25 years in well -control and rig equipment inspection...

25 Years In Well-Control and Rig Equipment Inspection • Registered on ISN Net World and PEC Premier • OHSAS 18001: 2007 • ISO 9001: 2008 • IADC Accredited Training Center

Ricky Eaton Intervention Manager 21 years in Subsea Operations and Well-Control Equipment

Kickoff meeting and contents Safety evaluation of onsite personnel and equipment Intervention well-control equipment from a regulatory standpoint Equipment Pedigree Theoretical Shear Calculations The Letter

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Agenda

Kick Off Meeting

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Understanding the third-party verification process.

Narrow the gray areas with a frozen scope of work.

Critical components documentation and traceability review.

Incidents of Non-Compliance (INC) prevention.

Performance Improvement Plans (PINC) prevention.

Preventive maintenance and Repair history.

A equipment checklist philosophy will stay efficient alongside onsite systems testing.

Shearables.

Kick Off Meeting

We use a safety checklist in the evaluation process.

Job Safety Analysis (JSA) Proper testing equipment Ensure safety barriers Personnel competency


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Onsite Safety Evaluation

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Intervention Well-Control Equipment from a Regulation Standpoint

Subsea Intervention Units in retrospect are considered BOPs per 30-cfr-250.1706(e). These units are reviewed in accordance with the rig-based BOP regulations as

much as possible. The following documentation is being required by BSEE and pertains to the third-

party verification process:

Third-Party Shearing Verification Independent Third-Party Verification


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Critical Components Checklist

The components identified throughout this process intended to control or regulate the movement of wellbore fluids are considered critical.

The third-party verification process for Intervention well-control is driven by the Code of Federal Regulations (CFR). Not opinions. An experienced independent third-party technical team uses practical methodology. Any well-control verification process should be designed for the equipment being

used and to work efficiently with the onsite systems test procedures.



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Equipment Pedigree Importance of documentation

Indicates the equipment has been properly designed and constructed.

Validates Non Destructive Examinations (NDEs) and major inspections. Tracks modifications and current drawings. Documents the integrity of the equipment.

Equipment Pedigree What is pedigree


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Equipment Pedigree Onboard Documentation

Copies of the manufacturer’s equipment data book and third-party certification shall be available for review.

Equipment records such as API manufacturing documentation (COCs), NACE certification, and factory acceptance testing reports will be available onsite.

Maintenance and repair historical files shall be maintained by serial number and stay with the equipment at all times.

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Equipment Pedigree Preventive Maintenance (PM)

Planned maintenance is much more cost efficient than unplanned maintenance.

PM programs are audited through the independent third-party verification

process and considered critical. Intervention systems will meet or exceed OEM recommendations. Maintenance documents should be maintained on file, at the rig.



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Equipment Pedigree Insufficient Equipment Documentation

• Experience has shown that equipment often has insufficient

documentation.

• This results in a significant scope of work to verify compliance.

• We start with the PM program to see how the equipment is maintained.

• Building a pedigree through existing documentation.


Data Dashboard Pressure Containing Components Serial Number

S/N Verified

? Yes / No

PSL NDE/UT Inspection Date

Last Major

Inspection

COC Date

COC comments and location.

Maintenance

Documentation

Review Date

Rated Working Pressure

Last Docume

nted FAT Date

Data Book PM Program

5.25 15k Lubricator Ball Valve BPTH

20003-002 Yes 3 Jul-14 7/1/2014

8/16/20124

Recertification July 2014

5/15/2014 (RRE) 15k

6/21/2008

Yes Acceptable End Cap, 7 5/8” Thor Box, Collar Flange (2)

2186618/2/1 2186618/2/2 Yes 3

7/1/2014

7/25/2005


5/15/2014 (RRE) 15k Yes Acceptable

Seat 10110409-2-

1 Yes 3 7/1/20

14 9/12/2002



End Cap Retaining Ring (2)

W001 (Top) W002(Botto

m) Yes

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7/1/2014

11/11/2006

Recertification July 2014 5/15/201

4 (RRE) 15k Yes

Acceptable 5.300” Bore Ball Modification #102632 Rev. C

ENG389-03 /W004 Yes

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Jul-14 7/1/2014

9/22/2011

Recertification July 2014 5/15/201

4 (RRE)

15k Yes

Acceptable Main Housing, 15k Open Water Lubricator Valve 2186614/1/2 Yes 3 Jul-14 7/1/20

14 9/30/2003



Cage Nut 2220845/1/1 Yes 3

7/1/2014

1/13/2006



End Cap, W/ 7 5/8” Thor Pin W001

SLX3222F1 Yes 3 7/1/20

14 3/23/2006



Thor Pin S-seal P100001

5509 Yes 7/1/20

14 Recertification July 2014


Ball Half Cage 2193450/2/1 Yes 3 7/1/20

14 7/11/2005



Upper Mandrel Isolation Ring 2189225/12/

1 Yes

3 7/1/20

14 9/1/20

01 Recertification July

2014 5/15/2014 (RRE) 15k Yes Acceptable

Ball Rotation Boot (2) Replacement

2169998/1/2 2169998/1/1 Yes 3

7/1/2014

2/12/2007



Cage End Cap 2189225/7/1 Yes 3 7/1/20

14 3/2320

06 Recertification July

2014 5/15/2014 (RRE) 15k Yes Acceptable

Lower Mandrel ENG857-02

W001 Yes 3 7/1/20

14 8/20/2002



Lower Mandrel, Isolation Ring Stop W002 Yes

3 7/1/20

14 11/12/2002




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Independent Third-Party Theoretical Shear Verification Equipment

• Intervention Well-control OEM • Ram/Valve Model • Size and Pressure Rating • Shear Operator/Booster/Bonnet • Ram Design

Shearables • Pipe/Coil Tubing/Wireline • Wall Thickness [in] • Pipe Grade • Yield Strength • Water Depth

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4 types of independent third-party letters

Full condition independent third-party verification letter

o Complete systems audit and document review.

Independent third-party verification follow-up letter o Confirming nothing has been compromised since last service.

Regulatory Standpoint Independent Third-Party Verification Letters


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Regulatory Standpoint Independent Third-Party Letters

Statement of Fact (SOF) o Revisions to operations, procedures or equipment to keep

working. Wet Verification Letters

o Well hops


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Regulatory Standpoint Operations

Wet Verifications

Since the Wet Verification testing was conducted subsea, rather than on the stump, this is a more realistic demonstration of the intervention well-control system ability to work as intended if called upon during a well-control event.



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At The End of The Day

The well-control equipment will operate as originally designed.

Any modifications or upgrades to the equipment conducted after delivery has not compromised the design or operations of the system.

The equipment is designed for the specific equipment on the rig and

for the specific well design.

The equipment has not been compromised or damaged from the previous service.

The IWC equipment will operate in the conditions in which it will be

used.


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Contact Information

• Ricky Eaton • 1-281-398-3317 • [email protected]