The Department of Interior’s Bureau of Safety and Environmental Enforcement (BSEE) is proposing a “complete revision” of 30 CFR Part 250, Subpart H–oil and gas (O&G) production safety systems.  Major parts of the proposal address production safety systems, subsurface safety devices, safety device testing, and the lifecycle analysis (LCA) of safety and pollution prevention equipment. 

The Subpart H regulations were first published in 1988 and have yet to see a major revision.  As a result, the regulations have not kept pace with offshore O&G technologies, particularly those used in ultra-deepwater production.  

Subsea trees

The BSEE notes that Subpart H is particularly out of step with the development of subsea trees.  A tree is the assembly of valves, gauges, and chokes mounted on a well casinghead and used to control the production and flow of oil or gas.  There are two types of trees used in offshore production. 

Dry (surface) trees are located on the deck of the production platform; in this case, there can be direct access to valves and gauges to monitor well conditions.  Wet or subsurface trees are located on the sea floor, sometimes in depths exceeding 9,000 feet.  Direct access to wet trees is not possible, and conditions are therefore monitored from the production platform or onshore data centers. 

According to the BSEE, Subpart H does not adequately address wet tree technologies and other advances in such areas as foam fire-fighting systems, electronic-based emergency shutdown systems (ESD), subsea pumping, waterflooding, gaslift, and new alloys and equipment for high-temperature and high-pressure wells.

Contents of proposal

The proposal would make the following changes to Subpart H:

• Restructure the subpart to have shorter, easier-to-read sections based on the following headings:
  • General requirements
  • Surface and subsurface safety systems—dry trees
  • Subsea and subsurface safety systems—subsea trees
  • Production safety systems
  • Additional production system requirements
  • Safety device testing
  • Records and training
• Update and improve the safety and pollution prevention equipment (SPPE) LCA to increase the overall level of certainty that this equipment would perform as intended including in emergency situations.  The LCA involves vigilance throughout the entire life span of the SPPE, including design, manufacture, operational use, maintenance, and eventual decommissioning of the equipment.  A major component of the LCA involves the proper documentation of the entire process.  The documentation allows an avenue for continual improvement throughout the life of the equipment by evaluation of mechanical integrity and communication between equipment operators and manufacturers.
• Expand regulations to differentiate the requirements for operating dry tree and subsea tree production systems on the Outer Continental Shelf. 
• Incorporate new industry standards and update partially incorporated standards to require compliance with the complete standards.
• Add new requirements for, but not limited to, the following:
  • SPPE life-cycle and failure reporting
  • Foam fire-fighting systems
  • Electronic-based ESDs
  • Valve closure timing
  • Valve leakage rates
  • Boarding shut down valves (BSDV)
  • Equipment used for high-temperature and high-pressure wells
• Rewrite the subpart in plain language.

According to the BSEE, the proposal would implement best practices currently being deployed by industry leaders.

The proposed changed to Subpart H were published in the August 22, 2013, FR.