Adding Value to New HPHT Well Barrier Equipment Rapid Deployment including Regulatory Approvals
Authors: Cain David , Hoefler John , Goggans Tim , Kaculi Jim T. , Grohmann Andrew J. , Cain Jeremy 
Published: April 2018

This paper introduces a protocol to gain rapid and efficient regulatory approval of high pressure and/or high temperature (HPHT) well barrier equipment from the Bureau of Safety and Environmental Enforcement, (BSEE). The current application is for rapid deployment of HPHT well barrier equipment in the USA Gulf of Mexico (GoM) DeepWater in the outer continental shelf (OCS). This protocol is based on an efficient procedure developed by the independent third party (I3P) for independent review of engineering verification analysis and validation testing, per the regulator guidelines, and compliance to applicable industry standards to ensure equipment fit-for-purpose (FFP). The approach includes well defined roles and responsibilities for all parties involved. These responsibilities are to be implemented by a set of four primary interfacing entities: Regulator, Operator, Original Equipment Manufacturer (OEM), and Independent Third Party (I3P). Beyond these four areas of primary interface, there are secondary interfaces. These secondary interfaces may include engineering standards organizations and other technical authorities working for the Operator or OEM.
This paper is intended to demonstrate how critical elements such as: an Operator plan, a comprehensive I3P protocol, defined roles, defined responsibilities, thorough OEM documentation, project management, and early engagement of all parties are critical to efficient Regulator approval of HPHT technology equipment.
When these critical elements are combined with behaviors including: documenting communication between the interfacing entities, independence of the third party, collaboration, and concise clear reporting, they add value by facilitating the approval process and rapid deployment of HPHT technology.
This approach works very efficiently for the current regulatory approval process and the wellhead equipment in this case, but it is good guidance and a proven method for the independent third party review in general.
The Operator is required to submit a General Development of the Conceptual DeepWater Operational Plan (CDWOP) for the project describing the topside facility and its location along with the proposed subsea field layout with flowlines and export pipelines. Reservoir data will be submitted in this plan including design shut-in tubing pressure, flowing temperature, and produced fluids details. The operator will then nominate and request approval for an I3P for review of the verification and validation of HPHT equipment. The operator will then submit Conception Plans for groups of HPHT equipment needed for drilling and completion operations in compliance with instructions issued from BSEE in the General Development CDWOP approval process. After the operator has received the necessary Conceptual Plan approvals for the needed equipment and well completion operations, BSEE will approve the overall Conceptual Plan for the Project and a DWOP will be submitted for approval. The next step for the operator is to submit the required permits for the project.
The high level process includes:
Operator identification of new technology need(s) and the OEM(s)
Operator providing a conceptual deepwater operational development plan to the Regulator
Regulator acceptance of the plan and proposed I3P
Operator Functional Specifications
OEM Technical Specifications
I3P review and acceptance of new technology with statements of FFP
Acceptance of new technology by the Regulator
Rapid deployment by an Operator with OEM(s) and contractor(s) support
Potential missteps which lead to in-efficient plan execution are discussed in this paper and the negative impact on the time to deploy new technology HPHT DeepWater Barrier equipment. Well Barrier equipment provides safety in operations and protects the environment. Higher pressures and temperatures have been identified by regulators as an area which justifies additional review of verification (analysis) and validation because API standards have not been updated to include HPHT equipment.
The key conclusion is that rapid deployment of new technology equipment is supported when the primary entities provide value by completing the Operator plan efficiently. A novel flow diagram outlining the I3P protocol is included to provide an understanding of the process flow. Several vital I3P review modules contribute to efficiency and are discussed as part of an actual 20,000 psi subsea wellhead system (SWH) plan execution. Other key conclusions include: Operator planning, OEM comprehensive verification and validation, Cooperation, communication, collaboration, I3P independence, and concise reporting.