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Abstract
This paper describes a process for actively managing well integrity throughout the development life cycle with a particular focus on the production operations / well maintenance phase. Although developed in relation to ConocoPhillips UK North Sea development wells, most of the features of the process have application to all development well operations (both onshore & offshore) under any regulatory regime.

The original well integrity management process was developed in order to demonstrate compliance with the UK Offshore Installations & Wells (Design & Construction, etc) Regulations 1996 (DCR). Since that time the original process has continued to be modified to improve effectiveness & efficiency. As well as describing the current process, this paper also describes its development and how we see that the process might evolve in the future.

DCR regulations form a part of the UK ‘safety case’ regime. The ‘safety case’ regime places a strong focus on the development of site-specific performance standards; it also utilises the principles of independent examination & verification in order to demonstrate compliance. The process described in this paper represents a significant new contribution to the management of major accident hazards in well operations since it focuses on the use of performance standards and independent examination in order to ensure well integrity.

Introduction
All prudent well operators recognise the need to actively manage well integrity throughout the development life cycle. Different operators take different approaches depending on the nature of their operations, the risk profiles presented and the regulatory regime.

It is arguable that the industry has historically focussed a great deal of its attention on management of well integrity during the well design and construction phase. For exploration and appraisal wells drilled in increasingly challenging environments (underbalanced, HPHT, etc) this is entirely appropriate. However, it may be that in doing so the industry has not kept pace in terms of managing its approach to development well integrity during the operations and maintenance cycle. For many development wells, continued application of tried and tested industry standards is probably still the best strategy. However, in other situations, a fresh approach may be justifiable:

    •     For subsea development wells, often remote from host facilities, well integrity management standards might be improved by reflecting site-specific safety & environmental risks rather than applying integrity management standards more appropriate to platform-based wells.
    •     Even for conventional platform / onshore wells, appropriate integrity management standards might be allowed to vary depending upon well conditions (e.g. not-naturally-flowing, etc).
    •     Recent developments in completion equipment (particularly subsurface safety systems) may also justify changes to historically accepted well integrity management standards.
    •     Historically, well intervention operations have often received less formal control than drilling operations. There is perhaps a need to recognise that some of these operations pose potentially increased safety risks and should be subject to a greater level of control through the application of appropriate operations standards.