By Linda Hsieh, managing editor
In the post-Macondo world, there’s a renewed sense of urgency around deepwater drilling safety, and the government has made it clear that it will take aggressive steps to ensure that safety. It is expected that one of those steps will be the regulatory requirement of a safety case for deepwater drilling operations in the Gulf of Mexico.
The safety case was one component of the recommendations to the US Secretary of the Interior made by the Joint Industry Task Force in the immediate aftermath of the blowout. The Secretary’s 30-day report to the president that followed stated that the Bureau of Ocean Management, Regulation and Enforcement (BOEM) – MMS at that time – would issue a rulemaking proposal within 120 days on a safety case requirement.
In July, a joint industry task group comprising representatives of operator and drilling contractor companies began drafting the Well Construction Interface Document (WCID). The document will link the drilling contractor safety case with the operator’s safety management system, and include well-specific information such as the basis of design, well execution plan and risk assessment. It puts an emphasis on the prevention of loss of well control and the details of barrier controls.
The WCID will show how management of change and risk assessment processes will apply during their construction activities and ensure personnel competency. It also will align all parties to ensure that HSE standards are not compromised while undertaking shared activities. Specific responsibilities will be delineated for the operator and the drilling contractor, and a framework will be provided to allow the drilling contractor to intervene if unsafe acts are identified.
IADC HSE CASE GUIDELINES
Alan Spackman, IADC vice president – offshore technical and regulatory affairs, is participating on the joint industry task group to ensure that the WCID is compatible with the IADC HSE Case Guidelines. For years, IADC’s guidelines have been available to help drilling contractors build their HSE case as part of a wider safety management system. The guidelines were referenced in both the Joint Industry Task Force recommendations and the interior secretary’s report to the president.
Once safety case requirements for the Gulf of Mexico are issued – it’s unclear when that will be – IADC will be working to identify what changes may be needed in the IADC guidelines and to develop a Gulf of Mexico-specific annex.
As of mid-August, it was expected that the first edition of the WCID guidelines will be released in September 2010 for general use by the industry.
Well Construction Interface Document (WCID)
The purpose of the Well Construction Interface Document (WCID) is to ensure that all well construction work (drilling, suspension, completion, testing, workover and/or abandonment) is carried out in a manner to protect the safety and health of all workers and protect the environment. There is an emphasis on prevention of “loss of well control” and the details of barrier controls. The WCID will align the goals and objectives of HSE with the well construction process.
• Tie the safety-critical well construction components and processes with the elements of the traditional safety case bridging document.
• Identify, eliminate or mitigate risks associated with the proposed well work.
• Identify functional safety links and roles/responsibilities between the operator and drilling contractor to allow safe execution of the proposed well work.
• Communicate critical information about the operator’s well construction execution plans to the rig contractor.
• Address areas of the safety management process, including specialized areas such as management of change, well control, fire and explosion management, lifting equipment, dropped objects, permit to work, helicopter operations and incident database guidelines.
• Address all phases of the well construction process within the context of the proposed well work – drilling, suspension, completion, testing, workover and/or abandonment.
• Develop a WCID guideline that is easy to use and understand, yet robust and complete in detail.
• Basis of design discussion to introduce the specific well construction environment.
• Risk assessments discussion focused on loss of well control.
• Barrier and casing program discussion (design loads and unexpected loads) to ensure the rig contractor understands:
- What the critical barriers are.
- How these barriers are installed.
- How these barriers are tested and validated.
- How these barriers can fail.
- How to ensure these barriers do not fail.
• MOC discussion to manage circumstances when a change to the well execution plan is required.
• Roles/responsibilities discussion to ensure that the rig contractor uses their STOP work authority relative to “on the fly” operator changes in the well execution plan.
• Traditional safety case bridging discussion to align safety systems and ensure personal safety during the well execution.