Published July 11, 2016
BSEE has been publishing FAQs to the Well Control Rule on the agency website for
the past month. Today BSEE answered a very important question on how the rule will be implemented in regards to ongoing operations and operations that already have
approved permits. The complete answer is on the BSEE website, but in short there will not be any grandfathering of ongoing operations or already approved operations. If there is a
new regulation that goes into effect on July 28, 2016 that you will not be able to comply with, you will need to submit a revised permit requesting either a departure or
an alternate compliance (depending on if your current operation is as safe or safer than what the Well Control Rule requires). The BSEE answer seems to indicate that the
revised permit must be approved prior to July 28, 2016 in order to not interrupt your operations.
As we all know, the Well Control Rule is a very large rule that touches on many phases of well operations. It is strongly recommended that Operators begin to conduct a
gap analysis with the new Well Control Regulations for all ongoing operations as well as permitted operations where operations have not yet begun. Most ongoing operations
will require a revised permit, and it is therefore strongly recommended to have your revised permits submitted as soon as possible to get them into the queue to have them
reviewed by BSEE.
J. Connor Consulting has been actively engaged throughout the entire Well Control Rule making process and has the tools and resources available to help you through this
transitional period. If you have any questions please contact Lance Labiche at
(504) 427-3092 or (281) 578-3388 or by email at Lance.Labiche@jccteam.com.
Download Implementation Guidance PDF