Hi Ron,
NORSOK D-010 agrees with your "mess" scenario. Table C.7.C.2 requires that "any leak through the casing below the packer, will be contained by the well barrier system outside the casing, i.e. the packer shall be set below a verified annulus Well Barrier Element". And then it mentions "annulus seal (e.g. cement)".
The barrier requirement is fair enough: any leak through the primary, which includes production casing and packer, must be fully contained by the secondary. Insisting on an annulus WBE and mentioning cement explicitly is a bit more puzzling: typically, the annulus barrier element is the wellhead, not a lower seal (especially not cement).
If you look at all well barrier diagrams in the standard, you will see shaded (i.e., qualified) cement across the packer. This is a bit misleading, since you qualify cement to cross the annulus at the depth of the caprock, and then use the production casing - an inside-out barrier element - to climb up to the packer. But the meaning is clear: even if you don't have 30-50 m of defect-free cement above the packer, just by ensuring a bit of good cement you mitigate a major leak (and a major accident scenario) outside of your casing. So if you leave the production casing uncemented you do not impact your barrier system, which is based on probability of failure, but increase the severity of a leak and thus the risk.
In short, you can claim compliance with the letter of NORSOK D-010 as long as you qualify the secondary barrier. But you may want to follow the spirit of the standard and set the packer across a cemented annulus (which is required for injectors anyway).
By the way, in my experience this setup will be a nightmare to abandon: nobody wants to mill a packer, so you're looking at qualifying one or two annular barrier elements a safe distance above it. This means a top of cement >100 m above the packer setting depth to have a passing chance of success. How do you plan to abandon the well, knowing that regulations may not become looser in 20-30 years?
Best regards,
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Matteo Loizzo
Well integrity consultant
matteo.loizzo@mac.comBerlin, Germany
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