Regulatory Requirements and Reactivation Guidelines North Sea P&A Operations June 28 th , 2017 SPE Aberdeen 7th European Well Abandonment Seminar – Day 2 Claudio Pollio – Blue Edge S.r.l. 1
Summary • UK Regulations: Implementation of EU Directive. UK Regulatory Framework. Focus on P&A and Well Intervention. • Norwegian Regulations: Norwegian Regulatory Framework. Focus on P&A and Well Intervention. • Comparison between UK and Norwegian Regulations. • Rig Reactivation and Involvement of Class Authority. 2
UK Regulations (1) EU Directive on safety of offshore Oil & Gas operations • The 2013 EU Directive on safety of offshore Oil & Gas operations is built upon original UK provisions, and adds a few key concepts. • Each member state appoints an independent Competent Authority (CA) responsible for verification of compliance by operators and owners. • ‘Safety and Environmental critical elements’ are introduced. • Each Competent Authority shall ensure that operators and owners establish schemes for independent verification in order to: Verify suitability of Safety and Environmental critical elements. Verify Well Design and Well Control measures . • Department of Energy and Climate Change (DECC) and Health and Safety Executive (HSE) work in partnership to act as CA. 3
UK Regulations (2) UK Regulatory Framework scheme • Petroleum Act 1998 • Energy Act 2011 • Infrastructure Act 2015 • Hydrocarbons Licensing Acts • Energy Act 2016 Directive regulations 1995 • • SCR (Safety Case) PSR • • PFEER PUWER Regulations • • DCR LOLER • MAR • Industry Standards BSI, API, ISO, ASME, Norsok, ATEX • GASCET (HSE Guidelines) and Guidance Notes • Guidelines for abandonment of wells 2015 “goal setting” approach (Oil & Gas UK Guidelines) • UK Regulators: Oil & Gas authority (OGA), BEIS, HSE, DECC, OSDR (CA) 4
UK Regulations (3) Offshore Installation Regulations: SCR • The SCR 2015 applies to Oil & Gas operations in external waters, within the UK continental shelf. • SCR 2015 aims to reduce the risks to health and safety from major accident hazards. • It is an offence to operate an installation without a Safety Case accepted by the Competent Authority . • The Duty Holder (Operator or Owner) is responsible to submit the Safety Case. • The Safety Case should provide information on the arrangements for the P&A of a well. 5
UK Regulations (4) Focus on P&A and Decommissioning • The OGA provides a decommissioning road map for each stakeholder and decommissioning phase. https://www.ogauthority.co.uk/decommissioning/decommissioning-roadmap/ • GASCET guidelines provide standards, models and methodologies for the assessment of the Safety Case, such as: API Spec 6A - Specification for Wellhead and Christmas Tree Equipment. API Spec 16D - Specification for Control Systems for Drilling Well Control Equipment. API Standard 53 - Blowout Prevention Equipment Systems for Drilling Wells. Other API and standards. http://webcommunities.hse.gov.uk/connect.ti/gascet 6
UK Regulations (5) Well Control Equipment for P&A Offshore Installations and Wells (Design and Construction) Regulations 1996 • The well operator shall ensure that suitable Well Control Equipment is provided before beginning any well operation to protect against a blowout (Reg. 17). • Well Control Equipment should be deployed on all wells where there is a risk of release of flammable, explosive, toxic fluids or gasses, as well as where there is a risk of high pressure water flow. Guidelines for the Abandonment of Wells 2015 • These guidelines provide minimum criteria to ensure full and adequate isolation of formation fluids both within the wellbore and from the surface or seabed. • The assessment of flow potential should include future scenarios such as re- charging of reservoirs and re-development for hydrocarbon extraction. 7
Norwegian Regulations (1) Norwegian Regulatory Framework scheme • • Petroleum activities act Health legislation [Source: Handbook for Acknowledgement of Compliance (AoC) 2015] • • Working environment act Pollution control act Acts • The Management Regulations Regulations • The Framework Regulations • The Activities Regulations • The Facilities Regulations PSA Guidance to • Working environment regulations Regulations • Other Standards • Norsok, ISO, IEC, DNV, NOG, etc. 8
Norwegian Regulations (2) Norwegian Regulatory Framework • The operator is responsible for verification activities. The responsible party shall determine the need for and scope of verifications, as well as the verification method and its degree of independence, to document compliance with requirements in the health, safety and environment legislation. Framework Regulations § 19 • The Petroleum Safety Authority carries out supervision to ensure compliance. • High degree of freedom for satisfying the regulatory requirements. • The guidelines to the regulations are not legally binding. 9
Norwegian Regulations (3) Focus on Plug & Abandon and Well Intervention • An Application for Consent shall be submitted by the Operator to PSA for operations related to Plug & Abandon and Well Intervention activities. • An Acknowledgement of Compliance (AoC) is a declaration from the PSA which expresses the regulator’s confidence that a MOU can fulfil the requirements for petroleum operations on the NCS. • Applicable standards for Plug & Abandon and Well Intervention: Norsok D-010 – Well integrity in drilling and well operations. Norsok D-002 – Well Intervention Equipment. Norsok D-001 – Drilling Facilities. Norwegian Oil & Gas Guideline No. 070 - Design of Safety Systems. Norsok Z-013 , ISO 31000 - Risk and emergency preparedness analysis. Other Norsok and Industrial standards. 10
Norwegian Regulations (4) Well Control Equipment for P&A Norsok D-010 • Defines the requirements for the isolation of the formations, fluids and pressure for temporary and permanent abandonment. • Size and position of well barrier elements (cement plugs) are defined. • Well control requirements: Cutting/perforating the casing and retrieving seal assemblies shall be performed with active pressure Control Equipment in place to prevent uncontrolled flow from annuli between casings and into the well/riser. Norsok D-002 • Provides minimum requirements for Well Control Equipment used during abandonment operations depending on the adopted strategy (coiled tubing, wireline, snubbing). 11
UK vs. Norwegian Regulations Key Differences UK Regulations Norwegian Regulations • • The SCR applies to Oil & Gas operations Application for Consent applies to Oil & in external waters. Gas operations. • AoC is not required for fixed platforms. • • The SCR is reviewed by the CA (OSDR). An Application for Consent is processed by the PSA. • The SCR is governed by The Offshore • Installations Regulations 2015. It is governed by the PSA Framework Reg. 29 and PSA Management Reg. 25. • • CA shall ensure that operators and The responsible party shall ensure owners establish schemes for compliance with requirements and the independent verification of: need for independent verification. Environmental critical elements. Well design and well control • PSA acts as supervisor. measures. 12
Rig Reactivation (1) Fixed Platforms - Main EU Directives • Machinery Directive (machinery, safety components, lifting components, etc.). • Equipment for explosive atmospheres (ATEX) directive. • Pressure Equipment Directive (PED) covers a broad range of products such as: vessels, pressurised storage containers, heat exchangers, boilers, industrial piping, safety devices and pressure accessories. PED does not apply to Well Control Equipment • CE marking is the only marking which guarantees the machinery conforms to the requirements of the EU directives. 13
Rig Reactivation (2) MODU Lay-up status definition • Class Authorities (ABS, DNVGL) have issued guidelines for the lay- up of MODUs: The aim is to assist the operator during the lay-up activities to ease the subsequent reactivation and class renewal. Different rig conditions are addressed: cold lay-up, warm lay-up , enhanced lay-up. References: ABS Guide for lay-up and reactivation of mobile offshore drilling units – May 2016. DNVGL-CG-0290 Lay-up of Vessels – February 2016. 14
Rig Reactivation (3) Areas of attention • UKCS – SCR Review NATIONAL REQUIREMENTS • NCS – Application for Consent VERIFICATION OF COMPLIANCE • Gap analysis WITH P&A REGULATIONS (EU • Mitigations/Derogations (if needed) AND INDUSTRIAL STANDARD) SOURCING OF SUITABLE WELL • Development of technical specifications CONTROL AND/OR DRILLING • FAT EQUIPMENT • Maintenance of existing equipment RIG REACTIVATION • System Integration (new and existing equipment) • OEM involvement COMMISSIONING • UKCS: Independent verification involvement 15
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