The Obama administration on Wednesday proposed a rule to tighten standards for oil and gas production systems used offshore, in a bid to keep pace with the industry’s march into deeper waters and more challenging terrain.
The 149-page proposal also would require more rigorous cradle-to-grave assessments of critical safety and pollution prevention equipment, such as foam firefighting systems and electronic emergency shutdown devices.
The measure has been in the works for years, as offshore regulators sought to update standards that haven’t been significantly revised since they were first published in 1988.
“Since that time, much of the oil and gas production on the outer continental shelf has moved into deeper waters, and the regulations have not kept pace with the technological advancements,” the Bureau of Safety and Environmental Enforcement said in the proposal.
Deep-sea demand: Orders for offshore production facilities surging, led by Brazil
One major change is the increasing reliance on production equipment buried beneath the surface of the sea, including trees, the assemblies of valves and fittings that are mounted on well heads and used to control the flow of oil and gas.
Decades ago, oil and gas companies generally used dry tree completions, with the equipment easily accessible. But “production in the Gulf of Mexico now occurs in depths of 9,000 feet of water, with many of the wells producing from water depths greater than 4,000 feet utilizing ‘wet’ or subsea trees,” the bureau said. Since the subsea trees are located on the seafloor, workers can’t directly access the device’s valves and gauges. Instead, pressure, temperature and flow rate are monitored remotely.
Bureau Director James Watson cast the proposal as a mix of “common-sense changes” that “will help regulations keep pace with changing technologies that have enabled the industry to explore and develop resources in deeper waters.”
The oil industry has developed stronger alloys and equipment meant to withstand higher temperatures underground and stronger pressures under thousands of feet of water. Even close to shore, new technologies are being used to eke oil and gas from existing reservoirs.
Under the rule, oil and gas companies operating offshore would have to more frequently report failures in safety and pollution prevention equipment and better document maintenance of the systems. The government also is proposing the equipment be subjected to “life-cycle analysis,” a kind of vigorous, continual review covering the entire lifespan of the devices, from their design and manufacturing to their final decommissioning.
Although industry standards established by the American Petroleum Institute already recommend such cradle-to-grave analysis, the bureau said the proposed rule “would codify aspects of the life-cycle analysis into the regulations and bring attention to its importance.”
The goal, according to the proposed rule, is “to increase the overall level of certainty that this equipment would perform as intended including in emergency situations.”
Companies would have to notify manufacturers of failures of safety and pollution prevention equipment within 30 days after discovering the problems. And the rule would require operators to conduct investigations within 60 days of the failures, with the manufacturer of the equipment guaranteed a copy of any analysis reports.
The proposed rule incorporates a suite of API recommended practices for offshore production facilities, including a standard on design and hazards analysis of the facilities.
Energy companies also would have to use the “best available and safest technology” whenever the safety bureau deems it economically feasible for new drilling and production operations or practicable on existing operations. That is a proposed change to existing regulations that require the use of best available and safer technology “whenever practical” on “all exploration, development and production operations.”
In practice, this would mean the safety bureau generally would dictate what best safety technology is economically feasible, but offshore operators could ask for exceptions when the cost of the technology outweighs its benefits.
Gulf of Mexico: Accidents show depth of danger in shallow waters
With the proposed rule, the safety bureau also aims to make changes in response to the agency’s investigation of the availability of engineer-approved drawings on BP’s Atlantis oil and gas production platform. Under the proposed rule, engineering documents would have to be stamped by registered professional engineers, and they would have to be available to federal regulators on request. As-built diagrams of facilities and equipment also would have to be submitted to federal regulators.
Within a year of being finalized, the rule would effectively bar companies from installing single bore production risers from floating production facilities. The safety bureau said single bore production risers do not provide “an acceptable level of safety ” when operators have to work through the riser. That can cause wear over time, potentially compromising the riser’s integrity.
The public now has 60 days to comment on the proposed rule. In an interview with FuelFix, Watson stressed his desire to heed input from oil and gas operators, drilling companies, equipment manufacturers and other stakeholders in writing the rules.
This likely will be Watson’s last major act as director of the safety bureau. He is leaving later this month to take over as president and chief operating officer for the Americas division of the maritime classification society ABS.
The safety bureau is still working on another major set of regulations that would govern critical emergency equipment known as blowout preventers.
Also on FuelFix: