QUICK LOOK AT LEGISLATION GOOD OILFIELD PRACTICE AND ALARP RELATIONSHIP OF WOMP TO APPLICATIONS TO UNDERTAKE A WELL ACTIVITY WHAT IS REQUIRED FOR COMPLIANCE ABANDONMENT OF WELLS HAS BEEN THE MOST FREQUENT TOPIC FOR NOPEMA REQUESTS FOR FURTHER INFORMATION ON APPLICATION TO UNDERTAKE WELL ACTIVITIES RECENT ISSUES WITH ABANDONMENT OF AN EXPLORATION WELL PROMPTED THIS PRESENTATON, TO TRY AND COMMUNICATE NOPSEMA’S ASSESSMENT OF ABANDONMENT APPLICATIONS AND WHAT IS REQUIRED TO COMPLY WITH THE REGULATIONS.
Regulations
AUSTRALIAN LEGISLATION
• OFFSHORE PETROLEUM AND GREENHOUSE
GAS STORAGE ACT (OPGGSA) 2006 • RESOURCE MANAGEMENT AND
ADMINISTRATON REGULATIONS (RMAR) 2011 – PART 5
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Presenter
Presentation Notes
TWO PRIMARY PIECES OF LEGISLATION PRIMARY LEGISLATION IS THE OPGGSA 2006; REGULATION MADE UNDER THE ACT ARE PART 5 OF RMAR 2011 WHICH IMPOSE DUTIES ON TITLEHOLDERS (OIL COMPANIES)
Regulations
OPGGSA 2006 Section 569 (1): Work Practices • ALL OPERATIONS IN A WORKMANLIKE MANNER • ALL OPERATIONS IN ACCORDANCE WITH GOOD OILFIELD
PRACTICE Section 572 (3): Removal of Property • REMOVE ALL EQUIPMENT NO LONGER USED IN
OPERATIONS • REMOVE ALL EQUIPMENT NO LONGER TO BE USED IN
OPERATIONS
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ACTS AND REGULATIONS
Presenter
Presentation Notes
WORDING IS PARAPHRASED – PLEASE READ THE ACT FOR CORRECT WORDING ABANDONMENT OPERATIONS MUST BE CARRIED OUT IN: WORKMAN LIKE MANNER – THIS IS NOT DEFINED IN THE ACT BUT DOES NOT GIVE A FREE HAND TO THE REGULATOR – NOT PARTICULARY USEFUL - GOOD OIL FIELD PRACTICE IS DEFINED IN THE OPGGSA AS “ALL THOSE THINGS THAT ARE GENERALLY ACCEPTED AS GOOD AND SAFE IN EXPLORATION AND PRODUCTION OPERATIONS” – AGAIN I AM PARAPHRASING). MUST CONTROL THE FLOW AND PREVENT THE WASTE OR ESCAPE OF PETROLEUM OR WATER IN THE TITLE AREA REMOVE WELLHEAD.
Regulations
OPGGSA 2006 Schedule 3, Clause 13a (2): Duties of titleholders in relation to wells)
• RISKS TO PERSONS AT OR NEAR A FACILITY, FROM;
• SUSPENDED, ABANDONED OR CLOSED-IN WELLS, INCLUDING
FORMATION, OR ANYTHING IN A WELL;
• ARE AS LOW AS REASONABLY PRACTICABLE
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ACTS AND REGULATIONS
Presenter
Presentation Notes
AGAIN I AM PARAPHRASING. CLOSED –IN IS UNDERSTOOD BY NOPSEMA TO BE CLOSURE OF ANY SCSSV AND CLOSURE OF ANY WELLHEAD AND PRODUCTION TREE VALVES. THIS HAS OCCURRED FROM TIME TO TIME ESPECIALLY ON SUBSEA WELLS
Regulations
OPGGSSA 2006 Section 574 (2):(General powers to give directions – NOPSEMA) • NOPSEMA MAY DIRECT TITLEHOLDER IN; • ANY MATTER IN RELATION TO REGULATIONS; • DIRECTION MUST BE IN WRITING Section 586 (2): (Remedial Directions to Titleholders – NOPSEMA) – Section 587 (2) Former Titleholders
• REMOVE PROPERTY • PLUG OR CLOSE OFF ALL WELLS
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ACTS AND REGULATIONS
Presenter
Presentation Notes
NOPSEMA HAS QUITE DRACONIAN POWERS OF DIRECTION – WHICH IT WILL NOT USE LIGHTLY NOPSEMA MUST CONSIDER THE PROTECTION OF NATURAL RESOURCES IN THE TITLE AREA, AND MUST HAVE REGARD TO MAINTAINING THE SUITABILITY FOR A PART OF THE FORMATION FOR PERMANENT STORAGE OF GREENHOUSE GAS . ANY DIRECTION MUST BE IN WRITING WORK MUST BE TO THE SATISFACTION OF NOPSEMA NOPSEMA HAS SIMILAR POWER IN RELATION TO FORMER TITLEHOLDERS WHERE THE TITLE HAS BEEN WHOLLY OR PARTLY REVOKED, WHOLLY OR PARTLY CANCELLED, TERMINATED, EXPIRED.
Regulations
OPGGSSA 2006 Section 589: (Removal, Disposal or Sale of Property – NOPSEMA) IF TITLEHOLDER DOES NOT COMPLY WITH DIRECTION: • NOPSEMA CAN REMOVE & DISPOSE OF PROPERTY ;
AND • RECOVER COST OF THE DISPOSAL FROM THE
TITLEHOLDER OR EX-TITLEHOLDER
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ACTS AND REGULATIONS
Presenter
Presentation Notes
NOPSEMA CAN ONLY RECOVER COST FROM AN EX-TITLEHOLDER IF THE TITLE HAS BEEN WHOLLY OR PARTLY REVOKED, WHOLLY OR PARTLY CANCELLED, TERMINATED, EXPIRED. THIS DOES NOT APPLY IF TITLE HAS BEEN SURRENDERED
Regulations
RMAR 2011
• REG 5.02: ABANDONMENT AND SUSPENSION ARE WELL ACTIVITIES;
• REG 5.04: MUST HAVE AN ACCEPTED WOMP; • REG 5.22: MUST HAVE APPROVAL TO UNDERTAKE
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ACTS AND REGULATIONS
Presenter
Presentation Notes
PARAPHRASING
Regulations
RMAR 2011 – WOMP ACCEPTANCE CRITERIA
• TITLEHOLDER MUST SATISFY NOPSEMA THAT ABANDONMENT RISKS ARE MANAGED IN ACCORDANCE WITH;
GOOD OILFIELD PRACTICE, SOUND ENGINERING PRINCIPLES, STANDARDS & SPECIFICATIONS
• NOPSEMA WILL DECIDE BASED ON: TITLEHOLDER POLICIES AND PRINCIPLES DESCRIBED IN THE
WOMP; AND/OR INDUSTRY ABANDONMENT GUIDELINES AND STANDARDS
• SUCCESS AND DRY HOLE OPTIONS • BARRIER POSITIONS / LENGTHS • BARRIER STATUS DIAGRAMS • EVALUATION PROGRAM • VERIFICATION PLANS
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WOMP v AAUWA CONTENTS
Presenter
Presentation Notes
WHERE A TITLEHOLDER ISSUES A SINGLE WELL WOMP THEN ALL OR SOME OF THIS INFORMATION COULD BE IN THE WOMP – THIS IS A PRAGMATIC APPROACH BY NOPSEMA NOPSEMA HAVE RECOMMENDED TO THE FEDERAL GOVERNMENT CHANGES TO STRENGTHEN THE WOMP AND REPLACE THE AAUWA WITH A NOTIFICATION IF AND WHEN THE CHANGES ARE IMPLEMENTED THEN THE WOMP WOULD BE COME THE ONLY PERMISSIONING DOCUMENT. WE ENVISAGE THE NOTIFICATION BEING A VERY SLIM DOCUMENT WITH ONLY BASIC WELL ACTIVITY INFORMATION.
Regulations
ABANDONMENT GUIDELINES AND STANDARDS
TITLEHOLDER CAN DEMONSTRATE COMPLIANCE WITH GOOD OILFIELD PRACTICE BY REFERAL TO RELEVANT CURRENT INDUSTRY PRACTICE, GUIDELINES AND STANDARDS, SUCH AS: • OIL AND GAS UK - GUIDELINES FOR THE SUSPENSION AND
ABANDONMENT OF WELLS ISSUE 4 - 13 JULY 2012; AND • NORSOK STANDARD D-010 – WELL INTEGRITY IN DRILLING AND WELL
OPERATIONS REV 3 AUGUST 2004 (CURRENTLY UNDER REVIEW)
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GOOD OILFIELD PRACTICE
Presenter
Presentation Notes
COMPLIANCE CAN ALSO BE DEMONSTRATED BY A DETAILED HAZARD ID AND RISK ANALYSIS, DESCRIBED IN THE WOMP THE OIL AND GAS UK GUIDELINE WAS DEVELOPED BY A INDUSTRY WORKING GROUP WHICH INCLUDED A REPRESENTATIVE OF THE UK REGULATOR (HSE) THE NORSOK STANDARD WAS DEVELOPED WITH BROAD PETROLEUM INDUSTRY PARTICIPATION BY INTERESTED PARTIES IN THE NORWEGIAN PETROLEUM INDUSTRY AND IS OWNED BY THE NORWEGIAN PETROLEUM INDUSTRY REPRESENTED BY THE NORWEGIAN OIL INDUSTRY ASSOCIATION (OLF) AND FEDERATION OF NORWEGIAN MANUFACTURING INDUSTRIES (TBL).
• NO MOVEABLE HYDROCARBONS • NO OVERPRESSURED AQUIFERS
Presenter
Presentation Notes
FIRST THING TO ESTABLISH IN ANY ABANDONMENT IS THE DOWNHOLE CONDITIONS SURFACE AND INTERMEDIATE HOLES ARE USUALLY DRILLED AS QUICKLY AS POSSIBLE WITH A LWD IN THE STRING, SO THERE IS A QUESTION MARK OVER QUALITY OF DATA WELLS ON THE NORTH WEST SHELF ARE DRILLED SIGNIFICANTLY OVERBALANCED WHICH COULD MASK ANY PRESSURED AQUIFERS TITLEHOLDER IS LOOKING FOR HYDROCARBONS NOT PRESSURED AQUIFERS NOPSEMA SEEK ASSURANCE THAT DOWN HOLE CONDITIONS HAVE BEEN SATISFACTORILY EVALUATED.
Dry Hole Abandonment
PERMANENT PRIMARY BARRIER
OIL AND GAS UK GUIDELINES 100 ft. MD of good cement, typically 500 ft. MD with or without a mechanical support. Verification : tagged and pressure tested, unless placed on top of a mechanical support.
NORSOK D-010 STANDARD REV 3 100 M of firm cement without mechanical support. Verification: tagged and pressure tested. 50 M of firm cement with mechanical support. Verification: not required Volume mixed to account for surface and down hole contamination during pumping and placement.
Mechanical Support (not a permanent barrier). Tagged and pressure tested.
Seabed plug - not a permanent barrier
Presenter
Presentation Notes
NO MOVEABLE HYDROCARBONS OR PRESSURED AQUIFERS SINGLE PLUG OK – READ FROM SLIDE SURFACE PLUG HAS BEEN AN ISSUE ON A NUMBER OF OCCASIONS. NOPSEMA HAS APPROVED ABANDONMENTS WITH AND WITHOUT A SURFACE PLUG. TITLEHOLDER SHOULD BE CLEAR ON THE RISK BEING CONTROL BY SURFACE PLUG NOT A PRESSURE BARRIER BECAUSE OF ITS LOCATION ADJACENT TO LOW STRENGTH FORMATIONS. IT MAY BE REQUIRED ON ENVIRONMENTAL GROUNDS DEPENDING ON WHAT FLUID IS LEFT IN THE HOLE.
Recent Dry Hole Abandonment
Cement on top of mechanical support , approximately 18 M. Not tagged .
Mechanical support (not a permanent barrier). Tagged and pressure tested.
Squeezed cement below retainer approximately 71 M.
AGE packer above cut 13 3/8” casing plus 50M of cement. Seabed plug - not a permanent barrier
Presenter
Presentation Notes
RECENT ABANDONMENT ISSUE AMBIGUITY IN THE WOMP AND APPLICATION ON ABANDONMENT CONFIGURATION NOPSEMA HAD RESERVATIONS ABOUT THE EVALUATION OF OPEN HOLE AND DEMONSTRATION OF A DRY WELL. NOPSEMA CONCERNED THAT BARRIER WAS NOT PROPERLY VERIFIED. ONLY THE MECHANICAL SUPPORT WAS VERIFIED, WHICH WAS NOT A PERMANENT BARRIER. SQUEEZED CEMENT BELOW – CONDITION AND POSITON CANNOT BE CONFIRMED CEMENT ON TOP OF SUPPORT – NOPSEMA CONSIDERED TOO SHORT FOR GOOD OILFIELD PRACTICE, SO SHOULD HAVE BEEN TAGGED AND PRESSURE TESTED BACK PRESSURE VALVE IN THE CEMENT RETAINER NOT TESTED. THE COMBINATION OF A MECHANICAL PLUG AND TWO UNVERIFIED CEMENT PLUGS DOES NOT MAKE A VERIFIED PERMANENT BARRIER. NOPSEMA DOES NOT CONSIDER THE SURFACE PLUG TO BE A BARRIER AS IT CANNOT CONTAIN SIGNIFICANT PRESSURE. THE DIFFERENCE BETWEEN AN ACCEPTABLE BARRIER AND AN UNACCEPTABLE BARRIER COULD BE AS LITTLE AS A FEW HUNDRED FT OF CEMENT ASK YOUR SELF IS IT REASONABLY PRACTICABLE TO PUMP 100M OF CEMENT INSTEAD OF 30 M. IF YOU DON’T WANT TO WAIT TO TAG A CEMENT PLUG THEN PUMP MORE CEMENT.
Discovery Abandonment
OIL AND GAS UK GUIDELINES 100 ft. MD of good cement, typically 500 ft. MD with or without a mechanical plug. NORSOK D-010 STANDARD REV 3 100 M MD of firm cement. 50M MD on a mechanical plug.
Mechanical plug (not a permanent barrier). Tagged and pressure tested.
Primary Barrier Verification: tagged and pressure tested unless supported by a mechanical plug
Secondary Barrier Verification: tagged
Zone A
Seabed plug - not a permanent barrier
Presenter
Presentation Notes
EXAMPLE ABANDONMNT WHERE EVALUATED PRESSURE IN ‘ZONE A’, IS LESS THAN FRACTURE PRESSURE AT THE SHOE LENGTH OF CEMENT BARRIERS MUST TAKE ACCOUNT OF MIXING DURING PUMPING AND PLACEMENT CONTIGUOUS CEMENT HORIZONTALLY SECONDARY BARRIER VERIFIED BY TAGGING SECONDARY BARRIER CAN BE COMBINED WITH PRIMARY BARRIER , WHICH WILL CHANGE THE LENGTH REQUIRED. 200 FT OR 800 FT PRIMARY BARRIER CAN BE PLACED ON A TAGGED AND PRESSURE TESTED MECHANICAL PLUG AND ONLY HAS TO BE TAGGED PROVIDED LENGTH IS APPROPRIATE. FINAL PLUG (ENVIRONMENTAL PLUG?) IS NOT CONSIDERED BY NOPSEMA TO BE A BARRIER AND NOT NECESSARY IF FRACTURE PRESSURE AT SHOE IS LESS THAN FORMATION PRESSURE THEN TWO BARRIERS ARE REQUIRED BELOW THE SHOE – HOWEVER THIS SHOULD NEVER HAPPEN AS CASING SHOULD BE SET IF SUCH A SITUATION IS ENCOUNTERED.
Multi-Zone Discovery Abandonment
OIL AND GAS UK GUIDELINES 100 ft. MD of good cement, typically 500 ft. MD with or without a mechanical plug. NORSOK D-010 STANDARD REV 3 100 M MD of firm cement. 50M MD on a mechanical plug.
Mechanical plug (not a permanent barrier). Tagged and pressure tested. Primary Barrier to Zone A
Verification: tagged and pressure tested
Secondary Barrier to Zone A and Primary Barrier to Zone B Verification: tagged and pressure tested.
Zone B
Zone A
Secondary Barrier to Zone B Verification: tagged and pressure tested unless set on a mechanical plug.
Seabed plug - not a permanent barrier
Presenter
Presentation Notes
EXAMPLE OF ABANDONMENT WHERE EVALUATED PRESSURE IN ZONE A GREATER THAN FRACTURE PRESSURE AT THE SHOE LENGTH OF CEMENT BARRIERS MUST TAKE ACCOUNT OF MIXING DURING PUMPING AND PLACEMENT CONTINUOUS CEMENT HORIZONTALLY SECONDARY BARRIER TO ZONE A CAN BE COMBINED WITH PRIMARY BARRIER , WHICH WILL CHANGE THE LENGTH REQUIRED. CASING BARRIER CAN BE PLACED ON A TAGGED AND PRESSURE TESTED MECHANICAL PLUG AND ONLY HAS TO BE TAGGED PROVIDED LENGTH IS APPROPRIATE. IF FRACTURE PRESSURE AT SHOE IS LESS THAN FORMATION PRESSURE THEN TWO BARRIERS ARE REQUIRED BELOW THE SHOE – HOWEVER THIS SHOULD NEVER HAPPEN AS CASING SHOULD BE SET IF SUCH A SITUATION IS ENCOUNTERED. FINAL PLUG IS NOT CONSIDERED BY NOPSEMA TO BE A BARRIER - TITLEHOLDER SHOULD BE CLEAR ABOUT THE RISK THAT IS BEING CONTROLLED.
Regulations
ABANDONMENT PRINCIPLES
• TWO VERIFIED BARRIERS BETWEEN HYDROCARBONS AND SURFACE
• ONE VERIFIED BARRIER BETWEEN OVERPRESSURED AQUIFER AND SURFACE
• ONE VERIFIED BARRIER BETWEEN PERMEABLE ZONES OF DIFFERING PRESSURE
• BARRIER MUST BE HORIZONTALLY CONTIGUOUS • MECHANICAL PLUGS ARE NOT PERMANENT BARRIERS
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Regulations
FINAL THOUGHTS
ABANDONMENT IS FOREVER YOU WILL NOT GET A SECOND CHANCE
