26 Miss. Code. R. 3-1.6

Current through October 10, 2024
Rule 26-3-1.6 - INSTALLATION OF SUBSURFACE SAFETY DEVICE

The operator shall comply with the following requirements. All departures from the requirements specified in this rule shall be subject to approval by the Supervisor. All applications for approval under the provisions of this rule shall be submitted to the Supervisor. References in this rule to approvals, determinations or requirements are to those given or made by the Supervisor or his delegated representative:

1. Installation

All tubing installations open to hydrocarbon-bearing zones shall be equipped with a subsurface-controlled or a surface - or other remotely controlled subsurface safety device, to be installed at a depth of 100 feet or more below the waters' floor unless, after application and justification, the well is determined to be incapable of flowing oil or gas. These installations shall be made as required in Subparagraph A below within two (2) days after stabilized production is established, and during this period of time the well shall not be left unattended while open to production.

A. New Wells

All tubing installations in wells shall be equipped with a surface or other remotely controlled subsurface safety device; provided, that wells with a shut-in tubing pressure of 4,000 psig or greater shall be equipped with a subsurface-controlled subsurface safety device in lieu of a surface or other remotely controlled subsurface safety device unless a surface or other remotely controlled subsurface safety device is approved or required. When the shut-in tubing pressure declines below 4,000 psig, a surface or other remotely controlled subsurface safety device shall be installed when the tubing is first removed and reinstalled.

B. Shut-in Wells

A tubing plug shall be installed in lieu of, or in addition to, other subsurface safety devices if a well has been shut-in for a period of six (6) months. Such plugs shall be set at a depth of 100 feet or more below the waters' floor. All retrievable plugs installed shall be of the pump-through type. All wells perforated and completed, but not placed on production, shall be equipped with a subsurface safety device or tubing plug within two (2) days after completion.

C. Injection Wells

Subsurface safety devices as required in Subparagraph A above shall be installed in all injection wells unless, after application and justification, it is determined that the well is incapable of flowing oil or gas, which condition shall be verified annually.

2. Technological Advancement

As technological research, progress and product improvement result in increased effectiveness of existing safety devices or the development of new devices or systems, such devices or systems may be required or used upon application, justification and approval. Applications for routine use shall include evidence that the device or system has been field-tested at least once each month for a minimum of six (6) consecutive months, and that each test indicated proper operation.

3. Testing and Inspection

Subsurface safety devices shall be designed, adjusted, installed and maintained to insure reliable operation. During testing and inspection procedures, the well shall not be left unattended while open to production unless a properly operating subsurface safety device has been installed in the well.

A. Surface-Controlled Subsurface Safety Devices

Each surface or other remotely controlled subsurface safety device installed in a well shall be tested in place for proper operation when installed and thereafter at intervals not exceeding six (6) months. If the device does not operate properly, it shall be removed, repaired and reinstalled or replaced and tested to insure proper operation.

B. Subsurface-Controlled Subsurface Safety Devices

Each subsurface-controlled subsurface safety device installed in a well shall be removed, inspected and repaired or adjusted as necessary and reinstalled at intervals not exceeding six (6) months; provided, that such removable devices set in a landing nipple shall be removed, inspected and repaired or adjusted as necessary and reinstalled at intervals not exceeding twelve (12) months. Each velocity-type device shall be designed to close at a flow rate not to exceed the larger of either 150 percent of, or 200 BFPD above, the most recent well-test rate which equals or exceeds the approved production rate. The above closing flow rate shall not exceed the calculated capacity of the well to produce against a flowing wellhead pressure of fifty (50) psig. Each preset tubing-pressure-actuated device shall be designed to close prior to reduction of the flowing wellhead pressure to fifty (50) psig.

C. Tubing Plugs

A shut-in well equipped with a tubing plug shall be inspected for leakage by opening the well to possible flow at intervals not exceeding six (6) months. If sustained liquid flow exceeds 400 cc/min., or gas flow exceeds fifteen (15) cu.ft./min., the plug shall be removed, repaired and reinstalled or an additional tubing plug installed to prevent leakage.

4. Temporary Removal

Each wireline or pumpdown-retrievable subsurface safety device may be removed, without further authority or notice, for a routine operation for a period not to exceed fifteen (15) days. The well shall be clearly identified as being without a subsurface safety device and shall not be left unattended while open to production. The provisions of this paragraph are not applicable to the testing and inspection procedures in Paragraph 3 above.

5. Additional Protective Equipment

All tubing installations in which a wireline or pumpdown- retrievable subsurface safety device is to be installed shall be equipped with a landing nipple, with flow couplings or other protective equipment above and below, to provide for setting of the subsurface safety device. 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, or of an independent remote shut-in system.

6. Departures

All departures (or waivers) shall be applied for in writing to the Supervisor. All applications for departures shall include a detailed statement of the well conditions, efforts made to overcome any difficulties and proposed alternate safety measures.

7. Emergency Action

All tubing installations open to hydrocarbon-bearing zones and not equipped with a subsurface safety device as permitted by this rule shall be clearly identified as not being so equipped, and a subsurface safety device or tubing plug shall be available at the field location. In the event of an emergency, such as an impending hurricane, such device or plug shall be promptly installed within the limits of practicability, due consideration being given to personnel safety.

8. Records

The operator shall maintain the following records for a minimum period of one (1) year for each subsurface safety device and tubing plug installed, which records shall be available to any authorized representative of the Board:

A. Field Records

Individual well records shall be maintained at or near the field and shall include, as a minimum, the following information:

(1) A record which will give design and other information, i.e., make, model, type, spacers, bean and spring size, pressure, etc.
(2) Verification of assembly by a qualified person in charge of installing the device and installation date.
(3) Verification of setting depth and all operational tests as required in this order.
(4) Removal date, reason for removal and reinstallation date.
(5) A record of all modifications of design in the field.
(6) All mechanical failures or malfunctions, including sandcutting, of such devices, with notation as to cause or probable cause.
(7) Verification that a failure report was submitted.
B. Other Records

The following records, as a minimum, shall be maintained at the operator's office:

(1) Verified design information of subsurface- controlled subsurface safety devices for the individual well.
(2) Verification of assembly and installation according to design information.
(3) All failure reports.
(4) All laboratory analysis reports of failed or damaged parts.
(5) Quarterly failure-analysis report.
9. Reports

Well completion reports (Form No. 3) and any subsequent reports of workover (Form No. 3) shall include the type and the depth of the subsurface safety devices and tubing plugs installed in the well or indicate that a departure has been granted.

To establish a failure-reporting and corrective-action program as a basis for reliability and quality control, each operator shall submit a quarterly failure-analysis report to the Supervisor, identifying mechanical failures by lease and well, make and model, cause or probable cause of failure and action taken to correct the failure. The reporting period shall begin the first day of the month following the date of this order. The reports shall be submitted by February 28, May 31, August 31 and November 30 for the periods ending January 31, April 30, July 31 and October 31 of each year.

26 Miss. Code. R. 3-1.6

MCA Section 53-1-17(3) (1972)