This paper assesses regulatory rules associated with drilling and completions activities in Queensland unconventional oil and gas plays. This assessment is based on a typology that classified rules into defined categories, defining their structure and what types of activities are required to assure them. This paper also reviewed a sample of ‘as built’ Well Completion Reports (WCR) to understand the self-assurance activities conducted by operating companies as well as to identify trends in compliance against a sample of rules.
The typology assessment identified that rulemaking was generally consistent across documents, and a clear balance existed between rules focused on design and rules focused on field operations. The assessment also identified the actual wording of rules could benefit by more standardisation in some areas. Importantly, this assessment also identified the large volume of complex assurance activities faced by inspectors.
The ‘as built’ data review identified a clear commitment to the written rules and evidence of self-assurance activities being consistently conducted by operators. This review also confirmed the value of WCR analysis and the potential to use them to measure compliance.
Whilst this paper has provided valuable insight into rule making and the approach to self-assurance taken by some operators, there are many areas of the wider regulatory system that would be well served by further analysis. This paper has proposed some recommendations for such analysis to help make a more holistic assessment of effectiveness in the future.
