On April 17, 2015, the Bureau of Safety and Environmental Enforcement (BSEE) announced its new proposed BOP and well control requirements rule for the outer continental shelf federal waters, 30 C.F.R. Part 250. Several years in the making, it aims to enhance well control and equipment reliability, and includes a suite of reforms in well design, well control, casing, cementing, real-time well monitoring, and subsea containment.
“While we have current requirements related to well control, BOP equipment, and well control equipment, this represents a major upgrade in existing regulations,” BSEE’s Chief of Offshore Regulatory Programs Doug Morris told Offshore.
Currently undergoing BSEE’s in-house review as the agency works to produce the final version, once completed, the proposed rule will go before the US Office of Information and Regulatory Affairs in the US Office of Management and Budget for finalization. Although BSEE is unable to say at this time when the final rule will be published, the agency said that it expected to finish its review soon.
Post-Macondo standards
Morris said that the rule has been under development since 2012. The impetus for its drafting, however, reaches back even further.
Following the Deepwater Horizon tragedy, several groups headed investigations that resulted in sets of recommendations being made to the industry. The proposed rule says that these investigations found “a need to enhance well control best practices to advance safety and protection of the environment.” In 30 C.F.R. Part 250, BSEE intends to bolster these recommendations by formalizing them into legal requirements. Additionally, the agency has incorporated guidance from its formal communications to operators and contractors, which are termed Notices to Lessees and Operators.
“We had a lot of recommendations arising out of Deepwater Horizon, some of which related to blowout preventers, and some of which related to issues like drilling margins,” Morris said. “To the extent we could, we tried to address those issues within this proposed rule-making.” He said that hundreds of Macondo-related recommendations were captured in this rule.
BSEE is also looking to close existing gaps with the new rule, thereby strengthening the cohesion between its regulations and industry standard practices, especially with regard to BOP testing and reliability. Included in the new rule are several post-Macondo industry standards to establish minimum requirements for the design, manufacture, repair, and maintenance of BOPs. Of the eight American Petroleum Institute (API) and American National Standards Institute (ANSI) standards included in the new rule, five are specifically related to BOP systems.
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