NORSOK D-010: Section 7 Completion Respondent WIF / Jan Krokeide Date Section 15.09.2012 7 Chapter number 15.10 Suggested text Comments Change bullet i B from "provide a seal in annulus space between the itself and the wellhead," to "• provide sealing in between the tubing, wellhead and x-mas tree," Submitted before 15.09.2012 7 15.10 Change D to the following: "All seals shall be tested in the direction it is designed to hold pressure." A seal cannot be qualified if not tested the correct way. WIF / Jan Krokeide 15.09.2012 7 15.10 Add a point to F: "2. Accessible seals (land- and platform wells) shall be Leaks through TH seals is a commonly known industry problem. The status should be known such that repairs and mitigating actions periodically leak tested, first time within 1 year then at a maximum frequency of can be done avoiding further escalation of leak to the surroundings. 2 years." Yes Yes WIF / Jan Krokeide 15.09.2012 7 15.12 Change A to the following: "This element consists of the wellhead housing and Typing error and clarify that the valve is an annulus valve. an annulus isolation valve." Yes WIF / Jan Krokeide 15.09.2012 7 15.12 Add 5 point to F as follows: "2. The test duration for the valves shall be minimum 10 min, test duration is volume and compressibility dependent and shall be hold for a period giving measurable pressure change for the allowed leak rate 3. Manual valves exposed to injection or production fluids shall be minimum leak tested every 6 months. For passive annuli the manual valves shall be minimum tested yearly. 4. Injection valves shall be leak tested at regular intervals as follows: • monthly, until three consecutive qualified tests have been performed, thereafter • every three months, until three consecutive qualified tests have been performed, thereafter • every six months For existing fields with good reliability data for the valve type and specific fluid and rate conditions, 1 monthly and 1 three monthly test is sufficient before increasing the regular test intervals to every six month 5. If the leak rate cannot be measured directly, indirect measurement by pressure monitoring of an enclosed volume downstream of the valve shall be performed. 6. The injection valves shall be periodically function tested including the emergency shutdown function based on reliability analysis but as a minimum yearly. It shall be verified acceptable shut down time and that the valve closes on signal." Missing requirements for valve testing Yes Change C point 5 to the following: "5. When used in conjunction with annulus injection (gas lift, cuttings injection, etc.) any low temperature cycling effects need to be taken into consideration and the valve shall be.: • surface controlled, • automatically operated, • fail-safe closed," Same requirements of fail safe etc as for XT and DHSV in this case WIF / Jan Krokeide 15.09.2012 15.09.2012 7 7 15.12 15.29 Yes 7 15.29 C point 1: Change to: "1. The components (pipe and threads) shall be gas tight Gas tight treads should only be required when exposed to HC whenever exposed to hydrocarbons during its lifetime. " Yes WIF / Jan Krokeide 15.09.2012 7 15.29 C point 4: Change to "For gaslift valves and CIVs to qualify as a well barrier there shall be a qualification test demonstrating the valves ability to be gas tight over an operator defined number of cycles. The valve shall be subject to frequent testing with acceptable results similar to testing of SCSSVs" Yes WIF / Jan Krokeide 15.09.2012 7 7 15.29 15.29 Add same requirements to CIV as to GLV. Add a point to D as follows: "2. The valves shall be tested with both low and It is not sufficient to only test to METP high differential pressure in the direction of flow. The low pressure test shall be maximum 7MPa." Yes Change F from "1. Pressure integrity is monitored by independence of the annulus pressure." to: "1. Pressure monitoring of annuli, control/ injection lines . 2. Valves (e.g. gas lift valves or chemical injection valves) to be periodically leak tested according to testing of ASVs and with the same leak acceptance criteria." Yes Need to cover all monitoring methods of the items in the completion string WIF / Jan Krokeide 15.09.2012 7 15.43 C point 3: Change the bullet "• Grade V1 for design validation," to "• Grade V1 The liner top packer will leak gas if not gas tight when free gas at depth. for design validation, V0 if free gas at depth" Yes WIF / Jan Krokeide 15.09.2012 7 15.43 C: Add a point to the list: "7. For gas lifted wells where liner top packer is This is an important point to add for gas lifted wells exposed to gas lift, the liner top packer shall be set at depth with sufficient formation strength and casing isolation material to prevent possible out of zone injection. The same requirements as for production packer / tie-back packer shall apply." Yes F. Change to the following: "Monitoring of annulus pressure or none if below production packer. " Yes WIF / Jan Krokeide 15.09.2012 7 15.43 G 100 % G 100 % G 100 % None monitoring is not always relevant. Dependant on setting depth. changed added word added added 100 % added G 15.09.2012 15.09.2012 100 % Yes WIF / Jan Krokeide WIF / Jan Krokeide G G Change B from "Its purpose may be to provide support to the functionality of Change control line filter subs to control line with seals/connections etc. the completion, i.e. gas-lift or side pocket mandrels with valves or dummies, nipple profiles, gauge carriers, control line filter subs, etc." to "Its purpose may be to provide support to the functionality of the completion, i.e. gas-lift or side pocket mandrels with valves or dummies, nipple profiles, gauge carriers, control line with seals/connections, etc. " Editor Comment changed Yes WIF / Jan Krokeide WIF / Jan Krokeide Category (W, G , Y, R, B) Status 100 % changed G 100 % G 100 % added added G 100 % G 100 % added changed and added G 100 % G 100 % added added G 100 % G 100 % added WIF / Jan Krokeide 15.09.2012 7 15.7 Change heading of table from "15.7 Table 7 – Production packer " to "15.7 Table 7 – Production packer / tie back packer" Tie back packer is often also a barrier element that would need the same requirements as for production packer Yes WIF / Jan Krokeide 15.09.2012 7 15.7 Rephrase first point in C from "1. It shall as a minimum be tested to V1 class as per ISO 14310" to "1. It shall as a minimum be tested to V1 class as per ISO 14310. V0 if free gas at depth" V1 is not sufficient if free gas is present at depth, then gas will leak through and problems with annulus pressure build up in the operational phase will occur. Yes WIF / Jan Krokeide WIF / Jan Krokeide WIF / Jan Krokeide WIF / Jan Krokeide [email protected] 15.09.2012 15.09.2012 15.09.2012 15.09.2012 15.09.12 16:39 7 7 7 7 7 15.7 15.8 15.9 15.9 7.6.1 Add a point to C: "2. The setting shall be at a depth such that any leak through It is important to add a requirement to the placement/depth of the packer. It is a commonly known problem in the industry that the casing below the packer, will be contained by the barrier system outside unfortunately some wells have nor properly isolation outside the packer leading to e.g. out of zone injection etc. the casing. This means formation integrity and any annulus seal (e.g. Cement) shall be able to withstand the pressures or temperatures expected throughout the lifetime of the well" Yes Change F to the following: "1. The valve shall be leak tested at specified regular intervals minimum as follows: • monthly, until three consecutive qualified tests have been performed, thereafter • every three months, until three consecutive qualified tests have been performed, thereafter • every six months. • test duration is volume and compressibility dependent and shall be hold for a period giving measurable pressure change for the allowed leak rate. Minimum 30 min for HC, and 10 min for water. 2. For existing fields with good reliability data for the valve type and specific fluid and rate conditions, 1 monthly and 1 three monthly test is sufficient before increasing the regular test intervals to every six month 2.3. Acceptance of downhole safety valve tests shall meet API RP 14B requirements being • 0,42 Sm3/min (25,5 Sm3/hr) (900 scf/hr) for gas, • 0,4 l/min (6,3 gal/hr) for liquid. 3.4. If the leak rate cannot be measured directly, indirect measurement by pressure monitoring of an enclosed volume downstream of the valve shall be performed. 4. The valve shall be periodically function tested including the emergency shutdown function based on reliability analysis but as a minimum yearly. It shall be verified acceptable shut down time and that the valve closes on signal. The shut down time is recorded at bled down hydraulic system." Yes Test duration of 30 minutes does not give any meaning for other than HC wells. For water wells 10 minutes is commonly used in the industry. Regarding the test frequency, the standard should be differntiated between new wells/fields without reliablility data and new wells with good field data and good reliability data for the same valve type at the field. It is very confusing to write in the standard that the test can be attempted 3 times. If the valve fails at the first test this is a safety critical error and the test should therefore be regarded as failed and count as failed when calculating reliablility. Measures and attempts to repair the valve should not be written in this context as it confuse the reader to misunderstand when the valve actually is regarded to have failed. Need to add requirement of periodic function testing. 100 % G 100 % added Change F to the following: Same reason as for changes to F in 15.8 "1. The valve shall be leak tested at specified regular intervals as follows: • test duration shall be minimum 30 min (10 min for water), test duration is volume and compressibility dependent and shall be hold for a period giving measurable pressure change for the allowed leak rate • monthly, until three consecutive qualified tests have been performed, thereafter • every three months, until three consecutive qualified tests have been performed, thereafter • every six months 2. For existing fields with good reliability data for the valve type and specific fluid and rate conditions, 1 monthly and 1 three monthly test is sufficient before increasing the regular test intervals to every six month 3. Acceptance of downhole safety valve tests shall meet API RP 4B requirements being • 0,42 Sm3/min (25,5 Sm3/hr) (900 scf/hr) for gas, • 0,4 l/min (6,3 gal/hr) for liquid. 4. If the leak rate can not be measured directly, indirect measurement by pressure monitoring of an enclosed volume downstream of the valve shall be performed. 5. The valve shall be periodically function tested including the emergency shutdown function based on reliability analysis but as a minimum yearly. It shall be verified acceptable shut down time and that the valve closes on signal. The shut down time is recorded at bled down hydraulic system." Yes Suggest adding the following wording: “All safety critical components […]” Typically safety critical components are string components from the tubing hanger down to and including the production packer. A leak in the tail pipe typically would not constitute a safety problem (but it might have operational implications, but this should be assessed by the operator). 100 % added G Yes added to heading for table 43 added G Add 3 point to C as follows: These point are covered for SCSSV but not for ASV, but are as valid here. "6. It shall be • surface controlled, • automatically operated, • hydraulically operated, • fail-safe closed, 7. It should be placed below the well kick-off point in order to provide well shutin capabilities below a potential collision point. 8. The fail-safe closing function (maximum setting depth) should be calculated based on the highest density of fluids in the annulus. All components of the completion string including connections (i.e. tubing, packers, polished bore receptacle, nipples, mandrels, ASV, valve bodies, DHSV, plugs, etc.) shall be subject to load case verification” G 100 % added G 100 % added G G 100 % 100 % Accepted and implemented the wording "safety critical" and equipment listing deleted as the operator has to define safety critical components as part of the safety case. WIF / Jan Krokeide [email protected] WIF / Jan Krokeide [email protected] Sveinung Robertson / Statoil [email protected] 15.09.2012 7 7.6.5 Rephrase "c) Production tree valves master valves – PMV, AMV." to "c) Production tree master and wing valves." Why is wing valve removed from the list of beeing part of the emergency shut down system? Wing valve shall be part of the system according to PSA regulation. 14.09.12 10:08 7 7.7.2 “All platform wells shall have an ASV installed in the A-annulus […] A gas lift injection valve (a WBE) can be used as an alternative to an ASV in subsea wells. […]” Clarification required: Does that mean that an ASV is no longer a requirement for subsea wells, as long as gas lift mandrels with gas lift valves (check valves) are used? 15.09.2012 7 7.7.5 14.09.12 14:43 7 15.10 B Function 15.9.2012 7 15.6 14.09.12 12:44 7 7.1 Rephrase "b) B-annulus shall have continuous pressure monitoring with Cement is not a horizontal barrier and a leak in prod csg at intermed csg depth may occur. This means that the formation at int csg alarms. For subsea wells the B-annulus shall be designed to withstand the depth must have sufficient integrity independant of the cement height for prod csg. thermal pressure build-up. If this is not possible, a pressure management system shall be implemented. If the production casing is not cemented into the intermediate casing, the exposed formation shall have a documented ability to withstand a leaking production casing scenario." to "b) B-annulus shall have continuous pressure monitoring with alarms. For subsea wells the B-annulus shall be designed to withstand the thermal pressure build-up. If this is not possible, a pressure management system shall be implemented." Rephrase: "e) Production casing / liner cement should be cemented into the intermediate casing unless it can be documented that the formation can withstand METP (production casing leak scenario)." to "The formation at intermediate csg depth shall have a documented ability to withstand a leaking production casing scenario." may provide a profile to receive a BPV or plug to be used for nippling up/down The last bullet point is not entirely correct, as many tubing hangers are manufactured without a profile for BPV or plug the BOP or Xmas tree Jeg foreslår at tabell 6 i Norsok D010 fjernes og at tabell 28 dekker det som stå i tabell 6. Dette fordi utstyret beskrevet i tabell 6 etter min mening greit kan defineres til høre inn under utstyret i tabell 28 . Ved å bruke kun en tabell (tabell 28) for mekaniske plugger unngår en forvirring og at en kan bli fristet til å velge den "letteste" tabellen. Jeg har gjennom årene erfart at det er mye usikkerhet om hvordan innholdet i tabell 6 skal forstås. This section covers the requirements and guidelines for well integrity whilst installing the completion string No G 100 % Yes 100 % No Rephrased G 100 % G 100 % G 100 % word added reworked and combined the to tables Implemented - thanks The first sentence is too long and has 5 "and's" in it. The grammar needs to be changed This activity commences after the well is drilled and logged, The completion phase ends when the tubing hanger is landed and tested in the subsea wellhead or when a surface xmas tree is installed Accepted G 100 % G 100 % Accepted G 100 % Agree The purpose of this section is to describe the establishment of well barriers by the use of well barrier elements and guidelines to execute this activity [email protected] 14.09.12 12:44 7 7.3d [email protected] 14.09.12 12:44 7 7.3f [email protected] 14.09.12 12:44 7 7.6.1 A DHSV shall be installed in the completion string for all wells For surface wells this should be A and B annulus Minimum requirements for completion string design shall be established and documented Incorporated All completion, liner and tie-backs strings shall be designed to withstand all planned and/or expected stresses, including those induced during potential well control situations. The design process shall be for the full life cycle of the well, including abandonment. Degradation of materials shall be taken into consideration. The design basis and design margins shall be documentes G 100 % G 100 % G 100 % G 100 % G 100 % G 100 % B 100 % Design faktor krav matcher ikke kap 4.3.5 (Beskrevet oppfor). I tillegg er tri-axialt design for connection ikke relevant i dagens oljeindustri. Er absolutt mulig, men krever andre kompetanser og andre design tools. (I Statoil kan vi benytte connection performance envelopes, for moderne connections, men det gir ikke design faktor som svar.) G 100 % Reference made to section 4.3.5 and deleted from this section [email protected] 14.09.12 12:44 7 7.6.2d fluid and/or gas data [email protected] 14.09.12 13:22 7 7.6.2k (New) Plug and Abandonment [email protected] 14.09.12 13:22 7 7.6.3 table item 4 Dynamic flowing and injection conditions Water, Gas, WAG and SWAG injection wells are also subject to temperature effects [email protected] 14.09.12 13:22 7 7.6.3 table item 6 Bullheading/Pumping Injection should be added to 7.6.3 table item 4, as stated in the previous comment number 5 Added Added Incorporated Incorporated In comments section; Well killing, stimulation and fracturing [email protected] [email protected] Dag Johan Eiane / Statoil 14.09.12 13:22 14.09.12 13:22 15.9.2012 7 7 7 7.6.3 table item 8 comments section Stuck sring, shear ratings of pins/rings. Tensile strenghth of all completion components, including equipment connections 7.6.4 For through tubing plugs, packers and valves, the design pressure shall be a minimum of 1.1 times the stated MWP/maximum exposed load, whichever, is the highest. These plugs................. 7.6.4 Added Deleted as comments from industry states this to be an operational requirement and not a design requirement Dag Johan Eiane / Statoil 15.9.2012 7 7.6.4 Hva betyr setningen I klar tekst? "As an alternative to the above design factors…………………….." G 100 % Deleted Dag Johan Eiane / Statoil 15.9.2012 7 7.6.4 Siste setningen i 7.6.4 er et operasjonelt krav og ikke et design krav. G 100 % Deleted [email protected] 14.09.12 13:22 7 7.6.5b G 100 % Accepted [email protected] 14.09.12 13:22 7 7.7 Section The needs to a sub section included for Injection wells (Water, gas, WAG and SWAG) G 100 % Updated the disposal well section to include injection wells [email protected] 14.09.12 13:22 7 7.7.1 No suggestions, but the paragraph (one long sentence) requires re-writing to make it clearer G 100 % Agree and hope the new wording is better [email protected] 14.09.12 13:22 7 7.7.2 Dag Johan Eiane / Statoil [email protected] 15.9.2012 7 7.7.2 14.09.12 13:22 7 7.7.2c ASV or other fail safe closed devices, if installed Gas lift is a mothod to increase production whereas the back pressure in the production tubing is by injecting gas into the A annulus and through the tubing at a pre-determined depth downhole. The use of gas lift means large volumes of pressurised hydrocarbon gas in both the surface lines and the A annulus. Release of these volumes is a substancial topsides hazid to the platform The gas lift well definition has been deleted based on your comment Hvorfor benyttes D-010 til å forklare hva en gass løft brønn er? D-010 er et kravsdok og ikke laerebok. Gas should only be introduced to casing to tubing annulus, that has gas tight premium connections that are properly made up and tested B 100 % G 100 % G 100 % Noted Updated
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