The Offshore Operators Committee, American Petroleum Institute, Independent Petroleum Association of America, and National Ocean Industries Association and its member companies have engaged the US Minerals Management Service in high-level discussions about annulus casing monitoring, as well as sustained casing pressure in offshore wells. Proposed regulations sent out by the MMS represent a major step toward prescriptive regulations that tend to head off many effective and innovative solutions to problems of this nature. Meetings with MMS leaders and regional repre-sentatives at the agency's headquarters lead me to believe the MMS is willing to listen. Leaders we spoke with were eager to meet and discuss ways we could solve problems identified in this area.
It is critical that the industry understand the potential issues that can come up in the drafting of these regulations. Some of the proposed regulations may have far-reaching consequences.
The OOC is committed to bringing this message forward so that all stakeholders can be aware of efforts to change the way we do business. OOC in its comments and feedback to the MMS clearly noted the significant costs and workload issues associated with the proposed rule making. Our letter pointed out: "MMS and OOC have a long history of working together on policies dealing with casing pressure. OOC has provided comments numerous times to MMS-proposed policies on both sustained and unsustained casing pressure."
Historically, the majority of our comments have dealt with the regulatory and procedural aspects of casing pressure. However, we have come to realize that continued efforts from the regulatory approach will not, in our opinion, be effective on a cost or value added basis and will not reduce risk or improve safety over the current sustained casing pressure practices. Therefore, we now propose taking a technical and risk-based approach to answer the following question, "When is pressure on the casing an unacceptable risk?" We envision developing the answer to the question through a three-prong approach:
- Provide funding to a third party who is mutually acceptable to both MMS and industry to perform a risk-based study of casing pressure
- Based on the findings of the study, develop an API recommended practice (RP) on casing pressure
- Affirm that subsea wellheads designed in accordance with API Spec 17D with the capability to monitor and diagnose casing pressure in the production/tubing analysis pose a lower level of risk than redesigning the wellhead to accommodate monitoring of all casing annuli through the wellhead.
We envision the study and RP to consider the following issues from a technical and risk basis:
- Risk to personnel, equipment, and environment
- Differences in casing and wellhead designs
- Differences in pressure source
- Monitoring
- Testing protocols
- Diagnostics
- Remediation
- Documentation.
The study and RP would address all types of wells, fixed platform (surface wellhead and surface tree), subsea (subsurface wellhead and subsurface tree), and hybrid (subsurface wellhead, surface wellhead, and surface tree), and would address both sustained and unsustained casing pressure. After the RP is adopted by API, it could be incorporated into MMS's regulations similar to the way previous API RPs were incorporated.
OOC would then continue to work with the MMS to establish appropriate reporting procedures by industry to the MMS. The key would be to make sure these procedures are not overly burdensome to either industry or the MMS.
We believe that both API and OOC will sponsor and support such an effort to answer the question "When does casing pressure pose an unacceptable risk?" We should be made aware of the MMS's response concerning this issue in the near future, and we will keep the industry informed of any developments in this area.
Allen J. Verret
Executive Director
Offshore Operators Committee
