Wellhead Removal - The case against removal?

We are looking at doing an abandonment campaign and we are faced with the challenge from the regulators as to whether the wellhead should be removed. My thoughts are that wellhead removal was something that started in shallower waters where the wellhead would present a hazard to other users of the marine environment and then this requirement just migrated into deepwater water depths.

We can point to the recent GOM change in the CFR's where the BSEE will allow (with the district managers permission) the wellhead to be left in place in water depths greater than 305m. There is also precedent from NOPSEMA where a wellhead was left in place in 190m WD of Australia.

My question to the wider group is are there any good examples out there of where the wellhead was removed during abandonment and then there was a requirement to go back to that well?

Much appreciated 
8 Answer(s)

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