Regulatory Requirements and Reactivation Guidelines

Transcription

1 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

2 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

3 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

4 UK Regulations (2) UK Regulatory Framework scheme Acts Petroleum Act 1998 Infrastructure Act 2015 Energy Act 2016 Energy Act 2011 Hydrocarbons Licensing Directive regulations 1995 Regulations SCR (Safety Case) PFEER DCR MAR PSR PUWER LOLER Industry Standards and Guidance Notes goal setting approach BSI, API, ISO, ASME, Norsok, ATEX GASCET (HSE Guidelines) Guidelines for abandonment of wells 2015 (Oil & Gas UK Guidelines) UK Regulators: Oil & Gas authority (OGA), BEIS, HSE, DECC, OSDR (CA) 4

5 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

6 UK Regulations (4) Focus on P&A and Decommissioning The OGA provides a decommissioning road map for each stakeholder and decommissioning phase. 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. 6

7 UK Regulations (5) 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 Well Control Equipment for P&A 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 recharging of reservoirs and re-development for hydrocarbon extraction. 7

8 [Source: Handbook for Acknowledgement of Compliance (AoC) 2015] Norwegian Regulations (1) Norwegian Regulatory Framework scheme Acts Petroleum activities act Working environment act Health legislation Pollution control act Regulations PSA Guidance to Regulations The Management Regulations The Framework Regulations The Activities Regulations The Facilities Regulations Working environment regulations Other Standards Norsok, ISO, IEC, DNV, NOG, etc. 8

9 Norwegian Regulations (2) The operator is responsible for verification activities. Norwegian Regulatory Framework 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

10 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 Design of Safety Systems. Norsok Z-013, ISO Risk and emergency preparedness analysis. Other Norsok and Industrial standards. 10

11 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

12 UK vs. Norwegian Regulations Key Differences UK Regulations The SCR applies to Oil & Gas operations in external waters. The SCR is reviewed by the CA (OSDR). The SCR is governed by The Offshore Installations Regulations CA shall ensure that operators and owners establish schemes for independent verification of: Environmental critical elements. Well design and well control measures. Norwegian Regulations Application for Consent applies to Oil & Gas operations. AoC is not required for fixed platforms. An Application for Consent is processed by the PSA. It is governed by the PSA Framework Reg. 29 and PSA Management Reg. 25. The responsible party shall ensure compliance with requirements and the need for independent verification. PSA acts as supervisor. 12

13 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

14 Rig Reactivation (2) MODU Lay-up status definition Class Authorities (ABS, DNVGL) have issued guidelines for the layup 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 DNVGL-CG-0290 Lay-up of Vessels February

15 Rig Reactivation (3) Areas of attention NATIONAL REQUIREMENTS UKCS SCR Review NCS Application for Consent VERIFICATION OF COMPLIANCE WITH P&A REGULATIONS (EU AND INDUSTRIAL STANDARD) Gap analysis Mitigations/Derogations (if needed) SOURCING OF SUITABLE WELL CONTROL AND/OR DRILLING EQUIPMENT Development of technical specifications FAT RIG REACTIVATION Maintenance of existing equipment System Integration (new and existing equipment) COMMISSIONING OEM involvement UKCS: Independent verification involvement 15