HPHT Technology Development Approval: Verification and Validation in the Context of the BSEE Regulatory Process

摘要

The engineering, design, qualification, and implementation of drilling, completion, production, and intervention equipment for high-pressure/high-temperature (HPHT) developments is currently underway to enable next frontier of projects in the Gulf of Mexico (GoM). As HPHT technology is being developed, it is prudent to recognize that such a technology is only "of value" when it can be used and deployed, hence, create a utility. This is enabled through a robust qualification, verification and regulatory approval. Per the Code of Federal Regulations, the Bureau of Safety and Environmental Enforcement (BSEE) regulates the oil and gas, exploration, development, and production operations on the Outer Continental Shelf (OCS). BSEE has a set of well-established regulatory processes to facilitate approval of OCS major capital projects. For example, through the Deepwater Operations Plan (DWOP) BSEE grants approvals to Operators for site specific named OCS projects. Through this process, per 30 CFR 250.804, prior to equipment installation in an HPHT environment, an operator must submit detailed reports, to demonstrate that the equipment can perform in the applicable HPHT environment. Unlike historical OCS projects with pressures less than 15,000 psi and temperatures less than 350°F where subsea production equipment is governed by codes and standards referenced in 30 CFR 250.804(b), equipment required for well completion or well control in HPHT environments in most instances exceeds the ratings prescribed in these historical codes and standards. This paper discusses the requirements set forth by BSEE for Independent Third-Party (I3P) verification of HPHT equipment fitness for service as well as the distinction between 1) BSEE Acceptance of Verification of Equipment Technical Specifications and 2) BSEE Approval of the use of HPHT Equipment that meet or exceed Project Specific Functional Specifications. The necessary steps that must take place to achieve first oil for frontier project are discussed from the perspective of technical readiness. Other decision criteria are out of the scope of this paper. This paper discusses aspects of technology assessment, development, qualification, independent verification, steps that lead to technology acceptance and BSEE project approval.to.