Well Intervention and The BSEE Well Control Rule: Who Will You Call?
The BSEE Well Control Rule effective since 28 July 2016 is a significant step-change for the Oil & Gas Industry. The requirements and stipulations encompass regulatory oversight, operational protocols, equipment design, and quality management principles derived from a variety of sources: incorporation of industry standards, revised guidance from previous Notices to Lessees (NTLs), and implementation of recommendations resulting from various investigations of the Macondo incident, to name a few. The significance and potential impact of this rule has been discussed extensively since the rule was first proposed in April of 2015; however, most of the attention has been devoted to the drilling industry specifically, even though the impact extends in the well intervention realm as well.
Prior to the Well Control Rule, BOP and well-control requirements were scattered among different sections depending on the type of operations conducted. The Well Control Rule consolidated all requirements found in these subparts under one, Subpart G, which is now referenced by other Subparts throughout Title 30, Part 250 of the Code of Federal Regulations (30 CFR 250). In particular:
- Subpart D, 30 CFR 250.411(f): Oil and Gas Drilling Operations
- Subpart E, 30 CFR 250.513(b)(4): Oil and Gas Well-Completion Operations
- Subpart F, 30 CFR 250.613(b)(3): Oil and Gas Well-Workover Operations
Refer to Subpart G, 30 CFR 250.731, which states: “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.” Note the term “BOP” is not specific to drilling BOPs, and therefore encompasses all blowout preventers by definition. Moreover, 30 CFR 250.731(c) requires certification pursuant to 30 CFR 250.732, for every application for permit to drill (APD) or application for permit to modify (APM).
From an equipment perspective, there are significant differences between a BOP designed for drilling operations and a BOP used for well intervention. This in turn may lead to the thought that an independent third party, or BSEE-Approved Verification Organization (BAVO) once the list is published by BSEE, that specializes in drilling BOPs may not be the best choice to verify a BOP for intervention operations (and vice versa). However, from a regulatory standpoint, the requirements for the BOPs are the same. Furthermore, from a conceptual standpoint, a drilling BOP and an intervention BOP fulfill the same overarching purpose: seal the wellbore to prevent a blowout. If the regulatory and functional requirements are the same, it is feasible then that an independent third party who understands the differences and builds a service delivery framework to support them can in fact verify compliance of both drilling and intervention well control systems.
Athens Group is such an independent third party. We have built a Knowledge Delivery System that defines our approach; designed a modular Well Control Inspection TrackerTM (WCIT) that incorporates regulatory, industry, and functional requirements; and we supplement this with the expertise of our DTA Consultants who average 20 years of experience in both drilling and intervention systems. This enables us to offer our clients a partner that can deliver consistently high-quality deliverables to ensure compliance of all of their operations. For more information or to discuss your specific project, please email firstname.lastname@example.org or call us toll free +1 (877) 499-8393.