CASING PRESSURE NTL

Gulf Coast Environmental Affairs Group

(GCEAG) Meeting

RUSSELL HOSHMANMay 14, 2009 Houston, TX

MMS Contact InformationMMS Contact Information

Ken KinnettKen Kinnett

Phone Number: 504-736-2847Phone Number: 504-736-2847

e-mail: kenneth.kinnett@mms.gove-mail: kenneth.kinnett@mms.gov

2009 Casing Pressure NTL2009 Casing Pressure NTL

• NTL No. 2009-G01 “Casing Pressure” will NTL No. 2009-G01 “Casing Pressure” will replace the 1994 Sustained Casing replace the 1994 Sustained Casing Pressure LTLPressure LTL

• Effective date: July 1, 2009Effective date: July 1, 2009

• This NTL has being drafted into a This NTL has being drafted into a Proposed Rule Proposed Rule

Maximum Allowable Wellhead Maximum Allowable Wellhead Operating Pressure (MAWOP)Operating Pressure (MAWOP)

• MAWOP from API RP 90 for an annulus is the MAWOP from API RP 90 for an annulus is the lesser of the following:lesser of the following:• 50% of the MIYP of the casing being 50% of the MIYP of the casing being

evaluated; orevaluated; or• 80% of the MIYP of the next outer casing; or80% of the MIYP of the next outer casing; or• 75% of the MCP of the inner tubular pipe 75% of the MCP of the inner tubular pipe

bodybody• The outermost pressure-containing casing The outermost pressure-containing casing

MAWOP can not exceed 30% of its MIYPMAWOP can not exceed 30% of its MIYP

MAWOP ExampleMAWOP Example API RP 90 API RP 90

50% 75% 80% %Annulus MIYP Collapse MIYP Collapse MIYP MWOP MIYP

PSIG PSIG PSIG PSIG PSIG PSIGProd Tubing 3.5", 12.9#, L-80 15,000 15,310 11,483 N/A

"A" 7 5/8",39#, Q-125 14,340 12,060 7,170 9,045 7,170 50%"B" 9 5/8", 53.5#, Q-125 12,390 8,440 6,195 6,330 9,912 2,760 22%"C" 13 3/8", 68#, K-55 3,450 1,950 1,725 1,463 2,760 1,725 50%"D" 18 5/8", 87.5#, K-55 2,250 630 1,125 1,800 675 30%

Monitor/Record Casing PressureMonitor/Record Casing Pressure

• Fixed Platform Wells, monthly, one data Fixed Platform Wells, monthly, one data point/month point/month

• Hybrid and Subsea Wells, continuously, one Hybrid and Subsea Wells, continuously, one data point/daydata point/day

• Departure Wells:Departure Wells:• Manned Platform, daily, one data point/dayManned Platform, daily, one data point/day• Unmanned Platform, weekly, one data point/weekUnmanned Platform, weekly, one data point/week

* Zero is a number, needs to be recorded.* Zero is a number, needs to be recorded.

Within 30 Days of First Observing Within 30 Days of First Observing Casing Pressure or Imposing Pressure, Casing Pressure or Imposing Pressure,

Perform a Casing Diagnostic Test if:Perform a Casing Diagnostic Test if:

• Fixed Platform Wells > 100 psigFixed Platform Wells > 100 psig

• Hybrid Well Casings & Risers > 100 psigHybrid Well Casings & Risers > 100 psig

• Subsea Well, 100 psig > external hydrostatic Subsea Well, 100 psig > external hydrostatic pressurepressure

• Exemptions – Prod casing on G/L and wells Exemptions – Prod casing on G/L and wells undergoing startupundergoing startup

Perform Subsequent Casing Perform Subsequent Casing Diagnostic Test:Diagnostic Test:

• Once every 5 years for B,C, D, etc annuli Once every 5 years for B,C, D, etc annuli exceeding 20% of MIYPexceeding 20% of MIYP

• Once a year for A annuli exceeding 10% MIYPOnce a year for A annuli exceeding 10% MIYP• When a departure expires or becomes invalidWhen a departure expires or becomes invalid• When any casing or riser has a 200 psig When any casing or riser has a 200 psig

increaseincrease• G/L wells shut-in or flowing for 180 daysG/L wells shut-in or flowing for 180 days• After corrective action due to denialAfter corrective action due to denial

Maintaining Records Maintaining Records

• Two years for all casing pressure recordsTwo years for all casing pressure records

• Must be readily available in the fieldMust be readily available in the field

• Last casing diagnostic test maintained Last casing diagnostic test maintained until the well is abandoneduntil the well is abandoned

• No longer need to notify MMS of initial No longer need to notify MMS of initial casing pressurecasing pressure

Departure Request NeededDeparture Request Needed• If a Fixed Platform Well has casing If a Fixed Platform Well has casing

pressure greater than its MAWOPpressure greater than its MAWOP

• If a Fixed Platform Well has casing If a Fixed Platform Well has casing pressure greater than100 psig that can not pressure greater than100 psig that can not bleed to zero in 24 hr or is not bled to zerobleed to zero in 24 hr or is not bled to zero

• If communication exists between tubularsIf communication exists between tubulars

Departure Request NeededDeparture Request Needed

• If a casing has increasing pressure that is If a casing has increasing pressure that is bled to prevent it from exceeding its bled to prevent it from exceeding its MAWOP except during startup.MAWOP except during startup.

• If the well is a Hybrid well with pressure > If the well is a Hybrid well with pressure > 100 psig100 psig

• If the well is a subsea well with pressure > If the well is a subsea well with pressure > external hydrostatic pressure + 100 psigexternal hydrostatic pressure + 100 psig

Within 14 Days after Diagnostic Within 14 Days after Diagnostic Test Make a Departure RequestTest Make a Departure Request

• Company name and addressCompany name and address• Area name, OCS block number, lease Area name, OCS block number, lease

numbernumber• Manned or unmanned structureManned or unmanned structure• Water depthWater depth• Well name and API numberWell name and API number• Well schematicWell schematic• Well status (SI, TA, Prod., Inj., or GL)Well status (SI, TA, Prod., Inj., or GL)• Well type (dry tree, hybrid or subsea)Well type (dry tree, hybrid or subsea)

Within 14 Days after Diagnostic Within 14 Days after Diagnostic Test make a Departure RequestTest make a Departure Request

• All casing/riser sizes, weight, grades and MIYPAll casing/riser sizes, weight, grades and MIYP• All casing/riser calculated MAWOP’sAll casing/riser calculated MAWOP’s• All casing/riser pre-bleed down pressureAll casing/riser pre-bleed down pressure• Shut-in and flowing tubing pressureShut-in and flowing tubing pressure• Volume and types of fluid bledVolume and types of fluid bled• Last well testLast well test• Date and description of casing diagnostic testDate and description of casing diagnostic test• For all casing exceed 100 psig the diagnostic For all casing exceed 100 psig the diagnostic

test datatest data• Concentration of H2S present.Concentration of H2S present.

Departure ApprovalDeparture Approval

• MMS Regional Supervisor for Field MMS Regional Supervisor for Field OperationsOperations

• Term to be determined on a case by case Term to be determined on a case by case basisbasis

• May establish additional restrictions May establish additional restrictions

Departure DenialDeparture Denial

• Contact MMS District Manager within 72 Contact MMS District Manager within 72 hourshours

• Provide Plans for corrective action within Provide Plans for corrective action within 30 days 30 days

• District Manager can set time period for District Manager can set time period for corrective actioncorrective action

Corrective Action Without Corrective Action Without Departure RequestDeparture Request

• You can submit an APM or Plan for You can submit an APM or Plan for Corrective Action to the District Manager Corrective Action to the District Manager without making a departure requestwithout making a departure request

• Within 30 days after DiagnosticsWithin 30 days after Diagnostics• You will still need to provide the casing You will still need to provide the casing

pressure or diagnostic information for that pressure or diagnostic information for that well to the Regional Supervisor alone with well to the Regional Supervisor alone with copy of APM or Plancopy of APM or Plan

After Corrective ActionAfter Corrective Action

• Perform a casing diagnostic within 30 days after Perform a casing diagnostic within 30 days after corrective action takencorrective action taken

• Submit the casing diagnostic test to the Regional Submit the casing diagnostic test to the Regional Supervisor to change casing pressure well Supervisor to change casing pressure well statusstatus

• Submit the casing diagnostic test to the Regional Submit the casing diagnostic test to the Regional Supervisor for a departure request if the Supervisor for a departure request if the diagnostic test indicates that a departure is diagnostic test indicates that a departure is needed.needed.

Changing Departure StatusChanging Departure Status

• If a well is operating under a departure If a well is operating under a departure and the well condition changes such that a and the well condition changes such that a departure is no longer needed, you must departure is no longer needed, you must submit a diagnostic test to change the submit a diagnostic test to change the casing pressure well status.casing pressure well status.

Departure Becomes InvalidDeparture Becomes Invalid• The casing or riser pressure increases by The casing or riser pressure increases by

200 psig over the departure pressure200 psig over the departure pressure

• The departure expiresThe departure expires

• The well is worked over, sidetracked, The well is worked over, sidetracked, recompleted or acid stimulatedrecompleted or acid stimulated

Departure Becomes InvalidDeparture Becomes Invalid

• A different casing or riser on the same well A different casing or riser on the same well requires a departure requires a departure

• If you have more than one casing on a If you have more than one casing on a single well with a departure and if any one single well with a departure and if any one becomes invalid then they all become becomes invalid then they all become invalidinvalid

Questions?Questions?