PAF-seminar 2017Regulatory «Updates»

Johnny Gundersen PSA

Content:

Regulation/Guidelines/standards – principle

Documentation/Verification

Qualification of new technology/methods

Challenges not fulfilling requirements

Regulation/Guidelines/

standards - principle

Principal features of the regulations

The regulations are based on performance (functional) requirements, which:

• give the industry the freedom to choose its own good solutions

• underpin the allocation of responsibility

• refer to norms and industry standards, providing predictability for users and indicating the standard which solutions are expected to meet.

The regulations require the companies to set risk targetsand to manage their operations in relation to these.

Framework for Drilling & Well

• Legal level requirement:

• Framework Regulations

• Management Regulations

• Facility Regulations

• Activity Regulations

• Guidance level

• Guidance for Framework Regulations

• Guidance for Management Regulations

• Guidance for Facility Regulations

• Guidance for Activity Regulations

• Examples of Standards referred to in guidance to regulations

• NORSOK D-001 Drilling facilities, revision 3

• NORSOK D-002 System requirements well intervention equipment, revision 2

• NORSOK D-007 Well testing system, revision 2

• NORSOK D-010 Well integrity in drilling and well operations, revision 4

• DNV-OS-E101, Drilling Plant, October 2013

• NORSOK U-001 Subsea production systems, revision 3

• ISO 10423 Wellhead and Christmas tree equipment

• Norwegian Oil and Gas recommended guideline for well integrity No. 117

• Norwegian Oil and Gas recommended guideline for classification and categorization of well control and well integrity incidents No. 135

• Informative and normative references in standards

• T.ex API Standard 53, Blowout Prevention Equipment Systems for Drilling Wells

The Framework, Management, Facility and Activity

Regulations should all be read and seen in

conjunction with each other

Use of recognized standards (Framework §24)

• The regulatory requirement can normally be met by using the recommended standard referred to in the regulation

• In principle the operator should pursue the use of the recommended standards in the regulation

• If using other solutions, the operator shall be able to document that this solution fulfills the regulation (equivalent level of HSE)• The regulation and the guideline should be viewed in context to achieve

• the best possible understanding of the level of achievement

• regulatory requirements and required level of health, safety and working environment.

Cost effective solution preferred versus robust solutions according to the standards?

Documentation/Verification

Requirement to establish barriers that will function throughout the lifetime of the well

• Performance Requirement of Barriers (MR §5):• means verifiable requirements to, inter alia, capacity, reliability,

accessibility, efficiency, ability to withstand loads, integrity and robustness

• Well barriers shall be designed such that their performance can be verified (Facilities §48)• Verification of the performance of well barriers, can be based

on pressure testing, testing of accessibility, response time andleakage rates, as well as observation of physical properties.

Qualification of new Technology/new methods (Facilities §9)

• Qualification or testing shall demonstrate that applicable requirements can be fulfilled using the relevant new technology or methods.• DNV RP-A203 Qualification Procedures for New Technology

can be used to fulfil the requirements regarding methods for the qualification of new technology.

• Criteria shall be drawn up for development, testing and use so that the requirements for HSE are fulfilled

Challenges

Not following the recommended standardsExamples of this:

• Not able to establish barriers deep enough• No available logs or job history• Not able to verify barriers by logging or pressure testing

Necessary steps to be taken:• Basis should be to fulfill the intention of the regulation (no leaks to environment!)• Document and evaluate all relevant parameters and account

for uncertainties and external underground effects • Identify and discuss all compensating measures available• Evaluate alternative ways of documentation/verification• Probability and scale of leaks with chosen method – eternal prospective

If barriers still could not be documented/too large uncertainty (legal requirement are not met)

• Need to monitoring of wells?• Evaluate ability to intervene in case of leakages?

Thank you

questions?

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