Well Control Rule Lakeisha Harrison, Chief, Regulations and Standards Branch, Office of Offshore Regulatory Programs, BSEE July 2016 “To promote safety, protect the environment and conserve resources offshore through vigorous regulatory oversight and enforcement.”

BSEE Mission Statement 2

Define safe drilling practices Define performance criteria for downhole equipment Define performance criteria for Blowout preventers (BOPs) Increase and verify reliability of BOPs Establish criteria for maintenance and repair of BOP equipment Incorporate industry standards as a baseline Objectives 3

Prevention of loss of well control Incorporate guidance and policy Incorporate key industry standards Recommendations from investigations Increase reliability and performance of critical safety equipment Require risks to be reduced as low as reasonably practicable Require drilling activities to be performed with adequate margin of safety Overview of the Rule 4

Defines “safe drilling margin” Centralizer/cementing requirements Onshore real-time monitoring capabilities Safe Drilling Practices 5

Source Control and Containment Equipment 6 Must have the ability to control or contain a blowout event at the sea floor Determine if a full shut-in can be achieved without having reservoir fluids broach to the sea floor If the well can only be partially shut-in, then determine ability to flow and capture the residual fluids to a surface production and storage system

Developed from NTL 2010 N-10 Must have access to and the ability to deploy SCCE and all other necessary supporting and co-located equipment to regain control of the well Requirements for maintaining, testing, and inspecting the source control, containment, and co-located equipment Source Control and Containment Equipment 7

Fit for service Adopt American Petroleum Institute (API) standards Testing No liners as conductor casing Downhole Equipment 8

Shearing criteria for blind shear rams Closing/sealing criteria Accumulator capacity ROV performance criteria Dual shear rams Performance Criteria for BOPs 9

Manufactured under QA programs Training of repair personnel Traceability of repair/maintenance work Annual third-party certification and report Mandatory data sharing on failures within industry Reduce pressure testing of equipment during operations Increased Reliability of BOPs 10

Operations involving BOP equipment systems Choke and kill systems BOP and drill-through equipment Control systems and diverters Packers and bridge plugs Quality management systems Riser for floating production platforms Industry Standards as Baseline 11

Well Control Rule – Key Dates Gas bleed line with two valves for the annular preventer – 2 years Capability to shear and seal tubing with exterior control lines – 2 years BAVO – 1 year from the date when BSEE publishes the list of BAVOs RTM – 3 years Subsea accumulator capacity for autoshear and deadman – 5 years Dual shear rams – 5 years Install shear rams that center drill pipe during shearing – 7 years Remotely-controlled locks on surface BOP sealing rams – 3 years Shear electric-, wire-, and slick-line – 2 years Effective date: July 28, 2016 Additional compliance dates: 12

Topic and Section (WCR/Arctic) Well Control RuleArctic Rule Definitions No definitions for cap and flow systems, capping stack, or containment dome  Includes definitions for:  Cap and flow system  Capping stack  Containment dome  Source control and containment equipment and provides examples of surface equipment and subsea devices Real-time Monitoring  Includes provisions for a real-time monitoring plan  Applicable for subsea BOPs and surface BOPs on floating facilities Applicable for all MODUs Well control rule compared to the Arctic rule 13

Topic and Section (WCR/Arctic) Well Control RuleArctic Rule Source control and containment  Capping stack function and pressure testing requirements  Includes provisions for production safety systems used for flow and capture operations, subsea utility equipment, and co-located equipment  Capping stack positioned to ensure it will arrive onsite 24 hours after a loss of well control  Cap and flow systems positioned to ensure arrival onsite within 7 days  Containment dome positioned to ensure arrival within 7 days  Conduct a monthly stump test of dry stored capping stacks and stump test prior to each installations on a well  Upon loss of well control requires transit of a capping stack, cap and flow system, and containment dome Relief rig requirements Must have access to a relief rig Well control rule compared to the Arctic rule 14

Questions? 15

“To promote safety, protect the environment and conserve resources offshore through vigorous regulatory oversight and enforcement.” BSEE Website: Bureau of Safety and Environmental Enforcement BSEEgov