Regulatory Requirements and
Reactivation Guidelines
North Sea P&A Operations
June 28th, 2017
SPE Aberdeen 7th European Well Abandonment Seminar – Day 2
Claudio Pollio – Blue Edge S.r.l.
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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.
• 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.
EU Directive on safety of offshore Oil & Gas operations
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UK Regulations (1)
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UK Regulations (2)
UK Regulatory Framework scheme
• Petroleum Act 1998
• Infrastructure Act 2015
• Energy Act 2016
• Energy Act 2011
• Hydrocarbons Licensing
Directive regulations 1995
• PSR
• PUWER
• LOLER
Acts
Regulations
Industry Standards
and Guidance Notes“goal setting” approach
• SCR (Safety Case)
• PFEER
• DCR
• MAR
• 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)
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UK Regulations (3)
• 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.
Offshore Installation Regulations: SCR
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UK Regulations (4)
• 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
Focus on P&A and Decommissioning
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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
• 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.
Well Control Equipment for P&A
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Norwegian Regulations (1)
Norwegian Regulatory Framework scheme
Acts
Regulations
PSA Guidance to
Regulations
Standards
• Petroleum activities act
• Working environment act
• Health legislation
• Pollution control act
• The Management Regulations
• The Activities Regulations
• The Framework Regulations
• Working environment regulations
• Other
• Norsok, ISO, IEC, DNV, NOG, etc.
• The Facilities Regulations
[Sourc
e: H
andbook for
Acknow
ledgem
ent of C
om
plia
nce (
AoC
) 2015]
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Norwegian Regulations (2)
• 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.
Norwegian Regulatory Framework
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Norwegian Regulations (3)
• 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.
Focus on Plug & Abandon and Well Intervention
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Norwegian Regulations (4)
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).
Well Control Equipment for P&A
UK Regulations Norwegian Regulations
• The SCR applies to Oil & Gas operations
in external waters.
• Application for Consent applies to Oil &
Gas operations.
• AoC is not required for fixed platforms.
• The SCR is reviewed by the CA (OSDR).
• The SCR is governed by The Offshore
Installations Regulations 2015.
• An Application for Consent is processed by
the PSA.
• It is governed by the PSA Framework Reg.
29 and PSA Management Reg. 25.
• CA shall ensure that operators and
owners establish schemes for
independent verification of:
Environmental critical elements.
Well design and well control
measures.
• The responsible party shall ensure
compliance with requirements and the
need for independent verification.
• PSA acts as supervisor.
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UK vs. Norwegian Regulations
Key Differences
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.
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Rig Reactivation (1)
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Rig Reactivation (2)
• 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.
MODU Lay-up status definition
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Rig Reactivation (3)
Areas of attention
• UKCS – SCR Review
• NCS – Application for ConsentNATIONAL REQUIREMENTS
• Gap analysis
• Mitigations/Derogations (if needed)
VERIFICATION OF COMPLIANCE WITH P&A REGULATIONS (EU AND INDUSTRIAL STANDARD)
• Development of technical specifications
• FAT
SOURCING OF SUITABLE WELL CONTROL AND/OR DRILLING
EQUIPMENT
• Maintenance of existing equipment
• System Integration (new and existing equipment)RIG REACTIVATION
• OEM involvement
• UKCS: Independent verification involvementCOMMISSIONING