The Canada-Newfoundland and Labrador Offshore Petroleum Board
(C-NLOPB) has co-published with the Canada Nova Scotia Offshore Petroleum Board (CNSOPB) the Drilling and Production Guidelines. These guidelines address each of the 91 sections of the Newfoundland Offshore Petroleum Drilling and Production Regulations, and speak to a full range of topics associated with drilling and production projects.
The guidelines were initially issued on December 31, 2009 in draft form, for use on a one-year trial basis. Based on feedback received from various stakeholders and experience with their use, a number of improvements were made and the guidelines were re-published on May 31, 2011. The updates took into consideration the special oversight measures implemented for deep water operations as well as a review of initiatives taken in other jurisdictions.
Max Ruelokke, Chair and CEO of the C-NLOPB, said the changes to the guidelines are part of an on-going process of improvement to the Board’s regulatory oversight of offshore oil and gas activities. “Consistent with the key principles of performance based regulations, the need to update guidance on an ongoing basis is necessary to keep pace with industry best practices and evolving technology,” he said.
In the view of the dynamic nature of the matters addressed in the drilling and production guidelines, a process to initiate another round of updates will commence later this summer. In the next round, the Board will take into account its review of the Offshore Helicopter Safety Inquiry Implementation Team Advisory Documents, the Provincial Government’s Review of Offshore Oil-spill Prevention and Remediation Requirements and Practices in Newfoundland, as well as the Board’s review of the Presidential Commission into the Deepwater Horizon incident. Input from stakeholders including industry, the workforce and outside experts will be sought as part of this process. In the meantime, any comments, questions or suggestions for improvement to these guidelines are welcomed. These can be forwarded to information@cnlopb.nl.ca.
The most recent updates and improvements to the Drilling and Production Guidelines include:
- Management system expectations were clarified in section 5.3.
- New guidance was added to sections 5.7 and 5.8 on “document control” and “change control process” to clarify expectations in how management systems documentation should be controlled.
- Redundant guidance regarding flow systems and metering was removed and, instead, the “Measurement Guidelines” were referenced.
- Removed redundant guidance regarding well data acquisition requirements and, instead, referenced the “Data Acquisition Guidelines”.
- Comprehensive guidance was added to section 6 respecting contingency planning to address relief well drilling, flight following and vessel tracking, resource sharing and mutual aid agreements, oil spill preparedness, precautionary down-manning, search and rescue, a dedicated Search and Rescue (SAR) helicopter, exercises and drills, communication equipment and facilities, medical support and subsea oil spill containment equipment.
- Guidance was added to section 6 respecting the public release of contingency plans, specifically the need to arrange any personal information in the plan in a manner that facilitates its redaction. This will aid in the public release of these plans as is provided in the legislation.
- Added guidance to section 10.5 clarifying that an “Approval to Alter the Condition of a Well” is required for chemical treatment programs that could affect the completion of a well.
- Added guidance to section 16.2 with respect to how a resource management plan is to be updated as part of the annual production report.
- Added guidance to section 19 respecting the ALARP principle (to reduce risk to personnel and the environment to a level that is as low as reasonably practicable).
- Added guidance to section 26.0 respecting considerations for “sour” environments.
- Added a reference to the “Offshore Waste Treatment Guidelines” in section 28.10 regarding performance standards for oiled drill cuttings.
- Added guidance to section 29.6 with respect to both stump testing and subsea testing of back-up Blowout Preventer (BOP) control systems (Remotely Operated Vehicle [ROV] Intervention; Autoshear; Deadman and Acoustic). Also, added guidance respecting arming of back-up systems and the need for two blind shear rams in the BOP stack.
- Added guidance to section 37.8 respecting requirements for back-up BOP systems with particular expectations for ROV intervention capability.
- Added clarification to section 29.9 respecting high pressure riser expectations.
- Added guidance with respect to section 34(2) of the regulations that the operator should explicitly specify the type of downhole safety valve to be used during formation flow tests as this is a critical well barrier during testing operations.
- Added guidance to section 36.2 with respect to dual mechanical barriers in casing strings.
- Added a reference to American Petroleum Institute Recommended Practice 90 respecting the integrity of production wells.
- Amended section 37.2 clarifying expectations respecting the testing frequency of BOP stacks.
- Added to section 43.3 expectations respecting inflow testing of well barriers.
- Added guidance respecting process operations to section 45.4.
- Clarified expectations for function testing and pressure testing subsurface safety valves in section 47.1.
- Added to section 62.1 guidance that a conservation officer should be notified of any failures of custody flow meters.
- Added guidance to section 68 respecting prohibition of oil burning.
- Added additional content for drilling and production reports in section 84.1.
- Clarified guidance respecting notification of safety and research related reports in section 84.5.
As a result of publishing these new guidelines in final form, the
C-NLOPB’s Guidelines Respecting Drilling Programs have been rescinded. The C-NLOPB has also issued an Interpretation Note covering the following matters:
- Evacuation Systems
- Materials and Personnel Handling Equipment and Procedures
- Lighting, Sound and Occupational Hygiene
- Handling of Chemical Substances, Waste Material and Oil
- Quick Disconnect and Mooring Quick Release Systems
- Organizational Competence
- Helicopter Decks
- Protection of Combustion Engines
Media Contact:
Sean Kelly M.A., APR, FCPRS
Manager of Public Relations
(709) 778-1418
(709) 689-0713 (cell)
skelly@cnlopb.nl.ca
Any reference in the News Release Archive to C-NLOPB e-mail addresses may have changed or been updated. All current e-mail correspondence with the Board contain @cnlopb.ca notwithstanding the address in the respective news release.