Anchor Project: 20K Regulatory Process and Approval – Challenges and Lessons Learned

Abstract

Abstract This paper provides an overview of Anchor’s project technology compliance with Code of Federal Regulations (CFR) Title 30 part 250 and Bureau of Safety and Environmental Enforcement (BSEE) Notice to Lessees (NTLs) No. 2019-G02 and 2019-G03. Challenges encountered and lessons learned are presented including various equipment qualifications and preparation of hundreds of regulatory compliance documents, handling of proprietary information, and process consistency of different Independent Third Parties (I3Ps). Further, some examples of how changes were managed through the Management of Change (MoC) processes and how BSEE’s Requests for Information (RFI) and responses were handled are discussed. Observations include how project technology fitness-for-purpose (FFP) and the site-specific (SS) fitness-for-service (FFS) as a barrier in the applicable project specific condition was accomplished. When the Anchor Project was initiated, the regulatory language was sufficient to cover the permitting and approval requirements at that time. However, the CFR 250.804 language for equipment operating in high pressure, high temperature (HPHT) environments established and provided for a performance-based requirement to document the verification and validation of equipment, without, however, defining any prescriptive guidance of its intent and implementation process. To establish some specificity and objectivity of assessment, industry reacted to the CFR with early efforts such as for example DeepStar consortium workshops as early as 2013, followed by other industry engagements with regulators. Sessions and seminars at the American Petroleum Institute (API) and the Offshore Technology Conference (OTC) and various joint industry and regulatory workshops created the environment for API to enhance existing standards to address HPHT concerns or develop new HPHT standards. This led to the issuance of BSEE NTLs No. 2019-G02 and No. 2019-G03 which provided guidance for requesting approval to install and use equipment in a HPHT environment. Before the regulatory HPHT approval process was formalized with proper guidance from NTLs, Chevron relied on existing regulations and the information provided in BSEE presentations and workshops and best industry practices to progress the verification and validation of the HPHT technologies. The preparation of documents following the guidance of BSEE NTLs No. 2019-G02 and G03 and CFR 250 requirements involved significant effort and coordination between various teams within Chevron and the Anchor project, and many interactions with I3Ps and subsea equipment vendors and subcontractors. To ensure compliance with CFR and HPHT SS and non-site specific (NSS) NTLs requirements, over 800 documents were submitted to BSEE for review for the Anchor project. The BSEE RFI process required additional clarification or justification, supplemental data submissions in the form of operator expert review (OER) reports, and in some cases, revision of the I3P reports. The combination of the I3P and OER reports submitted, responses to RFIs, numerous meetings and presentations, ultimately resulted in the issuance of review and approval letters for all Anchor HPHT equipment submissions. This paper summarizes the challenges with the regulatory process dealing with the large scope and challenges of the Anchor project. Lessons learned in the collaborative efforts between the company, various equipment vendors and I3Ps, and BSEE to secure compliance to CFR, while coping with COVID-19 challenges and the remote work environment are presented. Other topics regarding barrier philosophies, standard and alternate analysis methods, standards incorporated by reference in CFR, API and other standards are discussed. The major efforts and approach used during this process resulted in the BSEE review/approval of over 800 documents – a prerequisite for the successful execution and installation of the equipment (subsurface, wells, subsea systems, FPU, and export pipelines, etc.). For clarity, the following terms are used throughout this paper. High Pressure High Temperature (HPHT) refers to equipment rated to pressures greater than 15,000 psi and/or temperatures equal to or greater than 350°F. Anchor is a high pressure project under the HPHT category. 20K refers to the Anchor project’s technology development and qualification program.