The US Bureau of Safety and Environmental Enforcement (BSEE) is proposing regulations that would improve operational safety, human health and environmental protections offshore, while providing clarity to industry regarding BSEE’s review of projects proposing to utilize new or unusual technology, including equipment used in high pressure and/or high temperature environments (HPHT).
BSEE considers novel technology to include equipment or procedures that have not been used previously or extensively under the anticipated operating conditions; have not been used previously in a particular Outer Continental Shelf (OCS) region; or that have operating characteristics outside the performance parameters established in 30 CFR part 250. The rule was developed to increase safety as the industry moves to more challenging environments.
An HPHT environment is present when well conditions have pressures greater than 15,000 psi or temperatures greater than 350°F.
“BSEE serves the American people as the lead federal agency for overseeing safe and environmentally responsible offshore energy production,” said BSEE Director Kevin Sligh. “The rules BSEE promulgates are critical to ensuring the offshore energy industry drives down risks of injury to offshore workers and protects the offshore environment, and this rule is particularly important for maintaining safe operations as the industry starts encountering more challenging operating conditions.”
This proposed rule would formally codify BSEE’s existing practice for reviewing and approving novel technology projects, including projects in HPHT environments, to provide clarity and certainty surrounding related requirements and BSEE processes. This proposed rule would specifically:
- require submission of information in an order that provides both operators and BSEE the ability to evaluate whether a new or unusual technology project is economically and operationally feasible;
- add specific equipment requirements, particularly for barriers, through new regulations and incorporation of industry standards; and
- require independent third party (I3P) review of operator submissions, in certain cases, or provide BSEE with the ability to require I3P review, to ensure project viability and safety.
The proposed rule will be published in the Federal Register on May 16, 2022. The 60-day public comment period closes July 15, 2022.