§ 250.518

250.518(e)(1)

Question: Requestors sought confirmation that packers set below the production packer, such as sump packers or isolation packers, do not have to comply with API Spec 11D1.

Answer: If a packer or bridge plug is not being used or qualified as a mechanical barrier (e.g., a sump packer or casing bridge plug), BSEE does not consider it to be a permanently installed packer or bridge plug for purposes of §§ 250.518(e)(1), 250.619(e)(1), and 250.1703(b), and therefore does not require that it comply with API Spec. 11D1.

250.518(e)(1) and 619(e)(1) – existing inventory

Question: This question relates to existing operator and manufacturer inventory of packers and bridge plugs that do not have documentation of conformance with API spec. 11D1.  Is there a standard way that BSEE would respond and allow product with a manufacturing date prior to the effective date of the rule?

Answer: All packers or bridge plugs designated as qualified mechanical barriers are required to be in conformance with API spec. 11D1 and there is no “grandfathering” of equipment that is currently in inventory.

250.518(e)(3)

Question: Is it BSEE’s intention that setting the depth of the production packer as close as practically possible to the perforated interval will allow for future potential work below the packer, including through tubing plugbacks (i.e., future shallower perforations)?

Answer: Each production packer setting depth will be evaluated on a case–by-case basis. Each well and situation is unique. It is reasonably possible that BSEE will approve a setting depth for a production packer that will allow for future potential work below the packer. The provisions at §§ 250.518(e)(3) and 250.619(e)(3) do not require that BSEE only approve a setting depth that would preclude future potential work below the packer.

The new regulations are not intended to hinder the installation of production equipment by setting a fixed interval length that must be met or to hinder an operator's flexibility to intervene in or manage its well as necessary. During the permit application process, BSEE may request additional information to justify your specified production packer setting depth to ensure that the packer is set as required in these sections to help ensure long-term equipment reliability.

The final rule preamble explained that “BSEE wants to ensure that the packer is not set too high, so that, if there is a problem with the packer in the well (e.g., a leak), operators will have enough space above the packer to pump a sufficient volume of weighted fluid into the well to exert a hydrostatic force greater than the force created by the reservoir pressure below the packer.” 81 Fed. Reg. 25888, 25927 (April 29, 2016).

250.518(e)(4) and 250.619(e)(4) – Setting packers in cemented intervals

Question: Please provide clarity on what options are available for setting packers in un-cemented casing. Industry data confirms that setting packers in un-cemented casing is common and safe. (Example - SPAR - Mudline Packer)

The requirement to set production packers within the cemented interval of the selected casing section is not always possible. Please confirm that an alternative mean of compliance will be acceptable in lieu of performing any type of remedial cement squeeze.

Answer: Requests for departure or alternate compliance to set the packer in an un-cemented casing will be reviewed on a case-by-case basis in connection with the permit.