
install the required barriers or if special circumstances occur.
(b) Before you displace kill-weight fluid from the wellbore and/or
riser, thereby creating an underbalanced state, you must obtain
approval from the BSEE District Manager. To obtain approval, you must
submit with your APD or APM your reasons for displacing the kill-weight
fluid and provide detailed step-by-step written procedures describing
how you will safely displace these fluids. The step-by-step
displacement procedures must address the following:
(1) Number and type of independent barriers, as described in Sec.
250.420(b)(3), that are in place for each flow path that requires such
barriers,
(2) Tests you will conduct to ensure integrity of independent
barriers,
(3) BOP procedures you will use while displacing kill-weight
fluids, and
(4) Procedures you will use to monitor the volumes and rates of
fluids entering and leaving the wellbore.
Sec. 250.721 What are the requirements for pressure testing casing
and liners?
(a) You must test each casing string that extends to the wellhead
according to the following table:
------------------------------------------------------------------------
Casing type Minimum test pressure
------------------------------------------------------------------------
(1) Drive or Structural,............... Not required.
(2) Conductor, excluding subsea 250 psi.
wellheads..
(3) Surface, Intermediate, and 70 percent of its minimum
Production,. internal yield.
------------------------------------------------------------------------
(b) You must test each drilling liner and liner-lap to a pressure
at least equal to the anticipated leak off pressure of the formation
below that liner shoe, or subsequent liner shoes if set. You must
conduct this test before you continue operations in the well.
(c) You must test each production liner and liner-lap to a minimum
of 500 psi above the formation fracture pressure at the casing shoe
into which the liner is lapped.
(d) The District Manager may approve or require other casing test
pressures.
[[Page 21573]]
(e) If you plan to produce a well, you must:
(1) For a well that is fully cased and cemented, pressure test the
entire well to maximum anticipated shut-in tubing pressure before
perforating the casing or liner; or
(2) For an open-hole completion, pressure test the entire well to
maximum anticipated shut-in tubing pressure before you drill the open-
hole section.
(f) You may not resume operations until you obtain a satisfactory
pressure test. If the pressure declines more than 10 percent in a 30-
minute test, or if there is another indication of a leak, you must
submit to the District Manager for approval your proposed plans to re-
cement, repair the casing or liner, or run additional casing/liner to
provide a proper seal. Your submittal must include a PE certification
of your proposed plans.
(g) You must perform a negative pressure test on all wells that use
a subsea BOP stack or wells with mudline suspension systems.
(1) You must perform a negative pressure test on your final casing
string or liner. This test must be conducted after setting your second
barrier just above the shoe track, but prior to conducting any
completion operations.
(2) You must perform a negative test prior to unlatching the BOP at
any point in the well. The negative test must be performed on those
components, at a minimum, that will be exposed to the negative
differential pressure that will occur when the BOP is disconnected.
(3) The District Manager may require you to perform additional
negative pressure tests on other casing strings or liners (e.g.,
intermediate casing string or liner) or on wells with a surface BOP
stack.
(4) You must submit for approval with your APD or APM, test
procedures and criteria for a successful negative test. If any of your
test procedures or criteria for a successful test change, you must
submit for approval the changes in a revised APD or APM.
(5) You must document all your test results and make them available
to BSEE upon request.
(6) If you have any indication of a failed negative pressure test,
such as, but not limited to, pressure buildup or observed flow, you
must immediately investigate the cause. If your investigation confirms
that a failure occurred during the negative pressure test, you must:
(i) Correct the problem and immediately notify the appropriate BSEE
District Manager; and
(ii) Submit a description of the corrective action taken and
receive approval from the appropriate BSEE District Manager for the
retest.
(7) You must have two barriers in place, as described in Sec.
250.420(b)(3), at any time and for any well, prior to performing the
negative pressure test.
(8) You must include documentation of the successful negative
pressure test in the End-of-Operations Report (Form BSEE-0125).
Sec. 250.722 What are the requirements for prolonged operations in a
well?
If wellbore operations continue within a casing or liner for more
than 30 days from the previous pressure test of the well's casing or
liner, you must:
(a) Stop operations as soon as practicable, and evaluate the
effects of the prolonged operations on continued operations and the
life of the well. At a minimum, you must:
(1) Evaluate the well's casing with either a pressure test, caliper
tool, or imaging tool. On a case-by-case basis the District Manager may
require a specific method of evaluation; and
(2) Report the results of your evaluation to the District Manager
and obtain approval of those results before resuming operations. Your
report must include calculations that show the well's integrity is
above the minimum safety factors.
(b) If well integrity has deteriorated to a level below minimum
safety factors, you must:
(1) Obtain approval from the District Manager to begin repairs or
install additional casing. To obtain approval, you must also provide a
PE certification showing that he or she reviewed and approved the
proposed changes;
(2) Repair the casing or run another casing string; and
(3) Perform a pressure test after the repairs are made or
additional casing is installed and report the results to the District
Manager as specified in Sec. 250.721.
Sec. 250.723 What additional safety measures must I take when I
conduct operations on a platform that has producing wells or has other
hydrocarbon flow?
You must take the following safety measures when you conduct
operations with a rig unit or lift boat on or jacked-up over a platform
with producing wells or that has other hydrocarbon flow:
(a) The movement of rig units and related equipment on and off a
platform or from well to well on the same platform, including rigging
up and rigging down, must be conducted in a safe manner;
(b) You must install an emergency shutdown station for the
production system near the rig operator's console;
(c) You must shut-in all producible wells located in the affected
wellbay below the surface and at the wellhead when:
(1) You move a rig unit or related equipment on and off a platform.
This includes rigging up and rigging down activities within 500 feet of
the affected platform;
(2) You move or skid a rig unit between wells on a platform; or
(3) A MODU or lift boat moves within 500 feet of a platform. You
may resume production once the MODU or lift boat is in place, secured,
and ready to begin operations.
(d) All wells in the same well-bay which are capable of producing
hydrocarbons must be shut-in below the surface with a pump-through-type
tubing plug and at the surface with a closed master valve prior to
moving rig units and related equipment unless otherwise approved by the
District Manager.
(1) A closed surface-controlled subsurface safety valve of the
pump-through-type may be used in lieu of the pump-through-type tubing
plug provided that the surface control has been locked out of
operation.
(2) The well to which a rig unit or related equipment is to be
moved must be equipped with a back-pressure valve prior to removing the
tree and installing and testing the BOP system.
(3) The well from which a rig unit or related equipment is to be
moved must be equipped with a back pressure valve prior to removing the
BOP system and installing the production tree.
(e) Coiled tubing units, snubbing units, or wireline units may be
moved onto and off of a platform without shutting in wells.
Sec. 250.724 What are the real-time monitoring requirements?
(a) When conducting well operations with a subsea BOP or surface
BOP on a floating facility or when operating in an HPHT environment you
must, within 3 years of publication of the final rule, gather and
monitor real-time well data using an independent, automatic, and
continuous monitoring system capable of recording, storing, and
transmitting all aspects of:
(1) The BOP control system;
(2) The well's fluid handling systems on the rig; and
(3) The well's downhole conditions with the bottom hole assembly
tools (if any tools are installed).
(b) You must immediately transmit these data as they are gathered
to a
[[Page 21574]]
designated onshore location during operations where they must be
monitored by qualified personnel who must be in continuous contact with
rig personnel during operations. After operations, you must preserve
and store this data at a designated location for recordkeeping purposes
as required in Sec. Sec. 250.740 and 250.741. You must designate the
location where the data will be stored and monitored during operations
in your APD or APM. The location and the data must be made accessible
to BSEE upon request.
(c) If you lose any real-time monitoring capability during
operations covered by this section, you must immediately notify the
District Manager. The District Manager may require other measures until
real-time monitoring capability is restored.
Blowout Preventer (BOP) System Requirements
Sec. 250.730 What are the general requirements for BOP systems and
system components?
(a) You must design, install, maintain, inspect, test, and use the
BOP system and system components to ensure well control. The working-
pressure rating of each BOP component must exceed MASP as defined for
the operation. For a subsea BOP, the MASP must be taken at the mudline.
The BOP system includes the BOP stack, control system, and any other
associated system(s) and equipment. The BOP system and individual
components must be able to perform their expected functions and be
compatible with each other. Each ram (excluding casing shear/
supershear) must be capable of closing and sealing the wellbore at all
times, including under flowing conditions as defined for the operation
and specific well conditions, without losing ram closure time and
sealing integrity due to the corrosiveness, volume, and abrasiveness of
any fluids in the wellbore that you may encounter. Your BOP system must
meet the following requirements:
(1) The BOP requirements of API Standard 53 (incorporated by
reference in Sec. 250.198) and the requirements of Sec. Sec. 250.733
through 250.739. If there is a conflict between API Standard 53 and the
requirements of this subpart, you must follow the requirements of this
subpart.
(2) The following industry standards (all incorporated by reference
in Sec. 250.198):
(i) ANSI/API Spec. 6A;
(ii) ANSI/API Spec. 16A;
(iii) ANSI/API Spec. 16C;
(iv) API Spec. 16D; and
(v) ANSI/API Spec. 17D.
(3) For surface and subsea BOPs, the pipe and variable bore rams
installed in the BOP stack must be capable of effectively closing and
sealing on the tubular body of any drill pipe, workstring, and tubing
in the hole under MASP, as defined for the operation, with the proposed
regulator settings of the BOP control system.
(4) The current set of approved schematic drawings must be
available on the rig and at an onshore location. If you make any
modifications to the BOP or control system that will change your BSEE-
approved schematic drawings, you must suspend operations until you
obtain approval from the District Manager.
(b) You must design, fabricate, maintain, and repair your BOP
system according to the requirements contained in this subpart, OEM
recommendations unless otherwise directed by BSEE, and recognized
engineering practices. The training and qualification of repair and
maintenance personnel must meet or exceed any OEM training
recommendations unless otherwise directed by BSEE.
(c) You must follow the failure reporting procedures contained in
API Standard 53, ANSI/API Spec. 6A, and ANSI/API Spec 16A, and:
(1) You must provide a written report of equipment failure to the
manufacturer of such equipment within 30 days after the discovery and
identification of the failure.
(2) You must ensure that an investigation and a failure analysis
are initiated within 60 days of the failure to determine the cause of
the failure. If the investigation and analysis are performed by an
entity other than the manufacturer, you must ensure that the
manufacturer receives a copy of the analysis.
(3) If the equipment manufacturer notifies you that it has changed
the design of the equipment that failed, or if you have changed
operating or repair procedures as a result of a failure, then you must,
within 30 days of such notice or change, report the design change or
modified procedures in writing to the Chief, Office of Offshore
Regulatory Programs; Bureau of Safety and Environmental Enforcement; HE
3314; 45600 Woodland Road, Sterling, Virginia 20166.
(d) If you plan to use a BOP stack manufactured after the effective
date of this regulation, you must use one manufactured pursuant to an
API Spec. Q1 (as incorporated by reference in Sec. 250.198) quality
management system. Such quality management system must be certified by
an entity that meets the requirements of ISO 17011.
(1) The BSEE may consider accepting equipment manufactured under
quality assurance programs other than API Spec. Q1, provided you submit
a request to BSEE containing relevant information about the alternative
program and receive BSEE approval under Sec. 250.141.
(2) You must submit this request to the Chief, Office of Offshore
Regulatory Programs; Bureau of Safety and Environmental Enforcement; HE
3314: 45600 Woodland Road, Sterling, Virginia 20166.
Sec. 250.731 What information must I submit for BOP systems and
system components?
For any operation that requires the use of a BOP, you must include
the information listed in this section with your applicable APD, APM,
or other submittal. You are required to submit this information only
once for each well, unless the information changes from what you
provided in an earlier approved submission or you have moved off
location from the well. After you have submitted this information for a
particular well, subsequent APMs or other submittals for the well
should reference the approved submittal containing the information
required by this section and confirm that the information remains
accurate and that you have not moved off location from that well. If
the information changes or you have moved off location from the well,
you must submit updated information in your next submission.
------------------------------------------------------------------------
You must submit: Including:
------------------------------------------------------------------------
(a) A complete description of the BOP (1) Pressure ratings of BOP
system and system components, equipment;
(2) Proposed BOP test pressures
(for subsea BOPs, include both
surface and corresponding
subsea pressures);
(3) Rated capacities for liquid
and gas for the fluid-gas
separator system;
(4) Control fluid volumes
needed to close, seal, and
open each component;
[[Page 21575]]
(5) Control system pressure and
regulator settings needed to
achieve an effective seal of
each ram BOP under MASP as
defined for the operation;
(6) Number and volume of
accumulator bottles and bottle
banks (for subsea BOP, include
both surface and subsea
bottles);
(7) Accumulator pre-charge
calculations (for subsea BOP,
include both surface and
subsea calculations);
(8) All locking devices; and
(9) Control fluid volume
calculations for the
accumulator system (for a
subsea BOP system, include
both the surface and subsea
volumes).
(b) Schematic drawings,................ (1) The inside diameter of the
BOP stack,
(2) Number and type of
preventers (including blade
type for shear ram(s)),
(3) All locking devices,
(4) Size range for variable
bore ram(s),
(5) Size of fixed ram(s),
(6) All control systems with
all alarms and set points
labeled, including pods,
(7) Location and size of choke
and kill lines (and gas bleed
line(s) for subsea BOP),
(8) Associated valves of the
BOP system,
(9) Control station locations,
and
(10) A cross-section of the
riser for a subsea BOP system
showing number, size, and
labeling of all control,
supply, choke, and kill lines
down to the BOP.
(c) Certification by a BSEE-approved Verification that:
verification organization,
(1) Test data clearly
demonstrates the shear ram(s)
will shear the drill pipe at
the water depth as required in
Sec. 250.732;
(2) The BOP was designed,
tested, and maintained to
perform at the most extreme
anticipated conditions; and
(3) The accumulator system has
sufficient fluid to function
the BOP system without
assistance from the charging
system.
(d) Additional certification by a BSEE- Verification that:
approved verification organization, if
you use a subsea BOP, a BOP in an HPHT
environment as defined in Sec.
250.807, or a surface BOP on a
floating facility,
(1) The BOP stack is designed
for the specific equipment on
the rig and for the specific
well design;
(2) The BOP stack has not been
compromised or damaged from
previous service; and
(3) The BOP stack will operate
in the conditions in which it
will be used.
(e) If you are using a subsea BOP, A listing of the functions with
descriptions of autoshear, deadman, their sequences and timing.
and emergency disconnect sequence
(EDS) systems,
(f) Certification stating that the ...............................
Mechanical Integrity Assessment Report
required in Sec. 250.732(d) has been
submitted within the past 12 months
for a subsea BOP, a BOP being used in
an HPHT environment as defined in Sec.
250.807, or a surface BOP on a
floating facility.
------------------------------------------------------------------------
Sec. 250.732 What are the BSEE-approved verification organization
requirements for BOP systems and system components?
(a) The BSEE will maintain a list of BSEE-approved verification
organizations that you may use. For an organization to become a BSEE
approved verification organization, it must submit the following
information to the Chief, Office of Regulatory Programs: Bureau of
Safety and Environmental Enforcement: 45600 Woodland Road, Sterling,
Virginia, 20166, for BSEE review and approval:
(1) Previous experience in verification or in the design,
fabrication, installation, repair, or major modification of BOPs and
related systems and equipment;
(2) Technical capabilities;
(3) Size and type of organization;
(4) In-house availability of, or access to, appropriate technology.
This should include computer programs, hardware, and testing materials
and equipment;
(5) Ability to perform the verification functions for projects
considering current commitments;
(6) Previous experience with BSEE requirements and procedures; and
(7) Any additional information that may be relevant to BSEE's
review.
(b) Prior to beginning any operation requiring the use of any BOP,
you must submit verification by a BSEE-approved verification
organization and supporting documentation as required by this paragraph
to the appropriate District Manager and Regional Supervisor.
------------------------------------------------------------------------
You must submit verification and
documentation related to: That:
------------------------------------------------------------------------
(1) Shear testing,..................... (i) Demonstrates that the BOP
will shear the drill pipe and
any electric-, wire-, and
slick-line to be used in the
well;
[[Page 21576]]
(ii) Demonstrates the use of
test protocols and analysis
that represent recognized
engineering practices for
ensuring the repeatability and
reproducibility of the tests,
and that the testing was
performed by a facility that
meets generally accepted
quality assurance standards;
(iii) Provides a reasonable
representation of field
applications, taking into
consideration the physical and
mechanical properties of the
drill pipe;
(iv) Ensures testing was
performed on the outermost
edges of the shearing blades
of the positioning mechanism
as required in Sec.
250.734(a)(16);
(v) Demonstrates the shearing
capacity of the BOP equipment
to the physical and mechanical
properties of the drill pipe;
and
(vi) Includes all testing
results.
(2) Pressure integrity testing, and.... (i) Shows that testing is
conducted immediately after
the shearing tests;
(ii) Demonstrates that the
equipment will seal at the
rated working pressure of the
BOP for 30 minutes; and
(iii) Includes all test
results.
(3) Calculations....................... Include shearing and sealing
pressures for all pipe to be
used in the well including
corrections for MASP.
------------------------------------------------------------------------
(c) For wells in an HPHT environment, as defined by Sec.
250.807(b), you must submit verification by a BSEE-approved
verification organization that the verification organization conducted
a comprehensive review of the BOP system and related equipment you
propose to use. You must provide the BSEE-approved verification
organization access to any facility associated with the BOP system or
related equipment during the review process. You must submit the
verifications required by this paragraph to the appropriate District
Manager and Regional Supervisor before you begin any operations in an
HPHT environment with the proposed equipment.
------------------------------------------------------------------------
You must submit: Including:
------------------------------------------------------------------------
(1) Verification that the verification ...............................
organization conducted a detailed
review of the design package to ensure
that all critical components and
systems meet recognized engineering
practices,
(2) Verification that the designs of (i) Identification of all
individual components and the overall reasonable potential modes of
system have been proven in a testing failure, and
process that demonstrates the (ii) Evaluation of the design
performance and reliability of the verification tests. The design
equipment in a manner that is verification tests must assess
repeatable and reproducible, the equipment for the
identified potential modes of
failure.
(3) Verification that the BOP equipment ...............................
will perform as designed in the
temperature, pressure, and environment
that will be encountered, and
(4) Verification that the fabrication, For the quality control and
manufacture, and assembly of assurance mechanisms, complete
individual components and the overall material and quality controls
system uses recognized engineering over all contractors,
practices and quality control and subcontractors, distributors,
assurance mechanisms. and suppliers at every stage
in the fabrication,
manufacture, and assembly
process.
------------------------------------------------------------------------
(d) Once every 12 months, you must submit a Mechanical Integrity
Assessment Report for a subsea BOP, a BOP being used in an HPHT
environment as defined in Sec. 250.807, or a surface BOP on a floating
facility. This report must be completed by a BSEE-approved verification
organization. You must submit this report to the Chief, Office of
Regulatory Programs: Bureau of Safety and Environmental Enforcement:
45600 Woodland Road, Sterling, Virginia, 20166. This report must
include:
(1) A determination that the BOP stack and system meets or exceeds
all BSEE regulatory requirements, industry standards incorporated into
this subpart, and recognized engineering practices.
(2) Verification that complete documentation of the equipment's
service life exists that demonstrates that the BOP stack has not been
compromised or damaged during previous service.
(3) A description of all inspection, repair and maintenance records
reviewed, and verification that all repairs, replacement parts, and
maintenance meet regulatory requirements, recognized engineering
practices, and OEM specifications.
(4) A description of records reviewed related to any modifications
to the equipment and verification that any such changes do not
adversely affect the equipment's capability to perform as designed or
invalidate test results.
(5) A description of the Safety and Environmental Management
Systems (SEMS) plans reviewed related to assurance of quality and
mechanical integrity of critical equipment and verification that the
plans are comprehensive and fully implemented.
(6) Verification that the qualification and training of inspection,
repair, and maintenance personnel for the BOP systems meet recognized
engineering practices and OEM requirements.
(7) A description of all records reviewed covering OEM safety
alerts, all failure reports, and verification that any design or
maintenance issues have been completely identified and corrected.
(8) A comprehensive assessment of the overall system and
verification that all components (including mechanical, hydraulic,
electrical, and software) are compatible.
(9) Verification that documentation exists concerning the
traceability of the fabrication, repair, and maintenance of all
critical components.
[[Page 21577]]
(10) Verification of use of a formal maintenance tracking system to
ensure that corrective maintenance and scheduled maintenance is
implemented in a timely manner.
(11) Identification of gaps or deficiencies related to inspection
and maintenance procedures and documentation, documentation of any
deferred maintenance, and verification of the completion of corrective
action plans.
(12) Verification that any inspection, maintenance, or repair work
meets the manufacturer's design and material specifications.
(13) Verification of written procedures for operating the BOP stack
and LMRP (including proper techniques to prevent accidental
disconnection of these components) and minimum knowledge requirements
for personnel authorized to operate and maintain BOP components.
(14) Recommendations, if any, for how to improve the fabrication,
installation, operation, maintenance, inspection, and repair of the
equipment.
(e) You must make all documentation that supports the requirements
of this section available to BSEE upon request.
Sec. 250.733 What are the requirements for a surface BOP stack?
(a) When you drill or conduct operations with a surface BOP stack,
you must install the BOP system before drilling or conducting
operations to deepen the well below the surface casing and after the
well is deepened below the surface casing point. The surface BOP stack
must include at least four remote-controlled, hydraulically operated
BOPs, consisting of one annular BOP, one BOP equipped with blind-shear
rams, and two BOPs equipped with pipe rams.
(1) The blind-shear rams must be capable of shearing at any point
along the tubular body of any drill pipe (excluding tool joints,
bottom-hole tools, and bottom hole assemblies that include heavy-weight
pipe or collars), workstring, tubing, and any electric-, wire-, and
slick-line that is in the hole and sealing the wellbore after shearing.
If your blind-shear rams are unable to cut any electric-, wire-, or
slick-line under MASP as defined for the operation and seal the
wellbore, you must use an alternative cutting device capable of
shearing the lines before closing the BOP. This device must be
available on the rig floor during operations that require their use.
(2) The two BOPs equipped with pipe rams must be capable of closing
and sealing on the tubular body of any drill pipe, workstring, and
tubing under MASP, as defined for the operation, excluding the bottom
hole assembly that includes heavy-weight pipe or collars, and bottom-
hole tools.
(b) If you plan to use a surface BOP on a floating production
facility you must:
(1) Follow the BOP requirements in Sec. 250.734(a)(1). You must
comply with this requirement within 5 years from the publication of the
final rule.
(2) Use a dual bore riser configuration, for risers installed after
the effective date of this rule, before drilling or operating in any
hole section or interval where hydrocarbons are, or may be, exposed to
the well. The dual bore riser must meet the design requirements of API
RP 2RD (as incorporated by reference in Sec. 250.198) including
appropriate design for the most extreme anticipated operating and
environmental conditions.
(i) For a dual bore riser configuration, the annulus between the
risers must be monitored during operations. You must describe in your
APD or APM your annulus monitoring plan and how you will secure the
well in the event a leak is detected.
(ii) The inner riser for a dual riser configuration is subject to
the requirements for testing the casing or liner at Sec. 250.721.
(c) You must install separate side outlets on the BOP stack for the
kill and choke lines. If your stack does not have side outlets, you
must install a drilling spool with side outlets. The outlet valves must
hold pressure from both directions.
(d) You must install a choke and a kill line on the BOP stack. You
must equip each line with two full-bore, full-opening valves, one of
which must be remote-controlled. On the kill line, you may install a
check valve and a manual valve instead of the remote-controlled valve.
To use this configuration, both manual valves must be readily
accessible and you must install the check valve between the manual
valves and the pump.
(e) You must install hydraulically operated locks.
(f) For a surface BOP used in HPHT environments, if operations are
suspended to make repairs to any part of the BOP system, you must stop
operations at a safe downhole location. Before resuming operations you
must:
(1) Submit a revised APD or APM including documentation of the
repairs and a certification from a BSEE-approved verification
organization stating that they reviewed the repairs, and that the BOP
is fit for service; and
(2) Receive approval from the District Manager.
Sec. 250.734 What are the requirements for a subsea BOP system?
(a) When you drill or conduct operations with a subsea BOP system,
you must install the BOP system before drilling to deepen the well
below the surface casing or conducting operations if the well is
already deepened beyond the surface casing point. The District Manager
may require you to install a subsea BOP system before drilling or
conducting operations below the conductor casing if proposed casing
setting depths or local geology indicate the need. The following table
outlines your requirements.
------------------------------------------------------------------------
When operating with a subsea BOP
system, you must: Additional requirements
------------------------------------------------------------------------
(1) Have at least five remote- You must have at least one
controlled, hydraulically operated annular BOP, two BOPs equipped
BOPs; with pipe rams, and two BOPs
equipped with shear rams. For
the two shear ram requirement,
you must comply with this
requirement within 5 years
from the publication of the
final rule.
(i) Both BOPs equipped with
pipe rams must be capable of
closing and sealing on the
tubular body of any drill
pipe, workstring, and tubing
under MASP, as defined for the
operation, excluding the
bottom hole assembly that
includes heavy-weight pipe or
collars, and bottom-hole
tools.
[[Page 21578]]
(ii) Both shear rams must be
capable of shearing at any
point along the tubular body
of any drill pipe (excluding
tool joints, bottom-hole
tools, and bottom hole
assemblies that includes heavy-
weight pipe or collars),
workstring, tubing,
appropriate area for the liner
or casing landing string,
shear sub on subsea test tree,
and any electric-, wire-,
slick-line in the hole under
MASP. At least one shear ram
must be capable of sealing the
wellbore after shearing under
MASP conditions as defined for
the operation. Any non-sealing
shear rams must be installed
below the sealing shear rams.
(2) Have an operable dual-pod control ...............................
system to ensure proper and
independent operation of the BOP
system;
(3) Have the accumulator capacity The accumulator capacity must:
located subsea, to provide fast (i) Function each required
closure of the BOP components and to shear ram, choke and kill side
operate all critical functions in case outlet valves, one pipe ram,
of a loss of the power fluid and disconnect the LMRP.
connection to the surface;
(ii) Have the capability of
delivering fluid to each ROV
function i.e., flying leads.
(iii) Have dedicated
independent bottles for the
autoshear, deadman, and EDS
systems.
(iv) Perform under MASP
conditions as defined for the
operation.
(4) Have a subsea BOP stack equipped The ROV must be capable of
with remotely operated vehicle (ROV) performing critical functions,
intervention capability; including opening and closing
each shear ram, choke and kill
side outlet valves, all pipe
rams, and LMRP disconnect
under MASP conditions as
defined for the operation. The
ROV panels on the BOP and LMRP
must be compliant with API RP
17H (as incorporated by
reference in Sec. 250.198).
(5) Maintain an ROV and have a trained The crew must be trained in the
ROV crew on each rig unit on a operation of the ROV. The
continuous basis once BOP deployment training must include
has been initiated from the rig until simulator training on stabbing
recovered to the surface. The crew into an ROV intervention panel
must examine all ROV related well- on a subsea BOP stack. The ROV
control equipment (both surface and crew must be in communication
subsea) to ensure that it is properly with designated rig personnel
maintained and capable of shutting in who are knowledgeable about
the well during emergency operations; the BOP's capabilities.
(6) Provide autoshear, deadman, and EDS (i) Autoshear system means a
systems for dynamically positioned safety system that is designed
rigs; provide autoshear and deadman to automatically shut-in the
systems for moored rigs; wellbore in the event of a
disconnect of the LMRP. This
is considered a rapid
discharge system.
(ii) Deadman system means a
safety system that is designed
to automatically shut-in the
wellbore in the event of a
simultaneous absence of
hydraulic supply and signal
transmission capacity in both
subsea control pods. This is
considered a rapid discharge
system.
(iii) Emergency Disconnect
Sequence (EDS) system means a
safety system that is designed
to be manually activated to
shut-in the wellbore and
disconnect the LMRP in the
event of an emergency
situation. This is considered
a rapid discharge system.
(iv) Each emergency function
must close at a minimum, two
shear rams in sequence and be
capable of performing their
expected shearing and sealing
action under MASP conditions
as defined for the operation.
(v) Your sequencing must allow
a sufficient delay for closing
the upper shear ram after
beginning closure of the lower
shear ram to provide for
maximum shearing efficiency.
(vi) The control system for the
emergency functions must be a
fail-safe design, and the
logic must provide for the
subsequent step to be
independent from the previous
step having to be completed.
(7) Demonstrate that any acoustic If you choose to install an
control system will function in the acoustic control system in
proposed environment and conditions; addition to the autoshear,
deadman, and EDS requirements,
you must demonstrate to the
District Manager, as part of
the information submitted
under Sec. 250.731, that the
acoustic system will function
in the proposed environment
and conditions. The District
Manager may require additional
information.
(8) Have operational or physical Incorporate enable buttons on
barrier(s) on BOP control panels to control panels to ensure two-
prevent accidental disconnect handed operation for all
functions; critical functions.
(9) Clearly label all control panels Label other BOP control panels
for the subsea BOP system; such as hydraulic control
panel.
(10) Develop and use a management The management system must
system for operating the BOP system, include written procedures for
including the prevention of accidental operating the BOP stack and
or unplanned disconnects of the LMRP (including proper
system; techniques to prevent
accidental disconnection of
these components) and minimum
knowledge requirements for
personnel authorized to
operate and maintain BOP
components.
(11) Establish minimum requirements for Personnel must have:
personnel authorized to operate (i) Training in deepwater well-
critical BOP equipment; control theory and practice
according to the requirements
of Subpart O; and
(ii) A comprehensive knowledge
of BOP hardware and control
systems.
[[Page 21579]]
(12) Before removing the marine riser, You must maintain sufficient
displace the fluid in the riser with hydrostatic pressure or take
seawater; other suitable precautions to
compensate for the reduction
in pressure and to maintain a
safe and controlled well
condition. You must follow the
requirements of Sec.
250.720(b).
(13) Install the BOP stack in a well Your well cellar must be deep
cellar when in an ice-scour area; enough to ensure that the top
of the stack is below the
deepest probable ice-scour
depth.
(14) Install at least two side outlets (i) If your stack does not have
for a choke line and two side outlets side outlets, you must install
for a kill line; a drilling spool with side
outlets.
(ii) Each side outlet must have
two full-bore, full-opening
valves.
(iii) The valves must hold
pressure from both directions
and must be remote-controlled.
(iv) You must install a side
outlet below each sealing
shear ram. You may have a pipe
ram or rams between the
shearing ram and side outlet.
(15) Install a gas bleed line with two (i) The valves must hold
valves for the annular preventer;. pressure from both directions;
(ii) If you have dual annulars,
where one annular is on the
LMRP and one annular is on the
lower BOP stack, you must
install a gas bleed line on
each annular.
(16) Use a BOP system that has the (i) A mechanism coupled with
following mechanisms and capabilities: each shear ram to position the
entire pipe, including
connection, completely within
the area of the shearing blade
and ensure shearing will occur
any time the shear rams are
activated. This mechanism
cannot be another ram BOP or
annular preventer, but you may
use those during a planned
shear. You must install this
mechanism within 7 years from
the publication of the final
rule;
(ii) The ability to mitigate
compression of the pipe stub
between the shearing rams when
both shear rams are closed;
(iii) If your control pods
contain a subsea electronic
module with batteries, a
mechanism for personnel on the
rig to monitor the state of
charge of the subsea
electronic module batteries in
the BOP control pods.
------------------------------------------------------------------------
(b) If operations are suspended to make repairs to any part of the
subsea BOP system, you must stop operations at a safe downhole
location. Before resuming operations you must:
(1) Submit a revised permit with a verification report from a BSEE-
approved verification organization documenting the repairs and that the
BOP is fit for service;
(2) Perform a new BOP test in accordance with Sec. Sec. 250.737
and 250.738 upon relatch including deadman and ROV intervention; and
(3) Receive approval from the District Manager.
(c) If you plan to drill a new well with a subsea BOP, you do not
need to submit with your APD the verifications required by this subpart
for the open water drilling operation. Before drilling out the surface
casing, you must submit for approval a revised APD, including the
verifications required in this subpart.
Sec. 250.735 What associated systems and related equipment must all
BOP systems include?
All BOP systems must include the following associated systems and
related equipment:
(a) A surface accumulator system that provides 1.5 times the volume
of fluid capacity necessary to close and hold closed all BOP components
against MASP. The system must operate under MASP conditions as defined
for the operation. You must be able to operate all BOP functions
without assistance from a charging system, with the blind shear ram
being the last in the sequence, and still have enough pressure to shear
pipe and seal the well with a minimum pressure of 200 psi remaining on
the bottles above the precharge pressure. If you supply the accumulator
regulators by rig air and do not have a secondary source of pneumatic
supply, you must equip the regulators with manual overrides or other
devices to ensure capability of hydraulic operations if rig air is
lost;
(b) An automatic backup to the primary accumulator-charging system.
The power source must be independent from the power source for the
primary accumulator-charging system. The independent power source must
possess sufficient capability to close and hold closed all BOP
components under MASP conditions as defined for the operation;
(c) At least two full BOP control stations. One station must be on
the rig floor. You must locate the other station in a readily
accessible location away from the rig floor;
(d) The choke line(s) installed above the bottom well-control ram;
(e) The kill line that may be installed below the bottom ram, but
it must be installed beneath at least one pipe ram;
(f) A fill-up line above the uppermost BOP;
(g) Hydraulically operated locking devices installed on the sealing
ram-type BOPs; and
(h) A wellhead assembly with a rated working pressure that exceeds
the maximum anticipated wellhead pressure.
Sec. 250.736 What are the requirements for choke manifolds, kelly
valves, inside BOPs, and drill string safety valves?
(a) Your BOP system must include a choke manifold that is suitable
for the anticipated surface pressures, anticipated methods of well
control, the surrounding environment, and the corrosiveness, volume,
and abrasiveness of drilling fluids and well fluids that you may
encounter.
(b) Choke manifold components must have a rated working pressure at
least as great as the rated working pressure of the ram BOPs. If your
choke manifold has buffer tanks downstream of choke assemblies, you
must install isolation valves on any bleed lines.
(c) Valves, pipes, flexible steel hoses, and other fittings
upstream of the choke manifold must have a rated working pressure at
least as great as the rated working pressure of the ram BOPs.
(d) You must use the following BOP equipment with a rated working
pressure and temperature of at least as great as the working pressure
and
[[Page 21580]]
temperature of the ram BOP during all operations:
(1) A kelly valve installed below the swivel (upper kelly valve);
(2) A kelly valve installed at the bottom of the kelly (lower kelly
valve). You must be able to strip the lower kelly valve through the BOP
stack;
(3) If you operate with a mud motor and use drill pipe instead of a
kelly, one kelly valve installed above, and one strippable kelly valve
installed below, the joint of pipe used in place of a kelly;
(4) On a top-drive system equipped with a remote-controlled valve,
a strippable kelly-type valve installed below the remote-controlled
valve;
(5) An inside BOP in the open position located on the rig floor.
You must be able to install an inside BOP for each size connection in
the pipe;
(6) A drill string safety valve in the open position located on the
rig floor. You must have a drill-string safety valve available for each
size connection in the pipe;
(7) When running casing, a safety valve in the open position
available on the rig floor to fit the casing string being run in the
hole;
(8) All required manual and remote-controlled kelly valves, drill-
string safety valves, and comparable-type valves (i.e., kelly-type
valve in a top-drive system) that are essentially full opening; and
(9) A wrench to fit each manual valve. Each wrench must be readily
accessible to the drilling crew.
Sec. 250.737 What are the BOP system testing requirements?
Your BOP system (this includes the choke manifold, kelly valves,
inside BOP, and drill string safety valve) must meet the following
testing requirements:
(a) Pressure test frequency. You must pressure test your BOP
system:
(1) When installed;
(2) Before 14 days have elapsed since your last BOP pressure test,
or 30 days since your last blind-shear ram BOP pressure test. You must
begin to test your BOP system before midnight on the 14th day (or 30th
day for your blind-shear rams) following the conclusion of the previous
test;
(3) Before drilling out each string of casing or a liner. You may
omit this pressure test requirement if you did not remove the BOP stack
to run the casing string or liner, the required BOP test pressures for
the next section of the hole are not greater than the test pressures
for the previous BOP test, and the time elapsed between tests has not
exceeded 14 days (or 30 days for blind-shear rams). You must indicate
in your APD which casing strings and liners meet these criteria;
(4) The District Manager may require more frequent testing if
conditions or your BOP performance warrants.
(b) Pressure test procedures. When you pressure test the BOP
system, you must conduct a low-pressure test and a high-pressure test
for each BOP component. You must begin each test by conducting the low-
pressure test then transition to the high-pressure test. Each
individual pressure test must hold pressure long enough to demonstrate
the tested component(s) holds the required pressure. The table in this
paragraph outlines your pressure test requirements.
------------------------------------------------------------------------
According to the following
You must conduct a . . . procedures . . .
------------------------------------------------------------------------
(1) Low-pressure test.................. All low-pressure tests must be
between 250 and 350 psi. Any
initial pressure above 350 psi
must be bled back to a
pressure between 250 and 350
psi before starting the test.
If the initial pressure
exceeds 500 psi, you must
bleed back to zero and
reinitiate the test.
(2) High-pressure test for blind-shear The high-pressure test must
ram-type BOPs, ram-type BOPs, the equal the rated working
choke manifold, outside of all choke pressure of the equipment or
and kill side outlet valves (and be 500 psi greater than your
annular gas bleed valves for subsea calculated MASP, as defined
BOP), inside of all choke and kill for the operation for the
side outlet valves below uppermost applicable section of hole.
ram, and other BOP components. Before you may test BOP
equipment to the MASP plus 500
psi, the District Manager must
have approved those test
pressures in your APD.
(3) High-pressure test for annular-type The high pressure test must
BOPs, inside of choke or kill valves equal 70 percent of the rated
(and annular gas bleed valves for working pressure of the
subsea BOP) above the uppermost ram equipment or be 500 psi
BOP. greater than your calculated
MASP, as defined for the
operation for the applicable
section of hole. Before you
may test BOP equipment to the
MASP plus 500 psi, the
District Manager must have
approved those test pressures
in your APD.
------------------------------------------------------------------------
(c) Duration of pressure test. Each test must hold the required
pressure for 5 minutes, which must be recorded on a chart not exceeding
4 hours. However, for surface BOP systems and surface equipment of a
subsea BOP system, a 3-minute test duration is acceptable if recorded
on a chart not exceeding 4 hours, or on a digital recorder. The
recorded test pressures must be within the middle half of the chart
range, i.e., cannot be within the lower or upper one-fourth of the
chart range. If the equipment does not hold the required pressure
during a test, you must correct the problem and retest the affected
component(s).
(d) Additional test requirements. You must meet the following
additional BOP testing requirements:
------------------------------------------------------------------------
You must . . . Additional requirements . . .
------------------------------------------------------------------------
(1) Follow the testing requirements of If there is a conflict between
API Standard 53 (as incorporated in API Standard 53 testing
Sec. 250.198). requirements and this section,
you must follow the
requirements of this section.
(2) Use water to test a surface BOP (i) You must submit test
system.. procedures with your APD or
APM for District Manager
approval.
(ii) Contact the District
Manager at least 72 hours
prior to beginning the test to
allow BSEE representative(s)
to witness testing. If BSEE
representative(s) are unable
to witness testing, you must
provide the test results to
the appropriate District
Manager within 72 hours after
completion of the tests.
(3) Stump test a subsea BOP system (i) You must use water to
before installation.. conduct this test. You may use
drilling fluids to conduct
subsequent tests of a subsea
BOP system.
[[Page 21581]]
(ii) You must submit test
procedures with your APD or
APM for District Manager
approval.
(iii) Contact the District
Manager at least 72 hours
prior to beginning the stump
test to allow BSEE
representative(s) to witness
testing. If BSEE
representative(s) are unable
to witness testing, you must
provide the test results to
the appropriate District
Manager within 72 hours after
completion of the tests.
(iv) You must test and verify
closure of all ROV
intervention functions on your
subsea BOP stack during the
stump test.
(v) You must follow (b) and (c)
of this section.
(4) Perform an initial subsea BOP test. (i) You must perform the
initial subsea BOP test on the
seafloor within 30 days of the
stump test.
(ii) You must submit test
procedures with your APD or
APM for District Manager
approval.
(iii) You must pressure test
well-control rams according to
(b) and (c) of this section.
(iv) You must notify the
District Manager at least 72
hours prior to beginning the
initial subsea test for the
BOP system to allow BSEE
representative(s) to witness
testing.
(v) You must test and verify
closure of at least one set of
rams during the initial subsea
test through a ROV hot stab.
You must pressure test the
selected rams according to (b)
and (c) of this section.
(5) Alternate tests between control (i) For two complete BOP
stations and pods.. control stations:
(A) Designate a primary and
secondary station, and both
stations must be function-
tested weekly,
(B) The control station used
for the pressure test must be
alternated between pressure
tests, and
(C) For a subsea BOP, the pods
must be rotated between
control stations during weekly
function testing, and the pod
used for pressure testing must
be alternated between pressure
tests.
(ii) Any additional control
stations must be function
tested every 14 days.
(6) Pressure test variable bore-pipe ...............................
ram BOPs against the largest and
smallest sizes of pipe in use,
excluding the bottom hole assembly
that includes heavy-weight pipe or
collars and bottom-hole tools.
(7) Pressure test annular type BOPs ...............................
against the smallest pipe in use.
(8) Pressure test affected BOP ...............................
components following the disconnection
or repair of any well-pressure
containment seal in the wellhead or
BOP stack assembly.
(9) Function test annular and pipe/ ...............................
variable bore ram BOPs every 7 days
between pressure tests.
(10) Function test blind-shear ram BOPs ...............................
every 14 days.
(11) Actuate safety valves assembled ...............................
with proper casing connections before
running casing.
(12) Test and verify closure capability (i) Each ROV must be fully
of all ROV intervention functions on compatible with the BOP stack
your subsea BOP. ROV intervention panels.
(ii) You must submit test
procedures, including how you
will test each ROV
intervention function, with
your APD or APM for District
Manager approval.
(iii) You must document all
your test results and make
them available to BSEE upon
request.
(13) Function test autoshear, deadman, (i) You must submit test
and EDS systems separately on your procedures with your APD or
subsea BOP stack during the stump APM for District Manager
test. The District Manager may require approval. The procedures for
additional testing of the emergency these function tests must
systems. You must also test the include the schematics of the
deadman system and verify closure of actual controls and circuitry
the shearing rams during the initial of the system that will be
test on the seafloor. used during an actual
autoshear or deadman event.
(ii) The procedures must also
include the actions and
sequence of events that take
place on the approved
schematics of the BOP control
system and describe
specifically how the ROV will
be utilized during this
operation.
(iii) When you conduct the
initial deadman system test on
the seafloor, you must ensure
the well is secure and, if
hydrocarbons have been
present, appropriate barriers
are in place to isolate
hydrocarbons from the
wellhead. You must also have
an ROV on bottom during the
test.
(iv) The testing of the deadman
system on the seafloor must
indicate the discharge
pressure of the subsea
accumulator system throughout
the test.
(v) For the function test of
the deadman system during the
initial test on the seafloor,
you must have the ability to
quickly disconnect the LMRP
should the rig experience a
loss of station-keeping event.
You must include your quick-
disconnect procedures with
your deadman test procedures.
[[Page 21582]]
(vi) You must pressure test the
blind-shear ram(s) according
to (b) and (c) of this
section.
(vii) If a casing shear ram is
installed, you must describe
how you will verify closure of
the ram.
(viii) You must document all
your test results and make
them available to BSEE upon
request.
------------------------------------------------------------------------
(e) Prior to conducting any shear ram tests in which you will shear
pipe, you must notify the BSEE District Manager at least 72 hours in
advance, to ensure that a representative of BSEE will have access to
the location to witness any testing.
Sec. 250.738 What must I do in certain situations involving BOP
equipment or systems?
The table in this section describes actions that you must take when
certain situations occur with BOP systems.
------------------------------------------------------------------------
If you encounter the following
situation: Then you must . . .
------------------------------------------------------------------------
(a) BOP equipment does not hold the Correct the problem and retest
required pressure during a test; the affected equipment. You
must report any problems or
irregularities, including any
leaks, to the District Manager
and on the daily report as
required in Sec. 250.746.
(b) Need to repair, replace, or (1) First place the well in a
reconfigure a surface or subsea BOP safe, controlled condition as
system; approved by the District
Manager (e.g., before drilling
out a casing shoe or after
setting a cement plug, bridge
plug, or a packer).
(2) Any repair or replacement
parts must be manufactured
under a quality assurance
program and must meet or
exceed the performance of the
original part produced by the
OEM.
(3) You must receive approval
from the District Manager
prior to resuming operations
with the new, repaired, or
reconfigured BOP. You must
submit a report from a BSEE-
approved verification
organization to the District
Manager certifying that the
BOP is fit for service.
(c) Need to postpone a BOP test due to Record the reason for
well-control problems such as lost postponing the test in the
circulation, formation fluid influx, daily report and conduct the
or stuck pipe;. required BOP test on the first
trip out of the hole.
(d) BOP control station or pod that Suspend operations until that
does not function properly;. station or pod is operable.
You must report any problems
or irregularities, including
any leaks, to the District
Manager.
(e) Plan to operate with a tapered Install two or more sets of
string;. conventional or variable-bore
pipe rams in the BOP stack to
provide for the following: two
sets of rams must be capable
of sealing around the larger-
size drill string and two sets
of pipe rams must be capable
of sealing around the smaller
size pipe, excluding the
bottom hole assembly that
includes heavy weight pipe or
collars and bottom-hole tools.
(f) Plan to install casing rams or Test the ram bonnets before
casing shear rams in a surface BOP running casing to the rated
stack;. working pressure or MASP plus
500 psi. The BOP must also
provide for sealing the well
after casing is sheared. If
this installation was not
included in your approved
permit, and changes the BOP
configuration approved in the
APD or APM, you must notify
and receive approval from the
District Manager.
(g) Plan to use an annular BOP with a Demonstrate that your well-
rated working pressure less than the control procedures or the
anticipated surface pressure;. anticipated well conditions
will not place demands above
its rated working pressure and
obtain approval from the
District Manager.
(h) Plan to use a subsea BOP system in Install the BOP stack in a well
an ice-scour area;. cellar. The well cellar must
be deep enough to ensure that
the top of the stack is below
the deepest probable ice-scour
depth.
(i) You activate any shear ram and pipe Retrieve, physically inspect,
or casing is sheared;. and conduct a full pressure
test of the BOP stack after
the situation is fully
controlled. You must submit to
the District Manager a report
from a BSEE-approved
verification organization
certifying that the BOP is fit
to return to service.
(j) Need to remove the BOP stack;...... Have a minimum of two barriers
in place prior to BOP removal.
You must obtain approval from
the District Manager of the
two barriers prior to removal
and the District Manager may
require additional barriers.
(k) In the event of a deadman or Place the blind-shear ram
autoshear activation, if there is a opening function in the block
possibility of the blind-shear ram position prior to re-
opening immediately upon re- establishing power to the
establishing power to the BOP stack; stack. Contact the District
Manager and receive approval
of procedures for re-
establishing power and
functions prior to latching up
the BOP stack or re-
establishing power to the
stack.
(l) If a test ram is to be used;....... Conduct the initial BOP test
after latching up using a test
tool, and test the wellhead/
BOP connection to the maximum
pressure for the approved ram
test for the well. All
hydraulically operated BOP
components must also be
functioned during the well
connection test.
[[Page 21583]]
(m) Plan to utilize any other well- Contact the District Manager
control equipment (e.g., but not and request approval in your
limited to, subsea isolation device, APD or APM. Your request must
subsea accumulator module, or gas include a report from a BSEE-
handler) that is in addition to the approved verification
equipment required in this subpart; organization on the
equipment's design and
suitability for its intended
use as well as any other
information required by the
District Manager. The District
Manager may impose any
conditions regarding the
equipment's capabilities,
operation, and testing.
(n) You have pipe/variable bore rams Indicate in your APD or APM
that have no current utility or well- which pipe/variable bore rams
control purposes; meet these criteria and
clearly label them on all BOP
control panels. You do not
need to function test or
pressure test pipe/variable
bore rams having no current
utility, and that will not be
used for well-control
purposes, until such time as
they are intended to be used
during operations.
(o) You install redundant components Comply with all testing,
for well control in your BOP system maintenance, and inspection
that are in addition to the required requirements in this subpart
components of this subpart (e.g., pipe/ that are applicable to those
variable bore rams, shear rams, well-control components. If
annular preventers, gas bleed lines, any redundant component fails
and choke/kill side outlets or lines); a test, you must submit a
report from a BSEE-approved
verification organization that
describes the failure, and
confirms that there is no
impact on the BOP that will
make it unfit for well-control
purposes. You must submit this
report to the District Manager
and receive approval before
resuming operations. The
District Manager may require
additional information.
(p) Need to position the bottom hole Ensure that the well has been
assembly, including heavy-weight pipe stable for a minimum of 30
or collars, and bottom-hole tools minutes prior to positioning
across the BOP for tripping or any the bottom hole assembly
other operations. across the BOP. You must have,
as part of your well-control
plan required by Sec.
250.710, procedures that
enable the immediate removal
of the bottom hole assembly
from across the BOP in the
event of a well control or
emergency situation (for
dynamically positioned rigs,
your plan must also include
steps for when the EDS must be
activated) before MASP
conditions are reached as
defined for the operation.
------------------------------------------------------------------------
Sec. 250.739 What are the BOP maintenance and inspection
requirements?
(a) You must maintain and inspect your BOP system to ensure that
the equipment functions as designed. The BOP maintenance and
inspections must meet or exceed any OEM recommendations, recognized
engineering practices, and industry standards incorporated by reference
into the regulations of this subpart, including API Standard 53
(incorporated by reference in Sec. 250.198). You must document how you
met or exceeded the provisions of API Standard 53, maintain complete
records to ensure the traceability of all critical components beginning
at fabrication, and record the results of your BOP inspections and
maintenance actions. You must make all records available to BSEE upon
request.
(b) A complete breakdown and detailed physical inspection of the
BOP and every associated system and component must be performed every 5
years. This complete breakdown and inspection may not be performed in
phased intervals. A BSEE-approved verification organization is required
to be present during the inspection and must compile a detailed report
documenting the inspection, including descriptions of any problems and
how they were corrected. You must make this report available to BSEE
upon request.
(c) You must visually inspect your surface BOP system on a daily
basis. You must visually inspect your subsea BOP system, marine riser,
and wellhead at least once every 3 days if weather and sea conditions
permit. You may use cameras to inspect subsea equipment.
(d) You must ensure that all personnel maintaining, inspecting, or
repairing BOPs, or critical components of the BOP system, meet the
qualification and training criteria specified by the OEMs and
recognized engineering practices.
(e) You must make all records available to BSEE upon request. You
must ensure that the rig owner maintains your BOP maintenance,
inspection, and repair records on the rig for 2 years from the date the
records are created or for a longer period if directed by BSEE. You
must maintain all design, maintenance, inspection, and repair records
at an onshore location for the service life of the equipment.
Records and Reporting
Sec. 250.740 What records must I keep?
You must keep a daily report consisting of complete, legible, and
accurate records for each well. You must keep records onsite while well
operations continue. After completion of operations, you must keep all
operation and other well records for the time periods shown in Sec.
250.741 at a location of your choice, except as required in Sec.
250.746. The records must contain complete information on all of the
following:
(a) Well operations, all testing conducted, and any real-time
monitoring data;
(b) Descriptions of formations penetrated;
(c) Content and character of oil, gas, water, and other mineral
deposits in each formation;
(d) Kind, weight, size, grade, and setting depth of casing;
(e) All well logs and surveys run in the wellbore;
(f) Any significant malfunction or problem; and
(g) All other information required by the District Manager.
Sec. 250.741 How long must I keep records?
You must keep records for the time periods shown in the following
table.
------------------------------------------------------------------------
You must keep records relating to . . .
Until . . .
------------------------------------------------------------------------
(a) Drilling;.......................... 90 days after you complete
operations.
(b) Casing and liner pressure tests, 2 years after the completion of
diverter tests, BOP tests, and real- operations.
time monitoring data;
[[Page 21584]]
(c) Completion of a well or of any You permanently plug and
workover activity that materially abandon the well or until you
alters the completion configuration or assign the lease and forward
affects a hydrocarbon-bearing zone. the records to the assignee.
------------------------------------------------------------------------
Sec. 250.742 What well records am I required to submit?
You must submit to BSEE copies of logs or charts of electrical,
radioactive, sonic, and other well logging operations; directional and
vertical well surveys; velocity profiles and surveys; and analysis of
cores. Each Region will provide specific instructions for submitting
well logs and surveys.
Sec. 250.743 What are the well activity reporting requirements?
(a) For operations in the BSEE GOM OCS Region, you must submit Form
BSEE-0133, Well Activity Report (WAR), to the District Manager on a
weekly basis. The reporting week is defined as beginning on Sunday (12
a.m.) and ending on the following Saturday (11:59 p.m.). This reporting
week corresponds to a week (Sunday through Saturday) on a standard
calendar. Report any well operations that extend past the end of this
weekly reporting period on the next weekly report. The reporting period
for the weekly report is never longer than 7 days, but could be less
than 7 days for the first reporting period and the last reporting
period for a particular well operation. Submit each WAR and
accompanying Form BSEE-0133S, Open Hole Data Report, to the BSEE GOM
OCS Region no later than close of business on the Friday immediately
after the closure of the reporting week. The District Manager may
require more frequent submittal of the WAR on a case-by-case basis.
(b) For operations in the Pacific or Alaska OCS Regions, you must
submit Form BSEE-0133, WAR, to the District Manager on a daily basis.
(c) The WAR must include a description of the operations conducted,
any abnormal or significant events that affect the permitted operation
each day within the report from the time you begin operations to the
time you end operations, any verbal approval received, the well's as-
built drawings, casing, fluid weights, shoe tests, test pressures at
surface conditions, and any other information required by the District
Manager. For casing cementing operations, indicate type of returns
(i.e., full, partial, or none). If partial or no returns are observed,
you must indicate how you determined the top of cement. For each
report, indicate the operation status for the well at the end of the
reporting period. On the final WAR, indicate the status of the well
(completed, temporarily abandoned, permanently abandoned, or drilling
suspended) and the date you finished such operations.
Sec. 250.744 What are the end of operation reporting requirements?
(a) Within 30 days after completing operations, except routine
operations as defined in Sec. 250.601, you must submit Form BSEE-0125,
End of Operations Report (EOR), to the District Manager. The EOR must
include a listing, with top and bottom depths, of all hydrocarbon zones
and other zones of porosity encountered with any cored intervals;
details on any drill-stem and formation tests conducted; documentation
of successful negative pressure testing on wells that use a subsea BOP
stack or wells with mudline suspension systems; and an updated
schematic of the full wellbore configuration. The schematic must be
clearly labeled and show all applicable top and bottom depths,
locations and sizes of all casings, cut casing or stubs, casing
perforations, casing rupture discs (indicate if burst or collapse and
rating), cemented intervals, cement plugs, mechanical plugs, perforated
zones, completion equipment, production and isolation packers,
alternate completions, tubing, landing nipples, subsurface safety
devices, and any other information required by the District Manager.
The EOR must indicate the status of the well (completed, temporarily
abandoned, permanently abandoned, or drilling suspended) and the date
of the well status designation. The wells' status date is subject to
the following:
(1) For surface well operations and riserless subsea operations,
the operations end date is subject to the discretion of the District
Manager; and
(2) For subsea well operations, the operations end date is
considered to be the date the BOP is disconnected from the wellhead
unless otherwise specified by the District Manager.
(b) You must submit public information copies of Form BSEE-0125
according to Sec. 250.186(b).
Sec. 250.745 What other well records could I be required to submit?
The District Manager or Regional Supervisor may require you to
submit copies of any or all of the following well records:
(a) Well records as specified in Sec. 250.740;
(b) Paleontological interpretations or reports identifying
microscopic fossils by depth and/or washed samples of drill cuttings
that you normally maintain for paleontological determinations. The
Regional Supervisor may issue a Notice to Lessees that sets forth the
manner, timeframe, and format for submitting this information;
(c) Service company reports on cementing, perforating, acidizing,
testing, or other similar services; or
(d) Other reports and records of operations.
Sec. 250.746 What are the recordkeeping requirements for casing,
liner, and BOP tests, and inspections of BOP systems and marine risers?
You must record the time, date, and results of all casing and liner
pressure tests. You must also record pressure tests, actuations, and
inspections of the BOP system, system components, and marine riser in
the daily report described in Sec. 250.740. In addition, you must:
(a) Record test pressures on pressure charts;
(b) Require your onsite lessee representative, designated rig or
contractor representative, and pump operator to sign and date the
pressure charts and daily reports as correct;
(c) Document on the daily report the sequential order of BOP and
auxiliary equipment testing and the pressure and duration of each test.
For subsea BOP systems, you must also record the closing times for
annular and ram BOPs. You may reference a BOP test plan if it is
available at the facility;
(d) Identify on the daily report the control station and pod used
during the test (identifying the pod does not apply to coiled tubing
and snubbing units);
(e) Identify on the daily report any problems or irregularities
observed during BOP system testing and record actions taken to remedy
the problems or irregularities. Any leaks associated with the BOP or
control system during testing are considered problems or irregularities
and must be reported immediately to the District Manager, and
documented in the WAR. If any problems or irregularities are observed
during testing, operations must be suspended
[[Page 21585]]
until the District Manager determines that you may continue; and
(f) Retain all records, including pressure charts, daily reports,
and referenced documents pertaining to tests, actuations, and
inspections at the facility for the duration of the operation. After
completion of the operation, you must retain all the records listed in
this section for a period of 2 years at the facility. You must also
retain the records at the lessee's field office nearest the facility or
at another location available to BSEE. You must make all the records
available to BSEE upon request.
0
41. Revise Sec. 250.1612 to read as follows:
Sec. 250.1612 Well-control drills.
Well-control drills must be conducted for each drilling crew in
accordance with the requirements set forth in Sec. 250.711 of this
part or as approved by the District Manager.
0
42. Amend Sec. 250.1703 by:
0
a. Revising paragraphs (b) and (e);
0
b. Redesignating paragraph (f) as paragraph (g); and
0
c. Adding a new paragraph (f).
The revisions and addition read as follows:
Sec. 250.1703 What are the general requirements for decommissioning?
* * * * *
(b) Permanently plug all wells. All packers and bridge plugs must
comply with API Spec. 11D1 (as incorporated by reference in Sec.
250.198);
* * * * *
(e) Clear the seafloor of all obstructions created by your lease
and pipeline right-of-way operations;
(f) Follow all applicable requirements of subpart G; and
* * * * *
0
43. Amend Sec. 250.1704 by revising paragraph (g) and adding paragraph
(h) to read as follows:
Sec. 250.1704 When must I submit decommissioning applications and
reports?
* * * * *
------------------------------------------------------------------------
Decommissioning applications
and reports When to submit Instructions
------------------------------------------------------------------------
* * * * * * *
(g) Form BSEE-0124, (1) Before you (i) Include
Application for Permit to temporarily abandon information
Modify (APM). The or permanently plug required under Sec.
submission of your APM must a well or zone, Sec. 250.1712
be accompanied by payment and 250.1721.
of the service fee listed (ii) When using a
in Sec. 250.125; BOP for abandonment
operations, include
information
required under Sec.
250.731.
(2) Before you Refer to Sec.
install a subsea 250.1722(a).
protective device,
(3) Before you Refer to Sec.
remove any casing 250.1723.
stub or mud line
suspension
equipment and any
subsea protective
device,
(h) Form BSEE-0125, End of (1) Within 30 days Include information
Operations Report (EOR); after you complete required under Sec.
a protective device 250.1722(d).
trawl test,
(2) Within 30 days Include information
after you complete required under Sec.
site clearance 250.1743(a).
verification
activities,
------------------------------------------------------------------------
Sec. 250.1705 [Removed and Reserved]
0
44. Remove and reserve Sec. 250.1705.
0
45. Amend Sec. 250.1706 by:
0
a. Revising the section heading;
0
b. Removing paragraphs (a) through (e); and
0
c. Redesignating paragraph (f) through (h) as paragraphs (a) through
(c). The revision reads as follows:
Sec. 250.1706 Coiled tubing and snubbing operations.
* * * * *
Sec. Sec. 250.1707 through 250.1709 [Removed and Reserved]
0
46. Remove and reserve Sec. Sec. 250.1707 through 250.1709.
0
47. In Sec. 250.1715, revise paragraph (a)(3)(iii)(B) to read as
follows:
Sec. 250.1715 How must I permanently plug a well?
* * * * *
(a) * * *
(3) * * *
(iii) * * *
(B) A casing bridge plug set 50 to 100 feet above the top of the
perforated interval and at least 50 feet of cement on top of the bridge
plug;
* * * * *
Sec. 250.1717 [Removed and Reserved]
0
48. Remove and reserve Sec. 250.1717.
Sec. 250.1721 [Amended]
0
49. Amend Sec. 250.1721 by removing paragraph (g) and redesignating
paragraph (h) as paragraph (g).
[FR Doc. 2015-08587 Filed 4-13-15; 4:15 pm]
BILLING CODE 4310-VH-P