Deepwater moratorium lifted early, but questions remain

The deepwater drilling moratorium was lifted on 12 October, but industry remains unclear when drilling in water deep or shallow will return to anything like normal levels. Promulgation of new rules and apparent shortages of necessary inspectors and government personnel have already combined to bottleneck permitting of wells in shallow water. Since the Macondo blowout, just 12 permits to drill new wells have been issued through 14 October for water depths of 500 ft or less. This statistic for the purportedly moratorium-free zone does not bode well for a speedy resumption of drilling in the Gulf of Mexico, whether in water deep or shallow.

The major task now is unraveling and gaining clarification of the 111-page interim Final Drilling Safety Rule, which was posted 7 October in the Federal Register’s reading room in advance of the Department of Interior’s move to end the moratorium.

The rule covers wellbore integrity, well control equipment and specifications, and training. Officially issued on 14 October, it became effective immediately.  Most of the rule’s provisions were already required under NTLs N05 and N06 issued earlier this year.

IADC to comment

IADC will submit comments on the rule, available through a link under Government Documents at www.iadc.org/offshore_GOM_reform. IADC welcomes input from members, which can be sent to alan.spackman@iadc.org. Please respond to Mr Spackman, IADC vice president-offshore regulatory and technical affairs, by 15 November.

26-year blowout cycle

The DOI estimates the rule’s annual implementation cost to industry at $183.1 million. It pegs the cost of a “catastrophic” blowout at $16.3 billion, and anticipates such an event will occur once every 26 years, “based on historical trends and the number of expected future wells.”

Despite compelling evidence that blowouts are rare and have historically resulted in minimal pollution and damage, DOI clings to the idea that the Macondo blowout was no rogue event, but indicative of a trend. “Circumstances suggest that, while a blowout and spill of this magnitude have not occurred before on the OCS, it is unlikely that the problems are unique to the Deepwater Horizon and BP’s Macondo well,” the regulation reads.

More rules to come

This interim drilling safety rule sets the stage for future rulemakings or further evaluations across a number of areas – cementing and casing, fluid displacement, BOPs, secondary control systems and ROVs, wild-well intervention, training, oil-spill response, and organization and safety management.

While the rule calls for “new requirements for specific well control training to include deepwater operations,” detail is sparse. IADC, whose WellCAP accreditation program is the world’s premier well-control training tool, has determined that the regulation’s call for deepwater well-control training is already addressed in the existing WellCAP supervisory curriculum. Operators and contractors were previously required to determine what type of training is appropriate for their operations; the interim final rule modified that section to include a specific reference to deepwater drilling.  Nonetheless, the IADC Well Control Committee will consider at its next meeting possible development of supplemental WellCAP courses dedicated to deepwater.

The rulemaking also means boom times for qualified professional engineers or other “independent third parties,” such as a technical classification society or an API-licensed manufacturing, inspection or certification firm. OEMs are specifically excluded. Among the items the third party must certify are:

• That blind-shear rams can cut any drill pipe under maximum sustained pressure;
• That subsea BOP is designed for specific equipment on the rig and the specific well design;
• Certification of two independently tested barriers and that casing & cementing designs are appropriate;
• Well abandonment design and procedures, including existence of at least two independently tested barriers during abandonment, one of which must be mechanical, and that the plug meets specified requirements.