By Kelli Ainsworth, Editorial Coordinator
The US Bureau of Safety and Environmental Enforcement (BSEE) is reassuring the industry that it will have up to five years to comply with the more capital-intensive provisions of the Well Control Rule. In an interview with DC at the 2016 OTC in Houston on 4 May, Lars Herbst, Regional Director of the Gulf of Mexico for BSEE, said the agency is now working on implementing the rule and providing additional guidance and clarification on the final rule where needed. The final Well Control Rule was published in the Federal Register on 29 April.
While most of the rule’s provisions will take effect 90 days from publication – on 28 July – BSEE recognizes that some provisions will require more time. These are primarily the ones related to BOP equipment specifications, Mr Herbst said. He also pointed out that although these provisions might require a large capital outlay, some companies have already made part of the required financial investments to align with API Standard 53. “The industry is already moving in that direction. Some of those capital investments have already been made.”
Mr Herbst also pointed out that BSEE has responded to industry concerns that the proposed rule was too prescriptive by incorporating more performance-based requirements in the final rule wherever possible. For instance, the proposed rule required operators to maintain a drilling margin of 0.5 lb/gal. “If the industry does analysis and shows that they can get to less than a 0.5 lb/gal margin, we will review that, and we have procedures in the final rule that will allow the acceptance of that.”
In addition, BSEE introduced more flexibility to the rule’s real-time monitoring requirements, said Allyson Anderson Book, BSEE’s Associate Director of Strategic Engagement. The agency is currently working on clarifying industry questions on performance-based requirements, she said. “Several members of the implementation team have sat down with industry groups to get ideas where they will be looking for additional guidance,” she said. Operators have asked BSEE for more information on elements that will be required in the real-time monitoring plan and how the plans will be handled.
Some provisions were not altered despite industry concerns, she said. Specifically, the industry worried that Well Control Rule went too far above and beyond current industry standards. However, Ms Book said, many of the recommendations from Macondo investigations suggested that relying on industry standards alone would not be enough. “We really analyzed each of the standards and best practices to see which ones needed to be enhanced based on the recommendations we had. A lot of people in the industry asked us to just stay with the standard and not go above and beyond that, but we did go further.”
In addition to its work on implementing the Well Control Rule, BSEE continues to investigate bolt failures in critical components related to the BOP stack, Mr Herbst said. The issue came to BSEE’s attention due to bolt failure on the connector joining the BOP and the wellhead. “We did isolate that particular issue and did get it corrected,” he said. “Those bolts were changed out, and even the manufacturing processes were changed in some cases.” However, similar bolts are used in different places along the BOP stack. BSEE is currently working with contractors and operators to improve quality assurance related to those bolts.
To learn more about BSEE’s implementation of the well control rule and the findings of the agency’s annual report, watch DC’s video with Lars Herbst from OTC 2016.