BSEE BOP Panel 3

Uploaded by bseeopa on 27.08.2012

This panel and going to address the life cycle of BOP's. The question for the panel is what
manufacturing test, maintenance, and certification requirements should be established to ensure
the reliability of BOP Equipment? The moderator Mr. Harish Patel is a manager for drilling
and production for the American Bureau of Shipping. He is responsible for the validation
of new technology and the development of requirements for the classification and certification of
technology used in marine applications. He has 24 years of experience related to the
design of a proven BOP used in the offshore industry. He has a master's in mechanical
engineering from Stevens Institute of Technology.
Thank you, and good morning, everybody. We appreciate the opportunity to present our
view. As we heard in the morning from Ken Salazar, there are major topics that we need
to address, and one is how we will maintain. We listened to the design side in the previous
panel. When you design something now, you have to manufacture and maintain and operate.
We are going to talk about how we will manufacture and operate. This panel represents a wide
number of speakers. We have API here which brings the codes and standards which will address how to maintain,
inspect, and test. And then we have Western Union. You will be able to see their view.
I was third introduced in the first speaker. Our first speaker is very well known in the
industry, moving in drilling operations in various parts of the world. He has drilled
the various deep water wells. He has been a member of the Board of Government and Center
for the Office of Safety, the member of the board of directors for the conference. He
is a member on the executive committee and board of directors. Please welcome Moe Plaisance
for his presentation. [applause]
Hello. Contrary to popular opinion, I am not dead. I am here. I have not retired yet either.
My presentation this morning is going to deal with the topic -- it is going to look a lot
like the new S53 because that is where we got it from.
We took part in the 53 rewrite group, and we are proud of the work that Frank and the
rest of the team did. It is certainly a great start to where we need to be. Not knowing
what we were going to see here, I think it will look a lot like 53. We will talk about
pre-deployment and testing during well operations, inspection and maintenance, re-deployment,
and at a specific time frame, one to five years, and certification requirements.
Let's talk about pre-deployment. Some of the older rigs are constrained by height; you
cannot join the lower marine rising package and the lower BOP Package. You have to bring
them under the seller debt, stack them under the road. We have been able to do some testing
using inflatable packers and other things. These are things that we will have to define
and test. As Dr. McCarthy was saying, we have done a
lot on pressure testing. We have not looked at worst case scenarios. We have not looked
at some of the other things that were mentioned today, but it is something we can work on:
capability of blind shear rams and operators for the plans to drill pipe. Suitability and
shear ability are extremely important to all of us and that is why we're here, to talk
about it. We have to work with all the manufacturers to see where we can best meet the requirements
as they come down the pike. I was under the first mandate to extend BOP
testing from seven days, which was in place from the Santa Barbara issue, to 14 days.
We looked at reliability; it was a pretty basic reliability issue. We got about 1000
BOP tests, and it may have painted a pretty picture but it did not stack up when all hell
broke loose. I think we can work together in meeting those requirements. We think BOP
testing of 21 days and allowing exceptions to that because of issues in the well or on
the rig, especially safety issues, and those would be handled by management of the change
scenario. We think that is the way to go. We certainly do not want to test with a pipe
in the hole. We sure do not want a fishing job. And you want to test the small spike
to be used in the whole section. Of course, now with variable rams, one set
of variables may cover three sets of pipes that we use. Inspection and maintenance; we
believe 100% in the tenets that were put up in 53 about inspection and maintenance. What
we want is to have the specifications of what we want to do and we want the ìhowî to be
something that we can work out, as we talked about this morning. There is talk about BOP's
having to go in, completely taking them apart, take them off the rig. Director Watson at
OTC asked me a question and said, ìdo the BOP's stay with the rig throughout its life?î
I said ìyes, sir. They are like my grandfather and his axe. He has had this axe for 35 years,
has changed the handle three times and the head twice.î [laughter]
It takes a little while, it will sink in. We have planned maintenance schedules, we
have replaceable wear pads, and we have done a lot of things that makes the difference.
We still need the maintenance requirements -- makes it easier. Taking a BOP down is labor-intensive;
it has safety issues moving it, getting it into a shop. All the drivers that have to
drive behind this heavy load, with the vehicle, and then we get it into the shop, and by that
time if we have not wrecked a rain jacket or steel face, then you have weld repairs
which we do have to put it in the oven, and there goes one life cycle from the thing.
There are a lot of issues we need to look at; it is just not that easy to say take it
in every time. What about failures in the mid? We have spare BOP's and other things
that we can send out and basically we have zeroed out that component. What I am saying
is, which was delineated earlier, ìtell us what you want and let us figure out how to
do it.î To me, that is the most important tenet that
we will get out of this. Again, inspection and maintenance, one to five years? It should
not be prescriptive to the nth degree that we're talking about it. Certification requirements.
We have worked with the certification requirements with the initial drilling rule. We talked
about the certification and verification issues that were put in to allow us to get by and
through the moratorium. I do not think any of us here have any problem with meeting all
of these requirements. I am sure my CEO would not have liked me to say that, but we do not.
We can meet these requirements, we just need to be given time to do it, and we need to
be given time to initiate. Chalk is a good friend of mine. He has an
order book that is more than full. He will not take us down. I am sure you will take
it, I'm sure, but we are trying to get this thing done. We have to remember, we are building
new rigs all over the world. The land rig business has gone completely desert. The same
machines that turn out the big BOP's turn out the land BOP's. There is a huge factor
of getting our equipment in, worked on, and meeting some of these things. If we can short
cut this and still meet the intent and requirement that is the way we need to go.
I have been chasing drilling rigs all over the world for 45 years. My dad did it before
me and my grandfather before him. I have four brothers. All of us worked in the industry.
One of them is a geologist, so he has more money than the rest of us. I love this industry.
My son worked in it. It has been a very tough couple of years, but I can stand up here and
say from a personal and from the company point of view at Diamond Offshore, we want to be
part of a solution and do what is best for our country, our people, and for the world.
We are active all over the world. Whatever comes about here will influence what happens
there. Thank you. I will be glad to answer questions once we are through. [applause]
Our next speaker will be John with API. John joined API in 1975. John has been in the industry
for the last 25 years and has a Business Management degree. He has been involved in various programs
with API. He is involved in the certification program and a training program also. Please
welcome John. [applause] Our next speaker will be John with API. John
joined API in 1975. John has been in the industry for the last 25 years and has a Business Management
degree. He has been involved in various programs with API. He is involved in the certification
program and a training program also. Please welcome John. [applause]
Thank you. I appreciate it. I appreciate the opportunity to get in front of everybody today
to give an overview of our API Monogram Program. Several of you probably know about the program,
being in the industry, and what we're doing with BOP Certification and licensing for the
program. Before I get started, one slot on a global
services industry is we are in the independent part of the API. We are the part that doesn't
do any of the lobbying or advocacy side of what we are known for, at least inside the
beltway. We do the work that we are known for around the world, and that is the training
and certifications, standards that we sell, industry statistics that we put together,
the events and conferences we work on for the industry.
My group has about 60 employees. We are hoping to have some new areas. We contract with 140
different auditors around the world to do the audits that we need to make sure manufacturing
is done properly and in accordance with API standards. We have an office in DC, where
the headquarters are, but we have offices in Houston, Dubai, Singapore, and Beijing.
We have quick certification programs. Today, I will focus my attention on the company-based
certification, the rehab. We publish standards and sell those, over 600 that we maintain,
have been doing it since 1924. We have 100 events this year and we also published eight
rotating statistics products. I will focus my attention on the Monogram Program because
that is what we're talking about here today, at least in terms of certification and verification
that manufacturers are making, or permit properly in accordance with API standards.
Monogram Program has been around since 1924. Actually, it started the same year that API
started to develop standards, started publishing standards. It has changed a lot since that
time, of course, but it encompasses most of API's upstream standards,
including some of the refinery standards, and also some supply chain standards, where
we are getting the raw materials to make the equipment that goes into making BOP's and
other things. The idea is to help promote the manufacturing of safe, reliable, interchangeable
equipment, so that when a company is operating around the world, whether it is in the Gulf
of Mexico or onshore, they can choose from a manufacturer that has gone through our process
and they have been audited to make sure that they can make that important decision with
API standards.
We have 4,000 licensed facilities among the world. About 80% of all of the licensees we
have are outside of the U.S. As you can see, about 70 different kinds of standards that
we do audits for BOP's are included in that. We will do an audit, depending on the type
of facility it is, on an annual basis for up to every three years, depending on what
kind of license they have with API. This year alone, we will conduct 3,500 audits of manufacturers
around the world. It is a massive undertaking to get this work done on an annual basis.
The foundation of the Monogram Program is called the API specification Q1. You have
all heard, Iím sure about ISO standards specification. This takes that standard and builds an extra
41 extra elements on top of that are of particular concern to the oil and gas industry. This
standard is maintained by a committee -- one of the API's hundreds of committees -- to
maintain our standards. The committee is made up of the manufacturers, oil companies, the
various auditors, the people with experience with quality management systems, and manufacturing
the equipment. I know Director Watson mentioned earlier today
how we need to have stricter controls over how we operate offshore. That is actually
one of the things that Q1 does, goes above and beyond the ISO standards and actually
has extra controls for the prevention and use of non-conforming equipment. This requires
annual management reviews and internal audits. I will not read all those extra controls,
but these are extra controls and above and beyond the ISO standards that our committee
finds are relevant and needed to make sure we have the right controls necessary to make
equipment for the industry. You will see there is a laundry list of things
that are very important for the manufacturing of the equipment. What does the Monogram Program
mean at the end of the day? We are providing a license to a manufacturer to actually stamp
that logo into the side of an equipment, or nameplate, and that logo is a guarantee to
API and the buyer, that piece of equipment has been made in accordance with standards
and is guaranteed to meet every minimum requirement of that standard. A licensee can only use
that mark on the side of the equipment if they have been audited to make sure their
management systems meet Q1, that they have proven that they have the capability to manufacture
equipment to the standard they have been provided a license for, and they can only use it on
equipment that meets the standard requirements. The important part of this is, for the buyers
especially, people tend to think of buyers as just oil and gas company owners, but some
of the largest manufacturer equipment is for other large manufacturers. The composite list
is our directory of certified manufacturers around the world. The hard copy version is
obsolete the next day. The useful version is online.
These are the various series of standards that we cover. I will not read all of these,
but as you can see, each one of these series has a subset of other standards that helps
to make up the different standard that we cover. Of course, what we're talking about
today are the Blow Out Preventers. Under that, the series 16 standards. You have heard several
of those mentioned today. That is where 16a states under our standards, just a brief review
of how you go through the licensing process. You go through an application review.
On the left, you will see various things required by API before we can get the process started.
We will work back and forth with a manufacturer until they have the application in-house and
proper. Documents are reviewed to make sure that their document requires them to ensure
they will meet all our Q1 expectations and specifications they will be licensed to before
we spend any time and energy onsite. One of the things that we spend a lot of time on
--I have been with API for 17 years-- we have done an incredible job in the last eight years
of improving the types of auditors that we use, the experiences we need. We make sure
we select auditors that have the background, in this case, drilling background, blow out
manufacturing, and the audits. The auditing team will be typically two people
for five or six days depending on the lessons they have. We will go through the audit, make
sure all of the non-conformances are completed. We have an on-line system that is convenient
for the manufacturers around world. After they have proved to us they meet the licensing
agreements, term of agreements, monitoring requirements, Q1 requirements, we will grant
them a license. We license BOP manufacturers, repairs, and re-manufacturers up to the third
edition of 16a. In March 2007, we decided to withdraw the
ability to apply for a repair and re- manufacturing license. They are withdrawn under API administrative
concerns with what was going on with the licensees. We wanted to make sure the repair remanufacture
licensees had access to the original equipment manufacturersí designs. It should come as
no surprise that was a difficult thing for us to mandate and for them to get access to.
Based on that critical element, we decided, there are not adequate controls in place for
us to feel comfortable issuing licenses in this area, so we withdrew that. Obviously,
we continue to license new manufacturing, but not repair or remanufacturing.
We talked about the new standard that is being billed -- standard 53. June 14, closed on
the 29th of last year. The second ballot was later last year, closing this year in January.
Then we have to find a resolution scheduled for May 18, we just got finished doing. The
major issues that were outstanding were allowance of risk assessment in lieu of two blind shear
rams. An option is to allow the operator to use their internal exception process to deviate
from the standards, we are trying to work these standards out. Last week, not only did
we have a standard meeting about standard 53, but we also had a meeting on what could
be specification 16AR. That will be addressing Blow Out Preventer repair, remanufacture.
There were about 60 people that attended. It will be a hotly-contested, interested group
working on that. We have a long way to go until we get to that point, but we may get
into that after the publication of the document, where the API is more comfortable doing licensing
to repair and remanufacturing, because that is important to this. Appreciate your time.
Happy to take questions at the end of our conversation. [applause]
Thank you, John, for the nice information on the manufacturing and quality control.
Our next speaker will be Don Jacobson. He is the Senior Vice President of Industry and
Government at Mobil Corp.. Don has been in the industry for the last 38 years. -- Noble
Corporation. Don is a member of the governing board of the Offshore Energy Safety Advisory
Committee chartered by Secretary of the Interior Ken Salazar. He is a key member. He is also
a member of the Options Safety Center in Houston. Welcome, Don. [applause]
Thank you. Happy to be here. Thank you to BSEE for organizing this. A bit more advance
notice would be helpful next time, but we are happy to contribute. I have a handful
of slides. One is my get out of jail card. Today's challenge -- you saw that we would
be talking about manufacturing and maintenance and certification. I will try to touch on
all three but leave certification comments to Jeff, who will follow me. Before getting
into it, you heard from the previous panel we have a panel after lunch -- about what
we can do with new designs. We have a pretty complicated kit already. Tom Hunter asked
that we make it reliable, repeatable, upgradable, repairable, understandable, and affordable.
We have a task ahead of us. Some of the comments from the previous panel
about defining what we wanted to do and to be specific about the function is critically
important, because this is complicated. As far as manufacturer, it would be good to
have equipment manufacturer to talk about it, but I will make a couple of comments.
You heard about API standards. We have compliance safety standards. We support at 100%. Deputy
Secretary Hayes asked questions about how we can do this together. We have the API work
group to work through this, and we have to make use of that. The next points about during
manufacturing being robust on QA/QC, manufacture and assembly, materials testing. If you look
at Nuclear Navy, the SUBSAFE program, the success of that program, one of the tenants
of the program is focusing on this QA/QC, making sure they have the right materials
and manufacturing. Certainly, certification and thorough documentation. Certainly, initial
certification, but also as they get into many aspects, it is important to maintain that.
I agree with Moe on API standard 53. Our maintenance program and policies are dovetailing in with
the requirements there. We have issued a subsea policy. The first bullet you can see. Itís
about getting all of the maintenance planned between wells, even at the expense of downtime.
The way the industry has progressed, we normally have an allotted time for maintenance. Beyond
that, depending on contract can be downtime, which means no revenue for contractors.
We think it is important to do this. Our contractual situation will catch up, but we are going
to be putting a stake in the ground to do what is required, and to make it mandatory.
It is not that we think it is better to do it this time, and another would be more prescriptive
about it. It applies to our floating fleet around the world, regardless of jurisdiction.
We have issued subsea standards, and this specifies what is required at the end the
well maintenance. It is about maintaining that certification of compliance and doing
the right one, three, and five-year maintenance cycles of our kit.
There are a lot of times that we want to change something, and customer requirements on different
configurations or changing regulations, being rigorous with the management and change process
for the system changes. You heard Tom Hunter present a question this morning about ìdo
we understand what the equipment is down at the seafloor?î We have to maintain that documentation
traceability throughout its life. We get specific about what we want to test prior to -- and
I have a slide on that. Also, how do we get management behind it, supporting it, taking
ownership for the subsea kit, from the CEO's office down to the subsea engineer on the
rig? Part of that is doing a rigorous audit program. Pre-deployment testing -- Moe mentioned
a number of these things built into 53. Just to give some more flavor or color to it, doing
complete valve testing and all the choke and kill lines, making sure that we move and retract,
have a number of connections, weíve got a number
of connectors that move and retract, making sure that they all function; we actually do
a visual on ram closure from bottom up, it seems kind of silly, but you have to do that
just to see them in position . Everything from bolt pods to bolt panels. This takes
a lot of time to do that. All valves, we make sure that we check it, but we also measure
it to see that weíve got proper functioning and closure.
Of course ROV intervention. Chuck had a great slide of some of the things being built into
those capabilities, making sure all those are tested; and this is before we go. Then
a rigorous set of pressure testing. Testing rams, flows, lock positions, the rams are
energized, making sure that we have rigorous tests. This does takes time, something that
the industry is responding to, and this is what we need to do offshore.
In addition to this, I mentioned, once we get on bottom, we do a set of required testing
that is a lot more rigorous than it was before. The industry has done a great job of responding
already to what we learned from the Deepwater Horizon event. Some of the standardization
of BOP's, at API standard 53 workgroup, and how they are different on the operator and
contractor side have kind of raised our expectations across the industry. Critical to this is people,
though; the fifth panel is about training and learning the elements. The subsea capabilities,
this is a complex kit ñ we saw 15,000 parts, theyíre electrical, hydraulic systems, theyíre
a complex kit. We need skilled people out there to do it. There are periods where the
stack is wet, where thereís mud, there is some maintenance to do. There is a lot to
do, so you need a unique individual that really thrives in that kind of environment. We have
a few experienced people go to engineering outfits we are bringing on board, and part
of that is just people, itís just comprehensive training and development. We have in-house
training. We go to vendors for critical training. We have improvement plans on each of these
guys. There is an ongoing assessment program. Iíve got a knowledge handbook here, our subsea
engineers, there is a curriculum they go through, and itís pretty rigorous and it helps to
test their skills and capabilities. Also to help us train, but to help the industry, typically
when stacks are down, they are down for a long periods of time. You might have a subsea
engineer who does not see a stack full for a year. So we actually have hit teams where
we go out and have an additional team comes in to support the effort. One, it provides
training so these guys can fast track their learning because they see a number of back
pulls a year, but also, it assures that some of this critical maintenance that is required
gets done and gets done thoroughly. There is a lot of effort going on. Iíll leave it
at that, I appreciate the time. [applause] Thank you, Don, for a very good presentation.
Our next presenter is Mr. Jeffrey Cutler. He has been working in this industry for over
30 years. Heís been involved in the oil and gas side of the business in various capacities.
For the last 13 years, he has been the Senior Vice President for engineering on the compliance
sides of the business. Jeff is also a part of the joint industry task force after the
Macondo. Please welcome Jeff. [applause] Top performance -- top performers. I think
that is what we all want. It is heartening to me to see the level of agreement we have
here. We have come a long way. We have a long way to go.
One of the things I want to do is to challenge you as I speak to think about two things that
characterize top performers. The first one is consistency. The second one is measurability.
As I make these comments, think about those two items as I go through them.
I may speak more quickly than I normally do, because Iíve got miles to go before I see
the two minute warning. Quite quickly, we will look at two different things in my presentation,
what the current status is and what issues that I see. Speaking a little bit more to
the joint industry project Dr. McCarthy referenced, you can see here a variety of reliability
comparisons with prior studies ñ there were two studies that I quoted here, Centaf 4 and
Centaf two Deepwater, that both measured Mean Time to Failure, as well as the JIP that was
including data from almost all wells that were drilled in the 2004 to 2006 time frame.
You see here a tremendous increase in Mean Time to Failure. Although I agree with Dr.
McCarthy these represent best case scenarios in terms of failures, at the same time they
do represent that our standard testing has resulted in much more reliable equipment.
I would think, though, a more critical parameter here is the variance in the Mean Time to Failure
on a rig-by-rig basis. First, I would like to point out the note
at the bottom that shows 35% of the rigs that were in the study showed no associated failures
at all in the timeframe. That is three years with no reported subsea failures. The flip
side of that is if you look at the range of those that did have failures; you can see
Mean Time Failures somewhere between, on the high side 850 days down to the low side of
50 or so. Thatís a huge number. The study was originally designed to investigate what
those reasons were. Based on the fact that we thought the record keeping was in some
cases suspect, meaning they were as much as five years or
six years old. We thought, and didnít prove, based on statistics, we thought it was largely
dependent on the people. On the current status, we look at the existing
standards. Obviously, we have class as an existing standard, technical class. Weíve
got API that Mr. Modine referenced before, also in the area of specifications as well
as recommended practices, primarily for operations and maintenance. We also have private standards,
and Iíll get to these in just a second. And finally the regulatory standards. And of course,
we've seen the number of times and here these are all generally considered minimum standards.
The reason I bring up these different standards is because each of them can play a part in
current compliance and verification regime. Specifically, who verifies compliance? Each
of those parties Iíve mentioned are capable and recognized as able to provide verification
according to the current regulations. I think there are some particular problems
with that. As an example, if you look at the historical focus of class societies, they
have been more focused with understanding the ability to do pressure containment as
well as failures for load and that sort of thing. If you get a vessel class as acceptable
for a class society, it does not tell you can move from one place to another, it just
says they can comply with standards that are not fitness for purpose standards.
Also, in the compliance, there is a clause that we fit into as a registered professional
engineering company. The selection of the verifier depends very much so on the licensee,
the operator. As a professional engineering registered company, one might imagine a company
registered in New York City that is doing elevator inspections at least by the letter
of the law, would be deemed to be qualified under the existing legislation. I take that
as a ludicrous example intentionally. So, that relates to the confidence requirements
buried in there, and the bigger question is ìhow often is this going to need to be done?î
I am not going to cover that here right now. People are required to verify BOP before every
well. One thing I will mention it, and I will only mention it briefly here, West's verification
standard was developed as a result of the procedures that have been informational over
the last 26 years. We put together those specifications that are job-specific that relate to regulations,
standards, and best industry practices. The big step for us is to decide what is mandatory.
For most of the 26 years, we have been hired as a result of our clientsí desire or recognition
that they provide a value-added service to help them achieve their objectives. However,
once it came time to be a verifier, we had to decide internally what is mandatory and
that wasnít a simple process. One of the things that I have heard a number of times,
and I agree wholeheartedly with, is the need ot consider BOPs as a system; and we think
that includes controls, both electronic and hydraulic. And all of the people who are providing
verification, I do not think provide that same system assurance.
One of the key things for regulators, I think, is to think about unintended consequences;
Iíll offer a few that have been discussed that Iím aware of. First of all, there is
consideration of reduced redundancy. Everybody likes redundancy, everybody likes more than
one. At the same time, the question that we should address is the fact that the industry
has embraced, as a result of the commercial agreements between equipment owners and the
people that use that equipment, is that we have always had, at least for a long time,
provided equipment that exceeds the requirements. Let me give a specific example. It is unusual
to see a BOP stack today working subsea that doesnít have two annulars. There are some
that do have, but the norm, I think, is two annulars. Only one is required anywhere in
any regulation. There is a bit of a climate offshore today that starts from the supposition
that if you have the equipment, it must work, and so with that idea we have doubled the
need to pull the BOP, which is in itself a risky operation, if we have one of the two
annular BOPs that doesnít work. So letís keep in mind the possibility that people will
work toward reduced redundancy as a result of unintended consequences.
People want to talk about more testing; more testing in general is good. I think if you
look at the reliability engineering concept, it suggests more testing equals more reliability.
The caveat there is that testing in and of itself is not deleterious on equipment. I
am unaware of any studies that have been done on the deteriorating effect of testing, itís
generally agreed in the industry that it hurts the equipment to continue to test it. And
weíre doing a lot more testing than we have historically done. One of the good things,
I think, is that weíve had a bit of an increased focus on repair work, specifically in the
non-[unintelligible] regime. Now on the issues I am going to cover quite
quickly, I am not going to give answers. Rather, simply ask questions. I have been accused
of many things, but not having an opinion is not one of them. So what Iíll do is ask
those questions and look for you to follow up on this; offer some considerations, leave
the answer to you. We talked about manufacturing standards and the fact that they are minimum
requirements and that the way they are developed involves necessarily compromises.
One of the key issues -- why do we have standards? So when you purchase something, you know it
is going to be consistent in meeting those minimum standards. At the same time, as time
passes we all recognize there are gaps. There is language in there that allows for technology
advances, which I think is critical. However, at the same time, there is no commentary about
how you evaluate that technology advance, and it is left to the parties in question
to make that statement this is an improved technology. There is no vetting of that against
the standard. Talking a little bit about maintenance systems.
There is always the discussion of whether it is centralized or decentralized. The key
thing there, I think historically the industry has always desired to put the accountability
of responsibility down to the rig manager level. One of the things that results from
that, or can result, is that you have a group of experts, subject matter experts, within
a given technology, making recommendations to the field that may or may not be implemented
based on other criteria of the decision makers. So, there is an issue of control and as it
relates to the maintenance activity versus optimization on a fleet-level basis. I would
like to restate that in a different way with a question; ìhow many the best ways are there
to maintain given piece of equipment?î The second thing that we addressed, really,
with the idea of simple -- is more better? That was one of the things that was a consistent
message post-Macondo. Let's do more of this, more of this, more of that. This certainly
doesnít keep with the idea of keeping it simple and understandable.
We talked about repair. There is not a repair standard. There was developed a 16 AR at one
point that was not passed and withdrew. As John mentioned, itís being re-surfaced. It
addresses remanufacturers. The question here is can the original equipment manufacturer
change? And if so, what are the criteria for that remanufacturer? That will hopefully be
addressed by 16 AR. Similarly, on a parts side, RP 53 talks about
equal or better parts? Who is to determine equal or better? How about mixing and matching
of those parts, is that acceptable and under what criteria is that acceptable. How about
buyout equipment? I have a regulator here in my hand, itís an OEM piece of equipment
if it comes in a bag of a particular marking, if itís not an OEM if itís not through that
system. I can argue both sides of that case. Separately, thereís an upgrade path. Sometimes
there are upgrade equipment that are not available from the OEM. And finally, how about something
thatís discontinued? So, stop the sign says. I offered many questions,
and the answers will vary by providers. The question is what is a minimum standard, and
are we happy about those standards? [applause] Thank you, Jeff. That was a nice overview
from the certification perspective; and very good questions. We have some time for the
question and answer session. We have a few minutes. I will start the discussion. In the
field, you do the maintenance. This is the group we have in the industry so we can continue
improvements. The issue is to transport from the industry so everybody knows there is an
issue. [Inaudible]
That's a good question. [laughter] I can only answer what we do in our organization.
Whenever we have failures, we try to circulate that and ask for feedback. It is being able
to track and quantify what type of failures we are having through the maintenance cycles
we're going through. This is data we can make logical assumptions from.
John. Speaking really personally rather than just for API, I hope we do include Repair
& Remanufacturer licensing back into the Monogram program. We're working on the standard, itís
going to be a while until we the published, and there is really no time frame, considering
we met just last Thursday. Iím no BOP expert. I certainly know that the reality is, we have
these things repaired and manufactured and looked at. If youíre going to mandate testing
and maintenance and repair, then we ought to put some language and requirements around
re-manufacturing. It didnít work the last time because of the way that we set it out.
We need to make sure we lay it out where it works for everybody. So, the only way to do
it, I think, at least one effective way is to set up a program where we are verifying
theyíre capabilities to do this kind of a thing. We're ratcheting up the requirements
on our licensees, whether we are pulling samples from the shelves and sending it to independent
test labs to make sure that theyíre manufacturing in accordance with the standards they are
according to standards. I look forward to being able to license to that in maybe a couple
of years before we get to that point. To build on Moe's comments, I guess a couple
of opportunities for feedback is the initial testing and the [inaudible] we learn certainly
when we do have failures, and weíre pulling the stack, and weíre trying to understand
we have discussions about, you know, can we operate safely with the conditions of the
stack and the components? We had some good discussions, proactive ones, over the last
year about one of the points Jeff made about redundancy. You know, if we have a certain
valve or a function thatís upstream of a critical reliability or closing
function, is it safe to operate? Weíve had some good feedback loops there. And itís
certainly when we have found issues, either technical or QA/QC -- bringing BSEE back in
and feeding our learning back into the organization. Thatís encouraging.
One of the things that I would say is characteristic of the maintenance activities on rigs, from
our perspective is that you never have too much. Iím not aware of very many discussions
where people are happy to reduce the amount of BOP maintenance that is done on rigs. Weíve
done a variety of maintenance studies, I would say almost all our studies have recommended
less maintenance, for a variety of reasons. And reliability engineer looks at the so-called
bathtub curve where we have high failures at the very initial parts. Obviously, with
better training and vetting of parts and that sort of thing, we can do better. But even
with good data, even with good information, there is great reluctance of people to reduce
maintenance as a general thing. If you can look at the performance of rigs on an individual
basis -- I have heard the term, the circus game, Whack-a-Mole. You know, when you get
good performance in one area and bad one in another, you move some folks around, next
thing you know, and you have a different poorly-performing rig. So weíve got a long way to go there
but I think we can do it. Thank you. Any questions from the floor? There
is one over there. Quick question. This is a manufacturing question
I guess. I was wondering {inaudible] duplicate, letís say, the 2,200 psi of external pressure
at the manufacturer's facility? We have not drilled at that depth quite yet.
Ahh, 5,000 feet of water ñ Thatís about 2,500 or so, round numbers
Oh, did I say 25,000? 2,500, sorry. That is a problem with hyperbaric testing.
Most of the chambers, I think thereís one, correct me if Iím wrong, I think there is
one in here in the states that can do hyperbaric testing with significant pieces of equipment.
That is the challenge. The unit, the whole unit, is operating as
an electrohydraulic -- 60 feet high. I'm assuming there is no hyperbaric chamber that is big
enough to create that the external pressure? Not today.
There is one question over there? Iím Kent Satterly with Shell. I would like
to refer to something Moe said earlier. He said: "tell us what you want and let us figure
out how to do it." I think if I could expand, Moe, on what I think you were saying, And
think what you were saying was: ëdonít stifle innovation, tell us what you would like us
to achieve, and let us use our capabilities and our technology to solve that problem.í
You know, part of the purpose of this workshop is obviously to collect information on BOP
performance and capability, but I think itís also for BSEE to understand what this regulation
is supposed to look like and what itís supposed to do. The history of rulemaking, particularly
since Macondo, has been rather on the prescriptive side. The problem with prescriptive regulation
tends to [inaudible] innovation. My question to the panel is: how might the regulation
look like and [inaudible] and technological advancements in BOP's and well control?
That was well said. Again, define the objective and turn us loose. Here we are, weíve gone
inÖ my first "deepwater" rig was a 1970, the Ocean Queen, and 600 feet was considered
ìthe deepest.î We have progressed now to 12,000 feet over that little bit of time.
Weíve taken the early multiplex systems building our first drill ship in ë77, we put a first
generation multiplex system in. We made it work. I guess the key is here, there are many
ways to skin a cat. I was very fortunate to be in the United Kingdom that was our area
to manage, in the United Kingdom. The [inaudible] safety regime started in, and we started seeing
the differences between prescription and goal-setting performance issues. We can achieve what everybody
wants. And don't box us in too much, so we can insure that we can get that innovation
and we can move ahead. Just to add to that, a good question, Kent.
I go back to, I think Tom Hunter mentioned this morning, the government's role, to deal
with the ìwhatî rather than the ìhowî. I think that is what Moe is also reinforcing.
I think Director Watson has talked about, in many public spaces, about ramping up the
capabilities of the BSEE organization, the technical capabilities. And thatís a work
in progress. I think thereís an opportunity to work together on defining the what, but
thereís got to be a strong industry influence into that currently, just from a capabilities
standpoint. And I think being able to -- if we go down the prescriptive route, and I think
thatís the point, Kent, that you were making, itís very hard to change from that. It is
slow and cumbersome and will not keep up with technology development. We have to design
a system that specifies what we really need, what performance criteria will be based on,
and, like Moe says, let us get after it and come up with the solutions.
I think this is one of the greatest technical challenges of our time in a modern basis.
If you go to different industry conferences, one of the common themes is people, and how
we have not very many of them. All these things that we're talking about doing are going to
require more people, more technical staff, more trained, advanced technology and focus.
I think the issues that we have in order to do that, is to understand priorities. We all
want to do everything right now, but we simply donít have the staff to do that. It is particularly
difficult, then, if we go to a performance regime, which is more difficult to understand.
"Do the right thing." how do I audit against "do the right thing"?
While you were getting up to the mic, Jeff, I would argue, though, Jeff, that there's
a level of definition of the ìwhatî. It is not a free for all. So itís clearly, ìthis
is what it needs to do,î how, and then I think we can work in that space.
I agree. I am in favor of a performance-based standard because it provides that flexibility
and encourages innovation. It is just more difficult to deal with by all parties.
Nick with Noble Energy. I think Jeff had a great point when he talked about testing,
the amount of testing we're doing and the impact that testing is having on the system
as a whole. Weíre doing a 15,000 psi pressure test on all functionality when we test on
the surface, then weíre splashing the stack, weíre testing every single function again,
then every 7 days weíre testing the functions again. So, I guess my question is, do we truly
understand the impacts that testing is having? Before we pass any more regulation, are we
going to put any more science behind that testing and how itís impacting the reliability
of the stacks? Because I can tell you from my experience post-Macondo, weíre seeing
more test failures, weíre seeing more stack pulls. So what I would deduct from that is
that reliability is decreasing. Going back to what we were saying earlier, yeah, we want
to see more functionality out of the stack, but I donít think weíve gotten the current
stacks right, because weíre not at 100 percent reliability. So, how can we move forward until
we get what we have right?
Thank you. I think that is just a statement you made.
Great question. I don't know -- it's a good -- I really canít answer that. I don't know
of any plans for a testing program. Maybe that is something that needs to be looked
at a little bit more, how the benefits are done, how it would be done, what we could
get out of that, how long it would take. Think about it. Jeff?
I absolutely agree we need to do more testing. One of the patterns we talked about earlier
is how many pieces of equipment of this type are in service today? You go and you buy an
electronic component, you can buy it from a number of places. They test them to failure,
thereís 68 zillion whatever. The fact of the matter is, we are talking about hundreds
of pieces of equipment here, a very small universe that makes the statistical analysis
very difficult. Not saying we canít or shouldn't do that. We have to keep in mind the reality
of the number of the universe of installed equipment that we have.
This has to do with requirements. We have heard mention of requirements ñ it ripples
through all parts of a life cycle ñ availability, reliability, and then down to the granular
level of every part in the system. What suggestions would you have to assure that requirements
are traceable to the product, itís performance are verified and
validated for the intended function, utility, or some quantifiable value and are also verified
and validated for the worst case scenarios, where you might, if you will, try to break
the software and see how robust it is ok. [laughter]
Do you have any valid manufacturers around? But I think this is more to the manufacturer.
They can answer, because, in my opinion, drillers are just doing the maintenance per the OEM
manuals. I will take a stab at that, if you will. One
of the things that I think we can take great steps at it improving is the transparency
in the transfer of information. One of the things that has been particularly problematic,
not just BOP but other systems as well is what exactly is the equipment designed to
do from a controls and software perspective? Generally speaking, I would characterize what
the owner of the equipment receives from the manufacturer, something like the light on
your car that says ìcheck engine." Thatís just not acceptable. We cannot afford to have
a check engine light and then have to figure out what the softwareís doing. We recently
had an issue where the particular manufacturer had a solution to a particular failure mode,
automatically evoking an emergency disconnect sequence. I have not met anybody that thought
that was a good response for that particular failure mode. What other kinds of things are
buried in that software that we donít know about? So I certainly encourage the transparency
of information as it relates to the transfer of electrons and making decisions one way
and another. Yeah, thanks. I mean the thinking is about
how can you verify that the requirements are addressed? Some of them come down certification,
maintenance, and so forth. It is hard to see if thatís done consistently and if this is
something the drillers will push for or the OEMs will bring or it will be pushed down
ultimately by the oil customers. Thank you. OK. I think we are running out of time, so
we will conclude our panel and thanks for everybody.