OTC 22758

Safety Enhancement to Offshore Drilling Operations Harish Patel, Man Pham, Milton Korn, Paul Waters, Bibek Das, American Bureau of Shipping

Copyright 2011, Offshore Technology Conference This paper was prepared for presentation at the Offshore Technology Conference Brasil held in Rio de Janeiro, Brazil, 4–6 October 2011. This paper was selected for presentation by an OTC program committee following review of information contained in an abstract submitted by the author(s). Contents of the paper have not been reviewed by the Offshore Technology Conference and are subject to correction by the author(s). The material does not necessarily reflect any position of the Offshore Technology Conference, its officers, or members. Electronic reproduction, distribution, or storage of any part of this paper without the written consent of the Offshore Technology Conference is prohibited. Permission to reproduce in print is restricted to an abstract of not more than 300 words; illustrations may not be copied. The abstract must contain conspicuous acknowledgment of OTC copyright.

Abstract

In the ongoing process of the offshore industry to improve safety aspects of drilling operations, ABS continues to

provide support by developing enhanced safety requirements. This paper addresses the latest research that ABS performed to

enhance its understanding of critical safety aspects in drilling operations and subsequent utilization of the results in updating

the ABS Guide for the Classification of Drilling Systems (ABS CDS Guide).

Several U.S. government regulatory initiatives have been implemented relative to offshore drilling operational safety.

Other governmental regulators have also taken a similar approach in assessing their existing regulations with the focus on

safety improvements. In parallel, the revised ABS CDS Guide provides updated safety requirements to assist industry to (1)

improve overall safety in drilling operations and (2) meet regulatory compliance for the drilling systems.

ABS commenced the criteria revision process with a gap-analysis between the existing offshore drilling practices and

technology (including deepwater), applicable U.S. and worldwide regulations, recognized industry codes and standards, etc.

Additionally, a survey was conducted with manufacturers, operators, and drilling contractors to identify main areas where the

safety aspect of drilling operation could be improved. Based on the research and survey, industry’s participation was a

critical element in the rule making process – it provided insight into various safety issues, concerns in drilling operations and

improved understanding between the industry and the regulators or Class society. From this process, ABS was able to

develop additional measures to enhance existing criteria for drilling operations, while adopting a holistic approach to the

classification process of drilling systems and equipment with consideration to the applicable regulatory initiatives.

This paper outlines the currently developing regulatory changes to the U.S. drilling industry that may potentially impact

worldwide drilling activities. This paper highlights the new safety requirements from our research and from the U.S.

regulatory perspective, including: BOP recertification, maintenance, and testing, API RP 53 rewrite to API Spec 53 for

adoption into the U.S. CFR, management of safety and environmental systems of API RP 75, safety case initiatives and the

role of third-party certification. This paper discusses the adoption of a performance-based standard for offshore drilling

operations in conjunction with the current prescriptive regulatory regime.

Introduction Historically, incidents often lead to reforms and/or revisions of existing regulations and standards. In the U.S., the

blowout on the Platform A-21 in the Santa Barbara Channel in January 1969 resulted in a large oil spill. Reforms from the

Platform A-21 incident resulted in the passage of the National Environmental Policy Act (NEPA). In July 1988, the accident

on Piper Alpha, in the UK sector of the North Sea, led to significant changes to the North Sea safety procedures, with

enforcement of these changes delegated to the United Kingdom Health and Safety Executive (UK HSE). Similarly, the

Macondo incident in the U.S. resulted in a range of reforms to the U.S. regulatory scheme for the offshore drilling industry.

The offshore drilling industry has also taken the initiative to revise and update existing recommended practices, codes and

standards associated with offshore drilling operations.

ABS recognizes that there is a need to assist the offshore industry by developing enhanced criteria which can lead to

improved safety aspects of drilling operations. As the offshore industry seeks the development of hydrocarbon reserves in

deeper water and harsher environments through advancements in offshore technology, ABS also recognizes the need to

maintain our Rules with the main intent of providing for the safety and security of life, property and the natural environment.

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Through a re-examination of current technology and experience, ABS has updated the ABS MODU Rules and the ABS CDS

Guide. This paper focuses on the update of the ABS CDS Guide as is specific to drilling operations.

This paper discusses the background of regulatory requirements along with initiatives by ABS, U.S. regulatory bodies

and industry code and standards committees to assist the offshore industry in achieving safety enhancements in offshore

drilling operations through the updating of rules, regulations, codes and standards. Offshore Regulatory and Safety Regimes

Offshore regulatory regime focus on safety in the maritime and offshore industry comes through many layers from the

international level, which facilitates and regulates international safety goals, to class societies that develop and establish rules

to provide for the structural and mechanical integrity of the complete marine and/or offshore structure, to industry codes and

standards that provide technical requirements to provide for the structural and mechanical integrity of specific equipment or

components. To protect the interests of its territorial waters, local jurisdictions also institute rules and regulations to promote

safety in the maritime and offshore industry within its own regions. Finally, the maritime vessel or offshore structure

owners/operators also have established their own technical, operating and maintenance requirements in order to protect their

people, operations and capital assets. Figure 1 – Regulations and Rules for Drilling Units, illustrates the various regulations

and rules that may be applied to a drilling unit.

International Maritime Organization

The offshore regulatory regimes begin on an international level with the International Maritime Organization (IMO),

which develops and maintains a comprehensive international regulatory framework for the maritime and offshore industries.

The IMO establishes regulations with the main focus of providing for safety at sea and the protection of the marine

environment. This is accomplished through various regulations such as:

• IMO Mobile Offshore Drilling Unit (MODU) Code

• International Convention for the Safety of Life at Sea (SOLAS)

• Convention on the Prevention of Maritime Pollution (MARPOL)

• International Ship and Port Facility Security Code (ISPS)

Class Society Rules / Flag State

Classification is a process which certifies adherence of a ship or other type of marine or offshore structure to a

recognized and independent set of technical standards and/or rules. The classification process is intended to promote

maritime and offshore safety. This process includes:

• The development of standards, know as Rules

• Technical plan review and design analysis

• Verification for compliance to the classifications

standards

• Survey during construction

• Source inspection of materials, equipment/machinery

• Acceptance by the Classification Committee

• Subsequent periodic survey for maintenance of class

• Survey of damage, repairs and modifications

In addition, the classification process can also assist in compliance with statutory requirements as many nations mandate

that vessels entering into their registry be classed. Classification societies often serve as “recognized organizations” for Flag

States; in this role the societies administer various statutory requirements.

Local Jurisdictions

Once the marine or offshore structures are operating in a nation’s territorial waters, the relevant port or coastal state has

jurisdiction. The local government establishes regulations to provide for safe operation of the marine and offshore structures

in their waters. For the United States, the Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMRE)

and the United States Coast Guard (USCG) are the primary authorities regulating offshore drilling activities in the U.S. Gulf

of Mexico (GoM), with the U.S. Environmental Protection Agency (EPA) also providing specific regulations relating to

environmental issues. For Norway, the Petroleum Safety Authority (PSA) is the organization which has responsibilities over

drilling operations and major safety and environmental risks. For the United Kingdom, the HSE has jurisdiction. Similarly,

other nations such as Australia, Canada and Brazil have authorities responsible for regulation of drilling operations and

protection of the environment.

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Industry Codes and Standards

Within industry, there exist technical codes, standards, specifications, and recommended practices with the main focus of

providing structural and mechanical integrity in the design, manufacturing and testing of various equipment and components.

Specific to the oil and gas industry, the American Petroleum Institute (API) has in its library approximately 500 technical

standards covering all aspects of structural and mechanical integrity. In addition to API, there is the International

Organization for Standardization (ISO), the American Society of Mechanical Engineers (ASME), and European Norm (EN)

with standards that cover related topics as well as other disciplines and industries.

Drilling Operators Drilling rig owners and operators have a vested interest in protecting their assets while performing offshore energy

exploration and development. In this regard, drilling rig owners and operators also apply their own technical requirements,

often based on past experience, in conjunction with other regulations as referenced above, to promote safety in their drilling

operations. These technical requirements may consist of standard operating procedures (SOPs) and corporate risk

management policies. These may cover elements of protection of life, protection of assets, safety and social awareness,

quality management systems, etc. ABS Guide for Classification of Drilling Systems

In updating the ABS CDS Guide it is recognized that there are many regulatory requirements governing the offshore

drilling industry, which may vary from region to region and between regulatory agencies. In addition to the differences in

regulatory requirements, drilling practices vary from one owner/operator to another. Further, existing offshore drilling

industry codes and standards are typically component-based. Within a drilling system, many components or equipment are

assembled and combined into a system to perform the intended service. However, codes and standards on a system-based

level have generally been lacking.

“Gap Analysis”

In order to better serve the offshore industry, understanding the challenges within the industry and ultimately providing

enhancement to the safety of offshore drilling operations, ABS commenced the ABS CDS Guide update project with a gap-

analysis between the existing ABS CDS Guide and various U.S. and worldwide regulations that included those of the U.S.

from USCG and BOEMRE, UK HSE, PSA, and NOPSA. ABS also performed a gap-analysis between the ABS CDS Guide

and existing industry recommended practices, codes and standards that included the API and the ISO, as applicable to the

drilling systems. Key points from the gap analysis include:

• ABS CDS Guide and U.S. regulations are prescriptive requirements while UK HSE, PSA, and NOPSA are mainly

performance-based with supplementary prescriptive requirements.

• ABS CDS Guide and U.S. regulations do not mandate performing risk identification and provide risk mitigation

measures, while this is a mandatory requirement for UK HSE, PSA, and NOPSA.

Industry-Wide Survey

In addition to the gap-analysis, ABS also conducted an industry survey of oilfield equipment manufacturers, drilling

operators and drilling contractors to identify industry concerns that may need improvement in an update of standards for

drilling operations. Industry’s participation was an important element in the rule making process in that it provided an

improved understanding between the industry and ABS on the latest practices and expectations. From this process, ABS

developed improved criteria related to safe drilling operations, while adopting a holistic approach to the classification process

of drilling systems and equipment. Some key feedback from the industry survey includes:

• While industry codes and standards are available for equipment at the component level, there are generally no codes or

standards available to address the integration of this equipment into systems and/or sub-systems

• Well control and its back-up systems needs enhancement

• Specific testing requirements should be specified for testing:

- at equipment manufacturer’s facility

- during installation at shipyards

- during commissioning

- during system integration test

• Detailed verification or certification requirements for equipment and component should be provided.

• Specific control system requirements and testing of control systems should be provided

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• Additional marinization aspects for the

ABS CDS Guide Update – March 2011 Upon completion of the work associated with the gap analysis and the updating efforts, ABS published the latest edition

of the ABS Guide for the Classification of Drilling System

The latest ABS CDS Guide includes a change from its predecessor with the introduction of a holistic approach to the

classification process of drilling systems through a system

with the ABS MODU Rules and covers drilling systems in connection with drilling and well testing operations

the requirements of API, ASME, ANSI, ISO, etc.

and marine experience. The applications of various rules and regulations for

– Regulations and Rules for Drilling Units.

Figure

ABS Classification Process

Classification is a process which independently

technical standards known as rules, from the design phase, survey throughout the fabrication and up to final survey at

commissioning. Certification of the drilling systems as an optional part of the overall classification process under the

requirements of the ABS CDS Guide is summarized in

Figure

dditional marinization aspects for the drilling systems and associated equipment should be addressed

Upon completion of the work associated with the gap analysis and the updating efforts, ABS published the latest edition

tion of Drilling System in March 2011.

includes a change from its predecessor with the introduction of a holistic approach to the

classification process of drilling systems through a system-based methodology. The ABS CDS Guide

and covers drilling systems in connection with drilling and well testing operations

the requirements of API, ASME, ANSI, ISO, etc., with additional requirements based upon past experience,

applications of various rules and regulations for a typical drilling unit are illustrated in

Figure 1 – Regulations and Rules for Drilling Units

independently certifies adherence of a vessel or offshore structure

known as rules, from the design phase, survey throughout the fabrication and up to final survey at

commissioning. Certification of the drilling systems as an optional part of the overall classification process under the

is summarized in Figure 2 - ABS Classification Process of Drilling System

Figure 2 - ABS Classification Process of Drilling System

should be addressed

Upon completion of the work associated with the gap analysis and the updating efforts, ABS published the latest edition

includes a change from its predecessor with the introduction of a holistic approach to the

CDS Guide is used in conjunction

and covers drilling systems in connection with drilling and well testing operations. It is based on

past experience, industry practice

are illustrated in Figure 1

of a vessel or offshore structure to a recognized set of

known as rules, from the design phase, survey throughout the fabrication and up to final survey at

commissioning. Certification of the drilling systems as an optional part of the overall classification process under the

ABS Classification Process of Drilling System.

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Once the drilling systems are in operation or service condition, ABS continues to perform survey of the drilling systems,

subsystems, equipment and/or components as part of maintenance of Class. In

Units and Drilling Systems, a typical schedule is shown for ABS survey activities

Figure 3 - Progression of

ABS CDS Guide Structure

The ABS CDS Guide provides a comprehensive approach to the classification of the drilling systems, sub

equipment and components, for the wellbore fluid’s path starting from the wellhead

including the well circulation systems and control systems. The Guide also provides technical requirements for pipe handling,

rotating, hoisting, and lifting.

This holistic approach to the classification process covers the drilling system including the i

subsystems. The overall structure of ABS

support systems and support systems. Each system is composed of various subsystems, equipment and component

illustrated in Figure 4 - ABS CDS Guide Structure.

nce the drilling systems are in operation or service condition, ABS continues to perform survey of the drilling systems,

subsystems, equipment and/or components as part of maintenance of Class. In Figure 3 - Progression of Surveys

, a typical schedule is shown for ABS survey activities.

Progression of Surveys for Drilling Units and Drilling Systems

provides a comprehensive approach to the classification of the drilling systems, sub

equipment and components, for the wellbore fluid’s path starting from the wellhead and progressing to the top of the derrick

including the well circulation systems and control systems. The Guide also provides technical requirements for pipe handling,

This holistic approach to the classification process covers the drilling system including the i

subsystems. The overall structure of ABS CDS Guide is divided into three (3) major systems: well control system, drilling

support systems and support systems. Each system is composed of various subsystems, equipment and component

Structure.

Figure 4 - ABC CDS Guide Structure

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nce the drilling systems are in operation or service condition, ABS continues to perform survey of the drilling systems,

Progression of Surveys for Drilling

provides a comprehensive approach to the classification of the drilling systems, sub-systems,

progressing to the top of the derrick,

including the well circulation systems and control systems. The Guide also provides technical requirements for pipe handling,

This holistic approach to the classification process covers the drilling system including the integration of associated

well control system, drilling

support systems and support systems. Each system is composed of various subsystems, equipment and components, as

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Safety Principles

To define the general design principles for the overall drilling systems is to define the intent from the system and sub

system levels down to the equipment and component levels. The

industry can apply in their design of the drilling system and associated subsystems. These principles include:

• General arrangement and equipment layout to reduce potential effects of events, reduce ignition hazards and

consequences

• Design of well control systems so that no single point failure will lead to

• Primary and secondary controls are to be provided for well control systems i.e., mud circulations, BOPs, etc.

• Two levels of protection for systems

• Drill control systems are to be “fail safe” designed with consideration for the systems’ intended services

• Zone management principles are to be followed for all hoisting, lifting, and pipe handling activities

ABS has identified major features that are made

• “Autoshear” and “Deadman” systems are mandatory well control

(DP) units

• Additional shear-ram is to be provided for

• Failure Mode Effect Analysis (FMEA)

performed for the complete well control system

Drill Systems and Subsystems

While the original equipment manufacturers (OE

various packaged equipment into the drilling unit.

Within the drilling systems, various systems and/or subsystems

wellhead through the flow path of the fluids. This starts with the well control system and associated equipment. Typical we

control systems include the mud circulation system and

mud circulation is the primary means of well control and the BOP is the secondary well control system. The well control

systems typically consist of the BOPs, lower marine riser package (LMRP), ch

associated auxiliary well control equipment. The

complete well control system down to the integrity of individual equipment based on appli

associated control systems (see Figure 5 - Well Control System)

.

To define the general design principles for the overall drilling systems is to define the intent from the system and sub

system levels down to the equipment and component levels. The Guide has defined some general safety principles that the

drilling system and associated subsystems. These principles include:

General arrangement and equipment layout to reduce potential effects of events, reduce ignition hazards and

ell control systems so that no single point failure will lead to failure or loss of system availability

Primary and secondary controls are to be provided for well control systems i.e., mud circulations, BOPs, etc.

ill control systems are to be “fail safe” designed with consideration for the systems’ intended services

Zone management principles are to be followed for all hoisting, lifting, and pipe handling activities

made to be prescriptive requirements within the Guide:

systems are mandatory well control requirements for floating and dynamically

ram is to be provided for floating and DP units

), Failure Mode Effect Criticality Analysis (FMECA) or similar analysis is to be

complete well control system and all computer-based systems

While the original equipment manufacturers (OEMs) will provide their packaged equipment, the shipyard will integrate

various packaged equipment into the drilling unit. ABS has identified this aspect as requiring a system

Within the drilling systems, various systems and/or subsystems work in combination to support

wellhead through the flow path of the fluids. This starts with the well control system and associated equipment. Typical we

mud circulation system and the BOP system. From a safety perspective, ABS has defined that

mud circulation is the primary means of well control and the BOP is the secondary well control system. The well control

systems typically consist of the BOPs, lower marine riser package (LMRP), choke and kill systems, diverter system and

associated auxiliary well control equipment. The Guide provides detailed requirements on the classification process for the

complete well control system down to the integrity of individual equipment based on applicable API standards, including the

Well Control System).

Figure 5 - Well Control Systems

To define the general design principles for the overall drilling systems is to define the intent from the system and sub-

has defined some general safety principles that the

drilling system and associated subsystems. These principles include:

General arrangement and equipment layout to reduce potential effects of events, reduce ignition hazards and

system availability.

Primary and secondary controls are to be provided for well control systems i.e., mud circulations, BOPs, etc.

ill control systems are to be “fail safe” designed with consideration for the systems’ intended services

Zone management principles are to be followed for all hoisting, lifting, and pipe handling activities

requirements for floating and dynamically-positioned

or similar analysis is to be

Ms) will provide their packaged equipment, the shipyard will integrate

ABS has identified this aspect as requiring a system-based approach.

to support drilling operations from

wellhead through the flow path of the fluids. This starts with the well control system and associated equipment. Typical well

safety perspective, ABS has defined that

mud circulation is the primary means of well control and the BOP is the secondary well control system. The well control

oke and kill systems, diverter system and

provides detailed requirements on the classification process for the

cable API standards, including the

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In addition to the well control system, the

drilling operations. The drilling support systems

that aid in the storage, movement, assembly and rotation

Drilling Support Systems). The Guide again provides detailed requirements o

drilling support system including the integrity of individual equipment based on applicable API stan

associated control systems.

Marinization

The drilling systems and associated equipment

production units with drilling capability

consideration to the marinization aspects for

applicable to equipment operating either on land

aspects of this equipment for operating in an

Limited space aboard marine and offshore units is a

The general arrangement or equipment layout is

equipment spacing relates to hazardous area classifications

prevention, etc. Recognizing the importance of these issues and understanding that drilling unit designs

Guide provides guidance on the general arrangement of drilling equi

Guide for Risk Evaluations for the Classification of Marine

Applications for the Marine and Offshore Oil and Gas Industries

Other marinization aspects include suitability of equipment to operate in an offshore dynamic environment.

provides requirements for applicable additional loads, motions

material requirements for equipment, piping, etc. with consideration to marine application

in industry codes and standards.

New Technology

ABS recognizes that the offshore drilling industry is advancing at a rapid pace

gradient drilling (DGD) and managed pressure drilling

and in harsher environments. In particular, implementation of DGD drilling

lowering the cost of drilling in deep water by

optimization of cement operations.

However, new technology or novel concept

when classing a vessel or offshore structure through processes detailed in

Novel Concepts (Novel Concepts Guide) and

Offshore Oil and Gas Industries. This guidance

In addition to the well control system, the integrity of the drilling support systems is equally critical in

systems typically comprise of hoisting, lifting, rotating and pipe

, assembly and rotation of the drill pipes used in normal drilling operation

again provides detailed requirements of the classification process for the complete

the integrity of individual equipment based on applicable API stan

Figure 6 - Drilling Support Systems

The drilling systems and associated equipment are installed on mobile offshore drilling units (MODUs)

and therefore, the Guide has also provided classification requirements with

consideration to the marinization aspects for offshore operating conditions of the equipment. While the API standards are

pplicable to equipment operating either on land-based or offshore drilling sites, ABS has to consider the marinization

n offshore marine environment.

Limited space aboard marine and offshore units is a critical consideration for equipment installation and safe operation.

he general arrangement or equipment layout is often important to the overall safety of the entire offshore drilling

to hazardous area classifications, escape and egress routes, fire and blast protection,

etc. Recognizing the importance of these issues and understanding that drilling unit designs

guidance on the general arrangement of drilling equipment layout. Other ABS publications

Guide for Risk Evaluations for the Classification of Marine-Related Facilities and ABS Guidance Notes on Risk Assessment

Applications for the Marine and Offshore Oil and Gas Industries provide further guidance on this aspect.

Other marinization aspects include suitability of equipment to operate in an offshore dynamic environment.

provides requirements for applicable additional loads, motions, etc. to consider for equipment design and installation in addition to

etc. with consideration to marine applications. These issues are not typically addressed

ABS recognizes that the offshore drilling industry is advancing at a rapid pace, developing new technology

pressure drilling to explore for and to develop hydrocarbon reserves at greater water depth

articular, implementation of DGD drilling offers significant benefits

deep water by reduction of the number of casing strings, reduction of non productive time, and

novel concepts come with new challenges and/or additional risks. ABS addresses new concepts

when classing a vessel or offshore structure through processes detailed in the ABS Guidance Notes on Review an

and ABS Guidance Notes on Risk Assessment Application for the Marine and

This guidance provides industry with a recognized risk assessment process and

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equally critical in supporting safe

typically comprise of hoisting, lifting, rotating and pipe handling systems

illing operations (see Figure 6 -

the classification process for the complete

the integrity of individual equipment based on applicable API standards, along with their

mobile offshore drilling units (MODUs) and offshore

has also provided classification requirements with

operating conditions of the equipment. While the API standards are

ABS has to consider the marinization

installation and safe operation.

to the overall safety of the entire offshore drilling plant as

, escape and egress routes, fire and blast protection, escalation

etc. Recognizing the importance of these issues and understanding that drilling unit designs vary; the latest

pment layout. Other ABS publications, such as the ABS

Guidance Notes on Risk Assessment

guidance on this aspect.

Other marinization aspects include suitability of equipment to operate in an offshore dynamic environment. The Guide

etc. to consider for equipment design and installation in addition to

. These issues are not typically addressed

new technology such as dual

develop hydrocarbon reserves at greater water depths

significant benefits to the industry by

tion of non productive time, and

. ABS addresses new concepts

Guidance Notes on Review and Approval of

Guidance Notes on Risk Assessment Application for the Marine and

recognized risk assessment process and

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methodology for identification of the inherent risk levels and associated mitigation measures of the novel concept, including,

where applicable, to drilling operations. ABS has provided these provisions in the latest ABS CDS Guide.

Risk Assessment

The updated CDS Guide requires the performance of a FMEA (Failure Modes and Effect Analysis) for systems and associated

equipment for drilling and well control. This also includes associated electrical control systems and computer-based control and

safety systems. An FMEA workshop identifies the potential failure modes, causes, consequences and safeguards to protect and

mitigate against that failure. A FMECA (Failure Modes, Effects and Criticality Analysis) is an extension of FMEA to assign a

criticality ranking to the failure mode based on the likelihood of occurrence of the cause and the severity level associated with the

consequence of failure on a system and equipment level. A FMEDA (Failure Mode, Effects and Diagnostic Analysis) is an

extension of FMEA for computer-based safety systems to assess the diagnostic coverage. It is to be noted that the latest Guide

places emphasis on the appropriate safety integrity level for these computer-based safety systems to be determined by the

application of recognized industry standard, such as IEC 61508 or ANSI/ISA 84 series.

FMEA/FMECA can be performed using both the functional and the comprehensive hardware approaches to cover the impacts

on systems/sub-systems and down to component levels, respectively. When major modifications to the rig/MODU that may

affect classification are to be carried out after the issuance of Classification Certificate, the Guide requires that

FMEA/FMECA for that particular system or equipment be revisited.

FMEA/FMECA can also include the human interfaces to assess operations. Based on the project phase, operating experience

and failure data history, the intensification and quantification of FMEA/FMECA to assess the aspects of redundancy, repair time,

availability, etc. increases. The results of the FMEA/FMECA add valuable information when drafting or revising preventive

maintenance plans, spare capacities, etc. The ABS Guidance Notes on Risk Assessment Application for the Marine and

Offshore Oil and Gas Industries gives further information on FMECA workshop documentation.

ISQM / SV Notations With the advancement in technology used to control and achieve greater efficiency in drilling systems, engineering

designers are increasingly relying upon computer-based integration on modern drilling units. As these computer-based

systems are reaching significant complexity, increased risk can result if the reliability of these systems and their performance

in normal and emergency conditions is not fully considered.

The mechanical and structural integrity aspects of drilling systems and associated equipment can be validated through

numerous industry codes, standards and class rules; and, as many systems are combined to perform a specific task, the

integrity of the control system of this equipment is an area that ABS recognized as an important element to the overall safety

of the drilling operations. In order to assist the drilling industry verify the control system software, ABS is publishing the

Guides for Integrated Software Quality Management (ISQM) and System Verification (SV).

ABS’ Guide for Integrated Software Quality Management (ISQM) is a notation to manage the development of complex

control systems software using an internationally recognized process that facilitates early discovery of concept errors and

software defects. Owners and operators are seeking confidence in the real-time control systems to reliably perform under

various drilling operations where the control systems are dispersed in equipment supplied by many different suppliers, each

with its own requirements. Detailed program descriptions, software and integration verification are key elements of ISQM,

providing added confidence in the control systems. ISQM is based on quality design, software development with

verification, and structured maintenance of software to support a safe and viable control system.

The ABS Guide for System Verification provides details on the optional “SV” notation that may be assigned to vessels or

offshore facilities for specific systems or integrations of systems that meet the requirements of the Guide. The “SV”

notation is one part of a two part ABS strategy of system oversight; the “SV” notation complements and supplements the

optional ABS “ISQM” notation. The ABS “SV” notation may be used independently of or in conjunction with the ABS

“ISQM” notation.

The “SV” notation provides a methodology for managing systems both during the initial construction/installation/-

commissioning, and throughout their life cycle, addressing change of systems in a systematic fashion to provide to

stakeholders a higher degree of confidence that the systems will perform in a specified manner when the systems are in an

operational, degraded or failed state.

The “SV” notation applied independently of the “ISQM” notation offers the opportunity to uncover defects and provide

remediation prior to deployment and costly non productive time; it also allows for optimization and selection of system

alternatives. The “SV” notation applied in conjunction with the “ISQM” notation provides additional confidence of proper

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system operation and offers opportunities to reduce non-productive time by building upon the “ISQM” notation methodology

that reduces the number of software defects.

United States Offshore Regulations A result of the Macondo incident has been a wide range of reforms to the United States offshore regulatory scheme requiring

additional safety enhancements for the US offshore drilling industry. The first change was the reorganization of the Mineral

Management Services (MMS), which is part of the Department of Interior, into three (3) independent entities with specific tasks:

1. Office of Natural Resources Revenue (ONRR), responsible for collecting royalties, rents, and other revenues from

mineral resources.

2. Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMRE), formerly MMS, responsible for

managing the development of conventional and renewable energy and mineral resources on the U.S. Outer Continental

Shelf (OCS) and enforcement of policy, rules and regulations related to safe and environmentally sound development of

U.S. OCS resources. The final phase of U.S. regulatory reorganization is expected to occur in October 2011, when

BOEMRE will be further divided into two separate entities:

2a. Bureau of Ocean Energy Management (BOEM) will be responsible for managing the development of conventional

and renewable energy and mineral resources on the U.S. OCS.

2b. Bureau of Safety and Environmental Enforcement (BSEE) will be responsible for enforcement of policy, rules and

regulations related to safe and environmentally sound development of U.S. OCS resources.

Department of Interior Safety Measures Report

The first investigative report of the Macondo incident came from the Department of

Interior within 30 days of the incident. The DoI Increased Safety Measures for Energy

Development on the Outer Continental Shelf, or the Safety Measures Report, of May 2010

provided recommendations to improve the safety of offshore drilling operations, and these

recommendations included:

1. Blowout preventer equipment and emergency systems

a. Certification of subsea BOP stack

b. New safety equipment requirements and operating procedures

c. New testing guidelines and inspection procedures

2. Procedures to ensure adequate physical barriers and well control systems are in

place to prevent oil and gas from escaping into the environment

a. Well-control guidelines and fluids displacement procedures

b. Well design and construction

c. Wild-well intervention

3. Organizational and safety management

a. Increase enforcement of existing safety regulations and procedures

b. Organization management

c. Personnel accountability procedures for operational safety (risk, injury, and spill prevention)

Notice to Lessees (NTL)

Shortly after the release of the DoI Safety Measures Report, BOEMRE issued its first Notice to Lessees (NTL) relating to

the Macondo incident. Notices to Lessees and Operators, or NTL's, are formal documents that provide clarification,

description or interpretation of a regulation or OCS standard; provide guidelines on the implementation of a special lease

stipulation or regional requirement; or provide a better understanding of the scope and meaning of a regulation by explaining

BOEMRE’s interpretation of a requirement. In this regard, NTL No. 2010-05 addressed recommendations from the Safety

Measures Report that warranted immediate implementation; however, the expiration date of NTL No. 2010-05 was

December 31, 2010 with some of the requirements specified in NTL No. 2010-05 codified into the Interim Final Rule

(Drilling Safety Rules).

Subsequently, NTL No. 2010-06 was issued with the effective date of June 18, 2010 and with a revised expiration date of

February 28, 2014. NTL No. 2010-06 requires the lessee/operator to submit for BOEMRE approval its Exploration Plan

(EP), Development and Production Plans (DPP) and Development Operations Coordination Documents on the OCS (DOCD)

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which are to consider the worst-case blowout scenario descriptions and a proposed or approved Oil Spill Response Plan

(OSRP).

Another NTL issued relating to DoI Safety Measures Report is NTL No. 2010-10, Statement of Compliance with

Applicable Regulations and Evaluation of Information Demonstrating Adequate Spill Response and Well Containment

Resources. NTL No. 2010-10 requires that the lessee/operator attest that they will comply and conduct drilling operations in

accordance with applicable regulations for a floating facility in the OCS through a statement signed by an officer of the

company and is to be included with every application for a well permit. NTL No. 2010-1 was enacted November 08, 2010

with an expiration date of November 08, 2015.

Interim Final Rule – Drilling Safety Rules

The first major U.S. regulation derived from the recommendations provided in the DoI Safety Measures report was the

development of the Drilling Safety Rules which was subsequently formulated into the Interim Final Rule for incorporation into the

U.S. Code of Federal Regulation (CFR), [30CFR Part 250 (Oil and Gas and Sulphur Operations in the Outer Continental Shelf -

Increased Safety Measures for Energy Development on the Outer Continental Shelf; Final Rule) published in October 2010].

The Interim Final Rule addresses requirements for two main areas, wellbore integrity and well control equipment, including

well control procedures to enhance safety of drilling operations. The specific provisions in the Interim Final Rule as related

to wellbore integrity are:

1. Incorporating by reference API RP 65—Part 2, Isolating Potential Flow Zones During Well Construction;

2. Submission of certification by a Registered Professional Engineer that the casing and cementing program is appropriate

for the purpose for which it is intended under expected wellbore pressure;

3. Requirements for two independent test barriers across each flow path during well completion activities (also certified by

a Registered Professional Engineer);

4. Ensuring proper installation of the casing or liner in the subsea wellhead or liner hanger;

5. Approval from the District Manager before displacing kill-weight drilling fluid; and

6. Deepwater well control training for rig personnel.

The provisions in the Interim Final Rules that addresses well control equipment include:

1. Submission of documentation and schematics for all control systems;

2. A requirement for independent third-party verification that the blind shear rams are capable of cutting any drill pipe in

the hole under maximum anticipated surface pressure (MASP);

3. A requirement for a subsea BOP stack to be equipped with ROV intervention capability. At a minimum, the ROV must

be capable of closing one set of pipe rams, closing one set of blind-shear rams, and unlatching the Lower Marine Riser

Package (LMRP);

4. A requirement for maintaining an ROV and having a trained ROV crew on each floating drilling rig on a continuous

basis;

5. A requirement for autoshear and deadman systems for dynamically positioned rigs;

6. Establishment of minimum requirements for personnel authorized to operate critical BOP equipment;

7. A requirement for documentation of subsea BOP inspections and maintenance according to API RP 53, Recommended

Practice for Blowout Prevention Equipment Systems for Drilling Wells;

8. Required testing of all ROV intervention functions on the subsea BOP stack during the stump test, and testing at least

one set of rams during the initial test on the seafloor;

9. Required function testing of autoshear and deadman systems on the subsea BOP stack during the stump test and testing

the deadman system during the initial test on the seafloor; and

10. Required pressure testing if any shear rams are used in an emergency.

Workplace Safety Rules

The second major U.S. regulation resulting from the DoI Safety Measures report is the Workplace Safety Rules which

require offshore drilling operators to develop and maintain a Safety and Environmental Management Systems (SEMS) based on

API RP 75, Recommended Practice for Development of a Safety and Environmental Management Program for Offshore

Operations and Facilities.

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The Bureau of Offshore Energy Management (BOEM) is adopting API RP 75, and will commence enforcement in

November 2011. The SEMS management system is applicable to all operators/lessees in the OCS on new and existing

facilities, and this includes drilling, production, construction, well workover, well completion, well servicing, and pipeline

activities. Specifically, SEMS applies to all OCS drilling facilities, temporary or permanent, under BOEMRE jurisdiction,

and this includes fixed installations, MODU, FPS, FPSO, TLP, SPAR, and pipelines to all OCS. There are 13 elements to the

SEMS management programs for which the operators must be able to demonstrate compliance:

1. General management program principles

2. Safety and environmental information

3. Hazard analysis

4. Management of change

5. Operating procedures

6. Safe work practices

7. Training

8 Quality assurance/Mechanical integrity

9. Pre-startup review

10. Emergency response and control

11. Incident investigation

12. SEMS element audit

13 Documentation and recordkeeping

United States Coast Guard: Risk-based Targeting of Foreign-Flagged MODUs

In order to enhance the safety of drilling activities, specifically to the MODUs that operate on the U.S. Outer Continental

Shelf (OCS), the United States Coast Guard (USCG) has implemented CG-543 Policy Letter 11-06, Risk-based Targeting of

Foreign Flagged Mobile Offshore Drilling Units (MODUs). This regulation came into effect on July 07, 2011. Under this

regulation, every foreign-flagged MODU must undergo USCG inspection and be issued a Certificate of Compliance (CoC)

to 33 CFR 143.210 prior to operation on the U.S. OCS. The CoC is valid for a period of 2 years, with re-inspection of the

MODU between 9 to 15 months after the date of CoC issuance to confirm that the MODU remains in full compliance with

the applicable regulations for allowance of continuing operation on the U.S. OCS for another year.

The U.S. Coast Guard has recognized that this prescriptive approach to the regulatory scheme does not identify those

MODUs that may require additional Coast Guard inspections and oversight for continued safe operation on the U.S. OCS.

To address this issue, the USCG has implemented the Mobile Offshore Drilling Unit (MODU) Safety and Environmental

Protection Compliance Targeting Matrix, which is a risk-ranking procedure that is applied to systematically identify high-

risk MODUs operating on the U.S. OCS, and subsequently will be subjected to additional USCG inspection and oversight.

The risk-ranking matrix is based on five (5) categories, and points are assigned accordingly:

1. Vessel management (owner, operator, lessee, charterer or managing operator) and its associated detaining record within

the previous 12 month period as specified in the Targeted Vessel Management Company List provided by CG-5432,

2. Flag Administration and its safety detention ratio;

3. Recognized Organization and its performance over the previous three years as related to safety detention ratio; and

4. Vessel history related to previous USCG inspection, receipt of USCG Certificate of Compliance, any form of

operational control (i.e., CoC suspension, COTP Order, Letter of Deviation, etc.), reportable marine casualty or pollution

case or marine violation within the past 12 month, and outstanding deficiency which was not satisfactorily resolved by

the required due date.

5. MODU Particulars: self-propelled, semi-submersible, jack-up (self-elevating unit), submersible, and age.

The MODU Safety and Environmental Protection Compliance Targeting Matrix provides an objective assessment of a

vessel’s risk of non-compliance with the marine standards through the assignments of resulting points. The matrix provides a

point total that results in corresponding designation of “Priority” or “Non-Priority”. Priority MODUs are to be inspected

every six (6) months after receiving their initial or renewal CoC. They will remain on a six month inspection schedule until

they complete two (2) successive exams with less than three (3) deficiencies. If the MODU has completed a satisfactory CoC

or CoC annual exam within the past six (6) months with no serious deficiencies and all the deficiencies issued during the

previous inspection have been resolved to the satisfaction of the USCG, the MODU can be downgraded to “Non-Priority”

status.

American Petroleum Institute (API) In response to the incident in the GoM, U.S. regulators rapidly enacted regulatory reforms for the enhancement of safety

in drilling operations. API and the drilling industry were also quick to react in re-examining recommended practices, codes

and standards. This process started with the update of API RP 53, Recommended Practices for Blowout Prevention

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Equipment Systems for Drilling Wells that involved participation from drilling operators, drilling contractors, oil equipment

manufacturers, regulators, and class societies.

“API RP 53” to “API Standard 53”

API RP 53 is an industry “recommended practices”, and there is a need to strengthen its intent to a “normative” standard;

therefore, API RP 53 has been proposed to be changed to “API Standard 53”. “API Standard 53” is tentatively due for

publication in Q3/Q4 of 2011. One significant change within API RP 53 is the changing of “should” to “shall”. In

accordance with API’s definitions, the word “should” implies a recommended practice a safe comparable alternative practice

is available, that may be impractical under certain circumstances or that may be unnecessary under certain circumstances or

applications, and this can mean voluntary compliance with the recommended practice therein. The word “shall” indicates

that the recommended practice has universal applicability to that specific activity. Specific sections of API RP 53 have been

incorporated by reference into 30 CFR Part 250, and BOEMRE clarified to drilling operators and/or contractors that they

must be in full compliance with the specified sections of API RP 53. Therefore, the change from “should” to “shall” will

facilitate compliance with the applicable requirements of 30 CFR Part 250.

Additionally, some proposed revisions within API Standard 53 to improve safety in drilling operations and current

practices include:

• Additional shear ram for floating or dynamically-positioned units.

• Performance-based approach - the allowance of inspection and maintenance schedule/frequency based on using

condition-based data or performance data to justify deviation from the prescriptive requirements. Prescriptive

requirements are specific rules that must be adhered to. A performance-based approach specifies objectives to be

achieved while providing flexibility in methodology, technology and/or approaches used to meet these objectives.

• Specific functional testing requirements and frequency/acceptance criteria for:

- secondary, emergency and other well control systems

- riser recoil

• Specific pressure testing requirements for well control systems and associate equipment, as associated with:

- pre-deployment

- installation / deployment

• Addressing BOP stack configuration for 25K and 30K pressure designations for surface and subsea BOP installation

• Specification of accumulator drawdown test requirements and acceptance criteria

• Notification of original equipment manufacturers by a written report of any drill –through equipment malfunction or

failure that occurs.

• Relocation of design requirements for well control to API Spec 16D, Specification for Control Systems for Drilling Well

Control Equipment and Control Systems for Diverter Equipment.

API 16 Series

In addition to the revision of API RP 53, the drilling industry has also undertaken the tasks of evaluating and revising the

complete API 16 Series, Drilling Well Control Systems, which comprises of the following specifications (Spec) and

recommended practices (RP):

1. Spec 16A: 3rd

Edition - Specification for Drill-through Equipment

2. Spec 16C: 1st Edition - Choke and Kill Systems

3. Spec 16D: 2nd

Edition - Control Systems for Drilling Well Control Equipment and Control Systems for Diverter

Equipment

4. Spec 16F: 1st Edition - Specification for Marine Drilling Riser Equipment

5. RP 16Q: 1st Edition - Design, Selection, Operation and Maintenance of Marine Drilling Riser Systems

6. Spec 16R: 1st Edition - Marine Drilling Riser Couplings

7. Spec 16RCD: 1st Edition - Drill Through Equipment – Rotating Control Devices

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API RP 64

As the diverter is an important component to the overall well control capability, the associated recommended practice,

API RP 64 – Recommended Practice for Diverter Systems Equipment and Operations is scheduled to undergo the revision

process in Q3 2011.

Conclusions

• ABS and U.S. regulators acknowledge the importance of independent third-party verifications for drilling systems

and associated equipment for compliance with applicable rules, regulations, codes and standards to confirm that the

systems and/or equipment meet their intended services. This requirement has been specified within U.S. regulations

• ABS believes that safety may be enhanced by the independent verification of drilling systems for compliance with

applicable regulations, codes and standards. Additionally, noting that many of these regulations, codes and

standards are at the "component level" with varying technical requirements, ABS believes that the holistic approach

to classification of drilling systems adopted by the ABS CDS Guide enhances safety by bridging these technical

variations through the provision of a holistic review, survey and testing regime.

• ABS CDS Guide provides an independent, comprehensive approach to the classification of the drilling systems, sub-

systems, equipment and components, a valuable tool for the enhancement of safety for drilling operations and

drilling unit.

• By providing guidance on software validation and verification of the integrity of control systems associated with

drilling operations, drilling safety can be improved.

• Changes in the U.S. regulatory regime will result in the enhancement of safety for drilling operations in the US

GoM, and these regulations can be adapted to other parts of the world to achieve the same goal.

References

[1] Department of Interior, Increased Safety Measures for Energy Development on the Outer Continental Shelf, May

27, 2010

[2] Department of Interior, Implementation Report – Reorganization of the Minerals Management Service, July 14,

2010

[3] Bureau of Offshore Energy Management - Drilling Safety Rules, September 30, 2010

[4] United States Codes of Federal Regulations, 30 CFR Part 250, Oil and Gas and Sulphur Operations in the Outer

Continental Shelf – Increased Safety Measures for Energy Development on the Outer Continental Shelf.

[5] Bureau of Offshore Energy Management - Workplace Safety Rules, September 30, 2010

[6] United States Coast Guard CG-543 Policy Letter 11-06, Risk-Based Targeting of Foreign Flagged Mobile Offshore

Drilling Units (MODUs)

[7] API RP 53, Recommended Practice for Blowout Prevention Equipment Systems for Drilling Wells, 3rd

Edition,

March 1997

[8] API RP 75, Recommended Practice for Development of a Safety and Environmental Management Program for

Offshore Operations and Facilities, 3rd

Edition, May 2004

Acknowledgement

The author would like to thank the American Bureau of Shipping (ABS) for granting permission to publish this paper.

He would also like to acknowledge the support provided by the members of the ABS team.

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