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By Nicholas Samford
Lloyds Register
Intervention/Decommissioning SME
Working together
for a safer world
Planning Decommissioning Operations
REGULATIONS
API 17G
API 17G4
30 CFR 250
SURFACE
Platform Based
SUBSEA
MODU
Riser Based Intervention
Riserless Based Intervention
PLATFORM BASED
Rig up on platform for diagnostics and P&A operations.
Pros
Cheaper than running a separate rig or lift boat
Better communications due to more compact work areas
Less traversing from vessel to vessel
Work in conjunction with production personnel for SIMOPS
Cons
Limited configuration of equipment
Limited equipment that can be placed on work decks due to weight and size constraints
More use of support vessels, which include fuel, personnel, and boat costs.
Limited by crane functionality or crane load capacity, that is if the platform crane is in
commission.
SUBSEA BASED
Modu’s
Pros
Plenty of deck space for all equipment
Use of derrick for running riser and pulling tubing, casing, and subsea equipment
Up to date cranes and space to lay out tubing and pipe
Use of subsea BOP stack, marine riser, and SSTT’s
More room for personnel
Cons
EXPENSIVE!!!
Long rig up times
Longer well hopping times
Most Modu’s were made for drilling and therefore are not designed to accept
decommissioning equipment
Requires more 3rd party personnel to work the bigger P&A/Intervention packages.
Subsea Based
Riser Based Decommission/Intervention
Pros
Quicker time back in hole
Quicker laying out tubing, pipe, and down
hole equipment with the crane
Full bore pressure rated riser from well to
surface
Can run coil tubing
Subsea IWCE stack and a surface BOP, i.e.
wireline, coil tubing, and snubbing BOP’s
Cons
Longer time run system.
Cumbersome to run.
Testing can take longer due to riser joint make up leaks.
Riser-less based
Pros
Quicker to run
Faster well hopping
Lower overall day rate
Less personnel and equipment needed
Cons
Can not run coil tubing
Deck space is limited
Can only perform bottom side P&A
Regulations
API 17G
API 17G presents the requirements and gives recommendations for the
performance, design, analysis, materials, fabrication, inspection, testing, welding,
marking, handling, storing, shipment, and purchase, of subsea
completion/workover riser equipment as one form of well intervention systems
run from a mobile offshore drilling unit (MODU) or multi-purpose vessels.
API 17G is intended to serve as a common reference for designers, manufacturers,
and operators/users, thereby reducing the need for end user specifications. This
API 17G also eliminates the need for interpretation of the applicability of
requirements given by other codes and standards for permanently installed
equipment.
API 17G4
API 17G4 is intended to supplement API Spec 17G with regard to open water riserless subsea
well interventions. The document’s purpose is to illustrate recommendations for the design,
build, and operation of open water riserless subsea well intervention systems. Most equipment
used for riserless well intervention are covered by standards widely used by the industry and as
such are to be governed by those standards. If not specifically referenced in this supplement,
then the expectation is that the main API 17G document prevails.
Specific equipment covered by API 17G4 for Riserless subsea well intervention operations is
listed as follows:
Riserless Well Control Package (RWCP)
Lubricator Assembly
Pressure Control Head and Dynamic Seal
Disconnect Systems
Control Systems
Injection/Circulation System
Connectors
30 CFR 250
The Secretary of the Interior (Secretary) authorized the Bureau of Safety and Environmental
Enforcement (BSEE) to regulate oil, gas, and sulphur exploration, development, and production
operations on the Outer Continental Shelf (OCS). Under the Secretary's authority, the Director
requires that all operations:
(a) Be conducted according to the OCS Lands Act (OCSLA), the regulations in this part, BSEE
orders, the lease or right-of-way, and other applicable laws, regulations, and amendments; and
(b) Conform to sound conservation practice to preserve, protect, and develop mineral resources of
the OCS to:
(1) Make resources available to meet the Nation's energy needs;
(2) Balance orderly energy resource development with protection of the human, marine, and
coastal environments;
(3) Ensure the public receives a fair and equitable return on the resources of the OCS;
(4) Preserve and maintain free enterprise competition; and
(5) Minimize or eliminate conflicts between the exploration, development, and production of
oil and natural gas and the recovery of other resources.
Questions?
Thank you
nickolas.samford@lr.org (US);
(Brazil):
E: luis.carneiro@lr.org / angela.hayashi@lr.org
T: +00 55 21 3523 0018 / 51
M: +00 55 11 98424 3029
Lloyd’s Register and variants of it are trading names of Lloyd’s Register Group Limited, its subsidiaries and affiliates. Lloyd’s Register
do Brasil Ltda is a Brazilian limited-liability company and a member of the Lloyd’s Register group
Lloyd's Register do Brasil Ltda is a Brazilian limited-liability company and a subsidiary of Lloyd's Register Group Limited.