Bureau of Safety and Environmental Enforcement (BSEE) approval of Shell’s Appomattox, located in the Gulf of Mexico, has helped define and clarify the safety requirements in its recently published high pressure and high temperature (HP/HT) related guidance documents.
The Appomattox project, which saw first oil in May 2019, is the first high temperature project to gain BSEE approval in the Gulf.
“BSEE’s job is to drive safety performance and environmental sustainability in all offshore energy activities,” said BSEE director Scott Angelle. “The collaboration between the offshore energy industry and BSEE spurred the innovation necessary to safely pursue resources in HP/HT operating conditions.”
In the Code of Federal Regulations, high pressure is defined as greater than 15,000 psi and high temperature is defined as greater than 350 degrees Fahrenheit.
Although the first HP/HT project in the Gulf of Mexico was proposed in late 2009, the Appomattox is the first to begin production, and in early June National Oilwell Varco announced the sale of two 20,000 psi blowout preventer stacks expected to be deployed in the Gulf of Mexico in 2021, making his decision a timely one.
“Having clear guidance available to all offshore operators drives safety and makes sense to ensure safe and environmentally-sustainable operations,” explained director Angelle. “In the past we had companies individually submitting data on HP/HT operations, without the benefit of a comprehensive or systematic framework for organizing and sharing that information. What we are implementing is a new approach that puts together industry experts to define the processes, procedures and standards that make up best practices, and makes that knowledge available to everyone.”
BSEE approved about 140 permits and plans covering different aspects of the Appomattox project. Because the semi-submersible platform is a major deepwater production facility, BSEE’s approval process for the structure alone occurred in three phases. It required a review by a certified verification agent, who followed the design, fabrication, and installation of the structure, then recommended to BSEE’s Office of Structural and Technical Support to accept the work.
Beginning in 2017, BSEE conducted several production safety system reviews and two pre-production inspections prior to approving Shell’s production on the Appomattox platform.
“In each permit review and inspection, high temperature conditions were factored into the approvals,” said BSEE Gulf of Mexico region director Lars Herbst. “The lessons we learned were incorporated into the newly published HP/HT-related guidance documents.”