BSEE Extends Comment Period for Offshore Production Safety Systems

The Bureau of Safety and Environmental Enforcement (BSEE) has extended the comment period on a proposed rule for offshore oil and gas production safety systems on the U.S. Outer Continental Shelf (OCS).

BSEE announced the extended comment period in the recent edition of the Federal Register. The original comment period was set to end Oct. 21. However, BSEE decided to extend the comment period by 45 days after receiving multiple requests from industry representatives.

Written comments are now due by Dec. 5.

BSEE announced the proposed rule in the Aug. 22 edition of the Federal Register. The proposed rule would amend and update Subpart H of U.S. oil and gas production safety systems regulations. Subpart H has not been updated since its first publication in 1988. Regulations have not kept pace with technological advancements and the fact that much OCS oil and gas production now takes place in deeper waters.

The update would include:

  • Update and improve the safety and pollution prevention equipment lifecycle analysis to boost the overall level of certainty that this equipment would perform as intended under emergency conditions
  • Expand regulations to differentiate requirements for operating dry tree and subsea tree production systems on the OCS
  • Incorporate new industry standards and update the incorporation of partially incorporated standards to require compliance with the complete standards

The proposed rule would also update regulations to require best available and safest technology (BAST) to follow more closely the Outer Continental Shelf Lands Act statutory provision.

Dry tree completions have been widely used in OCS shallow water platforms. They also have been used on new platform types suited for deeper waters, including compliant towers, tension leg platforms and spars. Wet or subsea trees are now being utilized for wells producing in greater than 4,000 feet of water. While dry tree arrangements on shallow water platforms allow direct access to valves and gauges to monitor well conditions and direct vertical well access, wet or subsea trees do not due to their location on the seafloor.

“Subpart H has not kept pace with industry’s pace of subsea trees and other technologies that have evolved or become more prevalent offshore over the last 20 years,” BSEE said in the Aug. 22 Federal Register notice. “This includes items as diverse as foam firefighting systems; electronic-based ESDs; subsea pumping; waterflooding, and gaslift; and new alloys and equipment for high temperature and high pressure wells.


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