A--RFI: Definition of Permanent Barriers

RFI DOIEFBO260009 Attachment 1 – Draft SOW 1 of 15 SECTION 1 DRAFT STATEMENT OF WORK Definition of Permanent Barriers 1.1 Introduction The Bureau of Safety and Environmental Enforcement (BSEE) is committed to promoting safety, protecting the environment, and conserving offshore resources through rigorous regulatory oversight and enforcement of offshore facilities engaged in oil and gas exploration, development, and production operations on the Outer Continental Shelf (OCS). To support effective decision making, BSEE invests in scientific research and technology assessments that address operational challenges in extreme offshore environments. Among other responsibilities, BSEE regulates the barriers required to maintain a seal of the well during operation and when plugging and abandoning. Defining permanent barriers within BSEE’s policy is critical for ensuring safe and environmentally responsible operations. 1.2 Background Hydraulic isolating barriers are essential "tools" designed to prevent fluid movement within a wellbore, whether in the space between the well and its casing or within the main well itself. They are critical components of a well-integrity system and can be categorized as either permanent or temporary based on their intended duration of use as barriers. These barriers play a vital role in safeguarding lives, protecting the environment, and ensuring the long-term integrity of the well. These tools encompass a wide variety of technologies, from mechanical plugs that are physically installed to fluids that can be pumped into place and later hardened to form an isolating barrier. Common examples of mechanical barriers include cast iron bridge plugs and tubular hangers equipped with packers, while cement serves as a typical non-mechanical barrier. However, these are not the only options available; they are simply the most commonly used. These tools provide hydraulic isolation and are crucial for maintaining the integrity of the well. This integrity is vital for keeping the well secure and under control throughout its entire lifespan, from construction to abandonment. Consequently, a thorough understanding of these barriers is critical to grasping their influence on the well's integrity and safety. In this document, hydraulic isolating barriers are defined as equivalent to the primary and secondary barriers specified in the Code of Federal Regulations Title 30 Chapter II Subchapter B Part 250.200(b). For a barrier to be recognized as such, it must undergo the testing requirements outlined in CFR 250.206. The CFR outlines requirements for barriers but provides limited guidance on the minimum parameters for permanent barrier plugs. This study aims to address that gap by improving BSEE’s understanding of these minimum parameters and developing guidelines for barrier qualification to support sound, science based permitting and policy enforcement. 1.3 Objective This study aims to review different types of permanent barriers, establish appropriate criteria and develop a database of minimum requirements for each type of barrier, and introduce a scorecard for evaluating the effectiveness and documentation of these barriers. The study should concentrate on compiling existing data on various barriers, obtained from manufacturers or via a literature review. The emphasis will be on identifying technologies currently in use globally -- 1 of 15 -- RFI DOIEFBO260009 Attachment 1 – Draft SOW 2 of 15 within the oil field sector, rather than conducting tests on these barriers. However, if the author determines that certain tests are necessary, these findings could be included as a conclusion in the report. BSEE plans to utilize this report and its outcomes to evaluate the supporting documents provided by operators, ensuring they meet the minimum requirements established in this study. Additionally, the report will aid in enforcing existing policies related to barrier installation and maintenance, while also considering potential future regulations regarding the types of barriers deemed acceptable in various scenarios. Conducting a technically reviewed study allows BSEE to improve its decision-making and enforcement processes. This ensures that these processes are based on data-driven decisions and align with policy directives, including Executive Order 14154 and Secretarial Order 3418 on Unleashing American Energy. 1.3.1 Research Questions 1. What types of technologies are available for constructing permanent barriers in offshore wells, both within and outside of tubular structural elements? 2. Which barrier technology performs best for each application? 3. What are the minimum barrier element parameter requirements for each of the barriers to be considered an effective isolating barrier? 4. To what extent have the technologies available for permanent barriers in offshore wells reached their current levels of maturity? 5. What are the benefits and disadvantages of the technologies available for permanent barriers in offshore wells? 1.3.2 Relevance and Importance of the Research Barriers are vital for offshore oil extraction safety because they maintain well integrity and control. Both permanent and temporary barriers play a fundamental role in managing the significant risks associated with this industry, but only the permanent barriers are considered integral parts of the well in its complete life cycle. They serve as essential lines of defense, safeguarding lives, protecting the environment, and ensuring the long-term integrity of the well. Reviewing these important safety barriers with a detailed technical analysis creates a solid basis for safety rules that the BSEE can apply to all related operations. This approach ensures the efficient and consistent enforcement of dependable regulations that the industry can rely on. Such reliability cultivates a culture of compliance and accountability within the industry, encouraging operators to prioritize safety in their daily practices. …