chapter 8 - guideline for the certification of

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Rules for Classification and Construction IV Industrial Services 6 Offshore Technology 8 Guideline for the Certification of Blow-Out Preventers Edition 2011

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Page 1: Chapter 8 - Guideline for the Certification of

Rules for Classification and Construction IV Industrial Services

6 Offshore Technology

8 Guideline for the Certification of Blow-Out Preventers

Edition 2011

Page 2: Chapter 8 - Guideline for the Certification of

The following Rules come into force on May 1st, 2011

Germanischer Lloyd SE GL Noble Denton

Brooktorkai 18, 20457 Hamburg, Germany

Phone: +49 40 36149-750 Fax: +49 40 36149-280

[email protected]

www.gl-group.com

"General Terms and Conditions" of the respective latest edition will be applicable (see Rules for Classification and Construction, I - Ship Technology, Part 0 - Classification and Surveys).

Reproduction by printing or photostatic means is only permissible with the consent of Germanischer Lloyd SE

GL Noble Denton.

Published by: Germanischer Lloyd SE, GL Noble Denton Printed by: Gebrüder Braasch GmbH, Hamburg

Page 3: Chapter 8 - Guideline for the Certification of

IV – Part 6 Section 1 Chapter 8 GL 2011 Certification of Blowout Preventers Page 1 of 20

Table of Contents

Section 1 ................................................................................................................................................................. 3 Certification of Blowout Preventers .................................................................................................................... 3 1. Scope of Equipment.................................................................................................................................. 3 2. Certification Process................................................................................................................................. 3 2.1 Basis for Certification............................................................................................................................... 3 2.2 Scope of Certification ............................................................................................................................... 3 2.3 Issue of Certificate.................................................................................................................................... 3 2.4 Operational Records ................................................................................................................................. 3 2.5 Validity of the Certification...................................................................................................................... 3 3. Certification of BOPs Built under Witness of GL .................................................................................... 6 3.1 General Notes ........................................................................................................................................... 6 3.2 Witness during Manufacture..................................................................................................................... 6 4. Certification of BOPs not Built under Witness of GL .............................................................................. 6 4.1 General Notes ........................................................................................................................................... 6 4.2 Certification Procedure............................................................................................................................. 6 5. Inspections to Maintain the Validity of a Certificate ................................................................................ 7 5.1 Types of Inspection................................................................................................................................... 7 5.2 Explanations and General Requirments.................................................................................................... 7 5.3 Performance of Inspections ...................................................................................................................... 7 6. Quality Management and Workmanship .................................................................................................. 7 Section 2 ................................................................................................................................................................. 8 Principles, Normative References, Conditions, Documents .............................................................................. 8 1. General Principles..................................................................................................................................... 8 2. Rules and Regulations to be Considered .................................................................................................. 8 2.1 Rules of Germanischer Lloyd ................................................................................................................... 8 2.2 Internationally Recognised Codes and Standards..................................................................................... 8 3. Safety, Environmental and Process Conditions ........................................................................................ 9 4. Documents for Examination ..................................................................................................................... 9 4.1 Types of Documents ................................................................................................................................. 9 4.2 Components and Subassemblies ............................................................................................................... 9 5. Failure Mode and Effect Analysis (FMEA)............................................................................................ 10 5.1 General.................................................................................................................................................... 10 5.2 Description of Subsystems Relevant for the Analysis ............................................................................ 10 5.3 Block Diagrams of Relevant Subsystems ............................................................................................... 10 5.4 Analysis of the Relevant Subsystems ..................................................................................................... 10 5.5 Tabular Worksheet.................................................................................................................................. 11 5.6 Assumptions and Defined Limits for the FMEA .................................................................................... 11 5.7 Management of Change.......................................................................................................................... 11 5.8 Conclusions ............................................................................................................................................ 11 5.9 FMEA-based Test Program .................................................................................................................... 11

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Chapter 8 Section 1 IV – Part 6 Page 2 of 20 Certification of Blowout Preventers GL 2011

Section 3 ............................................................................................................................................................... 12 Design and Manufacture of Blowout Preventers.............................................................................................. 12 1. Scope ...................................................................................................................................................... 12 2. BOP Stack............................................................................................................................................... 12 2.1 Pipe Rams ............................................................................................................................................... 12 2.2 Blind Shear Rams ................................................................................................................................... 12 2.3 Annular BOP .......................................................................................................................................... 12 2.4 Connectors .............................................................................................................................................. 12 3. Guide Frame Structure............................................................................................................................ 12 4. Equipment under Pressure ...................................................................................................................... 12 5. Control Systems...................................................................................................................................... 13 5.1 Design Review........................................................................................................................................ 13 5.2 Hydraulic Control Units (HCU) ............................................................................................................. 13 5.3 Electrical Control Units .......................................................................................................................... 13 5.4 Subsea Control Pods ............................................................................................................................... 14 5.5 Umbilicals............................................................................................................................................... 14 5.6 Accumulators.......................................................................................................................................... 14 5.7 Surface Control Stations ......................................................................................................................... 14 5.8 Control Station Locations ....................................................................................................................... 14 5.8.1 Control Station Functions ....................................................................................................................... 14 5.9 Control System Response Times ............................................................................................................ 15 6. Contingency Systems.............................................................................................................................. 15 6.1 Remotely Operated Vehicles (ROVs)..................................................................................................... 15 6.2 Deadman System .................................................................................................................................... 15 6.3 Auto-Shear System ................................................................................................................................. 15 6.4 Acoustic Control System ........................................................................................................................ 15 7. Choke and Kill System ........................................................................................................................... 15 Section 4 ............................................................................................................................................................... 16 Inspection and Test of Blowout Preventers ...................................................................................................... 16 1. Inspections during Manufacture and Assembly...................................................................................... 16 1.1 Quality Plan ............................................................................................................................................ 16 1.2 Inspection and Test Plan (ITP) ............................................................................................................... 16 1.3 Non-Destructive Testing (NDT) ............................................................................................................. 16 1.4 Pressure Test........................................................................................................................................... 16 2. Factory Acceptance Test (FAT).............................................................................................................. 16 3. Site Integration Test (SIT) ...................................................................................................................... 16 4. Annual Inspections ................................................................................................................................. 17 5. Inspections for Re-Certification.............................................................................................................. 17 6. Extraordinary inspections after Modification, Repair or Major Overhaul .............................................. 17 Appendix 1........................................................................................................................................................... 19 National Regulations........................................................................................................................................... 19

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IV – Part 6 Section 1 Chapter 8 GL 2011 Certification of Blowout Preventers Page 3 of 20

Section 1

Certification of Blowout Preventers

1. Scope of Equipment These guidelines are applicable to the design, con-struction, and inspection of blowout preventers (BOPs), which are to be certified by Germanischer Lloyd (GL), including their power supply interfaces and control and monitoring system.

Blowout preventers include:

– Main body and various types of hydraulic rams and/or seals and the guide frame structure, which together form the BOP stack;

– Hydraulic accumulators and electrical batteries forming the subsea power supply system;

– Interfaces to connect wellheads and lower ma-rine riser packages/risers;

– Interfaces to connect umbilicals for external power supply, control and monitoring;

– Interfaces to allow underwater manipulation by a remotely operated vehicle (ROV);

– Choke and kill system including manually and remotely controlled valves;

– Power Supply and Control System.

2. Certification Process The certification process comprises a design review and various stage inspections during the manufac-turing of components, the assembly of the BOP stack and the commissioning of the completed sys-tem. Certificates issued need to be renewed and reconfirmed in regular intervals, at least every five years, after annual inspections have been regularly conducted with success.

2.1 Basis for Certification

The following guidelines constitute the basis for the certification of blowout preventers. For require-ments not defined in these guidelines, other rules and guidelines of GL shall be applied as far as they are applicable. The latter include Rules for Materi-als and Welding as well as other Rules issued by GL.In addition, internationally accepted codes and standards form the basis of the certification. Details are referenced in Section 2, para 2.2.

2.2 Scope of Certification

Certification covers the entire BOP stack, including its machinery components, power supply, structural

elements, and control, monitoring and interfacing equipment.

2.3 Issue of Certificate

After successful completion of the certification activities the certificate will be issued by GL. The certificate shall be kept on the site where the BOP is deployed.

2.4 Operational Records

A BOP is required to carry an operational record file in which details of the operational history (site, environmental and process parameters, mainte-nance, damages, repair) and BOP test reports are entered. The operational records shall be submitted to the GL inspector on request.

2.5 Validity of the Certification

(1) The validity of a certificate is limited to five years. The certificate will be maintained and ex-tended in its validity as long as the BOP is sub-jected to all prescribed inspections and tests, and any modifications and repairs found to be necessary are carried out to the satisfaction of GL.

(2) If the BOP is not subjected to the prescribed inspections and tests at their due dates the certifi-cate will be suspended. However, when an inspec-tion becomes due while the BOP is in use, the in-spection may be deferred until the well is com-pleted.

(3) If the BOP has sufficient damage affecting the certification or if such damage may be assumed an inspection and test shall be conducted before the BOP is redeployed. GL shall be notified of such a situation in due course.

(4) Where it is found that the BOP no longer complies with the requirements on which the cer-tificate was issued, and if the operator fails to carry out the repairs or modifications considered neces-sary by GL within a specified period to be agreed upon, the certificate will expire.

(5) If the repairs and modifications required by GL have been carried out and the BOP is subjected to a re-certification inspection or an extraordinary inspection the original certification may be rein-stated. The inspection is to be carried out in accor-dance with the scope for re-certification inspections or extraordinary inspections respectively, refer to section 4, para 5 and para 6.

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Chapter 8 Section 1 IV – Part 6 Page 4 of 20 Certification of Blowout Preventers GL 2011

(6) The validity of a certificate of a laid-up BOP continues unchanged. On request, any inspections which become due may be deferred until the BOP is reactivated for service. In these circumstances, the total scope and extent of inspections and test required thereafter, shall be determined by GL on a case-to-case basis.

(7) If a certificate has for some reason expired or has been withdrawn by GL, such a certificate shall

be returned to GL.

(8) Should the BOP and its systems have had any form of modification since its initial delivery from manufacturer, then a design review incorporating said modifications shall be conducted.

(9) Any damage and subsequent repairs shall be subject to design review with the same parameters as a design review for modifications.

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IV – Part 6 Section 1 Chapter 8 GL 2011 Certification of Blowout Preventers Page 5 of 20

Fig. 1.1 Graphical presentation of the certifica-tion process

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Chapter 8 Section 1 IV – Part 6 Page 6 of 20 Certification of Blowout Preventers GL 2011

3. Certification of BOPs Built under Witness of GL

3.1 General Notes

(1) The application for certification of a BOP is to be submitted to GL in writing by the manufac-turer or operator.

(2) A document register shall be submitted as early as possible, indicating the specifications, calculations, drawings and data sheets, which are available, or will become available, for review in the course of the project.

(3) All documents describing the BOP are to be submitted in triplicate to GL in case of paper cop-ies. Alternatively, a single electronic submission for examination is acceptable.

(4) Alterations to documents and drawings ap-proved by GL are subject to a repeated approval of GL before any works commence.

(5) An Inspection and Test Plan (ITP) is to be submitted to GL for approval and mark-up of inter-vention points (monitor, witness, hold) to be at-tended by a GL Inspector and the designated In-spection Office is to be advised in good time of tests to be performed under the witness of GL.

(6) Upon the completion of the construction works and successful testing of the BOP, GL will issue the certificate.

3.2 Witness during Manufacture

(1) Materials for new constructions, replacements and repaired parts shall be tested as defined in the GL Rules for Materials, or other proven codes and standards acceptable to GL.

(2) Parts of the BOP requiring inspection and tests witnessed by GL will be checked during manufacture for conformity with the approved documents.

(3) The separate components of the BOP are to be tested in the manufacturer’s premises for mechani-cal strength and, where appropriate, for functional-ity. For components of novel design which do not yet have a proven track record when incorporated into a BOP, GL may demand more extensive tests.

(4) The GL inspector will witness the assembly of the BOP stack and the installation of the machin-ery, control, monitoring and interfacing compo-nents as per the quality control plans and inspection and test plans. The workmanship will be examined and the required strength, tightness and functional tests shall be carried out in his presence.

(5) Upon completion of the assembly, the BOP, including all structural elements and assembled components, shall be tested in accordance with the details set out in section 4 of these guidelines.

(6) To enable the GL inspector to fulfil his duty, he shall be granted free access to the BOP and to the workshops where parts requiring inspection and tests witnessed by GL are manufactured, assembled or tested. The necessary staff and equipment shall be provided.

4. Certification of BOPs not Built un-der Witness of GL

4.1 General Notes

(1) The application for the certification of a BOP not built under the witness of GL is to be submitted to GL in writing.

(2) All documents related to the BOP are to be submitted for examination with the application for certification. The scope and depth of examination will be in accordance with sections 2, 3 and 4 of this guideline.

(3) Existing certification, its validity and any rec-ommendations which have been made conditional upon the existing certification, are to be submitted together with the application.

4.2 Certification Procedure

(1) For admission to certification, the BOP shall be inspected in accordance with the provisions of an inspection for re-certification, refer to section 4, para 5.

(2) If the BOP holds a valid certificate of another recognised Classification Society, the scope and depth of the inspections and tests of individual parts may be deferred to the due dates for annual inspec-tion.

(3) A certificate will be issued on the basis of satisfactory results from the examination of docu-mentation and on the basis of satisfactory inspec-tion and test results witnessed by a GL inspector and documented in relevant inspection reports.

(4) Once a BOP has received a GL certificate, the same regulations will apply as for BOPs built under the witness of GL.

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IV – Part 6 Section 1 Chapter 8 GL 2011 Certification of Blowout Preventers Page 7 of 20

5. Inspections to Maintain the Validity of a Certificate

5.1 Types of Inspection

(1) A BOP, which is certified by GL is to be sub-jected to the following regular inspections, if the validity of the certificate is to be maintained:

– Annual Inspection, see section 4, para 4;

– Inspection for recertification after five years, see section 4, para 5;

– Extraordinary Inspection, where the BOP or some of its components have suffered damage liable to affect serviceability and, therefore, safety, see section 4, para 6.

(2) GL reserves the right to demand extraordinary inspections. Such inspections may be credited against prescribed regular inspections.

5.2 Explanations and General Requirments

(1) The designated inspection office is to be given timely notice when regular inspections become due or when it is intended to carry out repairs or modi-fications, so that the work can be witnessed.

(2) Equipment and components are to be arranged so that they are accessible for inspections on board. Where this is either not possible or would involve inappropriate efforts, inspections may also be per-formed, upon application, in the manufacturer’s works or in another authorised workshop.

(3) The results of each inspection together with any special requirements upon which the mainte-nance of certification or its validity is conditional, will be attached to the certificate.

(4) Where parts are damaged or worn to such an extent that they no longer comply with the require-ments of these guidelines or the applicable codes and standards, they shall be repaired or replaced.

(5) Where defects are repaired on a temporary basis or where GL agrees that repairs or replace-ments are not immediately necessary, the certificate and its validity may be confirmed for a limited period of time. Such limitation will be attached to the certificate and will be removed once all the necessary works have been carried out.

5.3 Performance of Inspections

All inspections are to be performed in accor-dance with prescribed procedures against predefined ac-ceptance criteria as outlined in inspection and test plans approved by GL.

Where the operational and functional particulars differ from the standard case, the scope of inspec-tion shall be adjusted accordingly in coordination with GL. The detailed scope of the inspections and tests is addressed in section 4 of this guideline.

6. Quality Management and Work-manship

(1) The manufacturer/supplier of a BOP shall apply a valid quality management system, such as ISO 9001 or equivalent.

(2) As far as required by such a QMS, all compo-nents shall be checked and inspected by the manu-facturer’s own personnel for completeness, correct dimensions and faultless workmanship during fab-rication, assembly and completion.

(3) Afterwards, all components and equipment shall be presented to GL for inspection in suitable sections and with proper access; for pressure testing normally in uncoated conditions.

(4) The GL inspector may reject components that have not been adequately prechecked and may require the resubmission upon successful comple-tion of such prechecks and any resulting corrective actions.

(5) All significant details concerning quality and functionality shall be reflected in the manufacturing documents and shall be presented to GL during inspections.

(6) If, due to insufficient or missing information in the detail documents, the quality and functional particulars of a component are in doubt, GL may require improvements. This is valid for supplemen-tal or additional parts even when at the time of document approval these were not required or could not be required due to lack of available information.

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Chapter 8 Section 2 IV – Part 6 Page 8 of 20 Principles, Normative References, Conditions, Documents GL 2011

Section 2

Principles, Normative References, Conditions, Documents

1. General Principles

(1) BOPs are to be designed and constructed in such a way that failure of single component cannot give rise to a safety critical situation.

(2) BOPs and their components shall be designed to meet the service conditions stated in the specifi-cation.

(3) BOPs shall be designed and built to ensure safe operation and facilitate adequate inspection, maintenance and repair.

(4) A consistent set of codes and standards shall be selected for the design and construction of BOPs, avoiding overlaps, gaps and contradictions.

(5) The codes and standards applied should be the latest revision available.

2. Rules and Regulations to be Consid-ered

BOPs and their components shall always be de-signed, built, and operated to meet the national laws and statutory requirements in force in the respective countries where they are to be used. Some exam-ples of relevant legislation are referenced in appen-dix 1.

2.1 Rules of Germanischer Lloyd

The following GL Rules are valid as additional requirements for the certification of BOPs:

– GL-Rules II - Materials and Welding, Parts 1 - 3

– GL-Rules IV – Industrial Services, Part 6 - Off-shore Technology

– GL Rules I – Ship Technology, Part 5 -Unmanned submersibles (ROV, AUV) and Un-derwater Working Machines

Designs differing from GL-Rules may be permit-ted, if they provide equivalent levels of safety.

(1) Where the design of a BOP or its components is based on new principles or technologies, which have not yet been sufficiently tested in practical operation, GL reserves the right to demand addi-tional submission of documentation and the execu-tion of additional special tests.

(2) GL reserves the right to impose demands in addition to those mentioned in Rules and Guide-lines in respect of all types of BOPs when consid-ered necessary due to new knowledge or experience becoming available or to sanction deviations from Rules and Guidelines in specially justified cases.

2.2 Internationally Recognised Codes and Standards

Codes and standards applicable to the certification of subsea well control equipment may include:

– API Spec 6A/ISO 10423, Specification for Wellhead and Christmas Tree Equipment;

– API Spec 16A/ISO 13533, Specification for Drill-through Equipment;

– API 16C, Specification for Choke and Kill Sys-tems;

– API Spec 16D, Specification for Control Sys-tems for Drilling, Well Control Equipment, and Control Systems for Diverter;

– API Spec 16F, Specification for Marine Drilling Riser Equipment;

– API Spec 17D, Subsea Wellhead and Christmas Tree Equipment;

– API RP 49, Recommended Practice for Drilling and Well Servicing Operations Involving Hy-drogen Sulphide;

– API RP 53, Recommended Practices for Blow-out Prevention Equipment Systems for Drilling Wells;

– API RP 59, Recommended Practice for Well Control Operations;

– ISO 13628-4, Petroleum and Natural Gas Indus-tries - Design and Operation of Subsea Produc-tion Systems - Part 4: Subsea Wellhead and Tree Equipment

– ISO 13628-5, Petroleum and Natural Gas Indus-tries - Design and Operation of Subsea Produc-tion Systems - Part 5: Subsea Umbilicals

– ISO 28781, Petroleum and Natural Gas Indus-tries - Drilling and Production Equipment - Sub-surface Barrier Valves and Related Equipment

– NACE MR 01-75, Petroleum and Natural Gas Industries – Materials for Use in H2S-Containing Environments in Oil and Gas Pro-duction.

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IV – Part 6 Section 2 Chapter 8 GL 2011 Principles, Normative References, Conditions, Documents Page 9 of 20

3. Safety, Environmental and Process Conditions

All safety, environmental and process conditions shall be submitted with the application, based on the codes and standards mentioned above. If infor-mation is not known or complete at time of submit-tal, GL shall be notified when such data can be expected.

4. Documents for Examination GL reserves the right to request documents and/or records in addition to those mentioned here below, as needed, to confirm that equipment, systems, and components under examination are in compliance with statutory regulations, codes and standards, GL-Rules and other normative references for the speci-fied operating conditions.

4.1 Types of Documents

The types of documents to be submitted to GL for independent design review shall comprise, but not be limited, to the following:

(1) Design specifications and data sheets, includ-ing material specifications;

(2) Design drawings, schematics, calculations, including general arrangement and assembly draw-ings;

(3) BOP system configuration;

(4) Quality Plan (QP);

(5) Inspection and Test Plan (ITP);

(6) Procedures for

Pressure Tests (internal and external over-pressure)

Function Tests

Factory Acceptance Test (FAT)

Site Integration Test (SIT)

(7) Material Test Records (MTR);

(8) NDT Records;

(9) Certificates of Conformance;

(10) Service History (if applicable) regarding:

Operation and Maintenance

Modifications and Repairs

Preservation and Storage

4.2 Components and Subassemblies

The documents listed above shall be submitted for:

(1) BOP stack comprising, but not limited to:

Annular BOP

Pipe Rams

Shear Rams

Bonnets

Actuators and Stems

Connectors to Wellheads and Lower Ma-rine Riser Package

Guide Frame Structure

(2) BOP Control System comprising, but not limited to:

Overall Control System

Surface control Stations

Accumulators

Actuators

Hydraulic Hoses

Valves and Fittings

Hydraulic Power Units

Control Pods

(3) Contingency Systems

Interface Panels for docking of and inter-vention by ROVs

Dead Man System

Auto Shear System

Acoustic Signal Transmission System, if installed

(4) Choke and Kill System comprising, but not limited to:

Valves and Fittings

Choke

Choke and Kill Lines

Choke and Kill Hoses

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Chapter 8 Section 2 IV – Part 6 Page 10 of 20 Principles, Normative References, Conditions, Documents GL 2011

5. Failure Mode and Effect Analysis (FMEA)

5.1 General

(1) A FMEA shall be executed in an early stage during the design in order to allow for system modifications in due time. A tabular form, e. g. according to IEC 60812, is to be used.

(2) The objective of the FMEA is to identify possible failures in the total system, in subsystems and in components of the complete BOP system, and to describe the effects and consequences of such failures. Additionally, the FMEA should high-light any measures proposed to be taken during the design stage to alleviate the likelihood of occur-rence and the severity of the effects of the respec-tive failure modes.

(3) Equivalent safety studies (e. g. HAZOP) may be acceptable, provided an equivalent stringence with regard to systematics and coverage can be demonstrated.

5.2 Description of Subsystems Relevant for the Analysis

(1) The FMEA shall represent an independent document and be understandable without consulting further documentation. This means that the basic functions of all relevant subsystems shall be de-scribed together with details of the installed redun-dancies and especially the interfaces between the subsystems.

(2) The description shall provide the operating personnel with a good overview of the structure and the functionality of the relevant subsystems of a BOP. For all subsystems, typical failure modes and their effects on the overall function of the BOP shall be indicated. The corrective actions to manage these failures and their effects shall be described.

(3) For BOPs, the following subsystems are rele-vant for maintaining the overall functional integrity:

– Guide frame;

– Systems for control and monitoring;

– Vessels and apparatus under pressure;

– Piping systems, fittings;

– Umbilicals;

– Electrical installations;

– Emergency power supply;

– Interface equipment for umbilicals and ROVs.

The system descriptions are to be complemented by block diagrams as mentioned below.

5.3 Block Diagrams of Relevant Subsystems

For each relevant subsystem, a block diagram shall be established. This block diagram shall contain the essential information of the system, which is re-quired for the failure analysis, and normally com-prises:

– Definitions of the subsystems;

– All essential components of the subsystems;

– Interfaces between the components of the sub-systems;

– Interfaces to or from other subsystems (typical for hydraulics and controls);

– Arrangements for control of the total system;

– Supplies from outside the total system;

– Further aspects depending on the actual design of the BOP stack.

5.4 Analysis of the Relevant Subsystems

The following essential aspects of each relevant subsystem shall be analysed. Any further aspects that are identified during the execution of the analy-sis shall also be analysed. See sample work sheet (Table 2.1):

– Failure of subsystems;

– Malfunction of subsystems;

– Failure of components in a subsystem;

– Malfunction of components;

– Interface failures between the subsystems, a subsystem and its components as well as be-tween components themselves. Interface analy-sis is of particular importance, as experience shows that many failures are created due to lack of information about data, medium and power transferred or how failures are spread via the in-terfaces to other subsystems and components;

– Hidden failures and potential means to make them self-revealing;

– Practicality of alarms for certain failures and arrangement of periodic testing where alarms are not suitable or practical;

– Failures initiated by external influences which may lead to simultaneous failure of redundant subsystems (common cause failures), like changed environmental conditions and their control, voltage and frequency fluctuations in power supply, contamination of supply media, etc.

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IV – Part 6 Chapter 8 GL 2011 Principles, Normative References, Conditions, Documents Page 11 of 20

5.5 Tabular Worksheet

The analysis shall be documented in tabular form. A typical work sheet is shown in Table 2.1. Similar

forms are acceptable as long as they are practical and follow the formats laid out in IEC 60812. the analysis shall consider all operational modes.

ID No. Subsystem Component

Type of Failure

Failure Cause

Failure Detection

Consequences for Total System

Consequences for Subsytem or Component

Failure Correction

Remarks

1 2 3 4

Table 2.1 Sample FMEA Worksheet

5.6 Assumptions and Defined Limits for the FMEA

For the FMEA, the assumptions are to be defined which set the frame and define the limits. Typical assumptions are:

– The operating personnel are qualified and trained to safely and competently operate the equipment;

– The settings and switching operations pre-scribed in the operations manual are followed by the operating personnel;

– The power supply system has a well defined degree of availability through redundancy.

5.7 Management of Change

In case of changes, modifications, repairs to the design and construction of the BOP, the relevant sections of the FMEA shall be updated accordingly.

In case of changes of the environmental and process parameters to values outside the design and operat-ing envelope, the relevant section of the FMEA shall be changed accordingly.

5.8 Conclusions

The FMEA shall contain a summary of the results of the analysis for the BOP. In addition, it should contain a listing of the main failures which may occur during the operation of the BOP. Training measures to handle events in case of such failures are to be proposed for the operating personnel aboard the drilling unit. A periodic check of the FMEA including practical trials is recommended.

5.9 FMEA-based Test Program

A test program shall be established that is aligned with the FMEA. The purpose of this program is to verify the assumptions and the expected operational behaviour of the BOP as defined in the FMEA.

The test program shall consider typical failure modes in the relevant systems and components including the worst case failure. All operational modes of the BOP shall be considered.

The test program shall be agreed with GL and shall specify in detail how the test will be carried out and/or how the simulation is done as an alternative for certain aspects of functional behaviour.

These specified tests shall be included in the factory acceptance test procedure.

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Chapter 8 Section 3 IV – Part 6 Page 12 of 20 Design and Manufacture of Blowout Preventers GL 2011

Section 3

Design and Manufacture of Blowout Preventers

1. Scope For the design of the BOP and all its additional sys-tems and components, a detailed specification shall be provided, which shall include the limiting pres-sure and temperature conditions.

Blowout preventers and additional pressurised equipment shall be designed in accordance with API RP 53 ‘Recommended Practices for Blowout Pre-vention Equipment Systems for Drilling Wells’ and additional subordinated recognised technical stan-dards.

All materials for the construction of a BOP and all its associated components shall be suitably selected in accordance with the chemical and physical data of the flowing media and shall comply with interna-tionally recognised standards. All materials, which may come into contact with the well fluid, shall be suitable for sour service. The requirements outlined in the NACE Standard MR0175/ISO 15156 are to be observed accordingly.

2. BOP Stack In general, all elements of the BOP stack, including flanges, valves, spools, adapters, clamps, etc. should conform to the requirement of API 16A or equiva-lent with regard to design, fabrication, testing and documentation.

2.1 Pipe Rams

The BOP stack shall conform to configurations illus-trated in API RP 53. It shall consist of at least two pipe rams with mechanical locking devices. Each set of pipe rams shall be capable of closing and sealing against at least one of the pipe sections in the hole. Each BOP stack shall have at least one pipe ram capable of closing and sealing against all pipe sec-tions to be run through the BOP stack.

Pipe rams must be capable of suspending the weight of a specified length of drill string when closed.

2.2 Blind Shear Rams

Each blind shear ram must be capable in a single operation of shearing, and sealing against pressure from below, the largest section of the highest grade pipe to be run in the well through the BOP when the specified control system pressure is available. Documentation shall be supplied verifying the fact.

2.3 Annular BOP

Annular BOPs are usually mounted above the Blind-Shear Rams and consist of a synthetic rubber blad-der reinforced with steel ribs.

Annular BOPs are either of ‘Wedge Type’ or ‘Spherical Type’. Either is acceptable insofar as they conform to the requirements of API Spec 16A with respect to design, fabrication, testing, and documen-tation.

2.4 Connectors

The BOP connectors that interface to the wellhead and to the lower marine riser package shall conform to the requirements of API 6A with respect to de-sign, fabrication, testing, and documentation.

3. Guide Frame Structure

The BOP guide frame, a four-post structure attached to the BOP assembly, is a means for guiding the complete BOP/LMRP assembly’s primary alignment onto the permanent guide base. The guide frame structure also acts as the structural mounting for the various components of the remote control system, and the choke and kills connectors and stab subs.

The guide frame structure shall have sufficient strength to protect the BOP stack from damage dur-ing handling and landing operations. However, the guide frame structure should not be considered as part of the well bore structure, because under operat-ing conditions the BOP elements shall have the required bending strength based on maximum riser tension and angle.

The BOP guide frame is to be designed in accor-dance with AISC or another equivalent recognised structural standard.

4. Equipment under Pressure

Blowout preventers and all associated pressurised equipment (vessels, piping, hoses, etc.) shall be de-signed in accordance with recognised technical stan-dards, e. g. ASME, BS 5500, PED or equivalent.

Design conditions shall account for the maximum working pressure and temperature.

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Hoses to be connected and disconnected shall be de-signed with quick-release self-sealing couplings to ensure a tight shut-off and sealing in operation and easy handling by personnel.

5. Control Systems All equipment for the control and monitoring of a BOP shall be designed and constructed in accor-dance with this guideline, the suitable standards (e. g. API 6A and 16D or equivalent) and the specifica-tions in accordance with the design and environ-mental conditions specified for the BOP and its environment. Additionally, the guidance and rec-ommendations put forth in API RP 53 should be considered as part of the path to certification and re-certification.

The BOP control system shall consist of a dual-pod arrangement.

A second and independent system for intervention by remotely operated vehicles (ROVs) shall be pro-vided.

All equipment shall be designed, manufactured, tested and commissioned according to the proce-dures of the equipment manufacturer approved by GL and relevant regulatory requirements.

5.1 Design Review

The BOP Control and Monitoring System shall un-dergo a design review prior to the start of fabrica-tion, which shall be conducted in accordance with this guideline and all applicable codes and standards.

The design review of the Electrical, Instrumentation and Control Systems shall include, but is not limited to the following:

(1) Batteries including installation, arrangement and details, where provided, to include charging apparatus, ventilation and corrosion protection;

(2) Arrangement plans showing location of units controlled, instrumentation and control devices;

(3) Specifications for control and instrumentation equipment;

(4) Set points for control system components;

(5) Appropriate elements addressed in the Failure Modes and Effects Analysis (FMEA);

(6) Calculations for control systems demonstrating the systems’ ability to react adequately to anticipated occurrences, including transients. Documentation shall include but is not limited to volumetric capac-

ity calculations, reservoir sizing, hydraulic and elec-trical analysis;

(7) Arrangements and details of control consoles, including views and installation arrangements to-gether with schematic plans and logic description for all power, control and monitoring systems, including their functions;

(8) Type and size of all electrical cables and wir-ing associated with the control systems, including voltage rating, service voltage and currents, together with overload and shortcircuit protection;

(9) Schematic plans and logic description of hy-draulic and pneumatic control systems together with all interconnections, piping sizes and materials, including working pressures and relief valve set-tings;

(10) Description of all alarm and emergency trip-ping arrangements and functional layouts, and de-scription of all special valves, actuators, sensors and relays.

5.2 Hydraulic Control Units (HCU)

The Hydraulic Control Unit (HCU) supplies a stable, regulated, filtered fluid. This fluid is supplied via a system of hydraulic lines and an umbilical to BOP mounted subsea accumulators.

The hydraulic system shall be robust and maintain the specified pressure values and volume flows.

The HCU reservoir shall include provisions for ob-taining, and maintaining, the specified cleanliness requirement, such as drainage or circulation and filtration capability, should the fluid become con-taminated. Output fluid from the HCU reservoir shall be prepared to a cleanliness level as defined in SAE AS 4059. The selected cleanliness level shall be according to the manufacturer’s written specifica-tion. Working fluid volumes shall comply with API RP 53.

The HCU may be considered as a second control panel.

5.3 Electrical Control Units

The electrical control units shall have a central con-trol point. Alternatively, each control panel may communicate directly and independently with each control pod.

The electrical control unit shall be supplied with electrical power from an uninterruptable power supply (UPS). The UPS battery backup shall be capable of running the system for at least two hours after loss of main power supply. The UPS shall be monitored from a remote manned location with, as a

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minimum, alarm reporting of main power supply failure and internal UPS failure.

5.4 Subsea Control Pods

The BOP stack shall provide two completely inde-pendent and redundant control pods. Each pod shall contain all necessary valves and controls to operate the BOP stack functions. Each control pod shall be colour coded (e. g. Yellow and Blue), suitable for easy ROV identification subsea.

The failure of one subsea control pod shall not affect the safe operation of the other pod and a means of isolating the failed pod shall be provided.

The control pods may be retrievable or non-retrievable.

5.5 Umbilicals

In general, the subsea umbilicals ensure hydraulic and electrical power supply, communications, and control of the subsea control pods.

Some systems may combine hydraulic and electrical services in one umbilical, while other systems may separate the supply of hydraulic fluid into a rigid conduit assembly on each riser joint.

In each case, the electrical conductors and electrical insulation as well as any hydraulic hose or tubing assemblies shall not be used as load bearing compo-nents in the umbilical assembly.

Two control umbilicals shall be provided, connect-ing to the two subsea control pods to the surface control stations. Two methods of providing subsea fluid power to the subsea pods shall be provided. These systems may be rigid hydraulic conduits or hydraulic umbilical hoses.

Umbilical strain relief and over-bending protection shall be provided for the interface between umbilical and subsea pod.

The umbilical shall be designed and fabricated in ac-cordance with ISO 13628-5, Subsea Umbilicals, or equivalent.

5.6 Accumulators

Accumulator systems are required for subsea BOP stacks. The volume and pressure capacities for all subsea accumulators shall be suitable to ensure that specified valve closing times are met, in accordance with API 16D or equivalent.

Accumulator calculations for Deadman, Autoshear and some acoustic systems, which are classified as rapid discharge systems, shall follow Method C in API 16D.

Details of the specified drill string to be used after BOP certification shall be used when evaluating ac-cumlator performance, because metallurgical differ-ences in drill string pipe from different manufactur-ers may require recalculation due to different shear ram closing pressure.

A dedicated accumulator system with appropriate volume and pressure shall be provided for BOP sys-tems with a rapid secondary disconnect function. Additionally, when the BOP system features a two shear ram arrangement, volumetric calculations shall include both sets of shear rams.

5.7 Surface Control Stations

There shall be at least two distinct and separate BOP control stations for all BOP functions. The stations shall be mutually independent of each other. Func-tions shall have physical barriers on the buttons to prevent accidental activation of disconnect func-tions.

5.8 Control Station Locations

The first control station shall be located adjacent to the drilling console while the second control station shall be located near the main hydraulic supply unit for the BOP.

If a third panel, which may have limited functional-ity, is installed for emergency operations, it should be installed remote from the rig floor.

Access to either control station shall not require per-sonnel to cross the drill floor or cellar deck.

If any of the control stations is located in a desig-nated hazardous area, it shall comply with the rele-vant codes and standards for exprotection.

5.8.1 Control Station Functions

Control station panels shall include, as a minimum but not limited to, the following functions:

– Close/open of all rams, annular preventers and choke and kill valves;

– Mechanical locking of rams;

– Primary disconnect of the Lower Marine Riser Package;

– Emergency Disconnect (only on floating rigs);

– Provision of audible and visual alarms for, as a minimum, low fluid level in reservoirs, loss of power supply and low accumulator pressure.

Enable buttons shall be provided on the panels for all critical functions such that two-handed operations are necessary. All functions on the panels shall be clearly labelled.

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Secondary additional protection against inadvertent operation of riser disconnects and shear ram func-tions shall be provided on the control panels.

Further functions as per API 16D shall be consid-ered.

5.9 Control System Response Times

For Subsea Blowout Preventers the following sys-tem response times shall be achieved under the con-sideration of the accumulator design and control system internal delays:

– Closing of each ram BOP shall be achieved in less than 45 seconds;

– Closing of an annular BOP shall be achieved in less than 60 seconds;

– Operating times for choke and kill valves shall not exceed the minimum observed ram BOP closing times;

– The time to unlatch the Lower Marine Riser Package shall not exceed 45 seconds.

For Surface Blow Out Preventers shorter times are stipulated in API 16D and shall be observed accord-ingly.

Conventional measurement of response time begins when the function is activated at any control panel and ends when the read back pressure gauge recov-ers to its nominal setting. Response times are based on fully charged accumulators, design water depth and minimum temperatures.

6. Contingency Systems

6.1 Remotely Operated Vehicles (ROVs)

All subsea BOPs shall be equipped with Remotely Operated Vehicle (ROV) intervention capability. The intervention provision shall be such that the ROV shall be capable of closing one set of pipe rams, closing one set of blind-shear rams, and unlatching the lower marine riser package.

A multi-function ROV operating panel shall be mounted in an accessible location on the BOP stack and the panel shall be clearly marked for identifica-tion by the ROV cameras.

All ROV interfaces shall comply with the require-ments of ISO 13628-8. Their markings shall comply with the requirements of ISO 13628-1, Table B.1.

6.2 Deadman System

A deadman system is defined as a safety system that is designed to automatically close the blind-shear rams in the event of a simultaneous absence of hy-draulic supply and signal transmission capacity in both subsea control pods.

A deadman system shall be installed for BOPs used on floating drilling units.

6.3 Auto-Shear System

An auto-shear system is defined as a safety system that is designed to automatically shut in the well in the event of an unplanned disconnect of the Lower Marine Riser package (LMRP).

When the auto-shear system is armed, a disconnect of the LMRP shall cause the auto shear system to close the shear rams.

If, based on operator and rig procedures, the choke and kill valves are not automatically closed in this instance, which is an option based on API 16D, this shall be explicitely mentioned and justified.

An auto-shear system shall be installed for BOPs used on floating drilling units.

6.4 Acoustic Control System

Floating rigs may use an acoustic system, optionally, in addition to deadman and auto-shear, as an emer-gency backup to control critical BOP functions. Ac-cumulator requirements for this system shall meet the recommendations for acoustic system subsea accumulators in API 16D. Additional requirements for this type of system can also be found in API 16D and should be observed.

7. Choke and Kill System

In general, all elements of the choke and kill system, including flanges, valves, spools, adapters, clamps, and chokes shall conform to the requirements of API 16C or equivalent.

Each of the choke or kill lines shall have two valves of fail-to-close type, mounted in series close to the BOP stack in a position which protects them from dropped objects. They shall be hydraulically oper-ated and opened against spring force.

For maximal valve closing times refer to 5.9.

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Section 4

Inspection and Test of Blowout Preventers

1. Inspections during Manufacture and Assembly

Inspections and test of BOPs shall be carried out ac-cording to the following documents, to ensure that the BOP meets all design particulars approved by GL:

– Quality Control Plan (QCP);

– Inspection and Test Plan (ITP).

1.1 Quality Plan

The Quality Plan is a fundamental element of the QA system of the BOP manufacturer.

The Quality Plan should outline all QA activities that will be implemented within the design and fab-rication procedure of the BOP and its associated components.

The quality Plan shall be specific for a project.

1.2 Inspection and Test Plan (ITP)

All inspections and tests to be carried out during manufacture and assembly shall be listed in an In-spection and Test Plan. This ITP shall include and outline all specific tests and inspections which have to be performed during manufacture and assembly with reference to test procedures, standards, specifi-cations and acceptance criteria.

Furthermore, each test step shall provide information about the requirements for reviewing the test docu-mentation and the specific monitoring and witness-ing points by GL.

The ITP shall be submitted to GL for review and mark up of interventions (Monitor, Witness, Hold) within a reasonable notification period.

1.3 Non-Destructive Testing (NDT)

All non-destructive test (NDT) reports and subse-quent inspections shall be signed and dated, and be provided as part of the BOP stack dossier. Inspection reports shall include the name, qualifications, and contact information of the personnel who performed the testing. The scope of the NDT shall be as de-tailed on the inspection and test plan (ITP). All inci-dents and out of specification conditions shall be documented along with the remedial actions taken to correct the situation.

The ITP shall be signed and dated by the party per-forming the NDT, and by the manufacturer. At

points where the witnessing of a GL inspector is required, he will sign the ITP once the activity is successfully completed.

The qualifications of personnel performing NDT shall be either included in the NDT documentation or shall be traceable to equivalent records.

1.4 Pressure Test

Pressure test reports shall clearly show calibration results, test medium, time of test at pressure, test temperature, minimum test pressure required, and actual test pressure attained. GL shall be invited well in advance to witness pressure testing. Pressure testing shall be performed in unpainted conditions.

2. Factory Acceptance Test (FAT)

The BOP and all its associated equipment, including the control systems and contingency systems shall be subjected to a Factory Acceptance Test. All func-tions shall be tested during the FAT. Usually, this is executed while the BOP stack is mounted on a stump.

The scope of tests, the test conditions, procedures and acceptance criteria shall be based on the service and operating conditions and shall be submitted to GL for review and approval well in advance.

The scope of testing shall also include those items which result from the FMEA, refer to section 2, para 2.5.9.

Provided that certified evidence can be presented about the capability of the shear rams to cut off the drill string specified in the design documentation, such a test needs not to be executed and a normal function test of the shear ram operation is sufficient.

The FAT shall be carried out in presence of a GL in-spector who shall be invited well in advance.

3. Site Integration Test (SIT)

A site integration test shall be executed upon arrival of the BOP at a drilling location for the first time after completion of the FAT. The SIT has the objec-tive to demonstrate that the BOP and all associated control systems are fully functional on the location

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and are suitable for the specific well design and drilling programme.

The SIT comprises a comprehensive stump test on board of the drilling rig and an initial test on the sea-floor.

The scope of tests, the test conditions, procedures and acceptance criteria shall be based on the service and operating conditions and shall be submitted to GL for review and approval well in advance.

The initial test on the seafloor shall demonstrate, as a minimum, that the rams, the annular preventers, the choke and kill valves and deadman system are functioning correctly.

The SIT shall be conducted in the presence of a GL inspector who shall be invited well in advance.

4. Annual Inspections

The Annual Inspection of a BOP includes at least the following tests and checks, witnessed by GL:

(1) Examination of the documents relating to the BOP, including its surface control systems and scru-tiny of the operational history with BOP test reports and BOP maintenance records;

(2) Visual inspection of the guide frame, all fix-tures, covers, lifting points, claddings, etc. for dam-age, cracks, deformation, corrosion attacks and foul-ing;

(3) Check of the measures for corrosion protection (e. g. anodes);

(4) The BOP is to be pressure tested on its stump.

(5) All vessels and apparatus under external or internal overpressure, penetrations, valves, fittings and relevant safety equipment are to be subjected to external inspection.

(6) Check that insulation measurements have been performed on the electrical equipment;

(7) Review of control systems and of the set points of the alarm sensors;

(8) Change over from the main to the emergency electrical power supply is to be tested.

(9) The accuracy of all essential instrument read-ings is to be checked.

(10) All rams and annual preventers and the discon-nect system for the Lower Marine Riser Package

with their associated control systems, including deadman and auto-shear systems, shall be function-tested.

(11) The interfaces which allow a ROV to connect and perform overrides shall be function tested.

(12) Hose assemblies shall be checked for visible damages.

(13) The umbilicals shall be checked for visible damages, cracks, deformations and corrosion.

(14) Where applicable, acoustic backup control sys-tems shall be function tested.

(15) Upon successful completion of the Annual Inspection, the validity of the certificate will be confirmed.

(16) When an annual inspection becomes due while the BOP is in use, the inspection may be deferred until the well is completed.

5. Inspections for Re-Certification Every five years, an Inspection for Re-Certification shall be carried out, witnessed by GL. In addition to the annual inspections defined in para 4 above, the following tests and examinations shall be carried out:

(1) For vessels and apparatus under pressure, which cannot be satisfactorily inspected internally or for which their satisfactory condition cannot be fully verified by internal inspection, another non-destructive test method shall be used or a hydraulic pressure test shall be performed.

(2) Check shall be performed that accessories, especially hose assemblies and compensators have been changed according to the maintenance plan.

Upon satisfactory completion of the Inspection for Re-Certification, the validity of the certificate will be extended for another period of five years.

6. Extraordinary inspections after Modification, Repair or Major Over-haul

After modifications, repair or major overhaul, a BOP shall be subjected to an extraordinary inspection, witnessed by GL.

The scope and depth of the inspection shall be de-veloped in close cooperation between the holder of the certificate and GL.

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Additionally, in case of modifications it will be necessary to conduct a design review of those com-ponents and subsystems affected by the modifica-tions.

The scope and depth of this design review shall be determined by GL with the objective of confirming the compliance of the overall system with this guide-line.

The scope of inspections and tests shall be derived from the original tests during manufacturing, the

factory acceptance tests and the system integration tests as outlined in para 1, 2, 3 above. Due con-sideration will be given to avoid the unnecessary duplication of tests, where previous test results re-main valid.

In case of repairs, the spares used shall be acceptable to the original equipment manufacturer. Alterna-tively, non-OEM parts shall be subjected to a design review and to tests as outlined in para 1, 2, 3 above, and defined in a dedicated inspection and test plan which shall be subject to approval by GL.

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Appendix 1

National Regulations

This Appendix contains references to the national regulations of some countries. These should not be considered complete, but only as a possible starting point for each license holder. Statutory requirements may change any time, and should be investigated from case to case to ensure that the references used are current and complete.

In Australian waters, the regulators are the Na-tional Offshore Petroleum Safety Authority and also the regions including Government of Western Aus-tralia, Department of Mines and Petroleum. Key Regulations include, but may not be limited to:

– Petroleum (Submerged Lands) “Management of Safety on Offshore Facilities” Regulations 2007;

– Petroleum (Submerged Lands) “Management of Well Operations” Regulations 2004.

The approach requires ‘good oil field practice’ sup-ported by a Safety Case to ALARP, with independ-ent verification.

In Brazilian waters, the regulators are Agência Na-cional do Petróleo, Gás Natural e Biocombustiveis (ANP). Key Regulations include, but may not be limited to:

– Resolution No. 43;

– Technical resolution Safety Management System (SGSO);

– CONAMA Resolution No. 23: Licensing of drilling and production activities.

The approach is goal-setting, with reliance on indus-try standards and the requirement for risk analysis.

In Canadian waters, the regulators are the National Energy Board, the Canada Nova Scotia Offshore Petroleum Board and the Canada Newfoundland & Labrador Offshore Petroleum Board. Key Regula-tions include, but may not be limited to:

– Canada Oil and Gas Operations Act (COGOA);

– SOR/2009-315 Canada Oil & Gas Drilling and Production Regulations;

– Draft Safety Plan Guidelines;

– Draft Drilling and Production Guidelines.

Section 36.1 of the Safety Plan Guidelines lists In-dustry Standards and Practices that may be used; these are mostly API, together with NACE Standard MR0175.92m Item No. 53024 & NORSOK 010;

The majority of the Drilling and Production Regula-tions are written in a goal- or performance-based style with clear regulatory objectives or goals. Goal-oriented regulation is a hybrid approach that in-cludes prescriptive and goal- or performance-based elements. The prescriptive elements are retained in the management system elements, information re-quirements for reporting and in information re-quirements related to applications for authorisations and well approvals.

In Danish waters, the regulator is the Danish En-ergy Agency. Key Regulations include, but may not be limited to:

– Offshore Safety Act No. 1424 of December 21, 2005 with subsequent amendments;

– Executive Order No. 729 of 3rd July 2009;

– Guidelines for the Design of Fixed Offshore Installations 2009;

– Guidelines for Drilling – Exploration 1988 (2009), attachment to “A Guide to Hydrocarbon Licenses in Denmark”.

The approach requires a Safety Case to ALARP and the use of recognised standards.

In Indonesian waters, the regulator is effectively BP MIGAS and the requirements are usually set in Production Sharing Contracts.

It is understood that the approach requires ‘best oil-field practice’.

In Norwegian waters, the regulators are the Norwe-gian Petroleum Directorate (NPD) and the Petro-leum Safety Authority (PSA). Key Regulations in-clude, but may not be limited to:

– Regulations Relating To Design And Outfitting Of Facilities Etc. In The Petroleum Activities (The Facilities Regulations) Chapter IV-I, Sec-tions 48 – 55 and Guidelines thereto. This refer-ences NORSOK D-001, D-002 and D-010, with additional requirements to D-001;

– Regulations Relating To Conduct Of Activities In The Petroleum Activities (The Activities Regulations) Section 9 and Guidelines thereto – Chapter 4 / Sect. 30a and Chapter 7 /Section 46;

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– Regulations Relating To Material And Informa-tion In The Petroleum Activities (The Informa-tion Duty Regulations) Chapter III Section 7 & Guideline thereto. Refers to reporting according to NORSOK D-010;

There are extensive references to other standards (mainly API & NORSOK but some from ANSI, ASME, ISO, NACE, NS & TBK).

An overall objective for drilling and well activities will be the requirement that no single failure shall entail a life threatening situation for the involved personnel, or significant damage to material and the environment. This applies to both operations errors and to failure in connection with the equipment used directly in operations, as well as equipment with auxiliary functions. Safety systems are to be pro-vided with two independent levels of protection to prevent or minimise the effects of a single malfunc-tion or fault in the process equipment and piping system, including their controls. The two levels of control are to be provided by functionally different types of safety devices to reduce the probability of common cause failures.

In UK waters, the regulator is the Health & Safety Executive (HSE). Key Regulations include, but may not be limited to:

– SI 1996/913 The Offshore Installations and Wells (Design and Construction, etc.) Regula-tions 1996 (DCR).

The approach uses a Safety Case to ALARP. The Duty Holder must show that the Performance Stan-dards are suitable and sufficient, which is done through the application of industry standards or alternatively more detailed assessment, to show that the residual risk not removed by the safety system is as low as reasonably practicable (ALARP). Wells are covered by a separate Well Examination Scheme under DCR requiring examinations by independent and competent persons.

In US waters, the regulator under the Department of Interior (DOI) is the Bureau of Ocean Energy Man-agement, Regulation and Enforcement (BOEMRE). The BOEMRE has two separate functional bureaus:

– Bureau of Ocean Energy Management (BOEM) will be responsible for managing development of the nation’s offshore resources;

– Bureau of Safety and Environmental Enforce-ment (BSEE) for enforcing safety and environ-mental regulations.

Key regulations include, but may not be limited to:

– 30 CFR Part 250 - Oil and Gas and Sulphur Op-erations in the Outer Continental Shelf;

– NTL No. 2010-N10 US Department of the Inte-rior BOEMRE, National Notice to Lessees and Operators of Federal Oil and Gas Leases, Outer Continental Shelf, "Statement of Compliance with Applicable Regulations and Evaluation of Information Demonstrating Adequate Spill Re-sponse and Well Containment Resources", No-vember 08, 2010;

– NTL No. 2009-G07, US Department of the Inte-rior Minerals Management Service Gulf of Mex-ico OCS Region, National Notice to Lessees and Operators of Federal Oil and Gas Leases, Outer Continental Shelf, Gulf of Mexico OCS Region, "Location of Choke and Kill Lines on Blowout Preventer Stacks", May 1, 2009.

The regulations require adherence to a number of API RP's and Specs.