Well Control Requirements for Workstring Service Operations

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    Well control requirements for workstring serviceoperations

    (a) This section applies to through-tubing operations that are not subject to the

    requirements of 20 AAC 25.036 or 20 AAC 25.285, and that are performed with coiledtubing, small diameter drill pipe, or small diameter tubing. These operations are alsosubject to the requirements of 20 AAC 25.527.

    (b) The operator shall use a full lubricator system or open hole deployment type system.

    (c) The rated working pressure of the blowout prevention equipment (BOPE) and other

    well control equipment must exceed the maximum potential surface pressure to which itmay be subjected. If an approved Application for Sundry Approvals (Form 10-403) is

    required under 20 AAC 25.280, the commission will specify in that approvedapplication the working pressure that the equipment must be rated to meet or exceed.

    However, the rated working pressure of the annular type preventer need not exceed5,000 psi.

    (d) Well control equipment must include

    (1) at least one positive seal manual or hydraulic valve or blind ram flanged to the

    wellhead or tree;

    (2) in rotary drilling rig operations,

    (A) for an operation requiring a BOP stack equal to or less than API 5K, at least three

    preventers, including

    (i) one equipped with pipe rams that fit the size of drill pipe, tubing, or casing being

    used, except that pipe rams need not be sized to bottom-hole assemblies (BHAs) and

    drill collars;

    (ii) one with blind rams, except that a subsea BOPE assembly must have blind/shear

    rams in place of blind rams; and

    (iii) one annular type; and

    (B) for an operation requiring a BOP stack greater than API 5K, at least four preventers,

    including

    (i) two equipped with pipe rams that fit the size of the drill pipe, tubing, or casing beingused, except that pipe rams need not be sized to BHAs and drill collars;

    (ii) one with blind rams, except that a subsea BOPE assembly must have blind/shear

    rams in place of blind rams; and

    (iii) one annular type;

    (3) in coiled tubing unit operations,

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    (A) for an operation requiring a BOP stack equal to or less than API 5K,

    (i) BOPE rams providing for pipe, slip, cutting, and blinding operations on the coiled

    tubing in service;

    (ii) a high pressure pack-off, stripper, or annular type preventer; and

    (iii) if pressure deployment of tools is planned, a riser or lubricator sized to the BHAand providing for pressure integrity from the BOPE rams to the high pressure pack-off,

    stripper, or annular type preventer; and

    (B) for an operation requiring a BOP stack greater than API 5K,

    (i) BOPE rams providing for pipe, slip, cutting, and blinding operations on the coiled

    tubing in service;

    (ii) two high pressure pack-offs, strippers, or annular type preventers; and

    (iii) if pressure deployment of tools is planned, a riser or lubricator sized to the BHA

    and providing for pressure integrity from the BOPE rams to the high pressure pack-off,stripper, or annular type preventer;

    (4) a hydraulic actuating system with

    (A) sufficient accumulator capacity to supply 150 percent of the volume necessary toclose all BOPs, except blind rams, while maintaining a minimum pressure of 200 psi

    above the required precharge pressure when all BOPs, except blind rams, are closed,

    and all power sources are shut off; and

    (B) an accumulator pump system;

    (5) locking devices on the ram-type preventers;

    (6) in rotary drilling rig operations, one complete set of operable remote BOPE controlson or near the driller's station, in addition to controls on the accumulator system;

    (7) in coiled tubing operations, one complete set of operable remote BOPE controls on

    or near the operator's station and, if these controls are not in close proximity to thedrilling platform floor, a second annular type preventer closing control located on the

    drilling platform floor; and

    (8) a kill line capable of being attached with flanged or hubbed connections to the BOPbody, drilling spool, tree, wellhead, or other well control equipment.

    (e) The operator shall test the BOPE assembly as follows:

    (1) at least once a week, and after each use, repair, or change, BOPE pipe and blindrams must be function pressure-tested, using a non-compressible fluid, to the required

    working pressure specified in an approved Application for Sundry Approvals under 20AAC 25.280 or, if that application is not required, to the maximum potential surface

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    pressure to which they may be subjected, except that the annular type preventer neednot be tested to more than 50 percent of its rated working pressure;

    (2) after each installation of BOPE or other well control equipment, the equipment must

    be pressure-tested, before wellbore entry, to the maximum potential wellhead pressure

    to which it may be subjected, except that when testing against the annular typepreventer, pressure testing need not exceed 50 percent of the rated working pressure ofthe annular type preventer;

    (3) non-sealing equipment must be function-tested weekly, after a repair or change, and

    after an action that disconnects the hydraulic system lines from the BOPE, except that ifthe workstring is continuously in the well, function-testing must be performed as soon

    as possible after the workstring is pulled out of the well and the BHA clears the BOP;

    (4) after each well installation of the BOPE, the BOPE hydraulic connections to therams must be visually verified before wellbore entry.

    (f) In a rotary drilling rig operation, the operator shall have on location a copy of the

    approved Application for Sundry Approvals, if that application is required under 20AAC 25.280, and shall post on the drilling rig floor any geologic hazard information

    obtained while drilling the well and a copy of the operator's standing orders specifyingwell control procedures. In a coiled tubing operation, the operator shall post in the

    operator's cab a copy of the approved Application for Sundry Approvals, if that

    application is required under 20 AAC 25.280, any geologic hazard information obtainedwhile drilling the well, and a copy of the operator's standing orders specifying well

    control procedures. If an additional or separate substructure is used in a coiled tubingoperation, the operator shall post a second set of standing orders on the drilling platform

    floor.

    (g) Upon request of the operator, the commission will, in its discretion, approve avariance from the requirements of this section if the variance provides at least an

    equally effective means of well control.

    History: Eff. 11/7/99, Register 152

    Authority: AS 31.05.030

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