Harish Patel, ABS
Increasing numbers of high-pressure/high-temperature (HP/HT) projects for offshore fields are progressing toward sanction and construction. This journey started over a decade ago, at a time when the project needs were beyond the capacity of the available technology and applicable codes and standards.
Currently, the offshore industry is working to qualify HP/HT equipment. Full responsibility for this lies with the original equipment manufacturers (OEMs), with oversight by the operators to verify compliance with functional design specifications. In the US Gulf of Mexico (GoM), the Bureau of Safety and Environmental Enforcement (BSEE) also requires an independent third party (I3P) to review all documents and write reports for qualifying the HP/HT equipment.
Drilling and production technology must be capable of withstanding the harsh environments in HP/HT reservoirs, and this can entail an equipment re-design. With the new design comes a requirement to verify and validate that the equipment can withstand the expected loads. As the consequences of failure in offshore HP/HT environments are extremely serious, certain regulators have developed guidelines for HP/HT offshore oil and gas exploration and production. For example, the BSEE has published three notices to lessees (NTLs) (Nos. 2019-G02, 2019-G03, and 2019-G04) for HP/HT-related field development.
Since the process for approval of HP/HT equipment is new, involved parties initially go through a learning curve. As an independent classification society ABS acts as an I3P for various HP/HT projects. It has been involved in many technology qualification projects in a variety of applications and assists the oil and gas industry in the verification of designs. These programs have identified opportunities to work more efficiently as outlined below.
Effective industry collaboration
As the offshore industry is still in the developmental stage for HP/HT technology, it is expensive for an individual operator to single-handedly take on development of equipment and systems, address regulatory requirements, and safely execute projects. Co-operation is therefore a must to control costs associated with R&D and the development of codes, standards, and regulations.
Some examples where operators have collaborated to share costs are:
- HP/HT subsea christmas trees and production equipment joint industry agreements
- Material joint industry projects (JIPs) for qualifying materials for use in HP/HT environments
- Extension of approval from one operator to others.
Further, operators are sharing the BSEE’s requirement for I3P verification, eliminating duplication of work and saving a tremendous amount of time and resources for the industry. A similar approach is in place for subsea completion equipment.
The industry has worked with organizations such as the American Petroleum Institute (API), American Society of Mechanical Engineers (ASME) and the International Organization for Standardization (ISO) to put together HP/HT-related standards; and with the BSEE to develop HP/HT-related regulatory requirements alongside the API, ASME, Offshore Operators Committee, and DeepStar, on individual projects, with results shared at various industry events.
A key BSEE requirement in the US GoM is for I3Ps to undertake reviews of HP/HT design verification and validation documentation and to submit written reports to the bureau. This process requires more oversight which in turn pushes up cost and time. It has forced the industry to collaborate on compliance with regulations and the interpretation of requirements.
As development of HP/HT technologies has progressed, the BSEE has provided industry with guidance documents that are continuing to evolve. The process started with the technical assessment section (TAS) document “Guidance on Obtaining BSEE Approval to Implement a High Pressure and/or High Temperature Project in the Conceptual and Final DWOP.” After multiple revisions it was converted to six bureau interim directive (BID) documents “BID-2018- GXXX.” The BSEE has now published NTLs that provide the framework for operator compliance. These revisions underline the complexity of the regulatory requirement journey. But if the industry does not pay close attention to these developments and co-operate with regulators on the necessary changes, more time and cost will be incurred.
Following requests from individual operators/I3Ps, the BSEE is granting exceptions and permitting interpretations to its requirements on a case-by-case basis, but this too has led to increased costs and confusion within the industry. One example was a requirement for a higher burst margin. In response to the BSEE-sponsored report from Argonne National Lab, the bureau stipulated that the minimum safety margin should be higher than the ASME Section VIII, Division III requirement - against which the industry had spent millions of dollars on developing compliant designs. That decision had a major impact on the industry, and any late-stage clarification can create confusion as it may require some re-work.
There had been a lack of clarity from the BSEE on the appropriate volume of information, which caused operators and I3Ps to submit tremendous amount of paperwork, assuming that this was mandatory. That in turn meant allocating significant additional resources and caused further delays. However, following discussions and interactions over time and a steep learning curve by all parties involved, greater clarity has emerged, and the industry has learned how to satisfy the BSEE’s requirements with more compact reports.
For the initial projects under the BSEE process, operators faced uncertainty regarding I3Ps due to their technical expectations, the amount of information required, and the time required to complete the reviews and to deliver various reports. Many manufacturers in the oil and gas industry had not previously engaged with an I3P for reviews and validations of their designs. Additionally, there were varying expectations between I3Ps, which putting OEMs and operators in an unclear position.
Recognizing issues in early projects and in the regulatory development process, the industry has worked with I3Ps and the BSEE to devise standardized expectations for I3P review by clarifying all processes within the review path. The operator, manufacturer/designer, and I3P reviewer must meet to set roles and responsibilities prior to project kick-off. The culture of collaboration with an I3P must be addressed at the start of a project for work to progress efficiently. Interaction, communication, and direct involvement of key personnel from the bureau and the I3P are crucial to keeping all parties aligned.
The I3Ps can also assist in providing the documentation for all BSEE requirements listed in the bureau’s HP/HT regulatory document. Operators and I3Ps have taken steps to standardize the I3P report format. Reports must be generated with detail and information not only for documentation purposes, but also to provide a clear understanding of the entire design methodology and process. These report formats have made the BSEE’s review and approval process more efficient.
I3Ps are typically involved in the codes and standards committees – such as API and ASME committees – to develop requirements for HP/HT equipment design verification and validation. I3Ps are in a unique position to provide guidance and insight on applying these codes and standards on the HP/HT projects. They also play a key role in understanding the concerns of the operator and OEM while working with the regulators to determine the best path forward.
Personnel involved must be conversant with the codes and standards requested by the BSEE. OEMs should also address codes and standards which are not fully developed when considering HP/HT requirements. Some OEMs develop their own requirements to progress development, but this can result in regulatory compliance issues and can cause delay when the design verification and validation process has already started for some manufacturers.
Other potential issues that the industry has identified and jointly addressed are:
• I3P reviewer is unaware of changes in requirements, scope, approach/strategy, or schedule
• OEMs need to write the HP/HT qualification requirements for their equipment when industry standards are not available
• Operators fail to approve/update the OEM qualification requirements
• Qualification requirements are incomplete or incorrect
• Documentation of the OEM qualification requirements is lacking or is inconsistent in content and format
• Multiple design iterations prolong review process
• Methodology is new or unfamiliar to one or more parties
• Analysis methods have not been validated
• Manufacturers must comply to their own procedures and guidelines
• Sub-vendors must comply to established procedures and guidelines
• Personnel changes/lack of continuity
• Schedule conflicts/I3P reviewer falls behind schedule.
Fitness for service
Operators are responsible for the ‘fitness for service’ statement for BSEE, but there is no clear guideline from the bureau on its meaning. This requires further discussion with BSEE as there are legal issues involved, and it can take a long time for operators to understand their impact and meaning.
As the costs of HP/HT technology development are high and the industry is still operating in a relatively low oil price environment, cost control remains an imperative. In recent years, operators have been facing increased pressure from stakeholders to cut capex, reduce development times, and improve return on investment (ROI). This has driven a move toward greater standardization, thereby reducing cost without compromising safety. The industry is also working on multiple fronts to standardize equipment, through the API, ISO, and the International Association of Oil and Gas Producers (IOGP).
Other than cost reduction and increased safety, other benefits of standardization are increased clarity; shortened delivery time of material; better material quality; expedited design process; reduced weight; increased inter-changeability and compatibility; manufacturing efficiency; increased compliance with regulation; reduced conflict with regulators; shortened delivery time; and simplified operation and maintenance.
HP/HT is ready
High interest from the industry is spurring the development of sensors, materials, and equipment that will make HP/HT production a reality. However, developing revolutionary equipment is only one piece of solving the HP/HT puzzle. Having the design and safety standards that will help technology innovators develop, manufacture, and qualify solutions that will safely and reliably overcome these extremely challenging operating conditions is critical to permanently breaking the HP/HT barrier.
Over many years, operators have worked on the development and qualification of HP/HT technology at various levels. From regulatory codes and standards to R&D through JIPs to the OEM’s design and qualification, tremendous progress has been made in equipment qualification.
Starting with well control equipment such as wellheads, connectors, BOPs, and choke and kill equipment, two major OEMs have completed or are nearing completion of their qualification of HP/HT well control equipment with BSEE approval. The next major piece of equipment is an HP/HT wellhead system, with three large OEMs working toward qualification. One system is already approved by an I3P and is awaiting BSEE approval. A subsea production system tree, under a joint development agreement, is almost qualified and final reports have been submitted to BSEE for approval. Upper/lower completion major components are also qualified with an I3P and BSEE for approval.
Progress so far has been as planned and no major obstacles have been identified in the development of these projects. •
Harish Patel, Senior Technical Advisor, Technology – Drilling and Process, ABS