1. CASING PRESSURE NTL Gulf Coast Environmental Affairs Group (GCEAG) Meeting RUSSELL HOSHMAN May 14, 2009 Houston, TX

2. MMS Contact Information Ken Kinnett Phone Number: 504-736-2847 e-mail: kenneth.kinnett@mms.gov

3. 2009 Casing Pressure NTL • NTL No. 2009-G01 “Casing Pressure” will replace the 1994 Sustained Casing Pressure LTL • Effective date: July 1, 2009 • This NTL has being drafted into a Proposed Rule

4. Maximum Allowable Wellhead Operating Pressure (MAWOP) • MAWOP from API RP 90 for an annulus is the lesser of the following: • 50% of the MIYP of the casing being evaluated; or • 80% of the MIYP of the next outer casing; or • 75% of the MCP of the inner tubular pipe body • The outermost pressure-containing casing MAWOP can not exceed 30% of its MIYP

5. MAWOP Example API RP 90

6. Monitor/Record Casing Pressure • Fixed Platform Wells, monthly, one data point/month • Hybrid and Subsea Wells, continuously, one data point/day • Departure Wells: • Manned Platform, daily, one data point/day • Unmanned Platform, weekly, one data point/week * Zero is a number, needs to be recorded.

7. Within 30 Days of First Observing Casing Pressure or Imposing Pressure, Perform a Casing Diagnostic Test if: • Fixed Platform Wells > 100 psig • Hybrid Well Casings & Risers > 100 psig • Subsea Well, 100 psig > external hydrostatic pressure • Exemptions – Prod casing on G/L and wells undergoing startup

8. Perform Subsequent Casing Diagnostic Test: • Once every 5 years for B,C, D, etc annuli exceeding 20% of MIYP • Once a year for A annuli exceeding 10% MIYP • When a departure expires or becomes invalid • When any casing or riser has a 200 psig increase • G/L wells shut-in or flowing for 180 days • After corrective action due to denial

9. Maintaining Records • Two years for all casing pressure records • Must be readily available in the field • Last casing diagnostic test maintained until the well is abandoned • No longer need to notify MMS of initial casing pressure

10. Departure Request Needed • If a Fixed Platform Well has casing pressure greater than its MAWOP • If a Fixed Platform Well has casing pressure greater than100 psig that can not bleed to zero in 24 hr or is not bled to zero • If communication exists between tubulars

11. Departure Request Needed • If a casing has increasing pressure that is bled to prevent it from exceeding its MAWOP except during startup. • If the well is a Hybrid well with pressure > 100 psig • If the well is a subsea well with pressure > external hydrostatic pressure + 100 psig

12. Within 14 Days after Diagnostic Test Make a Departure Request • Company name and address • Area name, OCS block number, lease number • Manned or unmanned structure • Water depth • Well name and API number • Well schematic • Well status (SI, TA, Prod., Inj., or GL) • Well type (dry tree, hybrid or subsea)

13. Within 14 Days after Diagnostic Test make a Departure Request • All casing/riser sizes, weight, grades and MIYP • All casing/riser calculated MAWOP’s • All casing/riser pre-bleed down pressure • Shut-in and flowing tubing pressure • Volume and types of fluid bled • Last well test • Date and description of casing diagnostic test • For all casing exceed 100 psig the diagnostic test data • Concentration of H2S present.

14. Departure Approval • MMS Regional Supervisor for Field Operations • Term to be determined on a case by case basis • May establish additional restrictions

15. Departure Denial • Contact MMS District Manager within 72 hours • Provide Plans for corrective action within 30 days • District Manager can set time period for corrective action

16. Corrective Action Without Departure Request • You can submit an APM or Plan for Corrective Action to the District Manager without making a departure request • Within 30 days after Diagnostics • You will still need to provide the casing pressure or diagnostic information for that well to the Regional Supervisor alone with copy of APM or Plan

17. After Corrective Action • Perform a casing diagnostic within 30 days after corrective action taken • Submit the casing diagnostic test to the Regional Supervisor to change casing pressure well status • Submit the casing diagnostic test to the Regional Supervisor for a departure request if the diagnostic test indicates that a departure is needed.

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

19. Departure Becomes Invalid • The casing or riser pressure increases by 200 psig over the departure pressure • The departure expires • The well is worked over, sidetracked, recompleted or acid stimulated

20. Departure Becomes Invalid • A different casing or riser on the same well requires a departure • If you have more than one casing on a single well with a departure and if any one becomes invalid then they all become invalid

21. Questions?