Regulatory Requirements and

Reactivation Guidelines

North Sea P&A Operations

June 28th, 2017

SPE Aberdeen 7th European Well Abandonment Seminar – Day 2

Claudio Pollio – Blue Edge S.r.l.

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Summary

• UK Regulations:

Implementation of EU Directive.

UK Regulatory Framework.

Focus on P&A and Well Intervention.

• Norwegian Regulations:

Norwegian Regulatory Framework.

Focus on P&A and Well Intervention.

• Comparison between UK and Norwegian Regulations.

• Rig Reactivation and Involvement of Class Authority.

• The 2013 EU Directive on safety of offshore Oil & Gas operations is built upon

original UK provisions, and adds a few key concepts.

• Each member state appoints an independent Competent Authority (CA)

responsible for verification of compliance by operators and owners.

• ‘Safety and Environmental critical elements’ are introduced.

• Each Competent Authority shall ensure that operators and owners establish

schemes for independent verification in order to:

Verify suitability of Safety and Environmental critical elements.

Verify Well Design and Well Control measures.

• Department of Energy and Climate Change (DECC) and Health and Safety

Executive (HSE) work in partnership to act as CA.

EU Directive on safety of offshore Oil & Gas operations

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UK Regulations (1)

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UK Regulations (2)

UK Regulatory Framework scheme

• Petroleum Act 1998

• Infrastructure Act 2015

• Energy Act 2016

• Energy Act 2011

• Hydrocarbons Licensing

Directive regulations 1995

• PSR

• PUWER

• LOLER

Acts

Regulations

Industry Standards

and Guidance Notes“goal setting” approach

• SCR (Safety Case)

• PFEER

• DCR

• MAR

• BSI, API, ISO, ASME, Norsok, ATEX

• GASCET (HSE Guidelines)

• Guidelines for abandonment of wells 2015

(Oil & Gas UK Guidelines)

• UK Regulators:

Oil & Gas authority (OGA), BEIS, HSE, DECC, OSDR (CA)

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UK Regulations (3)

• The SCR 2015 applies to Oil & Gas operations in external waters, within

the UK continental shelf.

• SCR 2015 aims to reduce the risks to health and safety from major

accident hazards.

• It is an offence to operate an installation without a Safety Case accepted

by the Competent Authority.

• The Duty Holder (Operator or Owner) is responsible to submit the

Safety Case.

• The Safety Case should provide information on the arrangements for the

P&A of a well.

Offshore Installation Regulations: SCR

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UK Regulations (4)

• The OGA provides a decommissioning road map for each stakeholder and

decommissioning phase.

https://www.ogauthority.co.uk/decommissioning/decommissioning-roadmap/

• GASCET guidelines provide standards, models and methodologies for the

assessment of the Safety Case, such as:

API Spec 6A - Specification for Wellhead and Christmas Tree Equipment.

API Spec 16D - Specification for Control Systems for Drilling Well Control

Equipment.

API Standard 53 - Blowout Prevention Equipment Systems for Drilling

Wells.

Other API and standards.

http://webcommunities.hse.gov.uk/connect.ti/gascet

Focus on P&A and Decommissioning

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UK Regulations (5)

Offshore Installations and Wells (Design and Construction) Regulations 1996

• The well operator shall ensure that suitable Well Control Equipment is provided

before beginning any well operation to protect against a blowout (Reg. 17).

• Well Control Equipment should be deployed on all wells where there is a risk of

release of flammable, explosive, toxic fluids or gasses, as well as where there is

a risk of high pressure water flow.

Guidelines for the Abandonment of Wells 2015

• These guidelines provide minimum criteria to ensure full and adequate isolation

of formation fluids both within the wellbore and from the surface or seabed.

• The assessment of flow potential should include future scenarios such as re-

charging of reservoirs and re-development for hydrocarbon extraction.

Well Control Equipment for P&A

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Norwegian Regulations (1)

Norwegian Regulatory Framework scheme

Acts

Regulations

PSA Guidance to

Regulations

Standards

• Petroleum activities act

• Working environment act

• Health legislation

• Pollution control act

• The Management Regulations

• The Activities Regulations

• The Framework Regulations

• Working environment regulations

• Other

• Norsok, ISO, IEC, DNV, NOG, etc.

• The Facilities Regulations

[Sourc

e: H

andbook for

Acknow

ledgem

ent of C

om

plia

nce (

AoC

) 2015]

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Norwegian Regulations (2)

• The operator is responsible for verification activities.

The responsible party shall determine the need for and scope of

verifications, as well as the verification method and its degree of

independence, to document compliance with requirements in the health,

safety and environment legislation. Framework Regulations §19

• The Petroleum Safety Authority carries out supervision to ensure

compliance.

• High degree of freedom for satisfying the regulatory requirements.

• The guidelines to the regulations are not legally binding.

Norwegian Regulatory Framework

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Norwegian Regulations (3)

• An Application for Consent shall be submitted by the Operator to PSA for

operations related to Plug & Abandon and Well Intervention activities.

• An Acknowledgement of Compliance (AoC) is a declaration from the PSA

which expresses the regulator’s confidence that a MOU can fulfil the

requirements for petroleum operations on the NCS.

• Applicable standards for Plug & Abandon and Well Intervention:

Norsok D-010 – Well integrity in drilling and well operations.

Norsok D-002 – Well Intervention Equipment.

Norsok D-001 – Drilling Facilities.

Norwegian Oil & Gas Guideline No. 070 - Design of Safety Systems.

Norsok Z-013 , ISO 31000 - Risk and emergency preparedness analysis.

Other Norsok and Industrial standards.

Focus on Plug & Abandon and Well Intervention

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Norwegian Regulations (4)

Norsok D-010

• Defines the requirements for the isolation of the formations, fluids and pressure

for temporary and permanent abandonment.

• Size and position of well barrier elements (cement plugs) are defined.

• Well control requirements: Cutting/perforating the casing and retrieving seal

assemblies shall be performed with active pressure Control Equipment in place

to prevent uncontrolled flow from annuli between casings and into the well/riser.

Norsok D-002

• Provides minimum requirements for Well Control Equipment used during

abandonment operations depending on the adopted strategy (coiled tubing,

wireline, snubbing).

Well Control Equipment for P&A

UK Regulations Norwegian Regulations

• The SCR applies to Oil & Gas operations

in external waters.

• Application for Consent applies to Oil &

Gas operations.

• AoC is not required for fixed platforms.

• The SCR is reviewed by the CA (OSDR).

• The SCR is governed by The Offshore

Installations Regulations 2015.

• An Application for Consent is processed by

the PSA.

• It is governed by the PSA Framework Reg.

29 and PSA Management Reg. 25.

• CA shall ensure that operators and

owners establish schemes for

independent verification of:

Environmental critical elements.

Well design and well control

measures.

• The responsible party shall ensure

compliance with requirements and the

need for independent verification.

• PSA acts as supervisor.

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UK vs. Norwegian Regulations

Key Differences

Fixed Platforms - Main EU Directives

• Machinery Directive (machinery, safety components, lifting components, etc.).

• Equipment for explosive atmospheres (ATEX) directive.

• Pressure Equipment Directive (PED) covers a broad range of products such

as: vessels, pressurised storage containers, heat exchangers, boilers, industrial

piping, safety devices and pressure accessories.

PED does not apply to Well Control Equipment

• CE marking is the only marking which guarantees the machinery conforms to

the requirements of the EU directives.

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Rig Reactivation (1)

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Rig Reactivation (2)

• Class Authorities (ABS, DNVGL) have issued guidelines for the lay-

up of MODUs:

The aim is to assist the operator during the lay-up activities to ease the

subsequent reactivation and class renewal.

Different rig conditions are addressed: cold lay-up, warm lay-up,

enhanced lay-up.

References:

ABS Guide for lay-up and reactivation of mobile offshore drilling units –

May 2016.

DNVGL-CG-0290 Lay-up of Vessels – February 2016.

MODU Lay-up status definition

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Rig Reactivation (3)

Areas of attention

• UKCS – SCR Review

• NCS – Application for ConsentNATIONAL REQUIREMENTS

• Gap analysis

• Mitigations/Derogations (if needed)

VERIFICATION OF COMPLIANCE WITH P&A REGULATIONS (EU AND INDUSTRIAL STANDARD)

• Development of technical specifications

• FAT

SOURCING OF SUITABLE WELL CONTROL AND/OR DRILLING

EQUIPMENT

• Maintenance of existing equipment

• System Integration (new and existing equipment)RIG REACTIVATION

• OEM involvement

• UKCS: Independent verification involvementCOMMISSIONING