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Home My WebLink AboutCO 492Conservation Order Cover Page XHVZE This page is required for administrative purposes in managing the scanning process. It marks the extent of scanning and identifies certain actions that have been taken. Please insure that it retains it's current location in this file. Conservation Order Category Identifier Organizing RESCAN [] Color items: [] Grayscale items: [] Poor Quality Originals: [] Other: NOTES: DIGITAL DATA [] Diskettes, No. [] Other, No/Type OVERSIZED (Scannable with large plotter/scanner) [] Maps: [] Other items OVERSIZED (Not suitable for plotter/scanner, may work with 'log' scanner) [] Logs of various kinds [] Other BY: '~~'~MARIA Scanning Preparation TOTAL PAGES Production Scanning Stage I PAGE COUNT FROM SCANNED DOCUMENT: //O PAGE COUNT MATCHES NUMBER IN SCANNING PREPARATION: /~ YES ~ NO BY: Stage 2 IF NO IN STAGE 1, PAGE(S) DISCREPANCIES WERE FOUND: ~ YES ~ NO (SCANNING IS COMPLETE-AT THIS POINT UNLESS SPECIAL ATTENTION IS REQUIRED ON AN INDIVIDUAL PAGE BASIS DUE TO QUALITY, GRAYSCALE OR COLOR IMAGES) General Notes or Comments about this Document: 5/21/03 ConservOrdCvrPg.wpd • • INDEX CONSERVAfiION ORDER NO. 492 Prudhoe Bay Annulus Pressure 1. April 16, 2003 Notice of Hearing, Affidavit of publication, e -mail Distribution list, bulk mailing. 2. Proposed PBU Annular Pressure Rule 3. April 17, 2003 Notice of Hearing, Affidavit of publication, e-mail Distribution list, bulk mailing. 4. May 5, 2003 BPXA's Request for a hearing 5. May 19, 2003 PACE Public Comments 6. May 23, 2003 BPXA Working draft of testimony 7. May 27, 2003 Sign in Sheet 8. May 27, 2003 BPXA's submittal of documents for hearing 9. May 27, 2003 Annual Pressure Simulation Results 10. May 27, 2003 Transcript and correction sheet 11. June 3, 2003 BPXA's follow -up letter to CC's re: hearing 12. June 27, 2003 E- mail's from Dan Donkel objecting to CO 492 and then an e -mail later in the morning withdrawing the request. 13. October 9, 2004 Ltr from AOGCC to BPXA 14. February 8, 2006 e -mail re: termination of the requirement for the weekly SCP report 15. September 7, 2011 E -mail re: Requirements for Notification Conservation Order 492 ( ( CENTRAL NORTH SLOPE ~ AOGCC proposesmles' for Prudhoe wells The Alaska Oil and Gas Conservation Commission has published proposed rules for governing annular presSUres Úl Prudhoe Bay development wells ~d set May 27 as a tentative hearmgdate.An11ulåtpressures were determined,élSthecauseofanAUg. 16 , explosion at w~ll A-22afPrudhoe' which seriously' Úljuredaworker. The commission held_a hearing in . November on whether 'or not it" should issue such rules. Prudhoe Bayoperãtor. BPExplo'ration (Al~) and the A1Æ)SkaQilandGas Assòciation. told ,',the~ cOpmlission ,that changes have been made Úl owratlng pro- cedures and training' foll~\VÙ1~rthe~-22 explosion, ,and' bòth saidnonewreguJã- tions are needed. The commission said Jail. 16 that it had , . decided thata rUle ß.ddtessÚlg annular pres- sure management Úl"PrudhoeBay field development,wellsisappròþriatëtoptotect , worker såfety. That rUle,thecöm:n:ìišsionsåid;wöUld'reqUireBPt()..~~ thecomnû.s- sion informed a1x)Ut wells with pressurec°rrimunÌcatiÓi'l or leaks,atlct'îøget per1nÏssiön fromtlie commission forthecöntinuedó~iátionof $uch wells., . ,. . Rules proposed April..16iriclude.: daily~oni!Orin,g, ofPrudhoeaay;",ellstQ4~tect sustainbd pressures and notification tothe,cormnission.withinthree\y()rkingdays.of any' Prudhoe Bay unit ''well thateXhibitssuståinedmner annulus prèssure or,. outer annuluS pressure greaterthan20~rcentof1fie pucifþrëssutëratingÒfthe annulUS's outer tubular.'" The cormnission rilayretIUirë 'c9rrectivë'äcliòri otÚlcreåSed surveillançe for a well with sustained innetanhWl.1S oroutei"å.rinuluSpressure. / Ifa well has inner annulUS or outer annulüspressure greater ,than 4S.pefç.ent. ()fthe burst pressure rating ,of the apnul\lS's ',Qutertllbular, the . commission 'must1>e notified and the well, mustbeimmeâìatelyshutin. . At 'pressures , not greater,'thån 45percerit, the commission could .sanctioncontiriued operation "if the well operator demonstrates, by mechanical Últegrity testing, the exis~ fence offWo cOI11petentbarriers to ptessurecömInunication" attesting whichthecoQl- missiohhasan.onpQrfnni1v.to witness. ' . 'J.:¡Jenb .--.'-_on Joud AII1 JAAO A10 Want,to know more? If you'd like to read more about the annular pressure Issue go to Petroleum NeWs' web site: wmv.PetroleumNewsAJaska.com \'~;(' '10:--. , 'T' , . 2003 . March 9 AOGCC, with... tackles'" old and new business . Jan. 26 AOGCC will issue rule on " annular pressure management . Jan. 26 Pressure exceeded design burst rating' / 1\ 2002 . Nov. 24 OGCC hears from Bp, AOGA . Sept. 29 BP reports to AOGCC ' . Sept. 15 BP begins bringing 137 ,", Prudhoe Bay wells back on line ' . Sept. 1 BP halts production from. 150 slope wells ' ) J STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West 7th Avenue, Suite 100 Anchorage Alaska 99501 In the Matter Of: ) ) ) Prudhoe Bay Field: All Pools ) ) June 26, 2003 ) ) Conservation Order No. 492 A Hearing to Consider a Proposed Rule Governing the Operation of Development Wells in all Pools within the Prudhoe Bay Field with Pressure Communication or Leakage in any Casing, Tubing, or Packer. IT APPEARING THAT: 1. On its own motion, the Alaska Oil and Gas Conservation Commission ("Commission" or "AOGCC") proposed to adopt rules regulating sustained annulus pressures in Prudhoe Bay development wells. 2. Notice of opportunity for a public hearing on the proposal was published in the Anchorage Daily News on April 17, 2003. 3. By letter dated May 5,2003 BP Exploration (Alaska) Inc. ("BPXA") requested a hearing. 4. A hearing was held in conformance with 20 AAC 25.540 at the Commission's offices, 333 West 7th Avenue, Suite 100, Anchorage, Alaska 99501 on May 27,2003. FINDINGS 1. Findings 1, 3, 4, 5, 6, 7, 8, 9, 10, and 11 of Conservation Order No. 483 are incorporated by reference. 2. BPXA, the Prudhoe Bay Field operator, provided written and oral hearing testimony. BPXA's position is that sustained annulus pressures are appropriately addressed by BPXA's existing well integrity program parameters and that a new rule governing annular pressure in the Prudhoe Bay Field is unnecessary. 3. The Paper, Allied-Industrial, Chemical and Energy Workers International Union Local 8- 369, AFL-CIO, submitted written comments endorsing and supporting the proposed Prudhoe Bay Field annular pressure rules, and urged their immediate adoption. 4. The hearing record also incorporated the hearing record relating to Conservation Order No. 483, and the following material: the annular pressure management policies submitted by BPXA, MMS regulation 30 CFR 250.517, Applied Drilling Engineering by BourgoYlle, et aI., the Halliburton Cementing Tables, the Commission well files for the wells on BPXA's "A- B3" status list and on BPXA's waived well list, an annular pressure simulator developed by the Commission staff as contained in an MS Excel spreadsheet, and the Alberta Energy Utilities Board informational letter 89-19 and Interim Directive 99-3. The Commission also reviewed efforts by the American Petroleum Institute to develop a recommended practice for wells affected by sustained casing pressure. ) ) Conservation Order 'Tj2 June 27,2003 Page 2 of 4 5. BPXA performs pressure tests of tubulars and completion equipment in Prudhoe Bay Field development wells that are representative of actual well operating conditions, and monitors development wells for sustained annular pressures. 6. BPXA relies on a well pressure limit waiver process to continue operating Prudhoe Bay Field wells that exhibit inner annulus pressure exceeding 2000 psig with two pressure bleeds per week, or outer annulus pressure exceeding 1000 psig with two pressure bleeds per week. 7. Values of "burst pressure rating" and "minimum internal yield pressure" of well tubulars are numerically equal. 8. Pressure in an active Prudhoe Bay Field well not exceeding 45% of the burst pressure rating, or minimum internal yield pressure, of well tubulars is within the range of pressure that will not result in failure of well integrity, uncontrolled release of fluid or pressure, or threat to human safety. 9. Placing a shut-in Prudhoe Bay Field well in service results in well heating that can in turn cause significant increases in annular pressures. 10. BPXA intends to evaluate engineered solutions (controls, pressure relief systems, etc.) as to their applicability in managing annular pressures in Prudhoe Bay Field development wells. CONCLUSIONS I. There is a need for regulatory oversight of the management of Prudhoe Bay Field wells that exceed specific pressure thresholds, by administering rules regulating annular pressures. This methodology is consistent with similarly intended efforts by other regulatory agencies. 2. The objectives of rules regulating sustained annular pressures in Prudhoe Bay Field development wells are to conserve Alaska petroleum resources and protect human safety and the environment, through proper management of annular pressures. Proper annular pressure management aims to prevent failure of well integrity, uncontrolled release of fluid or pressure, or threat to human safety. 3. Prudhoe Bay Field annular pressure rules should recognize the variety of well completions and development well characteristics in the Prudhoe Bay Field. ') ) Conservation Order '"f"j2 June 27, 2003 Page 3 of 4 4. Recently revised BPXA Prudhoe Bay Field annular pressure management policies provide a reasonable starting point for establishing rules regulating annular pressure. However, BPXA's policies should be supplemented by (a) a requirement for AOGCC notification when Prudhoe Bay Field wells exhibit annular pressures that exceed specific thresholds, (b) a mechanism for operator submittal of corrective action proposals for affected wells, (c) a specific annular pressure limit that necessitates corrective action, and (d) operator accounting for annular pressure increases due to well heating during start-up. 5. The development of engineered solutions applicable to new and existing Prudhoe Bay Field development well systems may in the future satisfy some of the objectives of these rules for wells affected by annular pressures. 6. Well heating-induced annular pressure increases must be taken into account before initiating well start-up, to ensure that annular pressures at well operating temperature will not result in failure of well integrity, uncontrolled release of fluid or pressure, or threat to human safety. NOW THEREFORE IT IS ORDERED that each of the Conservation Orders Nos. 207, 311B, 329A, 341D, 345,452, 457A, 471, and 484 is amended to add the following rules: 1. The operator shall conduct and document a pressure test of tubulars and completion equipment in each development well at the time of installation or replacement that is sufficient to demonstrate that planned well operations will not result in failure of well integrity, uncontrolled release of fluid or pressure, or threat to human safety. 2. The operator shall monitor each development well daily to check for sustained pressure, except if prevented by extreme weather conditions, emergency situations, or similar unavoidable circumstances. Monitoring results shall be made available for AOGCC inspection. 3. The operator shall notify the AOGCC within three working days after the operator identifies a well as having (a) sustained inner annulus pressure that exceeds 2500 psig for wells processed through the Lisburne Processing Center and 2000 psig for all other development wells, or (b) sustained outer annulus pressure that exceeds 1000 psig. 4. The AOGCC may require the operator to submit in an Application for Sundry Approvals (Form 10-403) a proposal for corrective action or increased surveillance for any development well having sustained pressure that exceeds a limit set out in paragraph 3 of this rule. The AOGCC may approve the operator's proposal or may require other corrective action or surveillance. The AOGCC may require that corrective action be verified by mechanical integrity testing or other AOGCC approved diagnostic tests. The operator shall give AOGCC sufficient notice of the testing schedule to allow AOGCC to witness the tests. 5. If the operator identifies sustained pressure in the inner annulus of a development well that exceeds 45% of the burst pressure rating of the well's production casing for inner annulus pressure, or sustained pressure in the outer annulus that exceeds 45% of the burst pressure rating of the well's surface casing for outer annulus pressure, the operator shall notify the AOGCC within three working days and take corrective action. Unless well conditions require the operator to take emergency corrective action before AOGCC approval can be obtained, the operator shall submit in an Application for Sundry Approvals (Form 10- 403) a proposal for corrective action. The AOGCC may approve the operator's proposal or may require other corrective action. The AOGCC may also require that corrective action be ) Conservation Order 49L June 27, 2003 Page 4 of 4 verified by mechanical integrity testing or other AOGCC approved diagnostic tests. The operator shall give AOGCC sufficient notice of the testing schedule to allow AOGCC to witness the tests. ') / 6. Before a shut-in well is placed in service, any annulus pressure must be relieved to a sufficient degree (a) that the inner annulus pressure at operating temperature will be below 2500 psig for wells processed through the Lisburne Production Center and below 2000 psig for all other development wells, and (b) that the outer annulus pressure at operating temperature will be below 1000 psig. 7. F or purposes of these rules, "inner annulus" means the space in a well between tubing and production casing; "outer annulus" means the space in a well between production casing and surface casing; "sustained pressure" means pressure that (a) is measurable at the casing head of an annulus, (b) is not caused solely by temperature fluctuations, and (c) is not pressure that has been applied intentionally. DONE at Anchorage, Alaska and dated June 26,2003. '., ',',,"''',''--'' J íJ \ C~,'''' ~ ~ o.IL~~ s~~ t:Â , . ,0,f 'V; /L ~ ~ ",I'J*""ì~'~ ~ <'~'-lJn (~~!:J~~' ,t,'Y; Randy R~edrich, Commission~r . . 'r'), ¡.! i ~\ ),;i) ft"~"p Alaska 011 and Gas nservatlOn CommISSIon --. ~ IJj\ t ". .. . '- "....,': ',~ 't,. - r ' \'.;.4 ,.\.,¡¡ß,~rl,.....'L";'~' ., ~ \ tf,\'; " "iM¡,;.~:~'~;:.1/.~".é4::: ~ C~ "" ,,~if'" . ¡i.".~J.;(.:'" .,~. ".~ ..,- .i.:.,. .,..!It ", "\0..:..,'.1 I~ .~\~T-,,~.,,~ ..~j"~¡p,'~I' ~..."" \~ ~!t~!;;é~~~:,~ ",?, Daniel T. eamount, Jr., Commissioner .,~ (l(j¡<i (~O~~\~:/~ Alaska Oil and Gas Conservation Commission ;.,~..~~::~.~ ;"";.~"'.,'" -. ~~.-'~;...",.;~~ AS 31.05.080 provides that within 20 days after receipt of written notice of the entry of an order, a person affected by it may file with the Commission an application for rehearing. A request for rehearing must be received by 4:30 PM on the 23rd day following the date of the order, or next working day if a holiday or weekend, to be timely filed. The Commission shall grant or refuse the application in whole or in part within 10 days. The Commission can refuse an application by not acting on it within the 10-day period. An affected person has 30 days from the date the Commission refuses the application or mails (or otherwise distributes) an order upon rehearing, both being the final order of the Commission, to appeal the decision to Superior Court. Where a request for rehearing is denied by nonaction of the Commission, the 30-day period for appeal to Superior COUli runs from the date on which the request is deemed denied (i.e., 10th day after the application for rehearing was filed). ) \ ) .') '--;7# t'2¿j~C? cl~ ~ Ii< t/ / Û 3 /S.L/)( r:l7 ~ 7J9 9 g STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West 7th Avenue, Suite 100 Anchorage Alaska 99501 A Hearing to Consider a Proposed Rule Governing the Operation of Development Wells in all Pools within the Prudhoe Bay Field with Pressure Communication or Leakage in any Casing, Tubing, or Packer. ) ) ) Prudhoe Bay Field: All Pools ) ) June 26, 2003 ) ) Conservation Order No. 492 In the Matter Of: IT APPEARING THAT: 1. On its own motion, the Alaska Oil and Gas Conservation Commission ("Commission" or "AOGCC") proposed to adopt rules regulating sustained annulus pressures in Prudhoe Bay development wells. 2. Notice of opportunity for a public hearing on the proposal was published in the Anchorage Daily News on April 17, 2003. 3. By letter dated May 5,2003 BP Exploration (Alaska) Inc. ("BPXA") requested a hearing. 4. A hearing was held in conformance with 20 AAC 25.540 at the Çommission's offices, 333 West 7th Avenue, Suite 100, Anchorage, Alaska 99501 on May 27,2003. FINDINGS 1. Findings 1, 3,4, 5, 6, 7, 8, 9, 10, and 11 of Conservation Order No. 483 are incorporated by reference. 2. BPXA, the Prudhoe Bay Field operator, provided written and oral hearing testimony. BPXA's position is that sustained annulus pressures are appropriately addressed by BPXA's existing well integrity program parameters and that a new rule governing annular pressure in the Prudhoe Bay Field is unnecessary. 3. The Paper, Allied-Industrial, Chemical and Energy Workers International Union Local 8- 369, AFL-CIO, submitted written comments endorsing and supporting the proposed Prudhoe Bay Field annular pressure rules, and urged their immediate adoption. 4. The hearing record also incorporated the hearing record relating to Conservation Order No. 483, and the following material: the annular pressure management policies submitted by BPXA, MMS regulation 30 CFR 250.517, Applied Drilling Engineering by BourgoYlle, et al., the Halliburton Cementing Tables, the Commission well files for the wells on BPXA's "A- B3" status list and on BPXA's waived well list, an annular pressure simulator developed by the Commission staff as contained in an MS Excel spreadsheet, and the Alberta Energy Utilities Board informational letter 89-19 and Interim Directive 99-3. The Commission also reviewed efforts by the American Petroleum Institute to develop a recommended practice for wells affected by sustained casing pressure. SO Dept of Env & Natural Resources Oil and Gas Program 2050 West Main, Ste 1 Rapid City, SO 57702 Mary Jones XTO Energy, Inc. Cartography 810 Houston Street, Ste 2000 Ft. Worth, TX 76102-6298 W. Allen Huckabay ConocoPhillips Petroleum Company Offshore West Africa Exploration 600 North Dairy Ashford Houston, TX 77079-1175 Chevron Chemical Company Library PO Box 2100 Houston, TX 77252-9987 Robert Gravely 7681 South Kit Carson Drive Littleton, CO 80122 Richard Neahring NRG Associates President PO Box 1655 Colorado Springs, CO 80901 Samuel Van Vactor Economic Insight Inc. 3004 SW First Ave. Portland, OR 97201 Julie Houle State of Alaskan DNR Div of Oil & Gas, Resource Eva!. 550 West 7th Ave., Ste 800 Anchorage. AK 99501 Trustees for Alaska 1026 West 4th Ave., Ste 201 Anchorage, AK 99501-1980 ) Christine Hansen Interstate Oil & Gas Compact Comm Excutive Director PO Box 53127 Oklahoma City, OK 73152 Paul Walker Chevron 1301 McKinney, Rm 1750 Houston, TX 77010 Texico Exploration & Production PO Box 36366 Houston, TX 77236 Shawn Sutherland Unocal Revenue Accounting 14141 Southwest Freeway Sugar Land, TX 77478 George Vaught, Jr. PO Box 13557 Denver, CO 80201-3557 John Levorsen 200 North 3rd Street, #1202 Boise,lD 83702 Thor Cutler OW-137 US EPA egion 10 1200 Sixth Ave. Seattle, WA 98101 Cammy Taylor 1333 West 11th Ave. Anchorage, AK 99501 Mark Wedman Halliburton 6900 Arctic Blvd. Anchorage, AK 99502 ') ./ John Katz State of Alaska Alaska Governor's Office 444 North Capitol St., NW, Ste 336 Washington, DC 20001 Citgo Petroleum Corporation PO Box 3758 Tulsa, OK 74136 David McCaleb IHS Energy Group GEPS 5333 Westheimer, Ste 100 Houston, TX 77056 Chevron USA Alaska Division PO Box 1635 Houston, TX 77251 Kelly Valadez Tesoro Refining and Marketing Co. Supply & Distribution 300 Concord Plaza Drive San Antonio, TX 78216 Jerry Hodgden Hodgden Oil Company 408 18th Street Golden, CO 80401-2433 Kay Munger Munger Oil Information Service, Inc PO Box 45738 Los Angeles, CA 90045-0738 Michael Parks Marple's Business Newsletter 117 West Mercer S1, Ste 200 Seattle, WA 98119-3960 Susan Hill State of Alaska, ADEC EH 555 Cordova Street Anchorage, AK 99501 Ciri Land Department PO Box 93330 Anchorage, AK 99503 Mark Hanley Anadarko 3201 C Street, Ste 603 Anchorage, AK 99503 Judy Brady Alaska Oil & Gas Associates 121 West Fireweed Lane, Ste 207 Anchorage, AK 99503-2035 Gordon Severson 3201 Westmar Cr. Anchorage, AK 99508-4336 Tesoro Alaska Company PO Box 196272 Anchorage, AK 99519 Sue Miller BP Exploration (Alaska), Inc. PO Box 196612 Anchorage, AK 99519-6612 Penny Vadla Box 467 Ninilchik, AK 99639 Richard Wagner PO Box 60868 Fairbanks, AK 99706 Bernie Karl K&K Recycling Inc. PO Box 58055 Fairbanks, AK 99711 Kurt Olson State of Alaska Staff to Senator Tom Wagoner State Capitol Rm 427 Juneau, AK 99801 ) Schlumberger Drilling and Measurements 3940 Arctic Blvd., Ste 300 Anchorage, AK 99503 Jill Schneider US Geological Survey 4200 University Dr. Anchorage, AK 99508 David Cusato 600 West 76th Ave., #508 Anchorage, AK 99518 Jack Hakkila PO Box 190083 Anchorage, AK 99519 BP Exploration (Alaska), Inc. Land Manager PO Box 196612 Anchorage, AK 99519-6612 James Gibbs PO Box 1597 Soldotna, AK 99669 Cliff Burglin PO Box 131 Fairbanks, AK 99707 Williams Thomas Arctic Slope Regional Corporation Land Department PO Box 129 Barrow, AK 99723 Lt Governor Loren Leman State of Alaska PO Box 110015 Juneau, AK 99811-0015 \ Baker Oil Tools 4730 Business Park Blvd., #44 Anchorage, AK 99503 Jim Scherr US Minerals Management Service Resource Evaluation 949 East 36th Ave., Ste 308 Anchorage, AK 99508 Jeanne Dickey BP Exploration (Alaska), Inc. Legal Department PO Box 196612 Anchorage, AK 99518 Kevin Tabler Unocal PO Box 196247 Anchorage, AK 99519-6247 Kenai Peninsula Borough Economic Development Distr 14896 Kenai Spur Hwy #103A Kenai, AK 99611-7000 Kenai National Wildlife Refuge Refuge Manager PO Box 2139 Soldotna, AK 99669-2139 Harry Bader State of Alaska Department of Natural Resources 3700 Airport Way Fairbanks, AK 99709 North Slope Borough PO Box 69 Barrow, AK 99723 CO 492 } Subject: CO 492 Date: Thu, 26 Jun 2003 14:28:56 -0800 From: Jody Colombie <jody_colombie@admin.state.ak.us> Organization: Alaska Oil and Gas Conservation Commission To: Cynthia B Mciver <bren_mciver@admin.state.ak.us> Brent please add to web site. J . Nanu': C0492.doc . DCO-l-92.doc Type: \\,'IN\VORD File (application...'ms\\'ord) Encoding: base64 i Jody Colombie <jody - colombie@admin.state.ak.us> 1 of! 6/26/2003 2:49 PM CO 492 Subject: CO 492 Date: Thu, 26 Jun 2003 14:30:05 -0800 From: Jody Colombie <jody_colombie@admin.state.ak.us> Organization: Alaska Oil and Gas Conservation Commission To: Robert E Mintz <robert - mintz@law.state.ak.us>, John Tanigawa <JohnT@EvergreenGas.com>, Terrie Hubble <hubblet1@bp.com>, Sondra Stewman <StewmaSD@BP .com>, stanekj <stanekj@unocal.com>, ecolaw <ecolaw@trustees.org>, roseragsdale <roseragsdale@gci.net>, tnnjrl <tnnjrl@aol.com>, jbriddle <jbriddle@marathonoil.com>, rockhill <rockhill@aoga.org>, shaneg <shaneg@evergreengas.com>, rosew <rosew@evergreengas.com>, jdarlington <jdarlington@forestoil.com>, nelson <nelson@gci.net>, cboddy <cboddy@usibelli.com>, "markdalton" <markdalton@hdrinc.com>, "shannon.donnelly" <shannon.donnelly@conocophillips.com>, "mark p. worcester" <mark. p. worcester@conocophillips.com>, "j erry. c.dethlefs" <j erry.c. dethlefs@conocophillips.com> , arlenehm <arlenehm@gci.net>, bob <bob@inletkeeper.org>, wdv <wdv@dnr.state.akus>, tjr <tjr@dnr.state.akus>, bbritch <bbritch@alaska.net>, mjnelson <mjnelson@purvingertz.com>, burgin - d <burgin - d@niediak.com>, "charles.o'donnell" <charles.o'donnell@veco.com>, "Skillern, Randy L" <SkilleRL@BP.com>, "Dickey, Jeanne H" <DickeyJH@BP.com>, "Jones, Deborah J" <JonesD6@BP.com>, "Hyatt, Paul G" <hyattpg@BP.com>, "Rossberg, R Steven" <RossbeRS@BP.com>, "Shaw, Anne L (BP Alaska)" <ShawAL@BP.com>, "Kirchner, Joseph F" <KirchnJF@BP.com>, "Pospisil, Gordon" <PospisG@BP.com>, "Sommer, Francis S" <SommerFS@BP.com>, "Schultz, Mikel" <Mikel. Schultz@BP .com>, "Jenkins, David P" <JenkinDP@BP.com>, "Glover, Nick W" <GloverNW@BP.com>, "Kleppin, Daryl J" <KleppiDE@BP.com>, "Platt, Janet D" <PlattJD@BP.com>, "Wuestenfeld, Karen S" <WuesteKS@BP.com>, "Jacobsen, Rosanne M" <JacobsRM@BP.com>, ddonkel <ddonkel@cfl.rr.com>, collins_mount <collins - mount@revenue.state.akus>, mckay <mckay@gci.net>, "b arb ara. f. fullmer" <barb ara. f. fullmer@conocophillips.com>, eyancy <eyancy@seal-tite.net>, bocastwf <bocastwf@bp.com>, cowo <cowo@chevrontexaco.com>, ajiii88 <ajiii88@hotmail.com>, doug_schultze <doug- schultze@xtoenergy.com>, "hank.alford" <hank.alford@exxonmobil.com>, yesno 1 <yesno 1 @gci.net>, "john. w .hanes" <john. w .hanes@exxonmobil.com>, gspfoff <gspfoff@aurorapower.com>, "gregg.nady" <gregg.nady@shell.com>, "fred. steece" <fred. steece@state.sd. us>, rcrotty <rcrotty@ch2m.com>, jejones <jejones@aurorapower.com>, dapa <dapa@alaska.net>, jroderick <jroderick@gci.net>, eyancey <eyancey@seal-tite.net> Please find Conservation Order 492 issued today. Jody Colombie 10f2 6/26/2003 2:49 PM CO 492 20f2 ) . Name: C0492.doc DC0492.doc Type: \VIN\VORD Fil~ (application I11s\\'ord) Enco~~~"~:~~~~?~ .. .," ," ,.' ""'''''''''~'~'"===M~"",~,J Jody Colombie <jody- colombi~(q'admin.stat~.ak.Lls> ) 6/26/2003 2:49 PM r 1 CO 492 Requirements for Notificatio. • Page 1 of 2 Regg, James B (DOA) From: Regg, James B (DOA) (7(t( Sent: Wednesday, September 07, 2011 2:59 PM °-0 Z To: 'AK, D &C Well Integrity Coordinator' Cc: Daniel, Ryan; Aubert, Winton G (DOA); Maunder, Thomas E (DOA); Schwartz, Guy L (DOA) Subject: RE: CO 492 Requirements for Notification You are accurately understanding the intent of the sustained casing pressure (SCP) Conservation Orders (e.g., CO 492). There is no notification requirement for pressures that are "caused solely by temperature fluctuations "; of course inherent to that would be diagnostics completed on the annulus pressure to confirm it is actually thermally induced. "No notification" includes any pressure excursions above the SCP notification thresholds of Conservation Orders during well startup (which I would define as the time it takes to reach thermal equilibrium; understand this would typically be within 5 days if I remember discussions during development of our well safety valve system testing requirements). Some commentary regarding Rule 6 (bleeding pressure before startup) - perhaps more than you need or want but it is important to emphasize the concerns about thermal effects of bring a well on line. CO 492, Rule 6: "Before a shut -in well is placed in service, any annulus pressure must be relieved to a sufficient degree (a) that the inner annulus pressure at operating temperature will be below 2500 psig for wells processed through the Lisburne Production Center and below 2000 psig for all other development wells, and (b) that the outer annulus pressure at operating temperature will be below 1000 psig Notification of what should be a temporary pressure excursion (thermal effects) was deemed unnecessary. Instead, the pre -bleed requirement was adopted to prevent the overpressure due to thermal effects while starting a well. Bleeding annulus pressure before well start should minimize /eliminate the reliance on human intervention (bleeding pressures). This rule was an outgrowth of AOGCC's analysis of finding from PBU A -22 investigation and followup efforts, in particular the efforts to seek an engineered solution to relieving annulus pressure to avoid an overpressure event. You should have guidance for field personnel regarding bleeding pressures before startup, and maintaining man watch during startup. A simple annulus pressure model using Boyles and Charles Laws shows the impact of temperature on the annulus pressure, and can easily be used to determine how low to bleed annulus pressure prior to start-up. Jim Regg AOGCC 333 W.7th Avenue, Suite 100 Anchorage, AK 99501 907 - 793 -1236 From: AK, D &C Well Integrity Coordinator [ mailto: AKDCWelllntegrityCoordinator @bp.com] Sent: Wednesday, September 07, 2011 10:39 AM To: Regg, James B (DOA) Cc: Daniel, Ryan Subject: CO 492 Requirements for Notification Hi Jim, I wanted to get some clarification on AOGCC requirements for notification with regard to overpressure events on annuli. It is clear to me that per CO 492 the AOGCC requires notification when an overpressure event occurs on an annulus that is related to sustained casing pressure that exceeds the MOASP of the annulus (sustained casing pressure is defined as (a) measurable at the casing head of an annulus (b) not caused solely by temperature fluctuations, and (c) is not pressure that has been applied intentionally). Is there a similar requirement for notification for a thermally induced overpressure event during start up of a well that results in casing pressure above MOASP? 9/7/2011 CO 492 Requirements for Notificatio, Page 2 of 2 • Thank you in advance, Mehreen Vazir (Alternate: Gerald Murphy) Well Integrity Coordinator BP Alaska Drilling & Wells Well Integrity Office: 907.659.5102 Email: AKDCWelllntegrityCoordinator @BP.com 9/7/2011 #14 Re: Weekly SCP Report for Week Ending 5 February 2006 e e ~o y q z, ~fubjcct: Re: Weekly SCP Rcporl for \...·cck Ending 5 Fcbruary 2006 From: Winton Aubcrt <winton. aubcrt(i:ï)dmin.slatc.ak.us> Dllte: Wed, OS Feb 200614: 1 0: II -()I)OO To: ":\SL, Af)\V \Vclllntcgrily Engincer" <NSLADWWclllntcgrityEnginccr@BP.com> cc: .Imllcs B Regg <jim regg@admin.statc.ak.us>. Catherinc P Foerster <t'UThy.. f()crstcr(ii~admin.st¡¡te.ak.lIs'> Joe, Lately we at AOGCC have found the weekly SCP report to have very limited usefulness. Accordingly, the Commission hereby terminates the requirement for the weekly SCP report. All other reporting requirements are unchanged. Winton Aubert AOGCC 793-1231 NSU, ADW Wen Integrity Engineer wrote: Hello Winton and Jim. Attached is the SCP report for the week ending 5 February 2006. Please call with any questions. «SCP Report 02-05-06.htm» Joe Anders, P.E. Well Integrity Coordinator, BP Exploration, (Alaska) Inc. Work: 1-907-659-5102 Mobile: 943-1154 Pager: 659-5100, x 1154 Ernail: NSUADWWelllnteqrityEngineer(âJbp.com SCP Well Status Report 2/5/ Well Type WI Stat Problem Planned Action WI Note B-21 TxlA comm, TIFL failed on BUR 1/28/06. IAxOA Comm Bradenhead welded Problem AL Blinded Obj: Eval high lAP (oper call in 01/27) 1. DHD: TIFL - FAILED on BUR 2. SL: DGL V sta#5 & 6, POP 3. DHD: Re-TIFL IAxOA wav max IAP/OAP=1000#, DGLV P C-15 P TxlA comm, TlFL failed 2/5/06 on BUR. Obj: Eval high lAP, FO call-in SL to DGLV, DHD to Re-TIFL Problem 10f2 2/8/20062:39 PM ... Re: Weekly SCP Report for Week Ending 5 February 2006 e e 20f2 ....ø' 1. VLV: Repair broken wing valve - DONE Slow IAxOA can be managed by bl 2. DHD: TIFL - FAILED on BUR - 9/22/03 3. SL: DGLV Sta #4 & #3 4. DHD: Re-TIFL Total Wells: 2 Please contact the Well Integrity Coordinator at 1-907-659-5102 with any questions or if any of these planned actions are to be witnessed by an AOGCC inspector. This report is intended to fulfill the wellwork notification requirements of CO 492 and the other Well Integrity related Conservation Orders. Page 1 of 1 2/8/20062:39 PM =tt: ¡.......i VJ ) ') FRANK H. MURKOWSKI, GOVERNOR AIfASKA OIL AND GAS CONSERVATION COMMISSION 333 W. rrn AVENUE, SUITE 100 ANCHORAGE, ALASKA 99501-3539 PHONE (907) 279-1433 FAX (907) 276-7542 October 9, 2003 Mark Stanley Wells Delivery Manager BP Exploration (Alaska), Inc. P.O. Box 196612 Anchorage, AK 99519-6612 Dear Mr. Stanley: By letter dated October 29, 2002 the Alaska Oil and Gas Conservation Commis- sion ("Commission" or "AOGCC") established start-up, testing, operating, and data reporting requirements for certain wells within the Prudhoe Bay Field classi- fied by the field operator, BP Exploration (Alaska) Inc. ("BPXA"), as Category A/B3. Subsequently, Conservation Order 492, effective June 26, 2003, estab- lished start-up, testing, operating, and data reporting requirements for Prudhoe Bay Field development wells that exhibit sustained annulus pressures exceeding specific thresholds. AOGCC believes that the human safety and environmental protection purposes of the October 29, 2002 letter are tacit in the requirements of Conservation Order 492. Consequently, the Commission hereby rescinds re- quirements of the October 29, 2002 letter regarding Category A/B3 wells, with the following exception. Please be advised that an approved Sundry Notice (Form 10-403) is required for start-up of injection well OS 12-23. Sincerely, ~-~~ ~ ~pa ~P'--- Daniel T. amount, Jr. Chair Commissioner fc_L ~ ' ~;:n:;;;,ledrich ' ~ Commissioner cc: Harry Engel, BPXA . :~;i-Ü~NE(;~ OCT 14 2003 #12 Re: CO 492 Subject: Re: CO 492 Date: Fri, 27 Jun 2003 08:27:47 -0400 From: "Dan Donkel" <ddonkel~cfl.rr.com> To: "Jody Colombie" <jody_colombie~admin.state.ak.us> Dear Jody I sent an E-Mail to the AOGCC on this Order last night please delete it as I am not going to Oject to CO 492. Thanks for doing this for me. Original Message From: "Jody Colombie" <jody_colombie@admin.state.ak.us> To: "Robert E Mintz" <robert mintz@law.state.ak.us>; "John Tanigawa" <JohnT@EvergreenGas.com>; "Terrie Hubble" <hubbletl@bp.com>; "Sondra Stewman" <StewmaSD@bp.com>; "stanekj" <stanekj@unocal.com>; "ecolaw" <ecolaw@trustees.org>; "roseragsdale" <roseragsdale@gci.net>; "trmjrl" <trmjrl@aol.com>; "jbriddle" <jbriddle@marathonoil.com>; "rockhill" <rockhill@aoga.org>; "shaneg" <shaneg@EvergreenGas.com>; "rosew" <rosew@EvergreenGas.com>; "jdarlington" <jdarlington@forestoil.com>; "nelson" <nelson@gci.net>; "cboddy" <cboddy@usibelli.com>; "mark.dalton" <mark.dalton@hdrinc.com>; "shannonodonnelly" <shannon.donnelly@conocophillips.com>; "mark.p.worcester" <mark.p.worcester@conocophillips.com>; "jerry.c.dethlefs" <jerry.c.dethlefs@conocophillips.com>; "arlenehm" <arlenehm@gci.net>; "bob" <bob@inletkeeper.org>; "wdv" <wdv@dnr.state.ak.us>; "tjr" <tjr@dnr.state.ak.us>; "bbritch" <bbritch@alaska.net>; "mjnelson" <mjnelson@purvingertz.com>; "burgin_d" <burgin_d@niediak.com>; "charles.o'donnell" <charles.o'donnell@veco.com>; "Skillern, Randy L" <SkilleRL@bp.com>; "Dickey, Jeanne H" <DickeyJH@bp.com>; "Jones, Deborah J" <JonesD6@bp.com>; "Hyatt, Paul G" <hyattpg@bp.com>; "Rossber~, R Steven" <RossbeRS@bp.com>; "Shaw, Anne L (BP Alaska)" <ShawAL@bp.com>; "Kirchner, Joseph F" <KirchnJF@bp.com>; "Pospisil, Gordon" <PospisG@bp.com>; "Sommer, Francis S" <SommerFS@bp.com>; "Schultz, Mikel" <Mikel.Schultz@bp.com>; "Jenkins, David P" <JenkinDP@bp.com>; "Glover, Nick W" <GloverNW@bp.com>; "Kleppin, Daryl J" <KleppiDE@bp.com>; "Platt, Janet D" <PlattJD@bp.com>; "Wuestenfeld, Karen S" <WuesteKS@bp.com>; "Jacobsen, Rosanne M" <JacobsRM@bp.com>; "ddonkel" <ddonkel@cfl.rr.com>; "collins_mount" <collins mount@revenue.state.ak.us>; "mckay" <mckay@gci.net>; "barbara.f.fullmer" <barbara.f.fullmer@conocophillips.com>; "eyancy" <eyancy@seal-tite.net>; "bocastwf" <bocastwf@bp.com>; "cowo" <cowo@chevrontexaco.com>; "ajiii88" <ajiii88@hotmail.com>; "doug_schultze" <doug_schultze@xtoenergy.com>; "hank.alford" <hank.alford@exxonmobil.com>; "yesnol" <yesnol@gci.net>; "john.w.hanes" <john.w.hanes@exxonmobil.com>; "gspfoff" <gspfoff@aurorapower.com>; "gregg.nady" <gregg.nady@shell.com>; "fred.steece" <fred.steece@state.sd.us>; "rcrotty" <rcrotty@ch2m.com>; "jejones" <jejones@aurorapower.com>; "dapa" <dapa@alaska.net>; "jroderick" <jroderick@~ci.net>; "eyancey" <eyancey@seal-tite.net> Sent: Thursday, June 26, 2003 6:30 PM Subject: CO 492 Please find Conservation Order 492 issued today. Jody Col ombi e 1 of I 6/27/2003 8:47 AM Re: CO 492 Francis S" <SommerFS@bp.com>; "Schultz, Mikel" <Mikel.Schultz@bp.com>; "Jenkins, David P" <JenkinDP@bp.com>; "Glover, Nick W" <GloverNW@bp.com>; "Kleppin, Daryl J" <KleppiDE@bp.com>; "Platt, Janet D" <PlattJD@bp.com>; "Wuestenfeld, Karen S" <WuesteKS@bp.com>; "Jacobsen, Rosanne M" <JacobsRM@bp.com>; "ddonkel" <ddonkel@cfl.rr.com>; "collins mount" <collins mount@revenue.state.ak.us>; "mckay" <mckay@gci.net>; "barbara~f.fullmer" <barbara.f.fullmer@conocophillips.com>; "eyancy" <eyancy@seal-tite.net>; "bocastwf" <bocastwf@bp.com>; "cowo" <cowo@chevrontexaco.com>; "ajiii88" <ajiii88@hotmail.com>; "doug_schultze" <doug_schultze@xtoenergy.com>; "hank.alford" <hank.alford@exxonmobil.com>; "yesnol" <yesnol@gci.net>; "john.w.hanes" <john.w.hanes@exxonmobil.com>; "gspfoff" <gspfoff@aurorapower.com>; "gregg.nady" <gregg.nady@shell.com>; "fred.steece" <fred.steece@state.sd.us>; "rcrotty" <rcrotty@ch2m.com>; "jejones" <jejones@aurorapower.com>; "dapa" <dapa@alaska.net>; "jroderick" <jroderick@gci.net>; "eyancey" <eyancey@seal-tite.net> Sent: Thursday, June 26, 2003 6:30 PM Subject: CO 492 > Please find Conservation Order 492 issued today. > > Jody Col ombi e > 2 of 2 6/27/2003 8:47 AM Re: CO 492 ~ Subject: Re: CO 492 Date: Thu, 26 Jun 2003 22:44:23 -0400 From: "Daniel K. Donkel" <ddonkel@cfl.rr. com> To: "Jody Colombie" <jody_colombie~admin.state.ak.us> DEAR AOGCC I OBJECT TO SAID ORDER SINCE I AM A OWNER OF AN ORRI IN ADL 380066 NEXT TO A LEASE HELD BY THE SUBJECT UNIT AND THE AOGCC SET A NEW INTERPRETATION OF THE RULES ON NOTICE AS STATED ON MY PETITION PLEASE HAVE PROPER NOTICE SENT TO ALL OR I AND THE OTHERS Can AS I DO OBJECT AT ANY TIME THAT IS PROPER BY THE COURT I AND ALL CAN RESERVE ALL RIGHTS UNDER LAW AND CONTRACT. REMEMBER EQUAL TREATMENT UNDER LAW WHERE DID YOU SEE THAT RULE, SEE MY HEMI SPRINGS CASE, TREAT ME THE SAME UNDER LAW OR SEE THE JUDGE AGAIN BUT AS YOU KNOW YOU CAN NOT HAVE ANY MEANINGFUL EFFECT FROM A SIMPLE JUDGE BECAUSE YOU WORK FOR THE STATE OR SOMEONE BIGGER THAT NO ONE KNOWS ABOUT . I AM TELLING YOU TREAT ME EQUAL IT'S IN THE US CONSTITUTION SEE IF YOUR COUNSEL CAN FIND IT!!. You Must NOW send ALL NOTICES certified mail to all OWNERS ALL OVER affected under your new view of this notice law AND THIS NEW ORDER IT'S EQUAL TREATMENT UN THIS SAME NOTICE LAW as you have said in my Order and now all Orders by the AOGCC that are Not Sent Certified Mail ARE NULL AND VOID AS ARE ALL FORMER ORDERS CORRECT ME IF I AM WRONG ON, WILL YOU PLEASE let all know AS I HAVE FRIENDS THAT MAY OBJECT TO THE ALPINE ORDERS THAT PHILLIPS ONCE AGAIN FOUND YOUR FAVOR IN FAVOR AS THEY ARE YOUR LARGEST FINANCIAL CONTRIBUTOR, FOR YOUR SO CALLED INDEPENDENT AGENCY ARE THE NOT? YOUR NEW VIEW OF THIS VERY OLD LAW ON NOTICES WILL VOID ALL ORDERS SO ANY ONE CAN ACT AS THEY ARE NO GOOD RIGHT,? YOU MUST LET THE PUBLIC KNOW ALL ORDER ARE NO GOOD UNLESS THE HAVE A CERTIFIED MAIL OF NOTICE, PLEASE SAY THIS IS TRUE OR WHAT ARE YOU SAYING WITH THE HEMI SPRINGS CASE CONCERNING NOTICE ? PLEASE READ THE CONSTITUTION AND DON'T TREAD ON MY DELAWARE RIGHTS OR I WILL MAKE ANSWER TO A REAL JTJDGE AN YOU CAN TAKE THAT TO THE BANK AND CASH IT!!Do I have to file with the court my objection or will you treat me equal under the same law? Let me Know Will YOU? Daniel K. Donkel (407) 699-4937 - Telephone (407) 699-4718 - Fax ddonkel@cfl.rr.com This e-mail message is confidential, together with any attachments. If you are not the intended recipient, please notify the author immediately and destroy this message. Also, refrain from copying, disclosing or using the contents in any way. Original Message From: "Jody Colombie" <jody_colombie@admin.state.ak.us> To: "Robert E Mintz" <robert mintz@law.state.ak.us>; "John Tanigawa" <JohnT@EvergreenGas.com>; "Terrie Hubble" <hubbletl@bp.com>; "Sondra Stewman" <StewmaSD@bp.com>; "stanekj" <stanekj@unocal.com>; "ecolaw" <ecolaw@trustees.org>; "roseragsdale" <roseragsdale@gci.net>; "trmjrl" <trmjrl@aol.com>; "jbriddle" <jbriddle@marathonoil.com>; "rockhill" <rockhill@aoga.org>; "shaneg" <shaneg@EvergreenGas.com>; "rosew" <rosew@EvergreenGas.com>; "jdarlington" <jdarlington@forestoil.com>; "nelson" <nelson@gci.net>; "cboddy" <cboddy@usibelli.com>; "mark.dalton" <mark.dalton@hdrinc.com>; "shannon.donnelly" <shannon.donnelly@conocophillips.com>; "mark.p.worcester" <mark.p.worcester@conocophillips.com>; "jerry.c.dethlefs" <jerry.c.dethlefs@conocophillips.com>; "arlenehm" <arlenehm@gci.net>; "bob" <bob@inletkeeper.org>; "wdv" <wdv@dnr.state.ak.us>; "tjr" <tjr@dnr.state.ak.us>; "bbritch" <bbritch@alaska.net>; "mjnelson" <mjnelson@purvingertz.com>; "burgin_d" <burgin_d@niediak.com>; ',charles.o'donnell" <charles.o'donnell@veco.com>; "Skillern, Randy L" <SkilleRL@bp.com>; "Dickey, Jeanne H" <DickeyJH@bp.com>; "Jones, Deborah J" <JonesD6@bp.com>; "Hyatt, Paul G" <hyattpg@bp.com>; "Rossberg, R Steven" <RossbeRS@bp.com>; "Shaw, Anne L (BP Alaska)" <ShawAL@bp.com>; "Kirchner, Joseph F" <KirchnJF@bp.com>; "Pospisil, Gordon" <PospisG@bp.com>; "Sommer, 1 of 2 6/27/2003 8:09 AM Re: CO 492 Francis S" <SommerFS@bp.com>; "Schultz, Mikel" <Mikel.Schultz@bp.com>; "Jenkins, David P" <JenkinDP@bp.com>; "Glover, Nick W" <GloverNW@bp.com>; "Kleppin, Daryl J" <KleppiDE@bp.com>; "Platt, Janet D" <PlattJD@bp.com>; "Wuestenfeld, Karen S" <WuesteKS@bp.com>; "Jacobsen, Rosanne M" <JacobsRM@bp.com>; "ddonkel" <ddonkel@cfl.rr.com>; "collins mount" -- <collins mount@revenue.state.ak.us>; "mckay" <mckay@gci.net>; "barbara~f.fullmer" <barbara.f.fullmer@conocophillips.com>; "eyancy" <eyancy@seal-tite.net>; "bocastwf" <bocastwf@bp.com>; "cowo" <cowo@chevrontexaco.com>; "ajiii88" <ajiii88@hotmail.com>; "doug_schultze" <dou~_schultze@xtoenergy.com>; "hank.alford" <hank.alford@exxonmobil.com>; "yesnol" <yesnol@gci.net>; "john.w.hanes" <john.w.hanes@exxonmobil.com>; "gspfoff" <gspfoff@aurorapower.com>; "gregg.nady" <gregg.nady@shell.com>; "fred.steece" <fred.steece@state.sd.us>; "rcrotty" <rcrotty@ch2m.com>; "jejones" <jejones@aurorapower.com>; "dapa" <dapa@alaska.net>; "jroderick" <jroderick@gci.net>; "eyancey" <eyancey@seal-tite.net> Sent: Thursday, June 26, 2003 6:30 PM Subject: CO 492 > Please find Conservation Order 492 issued today. > Jody Colombie > 2 of 2 6/27/2003 8:09 AM #11 BP Exploration (Alaska) Inc. 900 East Benson Boulevard RO. Box 196612 Anchorage, Alaska 995196612 (907) 561-5111 June 3,2003 Sarah Palin, Chair Alaska Oil & Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, Alaska 99501 Reference: Follow-up to May 27, 2003 Hearing Dear Ms. Palin: RECEIVED JUN 0 ~, 2003 Alaska Oil & Gas Cons. Commission Anchora§e This letter responds to the request for additional information at the May 27, 2003 hearing regarding a proposed rule governing annular pressure in the Prudhoe Bay Field. Outer Annulus Down Squeeze Procedures For the period January 1, 2002 through May 29, 2003, twenty-two outer annulus down squeeze procedures were performed in the Prudhoe Bay Field. Definition of "Sustained Pressure" We were unable to find a reference to a definition of "Sustained pressure" in the currently applicable regulations of the various oil and gas regulatory agencies in the United States and Canada. However, a definition of the term "sustained pressure" has been proposed by the Minerals Management Service (MMS) to be included in 30 CFR Part 250, the proposed rules for "Oil and Gas and Sulfur Operations in the Outer Continental Shelf-Procedures for Dealing with Sustained Casing Pressure." These proposed rules were published in the Federal Register/Vol. 66, No. 218/Friday, November 9, 2001 and contain the following definition for "sustained casing pressure." 1. Measurable at the casing head of an annulus that rebuilds when bled down; 2. Not due solely to temperature fluctuations; 3. Not a pressure that has been applied deliberately; and 4. A result of one or more leaks. Proposed rule 30 CFR 250.518(b). We started with this proposed MMS rule, refined the language and deleted the fourth element as unnecessary. Then, we added pressure limit and bleed frequency criteria to allow the definition to be used to categorize wells deserving of special attention. BPXA's proposed definition is: "Sustained pressure" means pressure that: 1. is measurable at the casing head of an annulus, 2. is not caused solely by temperature fluctuations, 3. has not been applied through artificial lift operations, and 4. cannot be consistently maintained under the following limits with two or fewer bleeds per week: · inner annulus: 2500 psig for wells processed through the Lisburne Production Center and 2,000 psig for all other Prudhoe Bay development wells · outer annulus: 1000 psig BPXA sees the purpose of the regulation as increasing scrutiny of wells that are more likely to pose a safety or operational risk on account of sustained pressure. Any standard will be, to a certain degree, arbitrary. Our belief is that the best rule will be one that is simple and uniform, consistent with our well designs, and proven through experience to be effective in identifying those wells that deserve increased scrutinty. Thus, the proposed definition incorporates both bleed frequency and pressure threshold criteria. The BPXA proposed bleed frequency criteria are based on recognition that the dynamic nature of temperatures and pressures in a development well make it necessary to bleed pressure periodically. Our experience has shown that two bleeds per week are sufficient to differentiate these temporary impacts from sustained pressure and to indicate the relative degree of severity of any leaks. A frequency of one bleed per week usually indicates a small, undetectable leak. A frequency of three bleeds per week is an indication of a problem and is probably too frequent. Therefore, we have taken a conservative approach to allow a frequency of two bleeds per week. Our experience at Prudhoe Bay also indicates that the threshold pressures referenced, given our well designs, allow safe operation of Prudhoe Bay development wells. To support this, we have included as Attachment 1 a summary of common Prudhoe Bay well tubulars and associated burst pressures. You'll note that there are many different threshold pressures that our operators would be required to know if the commission's proposed 20% and 45% thresholds are adopted. Adopting criteria based upon the burst pressures of individual wells may at first thought appear to be more precise, but there is no bright-line "technical basis" available for present purposes. The goal of any standard, whether based on a percentage of burst pressure or a simple numerical limit, is simply to set a threshold that provides a conservative standard for determining which wells warrant increased attention. In that regard, we believe simplicity and uniformity strongly favor the uniform, simPle numerical limits set forth in our proposed rule, and not individual well-by-well standards.based on the specific materials used in that well. (In other areas in the country another approach may make more sense. If wells are consistent within an operating area, but different in the region from field to field, a burst- pressure criterion may be more fit-for-purpose than in Prudhoe Bay.) In sum, our experience shows that wells can be safely managed without undue additional measures when pressures can be maintained within reasonable limits with two or fewer bleeds per week. Our definition is grounded in operational experience and is a reasonable, conservative approach. Emergency Rule Procedures We also want to take this opportunity to clarify our response to the question the commission raised about the applicability of 20 AAC 25.539. As you know, the commission's proposed Rule 8 (our proposed Rule 7) is intended to address emergency situations. The commission's regulation 20 AAC 25.539 already provides the commission with the power to take emergency action, while providing procedures that allow the commission to receive the benefit of input from the operators, and the operators to receive the appropriate opportunity to protect their interests. This regulation is detailed and is well understood, and we do not feel we can waive the protections that it provides. If you have any questions, please call Harry Engel at 564-4194. BPXA Wells Delivery Manager BP Exploration (Alaska)Inc. Enclosures: Attachment 1. Prudhoe Bay Well Tubulars and asSociated burst pressures. Attachment 1 Prudhoe Bay Common Casing Sizes & Grades Surface Casing Grade Weight 18.625 J/K-55 96.5 13.375 L/N-80 72 13.375 L/N-80 68 13.375 J/K-55 68 10.75 L/N-80 45.5 9.625 L/N-80 47 9.625 L/N-80 40 7.625 S-95 29.7 7.625 L/N-80 29.7 Internal Yield 20% psi 2465 493 5380 1076 5020 1004 3450 690 5210 1042 6870 1374 5750 1150 8180 1636 6890 1378 45% 1109 2421 2259 1553 2345 3092 2588 3681 3101 Production Casing Grade Weight 9.625 SOO-95 47 9.625 UN-80 47 7.625 UN-80 29.7 7 UN-80 26 5.5 UN-80 17 5.5 ~N-80 15.5 Int Yield psi 20% 45% 8150 1630 3668 6870 1374 3092 6890 1378 3101 7240 1448 3258 7740 1548 3483 7000 1400 3150 #10 06/11/2003 11:55 FAX 907 564 404U bp Post-itTM brand fax transmittal memo 7671 'BP Exploration (Afaskal inc, 900 East Benson Boulevard RO. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 0 June 11, 2003 Via Fax: 276-7542 Jody Colombie, Special Staff Assistant ALASKA OIL & GAS CONSERVATION COMMISSION 333 West 7th Ave., Ste. 100 Anchorage, AK 99501 Re: Correction Sheet for May 27, 2003 Hearing Transcript Dear Jody: Enclosed is a Correction Sheet for the May 27, 2003 hearing transcript. We are experiencing technical difficulties with our email sen/em that is disrupting efforts to forward information electronically. I apologize for the inconvenience. Please feel free to call me with any questions at 564-4651. Paralegal GPE~ Intl~bgrity Management Team BP ~ration (Alaska), Inc. Enclosure: as stated 06/11/2003 11:55 FAX 907 564 4040 bp ExPLORA'IION CORRECTION SHEET ,, Page # Line #Says: Should say: ., 27 '"5 ...data is recOrded e..qually, ,,. f. ':'data is recorded weekly, .... . . 28 9 ..,that have received valve squeeze .,. that have received down squ~ze ,.. cement jobs? ,. cement jobs? ....... , · .- ,. _ ..... ,, , · . -. , .. ..... .-- , , . ., . .. , , , , ,,. _ Metro/correctpage 5-26-98 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ALASKA 0IL AND GAS CONSERVATION COMMISSION PUBLIC HEARING In Re: Commission's Proposed Annular Pressure Rule for Development Wells in all Pools within the Prudhoe Bay Unit. TRANSCRIPT OF PROCEEDINGS Anchorage, Alaska May 27, 2003 9:00 o'clock a.m. COMMISSIONERS: SARAH PALIN, Chairperson RANDY RUEDRI CH DAN SEAMOUNT METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 10 11 12 13 14 15 16 17 18 19 2O 21 22 23 24 25 TABLE OF CONTENTS OPENING REMARKS BY CHAIRPERSON PALIN. . TESTIMONY MR. ROSSBERG. DISCUSSION ..... END OF PROCEEDINGS. · Page 3 Page 6 Pages 24-29 · . Page 29 METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 P R O C E D I N G S (On record) CHAIR PALIN: Good Morning. This hearing is called to order on May 27th, 2003. It's 9:05 a.m. We're located here at the AOGCC offices at 333 West Seventh here in Anchorage, Alaska. Joining me today, I'm Sarah Palin, Chair of the Commission, is Dan Seamount to my right, and Randy Ruedrich, Commissioners. Assistant Attorney General Rob Mintz is here also, he's the Commission's counsel and he's here to advise the Commission on legal and procedural questions. He may have to sneak out a bit for another meeting at 9:30, so also joining us is Assistant A.G. Lenny Herzog, he's here also. Jan Scott of Metro Court Reporting is making a transcript of the proceedings, and those desiring a copy of the transcripts may make arrangements with Metro Court Reporting to receive that. This morning's hearing concerns a proposal by the Commission to establish rules for Prudhoe Bay on the subject of sustained casing pressures. The proposed rules were developed as a result of a process that included a previous hearing, as you will remember, on November 14th, 2002. The hearing record for today's hearing will incorporate the record of that November 14th hearing, including conservation order number 483, as well as other METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 AnChorage, Alaska 99501 (907) 276-3876 10 11 12 13 14 15 16 17 18 19 2O 21 22 23 24 25 materials that have been relied on in developing the proposed rules. And those items include the following: 1) The annular pressure policies submitted by BP Ex A, the MMS regulation 30 CFR 250.517, the American Petroleum Institute RP for sustained casing pressure, which is in development. The applied drilling engineering, Bourgoyne, et al.; the Halliburton cementing tables, which is the red book. The annular pressure simulator developed by the Commission staff as contained in an excel spread sheet. The well files for wells on BP's A-B3 status list, and the Alberta Energy Utilities Board informational letter, 89-19, and interim direct of 99-3. Notice of the hearing was published on April 17th, 2003, that was a corrected notice in the Anchorage Daily News. And these proceedings today will be held in accordance with 20 AAC 25.540. We have received a written comment by this Commission from William Bocast at P.A.C.E. This will be included in the hearing record. We have a sign-up sheet here; anyone wishing to testify or give a statement, please provide the information that's asked for on that sign-up sheet. And today we will hear both unsworn statements and sworn testimony. Each witness shall state their name and who they represent. If a person wishes to give expert testimony, they will state their qualifications and the Commission will rule METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 10 11 12 13 14 15 16 17 18 19 2O 21 22 23 24 25 on whether they qualify as an expert. A person wishing to make an unsworn oral statement will be allowed to do so after the conclusion of all testimony. The Commission may ask questions of a witness, and a person may not ask questions of witnesses directly. To have a question directed to a witness, we ask that you provide the question in writing, along with your name and that of the witness, to a designated Commission representative. And today we have Jim Regg and Winton Aubert, who are in the audience there with their hands raised. Please provide the questions to them. Before the end of the hearing, the Commission will review these questions and ask those it believes will be helpful in eliciting needed information. And I do have the sign-up sheet in front of me for those wishing to testify, and according to our list, Mr. Steve Rossberg from BP and -- just Steve Rossberg will be testifying first it sounds like. Okay. Are you giving us sworn testimony? MR. ROSSBERG: Yes, Ma'am, I will be. CHAIR PALIN: Okay. Please raise your right hand? (Oath administered) MR. ROSSBERG: Yes, I do. CHAIR PALIN: Thank you. And please, for the record, state your name and who you represent? MR. ROSSBERG: Good morning, my name is Steve METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 10 11 12 13 14 15 16 17 18 19 2O 21 22 23 24 25 Rossberg. I'm the Prudhoe Bay Wells Manager for BP Exploration in Alaska. BP is the operator of the Prudhoe Bay Field. I will be presenting testimony on behalf of BP, the operator of the Prudhoe Bay Field, and the other working interest owners regarding the corrected Notice of Public Hearing for proposed rules governing annular pressures in the Prudhoe Bay Field development wells. CHAIR PALIN: Okay. Commissioners, do you have any questions concerning Mr. Rossberg's qualifications or any objections to his expert witness? COMMISSIONER RUEDRICH: No. COMMISSIONER SEAMOUNT: No. CHAIR PALIN: Okay. Hearing no objection, then you are being accepted as an expert witness, and please proceed with your testimony. MR. ROSSBERG: Okay. TESTIMONY BY MR. ROSSBERG My testimony this morning will focus on the corrected Notice of Public Hearing regarding rules governing annular pressures in Prudhoe Bay development wells published April 17th, 2003. I will address each item in the proposed rule, providing information to support BP's recommendations for the rule. I'll start this morning with a brief review of what sustained casing pressure is. METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 10 11 12 13 14 15 16 17 18 19 2O 21 22 23 24 25 Annular pressure is possible in any well and develops from many causes. Creation of annular pressure is a normal result of production. In any sealed annulus, pressure will increase as a result of heating warm reservoir fluids which are produced through the tubulars. In addition to this phenomenon, annular pressure may result from leaks within a well bore. Many of these leaks are small leaks in various equipment, such as wellhead seals, threaded connections and packers. Annular pressure in producing oil and gas wells is a common oil field occurrence that is managed as part of ongoing operations in Alaska and around the world. It is managed through administrative, operating, and engineering controls that are applied to well design, construction and well integrity management programs. The operations and integrity management systems are subject to review by BP management and non-operators, and are adjusted and improved as a normal part of the operation. On November 14th, 2002, BP presented testimony at the AOGCC hearing regarding annular pressures in Prudhoe Bay development wells. The testimony concluded that a new rule governing annular pressure is not necessary to address the associated risks. BP continues to believe that sustained casing pressures are appropriately addressed by its well integrity program parameters. However, if the Commission METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 decides to adopt a new rule governing annular pressure in development wells, we request that our recommendations contained in this testimony and in the record, be taken into consideration. The Commission published proposed rules for governing annular pressures in Prudhoe Bay development wells on April 17, 2003. BP and the other Prudhoe Bay co-owners believe the proposed rules outlined and discussed below will enhance the rule, minimize the possibility of misinterpretation, and allow more effective implementation. Before I address each rule, I would like to present several definitions that I will use in my testimony and that we propose be incorporated into any rule that the Commission may decide to adopt to ensure clarity in the application of any rules in field operations and reporting. The definitions are as follows: "Inner annulus" means the space in the well between the tubing and the production casing. "Outer annulus" means the space in the well between the production casing and the surface casing. "Sustained Pressure" means pressure that: 1) is measurable at the casing head of an annulus, 2) is not caused solely by temperature fluctuations, 3) has not been applied through artificial lift operations, and METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 10 11 12 13 14 15 16 17 18 19 2O 21 22 23 24 25 Ii' 4) cannot be consistently maintained under the following limits with two or fewer bleeds per week. The limits are as follows: Inner annulus is 2500 pounds per square inch for wells processed through the Lisburne Production Center, and 2000 pounds per square inch for all other Prudhoe Bay development wells. Outer annulus would be 1000 psi. The rules proposed by the Commission did not include definitions. However, we believe they will be help clarify the application of the rule. The rationale for some aspects of these definitions is explained in my testimony in support of specific rules that we propose. However, one aspect of the definitions should be explained at the outset. The definition of "sustained pressure" contains threshold pressures for inner and outer annuli that are related to a bleed frequency. Due to the dynamic nature of temperatures and pressures in a development well, periodic bleeding is required to eliminate temporary impacts, such as thermal pressure. Our experience has shown that two bleeds per weeks are sufficient to differentiate these temporary impacts from sustained pressure and to indicate the relative degree of severity of any leak. In addition, our experience at Prudhoe Bay indicates that the threshold pressures referenced, given our well designs, allow safe operation of METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 10 11 12 13 14 15 16 17 18 19 2O 22 23 24 25 10 Prudhoe Bay development wells. Our experience shows that wells can be safely managed without undue additional measures when pressures can be maintained within reasonable limits with two or fewer bleeds per week. I will now discuss our recommendation for each rule. BP's recommended language for Rule 1: 1) The operator shall conduct and document a pressure test of tubulars and completion equipment in each development well at the time of installation or replacement that is sufficient to demonstrate the planned well operations will not result in failure of well integrity, uncontrolled release of fluid or pressure, or threat to human safety. In BP operations, tubulars and completion equipment in all wells are pressure tested at the time of installation or replacement to demonstrate integrity. Monitoring and surveillance programs ensure that integrity will be maintained. We believe the rule we propose is more specific and provides the protection intended by the rule as proposed by the Commission. Rule number 2. Rule 2: This is BP's recommended language for 2) Each development well must be monitored daily to check for sustained pressure, except as prevented by weather conditions, emergency situations or similar circumstances. The rationale behind this is that in BP operations, METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-$876 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 11 all development wells are monitored on a daily basis to check for sustained annular pressure as part of our comprehensive operational integrity system. However, certain circumstances, including weather conditions and emergency situations may prevent the pad operator from fulfilling this expectation. Our proposal acknowledges the unusual circumstances when it is not safe or not feasible to monitor a well on a daily basis. Rule 3. This is BP's recommended language: 3) The operator must notify the Commission within three working days after the operator identifies a well as having sustained pressure. The rationale behind the rule is as follows: As noted at the outset of my testimony, our proposed definition of the term "sustained pressure" includes specific pressure limits. These values provide an ample safety factor, apply to all wells uniformly, have proven to be effective in practice, and. are fully understood by operations staff. The rule as proposed by the Commission would impose limits calculated as a percentage of casing burst, which would result in many different trigger pressures. This would result in significantly increased burden on the operator, confusion and potential hazards to the pad operator. Rule number 4. BP's recommended language is as follows: 4) The Commission may require the operator to submit METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-38~6 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 12 a proposal for corrective action or increased surveillance for any development well identified as having sustained pressure. After reviewing the proposal, the Commission may require corrective action and verification by mechanical integrity testing, or other diagnostic tests, and that the Commission be given sufficient notice of the testing schedule. The rationale behind the rule as proposed is that while mechanical integrity tests may be appropriate to verify corrective actions in some instances, other diagnostic tests may be more suitable for given well conditions. Other recognized diagnostic tests include no-flow tests, leak rate tests, fluid levels and certain logs. Each test can provide data that will assist in diagnosing whether a well is safe to operate. BP recommended language for Rule 5. 5) If the operator identifies sustained pressure in the inner annulus of a development well in excess of 3000 pounds per square inch, or sustained pressure in the outer annulus in excess of 2000 pounds per square inch, the operator must notify the Commission within three working days and take appropriate action to prevent an uncontrolled release of fluid or pressure, or threat to human safety. The rationale is: We have taken the intent of the Commission's Rules 5 and 6, and combined them into one proposed rule. Specific limits, as opposed to percentages, METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 10 11 12 13 14 15 16 17 18 19 2O 21 22 23 24 25 13 are recommended for reasons previously discussed. These limits closely approximate 45 percent of burst as proposed by the Commission. If the limits are exceeded, appropriate action will be taken to secure the well. Recommended language for Rule 6. BP recommends the Rule read as follows: 6) Before a shut-in development well is placed in service, any annulus pressure must be relieved to a sufficient degree that the inner annulus pressure at operating temperature will be below 2500 pounds per square inch for wells processed through the Lisburne Production Center, and 2000 pounds per square inch for all other Prudhoe Bay development wells, and the outer annulus pressure at operating temperature will be below 1000 psi. This corresponds to the Commission's proposed Rule 7. BP's recommended language for Rule 7 is as follows: 7) The Commission may, by emergency action, require a development well to be shut-in until the operator takes Commission-approved corrective action, as provided under 20 AAC 25.539. The Commission may require that any corrective action be verified by mechanical integrity testing or other means, and may require that the Commission be given sufficient notice of the testing schedule. This corresponds to the Commission's proposed Rule 8. We agree with the intent of the proposed rule and have added' METR° COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 10 11 12 13 14 15 16 17 18 19 2O 21 22 23 24 25 14 language from the current Commission regulations to clarify the applicable procedures. We have already addressed the appropriateness of retaining the option to apply diagnostic testing, in addition to mechanical integrity testing. We appreciate the opportunity to prove these comments today, and look forward to working with you to address annular pressure issues at Prudhoe Bay. I would now welcome any questions that you may have. CHAIR PALIN: Okay. Thank you, Mr. Rossberg. Commissioners, any questions or comments? COMMISSIONER RUEDRICH: In view of the fact we only have one witness, is that still true, who wishes to testify? CHAIR PALIN: My sign-up sheet indicates only one wishing to testify today. COMMISSIONER RUEDRICH: Maybe we could take a quick recess and be a little more efficient in coming back and asking questions, rather than asking questions, then taking a recess and coming back for one or so additional items. CHAIR PALIN: Sure. COMMISSIONER SEAMOUNT: Have there been any written questions to our representatives? CHAIR PALIN: Okay. We've received no written questions from the audience, so Commissioner Ruedrich, how long a recess do you want? METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 15 COMMISSIONER RUEDRICH: Why don't we take at most, a ten minute recess. CHAIR PALIN: Okay. In ten minutes we'll be back on the record then. Thank you. (Off record) (On record) CHAIR PALIN: Okay. We're back on the record. And for the record, we need to add BP's list of waived wells to the materials relied-upon list and developing our proposed rules. So, now that that is duly noted, we'll continue. We do have a few questions for BP regarding their testimony. I want to start off, Mr. Rossberg, by asking is BP's definition of sustained casing pressure consistent with other regulatory agencies definition? MR. ROSSBERG: Yes. This -- this definition we proposed is consistent with the MMS prescribed definition with the exception, I believe, around bleeding and our pressure limits. Other than that, I think it's consistent. CHAIR PALIN: Okay. And do you have anything there in writing that you could submit to us regarding your definition and anything that maybe that is consistent with MMS and any other agencies, or could you submit that to us? MR. ROSSBERG: I don't have it here today, but we could pull that together and submit that. CHAIR PALIN: Okay. That would be METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 10 11 12 13 14 15 16 17 18 19 2O 21 22 23 24 25 16 appreciated. Thank you. Commissioners, do you have other questions for BP? COMMISSIONER RUEDRICH: Dan, do you want to run .... COMMISSIONER SEAMOUNT: I have just one question. I'm going to leave the -- being a geologist, I'm going to leave the more technical questions to our engineering or my engineering compadre. But under BP's recommended language for Rule 7, which would equate to the Commission's proposed Rule 8, it seems that you, Mr. Rossberg, it seems that BP is asking for a rule that's actually more onerous by recommending an emergency action. Under 20 AAC 25.539, the section on emergency action, it's -- it looks like it would require frequent hearings, if we were to take emergency action. Is BP prepared to be involved in frequent hearings? MR. ROSSBERG: Could I take one second here? COMMISSIONER SEAMOUNT: Yes. MS. JACOBSON: I think the answer is that -- I mean, we're subject -- this is Rosy Jacobson by the way, with BP. We're subject to 539 whether it's written into the rule or not. I don't know if that -- I guess I'm not really clear what your -- what your question is. COMMISSIONER SEAMOUNT: It -- it seems if we were to take emergency action on certain wells, that it could involve frequent hearings to resolve. METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 17 MS. JACOBSON: Under 539? COMMISSIONER SEAMOIINT: Yes. MS. JACOBSON: Well, then I guess -- it sounds like you've already got that power under 539, so we -- we would have to live with that. COMMISSIONER SEAMOUNT: Okay. MR. ROSSBERG: I think the primary difference in the way we scribe the rule, is we wanted the latitude around other tests in addition to mechanical integrity testing. That was the main difference that we wanted to get into this. COMMISSIONER SEAMOUNT: Okay. COMMISSIONER RUEDRICH: While you're at that point, let me follow on that. What other means of testing well integrity does BP consider to be definitive for mechanical integrity? MR. ROSSBERG: Okay. First of all, we use mechanical integrity testing in the normal course of our operations a lot. Testing the surface casing annulus is normally done with mechanical integrity testing, as also is the inner annulus, but when it comes to testing the tubing, mechanical integrity testing may always not be the most reliable means available to us, and that's ..... COMMISSIONER RUEDRICH: And why might that be? MR. ROSSBERG: ..... primarily due to once a METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 275-3876 10 11 12 13 14 15 16 17 18 19 2O 21 22 23' 24 25 18 well is on line and produced, you know, it tends to form scales sometimes, produce solids, things that may inhibit setting test plugs. We've got a high frequency of leak by in our test plugs. There are also other potential leak paths in the wells, gas lift designs, so mechanical integrity isn't that reliable of a means to certify the tubing as a barrier. I think what -- you have to accept the fact that there is some pressure communication from the tubing to the annulus in some wells. You can think about this, a good analogy, I think is a fire extinguisher. You buy a fire extinguisher when it's brand new, the pressure arrow is over in the green and you let it sit there for a year and a half and it tells you that, hey, the pressure in that fire extinguisher has gone down. So, pressure one-way leaks are possible. So, the methods that we prescribe to use in some cases are ways to certify that tubing as a practical barrier. We do -- we shoot fluid levels on the inner annulus, we'll shut the well in, shoot fluid levels and take pressures on the inner annulus to see if there is a fluid level response or a pressure response, which would indicate that you may not have a barrier. The other method we use is a no-flow test on the inner annulus where we'll actually rig up a kind of a household variety gas meter, it's designed to measure gas at a very low rate. And our threshold in that case is 900 standard cubic METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-$876 10 11 12 13 14 15 16 17 18 19 2O 21 22 23 24 25 19 feet per hour, which corresponds to the MMS regulations around a passing subsurface safety value test. So, what we're asking is that other options be allowed, other than just straight mechanical integrity testing. COMMISSIONER RUEDRICH: Well, under those type of thoughts, what is an example of well operating conditions that would actually result in a well being removed from service by BP at this time? MR. ROSSBERG: Being removed from service? COMMISSIONER RUEDRICH: Right. Shut-in, made safe. MR. ROSSBERG: If we have a good -- a good example would be a well with a tubing leak. If we've got a flowing well with a tubing leak, we will shut the well in until -- we will actually safe the well out until we can repair the tubing, either patch it or replace it with a rig work over. That's one example. COMMISSIONER RUEDRICH: Okay. In the situation where we already know we have a tubing -- tubing packer or pack-off problem; i.e., we have a frequent need to bleed the inner annulus, what conditions would put you to the point of looking at your casing strings and shutting the well in due to the deterioration of the well? MR. ROSSBERG: If -- well, on a flowing well, METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 10 11 12 13 14 15 16 17 18 19 2O 21 22 23 24 25 2O if we've got sustained inner annulus pressure that indicates that the packer of the tubing or the wellhead seals are leaking and incompetent, we have to shut the well in. We would in that case. COMMISSIONER RUEDRICH: Having looked at the testimony in the November hearing and listening to your discussions now, the discussion of two or fewer bleeds per week is prevalently discussed, what is the technical basis for that? MR. ROSSBERG: Well, the main issue around allowing us to bleed, actually there's several; one, we need to be able to bleed wells just to operate, simply to start up a well ..... COMMISSIONER RUEDRICH: I understand. MR. ROSSBERG: ..... we have to bleed. When you've got a well that develops outer annulus pressure, our threshold is a 1000 pounds, and we ask that the operators report any well that cannot be kept below that pressure with two or fewer bleeds per week. If the bleed frequency is consistently two bleeds per week, we recognize that as a problem; that well would then enter the well integrity system and we would probably waiver it to a higher pressure. So, the bleeding provides two things; it allows us to operate quote unquote, "normal wells", and it also gives us a feel for what sort of problem the well is presenting. So, if METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 10 11 12 13 14 15 16 17 18 19 2O 21 22 23 24 25 21 this bleeding becomes burdensome to the operator, it will be reported very quickly. COMMISSIONER RUEDRICH: Okay. Okay. That restates much of what your prior record has already indicated in our operational considerations. My question was, what are the technical justifications for the two bleeds per week rather than one or three or any other combination of logic? MR. ROSSBERG: It's been -- rather than appear technical, you know, prescription, it's been more of a evolving operating practice over the years. This practice has come to play through 20 plus years of operating the wells on the slope. So, it's developed over time. COMMISSIONER RUEDRICH: Okay. Going back to Rule 3 as you proposed, you indicate that this would result in a significant increased burden, confusion and potential hazards to the pad operator. I find that to be a very difficult concept to get my arms around. Since the operator is going to be doing the same thing, regardless what the rule is, he is going to be reading a pressure gauge, right? MR. ROSSBERG: That's right. They read -- these operators -- first of all, our safety systems today are based solely on administrative controls. In order for administrative controls to work, the key element is people have to follow those controls. COMMISSIONER RUEDRICH: I understand that. METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-$876 10 11 12 13 14 15 16 17 18 19 2O 21 22 23 24 25 22 MR. ROSSBERG: They have to understand and follow them. So, where the confusion may come into play, if we have percentages and a different pressure limit on each well, it will be less well understood by the operators and we think, you know, result in a higher likelihood that we would miss a threshold pressure. COMMISSIONER RUEDRICH: But let me reflect on what you've said, and I what I posed initially. The operator is just collecting the data; the operator is not the ultimate decision maker in this process? MR. ROSSBERG: That's correct. COMMISSIONER RUEDRICH: So, that from a technological standpoint, the technology exists without difficulty in any database to identify what the mechanical integrity of the well individually is, the casing specifications themselves, and then ultimately the percentage numbers. And you would be strictly looking at a comparison in the data management system, which is a technical item, would be developing the response that there is a problem, not the operator, is that correct? MR. ROSSBERG: Yeah, that's correct. I think that the issue is, we've got 1500 wells to manage up there and if we go with percentages, you -- the result would be many different threshold pressures that we would have to track. I mean, over the years we've got at least six generations of METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 10 11 12 13 14 15 16 17 18 19 2O 21 22 23 24 25 23 casing design, well bore design up there, that you would have slightly different threshold pressures for. It would make it more difficult, I think, to identify a well that exceeds a specific threshold versus the consistent 1000 and 2000 pounds. COMMISSIONER RUEDRICH: Okay. If that's the case, what is the technical basis for your 1000 and 2000 and 2500 psi numbers, because somewhere we have to have something that has a technical basis rather than an oper- -- the operational principles that you're working with came from somewhere ..... MR. ROSSBERG: Okay. COMMISSIONER RUEDRICH: ..... they revolved from some basis, what might that be? MR. ROSSBERG: You know, there is a sound technical justification for the 1000 and 2000, the numbers are engineered, they provide an ample safety factor and are well within the operating range of all of our casing designs on the slope. The second thing is that they provide an ample amount of differential between the inner annulus and outer annulus, so that a potential problem can be identified. Thirdly, at Prudhoe Bay and Lisburne, we've got some of the highest gas lift pressures in the world. Those systems run at 2000 pounds and 2500 pounds respectively. Typical gas lift pressures are in the eight to 1200 pound range. So, we METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 10 11 12 13 14 15 16 17 18 19 2O 21 22 23 24 25 24 do need some latitude on the pressure. And I think the fourth point that I -- I'll make it again, is that it's consistent and well understood by the operation staff and is an important element in our administrative controls. COMMISSIONER RUEDRICH: Let me go back to one thing that you discussed much earlier, and it was also in the November 14th material. You talk about testing the outer annulus, verifying its pressure integrity, and as I recollect, the testimony indicated that there was a -- if the annular spaces did not hold pressure, the outer annuli, they were then worked over to seal, that was then corrected in the testimony, but we never reached closure on what you do with a well that doesn't hold pressure on the annulus, you have no way to verify its annular integrity, do you? And it would simply -- if the production casing is leaking and the casing shoe is not sealed, which is the case with many of the wells in Prudhoe Bay, you have no knowledge then at all of what that annulus is doing, and if you have a casing leak, what is the situation? MR. ROSSBERG: Okay. The premise of our policy around whether a well is produced or not is very simple; in order to produce any well at Prudhoe you need two barriers, one of which must be the tubing. So to test the competency of the outer annulus, we do an MIT on that annulus to 1.2 times the maximum anticipated pressure. So, on a METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 25 typical gas lift well, it's about 2400 pounds, a flowing well it's close to 3000. If we rig up on that annulus and pump into it and it pumps away, we don't waiver that well, That well will go under closer engineering study. If appropriate, we may decide to cement squeeze the shoe and attempt to MIT that annulus again. COMMISSIONER RUEDRICH: Have you as yet, done such an operation? MR. ROSSBERG: Yes, sir. It's actually quite routine. COMMISSIONER RUEDRICH: Okay. How many times per year in the last five years would you say it might have happened? MR. ROSSBERG: It's been more in the last year. We have certainly done in the neighborhood of 25 to 30 jobs like that. I can get you the specific number. COMMISSIONER RUEDRICH: Okay. I'd appreciate that. that. MR. ROSSBERG: That's an estimate. I'll do CHAIR PALIN: Okay. More questions? COMMISSIONER RUEDRICH: I think I'd probably like to take a brief recess and review what text I have and if we have any additional items. CHAIR PALIN: Okay. Mr. Seamount, do you kave METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 10 11 12 13 14 15 16 17 18 19 2O 21 22 23 24 25 26 any questions before we take another break? COMMISSIONER SEAMOUNT: No, I don't. CHAIR PALIN: Okay. We're going to go off the record and take another break. (Off record) (On record) CHAIR PALIN: Back on the record then. We do have a few additional questions. Commissioner Ruedrich? COMMISSIONER RUEDRICH: Yes. Mr. Rossberg, in the original testimony, BP indicated that clearly rules needed to be flexible and adjustable for situations. I recollect the term, one size does not fit all. MR. ROSSBERG: Yes, sir. COMMISSIONER RUEDRICH: In an attempt to do this regulation, we wrote a rule that allows you to be very flexible. Why the change of heart? MR. ROSSBERG: I don't believe there is a change of heart. I think that the need for flexibility around any rules was in reference to the difference, let's say, between the wells in Prudhoe Bay and the wells at Milne Point or Kupurak or North Star, that there are differences. And I think what we're talking about here today, the Commission's desire to be flexible around trigger pressures is a concern to us because we do view the operator as the first line of defense in well integrity. We want there to be a very clear METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 10 11 12 13 14 15 16 17 18 19 2O 21 22 23 24' 25 27 understandable and consistent trigger pressure when that operator knows that he has to report it. One thing that I think I should clear up is that we require the operators to read the pressures daily, but that data is recorded equally, so if the operator sees a pressure spike above 1000 or 2000, we want that individual to notify the well integrity engineer. And these numbers are ingrained in the work force. COMMISSIONER RUEDRICH: So, for Prudhoe Bay where you were given annular space, you would obviously have, as you point out, four, five or six potential results in calculations. And in the same sense of simple mathematics, one of those will be the lowest number, and I believe our rule was developed to allow you to have your operating criteria as the acceptable lowest number. So, I don't think we have a problem in what we presented, but we will reflect on your observation. MR. ROSSBERG: Okay. I think that the final point I would make on that is, we may have four, five or six different wells designs on any given pad, so ..... COMMISSIONER RUEDRICH: Well; what our rule does is allow you, if you have a well that has a higher mechanical integrity, if it defaults on a standard, lowest, common denominator basis, to still conform if its own integrity is -- design integrity is higher. We were trying to METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-$876 10 11 12 13 14 15 16 17 18 19 2O 21 22 23 24 25 28 be constructively helpful on this process, and hopefully you can find that is a useful aspect of what we've proposed. MR. ROSSBERG: Okay. CHAIR PALIN: Okay. Any questions? COMMISSIONER SEAMOUNT: No further questions. COMMISSIONER RUEDRICH: We have two items that we're looking forward to receiving then, is that correct? One is the -- how your rule complies, and the other is on wells that have received valve squeeze cement jobs? MR. ROSSBERG: Yes, sir. COMMISSIONER RUEDRICH: And could we have those by next Tuesday, let's say? MR. ROSSBERG: That should not be a problem. We'll have those by Tuesday of next week. CHAIR PALIN: Okay. Then we thank you, Mr. Rossberg. Thank you. MR. ROSSBERG: Thank you. CHAIR PALIN: Again, my sign-up sheet indicates no other persons wishing to testify; however, I will ask if anyone wishes to make a statement or to testify, you're welcome to come forward. Okay. Hearing and seeing no one ..... COMMISSIONER RUEDRICH: I'm sorry, Counsel CHAIR PALIN: Oh, Mr. Herzog? METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-$876 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 29 MR. HERZOG: If you could just mention that the record will be held open until next Tuesday? CHAIR PALIN: I sure will do that, yes. Okay. This record will remain open until Tuesday, June 3rd, until the supplemental comments and information has been received and addressed by this Commission, and then we will close the record. Unless there are no other questions or comments from the Commissioners, okay, today's meeting is adjourned. Off the record. (Off record) * * * END OF PROCEEDINGS * * * METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 ( 10 11 12 13 14 15 16 17 18 i9 2O 21 22 23 24 25 3O CERTIFICATE SUPERIOR COURT STATE OF ALASKA I, Candice A. Bagoy, hereby certify that Janice S. Scott, Notary Public in and for the State of Alaska certifies: THAT the annexed and foregoing pages numbered 2 through 29 contain a full, true and correct transcript of the Public Hearing before the Alaska Oil and Gas Conservation Commission, taken by Janice S. Scott and transcribed by Janice S. Scott: THAT the Transcript has been prepared at the request of the Alaska Oil and Gas Conservation Commission, 333 West Seventh Avenue, Anchorage, Alaska, DATED at Anchorage, Alaska this 29th day of May, 2003. SIGNED AND CERTIFIED TO BY: Candice A. Bagoy <~ //' Notary in and for Alaska ~/ I My Commission Expires: 6/30/04 METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 #9 DV Depth 2605 Ann. Factor 0.3262 0,00035 P1 1900 Cmt Depth 2206 DI (A.P.) 85 T1 40 AT 1 1.5 2 2.5 3 3.5 4 4.5 5 5.5 6 6.5 7 7.5 8 8.5 9 9.5 10 10.5 11 11.5 12 12.5 13 13.5 14 14.5 15 15.5 16 16.5 17 17.5 18 18.5 19 19.5 20 20.5 21 21.5 22 22.5 23 23.5 24 24.5 25 25.5 26 26.5 27 27.5 28 28.5 29 V1 (A.P.) 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 AV (A.P.) 0 0 0 1 1 1 1 1 1 1 1 2 2 2 2 2 2 2 2 3 3 3 3 3 3 3 3 4 4 4 4 4 4 4 4 4 5 5 5 5 5 5 5 5 6 6 6 6 6 6 6 6 7 7 7 7 7 v2 (A.P.) 692 692 692 692 693 693 693 693 693 693 693 693 694 694 694 694 694 694 694 694 695 695 695 695 695 695 695 695 696 696 696 696 696 696 696 696 696 697 697 697 697 697 697 697 697 698 698 698 698 698 698 698 698 699 699 699 699 D2 (A.P.) 84 84 84 83 83 82 82 82 81 81 81 80 80 79 79 79 78 78 78 77 77 76 76 76 75 75 75 74 74 73 73 73 72 72 72 71 71 71 70 70 69 69 69 68 68 68 67 67 66 66 66 65 65 65 64 64 63 Vl (gas) 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 V2 (gas) 27 27 27 27 27 27 27 27 27 26 26 26 26 26 26 26 26 25 25 25 25 25 25 25 25 24 24 24 24 24 24 24 24 23 23 23 23 23 23 23 23 23 22 22 22 22 22 22 22 22 21 21 21 21 21 21 21 P2 (gas) 1921 1931 1942 1952 1963 1974 1985 1996 2007 2018 2029 2041 2052 2064 2075 2087 2099 2111 2123 2136 2148 2161 2173 2186 2199 2212 2225 2239 2252 2266 2279 2293 2307 2321 2336 2350 2365 2379 2394 2409 2424 2440 2455 2471 2487 2503 2519 2536 2552 2569 2586 2603 2621 2638 2656 2674 2692 29.5 3O 30.5 31 31.5 32 32.5 33 33.5 34 34.5 35 35.5 36 36.5 37 37.5 38 38.5 39 39.5 40 40.5 41 41.5 42 42.5 43 43.5 44 44.5 45 45.5 46 46.5 47 47.5 48 48.5 49 49.5 50 50.5 51 51.5 52 52.5 53 53.5 54 54.5 55 55.5 56 56.5 57 57.5 58 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 7 7 7 8 8 8 8 8 8 8 8 8 9 9 9 9 9 9 9 9 10 10 10 10 10 10 10 10 11 11 11 11 11 11 11 11 12 12 12 12 12 12 12 12 12 13 13 13 13 13 13 13 13 14 14 14 14 14 699 699 699 699 699 700 700 700 700 700 700 700 700 701 701 701 701 701 701 701 701 702 702 702 702 702 702 702 702 703 703 703 703 703 703 703 703 703 704 704 704 704 704 704 704 704 705 705 705 705 705 705 705 705 706 706 706 706 63 63 62 62 62 61 61 61 6O 6O 59 59 59 58 58 58 57 57 56 56 56 55 55 55 54 54 53 53 53 52 52 52 51 51 50 50 50 49 49 49 48 48 48 47 47 46 46 46 45 45 45 44 44 43 43 43 42 42 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 21 2O 2O 2O 2O 2O 2O 2O 2O 19 19 19 19 19 19 19 19 19 18 18 18 18 18 18 18 18 17 17 17 17 17 17 17 17 16 16 16 16 16 16 16 16 15 15 15 15 15 15 15 15 15 14 14 14 14 14 14 14 2710 2729 2748 2767 2786 2806 2825 2845 2866 2886 2907 2928 2949 2971 2993 3015 3037 3060 3083 3106 3130 3154 3178 3203 3227 3253 3278 3304 3331 3357 3384 3412 3440 3468 3497 3526 3555 3585 3616 3647 3678 3710 3743 3775 3809 3843 3877 3912 3948 3984 4021 4058 4097 4135 4175 4215 4256 4297 58.5 59 59.5 6O 60.5 61 61.5 62 62.5 63 63.5 64 64.5 65 65.5 66 66.5 67 67.5 68 68.5 69 69.5 70 70.5 71 71.5 72 72.5 73 73.5 74 74.5 75 75.5 76 76.5 77 77.5 78 78.5 79 79.5 80 80.5 81 81.5 82 82.5 83 83.5 84 84.5 85 85.5 86 86.5 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 692 14 14 14 15 15 15 15 15 15 15 15 15 16 16 16 16 16 16 16 16 17 17 17 17 17 17 17 17 18 18 18 18 18 18 18 18 19 19 19 19 19 19 19 19 19 20 20 20 20 20 20 20 20 21 21 21 21 706 706 706 706 707 707 707 707 707 707 707 707 707 708 708 708 708 708 708 708 708 709 709 709 709 709 709 709 709 710 710 710 710 710 710 710 710 711 711 711 711 711 711 711 711 711 712 712 712 712 712 712 712 712 713 713 713 42 41 41 40 40 40 39 39 39 38 38 37 37 37 36 36 36 35 35 35 34 34 33 33 33 32 32 32 31 31 30 30 30 29 29 29 28 28 27 27 27 26 26 26 25 25 24 24 24 23 23 23 22 22 22 21 21 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 14 13 13 13 13 13 13 13 13 12 12 12 12 12 12 12 12 12 11 11 11 11 11 11 11 11 10 10 10 10 10 10 10 10 9 9 9 9 9 9 9 9 8 8 8 8 8 8 8 8 8 7 7 7 7 7 7 4339 4382 4426 4471 4516 4562 4610 4658 4707 4756 4807 4859 4912 4966 5021 5078 5135 5194 5254 5315 5377 5441 5506 5573 5641 5711 5783 5856 5931 6007 6086 6166 6249 6334 6420 6509 6601 6695 6791 6890 6992 7096 7204 7315 7429 7546 7667 7791 7920 8053 8189 8331 8477 8628 8784 8946 9113 Annular Pressure as a Function of Temp. Change 1900 psi Initial Pressure 8oo0 7000 6000 5OOO · -, 4000 L- 3000 2000 IOO0 0 10 20 30 40 50 60 70 80 90 Delta T, deg. F #8 Proposed Annular Pressure Rule for Development Wells in all Pools within the Prudhoe Bay Unit STATE OF ALASKA Alaska Oil and Gas Conservation Commission 1. The operator shall conduct and document a pressure test of tubulars and completion equipment in each development well at the time of installation or replacement that is sufficient to demonstrate that the planned development well operations will not result in failure of well integrity, uncontrolled release of fluid or pressure, or threat to human safety. 2. Each development well must be monitored daily to check for sustained pressure, except as prevented by weather conditions, emergency situations or similar circumstances. 3. The operator must notify the commission within three working days after the operator identifies a development well as having sustained pressure. 4. The commission may require the operator to submit a proposal for corrective action or increased surveillance for any development well identified as having sustained pressure. After reviewing the proposal, the commission may require corrective action and verification by mechanical integrity testing, or other diagnostic tests, and that the commission be given sufficient notice of the testing schedule. 5. If the operator identifies sustained pressure in the inner annulus pressure of a development well in excess of 3000 psig or sustained pressure in the outer annulus of a development well in excess of 2000 psig, the operator must notify the commission within three working days and take appropriate action to prevent an uncontrolled release of fluid or pressure, or threat to human safety. 6. Before a shut-in development well is placed in service, any annulus pressure must be relieved to a sufficient degree that the inner annulus pressure at operating temperature will be below 2500 psig for wells processed through the Lisburne Production Center and 2,000 psig for all other Prudhoe Bay development wells, and the outer annulus pressure at operating temperature will be below 1000 psig. 7. The commission may, by emergency action, require a development well to be shut-in until the operator takes commission-approved corrective action, as provided under 20 AAC 25.539. The commission may require that any corrective action be verified by mechanical integrity testing or other means, and may require that the commission be given sufficient notice of the testing schedule. RECEIVED MAY ~ ? 2003 Alaska Oil & Gas Cons. Commission Anchorage Definitions "inner annulus" means the space in a well between tubing and production casing. "outer annulus" means the space in a well between the production casing and surface casing. "sustained pressure" means pressure that: 1. is measurable at the casing head of an annulus, 2. is not caused solely by temperature fluctuations, 3. is not pressure that has been applied through artificial lift operations, and 4. cannot be consistently maintained under the following limits with two or fewer bleeds per week: · inner annulus: 2500 psig for wells processed through the Lisburne Production Center and 2,000 psig for all other Prudhoe Bay development wells · outer annulus: 1000 psig. Prudhoe Bay AOGCC Public Hearing May 27, 2003 Steve Rossberg Prudhoe Bay Wells Manager RECEIVED MAY 2 7 2003 Alaska Oil & Gas Cons. Commission Anchorage Good morning, my name is Steve Rossberg. I am the Prudhoe Bay Wells Manager for BP Exploration (Alaska) Inc (BP). BP is the operator of the Prudhoe Bay Field. I am presenting testimony on behalf of BP, the operator of the Prudhoe Bay Field, and the other Working Interest Owners regarding the Corrected Notice of Public Hearing for proposed rules governing annular pressures in Prudhoe Bay Field development wells. I would now like to be sworn and qualified as a well operations expert witness at this time. (Administration of Oath) I received a Bachelor of Science Degree in Mechanical Engineering from Montana State University in 1982. Since then I have worked in Production and Drilling Engineering and Operations in several areas of the oil and gas business; including onshore and offshore operations, infield drilling, exploration drilling, remedial well work and production operations. Assignments have been primarily in the Rocky Mountain and Alaska regions. I have held engineering and operations positions in Milne Point and Prudhoe Bay. For the past six years I have managed BP's North Slope well operations, including well integrity, rig workovers and through tubing intervention. I have been a member of the Society of Petroleum Engineers for over 20 years. (Acceptance As Expert) My testimony this morning will focus on the Corrected Notice of Public Hearing regarding rules governing annular pressures in Prudhoe Bay development wells published April 17, 2003. I will address each item in the proposed rule, providing information to support BP's recommendations for the rule. I'll start with a brief review of sustained casing pressure. Annular pressure is possible in any well and develops from many causes. Creation of annular pressure is a normal result of production. In any sealed annulus, pressure will increase as a result of heating when warm reservoir fluids are produced through the tubulars. In addition to this phenomenon, annular pressure may result from leaks within a well bore. Many of these are small leaks in various equipment, such as wellhead seals, threaded connections and packers. Annular pressure in producing oil and gas wells is a common oil field occurrence that is managed as part of ongoing operations in Alaska and around the world. It is managed through administrative, operating, and engineering controls that are applied to well design, construction and well integrity management programs. The operations and integrity management systems are subject to review by BP management and non-operators, and are adjusted and improved as a normal part of operations. On November 14, 2002 BP presented testimony at the AOGCC hearing regarding annular pressures in Prudhoe Bay development wells. The testimony concluded that a new rule governing annular pressure is not necessary to address the associated risks. BP continues to believe that sustained casing pressures are appropriately addressed by its well integrity program parameters. However, if the commission decides to adopt a new rule governing annular pressure in development wells, we request that our recommendations contained in this testimony and in the record be taken into consideration. The commission published proposed rules for governing annular pressures in Prudhoe Bay development wells on April 17, 2003. BP and the other Prudhoe Bay co- owners believe the proposed rules outlined and discussed below will enhance the rule, minimize the possibility of misinterpretation, and allow more effective implementation. Before I address each rule, I would like to present several definitions that I will use in my testimony and that we propose be incorporated into any rule that the commission may decide to adopt to ensure clarity in the application of any rules in field operations and reporting: "inner annulus" means the space in a well between tubing and production casing. "outer annulus" means the space in a well between the production casing and surface casing. "sustained pressure" means pressure that: 1. is measurable at the casing head of an annulus, 2. is not caused solely by temperature fluctuations, 3. has not been applied through artificial lift operations, and 4. cannot be consistently maintained under the following limits with two or fewer bleeds per week: · inner annulus: 2500 psig for wells processed through the Lisburne Production Center and 2,000 psig for all other Prudhoe Bay development wells · outer annulus: 1000 psig. Discussion' The rules proposed by the commission did not include definitions. However, we believe they will help clarify the application of the Rule. The rationale for some aspects of these definitions is explained in my testimony in support of the specific rules that we propose. However, one aspect of the definitions should be explained at the outset. The definition of "sustained pressure" contains threshold pressures for the inner and outer annuli that are related to a bleed frequency. Due to the dynamic nature of temperatures and pressures in a development well, periodic bleeding is required to eliminate temporary impacts such as thermal pressure. Our experience has shown that two bleeds per week are sufficient to differentiate these temporary impacts from sustained pressure and to indicate the relative degree of severity of any leaks. In addition, our experience at Prudhoe Bay indicates that the threshold pressures referenced, given our well designs, allow safe operation of Prudhoe Bay development wells. Our experience shows that wells can be safely managed without undue additional measures when pressures can be maintained within reasonable limits with two or fewer bleeds per week. I will now discuss our recommendation for each rule. BP Recommended Language for Rule 1: 1. The operator shall conduct and document a pressure test of tubulars and completion equipment in each development well at the time of installation or replacement that is sufficient to demonstrate that the planned well operations will not result in failure of well integrity, uncontrolled release of fluid or pressure, or threat to human safety. Discussion: In BP operations, tubulars and completion equipment in all wells are pressure tested at the time of installation or replacement to demonstrate integrity. Monitoring and surveillance programs ensure that integrity will be maintained. We believe the rule we propose is more specific and provides the protection intended by the rule as proposed by the commission. BP Recommended Languaqe for Rule 2: 2. Each development well must be monitored daily to check for sustained pressure, except as prevented by weather conditions, emergency situations or similar circumstances. Discussion: In BP operations, all development wells are monitored on a daily basis to check for sustained annular pressure as part of our comprehensive operational integrity system. However, certain circumstances, including weather conditions and emergency situations may prevent the pad operator from fulfilling this expectation. Our proposal acknowledges the unusual circumstances when it is not safe or not feasible to monitor a well on a daily basis. BP Recommended Language for Rule 3: 3. The operator must notify the commission within three working days after the operator identifies a well as having sustained pressure. Discussion: As noted at the outset of my testimony, our proposed definition of the term "sustained pressure" includes specific pressure limits. These values provide an ample safety factor, apply to all wells uniformly, have proven to be effective in practice, and are fully understood by operations staff. The rule as proposed by the commission would impose limits calculated as a percentage of casing burst pressure, which would result in many different trigger pressures. This would result in significantly increased burden, confusion and potential hazards to the pad operator. BP Recommended Lanqua_qe for Rule 4 4. The commission may require the operator to submit a proposal for corrective action or increased surveillance for any development well identified as having sustained pressure. After reviewing the proposal, the commission may require corrective action and verification by mechanical integrity testing, or other diagnostic tests, and that the commission be given sufficient notice of the testing schedule. Discussion: While mechanical integrity tests may be appropriate to verify corrective actions in some instances, other diagnostic tests may be more suitable for given well conditions. Other recognized diagnostic tests include no-flow tests, leak rate tests, fluid levels and certain logs. Each test can provide data that will assist in diagnosing whether a well is safe to operate. BP Recommended Language for Rule 5 5. If the operator identifies sustained pressure in the inner annulus of a development well in excess of 3000 psig or sustained pressure in the outer annulus pressure of a development well in excess of 2000 psig, the operator must notify the commission within three working days and take appropriate action to prevent an uncontrolled release of fluid or pressure, or threat to human safety. Discussion: We have taken the intent of the commission's Rules 5 and 6 and combined them into one proposed rule. Specific limits, as opposed to percentages, are recommended for reasons previously discussed. These limits closely approximate 45% of burst as proposed by the commission. If the limits are exceeded, appropriate action will be taken to secure the well. BP Recommended Language for Rule 6 6. Before a shut-in development well is placed in service, any annulus pressure must be relieved to a sufficient degree that the inner annulus pressure at operating temperature will be below 2500 psig for wells processed through the Lisburne Production Center and 2000 psig for all other Prudhoe Bay development wells, and the outer annulus pressure at operating temperature will be below 1000 psig. Discussion: This corresponds to the commission's proposed Rule 7. BP Recommended Language for Rule 7 7. The commission may, by emergency action, require a development well to be shut-in until the operator takes commission-approved corrective action, as provided under 20 AAC 25.539. The commission may require that any corrective action be verified by mechanical integrity testing or other means, and may require that the commission be given sufficient notice of the testing schedule. Discussion: This corresponds to the commission's proposed Rule 8. We agree with the intent of the proposed rule and have added language from the current commission regulations to clarify the applicable procedures. We have already addressed the appropriateness of retaining the option to apply diagnostic testing in addition to mechanical integrity testing. We appreciate the opportunity to provide these comments today, and look forward to working with you to address annular pressure issues at Prudhoe Bay. I welcome any questions you may have. #7 STATE OF ALASKA OIL AND GAS CONSERVATION COMMISSION Rules Governing Annular Pressure in Prudhoe Bay DATE: May 27, 2003 TIME: 9:00 am NAME - AFFILIATION (PLEASE PRINT) ADDRESS/PHONE NUMBER TESTIFY (Yes or No) 2.(..¢--05W,-C ~ 5'b q-q l ,~ f ,,A~o XMeeting Sign-In #6 05/23/2003 15:52 FAX 907 564 4040 bp EXPLORATION ~001 Date: TO: Name: TELECOPY COMMUNICATIONS CENTER RECEIVED · ~IAY 2, 3 ~O0'j ,Company:. Loc<~tion: Fax # Confirm # FROM: Name & Ext.: Department: PAGES TO FOLLOW (Does Not Include Cover Sheet) SECURITY CLASSIFICATION PRIVATE SECRET CONFIDENTIAL Telecopy # 564-4637 Confirm # 564-5823 05/23/2003 15:53 FAX 907 564 4040 ... bp EXPLORATION ~002 WORKING DRAFT Prudhoe Bay AOGCC Public Hearing May 27, 2003 Steve Rossberg Prudhoe Bay Wells Manager Good morning, my name is Steve Rossberg. I am the Prudhoe Bay Wells .Manager for BP Exploration (Alaska) Inc (BP). BP is the operator of the Prudhoe Bay Field. I am presenting testimony on behalf of BP, the operator of the Prudhoe Bay Field, and the other Working Interest Owners regarding the Corrected Notice of Public Hearing for proposed rules governing annular pressures in Prudhoe Bay Field development wells. I would now like to be sworn and qualified as a well operations expert witness at this time. (Administration of Oath) I received a Bachelor of Science Degree in Mechanical Engineering from Montana State University in 1982. Since then I have worked in Production and Drilling Engineering and Operations in several areas of the oil and gas business; including onshore and offshore operations, infield drilling, exploration drilling, remedial well work and production operations. Assignments have been primarily in the Rocky Mountain and Alaska regions. I have held engineering and operations positions in Milne Point and Prudhoe Bay. For the past six years I have managed BP's North Slope well operations, including well integrity, rig workovers and through tubing intervention. I have been a member of the Society of Petroleum Engineers for over 20 years. (Acceptance As Expert) My testimony this morning will focus on the Corrected Notice of Public Hearing regarding rules governing annular pressures in Prudhoe Bay development wells published April 17, 2003. I will address each item in the proposed rule, providing information to support BP's recommendations for the rule. I'll start with a brief review of sustained casing pressure. Annular pressure is possible in any well and develops from many causes. Creation of annular pressure is a normal result of production. In any sealed annulus, pressure will increase as a result of heating when warm reservoir fluids are produced through the tubulars. In addition to this phenomenon, annular pressure may re, sult 05/23/2003 15:53 FAX 907 564 4040 ., bp EXPLORATION ~003 from leaks within a well bore. Many of these are small leaks in various equipment, such as wellhead seals, threaded connections and packers. Annular pressure in producing oil and gas wel~s is a common oil field occurrence that is managed as part of ongoing operations in Alaska and around the world. It is managed through administrative, operating, and engineering controls that are applied to well design, construction and well integrity management programs. The operations and integrity management systems are subject to review by BP management and non-operators, and are adjusted and improved as a normal part of operations. On November 14, 2002 BP presented testimony at the AOGCC hearing regarding annular pressures in Prudhoe Bay development wells. The testimony concluded that a new rule governing annular pressure is not necessary to address the associated risks. BP continues to believe that sustained casing pressures are appropriately addressed by its well integrity program parameters. However, if the commission decides to adopt a new rule governing annular pressure in development wells, we request that our recommendations contained in this testimony and in the record be taken into consideration. The commission published proposed rules for governing annular pressures in Prudhoe Bay development wells on April 17, 2003. BP and the other Prudhoe Bay co- owners believe the proposed rules outlined and discussed below will enhanc~,~ the rule, minimize the possibility of misinterpretation, and allow more effective implementation. Before I address each rule, I would like to present several definitions that I will use in my testimony and that we propose be incorporated into any rule that the commission may decide to adopt to ensure clarity in the application of any rull,~s in field operations and reporting: "inner annulus" means the space in a well between tubing and production casing. "outer annulus" means the space in a well between the production casing and surface casing. "sustained pressure" means pressure that: 1. is measurable at the casing head of an annulus, 2. is not caused solely by temperature fluctuations, 3. has not been applied through artificial lift operations, and 4. cannot be consistently maintained under the following limits with two or fewer bleeds per week: · inner annulus: 2500 psig for wells process~.~;d through the Lisburne Production Center anc[ 2,000 psig for al~ other Prudhoe Bay development wells · outer annulus: 1000 psig. 05/23/2003 15:54 FAX 907 564 4040 _ bp EXPLORATION ~004 Discussion: The rules proposed by the commission did not include definitions. However, we believe they will help clarify the application of the Rule. The rationale for some aspects of these definitions is explained in my testimony in support of the specific rules that we propose. However, one aspect of the definitions should be explained at the outset. The definition of "sustained pressure" contains threshold pressures for the inner and outer annuli that are related to a bleed frequency. Due to the dynamic nature of temperatures and pressures in a development well, periodic bleeding is required to eliminate temporary impacts such as thermal pressure. Our experience has shown that two bleeds per week are sufficient to differentiate these teml.~orary impacts from sustained pressure and to indicate the relative degree of severity of any leaks. In addition, our experience at Prudhoe Bay indicates that the threshold pressures referenced, given our well designs, allow safe operation of Prudhoe Bay development wells. Our experience shows that wells can be safely managed without undue .additional measures when pressures can be maintained within reason.able limits with two or fewer bleeds per week. l will now discuss our recommendation for each rule. BP Recommended Lanpua~e for Rule 1: 1. The operator shall conduct and document a pressure test of tubullars and completion equipment in each development well at the time of installation or replacement that is sufficient to demonstrate that llhe planned well operations will not result in failure of well integrity, uncontrolled release of fluid or pressure, or threat to human safety. Discussion: In BP operations, tubulars and completion equipment in all wells are pressure tested at the time of installation or replacement to demonstrate integrity. Monitoring and surveillance programs ensure that integrity will be maintained. We believe the rule we propose is more specific and provides the protection intended by the rule as proposed by the commission. , BP Recommended Language for Rule 2: 2. Each development well must be monitored daily to check for sustained pressure, except as prevented by weather conditions, emergency situations or similar circumstances. Discussion: In BP operations, all development wells are monitored on a daily basis to check for sustained annular pressure as part of our comprehensive operational integrity system. However, certain circumstances, including weather conditions and emergency situations may prevent the pad operator from fulfilling this expectation. Our proposal acknowledges the unusual circumstances when it is not safe or not feasible to monitor a well on a daily basis. BP Recommended Lan~luage for Rule 3: 05/23/2003 15:55 FAX 907 564 4040 bp EXPLORATION ~005 3. The operator must notify the commission within three working days after the operator identifies a well as having sustained pressure. Discussion: As noted at the outset of my testimony, our proposed definition of the term "sustained pressure" includes specific pressure limits. These values provide an ample safety factor, apply to alt wells uniformly, have proven to be effective in practice, and are fully understood by operations staff. The rule as proposed by the commission would impose limits calculated as a percentage of casing burst pressure, which would result in many different trigger pressures. This would result in significantly increased burden, confusion and potential hazards to the pad operator. BP Recommended Langua_~e for Rule 4 4. The commission may require the operator to submit a proposal for corrective action or increased surveillance for any development well identified as having sustained pressure. After reviewing the proposall, the commission may require corrective action and verification by mechanical integrity testing, or other diagnostic tests, and that the commission be given sufficient notice of the testing schedule. Discussion: While mechanical integrity tests may be appropriate to verify corrective actions in some instances, other diagnostic tests may be more sui'Iable for given well conditions. Other recognized diagnostic tests include no-flow tests, leak rate tests, fluid levels and certain logs. Each test can provide data that will assist in diagnosing whether a well is. safe to operate. BP Recommended Lan~uafle for Rule 5 . If the operator identifies sustained pressure in the inner annulus (>f a development well in excess of 3000 psig or sustained pressure in the outer annulus pressure of a development well in excess of 2000 psig, the operator must notify the commission within three working days and take appropriate action to prevent an uncontrolled release of fluid or pressure, or threat to human safety. Discussion: We have taken the intent of the commission's Rules 5 and 6 and combined them into one proposed rule. Specific limits, as opposed to percen, tages, are recommended for reasons previously discussed. These limits closely approximate 45% of burst as proposed by the commission. If the limits are exceeded, appropriate action will be taken to secure the well. BP Recommended Language for Rule 6 6. Before a shut-in development well is placed in service, any annulus pressure must be relieved to a sufficient degree that the inner ann. ulus pressure at operating temperature will be below 2500 psig for we~lls 05/23/2003 15:56 FAX 907 564 4040 bp EXPLORATION ~006 processed through the Lisburne Production Center and 2000 psig for all other Prudhoe Bay development wells, and the outer annulus pre~sure at operating temperature will be below 1000 psig. Discussion: This corresponds to the commission's proposed Rule 7. BP Recommended Lan_~uape for Rule 7 7. The commission may, by emergency action, require a developmen~t well to be shut-in until the operator takes commission-approved corrective action, as provided under 20 AAC 25.539. The commission may require that any corrective action be verified by mechanical integrity testing or other means, and may require that the commission be given sufficient notice of the testing schedule. Discussion: This corresponds to the commission's proposed Rule 8. We agree with the intent of the proposed rule and have added language from the currer~t commission regulations to clarify the applicable procedures. We have already addressed the appropriateness of retaining the option to apply diagnostic testing in addition to mechanical integrity testing. We appreciate the opportunity to provide these comments today, and look, forward to working with you to address annular pressure issues at Prudhoe Bay. I welcome any questions you may have. 05/23/2003 15:56 FAX 907 564 4040 bp EXPLORATION ~007 WORKING DRAFT Proposed Annular Pressure Rule for Development Wells in all Pools within the Prudhoe Bay Unit STATE OF ALASKA Alaska Oil and Gas Conservation Commission 1. The operator shall conduct and document a pressure test of tubulars and completion equipment in each development well at the time of installation or replacement that is sufficient to demonstrate that the planned development well operations will not result in failure of well integrity, uncontrolled release of fluid or pressure, or threat to human safety. 2. Each development well must be monitored daily to check for sustained pressure, except as prevented by weather conditions, emergency situations or similar circumstances. 3. The operator must notify the commission within three working days after the operator identifies a development well as having sustained pressure. 4. The commission may require the operator to submit a proposal for con;ective action or increased surveillance for any development well identified as having sustained pressure. After reviewing the proposal, the commission may require corrective action and verification by mechanical integrity testing, or other diagnostic tests, and that the commission be given sufficient notice of the testing schedule. 5. If the operator identifies sustained pressure in the inner annulus pressure of a development well in excess of 3000 psig or sustained pressure in the outer annulus of a development well in excess of 2000 psig, the operator must notify the commission within three working days and take appropriate action to prevent an uncontrolled release of fluid or pressure, or threat to human safety. 6. Before a shut-in development well is placed in service, any annulus pressure must be relieved to a sufficient degree that the inner annulus pressure at operating temperature will be below 2500 psig for wells processed through the Lisburne Production Center and 2,000 psig for all other Prudhoe Bay development wells, and the outer annulus pressure at operating temperature will be below 1000 psig. 7. The commission may, by emergency action, require a development well to be shut-in until the operator takes commission-approved corrective action, as provided under 20 AAC 25.539. The commission may require that any corrective actior~ be verified by mechanical integrity testing or other means, and may require that the commission be given sufficient notice of the testing schedule. 05/23/2003 15:57 FAX 907 564 4040 l' bp EXPLORATION ~]008 Definitions "inner annulus" means the space in a well between tubing and production casing. "outer annulus" means the space in a well between the production casing and surface casing. "sustained pressure" means pressure that: 1. is measurable at the casing head of an annulus, 2. is not caused solely by temperature fluctuations, 3. is not pressure that has been applied through artificial lift operations, and 4. cannot be consistently maintained under the following limits with two or fewer bleeds per week: · inner annulus: 2500 psig for wells processed through the Lisburne Production Center and 2,000 psig for all other Prudhoe Bay development wells . · outer annulus: 1000 psig. #5 05/19/03 03:27 FAX ~001 Paper, Allied-Industrial, Chemical and Energy Workers International Union, AFL-CIO P.A.C.E. LOCAL 6-369 Anchorage, Alaska ~515..6512 (ee?l.sse,.2320 PAX 1607~650-2320 ~. ,dp,-Ii'' ' Attention Jody Colombie and Commissioner Palin 2 Pages Follow PACE Written Comments on AOGCC Proposed Prudhoe Bay Unit Annular Pressure Rule Fax 907-276-7542 RECEIVED MAY 1 9 2003 Alaska 0il & Gas Cons. Commission Anchorage 05/19/03 03:27 FAX ~002 Paper, AlJledJndustrlaL~ Chemical and Energy Workers International Union, AFL.CIO P.A_C.E. LOCAL 8-369 Bec P-8 Anchorage, AlaSka ~9S15-~12 FAX (907~5~2320 May 19, 2003 Sarah Palin, Commissioner Alaska Oil and Gas Conservation Commission 333 W. 7th Ave #100 Anchorage, Alaska, 99501-3539 William F. Bocast Chairman, PACE Health and Safety Committee BP Bargaining Unit PACE Local 8-369 C/O BPX, North Slope, Mailstop P-8 PO Box 196612 Anchorage, Alaska 99519 Dear Commissioner Palin: The Paperworker, Allied Industrial, Chemical and Energy Workers Union (PACE) represents over 200 North Slope workers employed by BPX, Alaska. The BP.employee injured in the well A-22 explosion is one of our Union members. We have been following well safety issues with great interest, and have reviewed the AOGCC's Proposed Annular Pressure Rule. We wish to provide our written endorsement and support of the proposed mle, and urge its immediate adoption. We are currently working with BP on engineering controls to provide a first line of defense against an uncontrolled release of pressure such as we experienced with well A-22. We hope BP will agree to feasible engineering controls as a first line of defense to mitigate these potential hazards. We believe the Commission's Proposed Annular Pressure Rule will be an effective administrative control providing a second line of defense against another uncontrolled release of pressure. Thank You William F. Bocast Chairman, PACE Health and Safety Committee #4 bp May 5, 2003 Sarah Palin, Chair Alaska Oil & Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, Alaska 99501 BP Exploration (Alaska) Inc. 900 East Benson Boulevard P.O. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 Re: Request for Hearing Proposed Rule governing annular pressures in Prudhoe Bay Unit Tentative hearing date: May 27, 2003 Dear Ms. Palin: Pursuant to the Corrected Notice of Public Hearing issued by the Alaska Oil and Gas Conservation Commission (AOGCC) on April 17, 2003, BP Exploration (Alaska) Inc. (BP), on behalf of the Prudhoe Bay Unit Working Interest Owners, hereby requests that the subject hearing be held as proposed on May 27, 2003 at 9:00 a.m. Please contact me at 564-4556 with any questions. Sincerely, BP Exploration (Alaska)Inc. #3 ~ ADVERTISING ORDER NO. STATE OF ALASKA~ NOTICE TO PUBLISHER { .... ',TIreD INVOIC - ,.,oST BE IN TRIPLICATE SHOWING ADVERTISING ORDER NO.,' ADVERTISING ~,D^v,T oF .~.~,c^TIo. ~.~... oF ..~ Fo.~ w,~. ^~^CHED CO.~ O~"'" '''~""~'~~ 4044 ORDER ADVERTISEMENT MUST BE SUBMITTED WITH INVOICE ~ ~OG~C AG[NeY CONTACT DAT~. O~ A.O. " 333 W 7th Ave, Ste 100 Jod¥ Colombie April 16, 2003 PHONE PCN O A~chom~¢, AK 9950 ~ - (907) 793 -122 ] DATES ADVERTISEMENT REQUIRED: x Anchorage Daily News April 17, 2003 o 'P O Box 149001 TIlE MATERIAL BETWEEN TIlE DOIJBLE LINES MUST BE PRINTED IN ITS ~_ t. ~_~.uxcnorage, AK 99514 SPECIAL INSTRUCTIONS: Account #STOF0330 Advertisement to be published was e-mailed Type of Advertisement X Legal ~ Display ~ Classified ~-lOther (Specify) SEE ATTACHED PUBLIC HEARING I iTOTAL OFI AOGCC, 333 W. 7th Ave., Suite 100 ' ' ' PAGE 1 OF 'ALL PAGES$' Anchorage, AK 99501 2 PAGES I I REF TYPE NUMBER AMOUNT DATE COMMENTS I VEN 3 4 FIN AMOUNT SY CC PGM LC ACCT FY NMR DIST LIQ 1 03 02140100 73540 4 /% , · REQUISITIONED BY:/'/ .............' ( ~~,~] ~ ID'v's'°N APP~°VAL: ~ / 02-902 (Rev. 3/94) Publisher/Original Copies: Department Fiscal, Department, Receiving AO.FRM Corrected Notice of Public Hearing STATE OF ALASKA Alaska Oil and Gas Conservation Commission Re: Rules goveming annular pressures in Prudhoe Bay Unit development wells. The Alaska Oil and Gas Conservation Cormnission ("Commission") resolved to establish rules regulating sustained casing pressures in Prudhoe Bay Unit ("PBU") devel- opment wells. The Commission has tentatively set a public hearing on this application for May 27, 2003 at 9:00 am at the Alaska Oil and Gas Conservation Commission at 333 West 7th Avenue, Suite 100, Anchorage, Alaska 99501. A person may request that the tentatively scheduled hearing be held by filing a written request with the Commission no later than 4:30 pm on May 5, 2003. (This May 5 deadline replaces the erroneous April 1 deadline set out in the original notice of public hearing.) If a request for a hearing is not timely filed, the Commission will consider the is- suance of an order without a hearing. To learn if the Commission will hold the public hearing, please call 793-1221. In addition, a person may submit written comments regarding this application to the Alaska Oil and Gas Conservation Commission at 333 West 7th Avenue, Suite 100, Anchorage, Alaska 99501. Written comments must be received no later than 4:30 pm on May 19, 2003 (this May 19 deadline replaces the May 15 deadline set out in the original notice of public hearing) except that if the Commission decides to hold a public hearing, written comments must be received no later than 9:00 am on May 27, 2003. A copy of the proposed rule may be obtained from the Commission at the address set out above, or on the Commission's website at h ttp ://www. state, ak. us/1 ocal/akp ag es/AD MIN/o gc/ho m eo gc.htm If you are a person with a disability who may need a special modification in or- der to comment or to attend the public hearing, please contact Jody Colombie at 793- 1221 before May 9, 2003. (This May 9 deadline replaces the May 6 deadline set out in the original notice of public hearing). ~------ ~ ~ /2, Sarah Palin, ClSair Published Date: April 17, 2003 ADN AO# 02314044 Anchorage Daily News Affidavit of Publication 1001 Northway Drive. Anchorage, AK 99508 4121/2003 AD # DATE PO ACCOUNT 772405 04/17/2003 02314044 STOF0330 PRICE OTHER OTHER PER DAY CHARGES CHARGES $169.20 $169.20 $10.00 $0.00 OTHER OTHER OTHER GRAND CHARGES#3 CHARGES#4 CHARGES#5 TOTAL $0.00 $0.00 $0.00 $179.20 STATE OF ALASKA THIRD JUDICIAL DISTRICT Kimberly A. Kirby, being first duly sworn on oath deposes and says that she is an advertising representative of the Anchorage Daily News, a daily newspaper. That said newspaper has been approved by the Third Judicial Court, Anchorage, Alaska, and it now and has been published in the English language continually as a daily newspaper in Anchorage, Alaska., and it is now and during all saidtime was printed in an office maintained at the aforesaid place of publication of said newspaper. That the azmexed is a copy of an advertisement as it was published in regular issues (and not in supplemental form) of said newspaper on the above dates and that such newspaper was regularly distributed to its subscribers during all of said period. That the full amount of the fee charged for the foregoing publication is not in excess of the rate charged private individuals. Subscribed and sworn to me be ore t is date: Notary Public in and for the State of Alaska. Third Division. Anchorage, Alaska .e .... . Corrected Notice of Public Hearing ~ .STATE OF ALASKA ' AlasR'a, Oi! and Gas C°nServation commission Re: Rules 'governlng annular' pressures in Prudhoe Ba~/ UriJt development wells .... The Alaska Oil 'and Gas conservation Commis- sion ("CommJs'sl.on") resolved ta establish rules regulating sustained casing' pressures In Pru. dhoe Bay Unit ("PBU") deveJopment wells. ~he'Com~i~sion has tenfativ~ y set'a public hearJ'ng on :this ~appllcatJon for May ~7; 2003 at 9:00 am at the Alaska Oil arid Gas Conservafjon Cum- mission at 333 West 7th Avenue, Suite'100; Anchor- .age, A aska 99501. A Person' may reauest that the te~tatlve'ly scheduled hea~lng be.~eld by'fll'Ing a ,..'-'~*~' '~;,'?'~ 't':*h'*~ Co~ffiJssJ.O~ no.'later than ~ a'.. :~'". - a.~ .... '. ~.e ~f. l.,~ · ~' ?, ~': 5 -~l:~'-~l" '' ,...' :',t ~;~:1 :; ';:2'. ...... .~ · .. tfa request for a hea~ing'js not'timely tlr'ed, the Co~mission will consider the'issuaflce of an order withOUt a hear[fig.' To learn if the Commission will hold the'public hearing, please call 793-1221. ' . , . .'. ... /' ~, ... . .... . . In 'additl0~, :a person ~ay'su~mJ{' Writte~ com- ~ents regarding this appli'cation to the 'Alaska O[I 'and Gas Cofls~vat:~ C~m~r e* 333 West 7th Avenue, Suite 100, '..'r"c,~.::.: : : ..~: *c~7' Writ- ten c:~'6 ~'.:s' .:.v '.:;..".-:;. . r-~.-" 3~ 4:30 p~ :....... ;.. ,the. ": · . .,.,p~, .-. Pub · '~' ~":':;"~" "' ';: 'r'-'i ,v:. :" :',~- c.Jd~; '; "; ? :, :~-:', ; ,..: · .,... ..-". .... ?"v". ".., mus't be received no later than,9 00 am ~n ~ay 2/, 2003, . .A,,copy.of;~the.,prgpo,sed r~le m~y be obtained f'~o'~ .the',commissi~ ~t the address Set out above, Or'6~:th~:: CommissiGW{' Oobsite at e.a~ ~"~7 'oc~l/akpages/AD~'l N/ogc/ .btm 7'. ~ YOU area per,son .wlth a disabll.lty ;who may ...need a special modification in or-de.r .to.c0m~ent or 'to att.e0d'the, pub lc'hearing, please contact Jody Colombie at 793,1221 befOre ~ay 9, 2003. (This ..-:.; ~..::::".. .:':: : ;? the May 6 deadiine set out :;- ;..: .. oubiic hearing).' sbrah Palln, Chair Publish: April 17, 2003 RECEIVED MAY 0 1 2003 Alaska Oil & Gas Cons. Commission Anchorage ("Anchorage Daily News Affidavit of Publication 1001 Northway Drive, Anchorage, AK 99508 4/21/2003 AD # DATE PO ACCOUNT 771633 04/16/2003 02314043 STOF0330 PRICE OTHER OTHER PER DAY CHARGES CHARGES #2 $129.72 $129.72 $0.00 $0.00 OTHER OTHER OTHER GRAND CHARGES#3 CHARGES#4 CHARGES#5 TOTAL $0.00 $0.00 $0.00 $129.72 STATE OF ALASKA THIRD JUDICIAL DISTRICT Kimberly A. Kirby, being first duly sworn on oath deposes and says that she is an advertising representative of the Anchorage Daily News, a daily newspaper. That said newspaper has been approved by the Third Judicial Court, Anchorage, Alaska, and it now and has been published in the English language continually as a daily newspaper in Anchorage, Alaska, and it is now and during all saidtime was printed in an office maintained at the aforesaid place of publication of said newspaper. That 'the annexed is a copy of an advertisement as it was published in regular issues (and not in supplemental form) of said newspaper on the above dates and that such newspaper was regularly distributed to its subscribers during all of said period. That the full amount of the fee charged for the foregoing publication is not in excess of the rate charged private individuals. Signed , "' '/~' 'ate Subscribed and sworn to me before th~s d : Notary Public in and for the State of Alaska. Third Division. Anchorage, Alaska MY COMMISSION EXPIRES: ~//~2/~ / - ..-t[~.ttttrr.,,~' Notice,of Public Hearing Alaska oiI ami Gas ConServation Commission 'Re: Rules governing annular, pressures ,in Prudhoe Bay Unit development wells. The Alaska Oll'and 'Gas,Conservation Commls- sion ('"Commission")resol'ved'tO establish rules regulating sustai,ned casing pressures in Prudhoe Bay Unit. ("PBU") devel0pment wells. " ' The Commission has tentativefY set 'a public 'hearing on this application, for'May 27, 2003 at 9:00 am'vt' the Alaska OJ and GasConservat on Cam- I. mission at 333west 7th Ave'nue; Suite 100,.Anchor- .lace, Alaska 99501..A p.erSon may request'that the ',]~,te,0'~:c~ti:vel!v, ,,,~;,he,~li,~d~i,,hea r n g :~be,; he,ldl',b.y :i ng a 'l: Writt~h: ¢eqoest,:wlth the COmmission no tater than ',1 4~30,Pm on AprH"I~ 2003. ,, ." ,. ,: :'' "l'f a,request for a hearing is'nOt timely filed, the ' commission Will,consider :the issuaOce ,of an, order Wifh'00t ~ hearlng~,' T6".learn if the commission will h01d'th~,Public hearlng; please call 793;1221..' In additlOn,' a Person may submit Writ.ten c0m. r~entsregarding this .apPlication:to the Alasko Oil and'Gas Conservation Commiss on at 333 West.7th ':Avenue; Suite ::100, Anchor'age, Alaska ~9501. Writ- ten comments must be received'no later' than 4:30 pm on May' 15; 2003 except that i'f ,the. Commission decides to hold d.public..~hear'lng, written com- ments must be received no later.than 9:00am On May 27; 2003. If:you are a person wit. h a disability who may:need'a special modificatlo~ in, Order to comment or to attend the public' heati~g~ please cOntact Jody Colombie at 793-1221 befbt'e. MaY. 6, 2003. " sa'cab PalJn, Chair . Publish: APril 16, 2003 ' ..~...... '~:1 RECEIVED MAY 0 1 2003 Alaska Oil & Gas Cons. Commission Anchorage Re: Corrected Notice of Public Heating Subject: Re: Corrected Notice of Public Hearing Date: 16 Apr 2003 14:16:10 -0800 From: Legal Ads Anchorage Daily News <legalads@adn.com> To: <jody_colombie@admin.state.ak.us> Hi Jody: Following is the confirmation information on your "Corrected" legal notice. let me know if you need anything further. Account Number: STOF 0330 Legal Ad Number: 772405 Publication Date(s): April 17, Your Reference #: 02314044 Total: $179.20 2003 Thank You, Kim Kirby Anchorage Daily News Legal Classified Representative E-Mail: legalads@adn.com Phone: (907) 257-4296 Fax: (907) 279-8170 Please On Wednesday, April 16, 2003, jody_colombie@admin.state.ak.us wrote: >Please publish on Thursday April 17th. Yesterday notice had >errors. > >Jody 1 of 1 4/16/2003 2:32 PM STATE OF ~LASKA ~- NOTICE TO PUBLISHER i' ADVERTISING ORDER NO. ADVERTISING INVOICe.. ~ST BE IN TRIPLICATE SHOWING ADVERTISING ORDER NO.,. ATIFIED ~F,DAV,T OF PUBL,C*T,ON (.*.. 2 OF ~,S ~0~)W~ *~*~.~ ~0~ O~ A 0'0231 4044 ORDER ADVER~SEME~ MUST BE SUBMI~D WI~ I~OICE F AO~C AGENCY CO.ACT DATE OFA.O. ~ 333 West 7~ Avenue, Suite 100 Jodv Colombie A~fil 16. 2003 o ~chorage, ~ 99501 PHORE PeN M - (907~ 793-1221 ~ATE~ ADVERTISEMENT ~OUI~D: x ~chorage D~ly News April 17, 2003 0 P O Box 149001 ~E ~m~ BE~EEN ~E DOYLE LINES MUST BE PmN~D IN ITS ~choragc, ~ 99~ 14 zsr~ os ~t OA~S S~O~. SPECIAL INSTRUCTIONS: Accost ~STOF0330 United states of Ame~ca REMINDER State of ss INVOICE MUST BE IN TRIPLICATE AND MUST REFERENCE IHE ADVERTISING ORDER NUMBER. division. A CERTIFIED COPY OF THIS AFFIDAVIT OF PUBLICATION MUST BE SUBMI~ED WITH THE INVOICE. Before me, the undersigned, a nota~ public this day personally appeared A~ACH PROOF OF PUBLICATION HERE. who, being first duly sworn, according to law, says that he/she is the of Published at in said division and state of and that the adveaisement, of which the annexed is a tree copy, was published in said publication on the day of 2003, and thema~er for ~ consecutive days, the last publication appearing on the ~ day of ,2003, and that the rote charged thereon is not in excess of the rate charged p~vate individuals. Subscribed and sworn to before me This ~ day of 2003, Nota~ public for state of My commission expires . 02-901 (Rev. 3/94) AO.FRM Page 2 PUBLISHER Corrected Notice of Public Hearing Subject: Date: From: Organization: To: Corrected Notice of Public Hearing Wed, 16 Apr 2003 12:00:31 -0800 jody_colombie@admin, state.ak.us Alaska Oil and Gas Conservation Commission Robert E Mintz <robert_mintz~law.state.ak.us>, John Tanigawa <JohnT~EvergreenGas.com>, stanekj <stanekj~unocal.com>, ecolaw <ecolaw~trustees.org>, roseragsdale <roseragsdale~gci.net>, trmjrl <trmjrl @aol.com>, jbriddle <jbriddle~marathonoil.com>, rockhill <rockhill@aoga. org>, shaneg <shaneg@evergreengas.com>, rosew <rosew~evergreengas.com>, jdarlington <jdarlington~forestoil.com>, nelson <nelson@gci.net>, cboddy <cboddy@usibelli.com>, "mark.dalton" <mark.dalton@hdrinc.com>, "shannon.donnelly" <shannon.donnelly~conocophillips.com>, "mark.p.worcester" <mark.p.worcester@conocophillips.com>, "jerry. c.dethlefs" <j erry. c.dethlefs@conocophillips.com>, arlenehm <arlenehm@gci.net>, bob <bob@inletkeeper.org>, wdv <wdv~dnr. state.ak.us>, rjr <tjr~dnr. state.ak.us>, bbritch <bbritch@alaska.net>, greg-noble <greg-noble@blm.gov>, "charles.odonnell" <charles.odonnell~veco.com>, mjnelson <mjnelson~purvingertz.com>, burgin_d <burgin_d@niediak.com> ~ I Name: 2 Prudhoe Bay_Annulus Pressure.doc 1~2, emdhoe. Bay Annulus..Pressure.doct Type: ~INWOR~ File (applica~on/msword) ] ~Eneoding: base64 I of 1 4/16/2003 2:43 PM Corrected Notice of Hearing Subject: Corrected Notice of Hearing Date: Wed, 16 Apr 2003 14:31:53 -0800 From: Jody Colombie <jody_colombie@admin.state.ak.us> Organization: Alaska Oil and Gas Conservation Commission To: greg-noble <greg-noble@blm.gov>, "charles.odormell" <charles.odonnell~veco.com> Name: Pmdhoe_Bay_Annulus_Pressure.doc ~Pmdhoe Bay Annulus Pressure.doc Type: WINWORD File (application/msword) Encoding: base64 _ I Name: Pmdhoe Bay Annulus attachment.doc ~Pmdhoe Bay Annulus attachment.doc1 Type: WlNW(~RD ~-ile (appl~cation/msword) ....... iEneoding: base64 Jody Colombie <jody_ colombie~admin.state.ak.us> 1 of 1 ,, 4/16/2003 2:43 PM Corrected Notice of Hearing Subject: Corrected Notice of Hearing Date: Wed, 16 Apr 2003 14:42:32 -0800 From: Jody Colombie <jody_colombie~admin.state.ak.us> Organization: Alaska Oil and Gas Conservation Commission To: charles.o'donnell~veco.com ~Pmdhoe Bay. Annulus Pressure.doc Name: Pmdhoe_Bay_Annulus_Pressure.doc Type: WINWORD File (application/msword) Encoding: base64 Name: Pmdhoe Bay Annulus attachment.doct ~emdhoe Bay Annulus attachment.docI Type: WINW(~RD ~-ile (appl~ation/msword) ] ' i, Eneoding: base64 t IJody Colombie <jody. colombie@admin, state.ak.us> 1 of 1 4/16/2003 2:43 PM John Katz State of Alaska Alaska Govemor's Office 444 North Capitol St., NW, Ste 336 Washington, DC 20001 Daniel Donkel 2121 North Bayshore Drive, Ste 1219 Miami, FL 33137 SD Dept of Env & Natural Resources Oil and Gas Program 2050 West Main, Ste 1 Rapid City, SD 57702 Alfred James 200 West Douglas, Ste 525 Wichita, KS 67202 Jim Yancey SeaI-Tite International 500 Deer Cross Drive Madisonville, LA 70447 Christine Hansen Interstate Oil & Gas Compact Comm Excutive Director PO Box 53127 Oklahoma City, OK 73152 Citgo Petroleum Corporation PO Box 3758 Tulsa, OK 74136 Mary Jones XTO Energy, Inc. Cartography 810 Houston Street, Ste 2000 Ft. Worth, TX 76102-6298 Gregg Nady Shell E&P Company Onshore Exploration & Development PO Box 576 Houston, TX 77001-0576 Paul Walker Chevron 1301 McKinney, Rm 1750 Houston, TX 77010 G. Scott Pfoff Aurora Gas, LLC 10333 Richmond Ave, Ste 710 Houston, TX 77042 G. Havran Gaffney, Cline & Associations Library 1360 Post Oak Blvd., Ste 2500 Houston, TX 77056 David McCaleb IHS Energy Group GEPS 5333 Westheimer, Ste 100 Houston, TX 77056 William Holton, Jr. Marathon Oil Company Law Department 5555 San Fecipe St. Houston, TX 77056-2799 W. Allen Huckabay ConocoPhillips Petroleum Company Offshore West Africa Exploration 600 North Dairy Ashford Houston, TX 77079-1175 T.E. Alford ExxonMobil Exploration Company PO Box 4778 Houston, TX 77210-4778 Corry Woolington ChevronTexaco Land-Alaska PO Box 36366 Houston, TX 77236 Texico Exploration & Production PO Box 36366 Houston, TX 77236 Chevron USA Alaska Division PO Box 1635 Houston, TX 77251 Donna Williams World Oil Statistics Editor PO Box 2608 Houston, TX 77252 Chevron Chemical Company Library PO Box 2100 Houston, TX 77252-9987 Shelia McNulty Financial Times PO Box 25089 Houston, TX 77265-5089 Shawn Sutherland Unocal Revenue Accounting 14141 Southwest Freeway Sugar Land, TX 77478 Kelly Valadez Tesoro Refining and Marketing Co. Supply & Distribution 300 Concord Plaza Drive San Antonio, TX 78216 James White Intrepid Prod. Co./Alaskan Crude 4614 Bohill SanAntonio, TX 78217 Doug Schultze XTO Energy Inc. 3000 North Garfield, Ste 175 Midland, TX 79705 Robert Gravely 7681 South Kit Carson Drive Littleton, CO 80122 George Vaught, Jr. PO Box 13557 Denver, CO 80201-3557 Jerry Hodgden Hodgden Oil Company 408 18th Street Golden, CO 80401-2433 Richard Neahdng NRG Associates President PO Box 1655 Colorado Spdngs, CO 8O9O1 John Levomen 200 North 3~ Street,#1202 Boise, ID 83702 Kay Munger Munger Oilln~rmation Service, lnc PO Box 45738 Los Angeles, CA 90045-0738 John F. Be~quist Babson and Sheppa~ PO Box 8279 Long Beach, CA 90808-0279 Samuel Van Vactor Economiclnsightlnc. 3004 SWFimt Ave. Portland, OR 97201 Thor Cutler OW-137 US EPA egion 10 1200 Sixth Ave. Seattle, WA 98101 Michael Parks Marple's Business Newsletter 117 West Mercer St, Ste 200 Seattle, WA 98119-3960 Julie Houle State of Alaskan DNR Div of Oil & Gas, Resource Eval. 550 West 7th Ave., Ste 800 Anchorage, AK 99501 Duane Vaagen Fairweather 715 L Street, Ste 7 Anchorage, AK 99501 Richard Mount State of Alaska Department of Revenue 500 West 7th Ave., Ste 500 Anchorage, AK 99501 Ed Jones Aurora Gas, LLC Vice President 1029 West 3rd Ave., Ste 220 Anchorage, AK 99501 Susan Hill State of Alaska, ADEC EH 555 Cordova Street Anchorage, AK 99501 Cammy Taylor 1333 West 11th Ave. Anchorage, AK 99501 Trustees for Alaska 1026 West 4th Ave., Ste 201 Anchorage, AK 99501-1980 Mark Wedman Halliburton 6900 Arctic Blvd. Anchorage, AK 99502 Schlumberger Drilling and Measurements 3940 Arctic Blvd., Ste 300 Anchorage, AK 99503 Jack Laasch Natchiq Vice President Government Affairs 3900 C Street, Ste 701 Anchorage, AK 99503 Rob Crotty C/O CH2M HILL 301 West Nothern Lights Blvd Anchorage, AK 99503 Baker Oil Tools 4730 Business Park Blvd., #44 Anchorage, AK 99503 Ciri Land Department PO Box 93330 Anchorage, AK 99503 Mark Hanley Anadarko 3201 C Street, Ste 603 Anchorage, AK 99503 John Harris NI Energy Development Tubular 3301 C Street, Ste 208 Anchorage, AK 99503 Judy Brady Alaska Oil & Gas Associates 121 West Fireweed Lane, Ste 207 Anchorage, AK 99503-2035 Richard Prentki US Minerals Management Service 949 East 36th Ave., 3rd Floor Anchorage, AK 99508 Jim Scherr US Minerals Management Service Resource Evaluation 949 East 36th Ave., Ste 308 Anchorage, AK 99508 Jill Schneider US Geological Survey 4200 University Dr. Anchorage, AK 99508 Jeff Walker US Minerals Management Service Regional Supervisor 949 East 36th Ave., Ste 308 Anchorage, AK 99508 Paul L. Craig Trading Bay Energy Corp 5432 East Northern Lights, Ste 610 Anchorage, AK 99508 Gordon Severson 3201 Westmar Cr. Anchorage, AK 99508-4336 Jim Ruud ConocoPhillips Alaska, Inc. Land Department PO Box 100360 Anchorage, AK 99510 Perry Markley Alyeska Pipeline Service Company Oil Movements Department 1835 So. Bragaw - MS 575 Anchorage, AK 99515 Bill Bocast PACE Local 8-369 c/o BPX North Slope, Mailstop P-8 PO Box 196612 Anchorage, AK 99519 Kevin Tabler Unocal PO Box 196247 Anchorage, AK 99519-6247 Barbara Fullmer ConocoPhillips Alaska, Inc. Legal Department ATO 2084 PO Box 100360 Anchorage, AK 99510-0360 David Cusato 600 West 76th Ave., #508 Anchorage, AK 99518 Tesoro Alaska Company PO Box 196272 Anchorage, AK 99519 Sue Miller BP Exploration (Alaska), Inc. PO Box 196612 Anchorage, AK 99519-6612 Jordan Jacobsen Alyeska Pipeline Service Company Law Department 1835 So. Bragaw Anchorage, AK 99515 Jeanne Dickey BP Exploration (Alaska), Inc. Legal Department PO Box 196612 Anchorage, AK 99518 Jack Hakkila PO Box 190083 Anchorage, AK 99519 BP Exploration(Alaska),lnc. Land Manager PO Box 196612 Anchorage, AK 99519-6612 Dudley Platt D.A. Platt & Associates 9852 Little Diomede Cr. Eagle River, AK 99577 Peter McKay' 55441 Chinook Rd Kenai, AK 99611 KenaiPeninsula Borough Economic Development Distr 14896 KenaiSpurHwy #103A Kenai, AK 99611-7000 Penny Vadla Box 467 Ninilchik, AK 99639' Clairo Caldes US Fish & Wildlife Service Kenai Refuge PO Box 2139 Soldotna, AK 99669 Cliff Burglin PO Box 131 Fairbanks, AK 99707 Williams Thomas Arctic Slope Regional Corporation Land Department PO Box 129 Barrow, AK 99723 Lt Governor Loren Leman State of Alaska PO Box 110015 Juneau, AK 99811-0015 Marc Kovac PACE 8-369, Prudhoe Bay Vice-Chair PO Box 2973 Seward, AK 99664 Kenai National Wildlife Refuge Refuge Manager PO Box 2139 Soldotna, AK 99669-2139 Harry Bader State of Alaska Department of Natural Resources 3700 Airport Way Fairbanks, AK 99709 North Slope Borough PO Box 69 Barrow, AK 99723 James Gibbs PO Box 1597 Soldotna, AK 99669 Richard Wagner PO Box 60868 Fairbanks, AK 99706 Bernie Karl K&K Recyclinglnc. PO Box 58055 Fairbanks, AK 99711 Kurt Olson State of Alaska Staff to Senator Tom Wagoner State Capitol Rm 427 Juneau, AK 99801 #2 Proposed Prudhoe Bay Unit Annular Pressure Rule . The operator has the burden of demonstrating, by mechanical integrity testing, that all PBU wells can be safely operated, i.e., well operation will not result in failure of well integrity, uncontrolled release of fluid or pressure, or other threat to human safety. 2, All PBU wells must be monitored daily to detect sustained pressures in a well's tubing by production casing annulus ("inner annulus", or IA, if present), and the well's production casing by surface casing annulus ("outer annulus", or OA, if present.) The operator must notify AOGCC within three working days of any PBU well that exhibits sustained inner annulus pressUre or outer annulus pressure greater than 20 percent of the burst pressure rating of the annulus's outer tubular. . For any PBU well exhibiting sustained IA pressure or OA pressure as specified in 3. above, AOGCC may require the operator to implement corrective action or increased surveillance. Corrective action must be verified by mechanical integrity testing, which the Commission must be given the opportunity to witness. . If after Commission notification that a' PBU well exhibits sustained, elevated annulus pressure as specified in 3. above, the same well subsequently exhibits sustained IA pressure or OA pressure greater than 45 percent of the burst pressure rating of the annulus's outer tubular, the Commission must be notified and the well must be immediately shut in until the operator takes Commission approved corrective action. Corrective action must be verified by mechanical integrity testing, which the Commission must be given the opportunity to witness. . AOGCC may sanction continued operation of PBU wells with sustained IA pressure or OA pressure not greater than 45 percent of the burst pressure rating of the annulus's outer tubular if the well operator demonstrates, by mechanical integrity testing, the exiStence of two competent barriers to pressure communication. The Commission must be given the opportunity to witness this mechanical integrity testing. , Before a shut in PBU well is placed in service, any sustained IA pressure and OA pressure must be relieved to a sufficient degree that the pressure at operating temperature will be below the limit specified in 3. above. . If AOGCC determines that operation of any PBU well may result in failure of well integrity, uncontrolled release of fluid or pressure, or other threat to human safety, the Commission may, by administrative action, require such well to be shut in until the well operator takes Commission approved corrective action. Corrective action must be verified by mechanical integrity testing, which the Commission must be given the opportunity to witness. #1 STATE OF ALASKA · NOTICE TO PUBLISHER " ADVERTISING ORDER NO. ADVERTISING INVOICE MUST BE IN TRIPLICATE SHOWING ADVERTISING ORDER ~, CerTIFIED ~r,O^Vl. or PU.LlO^.,o. (...T2 or ~,s ~o~)~l~ ~c.~ co.~ o~A~ ~d~.~. 4043 ORDER ~VERTISEME~ MUST BE SUBMI~D WI~ I~OICE F AO~C AGENCY CONTACT DATE OF A.D. ~ 333 W 7~ Ave, Ste 100 Jody Colombie April 15, 2003 o ~chorage, ~ 99501 PHOUE PCN ~ - (907] 793 --1221 ~A~ ADVERTISEMENT ~QUI~D: x ~chorage D~ly News April 16, 2003 o P O Box 149001 ~chorage, ~ 99514 m~ ~mAL BEmEEN THE DOYLE LINES MUST BE PmNTED IN ITS EN~ ON ~E DATES SHO~. SPECIAL INSTRUCTIONS: Accost ~STOF0330 Adve~isement to be published w~ e-m~led Type of Advedisement X Legal ~ Display ~ Classified ~Other (Specie) SEE ATTACHED PUBLIC HEA~NG ~,,. ~ ..... ....... .,..,,.. ...... ....... :....,, ...................... ITOTALOF I ~:~SE~~~~~~ AOGCC, 333 W. 7th Ave., Suite 100 ~%:'~>~~,,,.;:'~~~] ~chorage, AK 99501 2PAGES REF ~PE NUMBER AMOUNT DATE COMMENTS I VEN 2 A~ 02910 3 4 FIN AMOUNT SY CC PGM LC ACCT FY NMR Dl~ LlQ ~ 03 02140100 73540 2 3 ...u,s,.,o.....: ' "'"' ".. , , , ., I o,v,s j' ~ ' .... , /,, 02-902 (Rev. 3/94) Publisher/Original Copies: Department Fiscal, Department, Receiving AO.FRM Notice of Public Hearing STATE OF ALASKA Alaska Oil and Gas Conservation Commission Re: Rules governing annular pressures in Prudhoe Bay Unit development wells. The Alaska Oil and Gas Conservation Commission ("Commission") resolved to establish rules regulating sustained casing pressures in Prudhoe Bay Unit ("PBU") devel- opment wells. The Commission has tentatively set a public hearing on this application for May 27, 2003 at 9:00 am at the Alaska Oil and Gas Conservation Commission at 333 West 7th Avenue, Suite 100, Anchorage, Alaska 99501. A person may request that the tentatively scheduled hearing be held by filing a written request with the Commission no later than 4:30 pm on April 1, 2003. If a request for a hearing is not timely filed, the Commission will consider the is- suance of an order without a hearing. To learn if the Commission will hold the public hearing, please call 793-1221. In addition, a person may submit written comments regarding this application to th the Alaska Oil and Gas Conservation Commission at 333 West 7 Avenue, Suite 100, Anchorage, Alaska 99501. Written comments must be received no later than 4:30 pm on May 15, 2003 except that if the Commission decides to hold a public hearing, written comments must be received no later than 9:00 am on May 27, 2003. If you are a person with a disability who may need a special modification in order to comment or to attend the public hearing, please contact Jody Colombie at 793-1221 before May 6, 2003. Sarah Palin, Ch~tir Published Date: April 16, 2003 ADN AO# 02314043 Re: Notice and Ad Order {, Subject: Re: Notice and Ad Order Date: 15 Apr 2003 16:30:23 -0800 From: Legal Ads Anchorage Daily News <legalads~adn. com> To: Jody Colombie <jody_colombie~admin.state.ak.us> Hi Jody: Following is the confirmation information on your legal notice. Please let me know if you need anything further. Account Number: STOF 0330 Legal Ad Number: 771633 Publication Date(s): April 16, 2003 Your Reference #: AO-02314043 Total: $129.72 Thank You, Kim Kirby Anchorage Daily News Legal Classified Representative E-Mail: legalads@adn.com Phone: (907) 257-4296 Fax: (907) 279-8170 On Tuesday, April 15, 2003, Jody Colombie <jody_colombie@admin.state.ak.us> wrote: >Please try and publish this notice tomorrow. > >Jody 1 of 1 4/16/2003 10:24 AM ..... STATE OF ALASKA ( NOTICE TO PUBLISHER {' ADVERTISING OI~--DER NO. ADVERTISING INVOIL;6 MUST BE IN TRIPLICATE SHOWING ADVERTISING ORDER't .... C,-d, TIFIED = ,DAV,T OF.U L,OAT,ON FO.MI W,TH ^ AO.ED COP OF A0'023140 3 ORDER ADVERTISEMENT MUST BE SUBMI'I-FED WITH INVOICE · :SEE.BOTTOM.: FOR'.Ifi~'.OI~.~.LA~. D~E~S~,~.'. · .. :.. ....... ~,.~ .; ....... ~.,....~,,~.~,.;.,~..~'..,. F AO~C AGEHCY COHTACT DATE OF ^,O. " 333 West ?~ A¥cnuc~ Suite 100 ]odv Co~ombie ^mil 1 ~. ~C)0~ o :Ancho;~gc~ .~ 9950! P~O~ i~ATE~ ~DYERTISE~EHT REOUIRED: x ,anchorage Daily News April 16, 2003 o ? O Box 149001 T,E MATERIAL BETW~.EN n~E ~OU~I~E USES ~USX Anchorage, AK 99514 esnaeTV os T,e ~ATES SaOWN. SPECIAL INSTRUCTIONS: Account #STOF0330 FFID ¥rF OF PUBLI 'I'ION United states of America REMINDER State of ss INVOICE MUST BE IN TRIPLICATE AND MUST REFERENCE THE ADVERTISING ORDER NUMBER. division. A CERTIFIED COPY OF THIS AFFIDAVIT OF PUBLICATION MUST BE SUBMITTED WITH THE INVOICE. Before me, the undersigned, a notary public this day personally appeared ATTACH PROOF OF PUBLICATION HERE. who, being first duly sworn, according to law, says that he/she is the of Published at in said division and state of and that the advertisement, of which the annexed is a true copy, was published in said publication on the day of 2003, and thereafter for consecutive days, the last publication appearing on the ~ day of ,2003, and that the rate charged thereon is not in excess of the rate charged private individuals. Subscribed and sworn to before me This day of 2003, Notary public for state of My commission expires 02-901 (Rev. 3/94) AO.FRM Page 2 PUBLISHER Notice Subject: Date: From: Organization: To: Notice Tue, 15 Apr 2003 13:34:52-0800 Jody Colombie <jody_colombie@admin.state.ak.us> Alaska Oil and Gas Conservation Commission Robert E Mintz <robert_mintz~law. state.ak.us>, John Tanigawa <JohnT@EvergreenGas.com>, stanekj <stanekj@unocal.com>, ecolaw <ecolaw@tmstees.org>, roseragsdale <roseragsdale@gci.net>, trmjrl <trrnjrl @aol.com>, jbriddle <jbriddle@marathonoil.com>, rockhill <rockhill@aoga. org>, shaneg <shaneg@evergreengas.com>, rosew <rosew~evergreengas.com>, arleneehm <arleneehm@gci.net>, jdarlington <jdarlington@forestoil.com>, nelson <nelson@gci.net>, cboddy <cboddy@usibelli.com>, "mark.dalton" <mark.dalton@hdrinc.com>, "shannon.donnelly" <shannon.donnelly@conocophillips.com>, "mark.p.worcester" <mark.p.worcester@conocophillips.com>, "jerry. c.dethlefs" <j erry.c.dethlefs@conocophillips.com> ~Pmdhoe Bay. Annulus attachment.doc: Name: Pmdhoe_Bay_Annulus_attachment.doc Type: WINWORD File (application/msword) Encoding: base64 l rua o _ a¥ Annulus_Pressure.doct Type: WINWORD File (application/msword)l ]J~Y "C~ i;mbie <j ody c~ lo--mb~e~a~nin, st~-~ie.-~.us-~~ 1 of 1 4/15/2003 1:50 PM Notice Subject: Notice Date: Tue, 15 Apr 2003 13:41:28-0800 From: Jody Colombie <jody_colombie~admin. state.ak.us> Organization: Alaska Oil and Gas Conservation Commission To: arlenehm <arlenehm@gci.net> ~Pmdhoe Bay Annulus attachment.doc Name: Prudhoe_Bay_Annulus_attachment.doc Type: WlNWORD File (application/msword) Encoding: base64 i Name: Prudhoe_Bay_Annulus_Pressure.doc ~Pmdhoe Bay Annulus Pressure.doc] Type: WINWORD File (application/msword) - -- ,lEncoding: base64 1 of 1 4/15/2003 1:50 PM Daniel Donkel 2121 North Bayshore Ddve, Ste 1219 Miami, FL 33137 SD Dept of Env & Natural Resources Oil and Gas Program 2050 West Main, Ste 1 Rapid City, SD 57702 John Katz State of Alaska Alaska Governor's Office 444 North Capitol St., NW, Ste 336 Washington, DC 20001 Alfred James 200 West Douglas, Ste 525 Wichita, KS 67202 Jim Yancey Seal-Tire International 500 Deer Cross Drive Madisonville, LA 70447 Mary Jones XTO Energy, Inc. Cartography 810 Houston Street, Ste 2000 Ft. Worth, TX 76102-6298 Paul Walker Chevron 1301 McKinney, Rm 1750 Houston, TX 77010 David McCaleb IHS Energy Group GEPS 5333 Westheimer, Ste 100 Houston, TX 77056 T.E. Alford ExxonMobil Exploration Company PO Box 4778 Houston, TX 77210-4778 Chevron USA Alaska Division PO Box 1635 Houston, TX 77251 Shelia McNulty Financial Times PO Box 25089 Houston, TX 77265-5089 James White Intrepid Prod. Co./Alaskan Crude 4614 Bohill SanAntonio, TX 78217 Christine Hansen Interstate Oil & Gas Compact Comm Excutive Director PO Box 53127 Oklahoma City, OK 73152 Gregg Nady Shell E&P Company Onshore Exploration & Development PO Box 576 Houston, TX 77001-0576 G. Scott Pfoff Aurora Gas, LLC 10333 Richmond Ave, Ste 710 Houston, TX 77042 William Holton, Jr. Marathon Oil Company Law Department 5555 San Fecipe St. Houston, TX 77056-2799 C~)rry Woolington ChevronTexaco Land-Alaska PO Box 36366 Houston, TX 77236 Donna Williams World Oil Statistics Editor PO Box 2608 Houston, TX 77252 Shawn Sutherland Unocal Revenue Accounting 14141 Southwest Freeway Sugar Land, TX 77478 Doug Schultze XTO Energy Inc. 3000 North Garfield, Ste 175 Midland, TX 79705 Citgo Petroleum Corporation PO Box 3758 Tulsa, OK 74136 Michael Nelson Purvin Gertz, Inc. Library 600 Travis, Ste 2150 Houston, TX 77002 G. Havran Gaffney, Cline & Associations Library 1360 Post Oak Blvd., Ste 2500 Houston, TX 77056 W. Allen Huckabay ConocoPhillips Petroleum Company Offshore West Africa Exploration 600 North Dairy Ashford Houston, TX 77079-1175 Texico Exploration & Production PO Box 36366 Houston, TX 77236 Chevron Chemical Company Library PO Box 2100 Houston, TX 77252-9987 Kelly Valadez Tesoro Refining and Marketing Co. Supply & Distribution 300 Concord Plaza Drive San Antonio, TX 78216 Robert Gravely 7681 South Kit Carson Drive Littleton, CO 80122 George Vaught, Jr. PO Box 13557 Denver, CO 80201-3557 Jerry Hodgden Hodgden Oil Company 408 18th Street Golden, CO 80401-2433 Richard Neahdng NRG Associates President PO Box 1655 Colorado Spdngs, CO 80901 John Levorsen 200 North 3rdStreet, #1202 Boise, ID 83702 Kay Munger Munger Oillnformation Service, lnc PO Box 45738 Los Angeles, CA 90045-0738 John F. Be~quist Babson and Sheppa~ PO Box 8279 Long Beach, CA 90808-0279 Samuel Van Vac~r Economiclnsightlnc. 3004 SWFimtAve. Portland, OR 97201 Thor Cutler OW-137 US EPA egion 10 1200 Sixth Ave. Seattle, WA 98101 Michael Parks Marple's Business Newsle~er 117West Mercer St, Ste 200 Seattle, WA 98119-3960 Julie Houle State of Alaskan DNR Div of Oil & Gas, Resource Eval. 550 West 7th Ave., Ste 800 Anchorage, AK 99501 Cammy Taylor 1333 West 11th Ave. Anchorage, AK 99501 Richard Mount State of Alaska Department of Revenue 500 West 7th Ave., Ste 500 Anchorage, AK 99501 William VanDyke State of Alaska Department of Natural Resources 550 West 7th Ave., Ste 800 Anchorage, AK 99501 Duane Vaagen Fairweather 715 L Street, Ste 7 Anchorage, AK 99501 Susan Hill State of Alaska, ADEC EH 555 Cordova Street Anchorage, AK 99501 Ed Jones Aurora Gas, LLC Vice President 1029 West 3rd Ave., Ste 220 Anchorage, AK 99501 Tim Ryherd State of Alaska Department of Natural Resources 550 West 7th Ave., Ste 800 Anchorage, AK 99501 Trustees for Alaska 1026 West 4th Ave., Ste 201 Anchorage, AK 99501-1980 Mark Wedman Halliburton 6900 Arctic Blvd. Anchorage, AK 99502 Schlumberger Drilling and Measurements 3940 Arctic Blvd., Ste 300 Anchorage, AK 99503 Rob Crotty C/O CH2M HILL 301 West Nothern Lights Bird Anchorage, AK 99503 Cid Land Department PO Box 93330 Anchorage, AK 99503 Jack Laasch Natchiq Vice President Government Affairs 3900 C Street, Ste 701 Anchorage, AK 99503 John Harris NI Energy Development Tubular 3301 C Street, Ste 208 Anchorage, AK 99503 Mark Hanley Anadarko 3201C Street, Ste 603 Anchorage, AK 99503 Baker Oil Tools 4730 Business Park Blvd., #44 Anchorage, AK 99503 Judy Brady Alaska Oil & Gas Associates 121 West Fireweed Lane, Ste 207 Anchorage, AK 99503-2035 Greg Noble Bureau of Land Management Energy and Minerals 6881 Abbott Loop Rd Anchorage, AK 99507 Jeff Walker US Minerals Management Service Regional Supervisor 949 East 36th Ave., Ste 308 Anchorage, AK 99508 Jill Schneider US Geological Survey 4200 University Dr. Anchorage, AK 99508 Richard Prentki US Minerals Management Service 949 East 36th Ave., 3rd Floor Anchorage, AK 99508 Paul L. Craig Trading Bay Energy Corp 5432 East Northern Lights, Ste 610 Anchorage, AK 99508 Jim Scherr US Minerals Management Service Resource Evaluation 949 East 36th Ave., Ste 306 Anchorage, AK 99508 Chuck O'Donnell Veco Alaska,Inc. 949 East 36th Ave., Ste 500 Anchorage, AK 99508 Gordon Severson 3201 Westmar Cr. Anchorage, AK 99508-4336 Jim Ruud ConocoPhillips Alaska, Inc. Land Department PO Box 100360 Anchorage, AK 99510 Barbara Fullmer ConocoPhillips Alaska, Inc. Legal Department ATO 2084 PO Box 100360 Anchorage, AK 99510-0360 Jordan Jacobsen Alyeska Pipeline Service Company Law Department 1835 So. Bragaw Anchorage, AK 99515 Perry Markley Alyeska Pipeline Service Company Oil Movements Department 1835 So. Bragaw - MS 575 Anchorage, AK 99515 Robert Britch, PE Northern Consulting Group 2454 Telequana Dr. Anchorage, AK 99517 David Cusato 600 West 76th Ave., #508 Anchorage, AK 99518 Jeanne Dickey BP Exploration (Alaska), Inc. Legal Department PO Box 196612 Anchorage, AK 99518 Bill Bocast PACE Local 8-369 cio BPX North Slope, Mailstop P-8 PO Box 196612 Anchorage, AK 99519 Jack Hakkila PO Box 190083 Anchorage, AK 99519 Tesoro Alaska Company PO Box 196272 Anchorage, AK 99519 Kevin Tabler Unocal PO Box 196247 Anchorage, AK 99519-6247 BP Exploration(Alaska),lnc. Land Manager PO Box 196612 Anchorage, AK 99519-6612 Sue Miller BP Exploration (Alaska), Inc. PO Box 196612 Anchorage, AK 99519-6612 Dudley Platt D.A. Platt & Associates 9852 Little Diomede Cr. Eagle River, AK 99577 Bob Shavelson Cook Inlet Keeper PO Box 3269 Homer, AK 99603 Peter McKay 55441 Chinook Rd Kenai, AK 99611 Kenai Peninsula Borough Economic Development Distr 14896 Kenai Spur Hwy #103A Kenai, AK 99611-7000 Penny Vadla Box 467 Ninilchik, AK 99639 Marc Kovac PACE 8-369, Prudhoe Bay Vice-Chair PO Box 2973 Seward, AK 99664 James Gibbs PO Box1597 Soldotna, AK 99669 Claire Caldes US Fish & Wildlife Service Kenai Refuge PO Box 2139 Soldotna, AK 99669 Kenai National WildlifeRe~ge Refuge Manager PO Box 2139 Soldotna, AK 99669-2139 Richard Wagner PO Box 60868 Fairbanks, AK 99706 Cliff Burglin PO Box 131 Fairbanks, AK 99707 Harry Bader State of Alaska Department of Natural Resources 3700 Airport Way Fairbanks, AK 99709 Bernie Kad K&K Recycling Inc. PO Box 58055 Fairbanks, AK 99711 Williams Thomas Arctic Slope Regional Corporation Land Department PO Box 129 Barrow, AK 99723 North Slope Borough PO Box 69 Barrow, AK 99723 Kurt Olson State of Alaska Staff to Senator Tom Wagoner State Capitol Rm 427 Juneau, AK 99801 Lt Governor Loren Leman State of Alaska PO Box 110015 Juneau, AK 99811-0015