Safety regulations that were hurried into publication by the Department of Interior (DOI) in October 2010 in an interim final rule (IFR) following the Deepwater Horizon oil spill have been written into final form with the addition of key amendments. According to the DOI’s Bureau of Safety and Environmental Enforcement (BSEE), the final action both carries over without change requirements in the IFR and includes refinements based on public comments on the IFR.

Interim final rule

The IFR established new measures to ensure that offshore drilling operations are governed by enhanced standards affecting areas such as the installation and integrity testing of well casings and cementing; certification of casings and cementing by a professional engineer; third- party verification of blind-shear ram capability and the blowout preventer (BOP); documentation of BOP inspection and maintenance; and well-control training for deepwater operations.

Offshore operators that have been in compliance with the IFR should carefully review the following changes to the IFR:

• Incorporation by reference of API’s updated Standard 65, Part 2, issued December 2010. This standard outlines the process for isolating potential flow zones during well construction. The updated standard improves the description and classification of well-control barriers and defines testing requirements for cement to be considered a barrier. Revised requirements on the installation of dual mechanical barriers in addition to cement for the final casing string (or liner if it is the final string) to prevent flow in the event of a failure in the cement. For the final casing string (or liner if it is the final string), the final rule provides that an operator must install one mechanical barrier in addition to cement to prevent flow in the event of a failure in the cement. The final rule also clarifies that float valves are not mechanical barriers.
• Revised provisions for pressure testing of casings to require the operator to perform a negative pressure test only on wells that use a subsea BOP stack or wells with a mudline suspension system instead of on all wells, as provided in the IFR.
• A new requirement that an operator must have two barriers in place before removing the BOP and that the BSEE district manager may require additional barriers.
• Extended requirements for BOPs and well-control fluids to well-completion, well-workover, and decommissioning operations to promote consistency in the regulations.

Alternative procedures

The BSEE notes that several commenters assert that compliance with standards written by the BSEE or incorporated by reference may not be feasible in certain situations and that such provisions need to be revised. The BSEE states that it intends to examine the need to revise its rules. However, pending any such future revisions, persons subject to compliance may seek BSEE approval of either alternative procedures or equipment.

Check the BSEE’s final offshore drilling safety rule.