A pragmatic interpretation of the BSEE Well Control Rule Real-Time Monitoring (RTM) requirements and a Comprehensive Real-Time Monitoring Plan are the Keys to Success.
The BSEE Well Control Rule (WCR) introduces a new requirement for collecting and transmitting well control equipment status and well integrity data when conducting “well operations with a subsea BOP or with a surface BOP on a floating facility, or when operating in a high pressure high temperature (HPHT) environment”. While the rule itself is straightforward, there is significant uncertainty about what is specifically required and how it should be implemented. The uncertainty is rooted in several diverse factors including:
- The somewhat inappropriate nomenclature, as the terms “real-time” and “remote” seem interchangeable
- Defining and achieving the necessary data quality is difficult as the specific purpose of the remote monitoring centers is unclear
- Navigating real time monitoring solutions is difficult since the potential solutions range from simple cloud databases to permanently manned 24×7 remote operations centers.
With an eye towards reducing the uncertainty and clarifying what is necessary to meet the requirements, let’s first look at what the rule actually says.
CFR 30 §250.724 asks ‘What are the real-time monitoring requirements?” and proceeds to describe 4 essential requirements:
You must have a real-time monitoring capability for the BOP control system, the well’s fluid handling system, and the downhole conditions as measured by any installed bottom hole assembly tools.
- You must transmit the monitored data to an onshore location as it is gathered and provide the capability for onshore qualified personnel to access and analyze that data.
- The operator must describe that remote monitoring capability to BSEE via a Real-Time Monitoring Plan, and provide a certification as part of your permit application.
- The operator must provide BSEE access to the on-shore monitoring facility and data.
What is more notable is that several critical pieces of information appear to be missing from the rule, including the specific data that should be monitored, and the specific roles and responsibilities of the offshore and onshore personnel with respect to using the data.
This lack of specifics represents a shift from a prescriptive regulatory approach to a performance based approach. While performance based rules may seem ambiguous, they are intended to provide a flexible implementation framework that accommodates differences in operations and makes adoption of newer and safer technologies much easier.
The BSEE provides a mechanism for addressing any ambiguity and gaining approval of your RTM capability by requiring that you create and make available to BSEE a real-time monitoring plan. This plan must specify the data you will collect, how you will be collecting it, where and when it will be transmitted and how the on-shore and off-shore resources will interact with respect to analyzing the data. In other words, the plan is your avenue to inform BSEE how you interpret the rule and address the “ambiguous” requirements.
The starting point for this plan is an understanding of the intent of the rule. There have been several industry forums which have resulted in voluminous amounts of comments and feedback attempting to define and clarify BSEE’s intent. At a high level:
- The rule is intended to increase the number and scope of qualified resources that can view and interpret well control data with the goal of enhancing the decision making.
- Operational decision making authority is not described in the rule and is not changed by the rule. Operational decision making authority remains where you currently define it.
- The rule is specifically and intentionally limited to remote monitoring, and there is no requirement for remote control.
It is within this context that we can interpret the BSEE rule and design real time monitoring systems to meet that intent. While the real-time monitoring plan must address numerous system capabilities such as data quality, resource competencies, cybersecurity, roles and responsibilities, for the purposes of this analysis let’s consider two specific parameters: the definition of “real-time” and the nature of the on-shore facilities.
The “real-time” requirement is called out and applied to three different activities covered by the rule:
- Data collection – BSEE requires that “… you must gather and monitor real-time well data …”
- Data transmission – BSEE requires that “You must transmit these data as they are gathered …”
- Remote data availability – BSEE requires that “Onshore personnel who monitor real-time data must have the capability to contact rig personnel during operations.” Which implies that the data analysis capability must be available to remote resources during the operation being monitored.
Having three different references to real-time makes designing a solution difficult. However, when considering the intent described above, we can arrive at a definition of real-time that covers all three activities. The intent is to inform and support decision making across both local and remote resources, during the operation being monitored. The definition of real time can then be stated as allowing sufficient time to allow the remote resources to receive, view and analyze the data so that their analysis is still relevant to the decision.
As for the capability of the on-shore monitoring, this can range from the highly advanced and interactive data centers to simple cloud based analysis packages. BSEE does not specify the form, only the function. As with the definition of real time, we can consider the intent of the rule when designing the on-shore monitoring capability. The on-shore resources need to be able to analyze the data and participate in the decision making. If this can be accomplished through a cloud database system and a spreadsheet analysis, then that is sufficient. There is no need to invest in large interactive data centers just to meet the BSEE rule.
The rule provides a performance based framework that allows the Operator or Lease Holder to design a real-time monitoring system that best fits the operational parameters. The rule also provides, through the requirement for a real-time monitoring plan, the mechanism for describing the specific implementation to BSEE for their approval. Athens Group Services has experience in the design, specification and verification of real time monitoring systems including the critical issues of data quality, remote access and analysis, and cybersecurity. We have developed templates and examples of real time monitoring plans that can be used as the basis for your RTM systems. Contact us for further information or assistance in implementing your RTM system to meet this new regulatory requirement.
Copyright 2017 Athens Group.