The U.S. Department of the Interior’s Bureau of Safety and Environmental Enforcement (BSEE) defines a high-pressure/high-temperature (HP/HT) environment as any reservoir that requires completion equipment or well control equipment with an assigned pressure rating greater than 15,000 psi and/or a temperature rating greater than 350°F.
These harsher and more extreme HP/HT drilling environments present a challenge to offshore operators and service companies. To safely and successfully operate in HP/HT environments, operators cannot use existing equipment as it exceeds its capability. Operators need to redesign equipment to accommodate HP/HT conditions as well as carry out advanced planning for modified operational procedures. Additionally, HP/HT equipment must undergo design verification and validation per BSEE requirements.
For new technology as technically complex as HP/HT equipment, BSEE requires an independent third party (I3P) review to facilitate the approval process.
BSEE requires the offshore operator to nominate an I3P that is responsible for evaluating documentation pertaining to the new technology and generate a report for BSEE’s review and approval. These BSEE requirements require the operator, original equipment manufacturer and subvendors to work with the I3P and BSEE.
The independent third-party review process
For the offshore industry to safely explore HP/HT environments, it is critical for all equipment to undergo a rigorous technology qualification process.
Classification organizations are particularly well-suited to the role of I3P. As independent parties with a high level of technical expertise, classification societies can support the certification and help BSEE in the evaluation of equipment for HP/HT applications. ABS also has a similar process in place for Type Approval certification as well as a robust product management process.
ABS acts as an I3P to assist in the design qualification by reviewing design verification and validation requirements and documentation of proposed HP/HT equipment. In this I3P role, ABS must work alongside any major participants involved in HP/HT operations to verify and validate that designs follow all applicable API and ASME codes, standards and guidelines.
The I3P is required to review the material selection, design analysis methods, calculations, validation testing, fabrication process and quality assurance alongside documentation pertaining to the technology qualification provided by the equipment manufacturers. The I3P is required to generate various reports for each piece of equipment per BSEE requirements.
These I3P reports are necessary to receive final approval from BSEE in the U.S. Gulf of Mexico. The lessons learned as an I3P will help ABS establish a baseline for standardizing the certification process of HP/HT drilling equipment and other new technologies.
Lessons learned by ABS as an I3P
There have been a few challenges in the validation and verification of HP/HT technology. Some of these challenges are technical in nature while others are administrative.
One of the most important lessons learned was that the I3P needs to be a part of any HP/HT project early on. By joining the process at the beginning, the I3P can familiarize itself with the new or adapted technology from the start. Additionally, it is easier to select software tools and communicate project timelines at the outset of the project rather than closer to completion.
Communication between the original equipment manufacturer, operator and any subvendors is key. During an initial kick off meeting, ABS as the I3P and the offshore operator decide on documentation management, non-disclosure agreements and a common information sharing software.
Another challenge could be information availability, or rather a lack thereof. There may not be enough initial information to conduct a proper review—for example, reports only contain very high-level summary instead of details, calculations, etc. or if the test procedure does not include test fixture and set-up, etc.
BSEE and API codes require equipment to meet ASME design check methodology. This requirement presents a unique challenge for industry as these are new methodologies for design compare to traditional API methods. ABS has noticed that application and understanding of ASME methodology varies from manufacturer to manufacturer. This variability poses a unique challenge for the I3P, in particular for fatigue and fracture mechanics analysis.
Another lesson learned is material qualification and testing to develop required properties, in particular fatigue and fracture mechanics properties.
After a review of documentation by the I3P, the original equipment manufacturer and operator must provide a clear resolution to any comments or findings. This resolution could be a technical justification, a revised document, additional documentation, new testing, etc. Any technical meetings held to review findings should involve the key subject matter experts of the original equipment manufacturer, the I3P and the operator.
Yet again, communication is key. There should be agreement on action items and responsibilities, and ABS as the I3P should know whom is responsible for responding to ABS findings (the original equipment manufacturer, the operator or a subvendor).
Those responsible for the HP/HT project may sometimes need to take exemption from applicable codes and standards. In this case, the I3P is required to review the justification for deviation and accompanying documentation. In the final I3P report, any deviations must be disclosed to the BSEE.
BSEE and ABS serve a similar role during HP/HT projects. Both organizations seek to be a safety net for offshore operators and promote both safety and environmental protection.
One of ABS’ main objectives during these ongoing HP/HT projects is to establish a standardized certification process for HP/HT verification/ validation, materials and manufacturing processes. Certification requirements are continuously developed with the goal of improving the overall safety program for deepwater drilling and production units.
We remain committed at ABS to improving safety as the offshore industry enters new frontiers such as HP/HT environments. Class and certification can give offshore operators greater confidence that their equipment is capable of safe, dependable operations.
Harish Patel is a Senior Technical Advisor and Engineer of Corporate Offshore Technology, Drilling and Process at ABS. He has over 25 years of industry experience related to design analysis of drilling systems and equipment. He also helps develop requirements for classification and certification of various offshore technologies such as HP/HT well control and subsea equipment and managed pressure drilling systems.
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