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General Notes or Comments about this Document:
5/21/03 ConservOrdCvrPg.wpd
STATE OF ALASKA
ALASKA OIL AND GAS CONSERVATION COMMISSION
3001 Porcupine Drive
Anchorage, Alaska 99501-3192
Re: THE APPLICATION OF AMOCO )
PRODUCTION COMPANY )
requesting an exception to )
20 AAC 25.035. )
Conservation Order No. 176
Platforms Anna, Bruce,
Baker and Dillon;
Cook Inlet.
September 1, 1981
IT APPEARING THAT:
Amoco Production Company, by letter dated July 7, 1981,
requested the Alaska Oil and Gas Conservation Commis-
sion to grant an exception to part of the surface hole
diverter system requirements in 20 AAC 25.035(b)(1) for
the drilling rigs on the referenced platforms, which
requires, among other things, the equivalent of a six-
inch line with at least two lines venting in different
directions.
·
Notice of Public Hearing was published in the Anchorage
Times on August 20, 1981.
3. There were no protests to the application.
FINDINGS
·
·
20 AAC 25.035(b)(1) is as follows:
(b) Surface Hole Diverter System:
(1) before drilling below the conductor
string, at least one remotely controlled annular pre-
venter and flow diverter system must be installed; the
annular preventer must permit the diversion of hydro-
carbons and other fluids; the low pressure, high capac-
ity diverter system must provide at least the equivalent
of a six-inch line with at least two lines venting in
different directions to insure safe downwind diversion
and must be designed to avoid freezeup; these lines
must be equipped with full-opening butterfly type
valves or other valves approved by the Commission; a
schemat~ic diagram, list of equipment, and operational
procedure for the diverter system must be submitted for
approval with the application for a Permit to Drill
(Form 10-401); and
The drilling rigs mounted on the four referenced
platforms have diverter systems that vent gas in the
derrick at either the derrickman's position or the
crown.
Conservation Order No. 176
Page 2
o
4,
The diverter systems on the drilling rigs on the
referenced platforms have functioned safely for more
than 10 years.
An exception, as requested, to 20 AAC 25.035(b)(1) for
rigs mounted on offshore platforms will not create an
unsafe drilling practice.
NOW, THEREFORE, it is ordered that:
The drilling rigs now mounted on platforms Anna, Bruce, Baker
and Dillon are exempted from the specific requirements of 20 AAC
25.035(b)(1) which require the equivalent of a six-inch line with
at least two lines venting in different directions. A system
with a minimum four-inch diverter flowline to a degasser and
vented by a minimum four-inch line at the derrickman's position
or the crown is approved.
DONE at Anchorage, Alaska and dated September 1, 1981.
ffoyl~FH. R~milt'on, Chairman
Alas~%a Oil and Gas Conservation Commission
Harry W. Kugl~r, Commissioner
Alaska Oil and Gas Conservation Commission
6~ ~i~o
AL ~ ~ e
lasts Oil nd Gas onse~v~t[on Commission
2. PUBLISHER
ADVERTISING
' 'ORDER
NOTICE TO PUBLISHER
INVOICE MUST BE IN TRIPLICATE SHOWING ADVERTISING
ORDER NO., CERTIFIEDAFFIDAVlT OF PUBLICATION (PART
2 OF THIS FORM) WITH ATTACHED COPY OF ADVERTISE-
MENT MUST BE SUBMITTED WITH INVOICE.
VENDOR NO.
DATES ADVERTISEMENT REQU
[DEPT. NO. A.O. NO.
5501
DATE O[ A.O. ,
~n?st 17, 19 81
RED:
.Aulc~/st 20, x.,,oJ_
THE MATERIAL BETWEEN THE DOUBLE LINES MUST BE PRINTED IN
ITS ENTIRETY ON THE DATES SHOWN.
BILLING ADDRESS:
S .A H E
AFFIDAVIT-OF-PUBLICATION
UNITED STATES OF AMERICA
STATE OF AT,ASKA t
THIRD DIVISION.
BEFORE ME, THE UNDERSIGNED, A NOTARY PUBLIC THIS DAY
PERSONALLY APPEARED PAra T4Z~TC~z~ WHO,
BEING FIRST DULY SWORN, ACCORDING TO LAW, SAYS THAT
HE/SHE IS THE T_,EGAT-- CT-Ep.K OF
PUBLISHED AT '". '..'ANCHORAGE IN SAID DIVISION
... AND STATE OF. ALASKA AND THAT THE
ADVERTISEMENT, OF WHICH THE ANNEXED IS A TRUE COPY,
WAS PUBLISHED IN SAID PUBLICATION ON THE . 20THDAY OF
AUGUST .19 8.____1, AND THEREAFTER FOR, NONE
CONSECUTIVE DAYS, THE LAST PUBLICATION APPEARING ON
THE 20TH,DAY OF AUGUST 1~_~_1, AND THAT THE
RATE CHARGED THEREON IS NOT IN EXCESS OF THE I:~_TE
CHARGED PRIVATE INDIVIDUALS.
1TIME 6 1/4INCHS 26.40 L79181
SUBSCRIBED AND SWORN TO BEFORE ME
THIS_ 25TH_DAY OF AUGUST 1981.
NOTARY PUBLIC FOR S~-~-'I:'E OF ALASKA
MY COMMISSION EXPIRES OCTOBER 20.,, 19R4
REMINDER-
ATTACH INVOICES AND PROOF OF PUBLICATION.
· ' 2.A.
, izedi
: · arry W.l~ugler,
i; :' : CommiSsioner :: r
, Alaska Oil and Gas ~
'COnservatiOn Commis~i0n
~ O~08 5501 ·
PUb: Aug. 20, 1981 ? '
L. A. Darsow
District Superintendent
Amoco Production Company
Post office Box 779
Anchorage, Alaska 99510
907-272-8471
July 7, 1981
File' LAD-754-447.1
Lonnie.C. Smith
Commi s s i oner
Alaska Oil and Gas Conservation Commission
3001 Porcupine Drive
Anchor. age, Alaska 99501
Dear Sir'
Request for Exception
'Surface Hole"DiVerter SyStem
With r. egard to your recent request for comments involvi.ng the Surface
Hole Diverter System Regulation (refer to your letter dated June 4,
1981, Regulation 20 AAC 25.035, Section 'B), Amoco is requesting an
exception to the section of this r. egulation which states:
'!...the low pressure, high capacity diverter
system must provide at least the equivalent
of a six-inch line with at least two lines
venti.ng in different directions to insure
safe downwind diversion .... "
We request this exception for all four of our Cook Inlet platforms for
all present and future drilli.ng operations.
Our present system of diversion, as seen in Attachment I, vents gas in
the derrick above the rig floor at the crown on platforms Anna 'and
Dillon, and at the derr'ickman's position on Bruce and Baker. Historically,
this system has been'rarely, yet successfully utilized to divert small
amounts of coal gas while drilling at these shallow depths. This gas is
low volume and 'tends to deplete quickly. This system has also been
satisfactor:y.inspected by your personnel in'the recent past and was found to be~'~~/~'~"~'~
LAD-754-447.1
July 7', 1981
?age 2
Furthermore, it is felt that diverter lines laid horizontally for
diversion of flow in two directions on an offhsore platform is far more
hazardous than our present system since there are many potential ignition
sources at or near the deck level that could easily.ignite'vented gas in
the event of a sudden wind change or similar occurrence. Also, our
system is functionally identical to the system seen in the API Recommended
Practices for Blowout Prevention Equipment Systems Bulletin (API RP 53),
Page 4, Figure 2~A.1; the API recommendations bei.ng widely accepted as
the standard of the industry.
In closing, we will appreciate your consideration of our request for
this exception and will be glad to field any questions or comments you
may have'r.egardi.ng this regulation and our system. We also invite you
or any of your associates to visit our.platforms and inspect the diverter
systems at your convenience.
Very truly yours,
L. A. Darsow
Di strict Superintendent
Attachments
TWM:cm
~AMOCO'
SUBJECT
Amoco 'Production CompaCt.*,'
ENGINEERING CHART
SHEET NO.
FILE
OF
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I
NOTICE OF PUBLIC HEARING
STATE OF ALASKA
Alaska Oil and Gas Conservation Commission
Re: The application of Amoco Production Company, dated July 7,
1981, requesting an exception to section (-b) of Alaska Oil
and Gas Conservation Commission's regulation 20 AAC 25.-035,
concerning the surface hole diverter system.
Notice is hereby given that Amoco Production Company has
requested the Alaska Oil and Gas Conservation Commission to issue
an order granting an exception to the surface hole diverter
requirements stated in 20 AAC 25.035 (b),(1), for their four Cook
Inlet platforms, Anna, Dillon, Bruce and Baker. Exception is
requested specifically for that phrase which states:
"...the low pressure, high capacity diverter system
must provide at least the equivalent of a six-inch line
with at least two lines venting in different directions
to insure safe downwind diversion "
Amoco Production Company proposes a minimum four inch
diverter flowline to a degasser and vented by a minimum four inch
single line to the crown or derrickman's position in the derrick
abOve the rig floor. Their systems are similar to the ~system as
shown in the API Recommended Practices for BLOWOUT PREVENTION
EQUIPMENT SYSTEMS Bulletin (API RP 53), page 4, figure 2.A.1. and
have been safely utilized for more than 10 years.
Parties who may be ~aggrieved if an order is issued granting
the referenced exception are allowed 10 days from the date of
this publication in which to file a protest in writing, stating
in detail the nature of the aggrievement, and a request for a
hearing. The place of filing is the Alaska Oil and Gas Con-
servation Commission, 3001 Porcupine Drive, Anchorage, Alaska
99501-3192. If such a protest is timely filed, a hearing on the
matter will be held at the above address at 9:00 AM, on
September 1, 1981 at which time protestants and others may be
heard. If no such protest is timely filed the Commission will
consider the issuance of the order without a hearing.
~Ha'rry W. KUgle/J' ~~r '
Commissioner
Alaska Oil and Gas Conservation Commission