Wells – DRAFT July 2015

TRIM Record Folder – [Record Folder]

Well Operator – [Company Name] Well Engineering & Operations Inspector – [Name]

REQUIREMENTS FOR WELL NOTIFICATION SUBMISSIONS

SCHEDULE 9 INSPECTION TEMPLATE

Note on Purpose of Template

This document will be available to inspectors to record the inspection of a well notification submitted under SCR2015 against the requirements of Schedule 9 , which outlines the ‘Particulars to be included in a notification of well operations ’. It has been decided that this will be conducted by the Wells Topic

Specialist inspector for the installation. The notification will also be copied to the Environmental Topic

Specialist. By exception the inspector may refer the notification to further topic specialist inspector(s) to comment where he/she feels it is necessary to explore the details of the submission further.

The document is drafted to complement the guidance being produced to support the regulations as well as existing topic sector guidance. Requirements identified by green text are new to SCR2015; those in black text were present in SCR05. It is proposed that similar templates will be developed for each discipline that together will form the complete record of the inspection process undertaken by the

Competent Authority. It is proposed to make these templates freely available to promote transparency and assist industry in drafting its submissions.

Relevant Pre-Existing Guidance

The following documents are industry guidance that can aid in determining if the duty holder is following good industry practice:

Well Lifecycle Practices Forum



Guidelines for the suspension and abandonment of wells



Guidelines on qualification of materials for the suspension and abandonment of wells



Guidelines for well-operators on competency of well-examiners



Guidelines for well-operators on well examination



Guidelines on competency for wells personnel



Guidelines on relief well planning for offshore wells



Well life cycle integrity guidelines



Guidelines on BOP Systems for Offshore Wells

Energy Institute



Model code of safe practice Part 17 Volumes 1,2 & 3 – High Pressure High

Temperature Wells



Model code of safe practice Part 15 – Area classification code for installations handling flammable fluids



Guidelines for offshore oil and gas installations that are not permanently manned

TRIM: 2015/274188 Revised: 22 July 2015

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Schedule 9 - Particulars to be included in a notification of well operations

1. The name and address of the well operator.

2. Where the well operation is to be carried out—

SCR2015 Regulatory Requirement

(a) from an installation, the name of the installation and the name and address of the duty holder for that installation; or

(b) by means of a vessel (not being an installation), the name of that vessel.

3. Particulars of the fluids to be used to control the pressure of the well.

4. Particulars of any plant, not described in the current safety case for the installation, which is to be used in connection with the well operation.

5. Particulars of the type of well, its number, and slot number, association with installations, and the name of any field development of which it may be part.

6. A description of the well operation and a programme of works which includes—

(a) the date on which the well operation is expected to commence and finish;

(b) the intended operational state of the well at the end of the well operation , including whether it is intended to be permanently or temporarily abandoned and whether production equipment is to be placed into the well for future use;

(c) details of barriers against loss of well control (including the equipment, drilling fluids and cement);

(d) directional control of the well path; and

(e) limitations on safe operations in keeping with the risk management.

7. A description of—

(a) any activities on or in connection with an installation or a vessel (not being an installation) during the well operation described pursuant to paragraph 6 which may involve any hazards with the potential to cause a major accident; and

(b) such hazards.

8. In the case of a well which is to be drilled—

(a) particulars, with suitable diagrams, of—

(i) the location of the top of the well;

(ii) the directional path of the well-bore;

(iii) its terminal depth and location; and

(iv) its position, and that of nearby wells, relative to each other;

(b) particulars of the geological strata and formations, and of fluids within them, through which it will pass, and of any hazards with the potential to cause a major accident which they may contain;

(c) the procedures for effectively monitoring the direction of the well-bore, and for minimising the likelihood and effects of intersecting nearby wells; and

(d) a description of the design of the well, including the limits on its safe operation and use.

9. In the case of an existing well—

( a) a diagram of the well;

(b) a summary of earlier operations in relation to it;

(c) the purposes for which it has been used;

(d) its current operational state;

(e) its state of repair;


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(f) the physical conditions within it; and

(g) its production capacity.

10. Where a well operation is to be carried out from a non-production installation or a vessel (not being an installation)—

( a) particulars of—

(i) the meteorological and oceanographic conditions to which that installation or, as the case may be, vessel may foreseeably be subjected;

(ii) the depth of water; and

(iii) the properties of the seabed and subsoil at the location at which the well operation will be carried out; and

(b) a description of how the well operator and—

(i) the owner of the installation; or

(ii) the operator and owner of the vessel, involved in the well operation will co-ordinate their management systems so as to reduce the risks from a major accident to comply with the relevant statutory provisions.

11. The report made under regulation 11(2)(b) in relation to the well operation, addressing in particular the matters in paragraph 6(c) to (e), together with a description of the actions of the well operator in response to the report.

12. A risk assessment incorporating a description of—

(a) the particular hazards associated with the well operation including any environmental, meteorological and seabed limitations on safe operations;

(b) the subsurface hazards;

(c) any surface or subsea operations which introduce simultaneous major hazard potential; and

(d) suitable control measures.

13. Where a well is to be constructed, modified or maintained by means of a non-production installation, additional information as follows—

(a) a description of any environmental, meteorological and seabed limitations on safe operations, and arrangements for identifying risks from seabed and marine hazards such as pipelines and the moorings of adjacent installations;

(b) a description of environmental conditions that have been taken into account within the internal emergency response arrangements for the installation;

(c) the description of the internal emergency response arrangements and a description of arrangements for responding in cases of major environmental incidents that are not described in the safety case; and

(d) a description of how the management systems of the well operator and the owner are to be coordinated to ensure effective control of major hazards at all times.

14. Particulars of information obtained pursuant to the PFEER Regulations and the Management Regulations 1995, so far as—

(a) relevant to the prevention of a major accident, and

(b) not otherwise required to be provided pursuant to this Schedule.

15. In respect of a well operation to be conducted, particulars of information relevant to the relevant statutory provisions obtained pursuant to Directive 2011/92/EU of the European Parliament and of the Council on the assessment of the effects of certain public and private projects on the environment.

16. An adequate description of the well operator’s safety and environmental management system (unless such a description has already been submitted by the well operator under another provision of these Regulations).


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Inspection Guidance / Minimum Information WN Ref Inspector’s Inspection Comments

1) Well Operator name

Well Operator address

2) Where the well operation is to be carried out — a) Installation name

Name of installation duty holder

Address of installation duty holder

OR b) Name of vessel

3) Particulars of the fluids to be used to control the pressure of the well:



Generic fluid type for drilling each hole section.



Mud density for each hole section.



Generic fluid type for testing, completion, workover operations.



Fluid density for each operation type; e.g. completion, testing, workover, re-entry etc.

4) Particulars of any plant, not described in the current safety case for the installation, which is to be used in connection with the well operation:

List of plant not included in SC, for example:



Well test package.



Workover BOP and riser.



High-pressure frac pump.



Cutting injection system.



Coiled tubing equipment.



Wireline equipment.



Hydraulic workover unit.


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Inspection Guidance / Minimum Information WN Ref

Inspector’s Inspection Comments

5) Particulars of the type of well, its number, and slot number, association with installations, and the name of any field development of which it may be part:



Exploration, appraisal or development.



Function for which it will be used if development well e.g. oil producer, gas producer, gas injector, water injector, gas lift, ESP producer, etc.



Well number. DECC well number [should include slot number for development wells]. DECC numbering system to be used prior to spud. (See DECC Petroleum Operations Notice PON 12 for details of well numbering systems)



Field name of which it is part.



Installation SC in which details of development wells are included – (i.e. production installation to which subsea wells are connected)

6) A description of the well operation and a programme of works:

List of operations to be carried out; e.g. re-enter, plugback, sidetrack, test, drill, extended well test, workover, set gauges, etc. a) Estimated start date and estimated finish date or duration. b) The operational state at the end should be one of: completed, permanently abandoned or temporarily abandoned (suspended), and whether production equipment (xmas tree etc.) is to be installed on it for future use. c) Details of barriers against loss of well control (including the equipment, drilling fluids and cement)?

Summary of the well programme which details the major steps related to the loss of well control e.g.: drill pilot hole for shallow gas, casing pressure test details, leak-off test and formation integrity tests to be carried out and required minimum values, cementing and confirmation of cement tops, testing of barriers prior to removing BOPs, testing details, details of well control equipment etc.


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Inspector’s Inspection Comments d) If applicable, a summary of how the directional control of the well path will be maintained during the well operation e) Pressure temperature and metallurgical limitations of the well and how these have been incorporated into the proposed well operation.

Provide limits and details of well control equipment.

7) A description of

— a) Those specific activities connected with the particular well operation with the potential to cause a major accident, examples are given in 7(b) below. b) These hazards could be such as: increase in collision frequency due to frac boat; increased risk of H

2

S when drilling a long reach appraisal well from a development platform; shallow gas; high pressure; higher gas inventory due to installing gas lift, major lost circulation due to severely depleted reservoir; higher than original pressures due to localised pressurisation from gas or water injection; testing high pressure wells with an un-weighted packer fluid; unable to work to company standards due to failure in a well, etc.

Details of any combined operations and names of other installations involved.

Confirm if SIMOPS are allowed and if this well operation will extend their scope.

Details of other operations connected with the well e.g. use of frac boat alongside, well test vessel to which produced fluids are being transferred, testing operations, cuttings injection, etc.

8) In the case of a well which is to be drilled — a) Are the particulars outlined, with suitable diagrams, of — i) Latitude and longitude of the surface and target location. ii) Directional plot for non-vertical wells: to include vertical


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Inspector’s Inspection Comments section and horizontal plan. iii) TD: measured and vertical. iv) Map showing the surface location and entire lateral position of well and all others in the vicinity (either at surface or at subsurface level). b) Geological column from surface to TD, detailing measured and vertical depths.

Estimated formation pressures in all permeable and porous zones.

Estimated fracture pressures at the intended casing points.

Prognosed fluid types (e.g. gas, condensate, oil, etc.) presence of gas cap etc., fluid gradient, presence and concentration of toxic or corrosive gases (e.g. CO

2

, H

2

S, etc.).

Potential producing formations to be identified.

Temperatures in potential producing formations, and at TD.

Confirmation that a specific shallow seismic review has been completed.

List particular hazards associated with the well e.g.:



Squeezing salt.



Major loss circulation zones.



Large uncertainty in geological prediction e.g. due to: salt domes, shallow wells, shallow gas, etc.



Overpressures.



Other hazards. c) Survey programme for each hole section.

Confirmation that the well operator has looked at potential for collision with all relevant wells and has plans in place to minimise risks.


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Confirmation that there is a system for programming surveys, and for comparing survey data with that of nearby wells, and that there is criteria for taking action.

List nearby wells, which are of special significance with respect to the drilling of the particular well and any intended action.

Provide separation factors for the significant wells. d) Estimated maximum surface pressures and temperatures during the well operations.

Summary of the hole sizes and section TD’s.

Summary of casing strings to be run, including setting depth, hanger depth (where appropriate), size, weight, grade and coupling, kick tolerance, and their specification if not API grades.

Provide wellhead specifications. Identify formation in which they should be set if basis for shoe selection.

Details of the cementing programme for each casing string and for any abandonment or suspension to be carried out continuous with drilling programme. Should include: zones to be cemented and slurry densities.

Details of test programmes including estimated maximum flow rates, whether the rig B

OP’s or xmas tree is to be used, perforating system and packer fluid.

Schematic diagram of proposed completion if a development well.

Pressure temperature and metallurgical limitations of the proposed well.

Provide limits and details of well control equipment.


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9) In the case of an existing well

— a) Current casing and completion or suspension diagram. b) List with dates of major operations on well e.g. set surface casing, tied back, drill and suspend, re-enter and carried out

EWT, re-enter and complete, major workovers, re-completions, setting insert completion strings using coiled tubing etc. c) List of purposes for which used, highlighting current use: e.g. appraisal well, oil producer converted to water injector, currently used for water injec tion, or for cuttings disposal to 20” / 13 3 /

8

” annulus; lifting method for a production well, etc. d) Current operational state is suspended or completed, shut-in or online. e) Details of any known or suspected safety related failure or defect in the well e.g. tubing to annulus communication, control line failure, corrosion problems, tree valve or subsea manifold failures. f) Details of barriers and fluids in the well. g) Estimated or actual shut in pressures and flow rates.

10) Where a well operation is to be carried out by means of a nonproduction installation or a vessel — a) The following particulars to be provided — i) Confirmation that the meteorological and oceanographic conditions have been assessed for the individual location for all times of the year that the installation / vessel may be on location; that they have been compared with limits of the installation / vessel and would not exceed them; specifically highlight if any conditions are approaching the limits of the installation / vessel: this should include riser tensioning, vortex shedding, etc. ii) Water depth and height of rotary table above mean sea level. iii) Provide main conclusions of the site survey and shallow seismic, which would include: potential for shallow gas at the location and in the vicinity, anchoring conditions, potential for punch through (jack-ups), seabed obstructions in the vicinity (pipelines, cables, wrecks, etc.).


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Inspector’s Inspection Comments b) A description of how the operator and owner of the installation; or, the operator and owner of the vessel involved in the well operation will co-ordinate their management systems so as to reduce the risks from a major accident to comply with the relevant statutory provisions.

The following information should be provided:

Assigned responsibilities for the main activities in connection with operations on the well: casing design, well control, testing, materials selection, completions, list of main responsible, list company responsibilities and where appropriate individual responsibilities e.g. OIM for jack-up may be OIM for combined operation complex.

Confirmation that those with assigned responsibilities have or will have policies, procedures or a detailed programme relating to their responsibilities in line with the particular well operations described in the notification, or if they do not, whose systems will be followed.

Applicable Codes of Practice, Standards or Recommended

Practices which will or will not be applied (important to highlight any internal policies, procedures or guidelines which will not be followed) e.g. API specifications, EI Model Codes of Safe

Practices, Oil & Gas UK Guidelines, etc.

Communication paths for normal and abnormal operations.

Details of the management and contractual structure, indicating how the various sub-contractors are linked to the well operator.

11) A copy of the well examination report in relation to the well operation included, together with a description of the actions of the well operator in response to the report.

The well notification should include the well examiners report and the planned actions of the well operator should be noted against each finding or comment. Where recommendations of the well examiner have not been accepted by the well operator, the reason


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Inspector’s Inspection Comments for non-acceptance should be given.

12) A risk assessment incorporating a description of — a) the particular hazards associated with the well operation including any environmental, meteorological and seabed limitations on safe operations? b) the subsurface hazards? c) any surface or subsea operations which introduce simultaneous major hazard potential? d) suitable control measures?

The well notification should include a risk assessment. This is a slight change to the requirement of the SCR 2005, which required a description of the hazards specific to the well.

The risk assessment should identify the hazards specific to the well and with the potential to cause a major accident; it should summarise the arrangements to control the risk.

In addition to the hazards arising from the subsurface conditions it should cover those arising from the environmental, meteorological and seabed conditions at the well location and the conduct of the operation or the planned use of the well.

Examples would include: the hazards associated with temporary well test equipment, the risk of collision due to the presence of a hydraulic fracturing vessel; an increase in gas inventory due to installation of a gas lift; and the simultaneous conduct of operations on adjacent wells.

13) Where a well is to be constructed, modified or maintained by means of a non-production installation, additional information as follows

— a) a description of any environmental, meteorological and seabed limitations on safe operations, and arrangements for identifying risks from seabed and marine hazards such as pipelines and the moorings of adjacent installations? b) a description of environmental conditions that have been taken into account within the internal emergency response arrangements for the installation?


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Inspector’s Inspection Comments c) a description of the internal emergency response arrangements and a description of arrangements for responding in cases of environmental incidents that are not described in the safety case? and d) a description of how the management systems of the well operator and the duty holder are to be coordinated to ensure effective control of major hazards at all times?

The well operator, if not itself the dutyholder for the installation, has a duty to cooperate with the dutyholder to enable him to comply with relevant statutory requirements. This applies in particular to the requirements of PFEER to prevent and mitigate fire and explosion and the release of flammable or explosive substances, for example during well testing using mobile surface test equipment. The arrangements will normally be fully covered by other requirements of this Schedule.

14) Particulars included of information obtained pursuant to the PFEER

Regulations and the Management Regulations 1995, so far as

— a) relevant to the prevention of a major accident? and b) not otherwise already required to be provided pursuant to this

Schedule?

15) In respect of the well operations to be conducted, are there particulars included of information relevant to the relevant statutory provisions obtained pursuant to Directive 2011/92/EU relating to the prevention of major accidents resulting in significant or serious damage to the environment?

The well notification should provide a description of information required under the Directive 2011/92/EU relating to the prevention of major accident which may result in significant or serious damage to the environment. In this context, the description could relate to but not limited to potential environmental effects from a major accident, and a description of technical and non-technical measures envisaged to prevent, reduce or offset them, including monitoring.

16) Has the well operator already submitted an adequate description of its safety and environmental management system as part of another submission under SCR2015? If not, is there an adequate description of the well operator’s safety and environmental management system?


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The description requires information on the management structure indicating the roles and responsibilities of key personnel involved with the well operation, including the operator's representatives and representatives of subcontractors on board the installation or vessel.

This entails identifying who has overall charge of the well operations and specifying the arrangements made for communication between responsible persons both on and offshore, during normal operations and in emergency conditions. The notification should refer to the safety related systems, codes and procedures which will be applied during operations, for example: well control procedures: permit-towork systems; barrier policies; well and completion design; and material or equipment selection.

A description of the well operator’s safety and environmental management system should be included with the notification if it has not been submitted to the competent authority with a previous notification or with a safety case for which the well operator is the installation dutyholder. The CMAPP and the description of the SEMS are live documents. Therefore, although the notification may be completed any material change to these documents should be submitted to the competent authority on submission of the next well notification after the material change is completed.


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Wells – DRAFT July 2015

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