Energy companies that are under the increasing scrutiny of the Bureau of Safety and Environmental Enforcement (BSEE), one of BOEMRE’s successor agencies, are probably well aware of all the requirements in the interim rule. Nonetheless, requirements pertaining to third-party verification of certain aspects of blowout preventers (BOPs) necessitate interactions with entities outside the company. Those interactions should be carefully monitored by compliance officers to avoid any possible miscommunication that could lead to findings of noncompliance. Independent third-party verifications must be included in applications for permits to drill (APD) submitted to BSEE.
Tasks for third parties
Under the interim rule, independent third parties develop information on two aspects of BOPs.
- They must verify that the blind shear rams installed in BOPs are capable of shearing any drill pipe in the drill hole under maximum anticipated surface pressure. Blind shear rams basically sever and seal the drill pipe. This requirement applies to both surface and subsea BOP systems. The verifying documentation must include test results and calculations of shearing capacity of all pipe to be used in the well, including correction or maximum anticipated surface pressure. The operator must include a discussion on how the drill pipe used during the shear test required the highest shear pressure and was the most difficult to shear.
- They must verify that the subsea BOP is designed for the specific equipment on the rig and compatible with the specific well location, well design, and well execution plan; that the BOP stack was not compromised or damaged from previous service; and that the BOP will operate in the conditions in which it will be used. Information showing that the shear rams are appropriate for the project must be included. The third party must also verify that the subsea BOP stack has not been damaged or compromised from previous service.
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Qualifications of third party
The applicant must provide the BSEE with the following information about the third party:
- Name and address of the individual or organization,
- Size and type of the organization or corporation,
- Previous experience as a Certified Entity, Certified Verification Agent (CVA), or similar third-party representative,
- Experience in design, fabrication, or installation of BOPs and related equipment,
- Technical capabilities (including professional certifications and organizational memberships) of the third party or the primary staff to be associated with the certifying functions for the specific project,
- In-house availability of or access to appropriate technology (i.e., computer modeling programs and hardware, testing materials, and equipment),
- Ability to perform and effectively manage certifying functions, inspections, and tests for the specific project considering current resource availability,
- Previous experience with regulatory requirements and procedures,
- Evidence that the third party is not owned or controlled by the designer, manufacturer, or supplier of the BOP system or subsystems to be inspected or tested under regulations applicable to this device or by any manufacturer of similar equipment or material,
- The level of work to be performed by the third party, and
- A list of documents and certifications expected to be furnished to the BSEE by the third party
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Choose carefully
The BSEE has made it clear that it regards BOPs as the most critical piece of equipment on a drilling rig, and inspectors will likely focus heavily on all aspects of compliance related to BOPs. Companies are advised to leave nothing to chance with the third-party verifiers they retain to ensure that no surprises occur either with the way verifications are conducted or the resulting information that will available to BSEE inspectors.