||You, as duty holder of the Piper Bravo installation have failed to follow the procedures and arrangements in your Piper Bravo Safety Case section 18.104.22.168 with the result that you have failed to maintain 15/17-B07, 15/17-B09, 15/17-B10, 15/17-B12 and 15/17-B18 in good repair. Your safety case references WEL-PRO-TLM-064 Well Integrity Management Overview which describes the processes that should be followed to maintain the integrity of the wells and Wells Performance Standard PS-PRO-TLM-029 which describes the performance that should be achieved from the wells Safety and Environmentally Critical Elements.
Our inspection from 15 December 2020 – 3 February 2021 identified:
• The well integrity failures including tubing to annulus communication and A annulus to B annulus communication have been known since 2005.
• The wells were fitted with mechanical plugs in 2011 the temporary nature of these plugs is captured in your risk assessment WRA688 which reflects industry guidelines and good practice.
• Your risk assessments WRA688 & WRA832 contained risk reduction measures and condition monitoring which were not performed; namely the regular logging to assess whether the plugs are leaking, flow testing, assessing the casing condition, distortion, cement condition and evidence for hole collapse or fill in the outer annuli and biennial flow testing to confirm if the plugs are leaking.
• Your risk assessments WRA688, WRA832, WRA1683, WRA1920 have since 2011 highlighted the need to set permanent plugs in these wells
• Between 2011 and 2020 the risk assessment process and dispensation process have been repeated with the same risk reduction measures without initiating any corrective action such as creation and execution of corrective work orders as required by the Well Deviation Process WEL-PRO-TLM-049
• During 2021 you are conducting a project on Piper B to
o Reactivate the Piper B Drilling Rig to Level 5
o Target G Infill Production Well
o Target D Infill Production Well
o At the time of my inspection there was no plan to restore integrity to wells 15/17-B07, 15/17-B09, 15/17-B12 or 15/17-B18 either through workover and repair or by setting permanent plugs as per your own risk assessments