Industry and Regulatory Changes in Offshore Operations

The recent incidents involved bolts shearing on blowout preventers—one of the pieces of equipment implicated in the Deepwater Horizon tragedy. Blowout preventers are a last line of defense in the well-control hierarchy. Fortunately, they are rarely needed and some would say they are a valve system of last resort, with the bluntest closure being achieved when the powerful blind shear ram severs and seals the pipe in order to cut off flow in a worst-case scenario.

Since 2003, and until the announcement in 2016, a lot of forensic work was required to piece together “the bolt problem.” That work began in earnest after Dec. 18, 2012, when BSEE inspectors identified a serious incident involving an offshore drilling operation. “Leaks were detected in a Lower Marine Riser Package, which was attached to a subsea blowout preventer beneath an offshore drilling rig,” said Doug Morris, BSEE’s chief of the Office of Offshore Regulatory Programs. “BSEE continues to have serious concerns with these types of connector bolts. Bolt failure is a recurring problem, which suggests that the problem may be systemic, given that it involves equipment from three primary manufacturers.”

Both BSEE and the original equipment manufacturer reacted quickly to the 2012 discovery. In Jan. 2013, BSEE charged its Quality Control-Failure Incident Team (QC-FIT) with conducting an in-depth examination of the issue. That team spent 18 months looking into: 1) root-causes; 2) connection design, manufacturing and quality control processes; and 3) other information related to bolt performance. The QC-FIT members worked collaboratively with original equipment manufacturers, drilling contractors and offshore operators. The team studied the bolts to identify why the bolts were shearing unexpectedly. Based on initial analyses that raised concerns, BSEE worked with the original equipment manufacturer to oversee the replacement of more than 10,000 bolts over a relatively short period of time.

Material Properties

In July 2014, Morris sent the QC-FIT report to BSEE’s director. The team identified several issues: stress corrosion cracking, improper heat treatment and coating processes used by sub-contractors, and quality assurance and quality control concerns related to bolt manufacturing and design, including material properties (hardness and strength). Key recommendations included better industry standards related to material properties and quality assurance for all components including valves, improved data sharing and additional research.

The March 2016 safety alert was issued due to the lack of an effective response by the industry and additional failures involving other subsea components made by other equipment manufacturers. Consequently, BSEE is recommending the following immediate action be taken until a more comprehensive remedy is developed:

• Standard committees should develop a consistent set of material property requirements for the manufacture of bolts.
• Increased emphasis should be placed on the development and use of a robust failure reporting system to address the use of critical safety equipment, including valves.
• Industry should develop and improve quality management standards that address the use of sub-tier subcontractors in the manufacture of critical items such as bolts. This is because quality management systems that typically meet the industry standards and certification programs only qualify and audit the first-tier level suppliers, and not the others in the supply chain.
• Additionally, BSEE asked industry to consider other research initiatives to address bolt design and material property improvements for subsea service and fitness for service.

“Real change and regulatory success happens when industry and government work together, which also includes our international partners,” said Morris. “Bolts are used everywhere offshore, so the lessons we learn here can be shared—and the lessons other countries learn need to be shared with us.” BSEE’s bolt experience has resulted in outreach to the member countries of the International Regulators Forum, which includes representatives from Australia, Brazil, Canada, Denmark, Mexico, the Netherlands, New Zealand, Norway and the United Kingdom. The forum unifies offshore petroleum health and safety regulators whose members are dedicated to raising offshore health and safety standards. “By sharing information and data, such as our bolt experience, we can identify potential safety issues and mitigate risks not just for the U.S. Outer Continental Shelf, but worldwide,” Morris said.

Morris points out that the development of “best practices” for bolts, valves and other issues can be a bit of a mystery to outsiders, causing some people to question the collaboration that can occur between regulators and those regulated. “Whether it is through a rulemaking process or standards development, an effective collaboration process facilitates input from both industry and government based on the safety issue, data and research. This dialogue and conversation along with the willingness to timely resolve safety problems will help to improve both regulations and industry standards.

The Well Control Rule

The recently finalized Well Control Rule, which BSEE published on April 29, 2016, addresses several issues related to equipment reliability and performance, including provisions of interest to valve manufacturers. The overarching theme of the WCR is safety, and BSEE hosted more than 17 listening sessions and 50 separate meetings with industry stakeholders to ensure their concerns were heard before the rule was finalized. “The newest regulations all have data-reporting requirements,” Morris said, “because data collection, sharing and analysis is at the heart of what it takes to make an industry safer.”

“We learned a lot from the bolt-shearing experience,” Morris concluded, “because we were able to look at of data over several years. This is one reason I am so dedicated to improving our safety data collection and sharing capabilities. We need to know not only about failures, but also about problems detected just short of failure. We should be focused on identifying and preventing potential safety events rather than responding to major events after they occur. I want us all to work together to develop best practices, contemplate challenges and resolve issues. I’m hopeful that bolts will serve as a good example of a way we can try to get ahead of a problem, before a major incident occurs that has global impact.”

The U.S. Department of Interior’s Bureau of Safety and Environmental Enforcement (BSEE) was formed “to promote safety, protect the environment and conserve resources offshore through vigorous regulatory oversight and enforcement.”