Ala. Admin. Code r. 400-2-6-.07

Current through Register Vol. 43, No. 1, October 31, 2024

Section 400-2-6-.07 - Subsurface Safety Devices

(1) Safety devices and valves shall be installed, inspected, and tested, and records shall be maintained in accordance with the following requirements:

(a) All wells open to hydrocarbon-bearing zones shall be equipped with a surface-controlled subsurface safety device, installed at a depth of one hundred (100) feet or more below the waters floor. In case of failure of the surface-controlled subsurface safety device a subsurface-controlled subsurface safety device may be installed, at a depth of one hundred (100) feet or more below the waters floor, upon approval by the Supervisor. All wells in which a subsurface safety device or tubing plug is installed shall have the tubing-casing annulus packed off above the uppermost open casing perforations. The control system for all surface-controlled subsurface safety devices shall be an integral part of the platform shut-in system. In addition to the activation by manual action on the platform, the system may be activated by and shut-in by a signal from a remote location. Surface-controlled Subsurface Safety Valve's (SCSSV's) shall close in response to shut-in signals from the Emergency Shutdown Device (ESD) and in response to the fire loop or other fire detection devices.

(b) Subsurface safety devices shall be adjusted, installed, and maintained to insure reliable operation. These installations shall be made within two (2) days after stabilized production is established. The well shall be continuously attended during the stabilization period and the interval preceding the installation of the safety device. If the subsurface safety device is not installed within this two- (2-) daytime interval, or other interval specified by the Supervisor, the well shall be shut in, unless a waiver for omitting the device has been approved by the Supervisor.

1. Each subsurface-controlled subsurface safety device shall be removed, inspected, and repaired or adjusted as necessary at intervals not to exceed twelve (12) months for valves installed in a landing nipple and at intervals not to exceed six (6) months for those valves not installed in a landing nipple. Prior to installation, each device shall be repaired as necessary and adjusted or resized to compensate for changes in well conditions.

2. The subsurface safety device may be removed from a well for routine operations without authorization or notice provided the well is attended while the master valve(s) is open. The well shall not be open to flow while the subsurface safety device is removed, except when flowing of the well is necessary for routine operations. When such operations occur, the well shall be identified by a sign on the wellhead stating that the subsurface safety device has been removed.

3. Each surface-controlled subsurface safety valve shall be tested in place for proper operation when installed or reinstalled and thereafter at intervals not exceeding six (6) months. Testing shall be in accordance with API RP 14B, and subsequent revisions thereof, to ensure proper operation. However, the Supervisor may require more frequent inspection and testing of these devices or valves. Prior to installation, each device shall be repaired as necessary and adjusted or resized to compensate for changes in well conditions.

(c) In all tubing installations, the tubing string shall be equipped with a landing nipple to provide for the setting of the subsurface safety device. New completions (perforated but not placed on production) and completions shut in for a period of one (1) year shall be equipped with either:

1. a pump-through-type tubing plug;

2. a surface-controlled SCSSV, provided the surface control has been rendered inoperative; or

3. an injection valve capable of preventing back flow. In lieu of, or in addition to, other subsurface safety devices such devices shall be set at a depth of one hundred (100) feet or more below the waters floor.

(d) In the event well conditions prevent, or make impractical the installation of subsurface safety devices, the operator may submit in writing a request for a waiver of the requirement for the installation of such a device, including a detailed statement of the efforts made to overcome the difficulties and, if possible, an alternate safety measure.

1. The Supervisor may require a different program under the following conditions:

(i) When artificial lift is required;

(ii) When the flowing tubing pressure at the wellhead is too low to permit adjustment of the safety device for proper operation;

(iii) When the subsurface device causes sand to plug the tubing or sand makes the subsurface safety device inoperative;

(iv) When flow rate fluctuation or water production prevents a well equipped with a subsurface device from producing;

(v) When the mechanical condition of the well does not permit the installation of a subsurface safety device or at the prescribed minimum depth under section (a) above;

(vi) Class II injection wells; and

(vii) Underground storage wells.

(e) Emergency Action. In the event of an emergency, such as an impending storm, any well not equipped with a subsurface safety device and which is capable of natural flow shall have the device properly installed as soon as possible with due consideration being given to personnel safety.

(f) The well completion report and any subsequent report of workover shall state the type and the depth of the subsurface safety device installed in the well or state that the requirement has been waived.

(g) The operator shall maintain records showing the present status and past history of each subsurface safety device, or automatic surface shut in device installed in lieu of a subsurface safety device, including pressure settings and setting depths (if applicable), and dates and details of inspections, testing, repairing, adjustment, installations and bench tests. Records shall be retained for a period of two (2) years during which time they shall be available for review by the Supervisor.

Author: State Oil and Gas Board

Ala. Admin. Code r. 400-2-6-.07

New Rule: Filed April 11, 2000; effective May 16, 2000.

Statutory Authority:Code of Ala. 1975, §§ 9-17-1, etseq.