The Newly Published BSEE Guidance Documents for the Approval of HPHT Equipment, Wells, and Projects in the Gulf of Mexico

Abstract The Bureau of Safety and Environmental Enforcement (BSEE) first published High Pressure/High Temperature (HPHT) regulations at 30 CFR 250.807 in 2010. Additional HPHT regulations were published in 2016. In 2019, BSEE published three (3) Notices to Lessees and Operators (NTLs) to provide clarification and guidance regarding BSEE's implementation of the regulations. The NTLs also provide recommendations, which if followed, facilitate BSEE's review and approval of HPHT equipment and well designs. The following NTLs formalized the guidance BSEE has been providing operators through the Conceptual Plan approval process: NTL No. 2019-G03 "Guidance for Information Submissions Regarding Site Specific and Non-Site Specific HPHT Equipment Design Verification Analysis and Design Validation Testing" provides guidance on information that an operator should submit concerning material selection, design verification analysis, design validation and functional testing processes, and procedures. It also explains BSEE's recommendations on how an operator could prove that HPHT equipment is fit-for-service in the applicable HPHT environment. Lastly, it provides guidance on Independent Third Party (I3P) and Operator Expert Reviewer (OER) reviews and reports.NTL No. 2019-G02 "Guidance for Information Submissions Regarding Proposed High Pressure and/or High Temperature (HPHT) Well Design, Completion, and Intervention Operations" provides recommendations and clarifications regarding operator HPHT well design, completion, and intervention operations information submittals that, if followed, facilitate BSEE's review and approval. Additionally, it provides guidance on I3P and operator reviews and reports.NTL No. 2019-G04 "Requesting Approval to Consider External Hydrostatic Pressure Effects When Calculating Internal Pressure Containment Capability for Pressure Containing and Pressure Controlling Subsea Equipment" provides guidance regarding the information that BSEE needs to analyze an operator's alternate equipment request, pursuant to 30 CFR 250.141, seeking approval to consider external hydrostatic pressure in the design and calculation of internal pressure containment capability of subsea equipment. The paper will focus on NTL No. 2019-G02 and NTL No. 2019-G03 (HPHT NTLs). The HPHT NTLs walk the reader through the required plans and reports an operator must submit and the voluntary plans and reports an operator may submit when requesting a review of HPHT equipment or a HPHT well design by BSEE. The HPHT NTLs describe the information BSEE requests in each plan and report in order to complete a review. They also outline the requirements for independent reviewers of HPHT equipment and well designs and provide guidance regarding report preparation and presentation. If any statement in this paper is inconsistent with the regulations or the NTLs, the regulations and NTLs govern.