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HomeMy WebLinkAboutCO 145 AConservation 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. /_z~L~_~/~ Conservation Order Category Identifier Organizing (do,~,) RESC~ DIGITAL DATA OVERSIZED (Scannable with large plotter/scanner) [;;K Color items: [] Diskettes, No. [] Maps: [] Grayscale items: [] Other, No/Type [] Other items [] Poor Quality Originals: OVERSIZED (Not suitable for [] Other: plotter/scanner, may work with 'log' scanner) [] Logs of various kinds NOTES: ~, ~---~ [] Other MARIA Scanning Preparation TOTAL PAGES Production Scanning Stage I PAGE COUNT FROM SCANNED DOCUMENT: ~ PAGE COUNT MATCHES NUMBER IN SCANNING PREPARATION: Y' YES NO 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 Re: STATE OF ALASKA DEPARTMENT OF NATURAL RESOURCES Division of Oil and Gas Conservation 3001 Porcupine Drive Anchorage, Alaska 99501 The motion of the Alaska Oil ) and Gas Conservation Committee ) to hold a hearing to determine ) the amount of gas necessary ) for safety flares at the ) Prudhoe Bay Field and other ) matters related to gas flaring.) Conservation Order No.145-A Prudhoe Oil Pool Prudhoe Bay Field January 12, 1978 IT APPEARING THAT: le The Alaska Oil and Gas Conservation Committee published a notice of public hearing in the Anchorage Daily News on November 3, 1977, pursuant to Title 11, Alaska Administra- tion Code, Section 22.540. · A public hearing was held on November 29, 1977 in the Pioneer School House, Third and Eagle Streets, Anchorage, Alaska at which time operators were heard. The record of the hearing was held open until December 13, 1977. FINDINGS: i · Gas flared in the course of purging gas handling facilities and maintaining a safety flare is an operational necessity at production and related facilities to prevent an explosive mixture from occurring and to ignite any hydrocarbons that are vented during emergencies or operational upsets to avoid the risk of loss of life and property due to explosion and fire from hydrocarbon accumulation. , The field is in the early stages of production and many unexpected problems have arisen requiring that produced gas be flared to minimize the risk of loss of life and property. · Other new gathering centers or flow stations are to become operational within the next two years and it may be necessary to flare some gas during the commissioning and start up for these facilities. · Based on what is now known, the curtailment of production will not be detrimental to ultimate recovery. · Administrative approvals which have been issued to permit temporary flaring of gas for purging and commissioning of production equipment are no longer necessary. Conservation Order 145-A Page 2 CONCLUSIONS: Safety of personnel and property is a paramount consideration; therefore the volume of gas used for safety flares should be sufficient to ignite the unexpected gas volumes that need to be vented due to emergencies and mechanical upsets of pro- duction and related equipment. · Unforseen and unplanned upsets occur due to mechanical failures and human error and in some instances these neces- sitate the flaring of gas for safety or operational purposes requiring that provisions be made to permit flaring on a very limited basis. e Presently, curtailment of oil production should not impair ultimate recovery; therefore a delay in the curtailment of production, at a facility that is flaring in excess of the approved safety flar. e rate, until another facility can in- crease its production to offset the curtailment is not considered an acceptable practice. ~ Contin~u~.d~.surveilla~ce of flared volumes from each facility is neCeSsary to 'insure that flaring is kept to a minimum. ~ The Committee should retain administrative authority to order an increase or decrease in the volume of gas allowed to be flared for safety from each facility, as additional experience may indicate. 6. Administrative approvals 98-B.8 and 145.2 should be canceled. NOW, THEREFORE IT IS ORDERED THAT: Rule 1. The flaring of gas is approved to maintain safety flares and to permit purging of the gas handling equipment at the rates specified for the following facilities. The daily average rate shall be calculated on a monthly basis. Facility Approved Rate A. Gathering Center No. 1 B. Gathering Center No. 2 C. Gathering Center No. 3 D. Flow Station No. 1 E. Flow Station No. 2 F. Flow Station No. 3 G. Field Fuel Gas Unit and Central Compressor Plant 1,100 MCF/D 1,100 MCF/D 1,100 MCF/D 1,000 MCF/D 1,000 MCF/D 1,000 MCF/D 1,000 MCF/D Rule 2. .After the commencement of any flaring incident at any facility arising from an emergency or operational Conservation Order No. 145-A Page 3 Rule 3. Rule 4. Rule 5. Rule 6. necessity, the Operator shall take the following action: ne Initiate appropriate action and procedures so that flaring can be terminated as soon as reasonably possible and the flaring can be minimized during the flaring period. B. Production shall be curtailed to minimize flaring as soon as reasonably possible. Flaring as a result of an emergency or operational necessity shall not be permitted longer than a total of twelve (12) hours after the commencement of each such incident without, approval of the Committee or its designated representative. Upon the request of the Operator to flare for more than a total of twelve (12) hours, a member of the Committee or its designated representative may verbally approve the request for a period not to exceed five (5) days beyond the twelve (12) hour period provided for in Rule 3. The following information shall be given to the Committee or its designated representative upon re- quest'for such approval; A. The facility at Which the flaring is occurring. B. Description of the flaring incident and cause. C. Time of commencement. D. Estimated time of termination. E. Volume of gas flared. F. Estimate of gas volume to be flared. G. Action being taken to minimize and eliminate' flaring. A request in writing must be submitted by the Operator in order to obtain written administrative approval to flare beyond the period provided in Rule 4. On a monthly basis the Operator shall submit a written report to the Committee on all flaring incidents that result from an emergency or operational necessity. The report shall be due by the 20th day of the month follow- ing the reporting mOnth. The report shall contain the following information for each flaring incident. A. The facility at which the flaring occurred. B. Time of commencement and termination of flaring. C. Description of the flaring incident and cause. D. Volume of gas flared. E'.' Action taken to eliminate the cause for the flaring incident. Conservation Order No. 145-A Page 4 Rule 7. Following a ten (10) day notice to the operator of any production facility the Committee may change the volumes of gas allowed to be flared for safety. Rule 8. Administrative approvals 98-B.8 and 145.2 are hereby canceled. DONE at Anchorage, Alaska and dated January 12, 1978. Thos. R. Marshall, Jr Executive Secretary Alaska Oil & Gas Conservation Committee Concurrence: 0 K ~iIbreth, Jr , ~irman Alaska Oil & Gas Conservation Committee Ho~le ~ Hamilton, Member Alaska-Oil & Gas Conservation Committee ALASKA OIL AND GAS November 29, ~NSERVATION COMMISSION WALTER.. J. HICK_EL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907):179-1435 TELECOPY: (907)276-7542 ADMINISTRATIVE APPROVAL NO. 145-A. 128 · . Additional flarevolume, Flow Station 2, Prudhoe Bay Unit, Eastern Operating Area. Mr. W. R. Worthington, EOC Supervisor Prudhoe Bay Operations ARCO Alaska, Inc. P. O. Box 10{)360 Anchorage, Alaska 99510-0360 Dear Mr. Worthington: We have received yonr letter of November 7, 1994 requesting additional flare volmne for thc Flow Station 2 (FS-2) facility in thc Eastern Operating Area of the Prudhoe Bay Unit. The additional flare volume is required during scheduled shntdown of FS-2 to facilitate repairs to the flare system. Thc Commission approves flaring up to 5 MMcf of gas over and above the designated safety flare at Flow Station 2. Flaring is scheduled to begin on or about December 12, 1994 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. DONE at Anchorage, Alaska and dated November 29, 1994. , ~lj~kda ~'~io1~ CommissiOn -Russell A. Douglass,' Commissionert~r Alaska Oil and Gas Conservation Commission erman Babcock, Commissioner ska Oil and Gas Conservation Commission ALASKA OIL AND GAS CONSERVATION COMMISSION WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 August 23, 1994 ADMINISTRATIVE APPROVAL NO. 145-A. 127 Re: Additional flare volume, Eastern Operating Area, Prudhoe Bay Unit, Eastern Operating Area. Mr. W. R. Worthington, EOC Supervisor Prudhoe Bay Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorage, Alaska 99510-0360 Dear Mr. Worthington: We have received your letter of August 23, 1994 requesting additional flare volume for Eastern Operating Area (EOA) facilities ( Flow Station 1 and Central Gas Facility) of the Prudhoe Bay Unit. The additional flare volume is required during scheduled maintenance activities and GHX-2 tie-ins. Operations scheduled at Flow Station 1 include Drill Site 2 commonline tie-in and testing of the new safety flare system. Operations scheduled at the Central Gas Facility include commissioning Cf the new tandem compressors, start-up of LTS-3 and the Stabilizer Feed Preheater tie-ins. The commission approves flaring up to 503 MMcf of gas over and above the designated safety flare at Flow Stations 1 and 150 MMcf of gas over and above the designated safety flare of the Central Gas Facility. Flaring is scheduled to begin on or about September 1, 1994 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of approved safety flare volumes is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass Commissioner BY ORDER OF THE COMMISSION ~4;~) print'ed on recycled paper b y C.D. ALASKA OIL AND GAS CONSERVATION COMMISSION WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 August 18, 1994 ADMINISTRATIVE APPROVAL NO. 145-A.126 Re~ Additional flare volume, Central Compressor Plant, Prudhoe Bay Unit, Eastern Operating Area. Mr. W. R. Worthington EOC Supervisor, Prudhoe Bay Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorage, Alaska 99510-0360 Dear Mr. Worthington: We have received your letter of August 16, 1994 requesting additional flare volume for the Central Compressor Plant (CCP) in the Eastern Operating Area of the Prudhoe Bay Unit. The additional flare volume is needed during repair of the CCP's high pressure flare system. The commission hereby approves flaring up to 70.0 MMcf of gas over and above the designated safety flare of theCCP. Flaring is expected to commence August 23, 1994 and continue until repairs are complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1000 Mcf/d safety flare volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass Commissioner BY ORD.ER OF TH.E 'COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 July 18, 1994 ADMINISTRATIVE APPROVAL NO. 145-A. 125 Re: Additional flare volume, Gathering Center No. 1 Prudhoe Bay Unit, Western Operating Area. Alison D. Cooke BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, AK 99519-6612 Dear Ms. Cooke: We have received your letter of July 12, 1994 requesting additional flare volume for Gathering Center No. 1 (GC-1) in the Western Operating Area of the Pmdhoe Bay Unit. The additional flare volume will be associated with testing of the intermediate pressure compressors. Testing is necessary to confirm viability of plant debottlenecking modifications. The Commission approves flaring up to 40 MMcf of gas over and above the designated safety flare volume of GC-1. Flaring is expected to commence on or about July 20, 1994 and continue until work is complete. It is understood that gas flaring will be kept to a minimum wheneVer possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1100 Mcf/d safety flare and purge volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or Used for lease operation. Sincerely, Russell A. Douglass Commissioner BY ORDER OF THE COMMISSION [,~C~ I)rirm::d on recycled I)~lr)~)r b '/C. !') ALASKA OIL AND GAS · CONSERVATION COMMISSION Jurie 6, 1994 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-14,33 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A.124 Re: Additional flare volume, Gathering Center No. 2 Prudhoe Bay Unit, Western Operating Area. Alison D. Cooke BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, Alaska 99519-6612 Dear Ms. Cooke: We have received your correspondence of June 3, 1993 requesting additional flare volume for Gathering Center No. 2 (GC2) in the Western Operating Area of the Prudhoe Bay Unit. The additional flare volume is associated with planned maintenance of the GC2 intermediate pressure and low pressure gas compressors. The Commission hereby approves flaring up to 40 MMcf of gas over and above the designated safety flare and purge volume of GC2. Additional flaring is expected to commence on or about June 27, 1994 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1100 Mcf/d safety flare and purge volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass Commissioner BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION May 17, 1994 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A.123 Rc~ Additional flare volume, Eastern Operating Area, Prudhoc Bay Unit, Eastern Operating Area. Mr. W. R. Worthington EOC Supervisor Prudhoe Bay Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorage, Alaska 99510-0360 Dear Mr. Worthington: We have received your letter of March 25, 1994, requesting additional flare volume for Eastern Operating Area (EOA) facilities Flow Station 1, Central Gas Facility and Central Compression Plant (FS 1, CGF, and CCP) of the Pmdhoe Bay Unit. The additional flare volume is required during a plmmed shutdown of FS-1 to facilitate tie-ins and modifications for the GHX-2 phase 2 grenex project. During the FS-1 shut-in fl~e high stage T/C 1809 will be shutdown for a combustion inspection and the CGF will shutdown the new tandem T/C's for discharge valve repairs. The Commission hereby approves flaring up to 16 MMcf of gas over and above the designated safety flare of flaese EOA facilities. Flaring is scheduled to begin on or about June 2, 1994 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Conunission fom~ 10-422. All gas produced in excess of the 5000 Mcf/d safety flare volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass Commissioner BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION April 13, 1994 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A. 122 Re~ Additionai flare volume, Eastern Operating Area, Prudhoe Bay Unit, Eastern Operating Area. . Mr. W. R. Worthington EOC Supervisor Pmdhoe Bay Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorage, Alaska 99510-0360 Dear Mr. Worthington: We have received your letter of March 25, 1994, requesting additional flare volume for all Eastern Operating Area (EOA) facilities' (FS 1, FS2, FS3, CGF, AND CCP) of the Prudhoe Bay Unit. The additional flare volume is required during a planned TAPS shutdown to facilitate a valve change out in Valdez. Operations scheduled during the shutdown/slowdown of PBU production include Spring water washes of the CCP turbine/compressors and major tie-ins to accomodate GHX-2 tie-ins. Tile Commission hereby approves flaring up to 309 MMcf of gas over and above tile designated safety flare of the EOA facilities. Flaring is scheduled to begin on or about April 15, 1994 and continue until work is complete. '. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska. Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 7000 Mcf/d safety flare volume is subject to AS.43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass Colnmissioner BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION December 30, 1993 .,WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-$19~. PHONE: (907) 279.1433 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A.121 Re' Additional flare volume, Gathering Center No. 2 Prudhoe Bay Unit, Western Operating Area. Alison D. Cooke BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, Alaska 99519-6612 Dear Ms. Cooke: We have received your correspondence of December 20, 1993 requesting additional flare volume for Gathering Center No. 2 (GC2) in the Western Operating Area of the Prudhoe Bay Unit. The additional flare volume is associated with flare capacity testing in preparation for installing an automated flare capacity alarm system. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 150 MMcf of gas over and above the designated safety flare and purge volume of GC2. Additional flaring is expected to commence on or about January 11, 1994 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volmnes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1100 Mcf/d safety flare and purge volume is subject to AS 43.55.020, and will be disposed ofin a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass Commissioner BY ORDER OF THE COMMISSION December 29, 1993 WALTER J. HICKEL, GOVEFtNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A.120 Re: Additional flare volume, Gathering Center No. 1 Prudhoe Bay Unit, Western Operating Area. Alison D. Cooke BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, Alaska 99519-6612 Dear Ms. Cooke: We have received your letter of December 21, 199'3 requesting additional flare volume for Gathering Center No. 1 (GC-1) in the Western Operating Area of the Prudhoe Bay Unit. The additional flare volume will be associated with the repair of the K107 intermediate pressure compressor. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 120 MMcf of gas over and above the designated safety flare and purge volume of GC- 1. This operational flaring is expected to commence on or about January 1, 1994 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1100 Mcf/d safety flare and purge volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass Commissioner BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION November 23, 1993 ADMINISTRATIVE APPROVAL NO. 145-A. 119 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 Re: Additional flare volume, Gathering Center No. 1 Prudhoe Bay Unit, Western Operating Area. Alison D. Cooke BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, Alaska 99519-6612 Dear Ms. Cooke: We have received your letter of November 19, 1993 requesting additional flare volume for Gathering Center No. 1 (GC-I.) in the Western Operating Area of the Pnldhoe Bay Unit. The additional flare volume will be associated with the GC-I Annex capacity test. The test objective is to assess whether equipment modifications are required to the Annex to reach its gas throughput design capacity based on dehydration performance° Operations are expected to commence on or about November 29, 1993 and are expected to continue for two days. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 25 MMSCFD of gas for each of the two days. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska. Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1100 Mcf/d safety flare volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION November 9, 1993 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-319~. PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A.118 Re: Additional flare volume, Gathering Center No. 1 Prudhoe Bay Unit, Western Operating Area. Alison D. Cooke BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, Alaska 99519-6612 iDear Ms. Cooke: We have received your letter of November 9, 1993 requesting additional flare volume for Gathering Center No. 1 (GC-1) in the Western Operating Area of the Prudhoe Bay Unit. The additional flare volume will be associated with the repair of leaking valves on the intermediate pressure and low pressure compressors. To facilitate these repairs the compressors must be taken off line. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 150 MMcf of gas over and above the designated safety flare of GC-1. This operational flaring is expected to commence on or about November 9, 1993 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1100 Mcf/d safety flare volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Dougla~ Commissioner BY ORD.ER OF TIlE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION November 8, 1993 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A.117 Re: Additional flare volume, Gathering Center No. 3, Prudhoe Bay Unit, Western Operating Area. Alison D. Cooke BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, Alaska 99519-6612 Dear Ms. Cooke: We have received your letter of November 8, 1993 requesting written confirmation of additional flare volume for Gathering Center 'No. 3 (GC3) in the Western Operating Area of the Prudhoe Bay Unit Verbally granted on November 6, 1993. The additional flare volume is needed during facility shutdown and repairs due to a compressor leak. The Commission hereby approves flaring up to 150 MMcf of gas over and above the designated safety flare of GC3. Operations commenced on November 6, 1993 and will continue until work is complete. .It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1100 Mcf/d safety flare volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass Commissioner BY ORDER O.F THE COMMISSION WALTER J. HICKEL, GOVERNOR ALASKA OIL AND GAS CONSERVATION COMMISSION September 7, 1993 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A. 116 Re: Additional flare volume, Gathering Center No. 1 Prudhoe Bay Unit, Western Operating Area. Alison D. Cooke BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, AK 99519-6612 Dear Ms. Cooke: We have received your letter of August 27, 1993 requesting additional flare volume for Gathering Center No. 1 (GC-1) in the Western Operating Area of the Prudhoe Bay Unit. The additional flare volume will be associated with testing of the new Gas Handling Expansion Two (GHX-2) Project flare system at GC-1 during commissioning of the new Annex. Objectives of the test include verification of capacity and backpressure of the first and second stage flares, checking operation of flare valves, verifying smokeless flaring and recording ground temperatures during flaring. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 1200 MMcf of gas over and above the designated safety flare of GC-1. This operational flaring is expected to commence on or about September 7, 1993 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1100 Mcf/d safety flare volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Yours very truly, Russell A. Douglass Commissioner BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION September 9, 1993 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A. 115 Re: Additional flare volume, Eastern Operating Area, Prudhoe Bay Unit, Eastern Operating Area. Mr. W. R. Worthington, EOC Supervisor Prudhoe Bay Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorage, Alaska 99510-0360 Dear Mr. Worthington: We have received your letter of August 28, 1993 requesting additional flare volume for Eastern Operating Area (EOA) facilities (Flow Station 3 and Central Gas Facility) of the Prudhoe Bay Unit. The additional flare volume is required during scheduled maintenance activities and GHX-2 tie-ins. Operations scheduled include shutdown and startup of Flow Station 3 for inlet manifold tie-ins for the GHX-2 project and planned maintenance on the gas dehydration equipment and partial shutdown of the Central Gas Facility in conjunction with the 4938 inlet module/60" gas transit lines shut-down for the GHX-2 project tie-ins. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 2 MMcf of gas over and above the designated safety flare at Flow Stations 3 and 300 MMcfofgas over and above the designated safety flare of the Central Gas Facility. Flaring is scheduled to begin on or about September 10, 1993 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of approved safety flare volumes is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Dougla8~~~~'~~ Commissioner BY ORDER OF THE COMMISSION July 9, 1993 ALASKA OIL AND GAS CONSERVATION COMMISSION WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A. 114 Re; Additional flare volume, Gathering Center No. 3, Prudhoe Bay Unit, Western Operating Area. Alison D. Cooke BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, Alaska 99519-6612 Dear MS. Cooke: We have received your letter of June 23, 1993 requesting additional flare volume for Gathering Center No. 3 (GC3) in the Western Operating Area of the Prudhoe Bay Unit. The additional flare volume is needed during scheduled maintenance of the facility. Maintenance operations will include LPS turbine preventive maintenance, turbine water wash, miscellaneous repairs to the LPS system, and repairs to one TEG reboi!er. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 250 MMcf of gas over and above the designated safety flare of GC3. Operations are expected to commence on or about July 26, 1993 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1100 Mcf/d safety flare volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass Commissioner BY ORDER OF THE COMMISSION , ..,prjr~ted on rec¥cletl paF)er b y CiD, July 9, 1993 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A. 113 Re: Additional flare volume, Gathering Center No. 1 Prudhoe Bay Unit, Western Operating Area. Alison D. Cooke BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, Alaska 99519-6612 Dear Ms. Cooke: We have received your letters of June 23, 1993 requesting additional flare volume for Gathering Center No. 1 (GC l) in the Western Operating Area of the Prudhoe Bay Unit. The additional flare volume is required during planned maintenance activity for the facility. Maintenance operations include installation of demister pads and new distributors in both TEG contactors, repairs to the waste heat recovery systems and both LPS turbines, scheduled preventive maintenance on one LPS turbine/compressor package and preventive maintenance on the LPS fin-fan units. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 1200 MMcf of gas over and above the designated safety flare of GC1. This operational flaring is exl~ected to commence on or abOut July 12, 1993 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and ail volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1100 Mcf/d safety flare volume is Subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass, Commissioner BY ORDER OF THE COMMISSION ~'~.~. printed on recycled pa per b y C,¢3. WALTER J. HIC, KEL, GOVERNOR ALASKA OIL AND GAS CONSERVATION COMMISSION June 15, 1993 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501.-3192 PHONE: (907) 279-1433 TELECOPY: (907) 2767542 ADMINISTRATIVE APPROVAL NO':~,'~4~Pi,.'I 12 Re: Additional flare volume Eastern Operating Area, Prudhoe Bay Unit.' Mr. J. A. Minier, EOC Supv Prudhoe Bay Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorage, AK 99510-0360 Dear Mr. Minier: We have received your letters of May 16 and 24, 1993 requesting additional flare volume for Eastern Operating Area (EOA) facilities of the Prudhoe Bay Unit. The additional flare volume is required during scheduled maintenance activities and GHX-2 tie-ins. Operations scheduled include shutdown and startup of Flow Stations 1 (FS 1) and 3 (FS 3).for inspection purposes during facility tie-in work for the GHX-2 project; recertification and modifications on A-Train vessels; smart pigging operations on production commonlines 4C and 16/17C at Flow Station 2 (FS 2); and shutdown of the Central Gas Facility (CGF) for GHX-2 tie-ins. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 2 MMcf of gas over and above the designated safety flares ofFS 1 and 3; 5 MMcf of gas over and above the designated safety flare ofFS 2, and 500 MMcf of gas over and above the designated safety flare of the CGF. Flaring is scheduled to begin on or about July 10, 1993 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of approved safety flare volumes is subject to AS 43.55.020, and will be disposed.of in a safe manner by flaring or used for lease operation. Yours very truly, Russell A. Douglass Commissioner BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION April 7, 1993 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE. ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A.11 l(revised) Re: Additional flare volume, Gathering Center No. 3, Prudhoe Bay Unit, 'Western Operating Area. Alison D. Cooke BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, Alaska 99519-6612 Dear Ms. Cooke: We have received your letter of March 26, 1993 requesting additional flare volume for Gathering Center No. 3 (GC3) in the Western Operating Area of the Prudhoe Bay Unit. The additional flare volume is needed during shutdown of the K-7000 LPS compressor for combustion and inlet guide vane inspections, a turbine water wash and waste heat recovery ducting repairs. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 900 MMcf of gas over and above the designated safety flare of GC3o Operations are expected to commence on or about April 7, 1993 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1100 Mcf/d safety flare volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. This approval supersedes AA 145-A. 111 issued March 31, 1993, since a transposition error incorrectly set the approved flare volume at 100 MMcf. Sincerely, Russell A Douglass, Commissioner BY ORDER OF THE COMMISSION ,, ~ printed on recycled psper b y C~D. ALASKA OIL AND GAS CONSERVATION COMMISSION March 31, 1993 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 Re: ADMINISTRATIVE APPROVAL~ Additional flare volume, Gathering Center No. 3, Prudhoe Bay Unit, Western Operating Area. Alison D. Cooke BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, Alaska 99519-6612 Dear Ms. Cooke: We have received your letter of March 26, 1993 requesting additional flare volume for Gathering Center No. 3 (GC3) in the Western Operating Area of the Prudhoe Bay Unit. The additional flare volume is needed during shutdown of the K-7000 LPS compressor for combustion and inlet guide vane inspections, a turbine water wash and waste heat recovery ducting repairs. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 100 MMcf of gas over and above the designated safety flare of GC3. Operations are expected to commence on or about April 7, 1993 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1100 Mcf/d safety flare volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, RusSell A. Douglass Commissioner BY ORDER OF THE COMMISSION ~) printed on recycled paper b y G. t3. ALASKA OIL AND GAS CONSERVATION COMMISSION March 31, 1993 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 Re: ADMINISTRATIVE APPROVA~ Additional flare volume, Gathering Center No. 1 Prudhoe-B3y Unit, Western Operating Area. Alison D. Cooke BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, Alaska 99519-6612 Dear Ms. Cooke: We have received your letters of March 26 and 29, 1993 requesting additional flare volume for Gathering Center No. 1 (GC 1) in the Western Operating Area of the Prudhoe Bay Unit. The additional flare volume is required to facilitate repairs to the K7001 LPS inertial separator. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 300 MMcf of gas over and above the designated safety flare of GC 1. This operational flaring is expected to commence on or about April 4, 1993 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1100 Mcf/d safety flare volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass Commissioner BY ORDER OF THE COMMISSION ~ printed on recycled paper b y C~ O, ALASKA OIL AND GAS CONSERVATION COMMISSION March 23, 1993 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 Re~ AD'MINISTRATIVE APPROVA~~'~ Additional flare volume, Gathering Center No. 3, Prudhoe Bay Unit, Western Operating Area. Alison D. Cooke BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, Alaska 99519-6612 Dear Ms. Cooke: We have received your letter of October 6, 1992 requesting additional flare volume for Gathering Center No. 3 (GC3) in the Western Operating Area of thePrudhoe Bay Unit. The additional flare volume is needed during shutdown and inspection of the K-7000 LPS compressor. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 100 MMcf of gas over and above the designated safety flare of GC3. Operations are expected to commence on or about March 23, 1993 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1100 Mcf/d safety flare volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass Commissioner BY ORDER OF THE COMMISSION ~:~ printed on recycled paper ALASKA OIL AND GAS CONSERVATION COMMISSION February 4, 1993 Re; WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. ~ Additional flare volume, Gathering Center No. 2 Prudhoe Bay Unit, Western Operating Area. Alison D. Cooke, Environmental Scientist Environmental & Regulatory Affairs, Alaska BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, Alaska 99519-6612 Dear Ms. Cooke: We have received your correspondence of January 26, 1993, requesting additional flare volume for Gathering Center No. 2 (GC2) in the Western Operating Area of the Prudhoe Bay Unit. The additional flare volume is associated with repair and replacement of corroded wet gas piping' requiring shutdown of the GC2 gas plant. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 1.3 MMMcf of gas over and above the designated safety flare of GC2. Additional flaring is expected to commence on or about February 14, 1993 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1100 Mcf/d safety flare volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass, Commissioner BY ORDER OF THE COMMISSION r~ printed on recycled paper b y '1 WALTER J. HICKEL, GOVERNOR ALASKA OIL AND GAS CONSERVATION COMMISSION December 30, 1992 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A.107 Re .' Additional flare volume, Gathering Center No. 1 Prudhoe Bay Unit, Western Operating Area. Alison D. Cooke BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, Alaska 99519-6612 Dear Ms. Cooke: We have received your letters of December 15, and December 23, 1992 requesting additional flare volume for Gathering Center No. 1 (GC1) in the Western Operating Area of the Prudhoe Bay Unit. The additional flare volume is required to facilitate installation of demister pads in the gas dehydration contactors at GC1. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 5500 MMcf of gas over and above the designated safety flare of GC1. This operational flaring is expected to commence on or about January 15, 1993 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1100 Mcf/d safety flare volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Commissioner BY ORDER OF TIlE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION November 13, 1992 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A.106 Re.' Additional flare volume, Gathering Center No. 1 Prudhoe Bay Unit, Western Operating Area. Alison D. Cooke BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, Alaska 99519-6612 Dear Ms. Cooke: We have received your letter of November 11, 1992 requesting additional flare volume for Gathering Center No. I (GC1) in the Western Operating Area of the Prudhoe Bay Unit. The additional flare volume is required to facilitate replacement of hydraulic oil filters on the LPS Compressor and inspection and repair of waste heat recovery unit ducting. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 300 MMcf of gas over and above the designated safety flare of GC1. Additional flaring is expected to commence on or about November 18, 1992 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the ll00 Mcf/d safety flare volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. · ioner BY ORDER OF THE COMMISSION ALASKA OIL AND GAS / CONSERVATION COMMISSION / WALTER J. HICKEL, GOVERNOR -,. 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-14,.'.'~ TELECOPY: (907) 276-7542 October 7, 1992 i ADMINISTRATIVE APPROVAL NO. 145-A.105 Re: Additional flare volume, Gathering Center No. 3, Prudhoe Bay Unit, Western Operating Area. Alison D. Cooke BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, Alaska 99519-6612 Dear Ms. Cooke: We have received your letter of October 6, 1992 requesting additional flare volume for Gathering Center No. 3 (GC3) in the Western Operating Area of the Prudhoe Bay Unit. The additional flare volume is needed during repair of a flange leak on the K-7000 LPS compressor and to complete maintenance activities on the LPS compressor. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 1.1 MMMcf of gas over and above the designated safety flare of GC3. Operations are expected to commence on or about October 7, 1992 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1100 Mcf/d safety flare volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass, Commissioner BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION September 15, 1992 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99,501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A.104 Re: Additional flare volume, Gathering Center No. 2 Prudhoe Bay Unit, Western Operating Area. Alison D. Cooke, Environmental Scientist Environmental & Regulatory Affairs, Alaska BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, Alaska 99519-6612 Dear Ms. Cooke: We have received your correspondence of September 2, 1992, requesting additional flare volume for Gathering Center No. 2 (GC2) in the Western Operating Area of the Prudhoe Bay Unit. The additional flare volume is associated with repairs to a leaking valve in the waste heat recovery system. During the valve repair the low pressure system compressors must be shut down and then restarted and calibrated when repair is complete. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 1900 MMcf of gas over and above the designated safety flare of GC2. Additional flaring is expected to commence on or about September 26, 1992 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1100 Mcf/d safety flare volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass~, Commissioner BY ORDER OF THE COMMISSION ~ printed on recycled peper b y August 31, 1992 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A.103 Re.' Additional flare volume, Gathering Center 3, Prudhoe Bay Unit, Western Operating Area. Ms. Alison D. Cooke, Environmental Scientist Environmental & Regulatory Affairs, Alaska BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, Alaska 99519-6612 Dear Ms. Cooke: We have received your letters of August 20 and 24, 1992 requesting additional flare volume, for Gathering Center 3(GC3) in the Western Operating Area (WOA) of the Prudhoe Bay Unit. The additional flare volume' is needed during scheduled repairs of the K-7001 compressor which requires shut down .of the unit. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 1.5 MMMcf of gas over and above the designated safety flare of GC3. Operations are expected to commence on or about September 1, 1992 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be. reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess' of the 1100 Mef/d safety flare volume is subject to AS 43.55.020, and. will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass Commissioner BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION August 7, 1992 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-14.33 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A.102 Re.' Additional flare volume, Gathering Centers 1, 2 'and 3, Prudhoe Bay Unit, Western Operating Area. Mr. Steven D. Taylor, Environmental & Regulatory Affairs, Alaska BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, Alaska 99519-6612 Dear Mr. Taylor: We have received your letter of August 6, 1992 requesting additional flare volume for all of the Gathering Centers 'in the Western Operating Area (WOA) of the Prudhoe Bay Unit. The additional flare volume is necessary to put the WOA 60" gas line back into service. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up~ to 100 MMcf of gas over and above the designated safety flare of the WOA Gathering Centers. Repairs are expected to commence on or about August 9, 1992 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 3300 Mcf/d safety flare volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A Douglass Commissioner BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION July 28, 1992 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A.101 Re: Additional safety flare volume, Gathering Center No. 2, Prudhoe Bay Unit, Western Operating Area. Mr. Steven D. Taylor, Manager Environmental & Regulatory Affairs, Alaska BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, Alaska 99519-6612 Dear Mr. Taylor: We have received your correspondence of July 22, 1992 requesting additional flare volume for Gathering Center No. 2 (GC2) in the Western Operating Area of the Prudhoe Bay Unit. The additional flare volume is associated with repairs to the intermediate pressure (IP) and low pressure (LP) compressors. Verbal approval for the flaring associated with repairs on the K-206 unit was given by Blair Wondzell on July 20, 1992 per Conservation Order 145-A Rule 4. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 150 MMcf of gas over and above the designated safety flare of GC2. Additional flaring commenced on July 20, 1992 and will continue until wOrk is complete. It is understood that gas flaring will 'be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission fOrm 10-422. All gas produced in excess of the 1100 Mcf/d safety flare volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass Commissioner BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION July 28, 1992 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A.100 Re .' Additional flare volume, Gathering Centers 1, and 2 Prudhoe Bay Unit, Western Operating Area. Ms. Alison D. Cooke, Environmental Scientist Environmental & Regulatory Affairs, Alaska BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, Alaska 99519-6612 Dear Ms. Cooke: We have received your letter of July 24, 1992 requesting additional flare volume for Gathering Centers I and 2 in the Western Operating Area (WOA) of the Prudhoe Bay Unit. The additional flare volume is associated with the restart of the 60 inch line from GC-1 to the CGF. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 100 MMcf of gas over and above the designated safety flare of the WOA Gathering Centers 1 and 2. Flaring is scheduled to begin on or about August 7, 1992, and continue until the work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 2200 Mcf/d safety flare volume, is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass Commissioner BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION July 28, 1992 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A.99 Re: Additional flare volume, Eastern Operating Area and Western Operating Area, Prudhoe Bay Unit. Mr. D. B. Montgomery, EOC Supervisor Prudhoe Bay Operations ARCO Alaska, Inc.. P. O. Box 100360 Anchorage, Alaska 99510-0360 Dear Mr. Montgomery: We have received your letter of July 7, 1992, requesting additional flare volume for all Eastern Operating Area (EOA) facilities (FS1, FS2, FS3, CGF, and CCP) and Western Operating Area (WOA) facilities (GC-1, GC-2, and GC-3) of the Prudhoe Bay Unit.. The additional flare volume is required while tying in a new 36" by-pass line to the CCP Tandem Compressors from the 60" transmission line and shutting down the CGF Booster Compressors for the second port-a-test tie in. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 100 MMcf of gas over and above the designated safety flare of the EOA and WOA facilities. Flaring is scheduled to begin on or about August 7, '1992, and continue until the work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 10,300 Mcf/d safety flare volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglasg' Commissioner, BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION July 10, 1992 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 Re: ADMINISTRATIVE APPROVAL NO. 145-A.98 Additional safety flare volume, Gathering Center No. 2 Prudhoe Bay Unit, Western Operating Area. Mr. Steven D. Taylor Environmental & Regulatory Affairs, Alaska BP Exploration (Alaska) Inc, P. O. Box 196612 Anchorage, Alaska 99519-6612 Dear Mr. Taylor: We have received your correspondence of June 9 and 22~ 1992, requesting additional flare volume for Gathering Center No. 2 (GC2) in the Western Operating Area of the Prudhoe Bay Unit. The additional flare volume is associated with a planned shutdown of the GC2 plant'on August 6-10, 1992. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 500 MMcf of gas over and above the designated safety flare of GC2. Additional flaring is expected to commence on or about August 6, 1992 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1100 Mcf/d safety flare volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass Commissioner' BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION April 27, 1992 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-14,...33 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A.97 Re: Additional flare volume, Gathering Center No. 1 Prudhoe Bay Unit, Western Operating Area. Mr. Steven D. Taylor Environmental & Regulatory Affairs, Alaska BP Exploration (.Alaska) Inc. P. O. Box 196612 Anchorage, Alaska 99519-6612 Dear Mr. Taylor: We have received your letter of July April 27, 1992, requesting additional flare 'volume for Gathering Center No. I (GC1) in the Western Operating Area of the Prudhoe Bay Unit. The additional flare volumes are required to facilitate repairs to a corroded pipe plug in the low pressure gas header. The Commission finds 'the additional flare volume to be an operational necessity, and hereby approves flaring up to 5 MMcf of gas over and above the designated safety flare of GC1. Additional flaring is expected to commence on or about April 27, 1992 and continue until work is complete. It is understoOd that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1100 Mcf/d safety flare volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease 'operation. Sincerely, Russell A. Douglass Commissioner BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION April 24, 1992 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1~ TELECOPY: (907) 2767542 ADMINISTRATIVE APPROVAL NO. 145-A.96 Re' Additional flare volume, Central Compressor Plant, Prudhoe Bay Unit, Eastern Operating Area. Mr. W. R. Worthington EOC Supervisor, Prudhoe Bay OPerations ARCO Alaska, Inc. P.'O. Box 100360 Anchorage, Alaska 99510-0360 Dear Mr. Worthington: ... We have received your letter of April .23, 1992, requesting additional flare volume for the Central ComPressor Plant (CCP) in the Eastern operating Area of the Prudhoe Bay' Unit. The additional' flare volume is in conjunction with .maintenance work that was recognized by the commission as operational necessity in AA 145-A.95. The Commission still finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 15.0 MMcf of . gas over and above the designated safety flare of the CCP. Flaring is expected to commence April 24, 1992 and continue until testing is complete. It is understood that gas flaring 'will be kept to a minimum whenever possible, and all volumes will be reported, monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1000 Mcf/d safety flare volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass Commissioner BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION April 16, 1992 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-14,33 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A.95 Re: Additional flare volume, Eastern Operating Area, Prudhoe Bay Unit, Eastern Operating Area. Mr. W. R. Worthington EOC Supervisor Prudhoe Bay Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorage, Alaska 99510-0360 Dear Mr. Worthington: We have received your letter of March 31, 1992, reqUesting additional flare volume for Eastern Operating Area (EOA) facilities (FSl, FS2, FS3, and CCP) of the Prudhoe Bay Unit. The additional flare volumes at FS1, FS2, and FS3 are required in conjunction with required maintenance and modifications to the 'A' & 'B' oil trains and the LPS gas train at FS2, and fieldwide smart pigging operations, on production commonlines. The additional flare volume at the CCP is required during annual turbine maintenance and installation of an anti-bog down valve on T/C 1808. The Commission finds the additional flare volumes to be an operational necessity, and hereby approves flaring up to; 4 MMcf at FS1, 20 MMcf at FS2, 10 MMcf at FS3 and 10 MMcf at the CCP over and above the designated safety flare pilots of the individual EOA facilities. Flaring is scheduled to begfn on or about April 19, 1992 and contihue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the individual safety flare pilot volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass Commis s ioner BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276,-7542 April 16, 1992 Re: ADMINISTRATIVE APPROVAL NO. 145-A.94 Additional flare volume, Gathering Center No. 3, Prudhoe Bay Unit, Western Operating Area. Mr. Steven D. Taylor, Manager Environmental &.Regulatory Affairs, Alaska BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, Alaska 99519-6612 Dear Mr. Taylor: We have received your letter of April 1, 1992 requesting additional flare volume for Gathering Center No. 3 (GC3) in the Western Operating Area of the Prudhoe Bay Unit. The additional flare volume is required during maintenance activities required to place, the E-364 gas to gas exchanger b~ck in service. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 100 MMcf of gas over and above the designated safety flare pilot of GC3. Operations are expected to commence on or about May 8, 1992 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1100 Mcf/d safety flare pilot volume is Subject to AS 43'.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass Commissioner BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION February 28, 1992 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501.3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A.93 Re.' Additional flare volume, Gathering Center No. 3, Prudhoe Bay Unit, Western Operating Area. Mr. Steven D. Taylor, Manager Environmental & Regulatory Affairs, Alaska BP Exploration (Alaska) Inc. P. O..BOx 196612 Anchorage, Alaska 99519-6612 Dear Mr. Taylor: We have received your letter of February 25, 1992 requesting additional flare volume for Gathering Center No. 3 (GC3) in the Western Operating Area of the Prudhoe Bay Unit. The additional flare 'volume is required while isolating equipment to perform maintenance on gas plant heat exchangers.. The Commission finds the additional flare volume to be an operational' necessity, and hereby approves flaring up to 20 MMcf of gas over and above the designated safety flare pilot of GC3. Operations are expected to commence on or about February .28, 1992 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422.' All gas produced' in excess of the 1100 Mcf/d safety flare pilot volume is subject to AS 43.55.020, and will. be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass Commissioner BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION February 10, 1992 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A.92 Re: Additional flare volume., Gathering Center No. 3, Prudhoe Bay Unit, Western Operating Area. Mr. Steven D. Taylor Environmental & Regulatory Affairs, Alaska BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, Alaska 99519-6612 Dear Mr. Taylor: We have received your letter of February 6, 1992 requesting additional flare volume for Gathering Center No. 3 (GC3) in the Western Operating Area of the Prudhoe Bay Unit. The additional flare volume is required during the shutdown and subsequent repair of the K-305 Low Pressure compressor. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 10 MMcf of gas over and above the designated safety flare pilot of GC3. Operations are expected to commence on or about February 10, 1992 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1100 Mcf/d safety flare pilot volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass Commissioner BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION January 13, 1992 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99,501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 Re-" ADMINISTRATIVE APPROVAL NO. 145-A.91 Additional flare volume, Gathering Center No. 3, Prudhoe Bay Unit ,Western Operating Area. Mr. Steven D. Taylor Environmental & Regulatory Affairs, Alaska BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, Alaska 99519-6612 Dear Mr. Taylor: We have received your letter of January 6, 1992 requesting additional flare volume for Gathering Center No. 3 (GC3) in the Western Operating Area of the Prudhoe Bay Unit. The additional .flare volume is required during scheduled maintenance work which includes gas exchanger work and valve replacement. The timing is such that it will correspond to a scheduled shutdown of GC3 for compressor conversion work. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 1 Bcf of gas over and above the designated safety flare pilot of GC3. Operations are expected to commence on or about January 17, 1992 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1100 Mcf/d safety flare pilot volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass, Commissioner BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION November 20, 1991 WALTER J. HICKEL, GOVERNOR ,, 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A.90 Re: Additional flare volume, Gathering Center No. 3, Prudhoe Bay Unit, Western Operating Area. Mr. Steven D. Taylor Environmental & Regulatory Affairs, Alaska BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, Alaska 99519-6612 Dear Mr. Taylor: We have received your letter of November 18, 1991, requesting additional flare volume for Gathering Center No. 3 (GC3) in the Western Operating Area of the Prudhoe Bay Unit. The additional flare volume is required during maintenance work on the gas to gas exchanger to repair a tube leak. The timing is such that it will correspond to a scheduled shutdown of GC3 for compressor R to P conversions. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 200 MMcf of gas over and above the designated safety flare pilot of GC3. Operations are expected to commence on or about November 20, 1991, and 'continue until work is~ bomplete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All .gas produced in excess of the 1100 Mcf/d safety flare pilot volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass~' Commissioner BY ORDER OF THE COMMISSION . printed on recycled paper b y ALASKA OIL AND GAS CONSERVATION COMMISSION September 6, 1991 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A.89 Re: Additional flare volume, Flow Station .3, Prudhoe Bay Unit, Eastern Operating Area. Mr. G. E. Griffin Operations Staff Manager Prudhoe Bay Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorage, Alaska 99510-0360 Dear Mr. Griffin: We have received your letter of September 4, 1991, requesting additional flare volume for Flow Station 3 (FS3) in the Eastern Operating Area of the Prudhoe Bay Unit. The additional flare volume is required to test modifications that have been made to the STV flare second and third stage assist gas tips. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 3.0 MMcf of gas over and above the designated safety flare pilot of FS3. Flaring is expected to commence September 7, 1991 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1000 Mcf/d safety flare pilot volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Commissioner BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION August 30, 1991 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-,3192 PHONE: (907) 279-14,.33 TELECOPY: (907) 276-7542 Re: ADMINISTRATIVE APPROVAL NO. 145-A.88 , \ Additional flare volume, Gathering Centers 1, 2 and 3, Prudhoe Bay Unit, Western Operating Area. Mr. Steven D. Taylor Environmental & Regulatory Affairs, Alaska BP Exploration (Alaska) Inc. P. O. Box 196612 AnchOrage, Alaska 99519-6612 Dear Mr. Taylor: We have received your letter of August 30, 1991, requesting additional flare volume for all of the Gathering Centers in the Western Operating Area (WOA) of the Prudhoe Bay Unit. ARCO plans to shutdown the 60" gas transit system for inspection and repair at the Central Gas Facility. The additional flare volume is necessary to reduce the pressure differential between the 38" and 60" transit gas systems as the WOA 60" line is brought back into service. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 100 MMcf of gas over and above the designated safety flare pilot of the WOA Gathering Centers. Repairs are expected to commence on or about September 1, 1991, and continue until work is complete. ., It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 3300 Mef/d safety flare pilot volume is subject to AS 43.55.020, and will be disposed of in a safe manner' by flaring or used for lease operation. Sincerely, Russell A. Douglass Commissioner BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 August 23, 1991 ADMINISTRATIVE APPROVAL NO. 145-A.87 Re: Additional flare volume, Eastern Area, Prudhoe Bay Unit. Mr. G. E. Griffin Operations Staff Manager Prudhoe Bay/Lisburne Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorage, Alaska 99510-0360 Dear Mr. Griffin: We have received your letter of August 16, 1991, requesting additional flare volume for all .Eastern 'Operating Area (EOA) facilities ( FSI, FS2, FS3, CGF, and CCP) of the Prudhoe Bay Unit. The additional flare volume is required during a planned shutdown of the Central Gas Facility in the EOA. Operations scheduled to be performed during the shutdown include modifying the inlet booster compressors, modifications to the NGL stabilizer process and replacement of leaking valves. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 200 MMcf of gas over and above the designated safety flare pilots of the EOA facilities. Flaring is scheduled to begin on or about AugUst 25, 1991 and continue until operations are completed. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Mr. G. E. Griffi~~'' August 23, 1991 Page 2 Gas Conservation Commission form 10-422. All gas produced in excess of the 7000 Mcf/d safety flare pilot volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease~ operation. Sincerely, Commissioner BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 July 30, 1991 ADMINISTRATIVE APPROVAL NO. 145-A.86 Re: Additional flare volume, Gathering Center No. l, 2 and 3, Prudhoe Bay Unit, Western Operating Area.. Mr. Steven D. Taylor Environmental & Regulatory Affairs, Alaska BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, Alaska 99519-6612 Dear Mr. Taylor: We have received your letter of ~_u_l_y..._30, 1991, requesting additional flare volume for Gathering Center No. 1 (GC1), Gathering Center No. 2 (GC2) and Gathering Center No. 3 (GC3) in the Western Operating Area of the Prudhoe Bay Unit. The additional flare volumes are necessitated by maintenance activities requiring shutdown of the 60" gas transit system at the Central Gas facility and Flow Station No. 3. The Commission finds the additional flare volumes to be an operational necessity, and hereby approves flaring up to 100 MMcf of gas over and above the designated safety flare pilots at the subject facilities. Additional flaring is expected to commence on or about July 30, 1991, and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Mr. Steven D. Taylor July 30, 1991 Page 2 Gas Conservation Commission form i0-422. All gas produced in excess of the l l00 Mcf/d safety flare pilot volume in each facility is subject to AS 43.55. 020, and will be disposed of in a safe manner by flaring or used for lease operation. · Sincerely, Chairman BY ORDER OF THE COMMISSION July 26, 1991 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A.85 Re: Additional flare volume, Flow Stations 1, 2, 3, central Gas Facility. ... (CGF) and Central Compression Plant, Prudhoe Bay Unit, Eastern Operating Area. Mr. G. E. Griffin, Operations Staff Manager Prudhoe Bay/Lisburne Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorage, Alaska 99510-0360 Dear Mr. Griffin: We have received your letter of~J_pJ_y..._..~_5_,........!991, requesting additional flare volume for Flow Stations 1, 2, 3, Central Gas Facility and Central Compression Plant in the Eastern Operating Area of the Prudhoe Bay Unit. The additional flare volume is required due to a shutdown of the CGF for tie-in work with the Gas Handling Expansion 2 Facility and for planned maintenance work at CGF. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 300 MMcf of gas over and above the designated safety pilots at the subject facilities. Flaring is expected to commence on or about A.u.~st...6, 1991 and continue until work is complete. ' It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1000 Mcf/d safety flare pilot volume is subject to AS 43.55.020, Mr. G. E. Griffin~' July 26, 1991 Page 2 and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Chairman BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 July 19, 1991 ADMINISTRATIVE APPROVAL NO. 145-A.84 Re: Additional flare volume, Gathering Center No. 1 and Gathering Center No. 2, Prudhoe Bay Unit, Western Operating Area. Mr. Steven D. Taylor Environmental & Regulatory Affairs, Alaska BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, Alaska 99519-6612 Dear Mr. Taylor: We have received your letter of ~!.~_._.~.5.,......!99!, requesting additional flare volume for Gathering Center No. 1 (GC1) and Gathering Center No. 2 (GC2) in the Western Operating Area of the Prudhoe Bay Unit. The additional flare volumes are required to facilitate cleaning and corrosion inhibitor injection pig runs for the gas transit header line from GC2 to GC3. The Commission finds the additional flare volumes to be an operational necessity, and hereby approves flaring up to 100 MMcf of gas over and above the designated safety flare pilot of GC1 and 125 MMcf at GC2. Additional flaring is expected to commence on or about July.. 20, 1991, and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Mr. Steven D. TL,.or July 19, 1991 Page 2 Gas Conservation Commission form 10-422. All gas produced in excess of the 1100 Mcf/d safety flare pilot volume in each facility is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell ^. Douglass Commissioner BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION July 15, 1991 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A.83 Re: Additional flare volume, Flow Station 3, Prudhoe Bay Unit, Eastern Operating Area. Mr. G. E. Griffin Operations Staff Manager Prudhoe Bay/Lisburne Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorage, Alaska 99510-0360 Dear Mr. Griffin: We have received your letter of July..9,..1991, requesting additional flare volume for Flow Station 3 (FS3) in the Eastern Operating Area of the Prudhoe Bay Unit. The additional flare volume is required during smart pigging operations on production commonlines 6D, 6C, 13B, 14D and 14B/C and water injection lines from FS3 to DS 13 and DS 14. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 2.5 MMef of gas over and above the designated safety flare pilot of FS3. Flaring is expected to commence on or about July 17, 1991 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1000 Mcf/d safety flare pilot volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass Commissioner BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION July 12, 1991 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501.,3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A.82 Re: Additional flare volume, Central Compressor Plant, Prudhoe Bay Unit, Eastern Operating Area. Mr. G. E. Griffin Operations Staff Manager Prudhoe Bay/Lisburne Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorage, Alaska 99510-0360 Dear Mr. Griffin: We have received your letter of._~!y_.9, 1991, requesting additional flare volume for the Central Compressor Plant (CCP) in the Eastern Operating Area of the Prudhoe Bay Unit. The additional flare volume is required during test operations in the facility to determine the number and severity of valve leaks. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 5.0 MMef of gas over and above the designated safety flare pilot of the CCP. Flaring is expected to commence July 12~,.~....1991 and continue until testing is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1000 Mef/d safety flare pilot volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass Commissioner BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION July 11, 1991 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A.81 Re: Additional flare volume, Gathering Center No. 3, Prudhoe Bay Unit, Western Operating Area. Mr. Steven D. Taylor Environmental & Regulatory Affairs, Alaska BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, Alaska 99519-6612 Dear Mr. Taylor: We have received your letter of July 9, 1991, requesting additional flare volume for Gathering.Center No. 3 (GC3) in the Western Operating Area of the Prudhoe Bay Unit. The additional flare volume is required to facilitate clean out and repair of the Intermediate Pressure (IP) Gas compressor Suction Scrubber, Vessel V-336 located at GC3. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 100 MMcf of gas over and above the designated safety flare pilot of GC3. Operations are expected to commence on or about July 11, 1991, and continue until work is complete. It is understood that gas flaring will ~be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the ll00 Mcf/d safety flare pilot volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass Commissioner BY ORDER OF THE COMMISSION June 5, 1991 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A.80 Re: Additional flare volume, Central Gas Facility, Prudhoe Bay Unit, Eastern Operating Area. · Mr. G. E. Griffin Operations Staff Manager Prudhoe Bay/Lisburne Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorage, Alaska 99510-0360 Dear Mr. Griffin: We have received your letter of May 31, 1991, requesting additional flare volume for the Central Gas Facility (CGF) in the Eastern Operating Area of the Prudhoe Bay Unit. The additional flare volume is required to test a 60" check valve assembly for induced acoustical vibration. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 350 MMcf of gas over and above the designated safety flare pilot of the CGF. Flaring will begin on or about June 7, 1991 and continue until testing is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 3000 Mcf/d safety flare pilot volume is subject to. AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglasg Commissioner BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 April 24, 1991 ADMINISTRATIVE APPROVAL NO. 145-A.79 Re: Additional flare volume, Flow Station 3, Prudhoe Bay Unit, Eastern Operating Area. Mr. G. E. Griffin, Operations Staff Mgr. Prudhoe Bay/Lisburne Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorage, Alaska 99510-0360 Dear Mr. Griffin: We have received your letter of April 18, 1991, requesting additional flare volume for Flow Station 3 (FS3) in the Eastern Operating Area of the Prudhoe Bay Unit. The additional flare volume is required for shutdown and subsequent startup of FS3. The facility shu(down will facilitate repair of the gas meter run on the 30 inch residue gas outlet line. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 3.3 MMcf of gas over and above the designated safety flare pilot of FS3. Flaring is expected to commence April 27, 1991 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1000 Mcf/d safety flare pilot volume i~ subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass Commissioner BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION April 18, 1991 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A.78 Re: Additional flare volume, Gathering Center No. 1, Prudhoe Bay Unit, Western Operating Area. Mr. Steven D. Taylor Environmental & Regulatory Affairs, Alaska BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, Alaska 99519-6612 Dear Mr. Taylor: We have received your letter of April 15, 1991, requesting additional flare volume for Gathering Center No. I (GC1) in the Western Operating Area of the Prudhoe Bay Unit. The additional flare volume is required to facilitate inspection and repairs of GC1 LPS'compressors waste heat recovery unit insulation. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 400 MMef of gas over and above the designated safety flare pilot of GC1. Repairs are expected to commence on or about April 20, 1991, and continue until work is complete. , It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1100 Mcf/d safety flare pilot volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglas§ Commissioner BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION WALTER J. HICKEL, GOVEI~NOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 April 15, 1991 ADMINISTRATIVE APPROVAL NO. 145-A.77 Re: Additional flare volume, Central Compressor Plant, Prudhoe Bay Unit, Eastern Operating Area. Mr. G. E. Griffin Operations Staff Manager Prudhoe Bay/Lisburne Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorage, Alaska 99510-0360 Dear Mr. Griffin: We have received your letter of April 12, 1991, requesting additional flare volume for the Central Compressor Plant (CCP) in the Eastern Operating Area of the Prudhoe Bay Unit. The additional flare .volume is required during flare system repairs. These repairs include restoration of the flare system to grade and restoring the pilot gas line to the flare blooie line. · The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 30.0 MMcf of gas over and above the designated safety flare pilot of the CCP. Flaring is expected to commence April 15, 1991 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1000 Mcf/d safety flare pilot volume is subject to AS 43.55.020, Mr. G. E. Griffin 2 April 15, 1991 and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Do'u~l~~ Commissioner BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 April 5, 1991 ADMINISTRATIVE APPROVAL NO. 145-A. 76 Re: Additional flare volume, Flow Station 1, Prudhoe Bay Unit, Eastern Operating Area. Mr. G. E. Griffin Operations Staff Manager Prudhoe Bay/Lisburne Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorage, Alaska 99510-0360 Dear Mr. Griffin: We have received your letter of A~4, 1991, requesting additional flare volume for Flow Station I (FS1) in the Eastern Operating Area of the Prudhoe Bay Unit. The additional flare volume is required for shutdown and subsequent startup of FS1. The facility shutdown will facilitate repair of the gas meter run, divert valve change outs at DriIlsite 1 and removal of a Cosasco corrosion coupon pulling tool that is stuck in Commonline 12C. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 3.0 MMcf of gas over and above the designated safety flare pilot of FS1. Flaring is expected to commence April 6, 1991 and continue until work is complete. It is understood that gas flaring will be kept to a minimum . whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1000 Mcf/d safety flare pilot volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass Commissioner BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION March 13, 1991 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-14.33 TELECOPY: (907) 276.7542 ADMINISTRATIVE APPROVAL NO. 145-A.75 Re: Additional flare volume, Flow Station 3, Prudhoe Bay Unit, Eastern Operating Area. Mr. G. E. Griffin Operations Staff Manager Prudhoe Bay/Lisburne Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorage, Alaska 99510-0360 Dear Mr. Griffin: We have received your letter of March 11, 1991, requesting additional flare volume for Flow Station 3 (FS3) in the Eastern Operating Area of the Prudhoe Bay Unit. The additional flare volume is required to test the stock tank vapor flare system modifications recently completed. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 6.0 MMcf of gas over and above the designated safety flare pilot of FS3. Testing is expected to take place in two separate events. The first test will commence on or about March 14, 1991, and the second test will commence on or about March 21,1991, continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1000 Mcf/d safety flare pilot volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Commissioner BY ORDER OF THE COMMISSION ALASKA OIL AND GAS CONSERVATION COMMISSION March 8, 1991 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 · TELECOPY: (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A.74 Re: Additional flare volume, Central Compressor Plant, Prudhoe' Bay Unit, Eastern Operating Area. Mr. G. E." Griffin Operations Staff Manager Prudhoe Bay/Lisburne Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorage, Alaska 99510-0360 Dear Mr. Griffin: We have received your. letter of March 8, 1991, requesting additional flare volume for the Central Compressor Plant (CCP) in the Eastern Operating Area of the Prudhoe Bay Unit. The additional flare volUme is required to determine temperature in the flare header to assure facility design after GHX-1 modifications meets safety standards. The Commission finds the additional flare' volume to be an operational necessity, and hereby approves flaring up to 3.0 MMcf of gas over and above the designated safety flare pilot of the CCP. Testing is expected to commence on or about March .1_1_~, 1991, and continue until work is complete. ,, It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1000 Mcf/d safety flare pilot volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, BY ORDER OF THE COMMISSION IJ ALASKA OIL AND GAS CONSERVATION COMMISSION January 11, 1991 WA LTER ]. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907)279-1433 Teleeopy No, (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 145-A.73 Re.' Additional flare volume, Central Gas Facility, Prudhoe Bay Unit, Eastern Operating Area. Mr. Mark Major Operations Representative Prudhoe Bay/Lisburne Operations P. O. Box 100360 Anchorage, Alaska 99510-0360 Dear Mr. Major: We have received your letter of January 9, 1991, requesting additional flare volume for the Central Gas Facility (CGF) in the Eastern Operating Area of the Prudhoe Bay Unit. The additional flare volume is required to facilitate testing of the pressure relief valves at this facility. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 100 MMcf of gas over and above the designated safety flare pilot of the CGF. Repairs are expected to commence on or about January 21, 1991, and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 3000 Mcf/d safety flare pilot volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. D'ou~ Commissioner BY ORDER OF THE COMMISSION December 21, 1990 Telecopy~ No. (907) 276-7542 A D M ! N I S T R A T I V E A P P R O V A L N O. 145-A.72 Re.. Additional flare volume, Central Compressor Plant, Prudhoe Bay Unit, Eastern Operating Area. Mr. Mark Major Operations Representative Prudhoe Bay/Lisburne Operations ARCO Alaska, %nc. P. O. Box 100360 Anchorage, AK 99510-0360 Dear Mr, Major: We have received your letter of December ~18_, 1990 requesting additional flare volume for the Central Compressor Plant (CCP) tn the Eastern Operating Area of the Prudhoe Bay Unit. The addition- al flare volume is required to facilitate repairs to the flare s ys t em. The Commission. finds the additional flare gas to be an operational necessity, and hereby approves flaring up to 50 MMCF of gas over and above the designated safety flare pilot of the CCP. Repairs are expected to commence on or about December _~21__, 1990, and continua until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission Form 10-422. Ail gas produced in excess of the 1000 MCF/D safety flare pilot volume is subject to AS 43.55.020, and will be disposed of in a safe manner' by flaring for lease operation. Lonnie C. Smith Commissioner BY ORDER, OF THE CO}~ISSION dl f/RAD 3,.AA, I, 4 5 December 11, 1990 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. !45-A.71 Re: Request for Additional flare volume, Eastern Operating Area, Prudhoe Bay Unit, Flow Station !. Mr. Mark Major Operations Representative Prudhoe Bay/Lisburne Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorage, AK 99510-0360 Dear Mr. Major: We have received your letter of December~10, 1990 requesting additional flare volume for Flow Station 1 (FSI) facility in the Eastern Operating Area (EOA) of the Prudhoe Bay Unit. The addi- tional flare volume is required to repair a 24" isolation valve in the artificial lift piping near FSI. The Commission finds the additional flare gas to be an operational necessity, and hereby approves flaring up to 19~MMCF of gas over and above the designated safety flare pilot of FSI. Work is scheduled to occur on or about December 14, 1990 to coincide with an expected North Slope production pro{~tio~ and continue until work is complete. If the production proration does not occur this approval will be in effect when the next appropriate opportunity arises or conditions warrant further action. It is understood that gas flaring will. be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission Form 10-422. All gas produced in excess of the 1000 MCF/D safety flare pilot volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, /'~ : 2,,".. ,. '~, ..... Commissioner BY ORDER OF THE CO~SM. ISSION dlf/RAD 3.AA145 November 6, 1990 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A. 70 Re: Additional flare volume, Gathering Center ~3, Prudhoe Bay Unit, Western Operating Area. Steven D. Taylor, Mgr. Environmental Compliance & Regulatory Affairs BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, AK 99519-6612 Dear Mr. Taylor We have received your letter of November 5, 1990 requesting approval to flare up to 700 MMCF of gas at Gathering Center #3 (GC-3). The flare volume requested will accommodate any opera- tional upsets while installing a new burner on one of the TEG reboilers located at GC-3, The Commission finds the additional flare gas to be an operational necessity, and hereby approves flaring up to 700 MMCF of gas over and above the designated safety flare pilot at GC-3. Flaring is scheduled to begin on or about November 7 and continue until .work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and ali. volumes will be reported monthly on Alaska Oil and Gas Conservation Commission Form 10-422. Ail gas produced in excess of the 1100 MCF/D safety flare pilot volume is subject to AS 43.55.020, and. will be disposed of in a safe manner by flaring or used for lease operation. Since: David W. Commissioner BY ORDER OF THE COM2~ISS!ON dlf/RAD 3. AA145 October 30, 1990 Telecopy No. (907) 276-7542 A D M I N ! S T R A T I V E A P P R O V A L M O. 145-A. 69 Request for additional flare volume, Eastern Operating Area, Prudhoe Bay Unit, Central Compressor Plant and Central Gas Facility. Mr. Mark Major Operations Representative Prudhoe Bay/Lisburne Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorage, AK 9951.0-0360 'Dear Mr Major: We have received your letter of October 26, 1990 requesting additional flare volume for Central Compressor Plant (CCP) and Central Gas Facility (CGF)in the Eastern Operating Area (EOA) of the Prudhoe Bay Unit. The additional flare volume is required to start up the new tandem compressors and to perform flar~ system testing at the CCP. The Con~nission further understands that, because of the interties between th~ CCP and CGF, it may be necessary for the CGF to flair during CCP compressor startup. The Commission finds the additional flare gas to be an operational necessity, and hereby approves flaring up to 150 MMCF of gas over and above the designated safety flare pilot of the CCP and CGF. Testing is scheduled to occur on or about November continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission Form 10-422. All gas produced in excess of the 4000 MCF/D safety flare pilot volume at the respective facilities is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. ~~~'~RiBgerely' ~ Da,vid W. Johnston Commission~ .......... ' BY ORDER OF THE COMMISSIOM dlf/RAD 3.AA145 October 23, 1990 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R 0 V A L N O. 145-A.68 Re: Request for additional flare volume, Gathering Centers #1. and #2, Western Operating Area, Prudhoe Bay Unit. Steven D. Taylor Environmental & Regulatory Affairs BP Exploration' (Alaska) Inc. P 0 Box 196612 Anchorage, AK 99519-6612 Dear Mr Taylor: We have received your letter of October 22, 1990 requesting approval to flare, up to 750 MMCF of gas at Gatheri.ng Centers #1 and ~.2 (GC-1, GC 2). The flare volume requested will result from "pigging" operations on the 34" gas transit line from GC-2 to GC-3 for corrosion survey work. The Commission finds the additional flare gas to be an operational necessity, and hereby approves flaring up to 750 MMCF of gas ovar and above the designated safety flare pilot at GC-1 and GC-2. Flaring is scheduled to occur on or about October 25, 1990 and continue until work is complete. It is understood that gas. flaring Will be kept to a minimum whenever possible, and all volumes will be reported monthly Alaska Oil and Gas Conservation' Commission Form 10-422. Ail gas produced in excess of the 2200 MCF/D safety flare pilot volume at the respective facilities is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for '].ease operation. Commissioner BY ORDER OF THE COMMISSION dlf/RAD 3.AA145 c: Pam Pope September 20, 1990 ADMINISTRATIVE APPROVAL Telecopy No. (907) 276-7542 N O. !45-A.67 Re: Request for additional flare volume, Western Operating Area, Prudhoe Bay Unit. Steven D. Taylor Environmental & Regulatory Affairs BP Exploration (Alaska) Inc. P O Box 196612 .Anchorage, AK 99519-6612 Dear Mr Taylor: We have received your letter of September 19, 1.990 requesting additional flare volume for the W~stern Operating Area (WOA) Gathering Centers 1 & 2 of the Prudhoe Bay Unit. The additional flare volume will be associated with shutdown of !P and LP compressors to install annulus-type flowmeters on the IP discharge piping at both gathering centers. The Commission finds the additional flare gas to be an operational necessity, and hereby approves flaring up to 20 MMCF of gas over and above the designated safety flare pilot of Gathering Centers 1 & 2. Flaring is scheduled to occur on. or about October 1, 1990 and continue until work is complete, .................................. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission Form 10-422. All gas produced in excess of the 2200 ~,~'~CF/D safety flare pilot ~ ~ subject to AS 43.55.020, volume at the respective facilit_es is and will be disposed of in. a safe manner by flaring or used for lease operation. Sincere Lomnie [th Commissioner BY ORDER OF THE COmmISSION dlf/RAD 3.AA145 c: Para Pope September 20, !990 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L ~? O. 145-A.66 Re: Request for additional flare volume, Endicott Field, Duck Island Unit. Steven D. Tay].or Environmental & Regulatory Affairs BP Exploration (Alaska)Inc. P 0 Box 196612 Anchorage, AK 99519-6612 Dear Mr Taylor: We have received your letter of September 19, 1990 requesting additional flare volume for the Endicott Oil Pool production facilities. The additional flare volume will be associated with shutdown, depressurization and startup for plant maintenance activities. The Commission finds the additional flare gas to be an operational necessity, and hereby approves flaring up to 50 ~CF of gas over and above the designated safety flare pilot of Endicott production facilities. Flaring is scheduled to occur on or about Septem- ber 21, 1990 and continu~ until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes Will be reported, monthly on Alaska Oil and Gas Conservation Commission Form 10-422. All gas produced in excess of the 400 MCF/D safety flare pilot volume at the respective facility is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Commissioner BY ORDER OF THE COMMISSIOb! d!f/RAD 3.AA145 c: Pam Pope September 17, 1990 Telecopy No. (907) 276-7542 A D M I N I S T R A T ! V E A P P R O V A L N O. 145-A. 65 Re: Request for additional flare volume, Eastern Operating Area, Prudhoe Bay Unit. Mark A Mai or Operations Representative Prudhoe Bay/Lisburne Operations ARCO Alaska Inc P O Box 100360 .Anchorage, AK 99510-0360 Dear Mr Mai or: We have received your letter of September !4, 1990 requesting additional flare volume for the Eastern Operating Area (EOA) Flow Stations, Central Compression Plant (CCP) and Central Gas Facility (CGF) of the Prudhoe Bay Unit (PBU), The additional flare volume will be associated with startup of the gas handling expansion transit piping in the PBU-EOA. The Commission finds the additional flare gas to be an operational necessity, and hereby approves flaring up to 75.0 MMCF of gas over and above the designated safety flare pilot of Flow Stations 1, 2, and 3, CCP and CGF. Flaring is scheduled to occur on or about se tem and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska. Oil and Gas Conservation Commission Form 10-422, Ail gas produced in excess of the 7000 MCF/D safety flare pilot volume at the respective facility is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, ,. Lonnie C Smith Commissioner BY ORDER OF THE COMMISSION dlf/RAD 3.AA145 September 12, 1990 Telecopy No. (907) 276-7542 A D M i N I S T R A T I V E A P P R O V A L N O. 145-A.64 Re: Request for additional flare volume, Western Operating Area, Prudhoe Bay Unit. Steven D Taylor Environmental & Regulatory Affairs BO Exploration (Alaska) Inc P O Box 196612 Anchorage, AK 99519-6612 Dear Mr Taylor: We have received yoUr letter of September 7, 1990 requesting additional flare volume for the Western Oper.ating Area (WOA) Gathering Centers of the Prudhoe Bay Unit. The additional flare volume will be associated with startup of the new GHX-1 60-inch gas transit system. The Commission finds the additional flare gas to be an operational necessity, and hereby approves flaring up to 500 MMCF of gas over and above the designated safety flare pilot of Gathering Centers 1, 2, and 3. Flaring is scheduled to begin on or about September 22t. 1990 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes'will be reported monthly on Alaska Oil and Gas Conservation Commission Form 10-422. All gas produced in excess of the .3300 MCF/D safety flare pilot volume at the respective facility is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, ~,, ............ ~ ' ~ ~'j~"~""'""~"' "':%, Lonnie C Smith Commissioner BY ORDER OF THE COmmISSION jo/RAD 3 .AA145 September 12, 1990 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A.63 Re: Request for additional flare volume, Eastern Operating Area, Flow Station ~1, Prudhoe Bay Unit. Mark A Major Operatio~'~s Representative ARCO Alaska Inc P O Box 100360 Anchorage, AK 99510-0360 Dear Mr Maj or~ We have received your letter of September 7, 1990 requesting additional flare volume for the Eastern Operating Area (EOA) Flow Station No. 1 (FS-1) of the Prudhoe Bay Unit. The additional flare volume will be associated with the shutdown and startup of FS-1 to perform gas handling expansion tie-in activities and other maintenanceoperations. The Commission finds the additional flare gas to be an operational necessity, and hereby approves flaring up to 15 MMCF of gas over and above the designated safety flare pilot of FS-1. Flaring is scheduled to begin on or about September 15, 1990 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will 'be reported monthly on Alaska Oil and Gas Conservation Con~nission Form 10-422. Ail gas produced in excess of the 1000 MCF/D safety flare pilot volu'me at the respective facility is subject to AS 43.55.020, and will be disposed of in a safe manner by' flaring or used for lease operation. Sincerely, / ~'~ M~'~'''' '~, ,..,..,"' ~ . ~" Lonnie C Sm~ith Commissioner BY ORDER OF THE CO~IISSION jo/RAD 3.AA145 September 5, 1990 Telecopy No. (907) 276-7542 A D M I N I S T R A T i V E A P P R O V A L N O. 145-A.62 Re: Request ior additional i'lare volume, Western Operating Area, Prudhoe Bay Unit. Steven D Taylor, Mgr Environmental & Regulatory Affairs BP Exploration (Alaska) Inc P O Box 196612 Anchorage, AK 99519-6612 Dear Mr Taylor: We have received your letter of September 4, 1990 requesting additional flare volume for the ~Western Operating Area (WOA), Gathering Center 2 of the Prudhoe Bay Unit. The additional flare volume will be associated with depressurimg the Miscible Injection Gas line in order to perform valve maintenance. The Commission finds the additional flare gas to be an operational necessity, and hereby approves flaring up to 1.5 MMCF of gas over and above the designated safety flare pilot of Gathering Center 2. Flaring is scheduled to begin on or about September 5, 1990 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and..all volumes' will be reported mont'hl'y on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess' of the 1100 MCF/D safety flare pilot volume at the respective facility is subject to AS 43.5.5.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Lonnie C Commissioner BY ORDER OF T~E COMMISSION j o/RAD 3.AA145 August 31, 1990 Telecopy No. (907) 276-7542 A D M i N I S T R A T I V E A P P R O V A L N O. 145-A.61 Re: Request for additional flare volume, Eastern Operating Area, Central Gas Facility, Prudhoe Bay Unit, revised. Mark A Major Oprns Representative Prudhoe Bay/Lisburne Oprns ARCO Alaska Inc P O Box 100360 Anchorage, AK 99510-0360 Dear Mr Major: We have received your letter of August !~5~.~1990 requesting additional flare volume for the Eastern Operating Area (EOA) Central Gas Facility (CGF) of the Prudhoe Bay Unit. The additional flare volume will 'be associated with shutdown and startup of the CGF to perform gas handling expansion tie-in activities and other maintenance operations. The Commission finds th~ additional flare gas to be an operational necessity,, and hereby approves flaring up to 3.0 bR~CF of' gas over and above the designated safety flare pilot of the CGF. Flaring is scheduled to begin on or about Sa..~,...t..e_...._mb_e.~._...2~,. 1990 and continue until work is complete. It is understood that gas flaring'will be kept to a minimum whenever possible, and all volumes wii1 be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. Ail gas produced in excess of the 3000 MCF/D safety flare pilot volume at the respective facility is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. BY ORDER OF THE CO~RISSION jo/RAD 3.AA145 August 28, 1990 Telecopy No. (907) 276-7542 A D M I N i S T R A T I V E A P P R O V A L N O. 145-A.61 Re: Request for additional flare volume, Eastern Operating Area, Central Gas Facility, Prudhoe Bay Unit, revised. Mark A Major Oprns Representative · Prudhoe Bay/Lisburne Oprns ARCO Alaska Inc P O Box 100360 Anchorage, AK 99510-0360 Dear Mr Major: We have received your letter of August 15, 1990 requesting additional flare volume for the Eastern Operating Area (EOA) Central Gas Facility (CGF) of the Prudhoe Bay Unit. The additional £1are 'volume will be associated with shutdown and startup of the CGF to perform gas handling expansion tie-in activities and other maintenance operations. The Commission finds the additional flare gas to be an operational necessity, and hereby approves flaring up to 30 MMCF of gas over and above the designated safety flare pilot of the CGF. Flaring is scheduled to begin on or about September 16, 1990 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible,, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. Ail gas produced in excess of the 3000 MCF/D safety flare pilot voltm~e at the respective facility is subject to AS 43.55.020, and 'will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, ~,.~,,.,~,,-,~ '~Lonnie C Commissioner BY ORDER OF THE CO~ISSiON jo/RAD 3.AA145 August 1, 1990 Telecopy No. (907) 276-7542 ADMINISTRATIVE APPROVAL NO. !45-A.60 Re: Request for additional flare volume, Eastern Operating Area, Flow Station No. 3, Prudhoe Bay Unit. Mr. Mark A. Major Operations Representative Prudhoe Bay/Ltsburne Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorage, AK 99510-0360 Dear Mr Major ~ We have received your letter of July 31, 1990 requesting addi- tional flare volume for the Eastern Operating Area (EOA) Flow Station No. 3 (FS-3) of the Prudhoe Bay Unit. The additional flare volume will be associated with shutdown and startup of FS-3 to perform gas handling expansion tie-in activities and other maintenance operations. The Commission finds the additional flare gas to be an operation- al necessity, and hereby approves flaring up to 15 I~CF of gas over and above the designated safety flare pilot of FS-3. Flaring is scheduled to begin on or about August 8, 1990 and continue until work is complete. It is understood that gas flaring will be kePt to a minimum. whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas COnservation Commission form 10-422. Ail gas produced in excess of the !000 MCF/D safety flare pilot volume at the respective facility is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, ,......~ ~:..,~,...,,.~.-...4 ~!~,~.~.~. ....... ,'~. L~hie C,f S=d. th Commissioner BY ORDER OF THE CO}~{ISSION dlf/RAD 3. AA145 July 20, 1990 ADMINISTRATIVE APPROVAL NO. Telecopy No. (907) 276-7542 145-A. 59 Re: Request for additional flare volume, Eastern Operating Area, Prudhoe Bay Unit. Mr. Mark A. Major Operations Representative Prudhoe Bay/Ltsburne Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorage, AK 99510-0360 Dear Mr Major, We have received your letter of J~q~6, 1990 requesting addi- tional flare volume for the Eastern Oper~ Area (EOA) Flow Station No. 2 (FM-2) of the Prudhoe Bay Unit. The additional flare volume will be associated with pigging activities in EOA commonlines to de.~ermine where corrosion exists, and subsequent repair of same. The Commission finds the additional flare gas to be an operation- al necessity, and hereby approves flaring up to' 10 MMCF of gas over and above the designated safety flare pilot of FS-2. Flaring i~,?'iScheduled to begin this month and continue until work is complete. It is understood that gas flaring .will be kept to a minimum whenever possible, and all volumes' will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. Ail gas produced in excess of the 1000 MCF/D safety flare pilot volume at the respective facilities is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, David W. tc Commissioner \. .......... BY ORDER OF THE COMMISSION dlf/RAD 3.AA145 July 16, 1990 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A.58 Re: Request for additional flare volume, Western Operating Area, Prudhoe Bay Unit. Steven D Taylor, Mgr Environmental & Regulatory Affairs BP Exploration (Alaska) Inc P 0 Box 196612 Anchorage, AK 99519-6612 Dear Mr Taylor: We have received your letter of Ju_qe 25, 1990 requesting additional flare volume for the We~-t-e-~'--O~"erating Area (WOA) Gathering Centers of the Prudhoe Bay Unit. The additional flare volume will be associated with the ~hutdown and depressurization of Gathering Center ~3 (GC-3) and black start test of GC-3 emergency power system. The Commission finds the additional flare gas to be an operational necessity, and hereby approves flaring up to 40 .MMCF of gas over and above the designated safety flare. pilot of Gathering Centers 1, 2, 'and 3. Flaring is scheduled to occur on or about August 26, 1990 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation'~Commission form 10-422. All gas produced in excess of the 3300 MCF/D safety flare pilot volume at the respective facilities is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Lonnie C Smith Commissioner BY ORDER OF THE COMMISSION Jo/RAD 3.AA145 c: Pam Pope -- BP July 12, 1990 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R 0 V A L N O. 145-A.57 Re: Request for additional flare volumo, Western Operating Area, Prudhoe Bay Unit. Steven D Taylor Environmental & Regulatory Affairs BP'Exploration (Alaska) Inc P O Box 196612 Anchorage, AK 99519-6612 Dear Mr 'Taylor: We have received your letter of J~M_...~:k,___199~ requesting additional flare volume for the Western Operating Area (WOA) Gathering Centers of the Prudhoe Bay Unit.. The additional flare volume will be a. sso¢iated With the shutdown and de~re, s-surization of Gatheting Center #1 (GC-1) for turn- around work. The Commission finds the additional flare gas to be an operational necessity, and hereby approves flaring up to 40 MMCF of gas over and above the designated safety flare pilot of Gathering Centers 1, 2, and 3. Flaring is scheduled to occur on or about ~u~u.~y 17, 1990 and continue until work is complete. It is understood that gas flaring will be kept to a minimtun whenever possible,, and all volumes will 'be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. Ail gas produced in .excess of the 3300 MCF/D safety flare pilot volume at the respective facilities is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sin, , ~ ....... .., /./i ..... '~'" ,..,..,.,/ Commiss loner BY ORDER OF THE COMMISSION j o/RAD 3.AA145 June 7, 1990 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R 0 V A L N O. 145-A. 56 Re: Request for additional flare volume, Eastern Operating Area, Prudhoe Bay Unit, Flow Stations 2 & 3. Mr. Mark Major Operations Representative Prudhoe Bay/Lisburne Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorage, AK 99510-0360 Dear Mr. Major.. We have received your letter of June 5, 1990 requesting addition- al flare volume for Flow Station 2 (FS2) and Flow Station 3 (FS-3) facility in the Eastern Operating Area (EOA) of the Prudhoe Bay Unit. The additional flare volume is associated with the shutdown of these facilities in conjunction with the Alyeska TAPS shutdown scheduled for June 12, 1990. The Commission finds t'he additional flare gas to be an opera- tional necessity, and hereby approves flaring up to 2 MMCF of gas over and above the designated safety flare pilot at FS-2 and 3 M~{CF of gas over and above the designated safety flare pilot at FS-3, It is understood that gas flaring will. be kept to a minimum whenever possible, and all volumes will be reporte_d monthly on Alaska Oil and Gas Conservation Commission form 10 422. Ail gas produced, in excess of the 1000 MCF/D safety flare pilot volume at the respective, facilities~, is sub/ect3 to AS 43..55_020'd f0~ and will be disposed of in a sa~e manner by flaring or use . lease operation. Sincerely ...... <~/!~onnie C .th Commissioner BY ORDER OF THE COMMISSION dlf/RAD-3 .AA145 June 6, 1990 Telecopy No. (907) 276-7542 A D M I N i S T R A T I V E A P P R O V A L N O. 145-A.55 Re: Request for additional flare volume, Western Operating Area, Prudhoe Bay Unit. Steven D Taylor, Manager Environmental & Regulatory Affairs BP Exploration (Alaska) Inc P 0 Box 196612 Anchorage, AK 99519-6612 Dear Mr Taylor: We have received your letter of June 4, 1990 requesting additional flare volume for the Western Operating Area (WOA) Gathering Centers of the Prudhoe Bay Unit. The additional flare volume will be associated with the shutdown and depressurizing of Gathering Center 2 (CC-2) and valve sequence testing of the GC-2 LPS compressors. The Conunission finds the additional flare gas to be an opera- tional necessity', and hereby approves flaring up to 40 MMCF of gas over and above the designated safety flare pilot of Gathering Centers 1, 2 & 3. Flaring is scheduled to occur on or about June 5, 1990 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible., and all volumes will. be reported monthly on Alaska Oil and Gas Conservation Commission fo~ 10-422. All gas produced in excess of the 3300 MCF/D safety flare pilot volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. S ~~.~6er e ly'.~,z : Lonnie C Smith Commissioner BY ORDER OF THE CO~MISSION jo/RAD-3 .AA145 May 25, 1990 Telecopy No. (907) 276-7542 A D M I N I S T R A T ! V E A P P R O V A l, N O. 145-A.54 Re: Request for additional flare volume, Western Operating Area, Prudhoe Bay Unit. Mr. Steven D, Taylor Environmental & Regulatory Affairs BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, AK 99519-6612 Dear Mr. Taylor We have received your letter of May 21, 1990 requesting addi- tional flare volume for the Western Operating Area (WOA) Gather- lng Centers of the Prudhoe Bay Unit. The additional flare volume will be associated with the Shutdown and depressurization of the am lift equipment while installing an isolation valve in the gas ~ift tie line between the two Prudhoe Operating Areas. The Commission finds the additional flare gas to be an opera- ti.on.al necessity, and. hereby approves, flaring up to 15 MMCF of gas over and above the designated safety flare pilot of Gathering Centers 1, 2 & 3. Flaring is scheduled to occur on or about Jun~_:~.~90 and continue until work is complete. It is understood that gas flaring'Will be kePt to a minimum whenever possible, and all volumes will be reported.monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 3300 MCF/D safety flare pilot volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Lonnie C Commissioner BY ORDER OF %~{E COMMISSION dlf/l~3~D-3.AA145 May 18, 1990 Te!ecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A. 53 Re: Request for additional flare volume, Eastern Operating Area, Prudhoe Bay Unit, Flow Station 3 Mr. Mark Major Operations Representative Prudhoe Bay/Lisburne Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorage, ~ 99510-0360 Dear Mr. Major: We have received your letter of May 15, 1990 requesting addi- tional flare volume for Flow Station 3 (FS-3) facility in the Eastern Operating Area (BOA) of the Prudhoe Bay Unit. The additional flare volume is required to install an artificial lift gas isolation valve. he Commission finds the additional flare gas to be an opera- tional necessity, and hereby approves flaring up to 2 MMCF of gas over and above the designated safety flare pilot of FS-3. Testing is scheduled to occur on or about June 7~ 1990 and continue until work i,s complete. -", ............ ~ It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will bm reported monthly on Alaska Oil and Gas Conservation Con~tssion form 10-422. All gas produced in excess of the 3300 MCF/D safety flare pilot volume is subject to AS 43.55. 020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, ............. ~ {., , it%,~''~''i,., ~.~.'~,'~ ............ ~"'_ ~:' ~3~onnie C ',h Commissioner BY ORDER OF THE COMMISSION dlflRAD-3. AA145 May 1, 1990 Telecopv No. ., (907) 276-7542 A D M I N I S T R A T I V E A P P R 0 V A L N Oo 145-A.52 Re: Request for additional flare volume, Western Operating Area, Prudhoe Bay Unit. Mr. Steven D. Taylor Environmental & Regulatory Affairs BP Exploration (Alaska) Inc. P. O. Box 196612 Anchorage, AK 99519-6612 Dear Mr. Taylor: We have received your letter of May 1, 1990 requesting additional flare volume for the Western Operating Area (WOA) Gathering Centers of the Prudhoe Bay Unit. The additional flare volume is required due to testing of facilities by ARCO in the Eastern Operating Area which will result in high transit line pressure in the WOA. The Commission finds the additional flare gas to be an opera- tional necessity, anAd hereby approves flaring up to 23 MMCF of gas over and above the designated safety flare pilot of Gathering Centers 1, 2 & 3. Testing is scheduled to occur on or about ~al ..... ~, 1990 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all voltnnes will be reported monthly on Alaska Oil and Gas Conservation .Commission form 10-422. Ail .gas produced in excess of the 3300 MCF/D safety flare pilot volume is subject to AS 43.55.020, and will be disposed of in a safe. manner by flaring or used for lease operation. BY ORDER OF THE COMMISSION dlf/RAD-3. AA145 cc: Pas Pope April 19, 1990 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R 0 V A L N O. 145-A.51 Re: Request for additional flare volume, Eastern Operating Area, Prudhoe Bay Unit, Central Compressor Plant. Mr. Mark Major Operations Representative Prudhoe Bay/Lisburne Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorage, AK 99510-0360 Dear Mr. Major: We have received your letter of April~17_~.1990 requesting addi- tional flare volume for Central CompresSor Plant (CCP) facility in the Eastern, Operating Area (EOA) of the Prudhoe Bay Unit. The additional flare volume is required to test the CCP flare system for its ability to handle increased gas volumes as a result of a gas handling expansion project. The Commission finds the additional flare gas to be an opera- tional necessity, and hereby approves flaring up to 80 MMCF of gas over and above the designated safety flare pilot of the CCP. Testing is scheduled to occur on or about April 23, 1990 and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all. volumes will. be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced, in excess of the 1000 MCF/D safety flare pilot volume is subject to AS 43.55.020, and. will be disposed of in a safe mann~r by flaring or used for lease operation. Commissioner BY ORDER OF THE COMMISSION d!f/RAD- 3. A~I 45 March 1, 1990 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R 0 V A L N O. 145-A.50 Re: Request for additional flare volume, Gathering Center #3, Prudhoe Bay Unit. Janet D Platt, Supervisor Enviro~unental Compliance BP Exploration (Alaska) Inc P O Box 196612 Anchorage, AK 99519-6612 Dear Ms Platt: We' have received your letter of February 27, 1990 requesting additional flare volume for Gathering Center #3 (GC-3) of the Prudhoe Bay Unit. The additional flare volume is required to facilitate flare capacity testing at GC-3~~':~. The Commission finds the additional flare gas to be an opera- tional necessity, and hereby approves flaring up to 80 MMCF of gas over and above the.designated safety flare pilot of GC-3. Flaring is scheduled tb begin on or about March 1 and continue. It is understood that gas flaring will be kept tq~a minimum' whenever posszble, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1000 MCF/D safety flare pilot volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, ~ZLonnie C Commissioner BY ORDER OF THE COMMISSION jo/RAD-3 .AA145 c: Pam Pope - BP January 29, 1990 Telecopy No. (907) 276-75&? A D M I N ! S T R A T i V E A P P R 0 V A I, N O. ]45-A.49 Re: Additional flare volume, Flow Station ~3, Prudhoe Bay Unit. M A Major Operations Representative Prudhoe Bay/Lisburne Operations ARCO Alaska, !nc P O Box ].00360 Anchorage, AK 99510-0360 Dear Mr Major: Wa have received your letter of January 29, 1990 requesting approval to flare up to 3 MMCF of gas at Flow Station ~J3 (FS3). The flare volume requested is needed to perform a flare system te'.st. The Commission finds the additional flar~ gas to be an opera- tional necessity, and hereby approves flaring up to 3 MMCF of gas over and above the designated safety flare pilot at FS3. Flaring is scheduled to begin on or about Febr.~uary 5 and~.continue until work is complete. It is understood gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1000 MCF/D safety flare pilot volume is sub,~ect to AS 43.55.020, and will be disposed of in a ~:afe manner by flaring or used for lease operation. BY ORDER OF THE CO~.~..ISSION dlftRAD- 3. AA14.5 December 19, 1989 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A.48 Re: Request for additional flare volume, Western Operating Area, Prudhoe Bay Unit. Stan Gates, Supervisor Enviro~umental Compliance BP Exploration (Alaska) Inc P 0 Box 196612 Anchorage, AK 99519-6612 Dear Mr Gates: We have received your letter of December 15, 1989 requesting additional flare volume for the Weste~-n---0'~-ting Area (WOA) of the Prudhoe Bay Unit. The additional flare volume is required to facilitate a high. gas rate test at Gathering Center ~3. Excess flaring is expected to occur at all three gaghering centers of the WOA. The Commission finds the additional flare gas to be an opera- tional necessity, and hereby approves flaring up...~to 2 BCF of gas over and above the combined designated safety flare pilot of the WOA. Flaring is scheduled to begin on or about Jan~a__r~_._~_.,~ ....... 1990 and. continue until work is complete. It is understood gas flaring will 'be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil amd Gas Conservation Commission form 10~422. Ail gas produced in excess of the~.3300 MCF/D safety flare pilot volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincere ly, .--4 z.,.'g.' / ., .Z,f.?:..,',,.~ ..... / ~"~'~ .............. ~,., ,,. Lonnie C Smith Commissioner BY ORDER OF THE COMMISSION Jo/RAD-3.AA145 c: Pam Pope - BP December 1, i989 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A. 47 Re: Additional flare volume, Central Gas Facility, Prudhoe Bay Unit. M A Major Operations Representative Prudhoe Bay/Lisburne Operations ARCO Alaska, Inc P 0 Box 100360 A~chorage, AK 99510-0360 Dear Mr Mai or: We have received your letter of November 29, 1989 requesting ap- proval to flare up to 1.3 MMCF of gas at the Central Gas Facility (¢GF). The flare volume requested is needed to perform a flare system test. The Commission finds the additional flare gas to be an opera~io~- al necessity, and hereby approves flaring up to 13 MMCF of gas over and above the designated safety flare pilot at the CGF. Flaring is scheduled to begin on or about December 5 and continue until work is complete. It is understood gas. flaring ~will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. Ail gas produced t'n excess of the 3000 ~CF/D safety flare pilot volume is su'bJec~ to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. BY ORDER OF THE COMMISSION dlf/3.AA145 October 25, 1989 Telecopy No. (907) 276-7542 A D M i N I S T R A T I V E A P P R O V A L N O. 145-A. 46 Re: Additional flare volume, Gathering Center #2, Prudhoe Bay Unit. Stan F. Gates Supervisor Environmental Compliance BP Exploration (Alaska) Inc P. O. Box 196612 ~chorage, AK 99519-6612 Dear Mr Taylor: We have received your letter of October 23, 1989 requesting ap- provai to flare up to 250 MMCF of gas at Gathering Center #2¢1 7v~'~ (GC-2). The flare voltune requested is for clean-up of a new gas injection we'll after perforating operations. The Co~mnission finds the additional flare gas to be an operation- al necessity, and hereby approves flaring up to 250 MMCF of over and above the designated safety flare pilot at GC-2?~ Flaring is scheduled to begin on or about October 29 and continue until work is complet~. it is understood gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in exce~s of the 1100 MCF/D safety flare pilo~ volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sinc~rely, ,.. Lonnie C ~h Con, his s ioner BY ORDER OF THE COMMISSION dlf/3.AA145 cc: Pam Pope Sepnember 18, 1989 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A. 45 Additional flare volume, Gathering Center #3, Prudhoe Bay Unit. Steven D Taylor Mamager Environmental and Regulatory Af'~'airs BP Exploration (Alaska) Inc P. O. Box 196612 Anchorage, AK 99519-6612 Dear Mr Taylor: We have received your letter of September 6, 1989 reques'~ing ap- prov'al to flare up to 900 MblCF of gas a~ Gathering Center ~3 ~.~ ~'~ (GC-3). The flare v'olume requested is for performance testing of the high pressure gas scrubber. The Commission. finds the additional flare gas to be an operation- al necessity, and hereby approves flaring up to 900 MMCF of ga.~ over and above the designated safety flare pilot at GC-3~ Flaring is scheduled to begin on o.r about October 5 and continue until work is complete. It is understood gas flaring will be kept to a minimua~ whenever possible, and all volum~es will be repo~ted monthly on Alaska Oil and Gas Conservation Con~ission form 10-422. All gas produced in excess of the 1100 MCF/D safety flare pilot volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Lonnie C Smith Commissioner BY ORDER OF THE COI~ISSION dlf/3.AA145 cc: Pam Pope .... ~'"' ' September 12, 1989 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A.44 Additional flare volume, Lisburne Production Facility, Prudhoe Bay Unit. M A Major Operations Representative Prudhoe Bay/Lisburne Ope~'ations AIiCO Alaska, Inc P O Box 100360 Anchorage, AK 99510-0360 Dear Mr Major:. We have received your letter of September 8, 1989 requesting ap- proval to flare up to 15 ~CF of gas at the Lisburne Production Facility (LPC). The flare volume requested is needed dur'ing testing of ~'he high pressure flare system. al necessity, and hereby' approves flaring up to 15 I~CF of gas over and above the designated safegy flare pilot at the LPC. Flaring is scheduled to begin on or about S~tember 12 and continue un~il work is cOmplete. ' --~ ................................ It is understood gas flaring will be kept to a minimum whenever 'possible, and ali volumes will be reported monthly on Alaska Oil and Gas Conservation Co~m~ission form 10-422. Ail gas produced ir~ excess of' the 1000 MCFD safety flare pilot volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, , /? ,.?' : ? ... BY ORDER OF THE COMMISSION dlf/3.AA145 September 1, 1989 Telecopy No. (907) 270-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A.43 Re: Additional flare volume, FS fi3, Prudhoe Bay Unit. M A Major Operations Representative Prudhoe Bay/Lisburne Operations ARCO Alaska, Inc P O Box 100360 Anchorage, AK 99510-0360 Dear Mr Major: We have received your letter of August 9, 1989 requesting ap- proval to flare up t.o 3.25 MMCF of gas at Flow Station ~/3 (FS3). The flare volume requested is needed during repair and surveil- lance of FS3 ¢ommonlines. The Commission finds the additional flare, gas to be an operation- al necessity, and hereby approves flaring.i'up to 3.25 MMCF of gas over and above the designated safety flare pilot at'FS3. Flaring is scheduled to begin on or about September 1 and continue until work is complete. it is understood gas flaring will be kept to a minim~n whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas COnservation Commission form 10-422. Ail gas produced in excess of the 1000 MCFD safety flare pilot volume is subject to AS 43.55.020, and will be disposed of in a saf,e manner by flaring or~usgd for lease operation. BY ORDER OF THE July 7, 1989 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A.42 Additional flare volume, FS ~2, Prudhoe Bay Uni~t. M A Major Operations Representative Prudhoe Bay/Lisburne Operations ARCO Alaska, Inc P O BoX 100360 Anchorage, AK 99510-0360 Dear Mr Major: We have received your letter of June 27, 1989 requesting approval to flare up to 35 MMCF of gas at Flow Station #2 (FS2). The flare volume requested is needed during corrosion inspection of FS2 commonlines and subsequent repair if necessary The Commission finds the additional flare gas to be an opera- tional ~necessity, and hereby approves flaring up to 35 MMCF of gas over and above the designated safety flare pilot at FS2. Flaring is scheduled to begin on or about July 15 and continue until work is complete. It is understood.gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska 0il and Gas Conservation Commission form 10-422. A,.%t..gas produced in excess of the 1000 MCFD safety flare pilot ~"~'~01ume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. BY ORDER OF THE COMMISSION Jo/3.AA145 June 29, 1989 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A. 41 Re, Additional flare volume, FS f2, Prudhoe Bay Unit. M. A. Major Operations Representative Prudhoe Bay/Lisburne Operations ARCO Alaska, Inc P O Box 100360 Anchorage, AK 99510-0360 Dear Mr Major: We have received your~letter of June 27, 1989 requesting approval ~o flare up to 15 MMC~ of gas at Flow Station #2 (FS-2). The flare volume requested is needed to accomodate shutdown/startup activities~ of the FS-2 facility. The Commission finds the additional flare gas to be an opera- tional necessity., and hereby approves flaring up to 15 ~R~CF of gas over and above the designated safety flare pilot at FS-2. Flaring is scheduled to begin on or about June 30 and continue until work is complete, It is understood gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 1000 MCFD safety flare pilot volume is subject to AS 43.55.020, and will be disposed of 'in a safe manner by flaring or used for lease operation. Commissioner : BY ORDER OF THE CO~MISSION dlf/3.AA145 May 4, 1989 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A.40 Re: Additional flare volume, FS ~1, Prudhoe Bay Unit. M. A. Major Operations Representative Prudhoe Bay/Lisburne Operations ARCO Alaska, Inc P 0 Box 100360 Anchorage, AK 99510-0360 Dear Mr Major: We have received your letter of M~~989 requesting approval to flare up to 4 MMCF of gas at Fl-ow Station ~1 (FS,1). The flare volume requested will allow for depressurization of the "A" and ':'C" processing trains prior to shutdown and maintenance. The Commission finds the additional flare gas to be an opera- tional necessity, and hereby approves flaring up to 4 MMCF of gas over and above the designated safety flare pilot at FS-1. Flaring is scheduled to begin on or about May 8 and continue until work is complete. ~-~ ....... It is understood gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. Ail gas produced in excess of the 1000 MCFD safety flare pilot volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sinc$.rely, // Commissioner BY ORDER OF THE. CO~ISSION dlf/3.AA145 March 3, 1989 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A.39 Re: Additional flare volume, FS #2, Prudhoe Bay Unit. M. A. Major Operations Representative Prudhoe Bay/Lisburne Operations ARCO Alaska, Inc P O Box 100360 ~chorage, AK 99510-0360 Dear Mr Major: We have received your letter of March 2, 1989 requesting approval to flare up to 50 MMCF of gas at Flow Station ~2 (FS-2). The flare volume requested is needed to verify the mechanical integrity of the existing emergency flaring system. The Commission finds the additional flare gas to be an oper.a tional necessity, and hereby approves flaring up to 50MI~CF of gas .'.~ .? over and above the designated safety flare pilot at FS-2. Flaring is scheduled to begin on or about M~a.~r~.h._~ and continue until work is complete. It is understood gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. Ail gas produced in excess of the 1000 MCFD safety flare pilot volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, ,/ , '~ , ;: ...~ , Lonnie C. Smith Commissioner BY ORDER OF THE COP~ISSION dlf/3.AA145 Telecopy No. (907) 276-7542 January 26, 1989 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A.38 Re: Additional safety flare volume, FS #1, Prudhoe Bay Unit. M A Major Operations Representative Prudhoe Bay/Lisburne Operations ARCO Alaska, Inc P 0 Box 100360 Anchorage, AK 99510-0360 Dear Mr Major: We have received your letter of January 20, 1989 requesting approval to flare up to 50 MMCF of additional gas at Flow Station #1 (FM-1). The additional flare volume will be needed while performing modifications to the flare system controllers at FS-1. The Commission finds the additional flare gas to be an opera- tional necessity, and hereby approves~flaring up to 50MMCF of gas over and above the designated safety flare at FS-1. Flaring is scheduled to begin on or about January 26 and continue until work is complete. It is understood gas flaring will be kept to a minimum whenever possible, and all volumes will be' reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. Sincerely, Chairman BY ORDER OF THE COMMISSION jo/3.AA145 January 6, 1989 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A. 37 Re: Additional safety flare volume, Flow Station ~2, Prudhoe Bay Unit. M A Major Operations Representative Prudhoe Bay/Lisburne Operations ARCO Alaska, Inc P 0 Box 100360 Anchorage, AK 99510-0360 Dear Mr Mai or.. We have received your letter of January 3, 1989 requesting approval to flare an additional 15,700 MCF of gas at Flow Sta- tion #2 (F$2) in the Prudhoe Bay Unit, Eastern Operating Area. The additional flare volume will result from gas used to depres- sure and/or sweep common flowlines so that inspections can b~ made (including radiographic) and the lines can be repaired as necessary during January to June, 1989. The Commission finds the additional flare gas to be an operation- al necessity, and hereby approves flaring up to 15,700 MCF of gas over and above the designated safety flare at Flow Station 2. Flaring is scheduled to begin in January 1989 and continue until work is complete sometime in June 1989, It is understood gas flaring will be kept to a minimum whenever possible and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. Sincerely, Lonnie C Smfth- Commissioner BY ORDER OF THE COMMISSION dlf/3.AA145 October 5, 1988 Telecopy No. (907) 276-7542 A D I.I I N I $ T R A T I V E A P P R O V A L N O. i45-A.36 Re: Additional safety flare volume, Flow Station ~!1, Prudhoe Bay Unit. M A Major Operations Representative Prudhoe Bay/LisburneOperations ARCO Alaska, Inc P 0 Box 100360 Anchorage, AK 99510-0360 Dear Mr Major: We have received your letter of October 3, 1988. On behalf of ARCO Alaska, Inc you are requesting approval to flare an addi- tional 7 ~.~SCF of gas at Flow Station #1 (FSI) in the Prudhoe Bay Unit, Eastern Operating Area. The additional flare volume will be a result of shutdown and startup activities of the "B'~ pro- cessing train at FSI for vessel cleanout/inspection, sand jet installation, conversion to low pressure separation and other maintenance . The Commission finds the additional flare to be an operational necessity, and hereby approves flaring up to 7 MMSCF of gas over and above the designated safety flare at Flow Station 1. Flaring is scheduled to begin on or' about October 10, 1988 and continue Until work is complete. It is understood gas flaring will be kept to a minimum whenever possible and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. BY ORDER OF THE COR~fISSION dlf/3.AA145 September 22, 1988 Telecopy t~o. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A.35 Re: Additional flare volume, Flow Station f/3, Prudhoe Bay Unit. M A Major Operations Representative Prudhoe Bay/Lisburne Operations ARCO Alaska, Inc P O Box 100360 Anchorage, ~K 99510-0360 Dear Mr Major: We have received your letter of September 19, 1988. On 'behalf of ARCO Alaska, Inc you are requesting approval to flare an additional 2 MMSCF of gas at Flow Station #3 (FS3). The flaring will be a result of shutdown and startup of the FS3 "B" process- ing train for maintenance and modifications. The Commission finds the flaring to be an operational necessity, and hereby approves flaring up to 2 MMSCF of gas over and above the allowable safety flare volume at FS3. Commencement of flaringwill be on or about.October 1, 1988 and continue until the work is completed. It is~understood all gas flaring will be kept to a minin%um whenever possible. Sincerely, ?.~ ~L. onnie/': C/Smith Commiss ionor BY ORDER OF THE COM~IISSION jo/3.AA145 May 31, 1988 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A.34 Re: Additional flare volume, Central Gas Facility, Prudhoe Bay Unit. M. A. Major Operations Representative Prudhoe Bay/Lisburne Operations ARCO Alaska, Inc P O Box 100360 Anchorage, AK 99510-0360 Dear Mr. Major: We have received your letter of May 23, 1988. On behalf of ARCO you are requesting approval to flare up to 300 P~SCF of gas at the Central Gas Facility (CGF) in the Prudhoe Bay Unit, Eastern Operating Area. The flaring will occur while performing capacity tests of the CGF flare system. The Commission finds the flaring to be an operational necessity and hereby approves flaring up to 300 MMSCF of gas over and above the designated safety flare volume approved for the CGF. Com- mencement of flaring will be on or about June 9, 1988 and contin- ue until testing is completed. It is understood that the flare volume will be kept to a minimum, and all gas flared under this authorization shall be metered and is subject to AS 43.55,020(e). S i~c e r e l~y, ?? Lonnie C. Smith Commissioner BY ORDER OF THE COMMISSION dlf/3.AA145 April 22, 1988 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A, 33 Re: Additional flare volume Flow Station #2, Prudhoe Bay Unit, T. M. Drumm Operations Representative ARCO Alaska, Inc P 0 Box 100360 Anchorage, AK 99510-0360 Dear Mr. Dr~nm: In accordance with our phone conversation of April 22, 1988 and subsequent correspondence of April 25, 1988 you have requested additional flare vol~!me for Flow Station ~2 in the Prudhoe Bay Unit. Additional flaring will result from repair work of the common lines from drillsites 3, 9 and 17. Repair work consists of line pressurization and de-pressurization associated with real time radiographic work and line replacement where necessary. The Commission finds the flaring to be an operational necessity and hereby approves flaring up to 28 MMSCF of gas over and above the designated safety flare volume approved for Flow Station #2. Commencement of flaring will be on or about April 22, 1988 and continue through the middle of June, 1988. It is understood that the flare volume will be kept to a minimum, and all gas' flared under this authorization shall be metered and is subject to AS 43.55.020(e). Chairman BY ORDER OF THE COP~.~ISSION dlf/3..AA145 April 4, 1988 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A.32 Re: Additional flare volume Flow Station #2, Prudhoe Bay Unit. M A Major 'Operations Coordinator Prudhoe Bay/Lisburne Operations ARCO Alaska, Inc P 0 Box 100360 Anchorage, AK 99510-0360 Dear Mr Major: We have received your letter of March 29, 1988. On behalf of ARCO you are requesting approval to flare up to 12.5MMSCF of gas over a 24-hour period at the Flow Station No. 2 (FS2) in the Prudhoe Bay Unit, Eastern Operating Area. The flaring will occur while making tie-ins' to the gas coolers at FS2. The Commission finds the flaring to be an operatiOnal necessity and hereby approves flaring up to 12.5MMSCF of gas over and above the designated safety flare volume apProved for FS2. Com- mencement of flaring will be on or about April 5, 1988 and continue for approximately 24 hours. It is understood that the flare volume will be kept to a minimum, and all gas flared under this authorization shall be metered and is subject to AS 43.55.020(e). Sincerely, ~ ~ Lonnie C Smith Co~issioner BY ORDER OF THE COMMISSION dlf/3.AA145 March 10, 1988 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R 0 V A L N O. 145-A.31 Re: Additional flare volume Central Compressor Plant, Prudhoe Bay Unit. M A Major Operations Coordinator Prudhoe Bay/Lisburne Operations ARCO Alaska, Inc P O Box 100360 Anchorage, AK 99510-0360 Dear Mr Major: We have received your letter of March 9, 1988. On behalf of ARCO you are requesting approval to flare up to 5MMCF of gas over a five day. period at the Central Compressor Plant (CCP) in the Prudhoe Bay Unit., Eastern Operating Area. The flaring will occur while making piping changes to reroute seal oil vapors back to the fuel inlet header for the compressors at the CCP. The Commission finds the flaring to be an operational necessity and hereby approves flaring up to 5MMSCF of gas over and above the designated safety flare volume approved for the CCP. Com- mencement of flaring will be on or about March 10, 1988 and continue for approximately five .days. It is understood that the flare volume will be kept to a minimum, and all gas flared under this authorization shall be metered and is subject to AS 43.55.020(e). BY ORDER OF THE COP~ISSION dlf/3.AA145 March 3, 1988 Telecopy No. (907) 276-7542 A D M I N I S T R A T i V E A P P R O V A L N O. 145-A.30 Re: Request for additional flare volume, Central Gas Facility (CGF), Prudhoe Bay Unit M A Major Operations Coordinator Prudhoe Bay/Lisburne Operations ARCO Alaska, !nc P 0 Box 100360 Anchorage, AK 99510-0360 Dear Mr Ma jet: We have received your letter of March 1, 1988. On behalf of ARCO you are requesting approval to flare up to 5MMCF of gas over a 10-day period at the CGF in the Prudhoe Bay Unit, Eastern Oper- ating Area. The flaring will occur while making modifications to the flare header to eliminate vibration problems. The Commission finds the flaring to be an operational necessity and 'hereby approves flaring up to 5MMSCF of gas over and above the designated safety flare volurae approved for the CGF. Com- mencement of flaring will be on or about March 10, 1988 and continue for approximately ten days. It is understood that. the flare volume will be kept to a minimum, and all gas flared under this authorization shall be metered and is subject to AS 43.55.020(e). Singerely,. ........ ,,' .~ fL.fb" Lonnie C Smith C o'mmi s s ioner BY ORDER OF THE COMMISSION jo/3.AA145 February 26, ]988 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R 0 V A L N O. 145-A.29 Re: Excess flaring, Central Compressor Plant (CCP), Prudhoe Bay Unit M A Major Operations Coordinator Prudhoe Bay/Lisburne Operations ARCO Alaska, Inc P 0 Box 100360 Anchorage, AK 99510-0360 Dear Mr Major: We have received your letter of February 25, 1988. You have requested approval to flare additional gas (beyond allowable safety flare) at the CCP in the Prudhoe Bay Unit. The reason for the excess flare is due to repairs that are required on the compressor fuel inlet header. The Connnission finds that the additional flare volume is an operational necessity and hereby approves flaring an additional 5MMSCF at the CCP during repair work. Excess flaring will commence on or about February 26, 1988. It is understood that the flare' volume will be kept to a minimum, and .all gas flared under this authorization shall be metered and is subject to AS 43.55.020(e). C ommis s loner BY ORDER OF THE COMMISSION jo/3 .AA14'5 November 27, 1987 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A.28 Re: Flow Station 3 flare testing. M A Major Operations Coordinato~ Prudhoe Bay/Lisburne Operations ARCO Alaska, Inc P O Box 100360 Anchorage, AK 99510-0360 Dear Mr Major: We have received your letter of November 24, 1987 requesting additional flare volume at Flow Station 3 (FS3) to conduct flare capacity testing. The purpose of the testing is to gather accurate data to establish safe flare limits for current and future operations at FS3. The Commission finds that the additional flare volume zs an operational necessity, and hereby approves flaring an additional 35MMSCF of gas at FS3. Testing is to conmnence on or about December 7, 1987 and continue until testing is complete. It is understood the flare volume will be kept to a minimum., and all gas flared under this authorization shall be metered and is subject to AS 43.55.020(e). Lonnie C' Smith Commissioner BY ORDER OF THE COMMISSION jo/3.AA145 September 28, 1987 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A.27 Re: Additional flare volume - Lisburne Production Facility. M A Major Operations Coordinator. Prudhoe Bay Operations ARCO Alaska, Inc P O Box 100360 Anchorage, AK 99510-0360 Dear Mr Major: We have received your letter of September 24, 1987 requesting additional flare volume at the Lisburne Production Facility (LPF) due to the scheduled TAPS shutdown and pending LGI-6 workover. The Commission finds the additional flare volume in each case to be an operational necessity. The Commission hereby approves an additional flare volume, of 50 MMSCF for the LPF shutdown and restart as a result of'the pipeline shutdown. An additional flare volume of 60 MMSCF is approved for the LPF during the rig-up rig-down for the workover of the LGI-6. The pipeline shutdown and corresponding flaring will start on or about September 29, 1987. The LGI-6 workover should begin within 10 days of the pipeline, shutdown. Excess flaring will cease when the jobs are completed. It is understood the flare volumes will be kept at a minimum, and all gas flared under this authorization shall be metered and is subject to AS 43.55.020(e). Szr~relyf~ (,/ Commissioner BY ORDER OF THE COMMISSION jo/3oAA145 September 23, 1987 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A.26 Re: Additional flaring at 'Flow Stations 1, 2, 3 and Central Gas Facility (CGF) Prudhoe Bay Unit - Eastern Operating Area (PBU-EOA) M A Major Operations Coordinator Prudhoe Bay Operations ARCO Alaska, Inc P O Box 100360 Anchorage, AK 99510-0360 Dear Mr Major: We have received your letter of September 22, 1987 requesting additional flare volume at the subject facilities due to the scheduled Trans-Alaska Pipeline System shutdown and ARCO Alaska, Inc's planned maintenance activities at these facilities. The Commission recognizes the requested flare volumes are an operational necessity, and hereby approves additional flare volumes for the following facilities and periods. ...Flow Station #1: Maximum 'additional flare volume of 15 MMSCF beginning on or about 1600 hours on September 28, 1987 and ending after routine maint- enance activities are completed. Flow Station #2: Maximum additional flare volume of 10 MMSCF beginning on or about 1600 hours September 28, 1987 and ending after routine maint- enance activities are completed. An additional 1.5 MMSCF of flare volume is approved for de- pressuring the production trains prior to piping and vessel modifications on or about October 12 and O~tober 26, 1987. Administrative Approval No. 145-A.26 ARCO Alaska, Inc September 23, 1987 Page 2 Flow Station #3: Maximum additional flare volume of 10 MMSCF beginning on or about 0001 hours September 28, 1987 and ending after vessel inspection/ recertification activities and flare system valve replacement are completed. Central Gas Facility: Maximum additional flare volume of 13 MMSCF beginning on or about 1600 hours on September 28, 1987 and ending after routine maint- enance activities are completed. It is understood the flare volumes will be kept at a minimum, and all gas flared under this authorization shall be metered and is subject to AS 43.55.020(e). Sincerely, Lonnie C Smith Commissioner BY ORDER OF THE COMMISSION jo/3.AA145 August 10, 1987 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A.25 Re: Excess flaring at Gathering Center 1. Robert C. Youngmun Manager, Production Accounting Standard Alaska Production Company P. O. Box 196612 Anchorage, AK 99519-6612 Dear Mr. Youngmun .. We have received your letter dated August 10, 1987 requesting an excess flare volume at Gathering Center 1 (GC-1). The excess flare volume .is required to perform a test of the modified flare control system. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring no more than 50 MMSCF of additional gas at GC-1 during testing of the flare system. Testing is scheduled to begin on or about August 10, 1987. It is understood the flare volume will be kept at a minimum, and all gas flared under this authorization shall be metered and is subject to AS 43.55.020(e). Sin~erely~ _-/. .... Lonnie C. Smith Commissioner BY ORDER OF THE COMMISSION jo/3.AA145 May 4, 1987 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A.24 Re: Flaring at Flow Station #3 (FS3), Prudhoe Bay Unit, Eastern Operating Area. Mr. M. A. Major Operations Coordinator Prudhoe Bay Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorage, AK 9510-0360 Dear Mr. Major: We have received your letter dated May 4, 1987 requesting additional flare volume at the FS3 facility. Flaring at FS3 is needed, due to problems experienced with miscible injectant~ (MI) diversion from the Central Gas Facility (CGF) to FS3. The Commission finds that flaring of additional gas during. ongoing repairs is preferable to shutting down the facility, and constitutes an operational necessity. The Commission hereby approves flaring up to 30 MMSCF/day of gas at FS3 until repairs to the compression system are completed. It is understood the flare volume will be kept to a minimum, and all gas flared under this authorization shall be metered and is subject to AS 43.55.020(e). Sincere 1 y~.,~,w Lonnie C. Smith Commissioner BY ORDER OF THE COMMISSION jo/3.AA145 March 26, 1987 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A.23 Re: Excess flaring at Gathering Center 1. Mr. Robert C. Youngmun Manager, Production Accounting Standard Alaska Production Company P. O. Box 196612 Anchorage, AK 99519-6612 Dear Mr. Youngmun: We have received your letter dated March 19, 1987 requesting an excess flare volume at Gathering Center 1 (GC-1). The excess flare volume is required for high gas rate process testing. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring no more than 50 FR~SCF of additional gas at GC-I during high gas rate process testing. Testing is scheduled to begin on or about April 1, 1987. It is understood that the flare volume will be kept at a minimum., and all gas flared under this authorization shall be metered and is subject to AS 43.55.020(e). Sing~erely, ,,, ....... /~, Lonnie C. Smith Commissioner BY ORDER OF THE CO~iISSION jo/3.AA145 Mar ch 17, 1987 Telecopy No. (907) 276-7542 A D M i N I S T R A T I V E A P P R O V A L N O. 145-A.22 Re: Central Gas Facility (CGF) upset flaring. Mr. M. A. Major Operations Coordinator Prudhoe Bay Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorage, AK 99510-0360 Dear Mr. Major: By letter dated March 16, 1987, on. behalf of ARCO Alaska, Inc., you requested approval for flaring miscible injectant (MI) at the CGF while resolving MI compressor problems. The problems are due primarily to an explosion which occurred March 14, 1987 in the seal oil reservoir of one'of the two MI compressor units at the CGF. The second MI compressor cannot be utilized until gearbox malfunctions are corrected. Repairs to both compressors are underway. The CGF will be operated at reduced rates of about 15-20 MBBL/day of NGL's, and 30 MMSCF/day of MI until gearbQx problem-s with the second MI compressor are resolved, or until other alternatives of dealing with the MI may be implemented. A complete shutdown of the CGF is not a viable alternate because of the large gas volumes necessarily flared during the CGF shutdown and startup operation. The Commission finds the flaring of the MI stream an operationml necessity during the interim. Therefore, the Commission hereby authorizes the. flaring of up to 30 MMSCF/day of MI until repairs to the second MI compressor are completed, or until other' alternatives may be devised and implemented. Administrative Approval No. 145-A.22 March 17, ]987 Page 2 It is understood that the flare volume will be kept at a minimum, and all gas flared under this authorization shall be metered and is subject to AS 43.55.020(e). S~r~cere ly, 7 Lonnie C. Smith Commissioner BY ORDER OF THE COMI~ISSION jo/3.AA]45 February ]9, 1987 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A.21 Re: Central Gas Facility (CGF) startup flaring. Request for additional flare volume. Mr. M. A. Major Operations Coordinator Prudhoe Bay Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorage, AK 995]0-0360 Dear Mr. Major: We have received your letter of February 17, 1987 requesting additional flare volume for startup and commissioning of the CGF. The additional flare volume is required for commissioning the second miscible injection (MI) compressor and the Western Operating Area MI line. An additional 500 MMSCF of flare volume may be necessary to complete CGF startup over and above the 2.43.MPR{SCF approved in AA 145-A.17 and AA ]45-A.20. The Commission finds the additional flare volume is an operational necessity, and hereby approves flaring an additional 500 MMSCF of gas at the CGF. The maximum of gas authorized to be flared during commissioning and startup of the CGF is now 2.93 MMMSCF. It is understood that the flare volume will be kept to a minimum, and all gas flared under this authorization shall be metered and is subject to AS 43.55.020(e). Sincerely, C~Lonnie C..Smith Commissioner BY ORDER OF THE COMMISSION jo/3.AA145 .,. January 28, 1987 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P'P R O V A L N O. 145-A. 20 Re: Central Gas Facility (CGF) startup flaring. Request for additional flare volume. Mr. M. A. Major Operations Coordinator Prudhoe Bay Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorage, Alaska 99510-0360 Dear Mr. Major: We have received your letter of January 26, 1987 requesting additional~ flare volume for commissioning and startup of the CGF. The additional flare volume is needed due to mechanical difficulties and operational procedure problems related to the miscible injection process equipment. An additional 1MMMSCF of flare volume may be necessary to complete CGF startup over and'above the 1.43 MMMSCF volume approved in AA 145-A.17. The Commission finds that the additional flare volume is an operational, necessity and hereby approves flaring an additional 1MMMSCF of gas at the CGF. The maximum of gas authorized to be flared during commissioning and startup of the CGF is now 2.43 M~fSCF. it is understood that the flare' volume will be kept at a minimum, and all gas flared under this authorization shall be metered and is subject to AS 43.55.020(e). Lomnie C. Smith Commissioner BY ORDER OF THE COMMISSION jo/3.AA145 January 28, 1987 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A.19 Re: Flaring during performance testing of first stage separators at Gathering Center #I (GC-1) Mr. Robert C. Youngmun Manager, Production Accounting Standard Alaska Production Company P. O. Box 196612 Anchorage, AK 99519-6612 Dear Mr. Youngman: We have received your'letter of January 22, 1987 requesting to flare gas at GC-1. It is understood that flaring is necessary in order to conduct 'performance te.sting on first stage separators at the Gathering Center. Testing is scheduled for the period January 26-30, 1987, and a maximum of 50 MMSCF of gas will be flared~ The Commission has determined this to be a case of operational necessity.. By this letter, Standard Alaska Production CompanM is authorized to flare up to 50 MMSCF of gas from GC-1 as described above or until the tests are complete. The Commission under- stands that the flare volume will be kept at a minimum for this work, and all gas flared under this authorization shall be metered and is subject to AS 43.55.020(e). Sincerely, , 1 .'Smith Commissioner BY ORDER OF THE CO~MISSION jo/3.AA145 November 13, 1986 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A.18 Re: Planned Flaring at Flow Stations~ 1, 2 and 3, Prudhoe Bay Unit (PBU), Eastern Operating Area (EOA). Mr. M. A. Major Operations Coordinator Prudhoe Bay Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorage, Alaska 99510-0360 Dear Mr. Major: We have received your letter of November 12, 1986 requesting approval to flare gas at Flow Stations t, 2 and 3 in the PBU. This gas flaring will be a result of depressuring the artificial lift system to perform maintenance activities and modifications to the artificial lift warm-up header located in module 4906 of Flow Station 3. The CommissiOn finds that gas flaring during this time is an operational necessitY. The Con~ission hereby approves flaring of up to 4.15 MMSCF of gas from Flow Stations 1, 2 and 3 in the PBU during activities related to the maintenance and modification of the artificial lift warm-up header. Flaring is to commence about November 18, 1986. It is understood that the flare volume will be kept at a minimum for this work, and all gas flared under this authorization shall be metered and is subject to AS 43.55.020(e). Sincerely, ~.~:Q ..4 ,, f¢-i'" ~Lonnie C. Smith Commissioner BY ORDER OF THE COMPIISSION dlf/3.AA145 November 10, 1986 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A.L N O. 145-A.17 Re: Central Gas Facility (CGF) Startup Flaring Mr. M. A. Major Operations Coordinator Prudhoe Bay Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorage, Alaska 99510-0360 Dear Mr. Major We have receiVed your letter of November 7,~ 1986 requesting flaring of gas during commissioning and startup of the CGF complex. The Commission finds that flaring of gas during the commissioning of the CGF constitutes an operational necessity. The Commission hereby approves flaring of up to 1.43 MMMCF of gas during com- missioning and startup of the CGF, commencing about November 15, 1986. The Commission requests that a brief progress report of startup operations be submitted no later than January 15, 1987. It is understood that the flare volume will be kept at a minimum for this work, and all gas flared under this authorization shall be metered and is subject to AS 43.55.020(e). Chairman BY ORDER OF THE COMMISSION jo/3.AA145 October 6, 1986 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R 0 V A L N O. 145-A.16 Re: Flaring during calibration and testing of Micon HP Flare Controller at GC-3. Mr. Robert C. Youngmun Manager Production Accounting. Standard Alaska Production Company P. O. Box 196612 Anchorage, AK 99519-6612 Dear Mr. Young~nun: We have received your letter of September 16, 1986 requesting to flare gas at Gathering Center #3. It is understood, that the flare is necessary' in order to calibrate and test the Micon HP Flare Controller installed recently. Testing is scheduled for the period October 16-22, 1986, and a maximum of 4MMSCF of gas will be flared. The Commission has determined this to be a case of operational necessity. By this letter, Standard Alaska Production Company.is authorized to flare up 'to 4~MSCF of gas from Gathering Center #3 as described above, or until the tests are complete. It is understood that the flare volume will be kept at a minimum for this work, and all gas flared under this authorization shall be metered and is subject to AS 43.55.020(e). Sincerely, i' Lonnie C. Smith Commissioner jo/3.AA145-A. !6 September 23, 1986 Telecopy No.. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A.15 Re: Flaring during calibration and testing of Micon HP Flare Controllers at GC-1 and GC-2. Mr. Robert C. Youngman Manager Production Accoun. ting. Standard Alaska Production Company P. O. Box 196612 Anchorage, AK 99519-6612 Dear Mr. Youngman: We have received your letter of September 16, 1986 requesting permission to flare gas at Gathering Center ~1 and Gathering Center #2. It is understood that the excess flare is necessary in order to calibrate and test the new Micon }~ Flare Controllers installed recently at each facility. Your estimated time and flaring requirements are as follows: Gathering Center #] Gathering Center ~2 4FR~SCF 4PlMSCF September 27, 1986 September 25, 1986 The Commission has determined that these are cases of operational necessity. By this letter Standard Alaska Production Company is authorized to flare up to 8~SCF of produced gas from the Gathering Centers, as described above, or until the tests are complete. It is understood that the flare volume will be kept at a minimum for this work, and all gas flared under this author- ization shall be metered arid is subject to AS 43.55.020(e). jo/3.AA]45-A.15 September 4, 1986 Tele¢opy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A.14 Re: Shutdown of Flow Station ~3 Mr. M. A. Major Operations Coordinator ARCO Alaska, Inc. P. O. Box 100360 Anchorage, AK 99510-.0360 Dear Mr. Major: We have received your letter of September 3, 1986 requesting permission to flare up to 20 MMSCF gas during the shutdown of Flow Station f~3. It is understood that the facility shutdown is an operational necessity in order to perform piping modifications which will facilitate tie-in with the Central Gas Facility. These operations are scheduled to begin on Friday, September 5, 2986, and should be completed by September 12, 1986. The Commission has determined that this is a case of operational necessity, and by this letter ARCO Alaska, Inc. is hereby authorized to flare up to 20 MMSCF of produced gas at Flow Station ~'3 over a seven (7) day period which is now planned to commence on September 5, 1986. It is understood that the flare volume will be kept at a minimum in performing this work, and all gas flared under this authorization shall .be metered and is subject to AS 43.55.020(e). Yours ver~y .Zruly, Lonnie C. Smith Commissioner BY ORDER OF THE COMMISSION' jo/3.AA145-A.14 August 8, 1986 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A. 13 Re: Flaring During Start-up of Gathering Centers after Turnaround Mr. Robert C. Youngmun Manager Production Accounting Standard Alaska Production Company P. O. Box 196612 Anchorage, Alaska 995~2-0612 Dear Mr. Youngmun: We have received your letter of August 8, 1986 requesting permis- sion to flare gas during start-up of Gathering Centers #1, ~2, and #3 following shutdown for maintenance work. It is understood that the facility shut down is an operational necessity that provides for preventative maintenance and various repairs and modifications to the various systems. These op- erations require flaring of gas during system checkout and facility start-up. Your estimated start-up timings and flaring requirements are as fo llows: Gathering Center Gathering Center #2 Gathering Center #3 25 MMSCF August 7-9, 1986 25 M2~SCF .August 28-30, 1986 25 ~ISCF September 18-20, 1986 Therefore, by this letter, Standard Alaska Production Company is hereby authorized to flare up to 25 MMSCF of produced gas at each of the Gathering Centers during start-up, after shut down. for maintenance, during the dates indicated above. It is understood that the flared volumes will be kept to the minimum necessary to accomplish equipment check-out and facility start-up and that all gas flared under this authorization shall be metered and is subject to AS 43.55-020(e). Yo ~"rs Ver Lonnie C. Smith Commissioner BY ORDER OF THE CO~4ISSION dlf:3.AA145-A.13 July 15, 1986 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A.12 Re: Shutdown of Flow Station No. 1 Mr. M. A. Major Operations Coordinator ARCO Alaska, Inc. P. O. Box 100360 Anchorage, AK 99510-0360 Dear Mr. Major: We have received your telephone request of July 14, 1986 and. letter of July 15, 1986 requesting permission to flare up to 55 MMSCF gas during the shutdown of Flow Station No. 1. It is understood that the facility shutdown is an operational necessity that provides for preventative maintenance and a variety of upgrade modifications and repairs to the various systems. These operations require flaring of gas during shutdown, check-out and startup of such activities as crude cooling, crude heating, HP gas relief, produced water overpressure/overflow protection, etc. Also, your revised schedule is to begin the shutdown on July 16, 1986, and to restart the facility' on July 31, 1986, but to provide for unforeseen circumstances you have requested several additional days after the' specified period for flexibility. Therefore, by this letter, ARCO.Alaska, Inc. is hereby authorized to flare up to 55 MMSCF of produced gas at Flow Station No. 1 for the purpose of plant modifications and repairs during the period from July 16, 1986 to August 7, 1986. It is understood that.the flared volume will be kept at a minimum in'performing this work and all gas flared under this authorization shall be metered and is subject to AS 43.44.020(e). Commissioner BY ORDER OF THE COMMISSION jo :3.AA145-A. 12 June 11, 1986 TELECOPY NO. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. !45-A. 11 Re: Annual Turnaround Flow Station No. 3 Mr. M. A. Major Operations Coordinator ARCO Alaska, Inc. P. O. Box 100360 Anchorage, Alaska 99510-0360 Dear Mr. Major: We have received your letter of June 6, 1986, requesting permis- sion to flare up to 34 ~MSCF gas during the 1986 plant turnaround for Flow Station No. 3. It is understood'that the plant turnaround is an operational necessity that provides for annual preventative maintenance and a variety of upgrade modifications to the various systems. These operations require flaring of gas during shutdown, check-out and startup of such activities as crude cooling, crude heating, HP gas relief, produced water overpressure/overflow protection, etc. Also, your schedule is to begin the shutdown on June 23, 1986, for a period of 11 days, to end on July 3, 1'986, but to provide .for unforeseen circumstances you have requested several addition- al days before and after the specified period for flexibility. Therefore, by this letter, .ARCO Alaska, Inc. is hereby authorized to flare up to 34 ~{SC'F of produced gas at Flow Station No. 3 for the purpose of plant turnaround and modifications during the period from June 15, 1986 to July 15, ]986. It is understood that the flared volume will be kept at a minimum in performing this work and all gas flared under this authorization shall be metered and is subject to AS 43.55.020(e). Your~7 veryt t,,~y , ~nnie C. "Smith Commissioner BY ORDER OF THE COMMISSION dlf: 3.AA145 April 9, 1986 TELECOPY NO. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A. 10 Re: Vibration Test During Flaring Mr. Robert C. Youngmun Manager Production Accounting Standard Alaska Production Company P. O. Box 196612 Anchorage, Alaska 99502-0612 Dear Mr. Youngmun: We have received your letter of April 7, 1986, requesting permission to flare gas for the purpose of determining the cause of failures in the PSV bellows. It is understood that you will flare through one of the.double slug catcher banks at either Gathering Center (GC) 1 or 3 while taking vibration data tests readings at several places along the header and flare valve discharge piping. Also, you have scheduled these tests to commence April 10, 1986, expect to flare a maximum of 4 MMSCF of gas and to complete all tests by April 17, 1986. · Therefore, by this letter, 'Standard Alaska Production Company is hereby authorized to flare up to 4 ~{SCF of produced gas to collect vibration data at GC-1 or GC-3, to be complete by April 17, 1986. It is understood that the flared volume will be kept at a minimum in gaining the necessary data and all gas flared under this authorization shall be metered and is subject to AS 43.55.020(e). Yours very truly Lonnie C. Smith Commissioner BY ORDER OF THE CO~MISSION dlf: 3.AA145 April 2, 1986 Telecopy No. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A.9 Re: Flare and Relief System Tests Mr. Robert C. Youngmun Manager Production Accounting Standard Alaska Production Company P. O. Box 196612 Anchorage, AK 99502-0612 Dear Mr. Youngmun.. We have received your letter of April 1, 1986, requesting permission to continue the Flare and Relief testing at Gathering Center (GC) 2. it is understood that this test was previously approved in Administrative Approval No. 145-A.7 and 145-A.8, but that you were unable to complete it by the cut-off date of March 31, 1986. Also, you have rescheduled this test and expect to complete it by April 10, 1986. Therefore, by this letter, Standard Alaska Production Company is hereby authorized to flare up to 25 },~CF of produced gas during Flare and Relief testing at GC-2 to be complete by April 10, 1986. It is understood that the flared volume will be kept at a minimum in gaining the necessary data, and all gas flared under this authorization shall be metered and is subject to AS 43.55.020 (e). Yours very~,,~.~,r~uly, Lonnie C. Smith Commissioner BY ORDER OF THE CO~R{ISSION jo:F.LCS.3 March 25, 1986 TELECOPY NO. (907) 276-7542 A D M I N I S T R A T I V E A P P R O V A L N O. 145-A. 8 Re: Flare and Relief System Tests Mr. Robert C. Youngmun Manager Production Accounting Standard Alaska Production Company P. O. Box 19661'2 Anchorage, Alaska 99502-0612 Dear Mr. Youngmun: We have received your letter of March 24, 1986, requesting permission to continue the Flare and Relief testing at Gathering Centers (GC) 2 and 3. It is understood that these are some of the tests approved in Administrative Approval No. 145-A. 7 which you were unable to complete by the cut-off date of February 17 as previously requested; also, you have now rescheduled these tests for March 26 and 27, 1986, and expect to flare up to 25 MMCF at GC-2.and.12 ~{CF at GC-3. Therefore, by this letter, Standard Alaska Production Company is hereby authorized to flare up to 37' MMCF of produced gas during .two separate Flare and Relief tests at GC-2 and GC-3 to be complete in March, 1986. It is understood that the flared volume will be kept at a minimum in gaining the necessary data and all gas flared under this authorization shall be metered and is subject to AS 43.55.020(e). s very~ tjr~ly Lonnie C. Smith Commissioner BY ORDER OF THE COMe.fISSION dlf:3.AA145 '~,. February 13, 1986 TELECOPY NO. (907) 276-7542 Re- A D M I N %_S T R A T I V E A P P R O V A L N O. Flare and Relief System Tests 145-A. 7 Mr. Robert C. Youngmun Manager Production Accounting Sohio Alaska Petroleum Company P. O, Box 6612 Anchorage, Alaska 99502-0612 Dear Mr. Youngmun: We have received your letters of February 4 and 11, 1986, re- questing permission to flare up to 104 ~SCF of gas by Febru- ary 17. It is understood that the gas will be flared at Gather- ing Centers (GC) 1, 2 and 3 in the Prudhoe Bay Field and the flaring will result from a two phase program of Flare and Relief testing conducted by the Production Department to determine their actual capacity for handling larger gas volumes in the future. Each test is expected to be for a duration of less than 12 hours and maximum flare amount for the five tests is estimated to range from 15-30 MMSCF. Therefore, by this letter, Sohio Alaska Petroleum Company is hereby authorized to flare up to 104 ~4SCF of produced gas during five separate Flare and Relief tests at GC-1, GC-2 and GC-3 to be Complete by February 17, 1986. It is understood that the flared volume will be kept at a minimum.in gaining the necessary data during the performance test and all gas flared under' this au- thorization shall be metered and is subject to AS 43.55.020(e), Yours veryr.., ~-r~ly Lonnie C. Smith Commis s loner BY ORDER OF THE COMMISSION dlf: 3. AA145 October 29, 1980 ADMINISTRATIVE APPROVAL Re: Large Diameter Flowlin~ Testing. NO. 145-A. 6 Mr. E. L. Berdon " Operations Coordinator '? ' Atlantic Richfield Compa P. O. Box 360 Anchorage, Alaska 99510' '~ ...... Dear Mr. Berdon: A letter from Atlantic RiChfield Company, dated October 24, 1980, has been received requesting an extension to DeCember 31, 1980 of Administrative Approval No. 145-A.5. . . Administrative Approval No. 145-A.5 was dated~ August 5, 1980 and granted Atlantic Richfield'/Company permission to flare 275 MMSCF of produced gas between mid-August and. N°vember~ 1, '1980 during the course of the referenced operation. Since the testing has been delayed because of the lack of on-site equipment and the same amount of gas Will ultimately be flared~ the request is hereby approved pursuant to Rule 5 of COnservation Order No. 145-A. Yours very truly, ,..,,. ~arry W. Kugler' Commissioner BY THE ORDER OF THE COMMISSION HWK :.dlf August 5, 1980 A D M I N I S T R A T I V E A P P R O V A L NO. 145.A.5 Re: Large Diameter Flowline Testing. Mr. E. L. Berdon Operations Coordinator Atlantic Richfield Company P. O. Box 360 Anchorage, Alaska 99510 Dear Mr. Berdon: A request to flare 275 M~4SCF of produced gas during the testing of a large diameter flowline has been received on July 31, 1980. The operator has requested the Commission to approve the flaring of gas during the testing, which is to determine the flow characteristics of oil, gas and water at pressures in the range of 200 to 300 psi. The tests are to take place between mid-August and November 1, 1980. The request is approved pursuant to Rule 5 of Conservation Order No. 145-A. Yours very truly, Harry W. Kugl~r Commissioner. BY THE ORDER OF THE COMMISSION HWK:be November 8, 1978 Be: Ommdss~~g Flow Station $3, ~ Bay Field Bobert A. Crosky North Alas~ Opera~~ Maua.~ar Atlantic Richfield P.O. Box 360 Anchorage, AlaSka 99510 A ~t to flare prod~ hydrc~arbo~s and/or natural gas during the ~ssianing of Flow Station 93 was' recei~l on N~ 3, 1978. The .ope~ requests the ~ttee to au.~orize the flaring of quantities of gas as are ~zL~d to ~ssian this flow station starting December 1, 1978 and to ext~ over a period of 30 clays after ~ ~troducticn of ~llstream fluids into Flow Station $3. The ~request is approved pursuant to m~le 5 of Cc~servation Orde~ No. 145-A. Very truly yours, / ! / ~msm~ s~- ~/~ ~ s~$ / Conservation .I,4Y S. i'IAMMO~II GOIIEf~NOt~ 300I PO£CLIPI~I£ §£1J/£-. ANCHO£AG£ 9£50! ALASKA OIL A~D c_j~$ CONSERVATION C@..~'~IYTF, F. March 14, 197 8 ADMINISTRATIVE APPROVAL NO. 145.3 Conm, ission~g Gathering[ Center No. 3, P.rudJkoe Bay Field G. N. Nelson Assistant General N~.anager-OE.:erations Sohio/BP Alaska Production Division P. O. Box 4--1379 Anchorage, Alaska 99509 Dear ~r. Nelson: An application to flare gas ~rzn.,. the commissioning of Gathering Center No. 3 was received on March 11, 1978. 55.e operator req..~ests the co~.4ttee to authorize the' .fl,_ring of such q%mmntities of gas as are re~Lired to commfssion tJ~is center starting April 1, 1978 and to extend to cover a .peri(x]. end._~mg one month after the introduction of first oil into Gathering Center No. 3. %~qe above request .is approved pursuant to ...Pule '5 of Conservation Order No. 145-A. Sincere ly, // Thos. R. L',.~arshal.!, Jr. Executive SecretaP./ Alaska Oil and Gas Conse~ation Com~_ttee AGO 10023323 Se~ 14., 1978 Application of the P~ Bay Unit operators, Atlantic Richfield ~ and Sohio-BP, to flare gas during the testing of certa/n pres~ separators to define their capacities. Atlantic Richfield ~y P. ,o. B~x 360 Anch~:, Alaska 99.510 Mr. G. N. Nelsc~. Asst. ~al ~,, Operati~s ,Sonio-B~ al~ ~ D!visi~ ~ 6-612 Anchorage, Alaska 99502 in~ designs, is 'necessary to deteam,/ne the ~, n~s of separato= facilities for the' continued .~l~t ,of the ~oe Bay Field. Th~ .application f~ .states that to. ~tely test the separators, it is e~ that a ~ ~ol~e of I75 ~ of gas ~ ha~ to be flared for ~ticnal necessity. Pursuant to Rule 5 of Cc~servation Order No. 145-A, 'the Oil and Cms. Ommezvat/on C~ittee authorizes the flaring of a ~ volu~ of 175 ~4SCF of gas' ~g the applx~i~ate period of Se~ 22 to September 30, 1978 while gas capacity tests are being .conduc~ .on certain high pressure separa~rs in the Prudhoe Bay Field. -2- September 14., 1978 The cc~ttee re~ that the Division of Oil and Gas Ccn~tic~ be notif~ and appraised of the gas flaring operations throughout the testing period. Very truly yours, t~nrry W. KUgler Alaska Oil and Gas Conservation C~ttee ARCO Alaska, Inc. [ Post Office Box 10 ) Anchorage, Alaska ~9510-0360 Telephone 907 276 1215 November 7, 1994 · · Mr. Russell A. Douglass, Commissioner State Of Alaska Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 Dear Mr. Douolass: Subject: Flaring at the PBU-EOA Facilities to Accommodate Maintenance Activities ARCO Alaska, Inc. (AAI) requests approval to flare up to 5 MMSCF of gas at Flow Station 2 (FS-2) in the Eastern'Operating Area of the PrudhOe Bay Unit (EOA). Every effort will be made to keep flaring to a minimum whenever possible, and all volumes will be reported on the Monthly Gas Disposition Report, Alaska Oil and Gas Conservation Commission form 10-422. · At FS-2, the flaring will occur in conjunction with a full facility shutdown to facilitate repairs to the flare system. Flaring is planned to begin December 8th and should be complete by December 12th, 1994, depending on facility restart problems. The 5 MMSCF volume includes contingencies. , Please contact me or my alternate, J. A. Minier, at 659-5922, if you have any questions. Sincerely, Wally Worthington EOC Supervisor. Prudhoe Bay Operations ARCO Alaska, Inc. Is a Subsidlal7 of AtlanllcRIchlleldCompany R£¢EIV D NOV 1 4 1994 Alas~ 0il & Gas Cons. c0mmlssi~n Anch0rs.,e ARCO Alaska, Inc. Post Office Box 1003 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 August 23, 1994 Mr. Russell A. Douglass, Commissioner State Of Alaska Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 Dear Mr. Douglass: Subject: Flaring at the PBU-EOA Facilities to Accommodate GHX-2 Tie-ins ARCO Alaska, Inc. (AAI) requests approval to flare up to 503 MMSCF of gas at Flow Station 1 (FS-1), and up to 150 MMSCF of gas at the Central Gas Facility (CGF) in the Eastern Operating Area of the Prudhoe Bay Unit (EOA). Every effort will be made to keep flaring to a minimum whenever possible, and all volumes will be reported on the Monthly Gas Disposition Report, Alaska Oil and Gas Conservation Commission form 10-422. At FS-1, the flaring will occur in conjunction with Drill Site 2's new commonline tie-in for the GHX-2 project, estimated at 3 MMSCF, to occur in early September (tentatively scheduled for 9/3/94). Post the successful start-up of FSI's Annex, the new flare system needs to be functionally checked out and tested. The current plan is to flare at a 1BSCFPD rate for 3 to 5 hours, during the late October / early November time frame. With contingencies, we are requesting a total 500 MMSCF flare volume. The total requested flare volume for FS-1 is 503 MMSCF, including contingencies. AAI further requests approval to flare up to 150 MMSCF of gas at the CGF, also in the EOA. This flaring is in conjunction with GHX-II Phase 2's new tandem compressor (T/C 1885 and 1886) commissioning, the start-up of LTS-3 (purging/blowdown volumes which also involves LTS-1 and 2) and the Stabilizer Feed Preheater tie-ins. With contingencies for unexpected downtime, the flaring should occur between September 1 and October 31, 1994. Please contact me or my alternate, John Sincer~, / W.R. Worthington /// '--- EOC Supervisor .. ~ Prudhoe Bay Operations Minier, at 659-5922, if you have any questions. RECEIVED AUG 2 5 1994 Alaska 0ii & Gas Cons. Commission Anchorage ARCO Alaska, Inc. Is a Subsidiary of AtlantlcRIchfleldCompany ARCO Alaska, Inc. ~' Post Office Box 1003 6~ Anchorage, Alaska 99510-0360 Telephone 907 276 1215 August 16, 1994 Mr. Russell A. Douglass, Commissioner State Of Alaska Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 Dear Mr. Douglass: Subject: Flaring at the PBU-EOA Facilities to Accommodate CCP Flare Repairs ARCO Alaska, Inc. (AAI) requests approval to flare up to 70 MMSCF of gas at the CCP in the Prudhoe Bay Unit (PBU). This volume will be used as assist gas in the auxiliary emergency flare to avoid black smoke as we isolate and repair the normal HP flare system. Every effort will be made to keep flaring to a minimum whenever possible, and all volumes will be reported on the Monthly Gas Disposition Report, Alaska Oil and Gas Conservation Commission form 10-422. The repair is expected to occur sometime between August 23rd and October 1st. The specific day will be a function of material procurement, pit dewatering required to accomplish the work, and weather conditions. The actual flaring duration will not exceed 7 days including ramp up time. If you have any questions, please contact Troy Weiss or Larry Bacak at 659-5923. Sincerely, W.R. Worthington EOC Supervisor Prudhoe Bay Operations RECEIVED AUG 2 2 1994 Alaska 0ii & Gas Cons. Commission Anchorage ARCO Alaska, Inc. Is a Subsidiary of AtlanticRichfleldCompany BP EXPLORATION July 12, 1994 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 GC-1 FLARE REQUEST ADMINISTRATIVE APPROVAL PRUDHOE BAY UNIT WOA BP Exploration (Alaska) Inc. 900 East Benson Boulevard P.O. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 Dear Mr. Douglass' BP Exploration (Alaska) Inc. requests written authorization to flare a total of 40 MMSCF of natural gas at GC-1, commencing on or about July 20, 1994. The flaring is necessary to conduct a performance test of the GC-1 intermediate pressure (IP) compressors. These machines take gas from the second stage separators and Iow pressure (LP) compressors and compress it to transit line pressure for transport to the Central Gas Facility and Central Compression Plant, Since start-up of the Gas Handling Expansion 2 (GHX-2) project in the fall of 1993, the IP compressors have been the primary constraint to production through the GC-1 facility. The test is necessary to confirm the viability of plant debottlenecking modifications. A production increase of 2-5 mbd is likely with the modifications. During the test, the IP and LP compressors will be isolated from the separators and the ]P compressors run at several sets of operating conditions using the recycle loop. Test duration is estimated at 12 hours. Without the ability to flare, full shutdown of both the original GC-1 plant and the new GHX-2 Annex would be required. In addition, the short duration plant shutdowns would significantly disrupt operations at the Central Gas Facility and Central Compression Plant. Flare assist gas will be used to avoid black smoke while flaring and effort will be taken to keep the flaring to a minimum. RECEIVED JUL 1 4 1994 Alaska 0il & Gas Cons. Con, mission Anchorage Mr. Russ Dougl~,.,s, AOGCC Page 2 July 12, 1994 If you have any questions concerning this request, please contact me at 564- 4838. Sincerely, Alison D. Cooke RECEIVED JUl_ ~ 4 1994 Alaska Oil & Gas Cons. Commission Anchorage ..TIJL 'l::;' ' ~4 .~' Mr. Russ Dou.~ss, AOGCC Page 3 July 12, 1994 File: D. Fisher/T, Niswander J, Giimy/J. Maddux J. Blythe/D. Paris M. Davis N. Weiss J. Platt C. Klein PC-PBU/AQ/Corresp. RECEIVED JUL 1 P 1994 Alaska 0it & Gas uons. uommtS~tQ~ ~ohorage BP EXPLORATION June 3, 1994 BP Exploration (Alaska) Inc. 900 East Benson Boulevard RO. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 GC-2 FLARE REQUEST ADMINISTRATIVE APPROVAL PRUDHOE BAY UNIT WOA Dear Mr. Douglass: JUN -.6 1994 0ii & Gas Cons. Commission Anchorage BP Exploration (AlaSka) Inc. requests written authorization to flare a total of 40 MMSCF of natural gas at GC-2, commencing on or about June 27, 1994. The flaring will be associated with planned maintenance on the GC-2 IP and LP gas compressors. During the period June 27-30, GC-2 is planning to shut down a slugcatcher for repairs to internals. To minimize production impacts, it is desirable to utilize the opportunity to do maintenance on the IP and LP compressors. Although maintenance work is planned on only one each of the IP and LP machines, a full shutdown of all four compressors is required to safe-out and isolate the compressors. Therefore the flare permit is meant to cover the 12 hour safe-outs at the beginning and end of the maintenance work and has the purpose of avoiding a plant shutdown. It is desirable to avoid a full plant shutdown from the perspectives of both safety and operability since significant operator intervention is required to restart the plant and wells following a shut-down thereby incurring a higher safety and environmental risk. Unstable plant operation may also result in a release of gas to the flare system during unloading, or potential oil carryover which may increase the risk of a black smoke release. Product quality might also be impacted by the upset of separator conditions and cooling of oil in the wellbore and flowlines following a shutdown. This could, and has in the past, caused produced water excursions of a relatively long dUration. A flare permit would allow continued operation of the plant during the equipment safe-out and reduce the risks indicated above. Flare assist gas will be used ( Mr. Russ Douglass, AOGCC Page 2 6/3/94 to avoid black smoke while flaring and effort will be taken to keep the flaring to a minimum. If you have any questions concerning this request, please contact me at 564- 4838. Sincerely, Alison D. Cooke JUN - 6 1994 oit & Gas cons. commission Anchorage Al{CO AlasKa, Inc.'i("' Post Office Boi ,a0360 Anchorage~ Alaska $951°-o3o0 Telephone 907 275 1215 POSt-it*" b~and Fax Transmittal Memo 767:2 ..... ktask~ O~t & t~as · ARCO Alaska, Inc, is = ~ul~sidlarv ol AllanfiCRiChflel~ICompan¥ March 25, 1994 gO;J , ~KO~ A0bL.L;g 2/ 3 Mr. Russell A. Douglass. Commissioner State Of Alaska Alaska Oil and Gas Conservation Comrnia~inn 3001 Porcupine Drive Anchorage, AK §StSo1.R192 Dear Mr. Douglass: .C_:ubjeet: Wa~hee Flarino at tho 'PBU-I~OA Facilities to ^ccomr~.q[ato .GHXr.~...TJo-ine :~nd._S:orio9 ~ator ARCO Alaska, I,~;. (AAI) requests approval to flare up to Z MM:SCF ol gas at Flow ~lalJonl (F8-1), Z MMSCF at Flow &la,on Z .(F,5-2], 2 MMSGF at FloW Station ;3 (1::~-3), cna up to 300 MMSGF of gas for Me Gemral Gas Facility (GGF) in the Prudhoe Bay Unit (PBU), A portion ol tills gas will be flarecl at the six (6) upstream oil facilities in support ct t~e new GGF tanciem T/C's and booster compressor sl~utclowns. Additionally, we request to tiara up to 3 MMSCF of gab st the Central Compression Plant (CCP) Ior normal T/C ahutdowna to facilitate tl~e ISpring water washes, Every ellort will be made to keep flaring to a minimum whenever possible, ancl all volumes Will be reporled on the Monthly Gas Disposition Report, Alaska Oil ancl Gas conservation Commission form 10-422. The driving event is Alyeska Pipeline Service shutting clown the TAPS to facilitate a valve change out in Valdez on April 15, 1994. This will result in a severe production proration in ali the fields (25 to as Iow as 10% proration level), hence opportunity to do shot[ term shutdown opportunity work, The shutdown/slowdown is expected to last 12 hours plus ramp up time. The Spring water waahes at the CCP will occur between April 12th to the 19th, 1994. Please contact me or my alternate, John ~in~erely, / . :}(~W.R. Worth EOC Sur~ervisot /,/ Prudhoe Bay Opera.ns Minier, at 659'-5922, if you have any questions. ARCO AI~. Ih~. it, ~ SUbSit~arv o! AIm~':i4Jeh~l~.~n~mr, V YRB OP~,~.A'I'I ONS-, P~t Ofl~cc Bo~ 100,~0 A.neheralle. Ala~kja .~SlO.Oa60 March 2B, 11}04 Mr. Russell A, Douglass, Commissioner $1a[e el Alaska Alaska Oil and Ge.~ Consewation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 I,~ar Mr. Douot~: Subject: Florins at the PBU-EOA Facilities to A~nmmt,.date.rGH?-~ Tie.ir~. High Stage ~Com0reasor Ina.~a~on and Tandem CornDressor V..a.l_ve Reuair,~ ARCO Alaska, hm, (AAI'i requesas approval to flare up to -~ MM~CF of oas at Flow Station 1 (F~-I), up to 10 MMSCF of gas for the Central Gas Facility (CGF) and up to 1 MMSCF at the Central Compression Plant (CGP) in Ihs E~tarn C3perating Area (EOA) of the Prudhee Bay Unit (PBU). Every effort will be made to keep flaring to a minimum wt~enewr possible, ancl all volumes will be reported on the Monthly Gas Disposition Report, Alaska Oil and Gas. Conservation Comrni~ion fo~m 10-42~. FS-1 will be ohut down to fa<:ilitate final tic-ins and modifications for ~e GHX-II Phase 2 Annex projeoi, beginning June 2, 1994. Taking advantage el this ga~ outage, tho CCP will be abutting down High Otage T/C#1809 Iora oomt3u~tlon Inspection also on June 2ncl, and the CGF Will shu~own the new Tandem T/C'o for discharge valve repairs between June 2nd and 6th, log4, Please con,act me or m~, ulternate, John MINer, at US~-5~I2Z, if you have any questions. REE£1VE[' APR 1;Z. 1994 Anchorage ARCO Alaska, Inc. Post Office Box 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 March 25, 1994 Mr. Russell A. Douglass, Commissioner State Of Alaska Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 Dear Mr. Douglass: Subject: Flaring at the PBU-EOA Facilities to Accommodate GHX-2 Tie-ins and Spring Water Washes ARCO Alaska, Inc. (AAI) requests approval to flare up to 2 MMSCF of gas at Flow Station1 (FS-1), 2 MMSCF at Flow Station 2 (FS-2), 2 MMSCF at Flow Station 3 (FS-3), and up to 300 MMSCF of gas for the Central Gas Facility (CGF) in the Prudhoe Bay Unit (PBU). A portion of this gas will be flared at the six (6) upstream oil facilities in support of the new CGF tandem T/C's and booster compressor shutdowns. Additionally, we request to flare up to 3 MMSCF of gas at the Central Compression Plant (CCP) for normal T/C shutdowns to facilitate the Spring water washes. Every effort will be made to keep flaring to a minimum whenever possible, and all volumes will be reported on the Monthly Gas Disposition Report, Alaska Oil and Gas Conservation Commission form 10-422. The driving event is Alyeska Pipeline Service shutting down the TAPS to facilitate a valve change out in Valdez On April 15, 1994. This will result in a'severe production proration in all the fields (25 to as Iow as 10% proration level), hence opportunity to do short term shutdown opportunity work. The shutdown/slowdown is expected to last 12 hours plus ramp up time. The Spring water washes at the CCP will occur between April 12th to the 19th, 1994. Please contact me or my alternate, John Minier, at 659-5922, if you have any questions. Sincerely, / W.R. Worthington /"// - EOC Supervisor /,/ Prudhoe Bay Operations MAY -'2 ]994 0ii & Gas Cons. Commissio[t Anchorage ARCO Alaska, Inc, is a Subsidiary of AtlanticRichfieldCompany ARCO Alaska, Inc. {" Post Office Box 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 March 25, 1994 Mr. Russell A. Douglass, Commissioner State Of Alaska Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 Dear Mr. Douglass: Subject: Flaring at the PBU-EOA Facilities to Accommodate GHX-2 Tie-ins, High Stage Compressor Inspection and Tandem Compressor Valve Repairs ARCO Alaska, Inc. (AAI) requests approval to flare up to 5 MMSCF of gas at Flow Station 1 (FS-1), up to 10 MMSCF of gas for the Central Gas Facility (CGF) and up to 1 MMSCF at the Central Compression Plant (CCP) in the Eastern Operating Area (EOA) of the Prudhoe Bay Unit (PBU). Every effort will be made to keep flaring to a minimum whenever possible, and all vOlumes will be reported on the Monthly Gas Disposition Report, Alaska Oil and Gas Conservation Commission form 10-422. FS-1 will be shut down to facilitate final tie-ins and modifications for the GHX-II Phase 2 Annex project, beginning June 2, 1994. Taking advantage of this gas outage, the CCP will be shutting down High Stage T/C#1809 for a combustion inspection also on June 2nd, and the CGF will shutdown the new Tandem T/C's for discharge valve repairs between June 2nd and 6th, 1994. Please contact me or my alternate, John Minier, at 659-5922, if.you have any questions. Sincerely, At~ska. Oil & Gas Co~s. Commissior~ Anchorage ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany S~NT BY:ARCO AK. INC, ; 4-12-94 ; 8:53; Anchorage, Alaska 'O~Og]O 0560 Tclci~hom 907 27§ 1215 March 2,5, 1004 Mr. Russell A. Douglass. Commissioner State Of Alaska Alaska Oil and Gas Comervation Commi~inn 3001 Porcult~ine Drive Anchorage, AK 99fiOl.R192 PRB OPERAT IONS--, FRO~I AOGCC;# 2/ 8 Dear Mr. Douglass: Subject: Waahee Flarino_ at the 'PB_U_,_EOA Faeilitiee to .Aeeernmedato .GH.X-2..TJo-ine and Rorina W._ator - ARCO Alaska, linc. (AAi) requests approval to tiara up to 2 MMSCF el gas at Flow Station1 (F8-1), g MMSCF at Flow Station 2 (Ffi-2), 2 MMSGF a[ Flow 3~atlon 3 (FS-3), anti up to 300 MMSCF o! gas for the central Gas Facility (GGF) in the Pructlloe Bay Unit (PBU), A portion el this gas will be flarecl at the six (6) upstream oil facilities in support of tile new GGF tanclem T/C's and booster compressor shutclowns. Actclitionally, we request to tiara up to 3 MMISCF of gas at the Central Compression Plant (CCP) for normal T/C shutdowns to facilitate tile spring water washes, Every eflort will be made to keep flaring to a minimum whenever possible, anti all volumes will be reported on the Monthly Gas Disposition Report, Alaska Oil and Gas conservation Commission form 10.422. 'the driving event is Alyeska Pipeline Service shutting down the TAPS to facilitate a valve change out in Valdez on April 15, 1994. This will result in a severe production proration in ali the tieids (25 to as Iow as 10% proration level), hence opportunity to do short term shutdown opportunity work, The shutdown/slowdown is expected to Mst 12 hours plus ramp up time. The Spring water washes at the CCP will occur between April 12th to the 19th, 1994. Please contact me or my alternate, John Minter, at 659'-5922, if you have any questions. SinTerel¥, / ,., W.R. Worlh~ Eec Sur~ervisor ?./ Prudhoe Ba~' OperatiOns ARCO Alasl~, IIY~, is & SUl~,Idlary of Allantl~R~ld~ldL'2emB~ny .~SENT BY:ARCO Ag. INC. ; 4-1.°.-94 ; PRB OPERATIONS- FROM AOGCC;# 8/ 8 P~L Office B<}x 100360 Allchoralle. Alask~a .(~S Td~-~ho'~ ~ 276 121,5 March Q$, 1904 Mr. Russell A, Douglass, Commissioner AMaka Oi~ and Gee Con&ervetk}r~ Ccxnmission (AOGGC) 3001 PoreuDine Drive Anchorage, AK 99501-3192 L}ear Mr. Douglasm: Subject: Flarina 8t the PBU-EOA Facilities tn Aeenmmndate._GHX-~ Tie-ins. High Staae Com.Drea~sr insoeetlon and !andem gomDres_~o.r......V.._alye Reuair~ ARCO Alaska, lnG, (AAI1 requests approval to flare up to n MMSCF of Oas at Flow Station 1 (F~-I), up to 10 MM$CF of gas for the Central Gas Facility (CGF) end up to 1 MMSCF a[ the Central Compression Plant (GGP) in the Eastern t3perating Area (EOA) of the Prudhoe Bay Unit (PBU). Every effort will be made to keep flarin~ to e minimum wtmaev~r possible, and alt volumes will be reportecl on the Mnnthly Gas Disposition Report, Alaska Oil and Gas Conservation Comrnlssion form 10-423, g$-1 will be shut down to fa<~ilitate final tic-ins and modifications for the GHX-II Phase Annex projeot, beginning June 2, 1994. Taking advantage of this gas outage, tho CCP will be shutting down High ~tage T;C#1809 for a comt~ustlon Inspection also on June ~,ncl, and the CGF will shu~own the new Tandem TIC% for discharge valv~ repairs between June 2nd and 6th, 1094, Please contact me or my ulterne~e, John Minier, at U59*SBZZ, it yOU have any' questions. Sincerely, Inc. i,~ ,, Sutmlelle, ly Ol Atiattlil(;tl,l,LCrlfial(IC, empaj.iif ,SEN$ BY: ARCO AK. I NC. ; 4-12-94 ; Al{CO Ala$1(a, InC. Post Office Box 100360 Ancho[age, AlasKa 99510-0360 Telephone 907 276 ~215 8'~2 ' PRB OPERAT I ON5-, FRO~ AOGCC'# !/ ,3 .t.~.~ No, of PBgc; ,,., Fax Transmittal Memo ?~7~ , ....,.~ ~ ~¢ ARCO Alasl~a, 1mc. is .'* Guia,~idiar~' et AllanficRichflelaCompany BP EXPLORATION December 20, 1993 BP Exploration (Alaska) Inc. 900 East Benson Boulevard P.O. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 GC-2 FLARE REQUEST ADMINISTRATIVE APPROVAL PRUDHOE BAY UNIT WOA Dear Mr. Douglass: BP Exploration (Alaska) Inc. requests written authorization to flare a total of 150 MMSCF of natural gas at GC-2, commencing on or about January 11, 1994. The flaring will be associated with the GC-2 flare capacity test. The objective of the flaring is to collect information which will allow a more accurate determination of GC-2 flare capacities in order to install an automated flare capacity alarm system. This will enhance the safety of the flare system through providing a warning when gas rates are approaching facility limits. It will also assist in providing data useful in optimizing facility gas throughput. Flare assist gas will be used to avoid black smoke while flaring and effort will be taken to keep the flaring to a minimum. If you have any questions concerning this request, please contact me at 564- 4838. Sincerely, %-.~.;.':-~.?'%' '~',~ Alison D. Cooke RECEIVED DEC 22 1993 Naska Oil & Gas Cons. Commission Anchorage BP EXPLORATION December 21, 1993 BP Exploration (Alaska) Inc. 900 East Benson Boulevard P.O. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 GC-1 FLARE REQUEST ADMINISTRATIVE APPROVAL PRUDHOE BAY UNIT WOA Dear Mr. Douglass: J'OMM .... ' ENG ASST ENG ASS'f' BP Exploration (Alaska) Inc. requests written authorization to flare a total of 120 MMSCF of natural gas at GC-1, commencing on or about January 1, 1994 for approximately four days. The flaring will be associated with maintenance work on an IP compressor at GC-I. Performance testing following repair of the recycle valves on the skid 18 compressors at GC-1 indicate that the K107 IP compressor is performing below its design curve. Rotating equipment maintenance and engineering personnel recommend preventive maintenance to improve the machine's performance and to prevent any further loss of capability or more serious failure. The maintenance work involves replacing the compressor bundle with a warehouse spare requiring 48-72 hours in addition to requisite safe- out and recommissioning time. Since this is one of only two compressors handling the IP compression load for the entire plant and GC-1 Annex, flaring is required to prevent a major facility shutdown with its inherent risks of freezing and equipment loss during winter conditions. Flare assist gas will be used to avoid black smoke while flaring and effort will be taken to keep the flaring to a minimum. If you have any questions concerning this request, please contact me at 564- 4838. Sincerely, Alison D. Cooke DEC 5 99,5 I~t~ & Gas Cons. commiss'~o~ 19 '93 05: 19PM BPX EMVIROMMEMT TO AO~'~C, AMCHORA~E BP EXP~N November 19, 1993 P. 1/1 ._Post. Ir' brand fax frans( i memo 7671 i~ ot ~ ~'1 ' ~lr~ ~,. ,..--?~ '-...~ -- . _ { -,- Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 _GC-1 FLARE.REQUEST _ADMINISTRAT..IVE APPROVAL PRUDHOE_BAY UNIT WO,~ Dear Mr. Douglass: BP Exploration (Alaska) Inc, requests written authorization to flare a total of 50 MMSCF of natural gas at Ge-l, commencing on or about November 29, 1993, The flaring will be associated with the the GC-1 Annex capacity test. The test objective is to assess whether equipment modifications ere required for the Annex to reach its gas throughput design capacity based on dehydration performance. The 'facility is currently limited by oil hydraulic capacity and capacity of the 2nd and 3rd stage gas compressors at GC-I. We believe that we can achieve the design throughput by flaring gas off the 2nd and 3 rd stage separators, upstream of the compressors. Anticipated flare volumes are 25 MMSCFD for two days. Flare assist gas will be used to avoid black smoke while flaring and effort will be taken to keep the flaring to a minimum. If you have any questions concerning this request, please contact me at 564- 4838, Sincerely, Alison D. Cooke BP EXPLORATION November 19, 1993 BP Exploration (Alaska) Inc. 900 East Benson Boulevard P.O. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 GC-1 FLARE REQUEST AOMINISTRATIVE APPROVAL PRUDHOE BAY UNIT WOA Dear Mr. Douglass: BP Exploration (Alaska) Inc. requests written authorization to flare a total of 50 MMSCF of natural gas at GC-1, commencing on or about November 29, 1993. 'The flaring will be associated with the the GC-1 Annex capacity test. The test objective is to assess whether equipment modifications are required for the Annex to reach its gas throughput design capacity based on dehydration performance. The facility is currently limited by oil hydraulic capacity and capacity of the 2nd and 3rd stage gas compressors at GC-1. We believe that we can achieve the design throughput by flaring gas off the 2nd and 3 rd stage separators, upstream of the compressors. Anticipated flare volumes are 25 MMSCFD for two days. Flare assist gas will be used to avoid black smoke while flaring and effort will be taken to keep the flaring to a minimum. If you have any questions concerning this request, please contact me at 564- 4838. Sincerely, Alison D. Cooke RECEIVED NOV 2 ~ 199~ Alaska Oil & Gas Cons. Commission Anchorage BP EXPLORATION November 8, 1993 BP Exploration (Alaska) Inc. 900 East Benson Boulevard RO. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 G(~-I FLARE REQUEST ADMINISTRATIVE APPROVAL PRUDHOE BAY UNIT WOA Dear Mr. Douglass: BP Exploration (Alaska) Inc. requests written authorization to flare a total of 150 MMSCF of natural gas at GC-1, commencing on or about November 9, 1993. Flaring should be completed on or about November 11, 1993. The flaring will be associated with the repair of leaking valves on the IP and LP compressors. The compressors have a common header and must be shutdown to safe-out the equipment for repairs. We expect the repairs to take approximately two days. Flare assist gas will be used to avoid black smoke while flaring and effort will be taken to keep the flaring to a minimum. If you have any questions concerning this request, please contact me at 564- 4838. Sincerely, Alison D. Cooke RECEIVED 04:~PM BPX EMVIROMMEMT TO ~OGCC, ~MCHOR~GE November 8, 1993 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 C-1 FLARE REQUEST ADMINISTRATIVE APPROVAL .P. BU _AYZU Dear Mr. Douglass' 81a Exl31Oratton (.a, leska) Inc. gOO East Benson BOulevard FO. Box 186612 Anertorage, Alaska gg51g-6612 P. 1/1 BP Exploration (Alaska) Inc. requests written authorization to flare a total of 150 MMSCF of natural gas at GC-1, commencing on or about November 9, 1993. Flaring should be completed on or about November 11, 1993. The flaring will be associated with the repair of leaking valves on the IP and LP compressors. The compressors have a common header and must be shutdown to safe-out the equipment for repairs. We expect the repairs to take approximately two days. Flare assist gas will be used to avoid black smoke while flaring and effort will be taken to keep the flaring to a minimum, If you have any questions concerning this request, please contact me at 564- 4838. Sincerely, Alison D, Cooke NOV 9 99, Alaska Oil & C~as Cons. C'o~nmiss~o~, Anchora..qe BP EXPLORATION November 8, 1993 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 GC-3 FLAREBEQUES[ ADMINISTRATIVE APPROVAL PRUDHOE BAY UNIT WOA BP Exploration (Alaska) Inc. 900 East Benson Boulevard RO. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 Dear Mr. Douglass: BP Exploration (Alaska) Inc. requests written authorization of the verbal authorization you gave us on November 6, 1993 to flare a total of 150 MMCF of natural gas at GC-3, commencing or about November 6, 1993. Flaring should be completed within approximately 3 days. The flaring was necessary at CC-3 because the facility shutdown due to a gas leak in a compressor. We anticipate approximately 3 days to repair the leak. Flare assist gas will be used to avoid black smoke while flaring and effort will be taken to keep the flaring to a minimum. If you have any questions concerning this issue, please contact me at 564- 4838. Sincerely, Alison D. Cooke I l 08 '~3 TO) AO[:,~F', AHCHORAGE November 8, 1993 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 BP F_xplomtion (Alas~) ~0 East Ben~on Bouleva.ml P:O, l~OX 19661~- Ancharege, Alaska 99519-6612. (907) 501-5111 P. 1/1 GC.-.3 FLARE REQUEST ADMINISTRATIVE AI:?PROVAL PRUDHOE BAY UNI_'EW_OA ,. Dear Mr. Douglass: BP Exploration (Alaska) Inc, requests written authorization of the verbal authorization you gave us on November 6, 1993 to flare a total of 150 MMCF of natural gas at GC-3, commencing or about November 6, 1993. Flaring should be completed within approximately 3 days. The flaring was necessary at CC-3 because the facility shutdown due to a gas leak in a compressor. We anticipate approximately 3 days to repair the leak. Flare assist gas will be used to avoid black smoke while flaring and effort will be taken to keep the flaring to a minimum, If you have any questions concerning this issue, please contact me at 564- 4838. Sincerely, Alison D. Cooke R E C E V E ?, NOV .~ 8 t99:~ ALASKA OIL AND GAS CONSERVATION COMMISSION September 22, 1993 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 Mr. C. J. Phillips Manager PB Petroleum Engineering BP Exploration (Alaska), Inc. P O Box 196612 Anchorage, AK 99519-6612 Gentlemen: Mr. D. F. Scheve Manager PB Operations, Engineering ARCO Alaska, Inc. P O Box 100360 Anchorage, AK 99510-0360 The Commission has received your August 19, 1993 request to modify Rule 5 of Conservation Order No. 145. While the Commission is supportive of your request, we want to propose making this change as part of a general consolidation and re-write of pool rules for the Prudhoe Bay °il pool. Over the years, numerous conservation orders have been issued for the pool. All these orders must be reviewed to determine current requirements. We would like to simplify matters by consolidating all Prudhoe Bay orders under one all inclusive order for the pool. Any future modifications can then be made to that one order, and an amended order issued. Only one order would exist for the pool, which would include all current requirements. The Commission lOoks forward to discussing this idea with you. If we agree that the concept has merit, we would propose that the operators put forth a proposed consolidated pool rules order for our review. Until we hear from you, we will delay action on your August 19, 1993 request. 'David W. Chairman BP EXPLORATION August 27, 1993 BP Exploration (Alaska) Inc. 900 East Benson Boulevard RO. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 GC-1 FLARE REQUEST ADMINI~;TRATIVE APPROVAL PRUDHOE BAY UNIT WOA Dear Mr. Douglass: BP Exploration (Alaska) Inc. requests written authorization to flare a total of 1,200 MMSCF of natural gas at GC-1, commencing on or about September 7, 1993. Flaring should be completed on or about September 24, 1993. The flaring will be associated with testing of the new Gas Handling Expansion Two (GHX-2) Project flare system at GC-1 during commissioning of the new Annex. At GC-1 as part of the GHX-2 Project a new flare system has been installed which includes two new flare stacks. As part of bringing the new facility on line we need to prove that the system will perform as designed. The objectives of the test will be to: 1. Verify capacity and backpressure during flaring out the !st stage flare and out the 2nd stage flare. 2. Verify correct opening and sequencing of all four flare valves, i.e. two downstream of the HP separator, one downstream of the contactor and the staging valve in the Flare Manifold Building. 3. Verify if the new flare stacks burn smokeless. 4. A secondary objective will also be to check the ground temperature and any impact to the tundra caused by the flaring. Note that the test is not geared to explicitly answer temperature impacts and we are just taking the opportunity to get temperatures while flaring. R'E'CE VED $ E P - 1 Alaska 0ii & Gas Cons. ComrnJssio*~ Anchorage Mr. Russ Dou~l,~,ss, AOGCC Page 2 8/27/93 Although the system is designed to flare at the rate of 1.44 BCFD, the maximum flare rate planned for the test is 800 MMSCFD. Data taken at this rate will allow us to extrapolate with confidence the system performance at design capacity. We are also allowing for a day of Iow rate flaring (360 MMSCFD) during startup. These flare stacks are among the largest ever fabricated in terms of volume throughput. The planned functional check-out will address the valve and control logic. The operational check-out will allow Operations to assess the operability of the flare systems and address any issues before the flares are required on an emergency basis. This is important because the flares will service not only the additional 525 module at GC-1, but effectively, the new CCP compressors and turbines as well. This effectively increases the risk of the flares being needed during a shutdown or upset condition during commissioning of the new equipment and therefore increases the importance of a thorough operational test under controlled conditions. Flare assist gas will be used to avoid black smoke while flaring and effort will be taken to keep the flaring to a minimum. If you have any questions concerning this issue, please contact me at 564- 4838. Sincerely, Alison D. Cooke $ E P - 1 199,~ Alaska 0ii & Gas Cons. Commission Anchorage TO A~]"-CC, AMCHORAGE BP EXPLORATION MESSAGE # P. 1/:3 BP Exploration (AIaska) Inc. P.O. Box 196612 Anchor~e, AK 995196612 FAX TRANSMITTAL COVER SHEET ENVIRONMENTAL & REGULATORY AFFAIRS DEPARTMENT TO: Name Mr. Russ Douglass company Alaska Oil and Gas Conservation Commission Loc;[tion Anchorage FAX No. 2 7 6' 7 5 4 2 Confirm No, FROM: Name Alison Cooke Department Environmental & Regulatory Affairs Department FAX No. (907) 564-5020 Confirm No. (907) Moil Stop M B 564-4838 11-6 NOTES: Th,-, PAGES TO FOLLOW: (Does Not Include Cover Sheet) 0 PRIVATE 0 SECRET RECF!V!: Alaska Oil & G~:-'m !..:..:}:~..-'~. t,..;~;~ ........ ;,. CONFIDENTIAL FAX No. 276-7542 August 27, 1993 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 GC-1 FLARE REQUEST /~DMINISTRATIVE APPROVAL _P_R_IJ._DHOE BAY UNIT WOA Dear Mr. Douglass: BP Exploration (Alaska) inc. requests written authorization to flare a total of 1,200 MMSCF of natural gas at GC-I, commencing on or about September 7, 1993. Flaring should be completed on or about September 24, 1993. The flaring will be associated with testing of the new Gas Handling Expansion Two (GHX-2) Project flare system at GC-1 during commissioning of the new Annex. At GC-1 as part of the GHX-2 Project a new flare system has been installed which includes two new flare stacks. As part of bringing the new facility on line we need to prove that the system will perform as designed. The objectives of the test will be to: 1. Verify capacity and backpressure during flaring out the 1st stage flare and out the 2nd stage flare. 2. Verify correct opening and sequencing of ali four flare valves, i.e. two downstream of the HP separator, one downstream of the contactor and' the staging valve in the Flare Manifold Building. 3. Vedfy if the new flare stacks burn smokeless. 4. A secondary objective will also be io check the ground temperature and any impact to the tundra caused by the flaring. Note that the test is not geared to explicitly answer temperature impacts and we are just taking the opportunity to get temperatures while flaring, · Mr, Russ Do[..ass, AOGCC {~. Pacje 2 8/27/93 Although the system is designed to flare at the rate of 1.44 BCFD, the maximum flare rate planned for the test is 800 MMSCFD. Data taken at this rate will allow us to extrapolate with confidence the system performance at design capacity, We are also allowing for a day of Iow rate fladng (360 MMSCFD) during startup. ~'. 3/3 These flare stacks are among the largest ever fabricated in terms of volume throughput. The planned functional check-out will address the valve and control logic. The operational check-out will allow Operations to assess the operability of the flare systems and address any issues before the flares are required on an emergency basis, This is important because the flares will service not only the additional 525 module at GC-1, but effectively, the new CCP compressors and turbines as well. This effectively increases the dsk of the flares being needed during a shutdown or upset condition during commissioning of the new equipment and therefore increases the importance of a thorough operational test under controlled conditions. Flare assist gas will be used to avoid black smoke while flaring and effort,, will be taken to keep the flaring to a minimum. If you have any questions concerning this issue, please contact me at 564- 4838. Sincerely, Alison D. Cooke ARCO Alaska, Inc.i [~ Post Office Box 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 August 28, 1993 Mr. Russell A. Douglass, Commissioner State Of Alaska Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 Dear Mr. Douglass: Subject: Flaring at the PBU-EOA Facilities to Accommodate GHX-2 Tie-ins ARCO Alaska, Inc. (AAI) requests approval to flare up to 2 MMSCF of gas at Flow Station 3 (FS-3), and up to 300 MMSCF of gas at the Central Gas Facility (CGF) in the Eastern Operating Area of the Prudhoe Bay Unit (EOA). Every effort will be made to keep flaring to a minimum whenever possible, and all volumes will be reported on the Monthly Gas Disposition Report, Alaska Oil and Gas Conservation Commission form 10-422. At FS-3, the flaring will occur in conjunction with the full facility, shutdown for the inlet manifold tie-ins for the GHX-2 project and planned maintenance on the gas dehydration equipment. The GHX-2 flaring is planned to coincide with the CGF partial shutdown, see next paragraph, while the gas dehydration repairs will occur between September 30 and October 7th, 1993. The total requested flare volume for FS-3 is 2 MMSCF, including contingencies. AAI further requests approval to flare up to 300 MMSCF of gas at the CGF, also in the EOA. This flaring is in conjunction with the 4938 inlet module/60" gas transit lines shut,down for the GHX-2 project tie-ins (new tandem compressor commissioning). With contingencies for unexpected downtime, the flaring should occur between September 10 and 20th, 1993. Please contact me or my alternate, John Minier, at 659-5922, if you have any questions. Sincerely, ARCO Alaska, Inc, Is a Subsidiary o! AtlantlcRichlleldCompany RE( EJVED S E P - 1 199; Alaska 0il & Gas Cons, Anchorage SENT BY: 8-28-93 ;10:31A~1 : PEGGY/EDNABS98295+ FROM AOGCC:# 1/ ~ ARCO ALASKA, INC PRUDHOE BAY EASTERN OFFTAKE CENTER (EOC) ---- , INSTRUCTIONS / MESSAGE: R E C E!\,' E r", ~SENT BY: 8-28-95 ;10:32A~ : ARCO Nmlm, Inc.. Post O~ Box 100360 Anchorage, Alaska 99510-0360 TeleBhone 907 276 1215 August 28, 1993 PEGGY/EDNA6595295~ (. FRO~ AOGCC;~ 2.; 2 Mr. Russell A. Douglass, Commissioner State Of Alaska Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 Dear Mr. Douglass: Subject: Flarinp at the PBU-EOA Facilities to Accommodete GHX-2 Tie-iris. ARCO Alaska, Inc. (AAI) requests approval to flare up to 2 MMSCF of gas at Flow Station 3 (FS-3), and up to 300 MMSCF of gas at the Central Gas Facility (CGF) in the Eastern Operating Area of the Prudhoe Bay. Unit (EOA). Every effort will be made to keep flaring to a minimum whenever possible, and all volumes will be reported on the Monthly Gas Disposition Report, Alaska Oil and Gas Conservation Commission form 10-422. At FS-3, the flaring will occur in conjunction with the full facility, shutdown for the inlet manifold tie-ins for the GHX-2 project and planned maintenance on the gas dehydration equipment. The GHX-2 flaring is planned to coincide with the CGF partial shutdown, see next paragraph, while the gas dehydration repairs will occur between September 30 and October 7th, 1993. The total requested flare volume for FS-3 Is 2 MMSCF, including contingencies. AAI further requests approval to flare up to 300 MMSCF of gas at the CGF, also in the EOA. This flaring is in conjunction with the 4938 inlet module/60" gas transit lines shut;down for the GHX-2 project tie-ins (new tandem compressor commissioning). With contingencies for unexpected downtime, the flaring should occur between September 10 and 20th, 1993. Please contact 'me or m~/alternate, John Minier, st 659-.5922, if you have any questions. Sincerely, AUG '3 0 Ataska 0il & Gas Cons. ARCO Alaska. Inc. is a Subsldla~' of AllantlcRIchflelcElompany ARCO Alaska, Inc.,~I'~,' Post Office Box 100360 Anchorage Alaska 99510-0360 Telephone 907 276 1215 August 19, 1993 Mr. D. W. Johnston, Chairman Alaska Oil & Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 Re: Request to Modif_v Rule 5. CO 145 Dear Mr. Johnston: The Prudhoe Bay Unit CPBU") operators request a modification to Rule 5, Conservation Order 145, which requires that "upon completion, each well shall be equipped with a suitable safety valve installed beloTM the base of the permafrost which will automatically shut in the well if an uncontrolled flow occurs." This valve is commonly called a Subsurface Safety Valve (SSSV). We propose Rule 5 be changed to be consistent with the corresponding rule in the pool rules for the Pt. McIntyre and Stump Island Oil Pools, Conservation Order 317, Rule 8, dated July 2, 1993. The proposed amended rule would remain more stringent than required under 20 AAC 25.265. The proposed revision would: 1) allow the AOGCC to approve removal of the SSSV after a successful demonstration that the well is not capable of unassisted hydrocarbon flow; 2) allow temporary removal of SSSV's from individual wells for routine wellwork operations without specific authorization or notice. As you know, this is a common practice and is an operational necessity for successfully completing a large number of routine wellwork operations requiring unrestricted internal wellbore dimensions. This modification will clarify the Rule and minimize administrative burden for both the Commission and the Operators; and 3) allow the AOGCC to administratively amend or waive the requirements of this rule in certain special circumstances. As well productivity declines, the PBU operators will continue to rework as many low productivity wells as possible and to seek innovative technology to enhance the economics of these wells. This change will allow the Commission to administratively consider changes to the requirements of this rule consistent with the application of new technology and specific well conditions. ARCO Alaska, Inc. Is a Subsidiary of Atlantic Richfield Company RECEIVED AU O 2 199 ) Alaska Oil & Gas Cons. Commi', Anchorage Mr. D. W. Johnston August 19, 1993 Page 2 Thus, the PBU operators propose that Conservation Order 145, Rule 5 be amended to read as follows: Rule 5: Automatic Shut-In Equipment a) Upon completion, each well which is capable of unassisted flow of hydrocarbons to the surface shall be equipped with: 1) a fail-safe automatic surface safety valve (SSV) capable of preventing an uncontrolled flow; and 2) a fail-safe automatic subsurface safety valve (SSSV), unless other types of subsurface valves are approved by the Commission, shall be installed in the tubing string below the base of the permafrost and be capable of preventing uncontrolled flow. b) A well that is not capable of unassisted flow of hydrocarbons as determined by a "no flow" performance test witnessed by a Commission representative is not required to have fail-safe automatic SSSV valves. c) SSSV's may be temporarily removed for routine wellwork operations without specific notice to, or authorization by the Commission. d) Upon proper application, the Commission may administratively amend or waive the requirements of this rule. Thank you for your consideration of this proposal. Please contact us at the numbers below should you have any questions or require additional information from us. Sincerely, c. Pfii'iiiP' - Manager PB Petroleum Engineering BP Exploration (Alaska), Inc. 564-4757 D. F. Scheve Manager PB Operations Engineering ARCO Alaska, Inc. 263 -4248 , RECEIV£D AU 199 Alaska 0il & 6as Cons, comrnissio~ Anchorage ARCO Alaska, InC. l~ Post Office ~ .00360 Anchorage Alaska 99510-0360 Telephone 907 276 1215 August 19, 1993 Mr. D. W. Johnston, Chairman Alaska Oil & Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 Re: Request to Modify Rule 5. CO 145 Dear Mr. Johnston: The Prudhoe Bay Unit ("PBU") operators request a modification to Rule 5, Conservation Order 145, which requires that "upon completion, each well shall be equipped with a suitable safety valve installed below the base of the permafrost which will automatically shut in the well if an uncontrolled flow occurs." This valve is commonly called a Subsurface Safety Valve (SSSV). We propose Rule 5 be changed to be consistent with the corresponding rule in the pool rules for the Pt. Mclntyre and Stump Island Oil Pools, Conservation Order 317,'Rule 8, dated July 2, 1993. The proposed amended rule would remain more stringent than required under 20 AAC 25.265. The proposed revision would: 1) allow the AOGCC to approve removal of the SSSV after a successful demonstration that the well is not capable of unassisted hydrocarbon flow; 2) allow temporary removal of SSSV's from individual wells for routine wellwork operations without specific authorization or notice. As you know, this is a common practice and is an operational necessity for successfully completing a large number of routine wellwork operations requiring unrestricted internal wellbore dimensions. This modification will clarify the Rule and minimize administrative burden for both the Commission and the Operators; and 3) allow the AOGCC to administratively amend or waive the requirements of this rule in certain special circumstances. As well productivity declines, the PBU operators will continue to rework as many low productivity wells as possible and to seek innovative technology to enhance the economics of these wells. This change will allow the Commission to administratively consider changes to the requirements of this rule consistent with the application of new technology and specific well conditions.. ARCO Alaska, Inc. is a Subsidiary of Atlantic Richfield Company Mr. D. W. Johnston t'~" August 19, 1993 Page 2 Thus, the PBU operators propose that Conservation Order 145, Rule 5 be amended to read as follows: Rule 5: Automatic Shut-In Equipment a) Upon completion, each well which is capable of unassisted flow of hydrocarbons to the surface shall be equipped with: 1) a fail-safe automatic surface safety valve (SSV) capable of preventing an uncontrolled flow; and 2) a fail-safe automatic subsurface safety valve (SSSV), unless other types of subsurface valves are approved by the Commission, shall be installed in the tubing string below the base of the permafrost and be capable of preventing uncontrolled flow. b) A well that is not capable of unassisted flow of hydrocarbons as determined by a "no flow" performance test witnessed by a Commission representative is not required to have fail-safe automatic SSSV valves. c) SSSV's may be temporarily removed for routine wellwork operations without specific notice to, or authorization by the Commission. d) Upon proper application, the Commission may administratively amend or waive the requirements of this. rule. Thank you for your consideration of this proposal. Please contact us at the numbers below should you have any questions or require additional information from us. Sincerely, Manager PB Petroleum Engineering BP Exploration (Alaska), Inc. 564-4757 D. F. Scheve Manager PB Operations Engineering ARCO Alaska, Inc. 263 -4248 BP EXPLORATION June 23, 1993 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 OOMM ~ BP Exploration (Alaska) Inc, R~S ENG S00 East Benson Boulevard ~R ENG I~ P.O. BOX 196612 S-~ ENG ~ Anchorage, Alaska 99519-66] ~N~--~~ (907) 561-5111 ~~~T~ SR G~ GC-3 FLARE REQUEST ADMINISTRATIVE APPROVAL PRUDHOE BAY UNIT WOA Dear Mr. Douglass: BP Exploration (Alaska) Inc. requests written authorization to flare a total of 250 MMCF of natural gas at GC-3, commencing or about July 26, 1993. Flaring should be completed within approximately 3 days. The flaring at GC-3 will be associated with maintenance work including LPS turbine preventive maintenance(scheduled inspections), turbine water wash, miscellaneous repairs to the LPS system, and repairs to one TEG reboiler. This work has been scheduled in a complementary manner with scheduled maintenance at GC-1 and to coincide with gas cuts resulting from shutdown of the CGF, for construction activities associated with the GHX-2 project, thus minimizing flaring requirements. Flare assist gas will be used to avoid black smoke while flaring and effort will be taken to keep the flaring to a minimum. If you have any questions concerning this issue, please contact me at 564- 4838. Sincerely, Alison D. Cooke RECEIVED J UN 2 4 1993 Alaska Oil & (~as Cons. uomrnjsslu Anchorage BP EXPLORATION BP Exploration (Alaska) Inc. 900 East Benson Boulevard P.O. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 March 29, 1993 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 REVISED GC-1 FLARE REQUEST ADMINISTRATIVE APPROVAL ipRUDHOE BAY UNIT WOA Dear Mr. Douglass: BP Exploration (Alaska) Inc. is submitting a revision of our March 23, 1993 request for written authorization to flare a total of 500 MMSCF of natural gas at GC-1, commencing on or about April 10, 1993. The total revised flare volume requested is 300 MMSCF of natural gas and the work has been moved forward to April 4 and is expected to last two days. The change in volume requested is related to a change in the work scope. The waste heat recovery ducting repairs have been dropped from the scope. The flaring will be associated with the K7001 LPS inertial separator repairs only. Flare assist gas will be used to avoid black smoke while flaring and effort will be taken to keep the flaring to a minimum. If you have any questions concerning this issue, please contact me at 564- 4838. Sincerely, Alison D. Cooke RECEIVED APR - 1 Alaska 0il & 6as Cons. Anchorage BP EXPLORATION March 26, 1993 BP Exploration (Alaska) Inc. 900 East Benson Boulevard P.O. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 GC-3 FLARE REQUEST ADMINISTRATIVE APPROVAL PRUDHOE BAY UNIT WOA Dear Mr. Douglass' BP Exploration (Alaska) Inc. requests written authorization to flare a total of 900 MMCF of natural gas at GC-3, commencing or about April 7, 1993. Flaring should be completed within approximately 3 days. The flaring will be associated with the scheduled shut down of the K-7000 LPS compressor for combustion and inlet guide vane inspections, a turbine water wash, and waste heat recovery ducting repairs. Flare assist gas will be used to avoid black smoke while flaring and effort will be taken to keep the flaring to a minimum. If you have any questions concerning this issue, please contact me at 564- 4838. Sincerely, Alison D. Cooke MAR ~ 0 Alaska Oi~ & Gas Co~s, Anchorag~ BP EXPLORATION BP Exploration (Alaska) Inc. 900 East Benson Boulevard P.O. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 March 26, 1993 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 GC-1 FLARE REQUEST ADMINISTRATIVE APPROVAL PRI,IDHOE BAY UNIT WOA Dear Mr. Douglass: BP Exploration (Alaska) Inc. requests written authorization to flare a total of 500 MMSCF of natural gas at GC-1, commencing on or about April 10, 1993. Flaring should be completed on or about April 13, 1993. The flaring will be associated with the K7001 LPS inertial separator repairs and K7000 Waste heat recovery ducting repairs. Flare assist gas will be used to avoid black smoke while flaring and effort will be taken to keep the flaring to a minimum. If you have any questions concerning this issue, please contact me at 564- 4838. Sincerely, Alison D. Cooke REEE[VED MAR 0 199 Alaska 0il & 6as Cons. Co[~m'tss~o~ ~nch0rag~ BP EXPLORATION March 22, 1993 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 BP Exploration (Alaska) Inc. 900 East Benson Boulevard P.O. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 CC-3 FLARE REQUEST ADMINISTRATIVE APPROVAL PR.UDHOE BAY UNIT WOA Dear Mr. Douglass: BP Exploration (Alaska) Inc. requests written authorization to flare a total of 100 MMCF of natural gas at CC-3, commencing or about March 23, 1993. Flaring should be completed within 10 hours. The flaring will be associated with the shut down of the K-7000 LPS compressor to inspect the exhaust duct. Flare assist gas will be used to avoid black smoke while flaring and effort will be taken to keep the flaring to a minimum. If you have any questions concerning this issue, please contact me at 564- 4838. Sincerely, Alison D. Cooke RECEIVED MAR 2 4 199;~ Alaska Oil & Gas Cons. Commission, Anchorage BP EXPLORATION January 26, 1993 BP Exploration (Alaska)Inc. 900 East Benson Boulevard P.O. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 EREQUEST APPROVAL PRUDHOE BAY UNIT WOA Dear Mr. Douglass' BP Exploration (Alaska) Inc. requests written authorization for flaring a total of 1.3 BCF of natural gas at GC-2 associated with repair and replacement of corroded wet gas piping requiring complete shutdown of the GC-2 gas plant. The repair work will take place on or about February 14 through February 18, 1993. During the shutdown, no gas can be sent from GC-2 to other Prudhoe Bay facilities. Flaring is required in order to maintain wells at minimum flow conditions, thus avoiding well line freeze-ups. Efforts will be made to minimize flare volumes through careful management of wells. Concurrent work on well pad J is also planned for the same time period, further minimizing flare volumes. If you have any questions concerning this issue, please contact Alison Cooke at 564-4838. Sincerely, Alison D. Cooke, Environmental Scientist Environmental & Regulatory Affairs, Alaska BP EXPLORATION December 23, 1992 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 '..0 M M~I' ~:"' BP Exploration (Alaska)Inc. 900 East Benson Boulevard SR ENG P.O. Box 196612 ENG ASST Anchorage, Alaska 99519-6612 (907) 561-5111 i ENG ASST. "~ G.~O~ GEOL ASS%~ ,- ,~TAT TECH-[ GC-1 FLARE REOUEST REVISION ADMINISTRATIVE APPROVAL PRUDHOE BAY UNIT WOA Dear Mr. Douglass: BP Exploration (Alaska) Inc. (BPX) requested a written authorization to flare a total of 2800 MMSCF of natural gas at GC-1 for a period commencing on or about January 15, 1993 in a letter dated December 15, 1992. BPX would like to amend the requested flare volume to a maximum value of 5500 MMSCF. The request for flaring was to allow for installation of demister pads in the gas dehydration contactors at GC-1. We now anticipate a 10 day shutdown with average flare volumes of 550 MMSCF/day rather than the levels estimated in the December 15th letter. As indicated in our first request, B PX expects the earliest start date to be January 15, 1993. We would however like the flexibility to begin work anytime between January 15 and February 28, 1993. If you have any questions concerning this issue, please contact me at 564-5501 or Alison Cooke at 564-4838. Sincerely, ~vironmental Compliance, Alaska BP EXPLORATION December 15, 1992 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 ;OMM BP Exploration (Alaska)Inc. 3R EN-"~--'--- 900 East Benson Boulevard P.O. Box 196612 ,~R ,'-NG Anchorage, Alaska 99519-6612 ~ (907) 561-5111 :ENG ~-g~-~' ~eoE~,;-. STAT GC-1 FLARE REQUEST ADMINISTRATIVE APPROVAL PRt,IDHOE BAY UNIT WOA Dear Mr. Douglass: BP Exploration (Alaska) Inc. requests written authorization to flare a total of 2800 MMSCF of natural gas at GC-1, commencing on or about January 15, 1993. Flaring should be completed on or about February 28, 1993. The additional flare volume is requested during installation of demister pads in the gas dehydration contactors at GC-1. The demisters are intended to reduce the carry-over of dehydration fluid (TEG) to the CGF and CCP. The work scope is estimated to require 10 days. The majority of the flaring activity will be on the first and last day of the installation. We expect the flaring to be approximately 600 MMSCFD on the first and last day and 200 MMSCFD for the eight intervening days. The earliest expected start date is January 15, 1993. We would however like the flexibility to begin work anytime between January 15 and February 28, 1993. The variable start date would allow for equipment delivery slippage as well as allowing for alignment of the work with unplanned outages such as a weather related pipeline slowdown. The alignment of this work could reduce the overall production and flaring impacts. Flare assist gas will be used to avoid black smoke while flaring. RECEIVED DEC 1 ? 3992 Alaska 0il & Gas Cons. Commission Anchorage Mr. Russ Douglas..., AOGCC Page 2 12/15/92 If you have any questions concerning this issue, please contact me at 564- 4838. Sincerely, Alison D. Cooke Environmental & Regulatory Affairs, Alaska ADC RECEIV£D DEC 1 7 199?- Alaska Oil & Gas Cons. Commiss~o~ ~nchorage BP EXPLORATION November 11, 1992 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 GC-1 FLARE REQUEST ADMINISTRATIVE APPROVAL PRUDHOE BAY UNIT WOA BP Exploration (Alaska)Inc. 900 East Benson Boulevard P.O. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 Dear Mr. Douglass' BP Exploration (Alaska) Inc. requests written authorization to flare a total of 300 MMSCF of natural gas at GC-1, commencing or about November 18, 1992. Flaring should be completed on or about November 19, 1992. This flaring will cover two increments of work associated with the LPS compressor. The first is replacement of hydraulic oil filters requiring shutdown of the turbine. In addition, inspection and repair of waste heat recovery unit ducting will take place requiring that the system be shutdown and allowed to cool. We will make every effort to reduce flaring by combining this activity with other maintenance gas reductions and concurrently working the two activities indicated above. Flare assist gas will be used to avoid black smoke whiie flaring. If you have any questions concerning this issue, please contact me at 564- 4838. Sincerely, Alison D. Cooke Environmental & Regulatory Affairs, Alaska ADC R£EEIV£D 06 ~9~ 10:38AM BPX EMVIROMMEMT BP EXI~OR/~IION October 6, 1992 P.2/2 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 GC-3_FLARE REQUEST ADMINISTRATIVE APPROVAL PRI, JDHQE BA_Y_UNIT WOA Dear Mr. Douglass: BP Exploration (Alaska) inc. requests written authorization to flare a total of 1100 MMCF of natural gas at Ge-3, commencing or about October 7, 1992. Flaring should be completed within 24 hours, The flaring will be associated with repair of a flange leak on the K-7000 LPS compressor and to complete the maintenance activities on the LPS compressor that .were approved on August 31, 1992 (A.A. No. 145-A.103). We are performing both these activities concurrently to minimize the total volume flared. We expect that flaring will begin after the LPS production is restarted. Flare assist gas will be used to avoid black smoke while flaring and effort will be taken to keep the flaring to a minimum. If.you have any questions concerning this issue, please contact me at 564- 4838. Sincerely, Alison D. Cooke OCT 06 'g~ 10:38~M BPX EMVIROMMEHT TO ~OGP. C, ~MCHOR~GE BP EXPLORATION MESSAGE # BP Exploration (Ataska) Inc, P, O. Box 196612 Anchorage, AK 99519-6612 FAX TRANSMITTAL COVER SHEET ENVIRONMENTAL & REGULATORY AFFAIRS DEPARTMENT TO: Name Company ...... '~0 ~'"'"~ ~---._.,~ Location -~_"(""~C~ - FAX NO. ~Tf^-- '--/~ ~-4 ~. Confirm No. FROM- . Department Environmental & Regulatory Affairs _. FAX No, (907) 564-5020 Confirm No, Mail Stop M B 1 1 -$ NOTES: --- R EC, i!.l'\IEr," ------ PAGES TO FOLLOW: (Does Not Include Cover Sheet) 0 PRIVATE 0 SECRET 0 CONFIDENTIAL BP EXPLORATION October 6, 1992 BP Exploration (Alaska)Inc. 900 East Benson Boulevard ~ .... . i_t,,' ~. . (907) 561-5111 ~ ~ - "~ Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 GC-3 FLARE REQUEST ADMINISTRATIVE APPROVAL PRUDHOE BAY UNIT WOA Dear Mr. Douglass: BP Exploration (Alaska) Inc. requests written authorization to flare a total of 1100 MMCF of natural gas at GC-3, commencing or about October 7, 1992. Flaring should be completed within 24 hours. The flaring will be associated with repair of a flange leak on the K-7000 LPS compressor and to complete the maintenance activities on the LPS compressor that were approved on August 31, 1992 (A.A. No. 145-A.103). We are performing both these activities concurrently to minimize the total volume flared. We expect that flaring will begin after the LPS production is restarted. Flare assist gas will be used to avoid black smoke while flaring and effort will be taken to keep the flaring to a minimum. If you have any questions concerning this issue, please contact me at 564- 4838. Sincerely, Alison D. Cooke REEEIVED OCT - 8 1992 Alaska 0ii & 6as Cons. Commiss~ot" Anchorage BP EXPLORATION September 2, 1992 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 BP Exploration (Alaska)Inc. ','.OMM 900 East Benson Boulevard Re. Box 196612 ~S ENG Anchorage, Alaska 99519-6612~R ,~NG (907) 561-5111 -~R ENG ENG ASST ENG ASST SR GEOL GEOL ASST 7:ECl_ ASST ..~TAT TECH ST/,-.iT TE~'H-+---' GC-2 FLARE REQUEST ADMINISTRATIVE APPROVAL PRUDHOE BAY UNIT WOA Dear Mr. Douglass: BP Exploration (Alaska) Inc. requests written authorization for flaring a total of 1.9 BCF of natural gas at GC-2 associated with repairing a leaking valve in the waste heat recovery (WHR) system. The maintenance work will take place on or about September 26 through September 30, 1992. For the first 48 hours work will involve shutting down both LPS compressors in order to repair the leaking valve in the WHR system. Both machines will be shut down, cooled, and drained in order to allow safe access to the valve. Subsequently, calibrations of the speedtronics controls on each machine will take place sequentially, the compressor being shutdown while calibrations are in progress. Flare assist gas will be used to avoid black smoke while flaring and effort will be taken to keep the flaring to a minimum. If you have any questions concerning this issue, please contact Alison Cooke at 564-4838. Sincerely, Alison D. Cooke, Environmental Scientist Environmental & Regulatory Affairs, Alaska RECEIVED S E P - 4 1992~ Alaska 0il & 6as Cons. f.;0mmissio~ Anchorage "92 BP £xploration (Alaska) Inc. I:~0, Box 196612 An(~lora~le, Alaska 99519-6612 P. 2,."? August 24, 1992 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 AMENDED GC-3 FLARE REQUEST -- ADMINISTRATIVE APPROVAL P~RU_DHOE BA.Y UNIT WOA. Dear Mr. Douglass: On August 20, 1992 BP Exploration (Alaska) Inc, requested written authorization to flare a total of 700 MMCF of natural gas at GC-3, commencing or about September 1, 1992, The flaring will be associated with a shutdown of one of our compressors (K-7001') to make repairs. We now expect that the maintenance activities will be more extensive than previously assessed and that GC-3 will be down longer due to these repairs. We anticipate the work will take approximately five days. Therefore, we would like to increase our request for administrative approval to a total flare volume of 1.5 BCF. Flare assist gas will be used to avoid black smoke while flaring and effort will be taken to keep the flaring to a minimum. if you have any questions concerning this issue, please contact me at 564- 4838, Sincerely, RECEIVED Alison D. Cooke AUG 2 4 1992 A~aska 0il & Gas Cons. Commission Anchorage AUG 24 12:37PM BPX EHVIROMMEMT TO AOGCC, AMCHORAGE ,. BP EXPLORATION MESSAGE # P. BP Exploration [Alaska) Inc. P.O. Box I96612 Anchorage. AK 99519-6612 FAX TRANSMITTAL COVER SHEET ENVIRONMENTAL & REGULATORY AFFAIRS DEPARTMENT Nanle Company TO' Loc~tio n FAX No, Confirm No. Nama Department FROM' -.. , Environmental & Regulatory Affairs FAXNo. (907) 564-5020 Confirm No. Mail Stop M B 11 -6 NOTES: KI:L. EI V EIJ PAGES TO FOLLOW: :L AUG '" ', ~nn~ Ala~-a-0ii &'~a,~' Cons.'C-br~missiOn .... Anchorage (Does Not Include Cover Sheet) 0 PRIVATE 0 SECRET 0 CONFIDENTIAL BP EXPLORATION August 24, 1992 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 BP Exploration (Alaska) Inc. 900 East Benson Boulevard RO. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 :30MM I P,E$ ENG ¢.~ SR ENG ENG ASST I AMENDED GG-:3 FLARE REQUEST ADMINISTRATIVE APPROVAL PRUDHO.E BAY UNIT WOA Dear Mr. Douglass: On August 20, 1992 BP Exploration (Alaska) Inc. requested written authorization to flare a total of 700 MMCF of natural gas at GC-3, commencing or about September 1, 1992. The flaring will be associated with a shutdown of one of our compressors (K-7001) to make repairs. We now expect that the maintenance activities will be more extensive than previously assessed and that GC-3 will be down longer due to these repairs. We anticipate the work will take approximately five days. Therefore, we would like to increase our request for administrative approval to a total flare volume of 1.5 BCF. Flare assist gas will be used to avoid black smoke while flaring and effort will be taken to keep the flaring to a minimum. If you have any questions concerning this issue, please contact me at 564- 4838. Sincerely, Alison D. Cooke RECEIVED AU G 2 5 1992 Alaska Oil & Gas Cons. Oom[~issio~ Anchorage BP EXPLORATION August 20, 1992 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 ~OMM BP Exploration (Alaska)Inc. :30MM 900 East Benson Boulevard .:{ES ENG P.O. Box 196612 SR ENG Anchorage, Alaska 99519-6612SR ENG (907) 561-5111 ENG ASST ENG ASST SR GEOL GEOL ,qEOL GC-3 FLARE REQUEST ADMINISTRATIVE APPROVAL PRUDHOE BAY UNIT WOA Dear Mr, Douglass: BP Exploration (Alaska) Inc, requests written authorization to flare a total of 700 MMCF of natural gas at GC-3, commencing or about September 1, 1992, Flaring should be completed on or about September 4, 1992, The flaring will be associated with a shutdown of one of our compressors (K- 7001) to make repairs to the waste heat recovery duct. We expect that flaring will begin after the LPS production is restarted. Flare assist gas will.be used to avoid black smoke while flaring and effort will be taken to keep the flaring. to a minimum. If you have any questions concerning this issue, please contact me at 564- 4838. Sincerely, Alison D. Cooke RECEIVED AU 6 2 1 1992 Alaska Oil & Gas Cons. 6oarnissiOn Anchorage 08: ~SAM BPX ENVIROMMEMT August 20, 1992 BP E~loration (Alaska) Inc. 900 East Benson Boulevat~ RO. ~x ~c~, A~s~ ~51~2 P. £/£ Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 GC-3 FLARE REQUEST A__DMINISTRATIVE APPROVAL.. PRUDH.OE BAY U. NIT WOA Dear Mr, Douglass: BP Exploration (Alaska) Inc. requests written authorization to flare a total of 700 MMCF of natural gas at GC-3, commencing or about September 1, 1992. Flaring should be completed on or about September 4, 1992. The flaring will be associated with a shutdown of one of our compressors (K- 7001) to make repairs to the waste heat recovery duct. We expect that flaring will begin after the LPS production is restarted. Flare assist gas will be used to avoid black smoke while flaring and effort will be taken to keep the flaring, to a minimum, If you have any questions concerning this issue, please contact me at 564- 4838. Sincerely, Alison D. Cooke RECEIVED Gas Cons. Commission Anchorage 08:28AH BPX EM¥1ROMMEMT TO AOGCC~ AMCHORAGE BP EXPLORATION MESSAGE # BP Exploration (Alaska) Inc. P.O. Box 196612 Anchorage, AK 99,519-6612 FAX TRANSMITTAL COVER SHEET ENVIRONMENTAL & REGULATORY AFFAIRS DEPARTMENT P.1/£ Name Company Locatio~ FAX No. TO: Confirm No, Name Department FAX No. FROM: Environmental & Regulatory Affairs _. (907) 564-5020 Confirm No, Mail Stop M B 1 1 -6 NOTES: PAGES TO FOLLOW: r3E£El\lED I~,L~LI v L At fG ? ~.~ 1992' ,.. ,,,t~s~,a on & Gas Cons. Commission Anchorage (Does Not Include Cover Sheet) 0 PRIVATE 0 SECRET 0 CONFIDENTIAL BP EXPLORATION August 6, 1992 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 BP Exploration (Alaska) Inc. 900 East Benson Boulevard RO. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 GC 1-2-3 FLARE REQUEST ADMINISTRATIVE APPROVAL PRUDHOE BAY UNIT WOA Dear Mr. Douglass BP Exploration (Alaska) Inc. requests written authorization to flare a total of 100 MMcf of natural gas at GC 1,2, and 3 on or about August 9, 1992. This flaring is required to put the sixty inch gas line back into service after tie in work is completed at CGF as part of the commissioning of the GHX II project. Most of the flaring will occur at GC-1, but some of the total of 100 MMcf will also flared at GC 2 and GC 3. This request for flaring is in addition to that already approved by you for flaring at GC 2 on or about Aug 6, 1992 under Administrative Aproval No. 145-A.98. This flaring event is consistent with the flaring which has already been approved for the EOA as part of the same facility commissioning work. If you have any questions concerning this issue, please contact David Lowe at 564-4792. Sincerely, Er/vironmental & Regulatory Affairs, Alaska SDT/DJL RECEIVED AU G 10 1892 ,Alaska Oil & Gas Cons. Commissio~ Anchorage AOGCC Flare Aug. 6, 1992 Page 2 .uest J. Platt D. Lowe A. Cooke Fisher/Backlund Paris/Blythe Maddux/Gilmy Volume Accounting-B. Wilks N. Weiss D. Seitz M. Davis ARCO-Doug Montgomery/Waylly Worthington PR-B6 File: PC-PBU/AQ/Corresp. I BP EXPLORATION July 24, 1992 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 BP Exploration (Alaska) Inc. 900 East Benson RO. Box 196612 Anchorage, Alaska (907) 561-5111 ,:RES ~ 8R ENG ENG ASST I ENG ASST I s. GEOL A_S_~.. .......................... STAT TEOH[ GO-1 and G(;;-2 FLARE REQUEST ADMINISTRATIVE APPROVAL ,PRUDHOE BAY UNIT WOA Dear Mr. Douglass: BP Exploration (Alaska) Inc. requests written authorization for flaring a total of 100 MMCF of natural gas at GC-1 and GC-2 associated with the restart up of the 60 inch line from GC-1 to CGF. The restart will take place on or about August 7, 1992. Flare assist gas will be used to avoid black smoke while, flaring and effort will be taken to keep the flaring to a minimum. If you have any questions concerning this issue, please contact Alison Cooke at 564-4838. Sincerely, Alison D. Cooke, Environmental Scientist Environmental & Regulatory Affairs, Alaska ADC RECEIVED Alaska.0JI .& Gas Co~s. C0mmiss[o[~ Anchorag~ JUL 24 '92 0~:22PM BPX EMVIROMMEHT - TO AOGCC, ANCHORAGE ,, BP EXPLORATION BP Exploration (Alaska) Inc. P.O. Box 196612 Anchorage, AK 99519-6612 MESSAGE # P. ~/2 FAX COVER SHEET ENVIRONMENTAL & REGULATORY AFFAIRS; DEPARTMENT Company Location FAX No. TO: Confirm No. FROM: ,,,,~ ..... ?,,,~_. c.._..~b..~ ..... Department Environmental & Regulatory Affairs FAXNo, (907) 564-5020 Confirm No. Mail Stop M B 11 -6 NOTES' PAGES TO FOLLOW: (Does Not Include Cover Sheet) 0 PRIVATE ©SECRET O CONFIDENTIAL RECEIVED J U L ?_ ? !992 Alaska 0ii & Gas Cons. Commission Anchorage 2~ '~2 P. 2/2 03:23PM BPX EMVIROMMEHT i" July 24, 1992 BP Exl3~lratlofl (Alas~) Inc. 900 East Ben,or} Boulevard P.O. Box 196612 Anchorage, Alaska {~$19-6612 {~7} S~-Slll Mr. Russ Douglass Alaska Oil and Gas Conservation commission 3001 Porcupine Drive Anchorage, Alaska 99501 GC-1 and GC-2 FLARE REQUEST ADMINISTRATIVE APPROVAL PRUDHOE BAY UNIT WOA Dear Mr. Douglass: BP Exploration (Alaska) Inc. requests written authorization for flaring a total of 100 MMCF of natural gas at GC-1 and GC-2 associated with the restart up of the 60 inch line from GC-1 to CGF, The restart will take place on or about August 7, 1992. Flare assist gas will be used to avoid black smoke while, flaring and effort will be taken to keep the flaring to a minimum. If you have any questions concerning this issue, please contact Alison Cooke at 564-4838. Sincerely, Alison D. Cooke, EnViron'mental S( ien-t Sf ............ Environmental & Regulatory Affairs, Alaska ADC RECEIVED tUL ~ 7 i~2 ,.~ast<a ui'l & Gas Cons. Commission Anchorage BP EXPLORATION July 22, 1992 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 C O M M BP Exploration (Alaska) Inc. SOMM 900 East Benson Boulevard I , ~.0. Box 196612 Anchorage, Alaska 99519-6612 SR'---E.-~ (907) 561-5111 SR ENG ;~G~ST ~;EOL ,:, ~AT TECH ............... : STAT TE~- GC-2 FLARE REQUEST ADMINISTRATIVE APPROVAL PRUDHOE BAY UNIT WOA Dear Mr. Douglass: BP Exploration (Alaska) Inc. requests written authorization for two flare events and a total of 150 MMCF of natural gas at GC-2 associated with the repair to the K-206 and K-207 compressors. The work on the K-206 LP compressor took place from July 20 through today, July 22, 1992. Kate Purl spoke to Blair Wondzell at your office on Monday, July 20 to obtain verbal approval for the flaring associated with the K-206 repairs. The work on the K-207 IP compressor will begin on or about July 24 and last approximately 3 days. The anticipated flare volume for these repairs is 25 MMscf/day. The repairs involve seal replacement and possible repairs to the compressor bundle on both units. Problems have recurred over the past several days with these compressors aggravated by high ambient temperatures. Flare assist gas will be used to avoid black smoke while flaring and effort will be taken to keep the flaring to a minimum. If you have any questions concerning this issue, please contact Alison Cooke at 564-4838. RECEIVED d U L 2 3 1992 Alaska Oil & Gas Cons. CommisSiOr~ Anchorage Mr. Russ Dougl. Page 2 7/22/92 ,, AOGCC Sincerely, SEtnev~reonn Dm;gnT~taYll~r'RMe~un~agtoe~ Affairs, Alaska SDT/ADC ARCO Alaska, Inc. '~/~' Post Office Box 10036c'~ Anchorage, Alaska 99510-0360 Telephone 907 276 1215 July 7, 1992 Mr. Russell A. Douglass, Commissioner State Of Alaska Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 Dear Mr. Douglass: Subject: Flaring at the PBU Facilities to Accommodate GHX-2 Projects Work AAI requests approval to flare up to 100MMSCF of gas at the Flow Stations, Central Gas Facility (CGF) and Central Compression Plant (CCP) in the Eastern Operating Area of the Prudhoe Bay Unit and at the WOA (BPX) Gathering Centers. The flaring will occur in conjunction with modifications to the gas plants for the Gas Handling Expansion Project - Phase II (GHX-II). The work consists of tying in a new 36" by-pass line to the CCP Tandem Compressors from the 60" transmission line and shutting down the CGF Booster Compressors for the second Port-a-test tie in. Flaring is required at the gas plants to safely depressure affected systems for shut-down/tie-in work and at the FSs/GCs to control system differential pressure upon re-commisioning. Flaring is planned to begin August 7 and should be complete by August 15, 1992, inclusive of start-up commissioning. The total requested flare volume is 100MMSCF, including contingencies. Every effort will be made to keep flaring to a minimum whenever possible and all volumes will be reported on the Monthly Gas Disposition Report, Alaska Oil and Gas Conservation Commission form 10-422. Please call me or my alternate Wally Worthington, at 659-5922, if you have any questions. Sincerely, D.B. Montgomery EOC Supervisor Prudhoe Bay Operations ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany I ECEIVED d U L 1 4 992 Alaska OiJ & Gas Cons, Commission Anchorage BP EXPLORATION June 22, 1992 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 BP Exploration (Alaska) Inc. 900 East Benson Boulevard P.O. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 AMENDED GC-2 FLARE REQUEST AOMINISTRATIVE APPROVAL PRUDHOE .BAY UNIT WOA Dear Mr. Douglass' On June 9, 1992, BP Exploration (Alaska) Inc. requested written authorization to flare a total of 2.5 BCF of natural gas at GC-2 associated with the shutdown of the GC-2 plant on August 6-10, 1992. Based on recent results from ultra- sonic testing we have determined that the high pressure flow lines will not need to be replaced during this shutdown. Therefore the amount of gas we need to flare is substantially less than our original re.q..uest. We would like to amend our request t~'~-f[tf~'ti-a'rat~'rization-to'"flare":~a'"J'~'~J'~"b-f 500 'MMCF of natural gas. We now estimate that the scheduled maintenance will be done over a ten day period and approximately 50 MMscf/day will be flared in assOciation with this work. Work efforts on various parts of the plant will be coordinated to minimize gas volumes flared. Flare assist gas will be used to avoid black smoke while flaring and effort Wilt be taken to keep the flaring to a nlinimum. If you have any questions concerning this amended request, please contact Alison Cooke at 564-4838. ' Steven DJ-Taylor,'-I~lanag~'~'~- -//' / - Environmental & Regular, Alaska SDT/ADC RECEIVED J UN 2 5 199~. Alaska .0il & Gas Cons. Commission Anchorage BP EXPt.OR~N BP Exploration (Alaska)Inc. PO Box 196612 Anchorage, Ataska 99519-6612 MESSAGE #. P. ~L/£ TELECOPY COMMUNICATIONS CENTER TO: Name; Company: Location' Confirm #_ FROM: Department: ,, "~._._~,,3 , Mail Stop: NOTES: PAGES TO FOLLOW RECEIVED (Do Not Include Cover Sheet) .jUN .'2 3 !992 AtasK~ Uii & Gas Cons. Commission _,.Anchorage ____ APPROVED' (For International Use Only) SECURITY CLASSIFICATION PRIVATE SECRET , . CONFIDENTIAL .... Telecopy # 564-5441 Confirm # 564-5443 AK 34~7.2 (1/89) FOR COMMUNICATIONS CENTER USE ONLY Time In Time Sent Time Confirmed Confirmed By Operator O?:~AM BPX EHVIROMMEMT .,- BP EXPLORATION June 22, 1992 BP Exploration (N~ska) inc. 900 Ea~ Benson ~ouleva~ RO, E~x 196612 Anchorage, A~sl~a 9{)s~i~-6612 (o.~r) s61-51~1 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 _AMENDED GO-2 FLARE REQUEST ADMINISTRATIVE APPROVAL P_RUD_HOE .BAY UNIT WOA Dear Mr. Douglass: On June 9, 1992, BP Exploration (Alaska) Inc. requested written authorization to flare a total of 2.5 BCF of natural gas at GC-2 associated with the shutdown of the GC-2 plant on August 6-10, 1992. Based on recent results from ultra- sonic testing we have deten~ined that the high pressure flow lines will not need to be replaced during this shutdown. Therefore the amount of gas we need to flare is substantially less than our original request. We would like to amend our request to written authorization to flare a total of 500 MMCF of natural gas, We now estimate that the scheduled maintenance will be done over a ten day period and approximately 50 MMscf/day will be flared in association with this work. Work efforts on various parts of the plant will be coordinated to minimize gas volumes flared. Flare assist gas will be used to avoid black smoke while flaring and effort will be taken to keep the flaring to a minimum. If you have any questions concerning this amended request, please contact Alison Cooke at 564-4838. Stay, eh D.--Taylo~,"l~lanag~ - ~/- Environmental & Regula ~ A~..~~ Alaska SDT/ADC RECEIVED Alaska 0il & Gas Cons. Commission Anchorage BP EXPLORATION June 9, 1992 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 COMM .... BP Exploration (Alaska) Inc. COMM 900 East Benson Boulevard P.O. Box 196612 RES ENG -~;~ Anchorage, Alaska 99519-6612SR ENG (907) 561-5111 SR ENG ENG ASST ; ENG ASST-i SE GEO L ~.~ GEOL ~-0£' ~-s-S~r ['~ :~TAT TIE'CHI STAT TECHI GC:-2 FLARE REQUEST ADMINISTRATIVE APPROVAL PRUDHOE BAY UNIT WOA Dear Mr. Douglass: BP Exploration (Alaska) Inc. requests written authorization to flare a total of 2.5 BCF of natural gas at GC-2 associated with the shutdown of the GC-2 plant on August 6-10, 1992. The workscope associated with this shutdown includes replacement of all HP gas discharge valves, the lateral piping and header to the IP gas cooler skid, and additional wet gas piping replacements between the LP gas separator and IP gas scrubber. Entries into the two vessels are also planned for inspection and repairs. Anticipated duration of this work is five days with an approximate flare volume of 500 MMscf/day. Alternatives to flaring these gas volumes include a full plant shutdown. This is a less desirable option since additional time required for equipment safe- outs and restoring the plant to service would add about four days to the length of the shutdown. D~production for this alternative would be approximately 2 million barrels compared to 300 thous~.-~l-15-b.-i'fi~l-~-f-0-K't~e ~d~g~.E-option. Additional ti-~e and resources would also be required to freeze protect high water cut wells to prevent freezing through the permafrost section of the wellbore during a full plant shutdown. Work efforts on various parts of the plant will be coordinated to minimize gas volumes flared. Repair of corroded sections of the Eileen West End flowline and cleanout and repair of the D-bank slugcatcher(both requiring production reductions) are scheduled simultaneously with the gas plant shl[~l~~ ! ~! I\ L ~;;, !.. I v ED JUN 1 2 1992 Alaska 0il & 6as Cons, (jommisSio~ Anchorage Mr. Russ Dougl{~ Page 2 6/9/92 ~, AOGCC Flare assist gas will be used to avoid black smoke while flaring and effort will be taken to keep the fladng to a minimum. If you have any questions concerning this issue, please contact Alison Cooke at 564-4838. Sincerely, Steve~v~v~n ~T E nvi ro n m~ n~aYl i~,~,~1~ n~~agtoe~ Affairs, Alaska SDT/ADC JUN 1 2 1992 Alaska Oil & Gas Cons. Comm~ss~o~'~ Anchorage BP EXPLORATION April 27, 1992 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 COMM L~ BP Exploration (Alaska)Inc. RES ENG ~ 900 East Benson Boulevard SE ENG ~ RO. Box 196612 Anchorage, Alaska 99519-6612SE ENG ~ (907) 561-5111 ~ ENG ASST I 'ENG ASST~I SR GEOL ~J~. GEOL ASSTI! L GEOL ASSTIm'~ STAT TECHI ,. STAT TECHt j GC-1 FLARE REQUEST ADMINISTRATIVE APPROVAL PRUDHOE BAY UNIT WOA Dear Mr. Douglass: BP Exploration (Alaska) Inc. requests written authorization to flare a total of 5 MMCF of natural gas at GC-1, commencing or about April 27, 1992. Flaring should be completed on or about May 4, 1992. The flaring will be in support of repairs due to a corroded pipe plug near Skid 22 in our L.P. gas header. It will be necessary to take the L.P., Skid 18 gas system out of service for approximately 6 hours during the repairs We will be required to flare our L.P. gas while welding repairs are made. Flare assist gas will be used to avoid black smoke while flaring and effort will be taken to keep the flaring to a minimum. If you have any questions concerning this issue, please contact Alison Cooke at 564-4838. Sincere,ly, . Steven D. Taylor, Mana{3er Environmental & Regulatory SDT/ADC Affairs, Alaska RECEIVED A~aska 0il & Gas Cons, Anchorage '92 O?:51AM BPX EHVIROMMEMT BP Exploration (AlaSI<~) inc. 900 Eaat Benson BOulevard P.O. BOx 196612 Ahchorag& Ale,$k~ 99519-6612 Apdl 27, 1992 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 GC-1 F .I, ARE.REQUEST ADIVJlNISTRATIVE APPRO~/AL PRUD. HOE .BAY UNIT WOA Dear Mr. Douglass; BP Exploration (Alaska) inc. requests written authorization to flare a total of 5 MMCF of natural gas at GC-1, commencing or about April 27, 1992. Flaring should be completed on or about May 4, 1992, The flaring will be in support, of repairs due to a corroded pipe plug near Skid 22 in our L.P, gas header. It will be necessary to take the L.P., Skid 18 gas system out of service for approximately 6 hours during the repairs We will be required to flare our L.P. gas while welding repairs are made. Flare assist gas will be used to avoid black smoke while flaring and effort will be taken to keep the flaring to a minimum. if you have any questions concerning this issue, please contact Alison Cooke at 564-4838, ~teven D.~Ta~10r, I~an~a~er ..... ' -' Environmental & Regulatory Affairs, Alaska SDT/ADC RECEIVED APR 2 ? 1997. ktaska Oil & Gas Cons. Commission Anchorage TO: 07:51RH ~PX £HVZROHHFHT . BP EXPLORATION BP E×pioration (Alaska) ]nc, PO Box 196612 Anchorage, Alask~ 99519-6612 TELECOPY COMMUNICATIONS CENTER Name:_ Company: Location: Fax # c~_. 77~, Confirm # MESSAGE #, . RECEIVED APR 2 7 1992 0il & Gas Cons. Commission Anchorage FROM: NOTES: Name & Ext.:_ ~_~~ Department:. ~_~. Mail Stop: PAGES TO FOLLOW __, ~ (Do Not include Cover Sheet) --APPROVED' (For International Use Only) SECURITY ~LASSIFICATION PRIVATE ._---- SECRET CONFIDENTIAL Telecopy # 564-5441 Confirm # 564-5443 AK 3417-2 FOR COMMUNICATIONS CENTER USE ONLY Time In _ Time Sent. _. Time Confirmed Confirmed By Operator __.. --.__. ARCO Alaska, Inc. { Post Office Box 10036 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 COMM · COMM RES ENG < April 23, 1992 SR ENG iSR ENG ENG ASST ~ Mr. Russell A. Douglass, Commissioner State Of Alaska Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 !ENG ASST. SR 'GEOL ASSTI~- GEOL ASSTI~L~ STAT TECHI i STAT TECH1 Fax 276-7542 I'FILE Dear Mr. Douglass: Subject: Revised Flare Volume for CCP Facility Work AAI requests.approval to flare up to 15 MMSCF of additional gas (25 MMSCF total) at the Central Compression Plant (CCP), in the Eastern Operating Area of the Prudhoe Bay Unit. The additional flare volume is requested to accomodate unexpected downtime as occurred on April 21,1992, when two Iow stage turbine/compressors came off line unexpectedly when a scheduled high stage turbine/compressor was brought down for its annual water wash maintenance. This event was originally anticipated for in the original flare volume request, but as stated, the contingency volume has been utilized. Every effort will be made to keep flaring to a minimum whenever possible and all volumes will be reported on the Monthly Gas Disposition Report, Alaska Oil and Gas Conservation Commission form 10-422. Please call me or my alternate, Doug Montgomery, at 659-5922, if you have any questions. Sincerely, W.R. Worth'~gntrOn EOC Supervisor , Prudhoe Bay Operations ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany RECEIVED APR 2 7 1997. Alaska 0il & Gas Cons. Commission Anchorage SENT BY:ARCO AK. INC. : 4-23-92 : 1:24P~ ; ARCO ilssk~, I~ , Po~t Office Box 100~0 .amchor~e, AIo~,I~, 6Q510-0360 Telephone 907 276 1215 April 23, 1992 ELD SLlYI~OIi'I'/OI"~-' , P~O~ A06CC;# 1/ I Mr. RuSSell A. Douglass, Commissioner State Of Alaska Alaska Oil ~ G~s Conservation Commission (AOGOC) 3001 Porcupine Drive Anchorage, AK 9950'1-3192 Fax 276-7542 Dear Mr. Douglass: Subj~t: .Dev..!~ed..., F!am.__V. olume., for~.C_.Cp. Facility......Work AAI requests approval to flare up to t6 MMSCF ~f additional gas (~5 MMSCF to.tel) at the Central Compression Plant (CCP), In 1he Eastern Operating Area of the Prudhoe Bay Unit. The additional flare volume I~t requested to aeoomodate unexpected downtime ~s occurred on April 21.1'992, when two 10w stage turbine/compressors came off line unexl~ectedly when a scheduled hi{Ih stage turbine/compressor was brought down for Ils annual water wash maintenance. This event was originally antioipeted for in the original flare volume request, but as stated, tt~e contingency volume has been utilized. Every effort will be made to keep flaring to a minimum whenever possible and all votume$ will be reported on the Monthly Gas Disposition Report, Alaska Oil and Gas Conservation Commission form 10-422. Please call me or my alternate, Doug Montgomery, at 659-$g22, if you have any questions. Sincerely, , ' W.R. Worthington /~/' -- Eec ,.~upervisor V . Prudl~oe Bay Operations R£C IV£D Gas Cons. Commission Anchorage ARCO Alaska. Inc. is a Subaidisry of AtlanlicRichflotdOompany ARCO A~s~, I~c. Post Office Box 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 April 12, 1992 CE COMM COMM RES ENG SR S Mr. Lonnie Smith Commissioner, State Of Alaska Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 Dear Mr. Smith' SR GEOL GEOL GEOL STAT STAT RECEIVED Subject: Flow Station 1 Flare Leakage. Aoril 9. 1992 APR 2'! ~,992 Alaska 0il & 6as Cows. 60mmissio~ Anchorage This memo serves to document our conversation of Friday, April 10th, pertaining to the normal flare leakage at Flow Station 1, Prudhoe Bay Field, Eastern Operating Area on Thursday, April 9, 1992. As described below, the normal flare leakage went to the fourth stage flare candles instead of the auxiliary flare, and will not be reported as a flaring event via a flare report. On April 9, 1992, at approximately 10:30 AM, Flow Station 1 raised the set point on the Residue Gas back pressure controller 5 psig to 615 psig. The purpose of this change was to reduce Residue Gas velocity through the gas trains to prevent excessive TEG losses. On April 10th, at 03:30 AM, Flow Station personnel detected the ignition of several candles on the fourth stage flare field. Initial investigation concluded that P176V, the High Pressure Operational Flare valve, was leaking. This was due to the additional back pressure being imposed on the facility. The valve was reopened and the back pressure controller set point was lowered to 610 psig. The duration of the incident was forty minutes. At 9:04 AM, the same day, several fourth stage flare candles ignited again. After checking P176V, further investigation revealed the fourth stage rupture disc, X281D, had ruptured, allowing normal flare leakage gas to the fourth stage flare. This gas leakage would normally be burned in the High Pressure Auxiliary Flare (see enclosed flare schematic). The rupture disc was isolated and repaired immediately. This flare event lasted forty-five minutes. It appears the fourth stage disc ruptured on March 24th, while flaring to relieve transit line pressure after the shut down of several compressors at the Central Compression Plant. Normal flare leakage did not become great enough to cause ignition of the fourth stage candles until .the plant's internal pressure was increased on April 9, 1992. ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany Memo to L. Smith Per our conversation, I am submitting this memo as an addendum to the Monthly Gas Disposition Report, AOGCC form 10-422, to document this event. If any further information is needed, please contact Doug Montgomery or myself at 659-5922. Sincerely,, W.R. Worthingtor)~/ "-- EOC Supervisor ~/ Prudhoe Bay Operations Enclosure ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany BP EXPLORATION April 1, 1992 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 dOMM "~; COMM ~ BP Exploration (Alaska)~r~ I=KI~'~- i.~,&/l-~' 900 East Benson Boulev~,~ ~ ~'~ ~ RO. Box ~966~2 SR ENG .. ~ Anchorage, A~aska 995~ENG ~ (907) 561-5111 ~ENG ASST [ _~ ~' ENG ASST ~. SR G EO.~; STAT TECHI STAT TECHI t GC-3 FLARE REQUEST ADMINISTRATIVE APPROVAL PRUDHOE BAY UNIT WOA Dear Mr. Douglass: BP Exploration (Alaska) Inc. requests written authorization to flare a total of 100 MMCF of natural gas at GC-3, commencing or about May 8, 1992. Flaring should be completed on or about May 9 1992. The flaring will be in support of maintenance activities required to place the E-364 gas-to-gas exchanger back in service. The exchanger was taken out of service on January 17 and replacement of the exchanger bundle was completed on March 31. Remaining work includes pulling blinds and restoring flow through the exchanger. The volume requested includes a contingency in case isolating valves do not hold, requiring gas to be bypassed around the plant. Flare assist gas will be used to avoid black smoke while flaring and effort will be taken to keep the flaring to a minimum. If you have any questions concerning this issue, please contact Alison Cooke at 564-4838. Since'~ A~/~,~ Steven D. '~a~,lor~-M~nager Environmental & Regulatory Affairs, Alaska SDT/ADC RECEIVED APR - 2 1992 Alaska .0il & Gas Cons. Comrnissio~ Anchorage BP EXPLORATION February 25, 1992 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 BP Exploration (Alaska) Inc. 900 East Benson Boulevard RO, Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 COMM RES ENG ~ SR ENG SR ENG ENG ASST I ENG ASST_ I SR GEO~./ GEOL A¢~T___~ ~-~f- ASSTi .~,~ ':gTAT TECHI STAT TECHI ; GC-3 FLARE REQUEST ADMINISTRATIVE APpRQVAL PRUDHOE BAY UNIT WOA Dear Mr. Douglass: BP Exploration (Alaska) Inc. requests written authorization to flare a total of 20 MMCF of natural gas at GC-3, commencing or about February 28, 1992. The flaring will be done while isolating equipment to perform maintenance on gas plant heat exchangers. Every effort will be taken to ensure smokeless flaring and reduce the flaring to a minimum. If you have any questions concerning this issue, please contact Alison Cooke at 564-4838 or Kate Purl at 564-4043. Sincerely, Stev~'n Ii. Taylor, IVl&nager ~ ~ Environmental & Regulatory Affairs, Alaska KFP RECEIVED Alaska 0il & 6as Cons. Comm'tssion Anchorage BP EXPLORATION February 6, 1992 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 BP Exploration (Alaska) Inc. 900 East Benson Boulevard P.O. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 '~ES ENG SE ~ SE ENG ENG ASST I ', ENG ASST I SR G EOi~___-' GEOL ASSTI ~ II GEOL ASSTI ~,'~ STAT TECHI i GO-3 FLARE REQUEST ADMINISTRATIVE APPROVAL pRUDHOE BAY UNIT WOA Dear Mr. Douglass' BP Exploration (Alaska) Inc. requests written authorization to flare a total of _I_0__MMGE_O_( natural gas at.~C-3, commencing or about February 10, 1992. Flaring should be completed on or a-b-6ut February 13, 1992. The flaring will be associated with a shutdown of one of our Low Pressure (LP) compressors (K-305) to make repairs due to high vibration. The flaring is necessary to maintain operation of the entire gas compression system. Flare assist gas will be used to avoid black smoke while flaring and effort will be taken to keep the flaring to a minimum. If ,,,,,,~.... h,..,z..-, ,:, any questions concerning. . this issue, p!ease contact Alison Cooke at 564-4838. Sincerely, Steven' D.~Ta~ylo~ M,~n~.ger Environmental & Re~lulatory Affairs, Alaska SDT/ADC R' ¢EIVED FEB t992 Alaska 011 & (las Cons. Commissio[~ Anchorage TO: THU 10 : 40 t~PX EN~ I RONMENT BP EXPLORATION BP Exp~oratqon (AlasKa) InC. PO Bux 19~612 Anchorage, Ala~k~ 99519-6612 TELECOPY SATELLITE UNiT Name: ~%. "'~.,,~'~ ~. "~ ~ ,,_,~. ~_~ Company: . ~ O_...~__~_,_t"' , Location: .-I:X,v.~'X,,~'~A r,,~. P.01 Mi::~AL~E # RECEIVED ¢ E B - 6 1992 maska ud & Gas Cons. Commission Anchorage FROM: Name & Ext.: '~\t~_~ ..... C_,--~,._- Department: 'E_~_~,~.,~~. PAGES TO FOLLOW (Do Not include Cover ,.Sheet) SECURITY CLASSIFICATION ___.__ PRIVATE _____ SECRET _________ CONFIDENTIAL SATELLITE FAX MACHINE Confirm AK 3417.06 r-rD ~IP EXR.OR#FION r',. 0.!. February 6, 1992 Mr. Huss Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska g9501 RECEIVED Alaska Oil & Gas Cons. Commission Anchorage GC-3 FLAFJE HEQUE_Q~ ADMINISTR,~.T. IVE APPROVAL PRUDHOE BAY UNLIT WOA Dear Mr, Douglass: lip Exploration (Alaska) Inc. requests written authorization to flare a total of 10 MMCF of natural gas at GC-3, commencing or about February 10, 1{)92. Flaring should be completed on or about February 13, 1992, The flaMng will be associated with a shutciown of one of our Low Pressure (LP) compressom (K-305) to make repairs due to high vibration, The flaring is necessary to maintain operation of the entire gas compression system. Flare assist gas will be used to avoid black smoke while flaring and effort will be taken to keep [he I'l~ring to a minirnum. If you have any questions concerning this i~sue, please contact Alison Cooke at 554-4838, Sincerely, Steven' D.'T~ylo~: M~nager Environmental & Re{jul~tory Affairs, Alaska SDT/ADC BP EXPLORATION January 6, 1992 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 BP Exploration (Alaska) Inc. 900 East Benson Boulevard RO. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 (~C-3 FI,ARE REQUEST ADMINISTRATIVE APPROVAL PRUDHOE BAY UNIT WOA Dear Mr. Douglass: BP Exploration (Alaska) Inc. requests, written authorization to flare a total of 1 BCF of natural gas at GC-3, commencing or about January 17, 1992. Flaring should be completed on or about January 18, 1992. The flaring will be associated with scheduled maintenance including gas exchanger work and valve replacement. We are performing all anticipated maintenance at this time to take advantage of the scheduled gas plant shutdown at GC-3 and to avoid the need for additional shutdown and flaring in the near future. The timing of the GC-3 shutdown is tied into the compressor conversion work in the Eastern Operating Area. Every effort will be taken to ensure smokeless flaring and keep the flaring to a minimum. If you have any questions concerning this issue, please contact Alison Cooke at 564-4838. Steven' D. "ra~,lor, Manager Environmental & Regdlatory Affairs, Alaska SDT/ADC REErEIVED JAN 1 0 1992 Alasl{a Oil :& Gas Cons. Commission Anchorage BP EXPLORATION November 18, 1991 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 BP Exploration (Alaska)Inl?,-'-,i.,~/; ~/f ........ ;-~, ' 900 East Benson Soulevar~ ',,,;L) M iV~ - .' P.O. Box 196612 (907) 561-5111 '-R~S ENG ~"[~G ASST :~~o~ -~E~~, H G¢-3 FLARE REQUEST ADMINISTRATIVE APPROVAL PRUDHOE BAY UNIT WOA Dear Mr. Douglass' BP Exploration (BPX) requests written authorization to flare a total of 200 MMCF of natural gas at GC-3, commencing or about November 20, 1991. Flaring should be completed on or about November 27, 1991. The flaring will be associated with maintenance to repair a tube leak in the gas to gas exchanger. We are performi_n~g_t, he maintenance at this time to . take adVantage of the s-q~h~e~du[ed~s~t-8~n~`~t~~.~:t~.~P~,``~~"i~```~(~i:~ effort will be taken to ensure smokeless flaring and keep the flaring to a minimum. If you have any questions concerning this issue, please contact Alison Cooke at 564-4838. Sincerely, ADC Affairs, Alaska ALASKA OIL AND GAS CONSERVATION COMMISSION September 20, 1991 WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 Mr. Tommie N. Thompson Permit Coordinator ARCO Alaska, Inc. P. O. Box 100360 Anchorage, Alaska 99510-0360 Re: Additional flare volume, Central Processing Facility No. 1 Kuparuk River Unit. Dear Mr. Thompson: We have received your letter of September 19, 1991, requesting additional flare volume for the Central Production Facility No. 1 (CPF1) in the Kuparuk River.Unit. The additional flare volume is for leak detection monitoring and for testing the CPF1 Smokeless Flare Project. The Commission finds the additional flare volume to be an operational necessity, and hereby approves flaring up to 160.0 MMcf of gas over and above the designated safjety flare pilot of the CPF1. Testing is expected to commence on or about September 24, 1991, and continue until work is complete. It is understood that gas flaring will be kept to a minimum whenever possible, and all volumes will be reported monthly on Alaska Oil and Gas Conservation Commission form 10-422. All gas produced in excess of the 250 Mcf/d safety flare pilot volume is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass Commissioner ARCO Alaska, Inc. [ Post Office Box 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 September 19, 1991 Mr. Russ Douglas Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 Dear Mr. Douglas' ARCO Alaska, Inc. has recently installed a smokeless flare at the CPF 1 facility in the Kuparuk Field. Plans are to begin testing the flare on Friday, September 24 and conclude within one week. The procedures and plans to be followed during the test are attached. Volumes will range from 250,000 SCFD to 160,000,000 SCFD. Test will occur over a 5 to 10 minute timeframe and are not expected to exceed 2 hours cumulatively. Request your review and approval. Sincerely, Permit Coordinator TNT/09/009 attachments RECEIVED Alaska 0ii & Gas Cons. Commissien Anchorage ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany AR3B-6003-C; Oliktok Pi.oeline Pressurization - Ooerational Readiness and Smokeless Flare testing It is requested that the Oliktok Pipeline be granted permission to pressurize the line above the present pressures maintained for leak detection monitoring and in support of a discontinued "conditioned" state. Once pressurized to the normal operating pressure of the line (800 psig, line capacity 9.6 MMSCF) the gas will be used to supply high rate gas volumes for testing of the new CPF-1 Smokeless Flare Project. Gas from the Oliktok line will be used to simulate high rate plant flaring observed during emergency operations and monitor pedormance (i.e., gas flow rates, pressures, and flare tip performance) of the new smokeless flares. This flare pedormance information will be used to substantiate compliance of the new flare system with State of Alaska and Federal regulations for smokeless flaring and provide valuable test results needed to support on-going engineering of the CPF-2 and CPF-3 smokeless flare systems. The Oliktok Pipeline will be fully evaluated for safety, operability prior to and during the pressurization of the line. When flare testing is completed the line will be returned to its presently maintained condition. Background The new CPF-1 Smokeless Flare has been installed at Kuparuk to meet State of Alaska and Federal environmental requirements for smokeless flaring during flare events. The new flare system shall have a smokeless capacity equal to the total flare capacity. Additionally, the CPF-1 plant will be capable of starting up and shutting down without having a smoking event as required by the regulations. Note: A smokeless flare is defined as having a smoke plume with an opacity less than 20%. The CPF-1 Smokeless Flare capacity is designed for a smokeless flare rate of 540 MMSCFD. This is the calculated maximum flare rate during a plant emergency blowdown at which the plant is maintained in a safe condition. The hydraulic design of the flare system was pedormed by computer modelling the plant relief system. Relief system simulators of this type have been found to have a range of accuracy of _+20% in measuring pressures and flows. Flare testing is needed to verify the hydraulic design for pressures and flowrates over the full range of process design conditions. The flare system hydraulics directly effect the plant system safety and ability of the flare equipment to pedorm properly. It's proposed that the Oliktok Pipeline be used as a large gas accumulator to supply gas rates which simulate emergency plant blowdown rates without adverse impact to plant operation. In fact, the Oliktok line simulates very well the separation vessels in the plant which hold large volumes of gas during emergency plant blowdown. Testing of the flare system is planned immediately following commissioning of the new flare. During the development of flare test plans, it became evident that there may not be sufficient gas available from the normally operating plant to fully test the flare system for operability, instrument control, gas measurement and flare system hydraulics. Testing of the CPF-1 flare system is proposed to begin September 20, 1991. The Oliktok line will be pressured to full operating pressure of 800 psig and used to supply only the volume of gas required above the plant supplied volume to effectively test the new flare system performance. At the completion of the flare testing, the Oliktok line will be reduced in pressure and returned to the pressure maintained for leak detection during discontinued service by recovering excess gas to the main gas process stream. Prior to and during the pressurization of the line for flare testing, the Oliktok Pipeline Company will monitor the line to assess the safety, operability, and integrity of the Oliktok line. This information will be recorded .and documented as evidence in support of the operational condition of the Oliktok Pipeline in discontinued service. It should be noted that the Oliktok Pipeline is not being placed in service but utilized for testing of the flare and documentation of its operational readiness. Smokeless Flare Testing Procedures These procedures will help determine the ability of the new flare to burn routine flare events smokelessly. Routine events are those which occur with a certain regularity: STV compressors tripping out, GLCs tripping out, flaring off the Primary as a result of a tripped GLC or as a result of a rapid rise in ambient temperature and a subsequent loss of turbine horsepower. Naturally, the flare testing should not take place until the new flare has been put on line though the completion of the start-up procedures and system status checklist. Testing Procedure: 1. Install a chart recorder to track Flare Knockout Drum pressure. 2. Create a Bailey trend screen to track LP Flare pressure and flow and HP Flare pressure and flow. 3. Lower PIC-1068A setpoint (STV Suction Scrubber V2-105 vent-to flare) as far as possible without flaring. Note: this is the old suction scrubber which will provide the heavist gas possible. 4. Unload the STV compressors one stage at a time. Note flare flow rates, temperatures, and pressures. Compare the STV total discharge flow (Bailey gas flows, page 4) to the indicated flare rate (ADS panel 21). 5. Reload the STVs and return PIC-1068A to its normal setting. 6. Lower the setpoint on PV-1009 (Primary vent-to-flare) as far as possible without flaring. 7. Open FV-1035A (First Stage Recycle) as far as necessary to produce the desired flow rate at PV-1009. Compare Gas Flow Overview values with the new flare system display. 8. Continue recycling additional stages of gas lift compressors until flare switchover occurs (approximately 140 MMSCFD or 25psi on the LP Flare ). Record flow rates, temperatures and pressures. If additional gas volume is needed, deliver gas from the lift gas system vent to flare using PV-1108. Only use the OPC line for flaring in the event that plant is not able to deliver the desired volume of gas. 9. Return the recycle valves to their normal positions and reset PV-1009. Post Office B ~00360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 September 4, 1991 Mr. Russell A. Douglass, Commissioner State of Alaska Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 Dear Mr. Douglass: Subject: Flaring at Flow Station 3 for STV Flare Test AA! requests approval from the AOGCC to flare up to 3 MMSCF at Flow Station 3. The flaring event will take place on or about September 7, 1991. The flaring event is necessary to test modifications that have been made to the STV flare second- and third-stage assist gas tips. The modifications have been made to enhance the smokeless burning capability of the STV flares. Gas flaring will be kept to a minimum whenever possible and all volumes will be reported on the Alaska Oil and Gas Conservation Commission Producer's Report of Gas Disposition, form 10-422. Should you have any questions please, call me at 265-6223. Sincerely, G. E. Griffin Operations staff~Manager Prudhoe Bay Operations GEG/hb RECEIVED SEP 5 1991 Alaska 0il & Gas Cons. comm'~ss'~ ;Anchorage ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany AR313-6003-C SEP-04-' 91 WED 11 :,59 I D." ANO 1200 . ARCO AIImim, Ino, Poit Offloi Box 100380 Anchorege, AIIIKI Telephone ~7 276 1215 TEL NO: 2656493 ~552 PO1 September 4, 1991 Mr. Ru~oell A. Douglass, Commissioner State of Alaska Alaska Oil and Gas Conservation Commission (AOG£C:) 13001 Porcupine Drive Anchorage, AK 99501-13192 Dear Mr. Douglass: Subject: ~!~rin_e...i~t Flow Station 3 for STV Flare...'l'~St AAI requests approval from the AOGCC to flare up to 3 MMSCF at Flow Station 3. The flaring event will take place on or about September 7, 1991. The flaring event is necessary to test modifications that have been made to the STV flare second- and third-stage assist gas tipo. The modifications have been made to ei~ance the smokeless burning capability of the STV flares. Gas flaring will be kept to a minimum whenever pOssible and all volumes will be reported on the Alaska Oil and Gas Conservation Commission Producer's Report of Gas Disposition, form 10-422. Should you have any questions please, call me at 265-6223. Sincerely, ~ Operations StMfq~fanager Prudhoe Bay Operations I £CEIVEo ARCO Alsek&, Ibc. I~ 4 l~l~91~lllry of Alllnt!eRiChfieldGOmpany AR3B-80O3-(~ BP EXPLORATION August 30, 1991 BP Exploration (Alaska) Inc. 900 East Benson Boulevard RO. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 Mr. Russ Douglass and Mr. Dave Johnston Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 GO-l, GC-2 and GC-3 FLARE REQUEST ADMINISTRATIVE APPROVAL PRUDH. OE BAY UNIT.WO.A Dear Mr. Douglass and Mr Johnston' BP Exploration (Alaska) Inc. requests written authorization to flare a total of 100 MMCF of natural gas at GC-1, GC-2 and GC-3, commencing on or about September 1, 1991. Flaring should be completed by September 3, 1991 but may extend longer. The flaring will be associated with maintenance activities requiring ARCO to shutdown the 60" gas transit system for inspection and repair at the CGF. Flaring is necessary to reduce the pressure differential between the 38" and 60" transit gas systems as the WOA 60,' line is brought back into service. Every effort will be taken to ensure smokeless flaring and reduce the flaring to a minimum. If you have any questions concerning this issue, please contact Alison Cooke at 564-4838. Sincergly, . Steven D. Taylo¢, M~.n~ager Environmental & R6:Cgulatory Affairs, Alaska ADC t £¢£1VED AU6 o Alaska.Oil & 6as Cons, Com~isslen Anct~Orage ARCO Alaska, Inc. ~ Post Office Bc~x ,00360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 August 16, 1991 Mr. Russell A. Douglass, Commissioner State of Alaska Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 Dear Mr. Douglass: Subject: Flaring at the Prudhoe Bay Unit Facilities to Accommodate Shutdown work at the Central Gas Facility. AAI requests approval to flare up to gOO MMSCF of gas at FS1, FS2, FS3, ~,,C'1, .GG-2, GG-3, CGF and the CCP. The event will begin on or about August 25, 1991, with an expected end date of approximately September 15, 1991. Flaring will be necessary during a planned shutdown for process modifications and maintenance work that will occur at the CGF. Piping and valves are being installed on the inlet booster compressors to convert the compressors from a series operation to a parallel operation as well as making modifications to the NGL stabilizer process. In addition, the propane refrigeration system will be deinventoried to replace leaking ball valves. The 60" gas transit lines will again be blocked in and the majority of the requested flare volume is due to the restart of this line. The estimated volume for each facility cannot accurately be determined at this time. Therefore, the requested approval is for all of the PBU separation and gas handling facilities. Gas flaring will be kept to a minimum whenever possible. All volumes will be reported on the monthly AOGCC Producer's Report of Gas Disposition according to the facility that actually did the flaring. Should you have any questions, please call me at (907) 265-6223. Sinc, grely, Operations Staff Manager Prudhoe Bay Operations GEG/hb RECEIVED AUG 1 1991 A/aska 0jr & Gas Cons. Commisslen Ancl oraga; ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany AR3B-6003-C AU~-1~-'91FR! 15:09 ID:ANO 1200 ARCO Allike, Ino, Pcmt Offioe Box Anchorage, Als. kB 99S10-05S0 Telephone gO7 276 1215 Au~.~t 16, 1991 TEL NO: 26.,5,6_4.~ ........ ( t~432 PO1 __~___ Mr, Russell A, Douglass, Commissioner State o£ Alaska Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 Dear Mr, Douglass; Subject: Flartng..at..the._Prudhoe B.a¥ Unit Facilities to Accom..m.._0date Shutdown.work at ..the_~ent.ra! GaS Facility AAI requests approval to flare up to ~0 MM$CF of gas at FSI, FS2, FS3, GCC, ~ ~, CGF and the CCP. The event will begin on or about August 25, 1991, with an expected end date of approximately September 15, 1991. Flaring will be necessary during a planned shutdown for process modifications and maintenance work that will occur at the CGF. Piping and valves are being installed on the inlet booster compressors to convert the compressors from a series operation to a parallel operation as well as making modifications to the NGL stabilizer process. In addition, the propane refrigeration system will be deinventoried to replace leaking ball valves, The 60" gas transit lines will again be blocked in and the majority of the requested flare volume is due to the restart of this line. The estimated volume for each fadlity cannot accurately be determined at this time, Therefore, the requested approval is for all of the PBU separation and gas handling facilities. Gas flaring will be kept to a minimum whenever possible. All volumes will be reported on the monthly AOGCC Producer's Report of Gas Disposition according to the facility that actually did the flaring. Should you have any questions, please call me at (907) 265-6223. Operations Staff Manager Prudhoe Bay Operations ALASKA OIL AND GAS CONSERVATION COMMISSION WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 July 30, 1991 Mr. G.' E. Griffin, Operations Staff Manager Prudhoe Bay/Lisburne Operations ARCO Alaska, Inc. P. O. Box 100360 Anchorhge, Alaska 99510-0360 Dear Mr. Griffin: Please be advised that the effective date of August 6, 1991 for Administrative Approval No. 145-A.85 is incorrect. This document gives Commission approval for the additional flare volume (300 MMcf) required during a planned turnaround of E.O.A. gas handling facilities. The cdrrect effective date for AA No. 145-A.85 is July 29, 1991. Sincerely, BP EXPLORATION July 29, 1991 Mr. Russ Douglass and Mr. Dave Johnston Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 BP Exploration (Alaska) Inc. 900 East Benson Boulevard P.O. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 GC-1, GC-2 and GC-3 FLARE REQUEST ADMINISTRATIVE APPROVAL PRUDHOE BAY UNIT WOA Dear Mr. Douglass and Mr Johnston' BP Exploration (Alaska) Inc. requests written authorization to flare a total of 100 MMCF of natural gas at GC-1, GC-2 and GC-3, commencing or about July 30, 1991. Flaring should be completed by August 10, 1991 but may extend longer. The flaring will be associated with maintenance activities requiring ARCO to shutdown the 60" gas transit system for inspection and repair of straightening vanes at the CGF and FS-3. Flaring is necessary to reduce the pressure differential between the 38" and 60" transit gas systems as the WOA 60" line is brought back into service. Every effort will be taken to ensure smokeless flaring and reduce the flaring to a minimum. If you have any queStions concerning this issue, please contact Kate Purl at 564-4043 or Alison Cooke at 564-4838. Sincerely, ~ ~( - VD~T~,~' Steven . ayor, MCna'ger Environmental & ReCulatory Affairs, Alaska KFP JUL ~ 1 t991 A~as~a.0il ,& Gas 0ohs. ~o~~s~ Anchorage ARCO Alaska, Inc.;~1' Post Office Bo. f00360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 July 25, 1991 Mr. Russell Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, AK 99501-3192 COMM 1~ RES ENG SR ENG SR ENG ENG ASS'f* ENG ASST SR GEOL GEOL ASSTf_~ FILE _. Dear Mr. Douglass: Subject: .REVISION-Flaring at the PBU-EOA F~tcilities to Accommodate Maintenance and Tie-In Work at the Central Gas Facility AAI requests approval to flare up to 300 MMSCF of gas at FS1, FS2, FS3, CGF and CCP. The flaring event will begin on or about July 29, 1991, with an expected duration of no more than ten days. Flaring will be necessary during a planned shutdown for maintenance and GHX 2 tie-in work at the CGF. The major maintenance work to be done during this shutdown is the removal of damaged straightening vanes in the CGF inlet module metering station. The two major tie-ins to be done during this period will facilitate future revamp work for the upcoming GHX 2 project. The 60" gas transit lines commissioned last fall will be shut-in during this effort. The majority of the field flaring will occur at the production facilities during the restart of these transit lines, which is expected to take place on or about August 6, 1991. Because of the dynamic nature of this start-up, exact flare volumes on a "per facility" basis cannot be accurately determined. For this reason, we are requesting approval of flaring on a "total volume to be flared" basis. Gas flaring reported on Disposition will be kept to a minimum whenever possible and all volumes will be the Alaska Oil and Gas Conservation Commission Producer's Report of Gas , form 10-422. Should you have any questions please call the Gas Plants Superintendent, George From, at (907) 659-8680. Sincerely, G. E. Griffin ~' Operations Staff Manager Prudhoe Bay Operations GEG/hb R £[VED JUL ,S Alaska Oil & Gas Cons. Commlssio~ Anchorage ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany AR3B-6003-C ARCO Alaska, Inc.~ Post Office ... 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 July 24, 1991 Mr. Russell A. Douglass, Commissioner State of Alaska Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, AK 99501-3192 RES ENG SR ENG SR ENG ENG ASST ENG ASST SR GEOL GEOL ASST GEOL ASST STAT TECH-- STAT TECH · FILE . .I Dear Mr. Douglass: Subject: Flare at the Central Gas Facility (CGF)..to Remove Straightening Vanes and GHX-2 Tie-Ins AAI requests approval to flare up to 2.5 MMSCF of gas at the CGF. The flaring event will begin on or about July 29, 1991, with an expected duration of no more than seven days. The purpose of the flaring event is to depressure the 60" inlet piping and separator to the CGF. The straightening vanes that broke loose upstream of the inlet gas meter this past February will then be removed. In addition, two piping tie-ins associated with GHX-2 will be made. Gas flaring will be kept to a minimum whenever possible and all volumes will be reported on the Alaska Oil and Gas Conservation Commission Producer's Report of Gas Disposition, form 10-422. Should you have any questions, please call me at 265-6223. Sincerely, . Operations Staff Manager Prudhoe Bay Operations RECEIV£D GEG/hb J U L 5 1991 Alaska 0ii & Gas Cons. commiss[o~ Anchorage ARCO Alaska, Inc. is a Subsidiary of AllanllcRIchfleldCornpany AR3B-6003-C .~,. Mr. Steven D. July 19, 1991 Page 2 Gas Conservation Commission form 10-422. All gas produced in excess of the 1100 Mcf/d safety flare pilot volume in each facility is subject to AS 43.55.020, and will be disposed of in a safe manner by flaring or used for lease operation. Sincerely, Russell A. Douglass Commissioner BY ORDER OF THE COMMISSION BP EXPLORATION BP Exploration (Alaska) Inc. 900 East Benson Boulevard P.O. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 July 15, 1991 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 GC-1 and GC-2 FLARE REQUEST, ADMINI,STRATIVE APPROVAL PRUDHOE BAY UNIT WOA Dear Mr. Douglass: BP Exploration (Alaska) Inc. requests written authorization to flare a total of 225 MMCF of natural gas at GC-1 and GC-2, commencing or about July 20, 1991. Flaring should be completed by July 24, 1991 but may extend longer. We anticipate flaring approximately 100 MMCF at GC-1 and 125 MMCF at GC-2. The flaring will be associated with cleaning and corrosion inhibitor injection pig runs scheduled for the gas transit header line from GC-2 to GC-3. Every effort will be taken to ensure smokeless flaring and reduce the flaring to a minimum. If you have any questions concerning this issue, please contact Alison Cooke at 564-4838. Si ncer,ely/~ ^. Steven D. Taylor, I~l'ar~ger Environmental & Regulatory Affairs, Alaska ADC ARCO Alaska, Ir{ Post Office. ,~ox 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 July 9, 1991 Mr. Russell A. Douglass, Commissioner State of Alaska Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 Dear Mr. Douglass: Subject: Flare at Flow Station 3 for Commonline Smart Pigging AAI requests approval to flare up to 2.5 MMSCF of gas at Flow Station 3 (FS 3) in the Eastern Operating Area of the Prudhoe Bay Unit. The flaring will occur in conjunction with smart pigging operations on production commonlines 6D, 6C/13B, 14D and 14B/C. There will also be smart pigging of two water injection lines from FS 3 to DS 13 and DS 14. The flaring will occur to depressure the lines and is in conjunction with installation and removal of the smart pig. The operation will begin on or about July 17, 1991 and should be completed within a three-week time frame. Every effort will be made to keep flaring to a minimum whenever possible and all volumes will be reported on the Monthly Gas Disposition Report, Alaska Oil and Gas Conservation Commission form 10-422. Please call me at 265-6223, if you have any questions. Sin~rely, .}...? ., - . Operations Staff Manager Prudhoe Bay Operations GEG/hb g£C£1v£b JUL 10 t991 Alaska Oil & ~as Cons. Commission Anchorage ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany AR3B-6003-C ARCO Alaska, Post Office Box 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 July 9, 1991 Mr. Russell A. Douglass, Commissioner State of Alaska Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 Dear Mr. Douglass: Subject: Flare at Central Compressor Plant to Determine Severity of Valve Leaks AAI requests approval to flare up to 5 MMSCF of gas at the Central Compressor Plant (CCP) located in the Eastern Operating Area of the Prudhoe Bay Unit. The flaring event will begin on or about July 12, 1991 with an expected duration of no more than 24 hours. The purpose of the test is to determine the severity of valve leaks in the facility. Gas flaring will be kept to a minimum whenever possible and all volumes will be reported on the monthly Alaska Oil and Gas Conservation Commission form 10-422. If you have any questions, please call me at 265-6223. Sincerely, G.E. Griffin~ I Operations Staff Manager Prudhoe Bay Operations GEG/hb REC£ VEb ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany AR3B-6003-C BP EXPLORATION BP Exploration (Alaska) Inc. 900 East Benson Boulevard RO. Box 196612 Anchorage, Alaska 99519-6612 (9O7) 561-5111 July 9, 1991 Mr. Russ Douglass Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 GC-3 FLARE REQUEST ADMINISTRATIVE APPROVAL PRUDHOE BAY UNIT WOA Dear Mr. Douglass' BP Exploration (BPX) requests written authorization to flare a total of 100MMCF of natural gas at GC-3, commencing or about July 11, 1991. Flaring should be completed within 48 hours but may extend longer. The flaring will be associated with maintenance to clean out and repair, as necessary, the Intermediate Pressure (IP) Gas compressor Suction Scrubber, Vessel V-336. Every effort will be taken to ensure smokeless flaring and reduce the flaring to a minimum. If you have any questions concerning this issue, please contact Alison Cooke at 564-4838 or Kate Purl at 564-4043, Sincerely, Stev er Environmental & R~gulatory Affairs, Alaska KFP RECEIVED JUL 1 0 199t Alaska 0il & Gas Cons. Commission Anchorage ARCO Alaska, Inc. ~ Post Office Box 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 May 31, 1991 Mr. Russell A. Douglass, Commissioner State of Alaska Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 Dear Mr. Douglass: Re: Flare at the CGF to Test for Flow Induced Acoustical Vibration RES -ENG I FILE I ARCO Alaska, Inc. requests approval to flare up to 350 MMSCF of gas at the Central Gas Facility. The flaring event will begin on or about June 7, 1991, with an expected duration of no more than twenty-four hours. This flare request is being submitted in order to test a modification that was made to a 60" check valve located on the discharge of the T/C 1801 booster compressor. After GHX-1 was completed and the inlet flow rates to the CGF reached 5.1 BSCFD, flow induced acoustical vibration was experienced in the facility. Investigation pinpointed the 60" check valve and an engineering consultant recommended the facility be operated below the flow rate at which the vibration occurs and the flow rate was reduced to 4.9 BSCFD. Modifications were recently made to the check valve, but in order to test the modifications, rates up to 5.4 BSCFD are planned. Gas flaring will be required to achieve this rate due to the warmer ambient temperatures and resulting lower horsepower. If these modifications prove to be successful, two additional 60" check valves are in the system that will also require modifications. Flaring during this test will be kept to a minimum whenever possible. All gas volumes flared will be included in the Producers Report(s) of Gas Disposition filed monthly with the AOGCC. This flaring event will not involve the Cooper-Rolls RB-211 turbine engine. However, to increase the starting reliability of the engines, several changes have been made. Stronger rod ends have been installed to prevent valve linkage failures. Focused discharge ignitors have been installed in the combustion section of these engines. These ignitors provide a more efficient light-off spark through the varying ambient temperature ranges. In addition, through experience, Operations has learned that optimum light- ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany AR3B-6003-G Mr. Russell Douglass May 31, 1991 Page 2 off occurs with the fuel gas adjusted for a given ambient temperature. These changes have substantially reduced the startup problems, but asymmetrical fuel nozzles have been been ordered from Cooper-Rolls that should make the starts even more reliable. With these changes and your concurrence, we will no longer report on this issue when requesting flare permits If you have any questions or desire additional information, do not hesitate to call me at 265-6223. Sincerely, · G. E. Griffin ~ ~, Operations Staff Manager Prudhoe Bay/Lisburne Operations GEG/hb ARCO Alaska, Inc.. Post Office Box 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 April 18, 1991 Mr. Russell Douglass Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 Dear Mr. Douglass: Subject: Flare at Flow Station 3 (FS 3) to Replace Meter Run AAI requests approval from the AOGCC to flare up to 3.3 MMSCF of gas at FS 3. The flaring event will begin on or about April 27, 1991 with an expected duration of twenty-four hours. FS 3 has experienced the same problem that FS 1 recently had. The straightening vanes located upstream of the venturi meter on the 30" residue gas outlet line have broken loose and have lodged in the venturi meter. The replacement requires a flow station shutdown to perform the work. The shutdown of the artificial lift compressor located at FS 3 will cause more gas flare than when the work was performed at FS1. If you have additional questions, please call me at 265-6223. Sincerely, , ¢ Operations St~ff anager Prudhoe Bay/Lisburne Operations GEG:fl ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany AR3B-6003-C BP EXPLO~N i RECEIVED APR 1 5 1991 ~.~1 & Gas Cons. Commission April 15, 1991 '" ~¢horage Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 FLARE R_EQUEST ADMINI~TRATIVE~PPROVAL PRUD.I-;I. QE BAY U_NtT Dear Mr. Smith' BP Exploration (BPX) requests written authorization to flare a total of 400 MMSCF of natural gas on or about April 20, through April 30, 1991 through Prudhoe Bay Unit Gathering Center 1. The flaring will be associated witI~ the inspection and repair of GC-1 LPS compressors waste heat recovery unit insulation. One LPS compressor will be shutdown at a time and inspected to determine the repairs needed, During the shutdown we witi need to flare for brief periods. Every effort will be taken to reduce flaring to a minimum, If you have any questions concerning this issue, please contact Alison Cooke at 564-4838. Sincerely,, SEtnev~ reonn DmZ) nTt~)~' tr'FiMe ~ ~agtoe; Affai rs, Al as ka ADC ~0 '8 IN~WNO~I6N~ XSE 6~= ~l NOW lG--gI--~8~ BP EXPLORATION BP Exploration (Alaska) Inc. ~R 1 5 1991 Gas Cons. Commissio~ Anchorage TELECOPY SATELLITE UNIT MESSAGE TO: Name: Company: Location: FROM: Name & Ext.:, Department' NOTES: PAGES TO FOLLOW (Do Not Include Cover Sheet) SECURITY CLASSIFICATION PRIVATE SECRET CONFIDENTIAL Fax # SATELLITE FAX MACHINE Confirm # AK 3417.06 (1/89) 'i: ~Z~ ',=1 ~N~WNO~I^N~ Xd~ NOW BP EXPLORATION April 15, 1991 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 BP Exploration (Alaska) Inc. 900 East Benson Boulevard RO. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 GC-1 FLARE REQUEST ADMINISTRATIVE APPROVAL P.R.UDHOE BAY UNIT. WOA Dear Mr. Smith: BP Exploration (BPX) requests written authorization to flare a total of 400 MMSCF of natural gas on or about April 20, through April 30, 1991 through Prudhoe Bay Unit Gathering Center 1. The flaring will be associated with the inspection and repair of GC-1 LPS compressors waste heat recovery unit insulation. One LPS compressor will be shutdown at a time and inspected to determine the repairs needed. During the shutdown we will need to flare for brief periods. Every effort will be taken to reduce flaring to a minimum. If you have any questions concerning this issue, please contact Alison Cooke at 564-4838. Sincerely, Steven D."Ta'ylo~', Ma~nager Environmental & RegUlatory Affairs, Alaska ADC RECEI,VED APR 1 '~"' ':' Gas Cons. c0mmiss]~ .... . ARCO Alaska, Inc.~[' Post Office Box 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 April 12, 1991 Mr. Russell A. Douglass, Commissioner State of Alaska Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 ENG ASoT E ~,f,::3 ASST GEOL A$ST GEOL ASST STAT TECH ~¥~,'-T-i--~C H FILE .. Dear Mr. Douglass: Re: (Revision) Request for Approval to Flare at the Central Compressor Plant (CCP) AA! requests AOGCC approval for flaring up to 30 MMSCF of 'gas at the CCP beginning on or about April 15, 1991, and ending approximately seven days after commencement. During the identified time frame, the CCP will be carrying out repairs to the flare system by restoring the flare system to design grade, as the flare has subsided in several places with time. Other repairs include restoring the pilot gas line to the flare "blooie" line. While the repairs are being made, all flare gas will be directed through the "blooie" line. On a normal daily basis, this flare volume is very low. Additional gas will be added to the normal flare gas to ensure the velocity is adequate so that flashback inside the "blooie" line does not occur. If flashback inside the "blooie" line occurs, sagging of the line can occur causing more damage. As stated above, the total of the additional gas should not exceed 30 MMSCF. If you have additional questions or require more information, please give me a call at 265-6223. / ~---~,,_. -~., .~,.- Operations Prudhoe Bay isburne Operations GEG/hb ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany AR3B'6003~C TEL N0:2656493 ARCO AlallKl, lnG, Po~t OflV~ Box 10051i0 AnOhorage, Al~lce ?(~lephone eO? Z?~ 1~115 April 12, 1991 Mr, Russell A, Dou$1ass, Commissioner State of Alaska Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorase, AK 99501-3192 Dear Mr. Douglass: Re: {Revision_.) Request for Approval to Flare t~.{: theCen[ral Compressor Plant_CCCP) ... AAI requests AOGCC approval for flaring up to 30 MMSCF oi gas at the CCP beginning on or about April 15, 1991, and ending approximately seven days afte/ coIItlnencement, Drtring the identified time frame, the CCP will be carrying out repairs to the flare system by restoring the flare system to design grade, as the flare has subsided in several places with time. Othei' repairs include restoring the pilot gas line to the flare '~looie" line. While the repairs are being made, all flare gas will be directed through the 'blooie" line. On a normal daily basis, this flare volume is very low. Additional gas will be added to the normal flare gas to ensure the. velocity is adequate so that flashback inside the "blooie" line does not occur. If flashback inside the "bloote" line occurs, sagging of the line can occur causing more damage. As stated above, the Wtal of the additional gas should not e×¢eed 30 MMSCF. If you have additional questions or require more information, please give me a call at 265-6223. Opetattona S~f/Mmiger Prudhoe nay/lgisburniOperations GEO/hb APR-l~-~91FRI 14:1~ ID:ANO 1200 AFICO Alii=ks, In(~..~ .......................... TE .L-_,~O ;.~.,~5~4~:~ ~699 PO1 ANOIATO IVle~.g~ ~nter ~a~l~lle P.O. Box I00~ Anchorage, N~ 99510 Gas Cons. Anchorage &PR 1 2199~~.,m~''' a) UR Only Blaok Ink 4) Use Only CIHrlDefin~l ¢oplts 5) Thank You For Your Cooperation I I ~' r . ' 11111 _L l_ lilaC" D i"7 "- III .......... II II_..ll _ i! i ii i ii ..i. i OOM~ANY · .. crrY "' I iiiii _. STATE I ·. . '" ' I II ri I ----- . .. ii I I I' ' Ill::: e .... I lll II .. m _BU.. Ii .. ' '~,V~ ~"'~ ! I II [. 11111 Ir .... -- '11 .fro .... TELEPHONE _ _ ' ....... m -- ..," NO. OF PAOE8 FOLLOWINO MAll. ..... ,L_ TI~H ___ - _ I Iff-. II . .." ..... I II I : II II ....... . MESSAGE OENTER OOMMENI~: . mill II I I il II I II ~ -.1111 XIROX co~l 'to NAME BUII. DIN~OOM COMMENTS IlllJ __ Il Machines Omnifax'G-39's (Grp 1, 2, 3) (907) 265-6470/6899/6486 ConfirmNerify (907) 265.6280 Telex 090-25122 ARCO Alaska AHG REVISION DATE: ARCO Alaska, Inc. ~ Post Office BOx 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 April 10, 1991 Mr. Russell A. Douglass, Commissioner State of Alaska Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 Dear Mr. Douglass: Re: Request for Approval to Flare at the Central Compressor Plant (CCP) AA! requests AOGCC approval for flaring up to 30 MMSCF of gas at the CCP beginning on or about April 17, 1991, and ending approximately seven days after commencement. During the identified time frame, the CCP will be carrying out repairs to the flare system by restoring the flare system to design grade, as the flare has subsided in several places with time. Other repairs include restoring the pilot gas line to the flare "blooie" line. While the repairs are being made, all flare gas will be directed through the "blooie" line. On a normal daily basis, this flare volume is very low. Additional gas will be added to the normal flare gas to ensure the velocity is adequate so that flashback inside the "blooie" line does not occur. If flashback inside the "blooie" line occurs, sagging of the line can occur causing more damage. As stated above, the total of the additional gas should not exceed 30 MMSCF. If you have additional questions or require more information, please give me a call at 265-6223. Sincerely, G. E. Griffin Operations Staff Manager Prudhoe Bay/Lisburne Operations GEG/hb RECEIVED APR 1 2 tggl Alaska 0il & Gas Cons. Commisslon Anchorage ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany AR3B-6003-C ARCO Alaska, Inc.i Post Office u^ 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 April 4, 1991 Mr. Russ Douglas Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 Dear Mr. Douglas: Subject: Flare at,Flow Station 1 to Replace Meter Run As discussed by phone today, AAI requests approval to flare up to 3 MMSCF of gas at Flow Station 1 (FS 1). The flaring event will begin on or about April 6, 1991 with an expected duration of twenty-four hours. The purpose for the request is to r~eplace the 3_0_0'_' gas meter run at the outlet of FS 1. Straightening vanes located upstream of the venturi meter b'foke loose (approximately March 29) and lodged in the venturi meter. The replacement requires a flow station shutdown to perform the work. While the flow station is down, we will also be changing out some divert valves at Drillsite 1 and remove a Cosasco corrosion coupon pulling tool that is stuck on Commonline 12C. The estimated flaring volumes for all these events should be no more than 3 MMSCF. If you have additional questions, please call me at 265-6223. Sincerely, G. E. Griffin I (! Operations St~.ff Manager Prudhoe Bay/Lisburne Operations GEG/hb R[CEIVED APR - [~ ]991 Alaska 0ii & Gas Cons, Caamissio~ Anchorage ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany AR3B-6003-C ARCO Alaska, Inci' Post officeb,.,.<' 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 March 8, 1991 Mr. Russ Douglas Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 Dear Mr. Douglas: ~'-~' ASST[ STAT TECHI .. ,:-. ~ /'f .¢ ~,,t, ! Subject: .Bequest for Approval of Gas Flaring Central Comoressor Plant (CCP) by ARCO Alaska. Inc. fAAII Operator, .Prudhoe...Bay Unit-Eastern Operating Area fPBU-EOA) As discussed today, AAI requests a modification to the flare volume of 1.5 MMSCF requested in our letter dated March 6, 1991 to a volume of 3.0 MMSCF. The test is being performed to substantiate temperatures in the flare header when one of the tandem compressors is depressured. The temperatures obtained are compared to the computer model that Engineering uses to predict temperatures under different scenarios of shutdown and depressuring. The temperatures were obtained previously but differed substantially from the model. Our ultimate goal is to ensure that we do not subject the piping to temperatures lower than what is allowed under the design code. At this time, we are not certain of that until we can repeat the temperatures previously obtained. Please call 265-6223, if you have any questions. Sin,~rely, //~ ... O. E. Oriffi Operations Staff IVIAnager ~rudhoe Bay/Lisbume Operations GEG/hb · ,?!~,laska ~ 6as Cons. r.,on~niss~o~ ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany AR3B-6003-C ARCO Alaska, Inc. Post Office ~^ ,00360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 March 6, 1991 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 Dear Mr Smith: Subject: Request for Approval of Gas Flaring Central Compressor Plant (CCP) by ARCO Alaska, Inc. (AAI) Operator, Prudhoe Bay Unit-Eastern Operating Area (PBU-EOA) AA! requests AOGCC approval for flaring up to 1.5MMscfD of gas at the CCP beginning on or about March 11, 1991, and ending approximately seven days after commencement. The purpose of the test is to substantiate temperature data in the flare header previously obtained in association with the depressuring of one of the new,,, tandem turbine compressors (T/C 1878) which was part of the GHX-1 expansion. If you have additional questions or information, give me a call at 265-6223. S ~~,ely, --, _ Operations Staff Manager Prudhoe Bay/Lisburne Operations GEG/hb RECEIVED MAR - '/1991 Alasl~a 011 & Gas Cons. Commission Anchorage ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany AR3B-6003-C ARCO Alaska, Ino. ii ii i_ i INSTRUCTIONS: 1) Number Pagfl 2) Remove Staplee 3) Ute Only Blaok Ink 4) Uae Only Clflr/Deflna<l Coplfl $) Thank You For Your Cooperation ANO/ATO Message Center Fa;simile Tranaml.lon P.O. Box Anchorage, Alaska ~$10 i iii i ..... II . / I IIII UIL. I II II ..I II -- _ ..... IIIIII - Jllll '11 I _. Ic)*'rE / '"-~.' .... __. I __ .I I _ CiTY 8TAI'E ' - - III .... _-- . I ..... · Hill. II VESII~# . II I ............ illl .Il.Ill IIIL. III I II 7__., ' .......... MESSAQE CENTER COMMENT~: XEFIOX ~OPII!-I TO -i NAME _. · .. '11 .L I III BUILDING/FtOOM FROM ~, e ,~ ¢ BLDCt,-RM, TELEPHONE COMMENTS NO. OIIr IIIAOE$ IIOi. LOWINO C;OVBR: MAIL ....... . .__ TRA,g'I-; Omnlfax'O*39'$ (Grp 1, 2, 3) (907) 265-6470/6899/6486 Confirm/Verify (907) Telex 090.25122 ARCO Alaska AHG REVISION DATE: ARCO Alaska, Inc. { Post OfficeB'O^ 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 March 11, 1991 Mr. Russ Douglas Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 Dear Mr. Douglas: Subject: Flare at Flow Station 3 to test STV Flare AAI requests AOGCC approval to flare up to 6 MMSCF of gas at Flow Station 3. The flaring will take place in two separate events. The first event will begin on or about March 14, 1991, with an expected duration of two hours. The second event will begin on or about March 21, 1991 and the expected duration will also be about two hours. The volume of gas flared is expected to be 2 MMSCF and 4 MMSCF, respectively. Two modifications have recently been made to the STV flare to enhance the smokeless burning capability of the flare. These modifications included a new smokeless flare tip and changes to the liquids drain system. The purpose of the flaring will be to test the STV flare to ensure the modifications were effective in reducing the black smoke emissions. If you have additional questions, please call me at 265-6223. Sin.c, erely, ....., -- Operations Staff Manager Prudhoe Bay/Lisburne Operations GEG/hb 1,99I · '. iii 8as Cons. Commiss,~o~... AnChorag,, ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany AR3B-6003-C ARCO Alaska, Inc. ~ Post Office Box 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 January 9, 1991 RECEIVED JAN 10 1991 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive A. nchorage, AK 99501-3192 Dear Mr. Smith: ~OMM -T. ES E'NG ,[..]~ '- ~R ENa ... ENG ASST l ~-NG ^S .S_T_~J GEOL A~$'T't ...... j STA-----T-T_E_G_' H ). J Subject: Request for Approval of Gas Flaring - Central Gas Facili _ty (CGF) Prudhoe Bay Unit-Eastern Operating Area (PBU-EOA) As we discussed, ARCO Alaska, Inc. (AAI), Operator of the PBU-EOA, requests AOGCC approval for flaring up to 100 MMscf of gas at the CGF beginning on or about January 21, 1991 and ending approximately seven days after commencement of work to perform pressure relief valve testing at this facility. During testing of the CGF flare system in 1989, strain and vibration levels occurring in selected pressure relief valving were identified as an item of concern for long-term flare system operation. To further identify and correct this situation, AA! proposes conducting up to eight series of tests of alternate designs of pressure relief valves in plant outlet service. Since these valves are in outlet service and since the strain/vibration difficulties are present only under operating conditions, AAI requests AOGCC approval for gas flaring as stated above. Gas flaring will be kept to a minimum whenever possible. All gas volumes flared will be included in the Producer's Report(s) of Gas Disposition filed monthly with the AOGCC. In the AOGCC's September 13, 1990 correspondence to AA! on CGF flaring, it was requested that information regarding our progress in resolving Cooper-Rolls turbine starting problems be included in future CGF flare requests. In AAI's September 26, 1990 correspondence to the AOGCC regarding CCP and CGF flaring, AAI stated that parts had been ordered from Cooper-Rolls which should improve the starting abilities of these units. At this time, these parts (asymmetrical burners and other ancillary equipment) ARCO Alaska, Inc. is a Subsidiary of AtianticRichlieldCompany Mr. Lonnie Smith January 9, 1991 Page 2 remain on order with Cooper-Rolls. AAI is continuing to pursue expedited delivery of these parts from Cooper-Rolls; however, our efforts to date have not been as successful as originally envisioned. AAI will continue providing the AOGCC with information on this matter until it is resolved. If you have any questions or desire additional information, do not hesitate to call me at 265-6136. Sincerely, M. A. Major Operations Representative Prudhoe Bay/Lisburne Operations MAM/hb BP EXPLORATION November 5, 1990 Ala~ldt NOV - 6 ]91t0 .Ott . as con .. Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 GO-3 FLARE REQUEST ADMINISTRATIVE APPROVAL PRUDH©E BAY UNIT WOA BP Exploration (Alaska) Inc. 900 East Benson Boulevard RO. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 Dear Mr. Smith: BP Exploration (BPX) requests written authorization to flare a total of 700 MMCF of natural gas at GC-3, on or about November 7 to November 20, 1990. The flaring will be associated with the installation of a new burner on one of the two TEG reboilers located at GC-3. One reboiler will be in service during this installation, and as an operational necessity, some flaring may be required for brief periods each day due to upsets. Every effort will be taken to reduce the flaring to a minimum. If you have any questions concerning this issue, please contact Kate Purl at 564-4O43. Sincerely, Affairs, Alaska KFP BP EXPLORATION October 22,1990 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 BP Exploration (Alaska) 900 East Benson Boulevard..) RO. Box 196612 .-, Anchorage, Alaska (907) 561-5111 ,,6.0-1 & ,2, FLARE REQUEST ADMINISTRATIVI~ APPROVAL PRUDHOE BAY,,UNIT,WOA Dear Mr. Smith' BP Exploration (BPX) requests written authorization to flare a total of 750 MMCF of natural gas, with approximately 400 MMCF at GC-2 and 350 MMCF at GC-1, on or about October 25 to October 31, 1990. The flaring at GC-1 will include the 100 MMCF previously requested on October 15, 1990 as the work will be done simultaneously. The flaring will be associated with the smart-pigging of the 34" gas transit line from GC-2 to GC-3 for corrosion survey work. Gas rates must be reduced to 185 MMCF to allow for the appropriate pig speed, which will require flaring. If you have any questions concerning this issue, please contact Kate Purl at 564-4043. Sincerely, MON ~PX ENVIRONMENT P.~2 BP EXPLORATION October 22,1990 BP Exl31erNion (Alaska) Inc. ~o0 East Benson Boulev~rcl ~. ~x 198612 ~Orage, Aia~ 99519-6812 Mr, Lonnie Smith Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 ..GC-._._I & 2 FLARE REQUEST ADMINIS_TRATIVE APPROVA_L _PRUDHOE BAY UNiT WOA Dear Mr. Smith: BP Exploration (BPX) requests written authorizat[on to flare a total of 750 MMCF of naturat gas, with approximately 400 MMCF at GC-2 and 350 MMCF at GC-1, on or about October 25 to October 31, 1990. The flaring at GC-1 will include the 100 MMCF previously requested on October 15, 1990 as the work will be done simultaneously. The flaring will be associated with the smart-pigging of the 34" gas transit tine from Ge-2 to GC-3 for corrosion survey work. Gas rates must be reduced to 185 MMCF to allow for the appropriate pig speed, which will require flaring, If you have any questions concerning this issue, please contact Kate Pud at 564-4043. Sincerely, Steven O. Taylo'~:i"-~anage~ Environmental & Regulatory Affairs, Alaska KFP 0CT--22--90 MON 1 I : 1 ? ;BPX BP EXPLORATION BP Exploration (Alaska)Inc. PO Box 196612 Anchorage, Aiaska 99519,-6612 ENVIRONMENT TELECOPY SATELLITE UNIT MESSAGE # P.O1 TO: Name: Company: Location' FROM: Name & Ext.: ,_~A_-7~ ?u ~ Department: ~ ~j ? ~ ~o,,J ~u .'7'. NOTES: PAGES TO FOLLOW (Do Not Include Cover Sheet) SECURITY CLASSIFICATION PRIVATE SECRET CONFIDENTIAL. ., ',..;.;..;'. '",'_,;,'. -_;;~,~, ,,,'..j.,; -:: j'. ,,; '"., .,%~,~./.'.;?,.., ~;',".':;'~'.:'."~.';,'"" .:- · ..-.,,;.,., SATELLITE FAX MACHINE Fax # c~"7(~ ")5~' ~ Confirm # BP EXPLORATI,ON October 15, 1990 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 (~0-1 FLARE REQUEST ADMINISTRATIVE APPROVAL PRUDHOE BAY UNIT WOA -. ,. BP Exploration (Alaska) Inc. .;','~' /' ~ ~ 900 East Benson Boulevard '~ ,,'~ ~' i'f? ~,-~. RO. Box 196612 "~'~ ' ~'~" ~' ~,""}Anchorage, Alas~ 99519-6612 .... r- ~ ~ (907) 561-5111 ,~ ~ ,., · / ,,,'. , .... :.:, ~ ;.% ". ~'""' Dear Mr. Smith: BP Exploration (BPX) requests written authorization to flare a total of 1-00- MMSCF of natural gas on or about October 25 to October 31, 1990 through Prudhoe Bay Unit Gathering Center 1. The flaring will be associated with the shutdown of one of two 24" gas export lines at GC-1 in order to replace a damaged gas sample quill If you have any questions concerning this issue, please contact Kate Purl at 564-4043, Sincerely, EStne~reonn Dm~aYl)~r'RMe;~aagt~):y Affairs, Alaska KFP TELECOPY NO: (907) 276-7542 October 12, 1990 Steven D. Taylor BP Exploration (Alaska) P. O. Box 196612 Anchorage, AK 99519-6612 Dear Mr. Taylor Thank you for your written follow-up to the flaring event occur- ring at GC-1. We understand that an unplanned additional volume of 14 ~MCF was flared because of a problem with the K-108 com- pressor bearing dam. This letter will reconfirm my verbal instructions to Erika Denman on October 8 that the Commission considers this flaring event to be an operational necessity, and allowable under the provision of Conservation Order 145A. The Commission notes that excess flaring also occurred at GC-1 on August 1 and. 2. That event was caused by a leak. in 'the system, which required a second depressurization and restart. The latest event at GC-!, which was caused by equipment problems, was not immediately detected and reported to us because of a flare-assist gas meter calibration error. The Commission would appreciate knowing what steps have been taken.by BPX to remedy these prob- lc'ms and to minimize future reoccurrences. Sincerely, .... " ~ ~ ..... ~' " · ~' ?'~','i ..... ~i~ ............. '"Lonnie C. Commission dlf:DWJ: 1.LCS. 45 Telecopy No. (907) 276-7542 September 28, 1990 Steven D. Taylor, Manager Environmental & Regulatory Affairs, Alaska BP Exploration (Alaska), Inc. P. O. Box 196612 Anchorage, AK 99519-6612 Re: Excess gas flaring, Prudhoe Bay Unit, Western Operating Area. Dear Mr Taylor: On July 12, 1990 gas flaring from facilities in the Western Operating Area (WOA) exceeded the volume permitted by A~ntnistra- tire Approval 145-A. 57. The cause of the'additional~ flaring was due to equipment malfunctions during startup flaring. The additional flaring ts considered an operational necessity and is permitted under Conservation Order 145-A, Rule 3. Your letter of S~eptember 24, 1990 explains the 'incident and hopefully your new policies will make reporting further incidents more timely. Sincerely, Lonnie C. Smith Commissioner dlf/A.RAD. 96 BP EXPLORATION September 24 1990 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 BP Exploration (Alaska) Inc. 900 East Benson Boulevar...,,~~ RO. Box 196612 " Anchorage, Alaska 9951~.~6/12 (907) 561-5111 :'% .r~" C 0 M M ~ { ........................... ~E;';G ASST ' SR GEOL .... _ ..... ":' "F,",.'T TECH GC-1 FLARE-ALLOWANCE PRUDHOE BAY UNIT WOA Dear Mr. Smith: On July 12, 1990 BP Exploration, Alaska Inc. (BPX) received approval (Administrative Approval No. 145-A.57) from the Alaska Oil and Gas Conservation Commission (AOGCC) to flare 40 MMCF of gas over and above the designated safety flare pilot of Gathering Centers 1, 2 and 3. Flaring was to occur during turnaround work at GC-1. Due to a breakdown in internal communications, BPX neglected to notify AOGCC that approximately 73 MMCF were flared on August 1 and 2, 1990 over a period of 15 hrs 13 minutes. BPX believed that an adequate system was in place to ensure that AOGCC would be notified promptly should flaring exceed the permitted volume. The Environment Department developed and distributed a manual to inform field personnel for procedures to be used when flaring was necessary. In addition, BPX had also conducted training sessions this summer addressing this issue. Obviously this was not enough and BPX greatly regrets our failure to comply with the flare notification requirements. We believe there were some extenuating circumstances which contributed to the problem. There were two separate equipment malfunctions which caused the flare to be used. Individually, each flaring event would not have exceeded the 12 hour limitation. However, because the time records for flaring were inadvertently combined, it is not possible to report the exact times for each individual flaring event. R E 6 E~V SEP 2 5 1990 Alaska Oil & Gas Cons. OomCtss'tot~ Anchorage flaring were inadvertently combined, it is not possible to report the exact times for each individual flaring event. The first flaring event occurred when the facility was being restarted. Pressure had been increased when a leak was discovered which required a second depressurization. After repair of the leak, the plant was repressurized for a second time which required burning more gas than predicted. Some time after repressurization, there was emergency venting because of problems with keeping the TEG system lit. The TEG would not rise to the required temperature. This led to the second flaring event. As noted above, individual time records for each flaring event were inadvertently combined so it is now impossible to accurately report the duration of the indivudual flaring time periods. BPX is taking immediate steps to make certain that a similar situation will not occur again. A training session for Anchorage and North Slope Facility Personnel will be held in the near future. It will address all issues of regulatory compliance and provide explicit procedures for notification. If you have any questions concerning this issue, please contact Kate Purl at 564-4043. Sincerely, SDT/KFP Affairs, Alaska RECEIVED S EP 2 § 1990 Alaska 0il & Gas Cons. t;or[~missio~ Anchorage PBU Production Manager PBU Facility Superintendent GC-1 Facility Supervisor Volume Accounting-B. Wilkes Tax-Bob Reynolds Business Coordinator, G. Campbell ARCO-Mark Major, PBU/Lisburne Operations David Pritchard Jack Litmer Janet Platt Erika Denman Kate Purl File: PC-PBU/AQ/Corresp. R[C[IV[D S F_.P 2 5 1990 Alaska 0il & ~as Cons. Commi: Anchorage BP EXPLORATION September 19 1990 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 ENDICOTT FLARE REQUEST ADMINISTRATIVE APPROVAL DUO, K ISLAND UNIT BP Exploration (Alaska) Inc. 900 East Benson Boulevard Re. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 Dear Mr. Smith' BP Exploration (BPX) requests written authorization to flare a total of 50 MMSCF of natural gas on or about September 21 to October 1, 1990. The flaring will be associated with the shutdown, depressurization and startup for plant maintenance activities. To minimize flaring, BPX will attempt to coordinate with scheduled/unscheduled Alyeska Pipeline Service Company blowdown; high gas/oil ratio (GOR) wells will be shut-in last and put on production first. If you have any questions concerning this issue, please contact Kate Purl at 564-4043. Sincerely, Environmental & Regulatory la a KFP BP EXPLORATION BP Exploration (Alaska) Inc. 900 East Benson Boulevard RO. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 September 17, 1990 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 .G ,C-1 & 2 FLARE REQUEST ADMINISTRATIVE APPROVAL ,PRUDHOE BAY UNIT WOA Dear Mr. Smith: BP Exploration (BPX) requests written authorization to flare a total of 20 MMSCF of natural gas on or about October 1 to October 8, 1990 through Prudhoe Bay Unit Gathering Centers 1 and 2. The flaring will be associated with the shutdown of both IP and LP compressors to install annubar-type flowmeters on the IP discharge piping at both GC-1 and GC-2. The flowmeters are necessary for control of the IP recycle superheat system. If you have any questions concerning this issue, please contact Kate Purl at 564-4O43. Sincerely, KFP ARCO Alaska, Inc. 't Post Office Box 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 September 14, 1990 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 Dear Mr. Smith' RE: Proposed Gas Flaring Flow Stations 1, 2 and 3, Central Compressor Plant and Gas Facility (FS 1, 2 and 3, CCP and CGF) Prudhoe Bay Unit-Eastern Operating Area (PBU-EOA) Central As we discussed last week, ARCO Alaska, Inc., Operator of the PBU-EOA, requests AOGCC approval for flaring up to a total of 750 MMCF at FS 1, 2, 3, CCP, and CGF beginning on or about September 22, 1990, and ending on or about October 6, 1990, to start up the sixty-inch gas handling expansion (GHX) transit piping in the PBU-EOA. As you are aware, the GHX project currently underway will increase the field gas handling capabilities from a nominal 4.0 BCF/day to a nominal 5.1 BCF/day amount. Startup of the aforementioned sixty-inch piping is an integral part of the overall GHX project. Because of the dynamic nature of this startup, exact flare volumes on a "per facility" basis cannot be accurately determined. For this reason, we are requesting AOGCC approval of flaring on a "total volume to be flared" basis. Due to the potential for unforeseen delays regarding sixty-inch piping startup, we request that AOGCC approval of flaring, if granted, be structured to accommodate such delays. Gas flaring will be kept to a minimum whenever possible. All gas volumes flared will be included in the Producer's Report(s) of Gas Disposition filed monthly with the If you have any questions or desire additional information, do not hesitate to call me at (907) 265-6136. Sincerely, ....... ,;,, /' ,,,.../" . ,/ M. A. Major/' Operations Representative Prudhoe Bay/Lisburne Operations MAM/hb ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompan ' September 13, 1990 Telecopy No. (907) 276-7542 M A Major Operations Representative Prudhoe Bay/Lisburne Oprns ARCO Alaska Inc P 0 Box 100360 Anchorage, AK 99510-0360 Re: Excess gas flaring, Central Gas Facility, Prudhoe Bay Unit, Eastern Operating Area. Dear Mr Major: On September 11, 1990 gas flaring at the Central Gas Facility (CGF) exceeded the volume permitted by Administrative Approval 145-A.61. The cause of the additional flaring was due to dii'ficulties in restarting the turbines for the miscible injection (MI) compressors. Although the additional flaring is considered an operational necessity and is permitted under Conservation Order 145-A, Rule 3, the Commission has some concerns regarding the incident. Your letter of September 11, 1990 indicates that startup difficulties experienced with the MI compressor turbines has happened before. It is the Commission's view, therefore, that this latest incident could have been foreseen. With this in mind, further gas flaring applications for the CGF should include additional information regarding the status of the MI compressor startup problems until such time as the problem is deemed solved. The Conm~ission appreciates your timely notification of the flaring incident. Sincerely, David W J oh~ns~n Commis s iork~ jo/A.RAD. 96 ARCO Alaska, Inc. B~c Post Office .. 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 September 11, 1990 Mr. David Johnston Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, AK 99501-3192 Dear Mr. Johnston' RE: Central Gas Facility (CGF) Flaring Prudhoe Bay Unit - Eastern Operating Area (PBU-EOA) !, Confirming our phone conversation at 8:00 a.m. today, attached is a summary of events covering flaring at the subject facility in September, 1990, during shutdown and startup activities, As stated in our discussion, the exceedance of the flare volume authorized by AOGCC administrative approval 145-A.61 was due to miscible injection compressor startup difficulties during plant startup. These MI compressors are driven by Cooper-Rolls Turbine units. During MI compressor startup, these turbines failed to light off, resulting in gas flaring of volumes greater than planned. Incidentally, this is not the first time that we have experienced starting difficulties with these turbines. We are continuing our efforts to resolve this difficulty with the vendor of these turbines. If you have any questions or desire additional information, do not hesitate to call me at (907) 265-6136. Sincerely, _ M. A. Major Operations Representative Prudhoe Bay/Lisburne Operations MAM/hb Attachment SE P 1 1. 990 Alaska 0il ~ Gas Cons. ARCO Alaska, Inc. is a Subsidiary of A~lanticRichfieldCornpany CGF SHUTDOWN / STARTUP FLARING SUMMARY SEPTEMBER, 1990 Date/Time 9/2 1800 hrs through 9/3 2400 hrs 9/4 0001 hrs through 9/8 2400 hrs 9/9 0001 hrs through 9/9 2400 hrs 9/10 0001 hrs through 9/10 2400 hrs 9/11 0001 hrs through 9/11 0700 hrs 9/11 0700 hrs through 9/11 0800 hrs Event Plant shutdown - Operations Shutdown - Maintenance and GHX work Begin plant startup - Operations Continue plant pressurization and startup. Continue plant startup. Flaring gas due to lack of MI compressors. Plant startup completed - AOGCC notified of flare exceedance situation. Volume Flared (MCF) 19,819 210 5,542 61,360 Comments No flaring above normal pilot and assist volumes. Routine startup through 2300 hours. Attempted MI compressor startups at 2300 hours without success. Neither MI compressor would light off. Reducing inlet gas rates while continuing to attempt MI compressor startup. MI compressor on line and loaded. Flaring discontinued. Total flared volume for CGF shutdown and startup. AOGCC authorized flare volume (145-A.61) Excess flare volume 86,931 MCF 3O,OOO MCF 56,931 MCF BP EXPLORATION September 7, 1990 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 BP Exploration (Alaska) Inc,.-~' : 0OMM 900 East Benson Boulev~.rd P.O. Box 196612 i " RES ENG SR ENG SR ENG ENG ASST Anchorage, Alaska 99519"6612 (907) 561-5111 ) ,.f ¢~ GC-1.2,&3 FLARE REQUEST ADMINISTRATIVE APPROVAL PRUDHOE BAY UNIT WOA Dear Mr. Smith' BP Exploration (BPX) requests written authorization to flare a total of 500 MMSCF of natural gas on or about September 22 to October 6, 1990 through Prudhoe Bay Unit Gathering Centers 1, 2 and 3. The flaring will be associated with start-up of the new GHX-1 60-inch gas transit system. This system will increase the facility's gas-handling capacity significantly. Flaring is necessary to reduce the pressure differential between the new and existing transit systems as the new line is brought into service. If you have any questions concerning this issue, please contact Kate Purl at 564-4O43. Sincerely, Steven D. TaylOr, M~na~er Environmental & ReCulatory Affairs, Alaska KFP RECEIVED SE P 11 1990 Alaska Oil & Gas Cons. Commiss'to[t Anchorage ARCO Alaska, Inc. ~,'~ Post Office BOx 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 September 7, 1990 I_E_FG-ASST ? j I :~ ~-[~:~ s ST }-' Mr. Lonnie Smith Alaska Oil and Gas Oonse~ation Commission (AOGCC) ~T~~C'H ~ 3001 Porcupine Drive ~S~-TECH~-' Anchorage, AK 99501-3192 Dear Mr. Smith: Re: Proposed Gas Flaring Flow Station No. I (FS 1) Prudhoe Bay Unit-Eastern Operating Area (PBU-EOA) As we discussed today, ARCO Alaska, Inc., Operator of the PBU-EOA, requests AOGCC approval for flaring up to 15,000 MCF of gas at FS 1 beginning on or about September 15, 1990, and ending on or about September 28, 1990, to shut down and restart this facility to perform gas handling expansion (GHX) tie-in activities and other maintenance operations. As you know, the PBU is in the process of expanding the field gas handling capabilities. The GHX project currently underway will increase the PBU gas handling rates from a nominal 4.0 BCF/day to a nominal 5.1 BCF/day amount. In order to achieve this increase, it is necessary to tie in new gas piping at FS 1, as well as at other PBU facilities. Because of the nature of these tie-ins, a full facility shutdown of FS 1 is required. Hence, AOGCC approval for flaring is requested. Although this work is scheduled to occur during the timeframe stated above, we request that the approval of flaring, if granted, be structured to allow for unforeseen circumstances which could potentially delay shutdown or restart of FS 1. Gas flaring will be kept to a minimum whenever possible. All gas volumes flared will be included in the Producer's Report(s)of Gas Disposition filed monthly with the If you have any questions, do not hesitate to call me at (907) 265-6136. Sincerely, M. A. Major Operations Representative Rrudhoe Bay/Lisburne Operations MAM/hb RECEIVED SEP 1 o ]990 .Oil & Gas Cons, 6 mmissi', ' Ar~chora,~ ' ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCon~pan::/ BP EXPLORATION September 4, 1990 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 BP Exploration (Alaska) Inc. 900 East Benson Boulevard RO. Box 196612 '~'MM Anchorage, Alaska 99519-66120OMM (907) 561-5111 RES ENG SR ENG SR ENG ENG ASST ENG ASST SR G E 0 ~_~ GEOL ~'~'T~-- ~'I~AT TECFi-i- .... GC-2 FLARE REQUEST ADMINISTRATIVE APPROVAL PRUDHOE BAY' UNIT WOA Dear Mr. Smith: BP Exploration (BPX) requests written authorization to flare a total of 1.5 MMSCF of natural gas approximately September 5 to September 10, 1990 through Prudhoe Bay Unit Gathering Center 2. The flaring will be associated with depressuring the Miscible Injection Gas line in order to perform maintenance on a valve. If you have any questions concerning this issue, please contact Kate Purl at 564-4043. Sincerely, steven D. Taylor, Manager Environmental & Regulatory Affairs, Alaska KFP RECEIVED S E P - 5 1990 Alaska Oil & Gas Cons. Gommission ~nchorage Teiecopy No. (907) 276-7542 August 28, 1990 Mark A Major Oprns Representative Prudhoe Bay/Lisburne Oprns ARCO Alaska Inc P 0 Box 100360 Anchorage, AK 99510-0360 Dear Mr Major: Enclosed please find a revised Administrative Approval No. 145-A.61. The beginning flare date in the original approval was incorrect. We apologize for the inconvenience, and request that the original and all copies be replaced with the revised, approval. Sincerely, Commi s s ion jo/3.AA145 encl Post Office Box 100360 Anchorage, Alaska 99510-0360 '~ ~1~ Telephone 907 276 1215 August 15, 1990 Mr. David Johnston '-,,'~ Alaska Oil and Gas Conse~ation Commission (AOGOO) 3001 Porcupine Drive -:":'-- Anchorage, AK 99501-3192 Dear Mr. Johnston' ~.~~, Fie: Proposed Gas Flaring Central Gas Facility (CGF) Prudhoe Bay Unit-Eastern Operating Area (PBU-EOA) As we discussed today, ARCO Alaska, Inc., Operator of the PBU-EOA, requests AOGCC approval for flaring up to 30,000 MCF of gas at the CGF beginning on or about September 2, 1990, and ending on or about September 16, 1990, to shut down and restart this facility to perform gas handling expansion (GHX) tie-in activities and other maintenance activities. As you know, the PBU is in the process of expanding the field gas handling capabilities. The GHX project currently underway will increase the PBU gas handling rates from a nominal 4.0 BCF/day to a nominal 5.1 BCF/day amount. In order to achieve this increase, it is necessary to tie in new gas piping at the CGF, as well as at other PBU facilities. Because of the nature of these tie-ins, a full facility shutdown of the CGF is required. Hence, AOG¢C approval for flaring is requested. Although this work is scheduled to occur during the timeframe stated above, we request that the approval of flaring, if granted, be structured to allow for unforeseen circumstances which could potentially delay shutdown or restart of the CGF. Gas flaring will be kept to a minimum whenever possible. All gas volumes flared will be included in the producer's reports(s) of gas disposition filed monthly with the If you have any questions, do not hesitate to call me at (907) 265-6136. Sincerely, M. A. Major Operations Representative P. rudhoe Bay/Lisburne Operations MAM/hb ARCO Alaska, Inc. is a Subsidiary of AdanticRichiieldCompa~ ' ARCO Alaska, Inc. ~,, Post Office lB,C{ 00360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 July 16,1990 'Mr. C. V. "Chat" Chatterton Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 Dear Mr. Chatterton: Subject: Planned Gas Flaring Flow Station #2 (FS 2) Prudhoe Bay Unit- Eastern Operating Area (PBU-EOA) As we discussed Friday, this letter is written confirmation of the AOGCC's approval to flare up to 10 MMSCF of gas at FS 2 beginning in July 1990 and ending on or about December 31, 1990 to perform smart pigging activities and repair operations, as needed, on four EOA commonlines. As .you are aware, we have been experiencing some internal and external corrosion on a number of the EOA commonlines which transport produced fluids from the various drillsites to the flow stations. In order to obtain more data concerning this corrosion, we plan to smart pig commonlines 3C, 9A, 160, and 16D during the next 5 to 6 months. All of these commonlines are located in the FS 2 area. Information derived from other corrosion inspection techniques (corrosion coupons, radiographic testing, etc.) currently indicates that repairs to these lines, in selected areas, will be required to at least 3 (and, possibly all 4) of ~hese commonlines. Smart pigging of these lines is expected to confirm the extent of corrosion in these selected areas as well as provide assistance on determining the appropriate repair technique(s) for these lines. We estimate that up to 2.5 MMSCF RI ¢EIVE, D ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany Mr. C. V. "Chat" Chatterton July 16, 1990 Page Two of sweep gas will be required to prepare each of these lines for the smart pigging and repair activities cited herein. For these reasons, AOGCC's approval of flaring was requested. The subject activity was discussed with you by ARCO's Daniel Cavin on June 29, 1990 via telephone. In that conversation, you verbally approved proceeding with the subject activity with the understanding that correspondence would be submitted to document this situation. All gas flaring will be kept to a minimum whenever possible. Gas volumes flared will be included in the Producer's Report(s) of Gas Disposition filed monthly with the AOGCC. If you have any questions or desire additional information, do not hesitate to call me at (907) 265-6136. Sincerely, Mark A. Major Operations Representative Prudhoe Bay/Lisburne Operations MAM:fl RE'CEIYED J[JL ~ ~ 1990 Oil & Gas C0~s. commiss/0.~ BP EXPLORATION BP Exploration (Alaska) Inc. 900 East Benson Boulevard RO. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 July 11, 1990 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 GC.-1,2,&3 FLARE REQUEST ADMINISTRATIVE APPROVAL ,PRUDHOE BAY UNIT WOA Dear Mr. Smith' BP Exploration (BPX) requests written authorization to flare a total of 40 MMSCF of natural gas approximately July 17, through August 7, 1990 through Prudhoe Bay Unit Gathering Centers 1,2 and 3. The flaring will be associated with shutdown and depressuring of GC-1 for turnaround work, and then restart of the facility. Minor flaring will also occur at GC-2 and 3 as result of the GC-1 activities. If you have any questions concerning this issue, please contact Pam Pope at 564-5499. Sincerely, S_~v.~ Dn .Taylor, Manager ~'nvi~onmental & Regulatory Affairs, Alaska RECEIVED ,JUL ]. 2 990 A~aska Oil & Gas Cons. JU~--11--9~ WEB 1~ :~' ~PX ENVIRONMENT P.02 BP EXPLOR~ July 11, 1990 Mr. Lonnle Smith Alaska Oil and Gas Conservation Commisaion 3001 Porcupine Drive Anchorage, Alaska 99501 Gq.-.1.2._~,3 FLARE REQUEST AD,[VliNISTRATIVE App~AiL PRUDHOE BAy UNIT. WDA Dear Mr. Smith: BP Exploration (BPX) requests written authorization to flare a total of 40 MMSCF of natural gas approximately July 17, through August 7, 1990 throug, h Prudhoe Bay Unit Gathering Centers 1, 2 and 3. The flaring will be assoc=~ated with shutdown and depressuring of CC-1 for turnaround work, and then restart of the facility, Minor flaring will also occur at CC-2 and 3 as result of the aC-1 activities. if you have any questions concerning this issue, please contact Para Pope at 564-5499. Sincerely, Gas Cons. Commission ~chomge r" BP EXPLORATION June 25, 1990 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 BP Exploration (Alaska) Inc. 900 East Benson Boulevard RO. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 GO-1.2.&3 FLARE. REQU.EST ADMINISTRATIVE APPROVAL PRUDHOE BAY UNIT WOA Dear Mr. Smith' BP Exploration (BPX) requests written authorization to flare a total of 40 MMSCF of natural gas approximately August 26, through September 13, 1990 through Prudhoe Bay Unit Gathering Centers 1, 2 and 3. The flaring will be associated with a black start test to be conducted at GC-3, and GC-3 shutdown and depressuring for turnaround work. Minor flaring at GC-1 and 2 is anticipated due to the planned activities for GC-3. If you have any questions concerning this issue, please contact Pam Pope at 564-5499. Sincerely, SEtne~reonn Dm;nTt~aYll~r~Me;~agt~)~ Affairs, Alaska PRP '": .:s',i,:";::~ .Oil.& ~as Cons. Cem~;ffss;,~,x:i .~ AnchoraFa ARCO Alaska, In(]. Post Office' ~ux 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 June 5, 1990 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission .3001 Porcupine Drive Anchorage, Alaska 99501-3192 ,_~S ENG ~_~ i SR ENG Proposed Gas Flaring Flow Station #2 (FS 2) and Flow Station #3 (FS 3) Prudhoe Bay Unit - Eastern Operating Area (PBU-EOA) Dear Mr. Smith: As we discussed today, ARCO Alaska, Inc., operator of the PBU-EOA, requests AOGCC approval for flaring up to 2,000 MCF of gas at FS 2 and up to 3,000 MCF of gas at FS 3 on or about June 12, 1990 to shut down and restart these facilities to accommodate the Alyeska TAPS shutdown scheduled for June 12, 1990. As you may be aware, Alyeska is currently planning a complete TAPS shutdown on June 12, 1990 to perform repairs and maintenance to its facilities. This shutdown is expected to last approximately 12 hours. During the shutdown, Alyeska plans to limit North Slope production to Pump Station # 1 at levels below what is required to keep all facilities on line. Because of this situation, ARCO plans call for a total shutdown of FS 2 and FS 3 while TAPS is down. The Central Compressor Plant (CCP) and the Central Gas Facility (CGF) will remain on line to handle gas produced during the TAPS shutdown. Although the TAPS shutdown is expected to last 12 hours, we request that the approval of flaring, if granted, be structured to allow for unforeseen circumstances which could potentially delay restart of FS 2 and FS 3. Gas flaring will be kept to a minimum whenever possible. volumes flared will be included in the Producer's Report(s) · Disposition, filed monthly with the AOGCC. All gas of Gas RE6EIVED J UN - 5 1990 Alaska 011 & Gas Cons. commission Anchorage ARCO Alaska, ~nc. is a Subsidiary of AflanticRichfieldCompany Mr. Lonnie Smith June 5, 1990 Page 2 If you have any questions or desire additional information, do not hesitate to call me at (907) 265-6136. Sincerely, M. A. Major Operations Representative Prudhoe Bay/Lisburne Operations MAM/kr RECEIVED JUN - 5 1990 Naslm.Oil & Gas Cons. Contmiss'lo[t ~nchorage BP EXPLORATION June 4, 1990 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 GC-1,2,&3 FLARE REQUEST ADMINISTRATIVE APPROVAL PRUDHOE BAY UNIT WOA BP Exploration (Alaska) Inc. 900 East Benson Boulevard RO. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 f'~'~-~"':'T"~ /'~../, --~ ;` .;-_'._.,:-. ~, ~ ~.,... , . .:' ~_ .,, ..... ................ L:..~. Dear Mr. Smith, BP Exploration (BPX) requests written authorization to flare a total of 40 MMSCF of natural gas approximately June 5 through June 24, 1990 through Prudhoe Bay Unit Gathering Centers 1,2 and 3. The flaring will be associated with the valve sequence testing of the GC-2 LPS compressors, GC-2 shutdown and depressuring for turnaround work and minor flaring at GC-1 and 3 due to the upset conditions of GC-2 after the turnaround. Please be aware that this flaring is in addition to flaring approved under May 25, 1990 dated Administrative Approval No. 145-A.54. If you have any questions concerning this issue, please contact Pam Pope at 564- 5499. Steven D. Tay~l r,('~J~n~tger Environmental & Re~gulatory Affairs PRP JUN 1 1 ]990 Oil.& {~as Cons. Commiss~n Anchora~ BP EXPLORATION BP Exploration (Alaska) Inc. 900 East Benson Boulevard RO. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 May21, 1990 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 GC-I,2,&3 FLARE REQUEST ADMINISTRATIVE APPROVAL PRUDHOE BAY UNIT WOA Dear Mr. Smith: ~-¢~-~.,...-.~ /'q,~ BP Exploration (BPX) requests written authorization to flare a total of 15 MMSCF of natural gas approximately June 5 through June 12, 1990 through Prudhoe Bay Unit Gathering Centers 1,2 and 3. The flaring will be associated with the shutdown and depressurization of the gaslift (GLT) equipment. The GLT shutdowns are necessary to install a new 24 inch isolation valve in the GLT tie-line between the Prudhoe Bay Field Western and Eastern Operating areas. if you have any questions concerning this issue, please contact Pam Pope at 564-5499. Sincerely, SFtnev~'reonn Dm;~l~Melun~gt~);y Affairs, Alaska PRP RECEIVE[) ,,t!,laska .Oil .& Gas Cons, CommisSjor~ ' ~nchorag~ ARCO Alaska, In{ Post Office oox 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 May 15, 1990 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive zanchorage, Alaska 99501-3192 Proposed Gas Flaring Flow Station #3 (FS 3) Prudhoe Bay Unit - Eastern Operating Area (PBU-EOA) Dear Mr. Smith: As we discussed today, ARCO Alaska, Inc., operator of the PBU-EOA, requests AOGCC approval for flaring up to 2,000 MCF of gas at FS 3 on or about June 7, 1990 to install an artificial lift gas isolation valve which will allow isolation of selected FS 3 inlet manifold piping from the PBU western operating area (WOA) artificial lift gas line. As you may be aware, the WOA normally provides all of the artificial lift gas requirements for the EOA and WOA. The FS 3 artificial lift gas equipment currently is used as a backup system. Due to safety and operational concerns with the present piping configurations, we propose installation of an isolation valve between the FS 3 inlet manifold piping and the artificial lift gas supply line from the WOA. In order to accomplish this work, it will be necessary to bleed down the line pressure from about 200 psi to atmospheric pressure via the FS 3 flare system. (BPX will depressure this line to about 200 psi via commonlines/large diameter towlines in the WOA.) Our calculations indicate that up to 2,000 MCF of gas will need to be flared to reach the desired conditions for valve installation. This work will be coinciding with the planned shutdown of the PBU-WOA Gathering Center #2 facility for gas handling expansion tie in work. Because the work proposed by ARCO is interconnected with operations in the WOA, we .request that the approval of flaring, if granted, be structured to allow for unforeseen circumstances which could potentially delay or accelerate the planned valve installation date of June 7, 1990. ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany ,,-~ "v 199[! ,, '_Andiorai~ Mr. Lonnie Smith May 15, 1990 Page 2 Gas flaring will be kept to a minimum whenever possible. All gas volumes flared will be included in the Producer's Report(s) of Gas Disposition, filed monthly with the AOGCC. If you have any questions or desire additional information, do not hesitate to call me at (907) 265-6136. Sincerely, M. A. Major Operations Representative Prudhoe Bay/Lisburne Operations MAM/kr BP EXPLORATION May 1, 1990 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 BP Exploration (Alaska) Inc. 900 East Benson Boulevard P.O. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 GC-1,2,&3 FLARE REQUEST ADMINISTRATIVE APPROVAL PRUDHOE BAY UNIT WOA Dear Mr. Smith, BP Exploration (BPX) requests written authorization to flare natural gas today May 1, 1990 to facilitate an ARCO proposed test of their Flow Station #3 GLT compressor. The ARCO GLT compressor experienced control problems yesterday, April 30, when it was brought on line. The ARCO test will cause high gas transit line pressures that will result in flaring at BPX Gathering Centers 1,2 & 3. It is anticipated that flare volumes will not exceed 23 million SCF and should occur over a 1 one day period. BPX requests AOGCC to approve this flaring as one of operational necessity. Your urgency in handling this issue would be greatly appreciated. If you have any questions concerning this issue, please contact Pam Pope at 564- 5499. Sincerely, E~vi,tonmental & Regulatory Affairs PRP · MA,v o ]99o Anchom~ TO: FROM: BP EXPLORATION 8P Exploration (AIa~ka) Inc. PO Box 196612 Anchorage, Alaska 99519-6612 RECEIVED TELECOPY SATELLITE UNIT Name: Company: Location: ~ Name & Ext.'.,, Department: ..~o 2. 0 NOTES: PAGES TO FOLLOW .................. '.~ (Do Not Include Cover Sheet) SECURITY CLASSIFICATION PRIVATE SECRET ~ ~: ., ............. .. CONFIDENTIAL .... · ' ~ : :::~: z :: ..... ,,,, . - , SATELLITE FAX MACHINE Fax # Confirm E,"T'd q~OP~ ).OB 3N~ NOIi~O]dX'q d~ ~O:TT 06, TO A~I4 BP Exploration (A{aska) Inc 900 East Benson Bouleyard ~O, Box I96~1~ Anchorage, Alaska 9S517,-6612 May 1, 1990 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 GC-1,2,&3 FLARE REQUEST ADMINISTRATIVE APPROVAL PRUDHOE BAY UNIT WOA Dear Mr. Smith, BP Exploration (BPX) requests written authorization to flare natural gas today May 1, 1990 to facilitate an ARCO proposed test of their Flow Station #3 GLT compressor, The ARCO GLT compressor experienced control problems yesterday, April 30, when it was brought on line. The ARCO test will cause high gas transit Iine pressures that will result in flaring at BPX Gathering Centers 1,2 & 3. It is anticipated that flare volumes will not exceed 23 million SCF and should occur over a 1 one day period. BPX requests AOGCC to approve this flaring as one of operational necessity. Your ur§ency in handling this issue would be greatly appreciated, If you have any questions concerning this issue, please contact Para Pope at 564- 5499. Sincerely, iiii [ ........ __ ........................ ~E~o~r~' D. Taylor, Manager nmental & Regulato~ Affaim PRP BP EXPLORATION April 23, 1990 Mr. Lonnie Smith Alaska OII and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 GC-3 FLARE AUTHORIZATION ADMINISTRATIVE APPROVAL NO. 145-A.50 PRUDHOE BAY UNIT WOA BP Exploration (Alaska) Inc. 900 East Benson Boulevard RO. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 Dear Mr. Smith, Please be advised that the flare test conducted at GC-3 described in administrative approval no. 145-A.50 has been completed. The test was conducted in two phases: phase 1: This phase of the flare capacity test was conducted at GC-3 on March 3, 1990, with total flare volume of 49, 184 MSCF. The test was designed to verify if the flare system operating capacity meets design capacity. The test was aborted prior to phase two as result of ice formation within the lines. Phase 2: This phase of the test was conducted on April 3, 1990, with a total flare volume of 12,143 MSCF. The test simulated a worst-case immediate gas loading to the flare system and measured performance during this condition. Both tests were conducted with flare volumes under the approved 80 MMSCF. understanding that the delay in flaring for the phase 2 test has been noted on Administrative Approval 145-A.50. It is our If you have any questions concerning this issue, please contact Pam Pope at 564- 5499. Sincerely, SE tnev~ reonn Dm; nT~aYl ' ~,r"RMe ~ u ~agt oe ~ Affairs RECEIVED APR 2 6 ]9.90 Oil & Gas Cons, Co~m[,~ri AnchoraFa ARCO Alaska, Inc{' Post Office L,,.,x 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 April 17, 1990 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission (AOGCC) '3001 Porcupine Drive Anchorage, Alaska 99501-3192 Proposed Flare System Testing Central Compressor Plant (CCP) Prudhoe Bay Unit - Eastern Operating Area (PBU-EOA) Dear Mr. Smith: As we discussed today, ARCO Alaska, Inc., operator of the PBU-EOA, requests AOGCC approval for flaring up to 80,000 MCF of gas at the CCP on or about April 23, 1990 to perform flare system testing. As you know, the PBU is in the process of increasing gas handling capabilities in the field. This gas handling expansion, also referred to as GHX-1, will increase field gas handling capabilities from a nominal 3.8 BCF/D rate to a nominal 5.1 BCF/D rate. One portion of this project deals with the conversion of the existing CCP Frame 5 turbines from Model R units to Model P units, an increased horsepower version. These changes, along with other modifications, will allow for increased gas injection into the gas cap of the field. In order to ensure that no major modifications will be needed to the CCP flare system as a result of GHX-1, we propose testing of this system under various conditions and monitoring its performance. The total duration of the flaring activities related to this test is expected to be less than 3 hours. Although this test is currently planned for April 23, it could be delayed or rescheduled due to poor weather conditions or other unforeseen factors. Hence, we request that the AOGCC approval for this test, if granted, be structured to allow for these circumstances. 'Gas flaring will be kept to a minimum whenever possible. All gas volumes flared will be included in the Producer's Report(s) of Gas Disposition, filed monthly with the AOGCC. RECEIVED ARCO Alaska, ~nc. is a Subsidiary of At~anticRichfieldCompany Mr. Lonnie Smith April 17, 1990 Page 2 If you have any questions or desire additional information, do not hesitate to call me at (907) 265-6136. Sincerely, M. A. Major Operations Representative Prudhoe Bay/Lisburne Operations MAM/kr BP EXPLORATION February 27, 1990 Alaska Oil and Gas Conservation Commission Attn: Lonnie C. Smith 300! Porcupine .Dri_ve Anchorage, AK 99501 BP Exploration (Alaska) Inc."% L.,',.., i,./! ill! 900 East Benson Boulevard . RO. Box 196612 Anchorage, Alaska 99519-6612~ (907) 561-5111 ~ ~'' [~'~'-,-~ ~ c"' r' ' ...... Dear Mr. Smith: As I discussed with you on February 26, 1990, BP Exploration requests permission to flare approximately 80 MMSCF of natural gas for flare capacity testing at Gathering Center 3 in the Western Operating Area of Prudhoe Bay starting on or about March 1, 1990 and proceeding for 3 to four days. The testing is planned in two phases. The first phase consists of introducing gas into the flare system in increments up to full gas production. This test will ensure that the predicted (modeled) capacity of the flare system is accurate and that the existing equipment is sufficient to handle increased gas handled at the facility. The second phase of testing will simulate a blocked outlet condition by closing the block valve to the gas transit line forcing a worst-case, immediate gas loading to the flare system Each test will be conducted at a minimum duration to limit the total gas volume flared. You indicated to me on the phone that you could not foresee any problem with BPX receiving an authorization to conduct this test. After reviewing this letter, if you have any concerns please contact me at 564-5501. BPX requests written approval for the above activity upon your review. Sincerely, Platt, Supervisor t.Environmental Compliance, Alaska RECEIVED MAR - 1 1990 Alaska Oil & Gas Cons. Commisslo[I Anchorage ARCO Alaska, Post Office'_ .,x 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 January 29, 1990 Mr. C. V. Chatterton Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, Alaska 99501-3192 Request for Approval of Gas Flaring Prudhoe Bay Unit (PBU) - Eastern Operating Area (EOA) Flow Station #3 (FS 3) Dear Mr. Chatterton: As we discussed Friday January 26, 1990, ARCO Alaska, Inc., operator of the PBU-EOA, requests AOGCC approval for flaring of up to 3 MMSCF of gas at FS 3 beginning on or about February 5, 1990 and ending on or about February 9, 1990 to perform a flare system test at this facility. The proposed flare test will be utilizing the stock tank vapor/intermediate pressure portion of the flare system. The primary purpose of the test will be to determine the effectiveness of the existing flare system regarding opacity. We plan to use the data generated to evaluate the need for flare system modifications so that such modifications, if needed, could be installed during a planned shutdown of FS 3 in the future. Gas volumes flared will be kept to a minimum, whenever possible. All gas volumes flared will be included in the Producer's Reports of Gas Disposition filed monthly with the AOGCC. If you have any questions, do not hesitate to call me at (907) 265- 6136. Sincerely, M. A. Major Operations Representative Prudhoe Bay/Lisburne Operations MAM/kr RECEIVED ,AN o 19 0 aaska.0ii & Gas Cons, Commissio[~. ~ ~nchor~ ARCO Alaska, inc. is a Subsidiary of AHan~icRichfie~dCornpany BP EXPLORATION December 15, 1989 Mr. Chat Chatterton Alaska OII and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 BP Exploration (Alaska) Inc. 900 East Benson Boulevard Re. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 ~,~ / v~- - .~. '--/,,~ REQUEST FOR FLARE AUTHORIZATION PRUDHOE BAY UNIT WOA Dear Mr. Chatterton, BP Exploration (BPX) requests written 'authorization to flare natural gas during the first two weeks of January 1990 to facilitate a high gas rate test at the PBU WOA Gathering Center #3 facility. The anticipated total flare vg.[l~me-fr-e~.m all three WOA gathering centers during this test period is approximate~l'~ 2 BSCF."~pecific details concerning this test operation is provided in Attachment 1': If you have any questions concerning this request, please contact Pam Pope at 564- 5499. Sincerely, Stan Gates, Supervisor Environmental Compliance, Alaska PRP/hd-mac REQUEST FOR FLARING TO CONDUCT HIGH GAS RATES TEST AT GC-3 (JANUARY 3 - 10, 1990) OBJECTIVE * Boost GC-3 gas production to 1.1BSCFD (expected future rate) * Demonstrate prototype upgrades to GC-3 gas system at future gas rate * Identify other "bottlenecks" that may prevent achieving target capacity - Basis for projects to further expand Gathering Center gas systems - Demonstrate high gas rate capacity without prohibitive operating costs PROCEDURE * Boost gas production at GC-3 to 1.1 BSCFD * Reduce inlet pressure to gas re-injection compressor - Draws more gas through the GC-3 gas processing system - Decreases capacity of reinjection compressors * Reduce reinjection gas rates from GC-2 and GC-1 - Provides more gas reinjection capacity for gas from GC-3 - Portions of GC-2 and GC-1 gas to be flared instead of reinjected - Gas to be flared has relatively high "oil yield" - Additional gas at GC-3 has a relatively low "oil yield" REQUESTED FLARING * Smokeless flaring of 285 MMSCFD for 7 days - Flaring from GC-2 (215 MMSCFD) and GC-1 (70 MMSCFD) - Total amount of gas flared estimated at 2 BSCFD - Total gas flared equivalent to 1/2 day's worth of gas reinjection ALTERNATIVES * Reduce gas production by 285 MMSCFD (cut oil by 60,000 barrels per day) * Risk future restriction of gas (and oil) production * Invest in possibly needless gas facility expansions SCHEDULE CONSIDERATIONS * Prototype modifications at GC-3 installed during Summer, 1989 - Project definition for GC-1 and GC-2 - Materials procurement for installation at GC-1 and GC-2 * Summer, 1989 testing thwarted by summer weather (gas cooling) * Previous test in October, 1989 identified potential problems - Unanticipated usage of gas dehydration inventory - Need to determine if identified problem is "real" FUTURE OPERATIONS * Additional Gas Transit Pipeline (Winter 89/90 installation) - Allows higher gas production rates at all facilities - Reduces need to flare at higher gas rates * Additional gas cooling - Lowers reinjection gas temperature - Improves gas reinjection equipment capacity RECEIVED Alaska Oil & Gas Cons. Anchorage bcc: P. Pope J. Swyter S. Taylor B. Packer B. Dotson/H. Grey D. Replogal/J. Gilroy GC Supervisors D. Calvin M. Chun B. Reynolds G. Campbell File: PC-PBU/AQ/Corresp. DEC 1.. 51989 Alaska 0il a Gas Cons. Comm'tssio~ Anchorage ARCO Alaska, Iri Post Offic~ ,.,ox 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 November 29, 1989 RECEIVED NOV 2 9 1_989 ,:,~aska Oil & 6as Cons. C0mm[ssfo~ Anch0rs~3 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, Alaska 99501-3192 RE: Request for Approval of Gas Flaring Central Gas Facility (CGF) Prudhoe Bay Unit (PBU) Eastern Operating Area (EOA) Dear Mr. Smith: As we discussed today, ARCO Alaska, Inc., operator of the PBU-EOA, requests AOGCC's approval for flaring of up to 13 MMSCF of gas at the CGF beginning on or about December 5, 1989 and ending on or about December 6, 1989 to perform a flare system test. As you are aware, the CGF flare system has undergone a series of modifications to correct deficiencies in this system since facility startup in late 1986. As part of our efforts to ensure the safe operation of the CGF flare system, we propose testing of this system at a variety of rates for limited time frames to monitor piping strain and vibration under various conditions. The proposed test is expected to require about 24 hours to perform and the total flaring duration is expected to be about one hour during the test. Flaring of gas will be kept to a minimum whenever possible. All gas volumes flared will be included in the Producer's Report of Gas Disposition filed monthly with the AOGCC. If you have any questions or desire additional information, do not hesitate to call me at 265-6136. Sincerely, M. A. Major Operations Representative Prudhoe Bay/Lisburne Operations MAM/kr ARCO Alaska, Inc. is a Subsidiary of AHanticRichfieldCompany BP EXPLORATION October 23, ]989 Chat V. Chatterton, Chairman Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 Prudhoe Bay Unit Western Operating Area .Request for Flaring Dear Mr. Chatterton' BP Exploration (Alaska) Inc. Anchorage, A aska 99519-8612 (907) 561-5111 ~/~ BP Exploration (BPX) requests authorization to flare approximately 250MMSCF of natural gas at Gathering Center #2 during the last week of October or first week of November to clean out a new gas injection well. A new gas injection well is being drilled in Eileen West End identified as ~-44. Prior to the well being placed on gas injection it needs to be perforated then flowed for clean-up. The W-44 well production rate will be ramped up over a period of two days to 70-80 MMSCFD. The well will be maintained at this rate for two days then shut-in. Please contact Pam Pope at 564-5499 is you have any questions concerning this flare request. Sincerely, Stan F. Gates, Supervisor Environmental Compl lance 7556E/PRP cc' P. Pope File · PC/PBU/AQ/Corr. RECEIVED OCT 2 ~ 1989 · Alaska Oil & Gas Cons. commlsslotl ;Anchorage BP EXPLORATION I~....torandum Dat~: ]~t 26, Production Flare PermSt During the ~-3 shut~own in June, mo~i£icatio=s were ma~e to the ~ Gas S~ v-03-9557 to oorrect design deficiencies. Last ~onth, a high rate perf~ce test for this scrt~l~r ha~ to be s~orte~ed due to h[gh ambient ~tures scheau.%ed October S - In or, er tm reach high gas rates in ~-3, the gas gathering line pressure will nee~ to be lowere~ by flar~ at Ge-2. The estimate~ fla lag rate is 300 ~ at GO-2 for a total volume of 900 ~[~F. There is a small possibility that scum of this gas ~ay be flare~ at GC-1. Please secure the flare ~t for this performan~ teat. If ad~itio~al information is =equire~, contac~ the GC-3 Process Er~ineer at E~c. 4952. 388.28 North Slope c~tions ~anag~ Facility ~in~e~t Facility ~~~io~ ~~~r RECEIVED 2 z 1989 Alaska 0il & ~as,Cons. Commissio~ AnchOrage AK ~7 (Weg) ~O=d IN~BWNO~ ! 6N.~ .XSE 6 l~ : T, l: AHI 68-- ~ BP EXI:q.ORATiON iI''' September 6, 1989 Chat V. Chatterton, Chairman Alaska 011 and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 Prudhoe Bay Unit Nestern Operating Area R_equest fo_r.. Flart nq Dear Hr. Chatterton: BP Exploration (BPX) requests authorization to flare natural gas during two Prudhoe Bay Unit Western Operating Area maintenance , pro~ects, as described below. 1. In an August g, 198g memo, BP Exploration provided you general details on proposed flaring for installation of permanent LDF pigging facilities associated with Gathering Centers #1 and Listed on Attachment #1 is the proposed schedule and flare volumes for this work. BPX requests aubhoriz~tion from AOGCC to flare these volumes over the periods listed. ' , 2. FactJJ.t~ Gathering Center #3 ~: Performance testing of HP Gas Scrubber V-O3-g557. Modifications were made to this unit during the June 1989 shutdown of Gathering Center #3. This test was originally scheduled for August but had to ba cut short as result of high ambi ent temperatures. Prooq.sed Flar(LD)_te/DuKBt~lon: October 5- 7 Pr..omose_d.~.Volumel 900 MMSCF Please contact Pamela Pope at 5~4-~49g concerning any questions or response to this request. Sincerely, Stev4i("O. Taylor, Manager Environmental & Regulatory Affairs, Alaska SDT/PRP/7427E cc: P. Pope S. Gates RECEIVED 2 :t I989 Alaska 0il & Gas Cons. Commissio[~ Anchorage MEMO BP EXPI.ORATION Date IN~WNO~Z~N~ RECEIVED Alaska,Oil & Gas 'Cons. Commissi(~ Anchorage BP EXPLORATION BP Exploration (Alaska)Inc, PO Box ~,96618 Anchorage, Alaska 99519-6612 MESSAGE # TELECOPY SATELLITE UNIT TO: Name; Company: Location: FROM: Name & Ext.' ,,, Department: NOTES- PAGES TO FOLLOW (Do Not Include Cover Sheet) SEC ~-I-:'r ~-~-~-A--$~-~ J'CA3:! O N PRIVATE SECRET CONFIDENTIAL ,, Fax # SATELLITE FAX MACHINE Confirm AK 3417.06 (1/89) TO 'd IN~WNO~I6N~ RECEIVED DEC 211989 Alaska 0ii & Gas Cons. commissiqtt Anchorage BP EXPLORATION September 6, 1989 Chat V. Chatterton, Chairman Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 Prudhoe Bay Unit Hestern Operating Area Request for Flaring BP Exploration (Alaska) Inc. ./9 900 East Benson Bouleva~ RO. Box 196612~,~ . Anchorage, Alaska/~19~ Dear Mr. Chatterton: BP Exploration (BPX) requests authorization to flare natural gas during two Prudhoe Bay Unit Hestern Operating Area maintenance projects, as described below. · In an August 9, 1989 memo, BP Exploration provided you general details on proposed flaring for installation of permanent LDF pigging facilities associated with Gathering Centers #1 and #2. Listed on Attachment #1 is the proposed schedule and flare volumes for this work. BPX requests authorization from AOGCC to flare these volumes over the periods listed. ~ · Facility Gathering Center #3 Reason' Performance testing of HP Gas Scrubber V-03-9557. Modifications were made to this unit during the June 1989 shutdown of Gathering Center #3. This test was originally scheduled for Augu'st but had to be cut short as result of high ambient temperatures. Proposed Flare Date/Duration: October 5- 7 Proposed Volume: 900 MMSCF Please contact Pamela Pope at 564-5499 concerning any questions or response to this request. Sincerely, Stev~D. Tayl~r~ ~qanag6r -" Environmental & Regulatory Affairs, Alaska SDT/PRP/7427E cc: P. Pope S. Gates RECEIVED S EP o ? )989 Alaska Oil & Gas Cons. Comrr~ssio~ Anchorage Page 2 Proposed LDF Flaring Schedule for Pigging Facility Tie-ins Pad X D H E B Y S R Pad D E F G H K A B C X Earl y Date 14 Aug. 18 Sep. 02 Oct. 16 Oct. 23 Oct. 30 Oct. 06 Nov. 13 Nov. F1 are MSCF 674 1228 937 446 1451 1625 1034 702 558 1278 Late Date 14 Aug. 24 Sep. 08 Oct. 22 Oct. 29 Oct. 05 Nov. 12 Nov. 19 Nov. Pad M N R S U Y Z Flare MSCF 745 1257 775 1169 2062 955 493 1516 3262 7427E/PRP RECEIVED S EP o 7 989 Alaska Oil & Gas Cons,, Commission Anchorage ARCO Alaska, Inc~ Post Office 15ox 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 August 29, 1989 Alaska Oil and Gas Conservation Commission C. V. Chatterton, Chairman 3001 Porcupine Drive Anchorage, AK 99501 COMM COMM COMM RES ENG SR ENG SR ENG ENG ASST ENG ASST SR GEOL GEOL GEOL FILE Dear Chat: ARCO Alaska, Inc., as operator of the Eastern Operating Area of the Prudhoe Bay Field, respectfully requests permission to flare approximately 3,250 MSCF of gas. The flare request is necessitated to allow pipeline repair work and SMART pigging operations on two common lines, 6C/13B/C and 14B/C. We are currently planning on combining the two activities to minimize the total flare volume. The present schedule calls for depressurization to conduct the repair and surveillance activities for common line 6C/3B/C to begin as early as September 1, 1989. Common line 14B/C is scheduled to begin its depressurization approximately one week later, September 9, 1989. The schedules are not firm at this time and are dependent upon other projects currently in progress. The estimated flare volumes per common line are as follows: 6C/13B/C 2,500 MSCF 14 B/C 750 MSCF Please call me at 263-4212 if you have any questions or concerns. Sincerely, T. M. Drumm Operations Representative Kuparuk Operations TMD/kp ARCO Alaska, Inc, is a Subsidiary of AtlanticRichfieldCompany BP EXPLORATION August 9, 1989 Chat V. Chatterton, Chairman Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 BP Exploration (Alaska) Inc. 900 East Benson Boulevard P.O. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 Dear Mr. Chatterton' The purpose of this correspondence is to document your verbal approval of the following operational flaring events as described to you by Pam Pope on 8/8/89. Facility Gathering Center #3 Reason: Maintenance and performance testing of high pressure scrubber. Proposed Flare Date/Duration: August 10, 1989, less than 12 hours. Proposed Volume: 1.5 MMSCF Facility Gathering Center #1 Reason: Maintenance and performance testing of high pressure scrubber. Proposed Flare Date/Duration: August 24, 1989, less than 12 hours. Proposed Volume: 1.5 MMSCF Facility Gathering Center #1 Reason' Installation of permanent LDF pigging facilities will require depressurizing of each LDF to install tie-ins. Proposed Flare Date/Duration: August(exact date to be identified)/each tie-in should require less that 12 hours of flaring. ProPosed Volume: 5.6 MMSCF Facility Gathering Center #2 Reason: Installation of permanent LDF pigging facilities will require depressurizing of each LDF to install tie-ins. Proposed Flare Date/Duration: August (exact date to be identified)/ each tie-in should require less that 12 hours of flaring. Proposed Volume: 10.8 MMSCF ,,. Chat V. Chatter1~n, Chairman August 9, 1989 Page 2 Facility Gathering Center #3 Reason: Installation of permanent LDF pigging facilities will require depressurizing of each LDF to install tie-ins. Proposed Flare Date/Duration: August(exact date to be identified)/ each tie-in should require less that 12 hours of flaring. Proposed Volume: 3.3 MMSCF Please contact Pam Pope at 564-5499 if you have any questions concerning this issue. Sincerely, vS~an Gates, Super i sor Environmental Compliance, Alaska 7385E/PRP cc: P. Pope S. Taylor ... ARCO Alaska, Inc. ti~ Post Office Box 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 June 27, 1989 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 ~1',,:'"';':" --"' ='":" ASS GEOL ASST~ ASST STAT TECH[ STAT TECH FiLE Dear Mr. Smith' Subject' Request for Approval of Gas Flaring Flow Station #2 (FS2) Prudhoe Bay Unit (PBU) Eastern Operating Area (EOA)\ As we discussed today, ARCO Alaska, Inc. (AAI), Operator of the PBU-EOA, requests AOGCC's approval for flaring of up to 35 MMSCF of gas at FS2 and for commonline inspection and repair activities beginning on or about July 15, 1989 and ending on or about December 31, 1989. As you are aware, increasing water production in the FS2 area has led to accelerated corrosion in a number of this area's commonlines. We have instituted an extensive corrosion inspection program for the commonlines in the FS2 area which goes beyond those activities performed in other parts of the field. This program includes increased corrosion coupon monitoring, ultrasonic testing of various lines, real-time radiographic testing of selected commonlines, and smart- pigging of certain lines. In order to perform portions of this workscope, it is necessary to depressure the commonline(s) being examined prior to conducting the surveys. Additionally, if these surveys indicate the need to perform repairs to these commonlines, it will, in most cases, require depressuring of the line(s) to perform these repairs. At this time, inspections RECEIVED ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany :J., UN 2 7 t989 Alaska 0il & Gas Cons. Commission Anchorage Mr. Lonnie Smith June 27, 1989 Page Two (and repairs, as needed,) are planned for the 3D, 4C, 9A, 9B, 11D, 16C, 16D, and 17D commonlines during the stated time frame. For these reasons, we request AOGCC's approval of flaring up to 35 MMSCF of gas at FS2 beginning on or about July 15, 1989 and continuing through December 31, 1989. Flaring of gas will be kept to a minimum whenever possible. All gas volumes flared will be included in the Producer's Report of Gas Disposition filed monthly with the AOGCC. If you have any questions or desire additional information, do not hesitate to call me at 265-6136. Sincerely, Operations Representative Prudhoe Bay/Lisburne Operations MAM:fl ARCO Alaska, I~, Post Off~, ~ox 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 June 27, 1989 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 Dear Mr. Smith' Subject: Request for Approval of Gas Flaring Flow Station #2 (FS2) Prudhoe Bay Unit (PBU) Eastern Operating Area (EOA)\ As we discussed today, ARCO Alaska, Inc. (AAI), Operator of the PBU-EOA, requests AOGCC's approval for flaring of up to 15 MMSCF of gas at FS2 for facility shutdown/startup activities beginning on or about June 30, 1989 and ending on or about July 14, 1989. Currently, AAI proposes to shut down FS2 at 0001 hours on June 30, 1989 to perform produced water handling/produced water treatment tie-in activities (in preparation for produced water handling and treatment modules scheduled to arrive via sealift later this summer), flare system upgrades and gas handling tie-in activities (in preparation for future gas handling expansion activities), and other miscellaneous maintenance activities. This work is expected to be completed in approximately 15 days. The estimated flare volume for FS2 shutdown and startup is 15 MMSCF. Flaring of gas will be kept to a minimum whenever possible. All gas volumes flared will be included in the Producer's Report of Gas Disposition filed monthly with the AOGCC. ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany RECEIVED 'JUN 2 ? t989 Alasa.0il & 6as Cons, Commission ,.., ~ ;ta, ncti0rage Mr. Lonnie Smith June 27, 1989 Page Two If you have any questions or desire additional information, do not hesitate to call me at 265-6136. Sincerely, Operations Representative Prudhoe Bay/Lisburne Operations MAM:fl ARCO Alaska, In~'"' Post Office'-__,x 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 May 3, 1989 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, AK 99501-3192 Subject: Request for Approval of Gas Flaring Flow Station #3 (FS3) Prudhoe Bay Unit (PBU) Eastern Operating Area (EOA) Dear Mr. Smith: As we discussed today, ARCO Alaska, Inc., operator of the PBU EOA, requests AOGCC's approval for flaring up to 6MMSCF of gas at FS3 beginning on or about May 4, 1989 and ending approximately six hours after the commencement of flaring to perform valve replacement and repair activities at this facility. The intermediate pressure discharge line from T/C 1802 (stock tank vapor/intermediate pressure turbine compressor) was determined to have a block valve that is stuck in the closed position. All attempts to operate this valve have been unsuccessful to date. The check valve and block valve that normally would be used to isolate this unit also appear to have some leakage at this time. Remedies to correct these valves have also been unsuccessful to date. To rectify this situation, we propose to shut down T/C 1802 and T/C 1801 (an additional stock tank vapor/intermediate pressure turbine compressor) for approximately six hours to perform valve replacement and repairs. (The piping configuration for T/C 1802 and T/C 1801 is such that both of these units will have to be shut down to repair the valving difficulties cited above.) While these units are off-line, gas flaring at about 1MMSCF/hour would be performed from the vessels upstream of these units. We have examined alternative repair plans to correct this situation. All other options to perform this work involve a full facility shutdown, which would consume greater gas flare volumes than the amount requested. Due to the timing of this flare request, verbal approval, to proceed was granted by you in our conversation. Gas flaring will be kept to a minimum whenever possible. All gas volumes flared will be included in the Producer's Report(s) of Gas Disposition filed monthly with the If you have any questions or desire additional information, do not hesitate to call me at 265-6136. Sincerely, M. A. Major Operations Representative Prudhoe Bay/Lisburne Operations MAM/plw ARCO Alaska, inc. is a Subsidiary of AtlanticRichfieldCompany RE¢iE.i? D MAY .-..,, ;t q ARCO Alaska, Inc.~" Post Officek .100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 May 3, 1989 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, AK 99501-3192 Subject' Request for Approval of Gas Flaring-Flow Station #1 (FS1) Prudhoe Bay Unit (PBU) Eastern Operating Area (EOA) Dear Mr. Smith' As we discussed yesterday, ARCO Alaska, Inc., operator of the PBU EOA, requests AOGCC's approval for flaring up to 4MMSCF of gas at FS1 beginning on or about May 8, 1989 and ending on or about May 28, 1989 to perform maintenance activities and modifications on the "A" and "C" processing trains at this facility. AAI currently plans to shut down the "A" and "C" processing at FS1 for approximately 10 days/train to perform vessel cleanout operations, vessel inspections, and sand jet system installation. (You may recall that we installed sand jet systems at flow station #2 about a year ago.) The sand jet systems allow for sediment removal from the vessels without requiring vessel shutdown and manual cleaning. Other minor maintenance to valving and other equipment will also be performed during these train shutdowns. The gas flare volume requested will allow for depressurization of the trains prior to shutdown and maintenance. Gas flaring will be kept to a minimum whenever possible. All gas volumes flared will be included in the Producer's Report(s) of Gas Disposition filed monthly with the If you have any questions or desire additional information, do not hesitate to call me at 265-6136. Sincerely, /.' ,.../_ /...t Operations Representative Prudhoe Bay/Lisburne Operations MAM/plw WAY - 3 AJasl~ 0ii & Gas ConS..C~mlss~O~t ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany ARCO Alaska, In({' Post Office' ,.,ux 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 March 2, 1989 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 Subject: Request for Approval of Gas Flaring Flow Station #2 (FS2) Prudhoe Bay Unit (PBU) Eastern Operating Area (EOA) Dear Mr. Smith: As we discussed today, ARCO Alaska, Inc. (AAI), operator of the PBU EOA, requests AOGCC's approval for flaring up to 50 MMSCF of gas at FS2 beginning and ending on or about March 8, 1989 to perform a flare system test. The purpose of the flare test is to verify the mechanical integrity of the existing flare system to determine the extent of modifications which may be required at FS2 for the planned gas handling expansion (GHX) activities in the PBU. As you may be aware, the GHX project will increase the overall PBU gas handling capabilities from it's current nominal capacity of about 3.6 BCF/D to about 5.1 BCF/D. The current FS2 test plans call for flaring at rates of up to about 650 MMSCF/D for brief periods while monitoring various aspects of the flare system, such as vibration, heat radiation, and other technical factors. The total test is expected to last about one to two hours. Data from this test will also be used to assist in evaluation of future flare system modifications that may be needed at Flow Stations 1 and 3. Gas flaring will be kept to a minimum whenever possible. All gas volumes flared will be included in the Producer's Report(s) of Gas Disposition filed monthly with the AOGCC. If you have any questions or desire additional information, do not hesitate to call me at 265-6136. Sincerely, M. A. Major Operations Representative Prudhoe Bay/Lisbume Operations MAM/plw RECEIVED Gas ~n$. C0m ,~issi0~ ~clt0.rage ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany ARCO Alaska, Inc. ~, Post Office Box 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 January 20, 1989 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 Subject: Request for Approval of Gas Flaring Flow Station I (FS1) Prudhoe Bay Unit Eastern Operating Area (PBU EOA) Dear Mr. Smith: As we discussed, ARCO Alaska, Inc. (AAI), operator of the PBU EOA, requests AOGCC's approval for flaring up to 50 MMSCF of gas at FS1 beginning on January 26 and ending on February 4 to perform modifications to the flare system controllers (staging valves) at this facility. The proposed modifications to this flare system will primarily involve electrical and instrumentation operations. In order to safely perform this work with the facility on-line, the flare staging valves must be kept in an open position in case of facility upsets (e.g. turbine/compressor trips, etc.). To prevent oxygen from entering the flare system while the staging valves are open, it will be necessary to maintain a gas flow through the system while the modifications are being performed. AAI has investigated other methods to perform this work and all other viable alternatives to the proposed plans involve a full facility shutdown. Based on historical data from EOA facility shutdowns and startups, it is likely that similar gas volumes would be flared during shutdown/startup operations, particularly if difficulties were encountered in this process. For these reasons, AOGCC approval of this planned flaring is requested. Gas flaring will be kept to a minimum whenever possible. All gas volumes flared will be included on the Producer's Report(s) of Gas Disposition filed monthly with the AOGCC. If you have any questions of desire additional information, do not hesitate to call me at 265-61 36. Sincerely, M. A. Major Operations Representative Prudhoe Bay/Lisburne Operations MAM/plw RECEIVED JAN 2 .,0il & Gas Cons. Commission "~,,,: ~chomge ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany ARCO Alaska, Inc.{ Post Office Box 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 January 3, 1989 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 Subject: Request for AOGCC Approval of Planned Flaring Flow Station #2 (FS2) Prudhoe Bay Unit (PBU) Eastern Operating Area (EOA) Dear Mr. Smith: As we discussed today, ARCO Alaska, Inc. (AAI), operator of the PBU EOA, requests AOGCC approval for flaring up to 15,700 MCF of gas at FS2 for commonline inspection and/or repair activities scheduled to occur in January, 1989 through June, 1989. As you are aware, we have been experiencing significant internal corrosion in a number of the commonlines in the EOA. At FS2, which is a high water production area, we plan to perform repairs to the 9A and 3C commonlines over the next several weeks based on previous inspections. We also plan to erform radio ra hic (and other) i~nspections on the 3D, 4B, 4C, 4D, 9B, 11D, 16D, 17D, and 16/17C commonlines between now and June, 1989. 'heseinspections (and repairs) of these lines require depressuring and/or sweeping of all the lines with gas prior to initiation of the inspections/repairs, which is the purpose for this flare request Please that the gas volume to be flared cited herein assumes that . note repairs will only be performed on the 9A and 3C commonlines. If future inspections lead to additional commonline repair work, it may be necessary for AAI to request approval for additional gas flaring from the AOGCC to perform such activities. We will keep you appraised of the overall commonline inspection/repair activities while the work is underway. Due to the short timeframe prior to commencement of this work, verbal approval to proceed was granted by you pending submittal of this written request. Gas flaring will be kept to a minimum whenever possible. All gas volumes flared will be included in the Producer's Report(s) of Gas Disposition filed monthly with the AOGCC. If you have any questions or desire additional information, do not hesitate to call me at 265-6136. Sincerely, M. A. Major Operations Representative Prudhoe Bay/Lisburne Operations .RECEIVED ~l~sl~ ~il .&. Gas Cons, MAM/plw ARCO Alaska, Inc, is a Subsidiary of AHanticRichfieldCompany ARCO Alaska, Inc. ( |-.Post Office Box 100360 ~ ~ (~ ~ i V E J.JAnchorage, Alaska 99510-0360 Telephone 907 276 1215 ,qEP 2 ., Sep.,t, ernber 19, 1988 GaS IJOrl$. (JC~,,~ll$5101l Mr. Lonnie Smith ~ ' Alaska Oil and Gas Consewation Commission 3001 Porcupine Drive ~.'TA~~~., ~, Anchorage, Alaska 99501-3192 Subject: Request for Approval of Planned Flaring of Gas Flow Station g3 (FS3) Prudhoe Bay Unit- Eastern Operating Area (PBU-EOA) Dear Mr. Smith: As we discussed last week, ARCO Alaska, Inc. (AAI), operator of the PBU EOA, request AOGCC's approval for flaring up to 1000 MSCF of gas at FS3 for "B" processing train shutdown and startup activities scheduled to occur in October, 1988. At this time, AAI plans to shut down the "B" production train in FS3, which is one of its three trains, on October 1, 1988 to perform vessel clean out and inspection, internal vessel modifications, and sand jet installation. (You may recall that we installed sand jetting systems in the vessels at FS2 in October 1987.) During this train shutdown, we also plan to upgrade the pressure ratings on the Iow pressure separation compressor discharge coolers (coolers for T/C 1803 and 1804) as well as perform other minor maintenance activities during the train shutdown. The operations are expected to be completed on October 10, 1988. Although the work is scheduled to begin on October 1, 1988 and be completed on October 10, 1988, we ask that the AOGCC approval of this request, if granted, be structured to cover unforeseen delays in the startup or completion of the herein described activities. Gas flaring will be kept to a minimum whenever possible. All gas volumes flared will be included in the Producer's Report(s) Of Gas Disposition filed monthly with the ACC:CC. If you have any questions or desire additional information, do not hesitate to call me at 265-6136. Sincerely, M. A. Major Operations Representative Prudhoe Bay/Lisburne Operations MAM/plw ARCO Alaska, Inc. Is a Subsidiary o! AllantlcRIchfleldCompany ARCO Alaska. Inc. ~ Post Office Box 100360 Anchoraqe. Alaska 99510-0360 Telel~l~one 307 2?6 1215 April 25, 1988 C. V. Chatterton Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 Subject: Flaring at Flow Station #2 (FS2) Prudhoe Bay Unit (PBU) Eastern Operating Area (EOA) Dear Mr. Chatterton: As discussed on Friday, ARCO Alaska, Inc. (ARCO), operator of the EOA for the PBU, received verbal approval to flare approximately 28 MMSCF of gas from our FS2 facility. The additional flare volumes are required to commence emergency repair work of common lines from drill sites 3, 9, and 17. Repair work consists of line pressurization and de-pressurization associated with real time radiographic (RTRT) work as well as line replacement where necessary. It is anticipated that the repair and radiographic work will commence 4/22/88 and continue through the middle of June. Flare activities associated with this work will also occur during this time frame. Attached is a data sheet detailing the repair and inspection activities as well as the estimated gas volume to be flared. As shown on the attached sheet the initial work emphasis is being placed on the lines across the Sag River bridge and the associated approaches. It is anticipated that repair work on the lines across the Sag will be complete prior to breakup. We appreciate your quick response on this matter. Please contact me at 263-4212 or Mark Major at 265-6136 if you require additional information. We will keep you appraised of the situation as more information becomes available. Sincerely, T. M. Drumm Operations Representative Attachment TMD/plw R£(~JESTED FLARE ~UHE$ ..... RTRT &C/-~ F.___~. Yolm--~H~-~- FIIr~ Yollllld~ ~i~ "~6-C " ~ir ~:~t'~loln~ ' ........ - 1.800~ IT-D ~ ~R br~ ....... 900 - rtrt ~~_~f !~ ~~ ...... ~6-p .... ~ ~r. br~ ......... 9o0 ~:c~ r~~~~~r.~Fs-~, -, ~=.-: ~'_~a,5~O.~3'D ~~r. br~ 90o - ,,, ~ ...... 9-B ,, rtrT f~ P~in s. ~ ~ r. to Ds ~ , , ~ ~ r. br~ 900 ..... --~b~o~: Ib.oooj .... ..................... ~ ......... ~ s--~ ..... :., ~ ~,.. ,.~ ~ ~" ~7 ~ ............. dune : · · .......... · ........ ............ z _ 19-B iJ 6-0 j~_n~L~ R. bric~_!o DS ~ 3 9-B N. bluff lo F$ ~2 :I6-D 17-D ,9-6 j4-C 5ubtc)[el:i N. bluff [o FS '~'2 N. bluff mfs ~2 N. bluff lo F$ N. bluff toF$ '[.ti~ I~h of c.~L-~:~ ................ ~ub~l: bluff - ...... 1~- 900 : 900 t 900 ...... 4 900' 900 9001 ARCO Alaska, Inc. ~ Post Office Box 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 March 29, 1988 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 Subject. Planned Flaring at Flow Station #2 (FS2) Prudhoe Bay Unit (PBU) Eastern Operating Area (EOA) Dear Mr. Smith' · As we discussed today, ARCO Alaska, Inc. (ARCO), operator of the EOA for the PBU, requests AOGCC approval of flaring up to 12.5 MMSCF of gas at FS2 beginning on or about April 5, 1988 and ending 24 hours after the start time to perform tie-ins to the gas coolers at this facility. As you may be aware, FS2 was shut down on February 11, 1988 due to leaks in the gas coolers and due to a combination of electrical and instrumentation malfunctions. Although FS2 was restarted on February 13, 1988, this situation resulted in the need to re-tube one of the gas coolers, which has, essentially, been completed. However, in order to tie-in this unit to the production and separation equipment at FS2, we request AOGCC approval to flare gas volumes from the slug catchers while performing this work. This work is currently scheduled to begin on April 5, 1988 and will coincide with planned Trans-Alaska Pipeline System (TAPS) maintenance on that day. It is expected that all gas cooler tie-in work will be completed within several hours. ARCO believes that the tie-in method outlined is the most effective way of performing this work from an energy conservation standpoint. Other options examined involve a complete shutdown and startup of the flow station. We estimate that such a shutdown would consume similar amounts of gas under a smooth shutdown/startup operation and would consume greater amounts of gas than the flare volume requested if difficulties were encountered. Flaring of gas will be kept to a minimum whenever possible. All gas volumes flared will be included on the Producer's Report of Gas Disposition filed monthly with the AOGCC. If you have any questions or desire further information, do not hesitate to call me at 254-6136. Sincerely, M. A. Major Operations Coordinator Prudhoe Bay/Lisburne Operations MAM/plw ' ~ Alaska Oil & Gas Cons. "':ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany ARCO Alaska, Inc. ~ Post OfficeI~u,~, 100360 Anchorage, A~aska 99510-0360 Telephone 907 276 1215 February 25, 1988 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, AK 99501-3192 Subject' Request for AOGCC Approval of Flaring at the Central Compressor Plant (CCP) Prudhoe Bay Unit - Eastern Operating Area Dear Mr. Smith: .............. ~ES ENG SR ENG ~ ENG S~ GEOk SR GEOL ~NG A~-T sTAT STAT~C~] FIL~: 'As we discussed today, ARCO Alaska Inc. (AAI), operator of the CCP for the Prudhoe Bay Unit, requests AOGCC approval of flaring up to 5MMSCF of gas for a four day period beginning at 0001 hours February 26, 1988 while performing repairs to the compressor fuel inlet header at this facility. On February 25, 1988, while performing routine maintenance activities at this facility, an external non-penetrating fracture was discovered in the 10 inch compressor fuel inlet header. Although investigations indicate that sufficient pipe thickness remains for pressure integrity, we plan to replace this section of pipe immediately to prevent the possibility of problems occurring with this pipe. A bypass will be installed around the suspect section of pipe while this pipe is removed and replaced. However, due to existing piping configurations, it will be necessary to route the vapors from the compressor seal oil systems (which are normally routed back into the fuel inlet header) to the flare header while repairs are performed. The repair operations are estimated to require up to four days to be completed. We estimate that up to 5MMSCF of gas volumes above the normal pilot and purge volumes will be flared during the repair activities. AAI believes that the repair procedures planned are the most effective method of handling this situation from an energy conservation standpoint. The other options examined for performing these repairs involve shutting down the CCP, which would require a full field shutdown or flaring at all other facilities while repairs are ongoing. These options would result in far greater gas flare volumes than the 5MMSCF of gas that will be flared under current plans. Flared volumes will be kept to a minimum whenever possible. All gas flare volumes will be included on the Producers Report of Gas Disposition filed monthly with the If you have any questions, do not hesitate to call me at 265-6136. Sincerely, M. A. Major Operations Coordinator Prudhoe Bay/Lisburne Operations RECEIVED FEB 2 ~ .[J~8 MAM/plw Naska 0il & Gas Cons. {;ommissiea Anchorage ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany Standard Alaska Production C~ml~~'' 900 Eost Benson B~ ard P.O. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 HAND DELIVERED Mr. Lonnie Smith Alaska Oil & Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 Dear Mr. Smith: STANDARD ALASKA PR( ~ DDU~,,,.~ION / 00~,~,~%~ "' ~':", "'.?~, .~:'.2 _ I 1 c~ t;? .~:':,, :.,-, - ..... August 10, 1987 Pursuant to Conservation Order No. 145-A dated January 12, 1978, Standard Alaska Production Company requests approval to flare at Gathering Center 1 during the week of August 10, 1987, or until the test is completed. See attached letter dated August 7, 1987 for detail information regarding flaring. Sincerely, Production Accounting Attachment cc: E. A. Dippe B. V. Dotson/M. Baugh J. Gilroy/D. Replogle R. L. Packer D. M. Webb RCY:jr 04g0T A unit of the original Standard Oil Company Founded in Cleveland. Ohio, in 1870, RECEIVEI) Oft!ce Correspondence ALASKA CC NO: AUG 1 015~7 ..... ~-~~~ Standard Alaska Production Company,/ 900 East Benson BOul{( P.O. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 March lg. lg87 Alaska Oil & Gas Conservation Commission 3001 Porcupine Drive Anchorage, AK g9501 ATTENTION: M~. LONNIE SMITH Dear Mr. Smith: High gas rate process testing will be conducted at Gathering Center 1 with a total associated flared volume not to exceed 50 MMSCF. Pursuant to Conservation Order No. 145-A dated January 12, 1978, Standard Alaska Production Company requests approval to flare at Gathering Center i between April I and April 8, 1987, or until the tests are completed. Sincerely, /~bert C. Youn ,.g~n, Manager .... Production Acco~ntlng dm1 cc: E. A. Dippe B. V. Dotson/M. Baugh J. Gilroy/D. Replogle R. L. Packer D. M. Webb RECEIVED 0426T A unit of the original Standard Oil Company Founded in Cleveland Ohio. in 1870. MAR 2 4 1987 Ataska 0ii & Gas Cons. Commission Anchorage' ARCO Alaska, Inc. Post Office Box 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 March 16, 1987 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, Alaska 99501-3192 SUBJECT' Prudhoe Bay Unit, Eastern Operating Area Central Gas Facility (CGF) Miscible Injectant (MI) Compressor Incident Dear Mr. Smith: As we discussed today, ARCO Alaska, Inc. (AAI), operator of the CGF, experienced a minor explosion at this facility on March 14, 1987. The purpose of this letter is both to request the AOGCC's approval for flaring MI for an interim period while resolving problems with the second MI compressor at the CGF, and to provide you with information concerning this incident. On March 14, 1987, at approximately 2:52AM, an explosion occurred in the seal oil reservoir of one of the two MI compressor units at the CGF. The cause of the explosion is unknown at this time. No personnel were injured by this incident. No oil spills or gas releases occurred due to this explosion, other than those gas volumes flared from operation of the various safety relief devices within the CGF. Repairs to the equipment damaged during this incident are expected to be completed'in about six weeks. After the explosion occurred and the safety and status of CGF personnel and equipment was determined, production rates of natural gas liquids (NGLs) and MI were reduced while attempting to place the second MI compressor into service. It was determined, after numerous starting attempts, that the second MI compressor had gearbox difficulties which, at this time, are expected to take up to a week for resolution. ARCO Alaska, Inc. Is a Subsidiary of AtlanticRIchfleldCompany March 16, 1987 Mr. Lonnie Smith Page 2 We propose operating the CGF at reduced rates of about 15-20 MBBLS/day of NGLs and about 30 MMSCF/day of MI for up to one week (through March 23, 1987) while resolving gearbox problems with the second MI compressor. Alternatively, there is a possibility that we may be able to fabricate bypasses from the MI system that will permit MI to be returned to the Iow pressure separation (LPS) production system at the flow stations and drillsites. However, the viability of this option is undergoing examination at this time and, if feasible, may take several days to implement. During this week, the NGLs would continue to be blended with the Prudhoe crude stream and shipped to ^lyeska. The MI stream would be flared until the second MI compressor is operational or until the above described bypasses can be fabricated. We believe our proposed CGF operational plan is the most efficient method of handling this unforeseen problem from an energy conservation standpoint. ^ total CGF shutdown while resolving the gearbox problems with the second MI compressor would result in greater gas volumes being flared during plant shutdown and startup activities than the gas volumes to be flared under our proposal. Additionally, it would be extremely difficult to determine whether or not the gearbox problems with the second MI compressor have been repaired without having MI available to test this unit. As discussed herein, we request AOGCC approval of flaring up to 30MMSCF/day of MI at the subject facility for a period commencing immediately and extending until 2400 hours March 23, 1987, or until such earlier time as MI bypasses are operational or the second MI compressor is repaired, for resolution of CGF operational problems stemming from the March 14, 1987 explosion at the CGF. This request seeks confirmation of the approval which you gave by telephone earlier this afternoon. All gas volumes flared will be included on the Producers Report(s) of Gas Disposition filed monthly with the AOGCC. We will keep you informed of our progress on this matter as we have done in similar circumstances in the past. If you have any questions or desire further information, do not hesitate to call me at (907)265-6136. M.A. Major Operations Coordinator Prudhoe Bay Operations ARCO Alaska, Inc. ~ Post Office B~^ 100360 . 99510-0360 Anchorage, Alaska Telephone 907 276 1215 January 26, 1987 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Dr. Anchorage, AK 99501-3192 Subject: Prudhoe Bay Unit, Eastern Operating Area Central Gas Facility (CGF) Startup Flaring Request for Additional Flare Volume Dear Mr. Smith: ARCO Alaska, Inc. (AAI) requests approval for flaring of up to 1.00 billion SCF of additional gas volume at the subject facility for continuation,~ of startup and commissioning activities. On November 7, 1986, AAI requested approval for flaring of up to 1.43 billion SCF of gas at the CGF for startup from the AOGCC. The AOGCC approved this request on November 10, 1986. The current flare permit began on November 15, 1986 or upon commencement of booster compressor commissioning activities and will end with completion of miscible injection (MI) equipment/process commissioning. At this time, we are experiencing minor mechanical difficulties and operational procedure problems related to the MI process which have prevented completion of MI process commissioning. We have been operating the stabilizer equipment, which produces MI fluids, at a minimum rate while resolving this situation, since MI fluids are needed to "troubleshoot" these problems. However, approximately 1.2 billion SCF of gas has been flared to date under the startup flare permit and additional gas volumes are needed to complete facility startup. For this reason, we request approval of flaring of an additional 1 billion SCF of gas (for a total of 2.43 billion SCF) to complete CGF startup. No change in the timing for conclusion of this permit is required. All gas volumes flared will be included on the Producers Report(s) of Gas Disposition filed monthly with the AOGCC. We will keep you informed of our progress in completing CGF startup as we have done in the past in similar situations. If you have any questions or desire further information, do not hesitate to call me at 265-6136. Sincerely, M. A. Major Ope rations Coordinator Prudhoe Bay Operations RECEIVET) 'Naska 0il & Gas Co~. Cpmmissi0n ArmA0rage ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany ARCO Alaska, InC. Ei Post Office ,, 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 November 12, 1986 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive ~V~DAnchorage, AK 99501-3192 ~..~..-~.~' i 2 1986Subject: Planned Flaring at Flow Stations 1, 2, and 3 Prudhoe Bay Unit Gas [;on.~. ~inmission Eastern Operating Area (EOA) Anchorage Dear Mr. Smith- ARCO Alaska, Inc. (ARCO) requests permission to flare an excess amount of gas at our Flow Stations 1, 2, and 3. The gas flaring will be the result of depressuring the artificial lift system to perform maintenance activities and modifications to the artificial lift warm-up header located in module 4906 at Flow Station #3. As you may be aware, the Alyeska pipeline is scheduled to be shut- down and North Slope production is to be slowed to a rate of about 600 MBBLS/day at 0600 hours on November 18, 1986 to permit pipeline repairs at Pump Station #10. This work is expected to require less than 18 hours to complete. During this slowdown, ARCO plans to perform the above described maintenance. To accomplish the depressuring required to perform this work, artificial lift gas pressure will be allowed to fall to wellbore pressure after the artificial lift compressor is shutdown. After achieving wellbore pressure in the piping system, gas will be routed to the low pressure separation (LPS) common lines to reduce the pressure further while recovering the gas for processing. Once LPS common line pressure is reached, the remaining gas pressure will be vented to flare at the three flow stations to achieve the minimum pressure in the system prior to piping disassembly for maintenance and modification. By sharing the flaring of gas between the flow stations, the maintenance/modification plans will be accelerated and the artificial lift system should be ready for restart when the Alyeska slowdown is completed. We request permission to flare up to a total of 4,150 MSCF of gas at 'the subject facilities beginning at 0001 hours November 18, 1986 or at the start of the Alyeska slowdown for Pump Station #10 repairs and ending on 0001 hours November 19, 1986 or 12 hours after completion of the Alyeska Pump Station #10 repair work. The gas volumes flared related to this work will be included on the Producer's Report(s) of Gas Disposition filed with the AOGCC. ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany Mr. Lonnie Smi~: ~ November 12, 1986 Page 2 It should be pointed out that, at this time, we do not plan to completely shutdown the EOA flow stations or the Central Compressor Plant during the Alyeska slowdown. However, if repairs to the Alyeska pipeline take longer than planned, we may have to shut in Prudhoe EOA oil production due to insufficient crude storage availability. If this situation occurs, we will contact you to obtain approval for additional flaring, if needed. If you have any questions or desire additional information, please call me at (907)265-6136. Sincerely, · Mark Major Operations Coordinator Prudhoe Bay MAM/plw' 083 1 2 1986 Gas Goi~. ~ommission Anchorage ARCO Alaska, Inc~ Post Office BU,, 100360/.~ p. ~ ,~~/L~ Anchorage A~aska 99510-0360 /I[. Telephone 907 276 1215 November 7, 1986 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, AK 99501-3192 SUBJECT: Central Gas Facility (CGF) Startup Flaring Dear Mr. Smith: ARCO Alaska Inc. requests approval for flaring of up to 1.43 billion SCF of gas during the commissioning and startup of the CGF. Due to the different processes contained in the CGF (miscible injectant, natural gas liquids, central compressor plant "feedstock" gas), the sequential nature of these processes, and the need to functionally check various equipment in the CGF, flaring of gas will be necessary during the startup of this facility. Flaring of gas will be kept to a minimum whenever possible. At this time, we anticipate flaring of gas in quantities in excess of the approved safety flare amount to begin in the November 15 - December 1 timeframe (for booster compressor startup) and end in the January 1 - January 15 timeframe (at the completion of miscible injection process startup). Because of the uncertainty concerning the actual dates of these activities, we request the flare permit to begin on November 15, 1986 or the date of commencement of booster compressor commissioning activities and end on January 12, 1987 or upon completion of miscible injection equipment/process commissioning. The attachments to this letter provide additional information on the flaring activities related to starting up the CGF. As we have done in the past in similar situations, we will keep you informed of our progress in starting up the CGF. If you have any questions or desire additional information, do not hesitate to call me at 265-6136. Sincerely, Mark Major Operations Coordinator Prudhoe Bay Operations MAM/plw:078 Attachments RECEIVED mov o 7 1986 Nasla Oil & Sas Cons. Comliss~ ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany '~" "--'" I~{ ~ 3o x 3o TO THE ,NCH-7 ~ to ,~..,c. Es 46 0700 4~ KEUFFEL 8:: ESSF'R CO, f4ADE , U.S.A. 6O ~40 3O 2O 10 CENTRAL GAS FACILITY START-UP FLARING ESTIMATE l , , i , J ' , ~'TART'~UP ' , , I _. . ' ; i ' r , ~ : ~ ~ ~ ....... ' : , ~ ' : I / I . ; ' , ~ . . . t / [ r , , , · ~, ' , ' ~ ~ : I , . i · ~ ~ i ...... 6~ ~T GAS START-UP COMPRESSORJ , 3 NOVEMBER DECEHBER JANUARY FEBRUARY MARCH - Pipeline & Booster Compressor Start-up - Miscible Injection Start-Up TABLE 1 Duration Start Dec. 1 Dec. 26 Finish Flared Gas Quantities (MMSCF) Dec. Jan. Total Dec. 23 300 --- 300 Jan 12 300 700 1,000 Start-Up Flaring 6OO 7OO 1 ,3OO - Continuous Safety Utility Dec. 1 Jan 12 90 40 130 690 740 1,430 Standard Alaska ,, Production Comparj(' 900 East Benson Bo~% ..J P.O. Box 196612 Anchorage, Alaska 99519-6612 (907) 564-5111 September 16, 1986 Alaska Oil & Gas Conservation Commission 3001 Porcupine Drive Anchorage, AK 99501 Attn: Mr. Lonnie Smith Gentlemen: Pursuant to Conservation Order No. 145-A dated January 12, 1978, Standard Alaska Production Company requests approval to flare at Gathering Center 1 and Gathering Center 2. See attached letters dated September 15, 1986 and September 16, 1986 for detailed information regarding requested flarings. Sincerely, dml Attachments cc: E. A. Dippe B. V. Dotson/M. Baugh J. Gilroy/D. Replogle R. L. Packer D. M. Webb 0350T R~bert C. Y~gmun ~4anager Production Accounting A unit of the original Standard Oil Company Founded in Cleveland, Ohio, in 1870, ,. office Corr..pondenoe ~ ~3b ¥cxmgaun PROI~. ACCTG. SEP 15 IBt~ office Correspondence NO: YOUR R~: F16 mat. ely 4 MMCF for ~ha cmlibra~/on ar~ t~st~ of the new Mioo~ HP Flare Con~ller a= C~-1, W~u~,~ was ~led during the t~Tm3~amd. If yo~ have at~ ~es~~, please oon~ this office. E00 0~0'0N NWO3 3dO]S HI,ON ~£:0~ 98/9I×60 Standard Alaska Production Company~ 900 East Benson Boule,~ P.O. Box 196612 Anchorage, Alaska 99519-6612 (907) 564-5111 August 8, 1986 Alaska 0il & Gas Conservation Commission 3001 Porcupine Drive Anchorage, AK 99501 Attention: Mr. Lonnie Smith Gentlemen: To confirm our telephone conversation of today, I am attaching a memo, also dated today, reflecting flaring intentions on Gathering Center start-ups following turnarounds. Pursuant to Conservation Order No. 145-A dated January 12, 1978, Standard Alaska Production Company requests approval to flare at Gathering Center 1, Gathering Center 2, and Gathering Center 3. Sincerely yours, R~ert~'/!. Youngn ~ Manager Production Accounting dml:0290T Attachment cc: E. A. Dippe B. V. Dotson/M. Baugh R. L. Packer D. M. Webb A unit of the original Standard Oil Company Founded in Cleveland, Ohio, in 1870. RECEIVED ,gl~ska 0ii & (~as Cons. Commission Anchorage Offloe Oorm.po~cte~¢e i!NU~!H ~L.~JP'~' ~_.UP'IIq RECEIVED AUG 1 2 1986 Oil & C~s Cons. Commission ARCO Alaska, Inc.(~',, Post Office B I00360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 July 15, 1986 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Drive Anchorage, Alaska 99501 RE: Prudhoe Bay Unit Eastern Operating Area Flow Station #1 Dear Mr. Smith: As we discussed today, ARCO Alaska, Inc. (AAI) desires permission to flare an excess amount of gas at our Flow Station #1. The gas flaring will be the result of the shutdown of this facility to perform high pressure flare relief system modifications, emergency shutdown/operational shutdown (ESD/OSD) system changes, produced water tank overpressure modifications, crude heating and crude cooling upgrades, triethylene glycol (TEG) regeneration equipment upgrades, a complete flare system inspection, and other minor modifications and repairs within this facility. The flaring will be associated with unavoidable shutdown, startup and check-out procedures related to this work. We request permission to flare up to 55 MMSCF beginning at 0001 hours on July 16, 1986 until 2400 hours on August 7, 1986 for this work at the subject facility. As conveyed to you in our conversation, this work was scheduled to begin later this month but was moved forward due to the early arrival of selected parts which will enable portions of this work to be performed prior to the complete shutdown of this facility. Some gas flaring will occur when performing this early work, which is related to flare system modifications. Because of this situation, verbal permission to flare the gas volumes requested in this letter was granted by you in our discussion. The current schedule calls for complete facility shutdown on July 22, 1986 and facility restart on July 31, 1986. The additional days after the facility shutdown requested in the flare permit are to cover unforeseen circumstances which could shift the end date of this shutdown, such as problems encounted while performing this work or unanticipated delays of the start date of the complete facility shutdown. ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany RECEIVED ,A~aska Oil & Gas Cons. Anchorage Gas volumes flared related to this work will be included on the Producer's Report(s) of Gas Disposition filed with the AOGCC. If you have any questions or desire additional information, please call me at (907) 265-6136. Sincerely, Mark A. Major Operations Coordinator Prudhoe Bay Alaska, Inc. {" ARCO Post Office Box 100360 Anchorage, Alaska 99510-0360 Telephone 907 276 1215 June 6, 1986 Mr. Lonnie Smith Alaska Oil and Gas Conservation Commission (AOGCC) 3001 Porcupine Dr. Anchorage, AK 99501 Dear Mr. Smith' Subject- Prudhoe Bay Unit Eastern Operating Area F1 ow Station #3 As we discussed today, ARCO Alaska Inc. (AAI) desires permission to flare up to 34 MMSCF of gas at the subject facility for the time frame of 6/15/86 to 7/15/86. This permit is requested to cover activities to be performed during the 1986 plant turnaround scheduled to begin on 6/23/86 and end on July 3, 1986. The additional days before and after the shutdown requested in the flare permit are to cover unforseen circumstances which could shift the actual start and end dates of this shutdown, such as TAPS slowdowns or problems encountered during the facility shutdown. During the plant turnaround, crude cooling, crude heating, HP gas relief, produced water overpressure/overfl ow protection, and a variety of other systems modifications will be upgraded or performed. The flaring will be associated with unavoidable shutdown, startup and check-out procedures. Gas volumes flared related to this work will be included on the producer's report(s) of gas disposition filed with the AOGCC. If you have any questions or desire additional information, please call me at (907)265-6136. Sincerely, M. A. Major Operations Coordinator Prudhoe Bay MAM'llh'017 RECEIVED ~,,, i',.~ ,q 9 !986 ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany SOHIO ALASKA PETROLEUM COMPANY April 1, 1986 Alaska Oil & Gas Conservation Commission 3001 Porcupine Drive Anchorage, AK 99501 Attention: Mr. Lonnie Smith 900 EAST BENSON BOULEVARD ANCHORAGE, ALASKA TELEPHONE (907) 561-5111 P.O. BOX 6612 ANCHORAGE, ALASKA 99502-0~!:.~. ~,'.. .... .~. . Gen tl emen: Pursuant to Conservation Order No. 145-A dated January 12, 1978 and Administrative Approval No. 145-A.7 dated February 13, 1986 and Administrative Approval No. 145-A.8 dated March 25, 1986, Standard Alaska Production Company requests approval to continue with the Flare and Relief testing that was not completed by February 17, 1986 and March 31, 1986. Attached for your convenience is the request by our Field Production SUperintendent to schedule the testing for April 3, 1986. From past scheduling experience our formal request is for approval to complete the testing by April 10, 1986. Sincerely yours, h~ger ;roducti°n'Acco 'u'nting dml:O290T Attachment cc: E. A. Dippe B. V. Dotson/R. E. Borah D. M. Webb Prudhoe Bay Field Manager RE£ElYEI) APR - ! 1986 Alaska, 01! & G~, Cern. Comml~81efl SOHIO ALASKA PETROLEUM COMPANY OFFICE CORRESPONDENCE Bay SOHIO ALASKA PETROLEUM COMPANY March 24, 1986 Alaska 0~1 & Gas Conservation Commission 3001 Porcupine Drive Anchorage, AK 99501 Attention: Mr. Lonnie Smith Gentlemen: Pursuant to Conservation Order No. 145-A dated January 12, 1978 and Administrative Approval No. 1~5.A.7 dated February 13, 1986, Standard Alaska Production Company requests approval to continue with the Flare and Relief testing that was not completed by February 17, 1986. Attached for your convenience is the request by our Field Production Superintendent to schedule the testing for March 26th and 27th, 1986. Sincerely yours, M~anager Production Accounting dml:O290T Attachment cc: E. A. Dippe B. V. Dotson/R. E. Borah D. M. Webb Prudhoe Ba~ Field Manager RECEIVED Alaska 0ii a uas '0o~'~s. Oommi,oo, inr~ SOHIO ALASKA PETROLEUM COMPANY OFFICE COR~£Si~ONDENC~ 12 ~CF ac ~e ~eq~e~ that ~he S=ate ~e notified o~ o~z intem~ a~d l~ ~b~=e are q~$~iona or chan~ea, pleas~ ~ontact this o~Ice, cc: ~ ~ay Yield ~C-2 ~uperviaor ~C- 1~ Supervisor SOHIO ALASKA PETROLEUM COMPANY February l l, 1986 State of Alaska Alaska Oil & Gas Conservation Commission P.O. Box 8090 Anchorage, Alaska 99508 Attention: Mr, Lonnie Smith 900 EAST BENSON BOULEVARD ANCHORAGE, ALASKA TELEPHONE (907) 561-5111 P.O. BOX 6612 ANCHORAGE, ALASKA 99502-0612 Gentlemen: Pursuant to Conservation Order No. 145-A dated 3anuary 12, 1978, Sohio Alaska Petroleum Company requests approval to continue with the Flare and Relief testing as detailed on the attached letter dated February 1, 1986. Please be advised that Phase II testing at Gathering Center-2 and Gathering Center-3 have also been scheduled at this time. dml:0235T Sincerely, - ~obert C. Yo~gmun ~anager Production Accounting Attachment CC: E. A. Dippe B. V. Dotson/R. E. Borah D. M. Webb Prudhoe Bay Field Manager RECEIVED F' i':~ .... !"id 1 ©`- 19 8 6 SOHIO ALASKA PETROLEUM COMPANY OFFICE CORRESPONDENCE TO: Manager Production Accounting DATE: February 1, 1986 FROM: Field Production Superintendent CC NO: SUBJECT: Flaring YOUR REF: Fl6 The Production Department is continuing with Phase II of the Flare & Relief Testing at GC-1 and Phase I Testing at GC-2 and GC-3. Tentative dates are scheduled for the weeks of February 10 and February 17 to conduct the testing. ,.T_ ..~ -~'-~"~ ycu ^~ ~ ~oo~ VT m ~ if' and aC GG-2 and GG-3. The flare vol~es expected are: Phase I Test: GC-2 30 ~SCF GC-3 26 ~SCF ~,~,,~ Phase II Test: GC-1 15 MMSCF GC-2 18 MMSCF GC-3 '15 MMSCF Please advise the State of our intent to flare. It will be reported on the day the testing occurs. If you have any questions, please call me. BVD:164peh cc: Prudhoe Bay Field Manager ZB. V. Do/son . AK 1009 (3 -81 ) OS-pr SOHIO ALASKA PETROLEUM COMPANY February 4, !986 900 EAST BENSON BOULEVARD ANCHORAGE, ALASKA TELEPHONE (907) 561-5111 P.O. BOX 6612 ANCHORAGE, ALASKA 99502~}612 CN: 1096 State of Alaska Alaska Oil & Gas Conservation Commission P.O. Box 8090 Anchorage, Alaska 99508 Attention: Mr. Lonnie Smith Gentlemen: Sohio Alaska Petroleum Company will be continuing with Phase Il of the Flare and Relief testing at Gather!ng Center-I, and Phase T testing at Gathering Center-2 and Gathering Center-3. Tentative dates are scheduled for the weeks of February 10th and February 17th. Estimated flare volumes are as follows: Phase I GC-2 30 MMSCF GC-3 26 MMSCF Phase II GC-i 15 MMSCF Sincerely, yobert C. You~mun ,,/Manager Production Accounting dml:0235T cc: Prudhoe Bay Field Manager B. V. Dotson/R. E. Borah E. A. Dippe, MB 1-4 SOHIO ALASKA PETROLEUM COMPANY 3111 "C" STREET, ANCHORAGE, ALASKA TELEPHONE (907) 561-5111 P.O. BOX 6612 ANCHORAGE, ALASKA 99502q3612 November 6, 1985 CN: 1064 State of Alaska Alaska Oil & Gas Conservation Commission P.O. Box 8090 Anchorage, Alaska 99508 Attention: Mr. Lonnie Smith Gentlemen: Sohio Alaska Petroleum Company will be conducting a Flare and Relief system test Phase I at Gathering Center-1 during the week of November 12, 1985 or November 19, 1985. Estimated flaring will total 16.4MMSCF. Phase II of the test will be conducted after a review of the Phase I test has been completed. We will advise of the time and estimated volumes of the Phase II testing. Sincerely, /l~obert C. You~j/mun Manager Production Accounting dml:0235T CC: Prudhoe Bay Field Manager B. V. Dotson/R. E. Borah E. A. Dippe, MB 1-4 TEST P~ ~ANU~R~ 20, ~986 . A partial system schematic of the GC-2 HP flare/relief system is shown in Attachment 1. It depicts the major components of the system as they are currently arranged. The modifications made by the LPS-] project are included. Flare/£elie'£ flow (excep2 tha~ routed to the LP fiare reiie[ header which is not shown) ~rom the original Brown and Root production separators is rou~ed to V-218 liquid knockout drum in Skid 5. All flare/relief flow from the LPS slugcatchers and compressors is routed to ~he v-7007 liquid knockout drum in ~odule 494. Flow from both knockouts to skid 40 is via looped ~0' lines. For the purposes of ~he tea~ ~he major sources of flake/relief flow are from the ~rown and ~ooC separato~ PCVs in skid 5 and irom the slugcatcher PCVs in.Skids 452,453, and 454. For simplicit~ other inputs to ~he system a~e no~ sho~n in this schematic. ., , At Skid 40 ~he flare/relief [low is prelerentially rouked for combustion first to the vertical flares via sequencinq valves, then to the 34' burn pit heade~ via a pressure control valve (~CV-U611}, and finally ~o vertical [la~es 5 and 6 via rupture discs. This assures tha~ small amo~2ts of gas are burned smokel~ssly in the vertical flares, and that only large emergency relief events are burned in the burn pit. Design set pressures of these devices are shown in Attachment 1. In the event of a failure of the pressure control valve, six PSVs will also divert flow to the 34" burnplt header. TEST OBJECTIVES The GC-2 flare/relief test and as~ociated preliminary activities have the following objectives: 1. To insure that the vertical flares are capable of burning gas at their design capacity. 2. To insure that the sequencing valves to the vertical flares and PCV-U611 are operating at their design set pressures. Anchora§o ). TO insure that all possible precautions have been taken to avoid movement of the flare/relief header system during relief events. Inspection of lowpo£nts for liquid . accumulation and the inspection of the header system for the complete installation of pipe supports is planned. 4. To monitor the life of the recently installed burn tips, and recommend appropriate system downrating or system modi~ications to avoid down~ating. S. To ~eco~mend a leak test prodedure (see below recommended p~ocedure) for the flare/relief header system so that leaking flanges can be identified and repaired. The implementation of this procedure will, as in the GC-I be at the disc~etion of the GC supervisor. 6. To obtain pressure drop data across the fla~e/~elie£ system at known gas flow~ates to insure that there are no unknown ~est~ictions in the system. These objectives will be met in three Phases: 1) Pre-test Activities 2) Testing 3) Data Analysis _FL~R.E/.RZLII~ $¥$TZM_.LZAK T.E_.ST PROCZDURZ The presence of leakin~ flanges in the flare/relief s~stem at G¢-2 has the potential of causing high ~as alarms o~ ~alon dumps in process modules during flaring events. At higher g~$ rates and incceas~ng basckpressnres leak rates will increase, A means of pressure te~ting the ~ystem on line allows the identification of leaking flanges so that repairs can be made, The current system configuration lends, itself well to a system leak test. The following basic procedure could be employed on the flare/relief sysem at GC-2 prior to testing: 1. Set PIC-U611 to the desired test pressure (0-25 psig). 2, Close the locked open valves to the number 3 flare, 3. If necessary introduce a flow of gas to the system to increase pressure, 4. Inspect the system for leaks, It may be necessary to test at low pressures first to identify the bad leaks. After repairs are made on the bad leaks t~e system would be able to hold higher pressures and the test could be repeated to identify less severe leaks,. PRm-~EST ACTIVITIES · Prior to the test the following tasks will be completed, The assigned ~esponsible q£oup(s) is listed with each task. 1. Operations Planning will p~ovide overall project coordination and will be ultimately responsible £o£ data acquisition and analysis. Operations Planning will p~ovide data sheets for all field data and also other data t~akin~ apparatus. Field ~ngineering will p~ovide assistance in the "setting up" of $CADA and PCS trend lo~s ~or the test. 2. A rough cost estimate for the test and .preliminary activities will be prepared by Operations Plaflnzng. The estimate will be submitted to Production who will provide an appropriate charge code for the work. ~. The operation of the flare sequencing valves (4,5,6) and PCV-U611 will be checked and documented by Field ~ngineering. They will also have the valves or their controllers repaired and retested (if required) prior to the test. The checkout will consist of artificially loading the pressure sensing devices and checking to see if the valves open and close at the proper pressures. Open and close stroke times will also be recoreded. Particular attention should be paid to the gap between the opening set pressure of the sequencing valve to flare 6 and the control set pressure of PCV-U611. The sequencing valve must open first. 4. Field Engineering (with the assistance of a N/S Pipe Designer) will inspect the main header system for adequate pipe supports (insuring that supports are present and properly assembled). They will also inspect the main header system for lowpoints which have not been previously identified. These inspections do not require any drafting. It is estimated that a 1--2 day walkthrough of the system after a a 1 day drawing research effort will be required. 5. The lowspots in the lines to the vertical flares will be X-rayed for liquid accumulation just prior to (no later than the day before) the test. Production will make the necessary arrangements with inspection to have this done. 6. Appropr£ate agencies will be notified of our intention toflare gas. Operations Planning will provide estimates of quantities, rates, and durations to P~oduction who will make the prope~ notifications. 7. Nine pressure gauges with high point indicators will be installed at the locations indicated in Attachment 1. This will allow pressure drop profiles of the system to be obtained. Operations Planning will provide the gauges (some of which may still be installed at Ge-1 or G¢-3 and will have to be moved). Gauge locations will be worked out by Operations Planning/Field Engineering. It is anticipated that taps for gauge installation will be available so that the actual Installation can be made by a production operator. 8. Inspection of the burn pit tips for heat damage will be made. The resistance of the newly installed tips to heat induced collapse must be determined, This will be done by Inspection/Field Engineering at the discretion of the facility supervisor. This does not have to be done prior to the test. ., 9. Field Engineering/Production will leak test the GC-1 flare system per the general procedure outlined below, at the discretion of the Faciltiy SuperviSor. This does not have to be done prior to the test. 10, The vertical flare tips will be inspected by Field Engineering/Operations Planning/Inspection if deemed appropriate by the facility supervisor. This would require a shutdown of the flare pad prior to the test to allow safe access to the flares. This does not have to be done prior to the test. !1. The gas flow meters used for the determination of flare/relief feedrates will be full'loop calibrated prior to the test. Field Engineering will w~ite the necessary work orders and insure the work i$ done. These meters are listed in the test procedure. TESTING The test. will introduce gas to the flare/relief system in a controlled staged fashion. Field data and data from the DCS and SCADA systems will be collected before, during and after the test. The actual test duration (time spent flaring) will be approximately two hours. The following are the proceduu~al guidelines used successfully on the GC-! Flare/Relief test and recommended for use on this test. 1. Set up the following points on a 1 minute hardcopy scan (available on a digital trend printout which must be set up and printed out every two two hours) in skid 7. (Field i~ngineerin9 to have responsibility for this and othe~ Skid 7 data acquisition): FI-7095 FI-?055 FI-?065 FI-B107 (A Bank Sluqcatcher Gas Flow) (B Bank Slugcatcher Gas Flow) (C Bank $1ugcatcher Gas Flow) (lst Staqe A l~ank Gas Flow) (lst stage B Bank Gas Flow) (Note: These meters and the 407 me,er below are to be full loop calibrated prior to the test.) Scan these flows a~ lined-ou~ conditions for at least two hours to get baseline da~a, du~iog the test, and afte~ the test for ~wo more hours to complete ~he baseline. ,. 2. Set Up the' Transit Gas Flowmeter (FI-407) on a one minute scan period digitial trend. This is off the SCADA system. Obtain hard copy printout~ of the data for two hours prior to, during and two hours after the test. 3. Set up a DC$ ~=oup with all of the slugcatcher and A and B bank HP 1st stage separator temperatures and pressures. Print out th~s group every half hour two hours prior to, during, and two hours after the test, 4. Station personnel to read the nine field pressure gauges points in the system. These points are ~hown in Attachment 1. One man in Skid 454, one in Skid 5, one in Skid 494, and two in skid 40 are needed. These personnel will make record at one minute intervals of the system pressure at their station. Operations planning, Field Engineering,and/or Production personnel will be assigned. 5, The two skid 40 personnel will also watch the action of the flare staging valves, and PCV-U611 and make record of valve positions, and valve opening times during the test. 6. Station a person to watch and photograph the vertical flares and to make record of flame patterns and times of staging. The variable slot flare tips are of special concern. Peculiar flame patterns may indicate "frozen" slots. Evidence of liquid carryover will also be checked for. ?. Introduce inc;ements of 9as flow to the system by opening the following separators to the flare in succession. Wait between increments at intervals long enough for steady state readings to be obtained between flow increases (app~oximately 5-10 minutes): A Slugcatcher via PV-7085B B Slu~catcher via PV-?025B Slu~catcher via Pv-70_55~ ~ Bank Separator via PV All0A Bank Separator via ~V-~ll0B The Field Engineer should be stationed in skid ? and shouZd keep a log of vhen flow [rom each separator is started to the fla~e/relief header and when flow from each separator has been ~ully diverted to the heade~. 9e should also insure at least 9-20 minutes of operation be~ore the next separator is lined to the flare. 8. Flare at maximum ra~es (continuing to process compressed r.p and IP gas in the gas plant if possible} 5-10 minutes to collect data. 9. Return to normal operation by returning separator flows to the gas plant in the reverse order, again waitin~ for 5-10 minutes between increments ~nd logging when flow transfers are s~a=ted and completed. Continue to co11~ct da=a as flow to the flare/reli~f system is reduced. DATA ANALYSIS Opera~icn~ Planning will analyze the data, make all data available in a tabulated form, and prepare and issue a final report with recommendations for future action, J.,e lO. 34" Y~OD ~' FL ie ; z E./.,-.,C E: L- / ~ F' ARCO Oil and ~ompany North Alas~.,., District Post Office Box 360 Anchorage. Alaska 99510 Telephone 907 277 56S7 October 24, 1980 Hr. Harry W. Kugler Commissioner Alaskan Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 J :3 ENG J 4 ENG I,.I '-"r":~E'Okl _ :_ I 3 C.-E6t./ I-s'rAT; t'[c ' ,i I sTAT'TE'C-- I ~ONFER: -FILF: Dear Harry' As a followup to our telephone conversation, this letter is to request an extension to December 31, 1980 of Administrative Approval No. 145.A.5 dated August 15, 1980. The initial large diameter flowline testing was completed with the flaring of approximately 24 MMCF. However, subsequent testing which requires the use of an on site computer has been delayed. It is now estimated that all testing will be complete by the end of the year. Should anyone at the Commission wish further details of the test or test results they should contact Hr. David Hoore (telephone' 265-6323). Thank you very much for your consideration. Sincerely, E. L. Berdon Operations Coordinator ELB'bjm c' D. Moore ARCO Oil and Gas Company is a Division of AtlanticRichfieldCornpany ARCO Oil and Gas f:::_,:pany North Alaska L~istrict Post Office Box 360 Anchorage, Alaska 99510 Telephone 907 277 5637 Ouly 30, 1980 Mr. Hoyle Hamilton Oil and Gas Conservation Committee Division of Oil and Gas 3001 Rorcupine Drive Anchorage, AK 99501 Dear Hoyle: I have attached a description of the Large Diameter Flowline Testing which we would like to do at our Rrudhoe Flow Station 2. As I discussed with you earlier, we are requesting an Administrative Order to cover the gas flaring associated with these tests. I hope this information is satisfactory; however, should any of your people need additional information or further briefing, they should contact David Moore of our Engineering Department (phone: 265-6323). Thank you for your consideration of this request and please call me if I Can assist in any way. Very truly yours, E. L. Berdon Operations Coordinator ELB:fh Attachment cc: D. W. Moore ARCO Oil and Gas Company is a Division of AtlanticRichfieldCompany ,' i, E.C, EIVED il LARGE DIAMETER FLOWLINE TEST Background Information The primary purpose of the large Diameter Flowline test is to determine the flow characteristics in 20" and 24" pipelines while flowing oil, gas, and water at pressures in the range of 200 to 300 psi. Beginning in 1982, this will be a common mode of producing wells which cannot produce adequately into the current high pressure (650 psi) system. The Prudhoe Bay Unit Owners feel this testing is required to evaluate certain design and operational aspects of this system. The first increment of facilities for the low pressure system has been ordered and will be installed at Flow Station 2. The 24" test pipeline is part of these facilities. The remaining facilities for Flow Station 2 will be barged in 1981. Several similar increments, each valued at around $100 million will be required to provide a field wide low pressure system. The 20" pipeline being tested is a pre-investment in the Flow Station 1 low pressure system now anticipated for the 1983 sealift. To meet the purpose of this test program, an extensive data collection computer system is being installed to allow rapid scanning of the 60 instruments monitoring the pipelines and down stream equipment. A limited amount of data collection is underway now on 12" and 16" pipelines to provide base line data and to iron out data gathering problems. The 20" and 24" pipelines are scheduled to be mechanically completed in early August. Initial testing will begin in early August and will be in the high pressure mode. The current flow station piping provides for three stages of separation (650 psi, 85 psi and 25 psi) with compression of the lower two stages up to 650 psi. The accumulated 650 psi gas is then shipped to the Central Compression Plant and injected into the gas cap. Testing the pipelines at high pressures will provide useful data but key variables (fluid velocity and liquid holdup) will significantly change in going to lower pressures. Without at least a limited amount of testing at low pressures, our test results will be of questionable value. The current plan is to have six separate low pressure tests-each at a different flow rate. We expect each low pressure test to haVe a 12 to 16 hour duration at the end of which we will raise the separator pressure back up to 650 psi and stop flaring.--'- Modifications are in progress / to allow compressing a portion of the gas to flare. However, due to the high flow rates, it is not practical to compress the entire stream. The requested volume of 275 M~SCF assumes no compression of the flared gases since we are uncertain of the gas handling capability of the revised system. Field testing of this system is scheduled for early August. The first low pressure test is expected to occur in late August. See the attached schedule for the timing of the remaining tests. They are spread out in an effort to maximize the data recovery and analysis from each test. During the time periods where no low pressure testing is underway, high pressure tests or data analysis will be conducted. The tentative plan is expected to be revised by the test engineers as test information is accumulated to assure keY test objectives are met. This may require altering the oil flow rate and duration or timing of a given test from that value shown in the attached plan. Two low pressure tests may be run back to back to evaluate the effect that rate changes have on the flow pattern and down stream facilities. However, we do not expect to exceed the requested flare volume of 275 ~ISCF. The ultimate use of the collected data is to provide a basis for exaluating and, if necessary, modifying our low pressure system design. The design engineering for the first low pressure increment (Flow Station 2) was based on a mathematical model of oil, water, and gas exiting a set of large diameter (20" to 28") pipelines. This model was based on state-of-the-art theory on multiphase flow and test data taken at Prudhoe Bay during 1978 (for which the AOGCC graciously permitted flaring). This model in turn was used in a hybrid (analog-digital) computer simulation of a flow station to determine the proper size of vessel (slug catcher) required to absorb the surges inherent in large multi- phase pipelines and provide a steady flow of oil and gas to down stream equipment. Field data taken since the purchase of the first increment of equipment shows a more complex flow mechanism than can be perceived from either current literature or the 1978 testing. We feel the current testing to further investigate the multiphase flow arena is warranted since it could affect the design and operation of the future field wide low pressure system. RECEIVED JUL '3 l,gm. Al~ka Oil & G. s ~.',r~ i..,~,~,~ssion Anchurage LARGE DIAMETER FLOW LINE TEST Sequence of Major Events Issue Purchase Order for 20" and 24" pipelines Sept Begin Construction of Laboratory Mock-up in Tulsa, OK April Complete Phase I of the Data Collection System Begin testing of the Tulsa Lab scale pipeline Begin early data collection on 12" and 16" pipelines Complete~ construction of the 20" and 24" pipelines Begin flow testing (high pressure) the 20" and 24" pipelines Low Pressure Test 1 (24") Low Pressure Test 2 (20") Complete the Tulsa Lab Testing Complete entire data collection system Low Pressure Tests 3,4,5, &6 Complete all testing 1979 1980 July 1980 July 1980 July 1980 August 1980 August 1980 August 1980 Sept 1980 Sept 1980 October 1980 October 1980 November 1980 RECEIVED Test # LARGE DIAMETER FLOW LINE TEST Low Pressure Testing Tentative Plan Oil Flow Rate, BOPD 110,000 75,000 60,000 90,000 130,000 50,000 Pipeline 24" 20" 24" 24" 24" 20" Expected Timing (3rd week) August 1980 (lst week) Sept 1980 (lst week) October 1980 (2nd week) October 1980 (3rd week) October 1980 (4th week) October 1980 A~.~ka OiJ & G;ts t',,~l'lS. L,I)Ii'ilTIj$$joi1 ,antic-RichfieldCompany North Ameri~.; ~ Producing Division Alaska Exp~" '.ion & Producing Operations / Post Office Box 360 /' Anchorage, Alaska 99510 ' Telephone 907 277 5637 Robert A. Crosky North Alaska Operations Manager November 1, 1978 The Alaska Oil and Gas Conservation Committee Division of Oil and Gas Conservation Department of Natural Resources State of Alaska 3001 Porcupine Drive Anchorage, Alaska 99501 Attention: Mr. Harry Kugler Executive Secretary Subject: Authorization to Flare Startup of Flow Station #3 Gentlemen: Atlantic Richfield Company, East Area Operator, Prudhoe Bay Unit, requests authorization to flare produced hydro- carbons and/or natural gas during the startup and commissioning of Flow Station #3. The startup of Flow Station #3 is presently scheduled to begin in early December 1978. The startup procedures which will be used at Flow Station #3 are based on the procedures and methods used in the success- ful startup of the East Operating Area Facilities in mid 1977. These procedures have been modified to reflect our present operating and well completion practices. The procedures also use our existing operating facilities to assist in the startup and minimize flaring. The general plan of Atlantic Richfield's Flow Station #3 startup plan are set out below: Prior to final acceptance of the oil and gas processing modules, Operations personnel will have placed essential utility systems in service. The Flow Station #3 oil wells at Drill Sites 6, 7, and 14 will be perforated and the diesel completion fluid in the tubing produced for a brief initial cleanup period to temporary tankage. This method will not normally surface reservoir fluids and should eliminate the need to flare reservoir fluids for cleanup prior to flowing the wells to the process facilities. After final acceptance of the oil and gas processing modules, a low pressure air test of the completed facilities will be conducted. On conclusion of the air test, the facilities will be nitrogen purged. Mr. Harry Kugler Page 2 November 1, 1978 ~nconclusion of the nitrogen purge, fuel gas will be introduced into the facilities to purge and pressurize the facilities and commission the flare system. Warm, processed crude oil free of solution gas from the A.R.Co. Oil Delivery Line will be backflowed into the plant and circulated for equipment warm up. It will be necessary to flare small amounts of the existing fuel gas blanket during this period to aid in maintaining circulation. At this point, the gas dehydration system will be warmed up by flowing field fuel gas through the gas dehydration system to flare. On successful conclusion of the above steps, well- stream fluids will be admitted to the facility at a rate which will minimize foaming, carryover and flaring while each well is warming up. During this period it will be necessary to flare second and third stage separator gas until these gas streams are of sufficient volume to allow the compressors to begin forward flow to the Central Compressor Plant where the gas will be reinjected. In summary, we intend to startup Flow Station #3 with a minimum of flaring. Flaring should be limited to the following periods during startup: A small amount of fuel gas which will be vented Or flared during startup of the flare system. A small amount of gas which will be flared to maintain proper pressure levels during facility warmup. Warmup of the gas dehydration vessels which should require about 10 MMscfd for a period of approximately two days. Well capacity ramp up to provide enough low pressure gas to begin forward flow from the compressors. The maximum flare rate should be less than 30 MMscfd. Mr. Harry Kugler Page 3 November 1, 1978 The preceding startup plan is based on our best estimate of an ideal startup sequence. It does not provide for unforeseen plant upsets, shutdowns, equipment malfunctions or other events which may impact our startup activities. Atlantic Richfield Company requests that the Alaska Oil and Gas Conservation Committee authorize the flaring of hydrocarbons as outlined in the above Flow Station #3 general startup plan beginning December 1, 1978 and continuing until thirty calendar days after the first wellstream fluids are introduced into Flow Station #3. Should you or any members of your staff require further details or information regarding this application please contact Mr. Dave Sampert, Senior Start-Up Engineer, 265-6293. RAC/TMM/bb -2- Se~~ 14, 1978 The cc~ttee requests that the Divisic~ of Oil and Gas Cc~lservaticn be notified and appraised of the gas flaring opera~~ throughout Very truly yours, }~ W. Kugler ~' Alaska Oil and Gas (~ervatio~ ~ttee SOHIO PETROLEUM COMPANY Division of Sohio Natural Resources Company SOHIO--BP ALASKA PRODUCTION DIVISION September 12, 1978 Mr. HoyleHamilton State Division of Oil & Gas Conservation Committee 3001 Porcupine Drive Anchorage, Alaska 99504 3111 "C" STREET ANCHORAGE, ALASI TELEPHONE (907) 265 MAIL: POUCH 6-6 2 : , ,, ., ANCHORAGE ALASK, i 9050~ ' " : ~,,..~! /. ,, RE: Prudhoe Bay Unit H.P. Separator Gas Capacity Tests Atlantic Richfield Company and Sohio-BP Operators Dear Mr. Hamiltc~: The Prudhoe Bay Unit Operators propose a series of high pressure oil and gas separator tests at Gathering Center No. 2 and Flow Station No. 2 commencing on September 23, 1978, as indicated in the attached schedule. The objective of the high pressure oil and gas separator tests is to define the gas capacities of our present H.P, separators with and without high surface internals in the separators. These gas capacities must be known to determine the future separation facility needs associated with the continued developments of the Prudhoe Bay field. The benefit of high surface internals in separators will be evaluated in the tests. Sohio-BP's Gathering Center No. 2 is ideally suited for this purpose. Bank C will represent an optimum internals type separator, and Bank D will represent the minimum internals type separator. The first stage separator in train C of ARCo's Flow Station No. 2 will represent a larger minimum internals type separator. Two critical unknowns will be uncovered from these tests. The first two tests will determine the minimum crude retention time in the separators. The remaining tests are aimed at resolving the gas capacities of the different type separa- tors wit~ and witl~ut antifoam chemical and at high and low pressures. Each test will require the flaring of the first stage gas. Also, during the blow-by or slippage test, it will be necessary to flare the gas from the second stage separator. The ga~ wil!%~,.,, ~..ared for f: E C ",,: operational safety, and the Division of Oil and Gas will be notified of our gas flaring operations throughout the testing period. Enclosed is a test schedule, a gas flaring schedule, a Sohio-BP test procedure, and an ARCo test procedure. Instrumentation equi~x~nt used on ARCo's Flow Station No. 2 performance test will be used for these tests. Manpower for calibrations and installations will be provided by the appropriate field operator. The tests will be performed by ARCo and Sohio-BP Field Operations, and the personnel for data taking will be provided by ARCo, Exxon, and Sohio-BP Engineering. These tests are essential in assessing the present H.P. separator caopabilities. Furthermore, t~he tests will play a major role in the develo~nent of the future separation facilities. Because of future gas production and gas lift operations, it will be necessary to increase our gas handling capabilities. Based on the above, we request your concurrence with this flaring as provided in the Conservation Order No. 145-A. If there are any questions concerning the proposed tests on the East portion of the field, please contact Mr. J.R. Schuyler at 265-6578 in Anchorage or 659-5237 in Prudhoe. Questions concerning the West should be directed to Mr. G.H. Balthrop III at 265-0348 in Anchorage. Very truly yours, AR.tA.~Ci~s~d~leld C~ Operations Manager, NA~ Sohio-BP G.N. Nelson Assistant General Manager Operations Attad~nents: 1. Sequence of Events Schedule 2. Many, mum Flared Gas Voluaes Expected 3. Sohio-BP Test Procedure 4. ARCo Test Procedure .. Sohio-BP Test Procedure , LIQUID RETENTION TIME TEST Initially, the pressure will be held to the normal first stage op- erating.pressure (approximately 600 psig.) This test will be con- sidered complete when the first signs of slippage (blow-by) are indicated on the second stage gas-off metering. Step. 1. e 3~ 5~ 6~ 7~ Reduce the proauction rate through Bank C.to 40 NBOPD. Route §a.s-off the second stage to flare. Bypass LSDL 2 Cl04 and manually operate, the shut down. Reduce the liquid level in V-201C to 2'6". Reduce the anti-foam chemical injection rate to the minimum possible. Increase production rate in 5 riBOPD increments until slippage (or carry-over) occurs. Allow enough time between increments for bank stabilization and data gathering. Repeat Steps 1 thru 6 for 'Bank D. ! ' ¢I ~... i I I I I :. !0 o. I~0 .. 70 80 So ~:. .~ PRESSURE HIGH GAS VELOCITY 'l'J" The test will be completed when carry-over is indicated. This indication of carry-over will be observed by continually monitoring a sample slip stream from the gas off line. The sample gas stream will be provided from the 1/2" tubing in- stalled as per instrumentation instruction. -Bank C- Step. 1. Set liquid level to 3' 0". 2. Adjust pressure to approximately 600 to 620 psig, whatever is the normal high pressure at that time. 3. Adjust production to 70 MBOPD and allow enough time for stabilization. 4. Reduce anti-foam chemical injection rate to the minimum possible. 5. By-pass ~SDH 2 C104 and manually operate the shut-down. 6. Increase liquid level in .increments of 3" until carry-over occurs. Always allow enough time for bank stabilization and data gathering between level changes. -Bank D- Step_ 1. Set liquid level to 3'0". 2. Adjust pressure as in (2) above. 3. Adjust production to 40 MBOPD and allow enOugh time for stabilization. 4. Reduce anti-foam chemical injection rate to the minimum possible.* 5. By-pass LSDH 2 D104 and manually operate the shut-down. 6. Increase liquid level in increments of 3" until carry-over occurs. Always allow enough time for bank stabilization and data gathering between level changes. 7. Set liquid level to 4'0". 8. Start ant-foam chemical injection and maintain at maximu'm rate. · 9. Adjust production to 80 MBOPD and allo~ enough time for stabilization. 10. Increase liquid level in increments crf 3" until carry-over occurs. (Same as 5 above). · It may not be pos. sible to operate this Bank without anti-foam' chemica Step 1. 2, 3. e 5. 6~ Y. 8~ LOW PRESSURE HIGH GAS VELOCITY TEST Step. 1. - Bank C - With the H. P. separator at normal operating pressure, set the chokes at the openings required to get 85 MBOPD at 200 psig. Divert gas to flare. Increase anti-foam chemical injection to maximum rate. Set liquid level at 4' 0". Reduce pressure in increments considered safe by operations personnel to 200 psig. Allow sufficient time for Bank to stabilize at this pressure. By-pass LSDH 2 C104 and manually operate the shut-down. Increase'liquid level in increments of 3" until carry-over Occurs. Allow enough time for stabilization and data taking between level changes. , . - Bank D - 6~ With the H. P. separator at normal operating pressure, set the chokes at the openings .required to get 75 MBOPD at 200 psig. 2. Divert gas to flare. 3. .Increase anti-foam chemical injection to maximum rate. 4. Set liquid level at 3' 0". 5. Reduce pressure to 200 ps. ig. Allow sufficient'time for. Bank to stabili.ze at this pressure. By]pass LSDH 2 D104 and manually operate the shu't-down. 8~ Increase liquid level in increments of 3" until carry-over occurs. DATA SHEET FOR SOHIO B.P. FIRST STAGE SEPARATOR TEST GATHERING CENTER BANK ~,-~ DATE !TIME (24 }m.' CLOCK) f ............. 1 .... n~q. ~'LO~ ~ emO~D) ..... . ...... ~Q, ~vE~, (F~. ~C~iEs) ......... ~' " ~o~ ~u~ C~SS) .. . sxs ~now ~E (~C~e~) OF BACK PRES. VALVE (3/4" D~'IN) (PVC].10~ & PVDll0B) tt.P. OIL S~PLE Dt~WN UP- STREz~I OF (3/4" DRAIN) LVCl08 & LUD108) o~S~WNa '~E ~n,n ~TE 0~ W~E ~X ~T~C '~C~EAS~S SAS o~ ~ ~n~ STASE S~. ~T~-~OA~ CUE~:~C~n ~a~C~t~O L~En COX~O~nE~ OU~eU~ , .. PKESSURE AT 3/4" DP~IN VALVE UPSTRE~ OF LVCl08 LVI) 108 . 3~ 4~ 5~ 6~ 8~ 9~ INSTRUMENTATION Install differential pressure cells to function as level transmitters in place of LT2CI08 and LT2DI08. Install circular pressure recorder (0-20 psig elements - 2 pens - with 24 hour clocks) on the level transmitter and level controller outputs. A. One 2 pen recorder at LT2CI08 & LC2C198 B. One 2 pen recorder at LT2DI08 & LC2DI08 Install flow recorders at FIT2CI07, FIT2C207, FIT2DI07, and FIT2D207 for a continuous measurement of the gas-off the first and second stage separators. If possible make arrangements to have the following: PIT2CllO & FIT2CI07 - 3,540 MCF/hr. 20in H20 Multiplier 20 PIT2DllO & FIT2DI07 PIT2C210 & FIT2C207 - 497 MCF/hr. 17in H20 Multiplier 50 PIT2D210 & FIT2D207 FQIT2C601 & FQIT2D601 recorded on the trend recorders at the MOC, Install gauge glass extensions on the first stage separators of Banks "C" and "D". Install ruled scale on the separator gauge glass, to read in feet and inches, the "0" or starting point 'of the rule to be even with the bottom of the shell of the first stage separators (V-201C & V-201D). Install test pressure gauges (0-1000 psig w/5 ps.i resolution and mlrror backed) at' the following locations- A. P1CllO & PIDllO or any location which would indicate separator gas pressure. B. At 3/4" drain valve just upstream of LVCI08 & LVDI08. , Install thermometers (API, yellowback type 0-220°F) in the f°llo~ing locations: TWCIO1; TWDIO1; TWCI02 & TWDI02. Prepare a calibration sheet for each of the following valves: LVCI08 & LVDI08 (see calibration sheet attached.) Install 1/2" stainless steel t~bing on the 3/4" drain valve on the upstream side of PVCllOA and PVDllOA. Route the tubing to the nearest outside location for use in detecting carry-over. CALl. BRAT]ION SttEET OII, [tP..Ar~¢ LF. VEL CONTROl, VALVE % OPi~N, AN]) A.YR PRESSURE ON DIAPtlItAGM REQUII%~;D- PROVER CALIBI>J~T:[ON t~ECO!~D SHEE~'. 8 ~, ;~';< DATE ' g h'; D T VESSEL TEST 'BY VALVE I.D. VALVE % TRAVEL, OPENIN~ 0% 25-2 50% 75'% 100% AIR PRESSURE ON DIAPP~RAGM , NOTE ANY UNUSUAL OPERATION Ot~ VALVE BELOW · o ARCo. Test Procedure LOW PRESSURE HIGH GAS VELOCITY TEST Train - C First Stage Separator Step 1. 2, 3, . 5~ 6~ 7, 8~ . ll. Set liquid level at 48". Set chokes at the forecast opening required to get 120 MBOPD at 200 psig. Divert gas to flare by reducing P18-IC to 200 psig. Run approximately 20 MMSCFD of residue gas through the inlet · manifold oil purge and into the common lines. Increase the liquid level in 3" increments until carry-over Occurs. Reset liquid level to 48". Set chokes at the forecast opening required to get. 120 MBOPD at 100 psig. Continue flaring and reset P18-IC to 100 psig. Continue running 20 MMSCFD of residue gas into the common lines. Increase the liquid level in 3" increments until carry-over' Occurs. Reset all valves and controllers to the normal mode of operation. ,,~:',l'. ''. .... ; ",'~' I' ''! ''t *~'f"l'~'."' -,','-'-~''',*,, ....' '1 -.'-.'i...*. ..... :[,;i..J.' ;:":;i. ;';.:".'~':::":';| ~'1'~,'' I'T .... ~ ....... :'''1 'i .... I''' I'~ ......... --.~q-. ..... P.... · ! ..... . . , · · ; .-. -., ........ '"; L:- :,.~' ~,..-. :.!..;.. '_L:.:.-,~-'J · ;.: I,,: :: ;i '.".i;:.i .... ., , ,,i... ! 'l .... ;''1 .... i~.',, .J;;...;..;.,;,'.,;.;;;:..',;::.; ;.;.'.;~ i ; |:';'1'...;;..":':':1':..:'.';! I,, I. ' J .... !.s, .,,.. i '~l '' ''1 .'1 '' .... ''' I''' ! '''1 ~--"--~"""'l .... l' -' :~-, ~ ............ .... ;iii!i:' i, .i .... i-'; '.J.,I .... :' '' ,..,1,.,,, , ,.~...,....~. · ' ":i .... ,,. ,,;,o., , ,,,,,I ~ ,, ~ . , I .... '. "LI ~ ..,-.* -.-- .-.o.~ ~ ¢...----q, ,.-.-* ,. -"-i '','' ' '"· *';''' I ,' ' '''' ~ ' .... , ...-*..;.* r.*.' .! - '' 'J :. ..... , ...... I ;,.j .,, '1 'l,' .' ',''' ..... ' ''*'' '' J'-"-',' ....... ~,'",','t,' .,,fl,,.,, .q~,.e""J :',i: : '. ....... ' ,~. .:'. .... · I. · . '[' ' I '!' · · I _'_,_"_ _' '_ _ _' .... ' '_ t~.:i::,:!i-.:,--' "'; .: .,.,/~'0~ :,:.: '",:,l ....";! :'~"'~ i' :: ! ~: ;':: 'I'; :'~ 1 '.'; ;'; : ,,~;~::::i ..::., '1' .,',,.:t i.: J ";:": :':; "~ :, I ,',',, t. , J_ ~,. ,, ,2, DATA SIIEET FOR ARCo.' FIRST STACE SEPARATOR TEST FLOW STATION~~ MODULE# TRAIN!/ DATE TIblE (24 tlR. CLOCK) ......... . z,:]:q F~.OW ~Tg (~'q~OP]:))' ' iLIQ. LEVEL (FT' iNC~iE'S) -~ ........... . FROM GAUGE Gl. ASS) ....... . GAS FLOW ~TE Li~:': 2'~~uR~' (F) ' ' ' ' - ' ........... ,. ...... GAs T~IPE~TU'RE' ( ,ff."'"~ skPl:::o'::: ~::s. (Ps:s) ......... P7-I .. · , .... . ....... ':1 P, GAs 'S~:{p':k'uPsTP~EAM' OF BACK PRES. VALVE (3/4" tt. P. OIL S'~[EAM OF L14V ..... ............................ C~RY-OVER WILL BE' INDICATED BY OBSEVAqNG GAS-OFF THROUGH CLOTH (CO~~S) ................... ..... . . ELAPSED TIblE BETWEEN D~S OF L27V ~T~-~O~ Cnm, I~CAL ~OECZ~OX ~Zg (OA~/PAY) ..... ......... LEVEL T~S~.'IIT TER eRESS~RE (~SI~) .......... [~ co~n~o~~ "OUS~UT ............. i ......... e~sspn~ (es~,~) ......................l: .... I~ICATIONS OF FLOW REGIME ~.o.~. ~~ ~ >. , ~-' _ './t ....... . 3~ 4~ 5~ 6. 7~ 9~ Instrumentat ion Install a differential pressure cell to function as the level transmitters in place of 1.14T. Install circular ct~art pressure recorders (0-20 psig elements - 2 pens - %.Tith 24 hour clocks) on the level transmitter and level controller outputs of L14T & L14C respectively. Install gas turbine flow meter at inhibitor injection point on gas-off the H.P. separator. Install a circular chart pressure recorder,(0-20 psig element with 24 hour clock) on the pressure controller P18IC. Install test pressure gauges (0-1000 psig with 5 psig resolution and mirror backed) on the ~. P. Separator P7I. Install thermometers (API, yello~.~ back type 0-220 F)'in Tg~.~ T16::;. Jumper out the high level shut-down 1,2S. Prepare .a calibration sheet for ~ach of the following valves: L14AV, L14BV and P18V. · Install 1/2" tubing on the 3/4" drain valve on 'the nps,tream side of P18V, route to a location convenient for venting during rag test. Install two nuclemr densitometers on the common lines connected to · Train - C as in the performance test. }!ount one on common line B from D.S. #3 and one on common line B from I)S #9. il. Install a circular chart pressure recorder (0-20 psig element %~itl~ 3 hour clock) on the }1. P. scrut~ber liquid pot level controller Output L27C. · ~%Co./SOH!O ~.P. Ist STAGE 5EPAF.7,TOP. TF.?TS ~ ....... AUGUST.~ ~ P4 25 26 27 2.q 29 ~n 31 ! 2 ?-,eta:'.-Cicn Tir. c Bank C R;.::~cntio:; Time Bank D 'High Fre~c-'.ure Bank C }.'.igh Prcss:.:r~ Ban:: P iow 7-;:,z?su.re ~ank C Lcw 2ressure Sank D Testing Schedule MAXIMUM FLARED GAS .VOLUMES_]EXPECTED. TEST ~ank D Low ?ressure . , Train C Low ~ressure DURATION~ AVERAGE RATE CHOreS) (ZBOPD) GAS VOL%~.E (~scF>. % · . 12 6O 21 . 12 12 60 7O 85 120 · TOTAL GAS ~LA~ED = · 12 21 17 19 30 27 4O 175 MBOPD -- Thousands of' barrels of oil per day MMSCF -- Millions of Standard Cubic Feet Date Time ''14/78 1645 - 1945 ATLANTIC RICHFIELD'COMPANY . = CONSERVATION ORDER Ng. 145 GAS FLARING INCIDENTS~L CCP/FFGU , Description of Volume-MCF Incident & Cause 9,170 High stage compressor #1812 went down unexpectedly on high exhaust gas temp. This was one of three high stage compressors 'on line at the time. j C. GEOL~ I . c. ENG' --"-~-i-~. 4 i~:..i~ 5 ENG 2 a~OU 3 GEOL Action Taken to DRAFT Eliminate Cause sec CONFER: FILE: Z~ed~e~ ~emg~ed ~o Volume flared in excess of measured safety pilot Measured Safety Pilot Volume TOTAL FLARED VOLUME 9,170 25,135 34,305 ATLANTIC RICHFIELD COMPANY CONSERVATION ORDER NO. 145 - A GAS FLARING INCIDENTS - FLOW STATION NO. 1 Date Time Vo lume-MCF Des crip~ion of Incident & Cause Action Taken to Eliminate Cause ~ ~!4/78 2015 - 2145 554 Flow Station shut down due to Control Power Plant outage. Flared gas due to shutdown and starting compressor. Placed emergency power in service and Power Plant back on line. Volume flared in excess of measured safety pilot ~sured Safety Pilot Volume 554 16,609 TOTAL FLARED VOLUME 17,163 ATLANTIC RICHFIELD COMPANY CONSERVATION ORDER NO. 145 - A GAS FLARING INCIDENTS - FLOW STATION NO. 2 Date Time Volume-MCF Description of Incident & Cause Action Taken to Eliminate Cause Volume flared in excess of measured safety pilot Measured Safety Pilot Volume 20,011 TOTAL FLARED VOLUME 20,011 DATE TIME 4/14/78 2011-2136 4/27/78 0845-1500 4/29/78 1233-1253 SOHIO PETROLE~4COMPANY CONSERVATION ORDER NO. 145 - A GAS FLAR1/~G /NCIDEW~ REPORT - GATHERiNG~~. APRIL-, 1978' . . 6,480 481 135 DESCRIPTION OF INCID~ & C~;JSE Power Failure at power plant . Loose wire on CircUit Ground Fault Shut Down 'A~iON TA_k~q TO EL~V~NATE CAffJS E Loose Circuit repaired Wire repaired Repaired loose wire Volume FlaredinExcess of Measured Safety Pilot Volume 7,096 Measured Safety Pilot Volume 25,750 TOTAL FLAREDVOL~ 32,846 _ SOHIO PETROLE~4 COMPANY CONSERVATION ORDER NO. 145 - A GAS FLARING'INCIDEk~ REPOR~ - GATHERING CENTER NO. 4/4/78 4/14/78 4/23/78 1610-2400 2011-2136 . 1602-1615 4/25/78 0308-0320 11,800 128 89~ 82 April, 1978' DESCRIPTION OF . INCIDL~NT & CAUSE Loss of Antifoam pump to "D" Bank, carry over caused high level & cc~pre~s~Dr~ shut down Failure at power plant cC~Pressor shut down on low flow signal ~ "A" Bank shut down - lost both LP om~ressors 4/30/78 0100-0145 Volume Flared in Excess of · Measured SafetyPilot Volume Measured Safety Pilot Volume TOTAL FLARED VOLU~. 6,400 18,499 27,901 46,400 Controls commissioning/calibrating 407 Loop back pressure controller ACTION TAKFxN TO ELIMINATE CAUSE Changed out pump and restarted cc~pressor Repaired· loose circuit Restart cc~pressorS.. Restart compressors. DATE TIME 4/11/78 0001-2400 4/12/78 " 4/13/78 " 4/14/78 " 4/15/78 " 4/16/78 " 4/17/78 " 4/18/78 " 4/19/78 " 4/20/78 " 4/21/78 "- 4/22/78 " 4/23/78 " 4/24/78 " 4/25/78 " 4/26/78 " 4/27/78' " .4/28/78 " 4/29/78 " 4/30/78 " SOHIO PETROL~L¢4 COMP~2~f CONSERVATION ORDER NO. 145 - A GAS FI2LRING INCIDENT REPOR~ - GATHERING CENTER NO. APRIL,-1978 5,221 16,229 8,136 816 777 1,032 615 547 549 607 720 910 814 792 1,047 935 3,049 611 533 443 DESCRiPTION OF INCIDL~qT & CAUSE ' ELIFk-/~kTE CAUSE 44,383 SOHIO PETROLEUM COMPANY Division of Sohio Natural Resources Company 3111 "C" STREET ANCHORAGE, ALASKA TELEPHONE (907)265-0000 SOHIO-BP ALASKA PRODUCTION DIVISION MAI L: P. O. BOX 4-1379 ANCHORAGE, ALASKA 99509 · March 9, The Alaska Oil & Gas Conservation Committee Division of Oil & Gas Conservation Department of Natural Resources State of Alaska 3001 Porcupine Drive Anchorage, Alaska 99501 Attention: Thomas R. Marshall, Jr. Executive Secretary Gentlemen: In accordance with Rule #5 of Conservation Order No ~... .1.4 5-A.,......~' the Sohio-BP Alaska Production Division of Sohio Petroleum Cc~pany~"'-W~'~t Area Operator, Prudhoe Bay Unit, hereby requests authorization to flare natural gas during the commissioning of Gathering Center #3. This conl~issioning is expected to begin during mid-April, 1978. The basic start-up and co~missioning program as was used for Gathering Center #2 and described in the November, 1977 report "Prudhoe Bay Unit West Operating Area Con~issioning Report, Gathering Center 1 - Gathering Center 2" has been revised to further minimize the volume of gas flaring attendant with the initial facility start-up. The major problems encountered during the cc~- missioning activities at Gathering Centers ~1 and ~2 have been resolved in advance for Gathering Center #3 with appropriate improvements and modifications of the facilities. The operating crews and con~issioning team that have been assigned to start-up Gathering Center ~3 consist primarily of individuals who participated in the cc~missioning and start-up activities at Gathering Centers ~1 and/or #2. The start-up program to be used for Gathering Center. #3 is described in the following paragraphs. The final sections of the plant are scheduled to be handed over from construction to the operating group on April 1, 1978. In advance of this date all utility systems (diesel fuel, fuel gas, emergency generation, instrument air, MEG heating, fire water and potable water) will be commissioned and operational. AGO 10023324 The Alaska Oil & Gas Conservation Ccmmitt~ 5~rch 9, 1978 Page 2 Subsequent to final handover on April 1, but prior to introduction of first oil into Gathering Center #3, the follc~ing systems will be ccmm%issioned: oil cooling water system, fire and gas detection systems, Halon fLre protection system, wet gas dryer system, flare pilot systems, flare purge system (using N2), TEG/compressor cooling water system, TEG circulating and regeneration system and compressor lube and seal oil system. Also, after handover, but prior to introduction of first oil, all plant piping and vessels will be N2 purged, following which high pressure leak testing will be performed using fuel gas at pressures approximating normal operating pressures. This period prior to first oil will also be utilized to make final equipment alignments and make final instrument and control checks. It is estimated that approximately 17 days will be necessary after April 1 handover to accomplish the activities outlined above prior to the introduction of first oil. No gas will be flared from produced wells during this period; however, a small unestimable volume of fuel gas will be vented and/or flared in association with the high pressure leak checks mentioned above. Flaring on a continuous basis of gas from produced wells will be necessary from the introduction of first oil until commissioning has progressed to the point of successfully starting up and operating one IP and one LP compressor. The period of continuous flaring will proceed through three phases of development as follows: Phase I - A single well through the test train, will be produced to clean-up and warm-up the well and cc~nission the test bank controls, shipping pump, burn pit flare/relief syste~, and related equipment. After the well temperature has risen, stabilized, and a short test has been run at approximately 10 MBOPD, three wells will be produced to clean-up and warm-up one bulk bank, increasing the oil rate to approximately 35 MBOPD with all off gas continuing to go to the burn pit flare. Subsequent to this, a sufficient rate of gas will be available to shift from the burn pit flare and safely con~ission the Coanda flares and flare system. During the period involved in commissioning the Coanda flares and flare system, the original three wells brought into the bulk bank will be diverted to and tested through the test bank and two additional wells will be introduced to bring the bulk bank up to design throughput and warm-up and clean-up additional incoming oil. The oil rate at this time would be expected to be approximately 75 MBOPD and maximum gas rate of approximately 52 ~CFD flaring to the Coanda flares. Total estimated time to achieve this phase of the commissioning program is three days under ideal conditions, without allowance for interruptions and delays caused by unexpected shutdowns and unforeseen equipment malfunctions. Phase II- With the Coanda flares and flare system stabilized and operating normally and oil and gas flare throughput rate of approximately 75 MBOPD and 52 MMCFD, respectively, from six producing wells, the following 24 hours will be directed to con~issioning the TEG high pressure gas dehydration facilities and establish delivery of AGO 10023325 The Alaska Oil & Gas Conservation Cc~mittee ~.~rch 9, 1978 Page 3 dehydrated high pressure gas to the Central Ccmpression Plant via the gas transit line. Having successfully achieved this step, the only gas going to flare ~uld be LP and IP gas from 2nd and 3rd stage separation plus the supplemental quantity of HP drive gas necessary to properly operate the Coanda flares and achieve a smokeless burn. At the same maximum oil rate (75 MBOPD), flaring ideally would be reduced to a rate of approximately 15 MMCFD consisting of LP, IP, and supplemental HP drive gas for the flares. During this period it will also be necessary to carefully conm~ission the standby flare control system whereby all gas is diverted frcm the gas dehydration facilities and routed to the flare system. Total tL. me to achieve this phase of the ccmm~issioning program is expected to be two days under ideal conditions. Phase III-With the oil throughput held at 75 MBOPD and only the LP, IP, and H~ drive gas going to flare, the IP and LP compressor will be con~,~ssioned. Until one IP and one LP machine have been successfully cc~issioned, flaring will continue at approximately 15 ~/ED. This rate of flaring is necessary in order to have sufficient LP gas available to con~nission the LP compressors, maintain stable plant operations, and stay above the turn-down rates for stable operation of the gas dehydration facilities. Upon successful completion of this phase of cc~missioning, oil throughput will be approximately 75 MBOPD and continuous flaring will have ceased. The estimated time to achieve this phase of the con~nissioning program is nine days under ideal conditions. In s~, during the three above phases of continuous flaring, it is estimated that approximately 14 continuous operating days are expected to be required under ideal conditions to eliminate continuous flaring. The maximum oil and gas flaring rates during this period are expected to be 75 MBOPD and 52 MMCFD or less. The flare rates are based on a 700 C~DR and do not take into account deductions for plant fuel and pilot/purge gas, so these volumes will effectively reduce the rates going to flare primarily during the period when all gas is being flared. Following cessation of continuous flaring, con~issioning activities involve bringing the remaining oil wells on stream (involving clean-up, warm-up, and testing for each well), commissioning the r~naining pair (one LP and one IP) of compressors, commissioning the second gas dehydration train, and com- missioning the remaining three bulk separation banks. The foregoing program is based on an ideal sequence of start-up events and commissioning activities with no allowance for the inevitable unforeseen plant upsets, shutdowns, and equi~nent malfunctions which can delay the progress of commissioning activities. AGO 10023326 The Alaska Oil & Gas Conservation Cc~mittee March 9, 1978 Page 4 Therefore, it is requested that the Alaska Oil and Gas Conservation Committ~ authorize the flaring of such quantities of gas as are required under the general cc~missioning program outlined above for Gathering Center #3. It is further requested that such authorization be effective April 1, 1978, and extend to cover a period ending one month after the introduction of first oil into Gathering Center #3. GNN/nl Very truly yours,~ G. N. Nelson Assistant C~neral Manager - Operations AGO 10023327 AGO 10023322 '~,~ December 21, 1977 NOTE TO CONSERVATION ORDER 145 FILE On Wednesday December 21, 1977 I called the office of Mr. B. Richard Edwards with a request that he return the call, Mr. Edwards was not in. I talked to his secretary and told her that I was inquiring about an enclosure, with Mr. Edwards' letter of December 1, 1977, which never arrived in our office. She indicated that it was probably her fault that the attachment had not been made and that she wOuld place it in the mail to us today and if that was the only reason I was calling, she would take care of that. I told her that was the only problem I had and we.would be awaiting the arrival of the attachment. O. K. Gilbreth, Jr. Public Hearing Conservation Order No. 145A November 29, 1977 9:00 AM Speakers: O. K. Gilbreth, Chairman, Alaska Oil and Gas Conservation Cc~m.~ittee Tc~ ~arshall, Executive Secretary., Alaska Oil and Gas Conservation Mark Singletary, Regional Attorney, Atlantic Richfield Cc~any Cecil Chapman, District Facilities Engineer, Atlantic Richfield Company Kenneth F. Chadwick, ~3nager of Production, BP Alaska Inc. Louis Berdon, Operations Coordinator, Atlantic Richfield Company John Reeder, Pegional Attorney, BP Alaska Inc. Hoyle Hamilton, Member, Alaska Oil and Gas Conservation Committee Public Hearing Conservation Order No. November 129, 1977 9:00 k~ 145A MR. GII.BRETH: C~xxt morning, ladies and gentlemen, we apologize for the cold delay in the hearing. Mr. ~arshall tells me that between the time we made arrangements for this hearing this morning that the city changed their procedures in opening this building and we didn't know that unfor- tunately, so he had to run find a key for us to get in. This is a public hearing being held on the motion of the Alaska Oil and Gas Conservation Cor~ittee to hear testimony to determine the pro}..w~r amount of gas to be flared as safety flares at producing and related facilities in the Prudhoe Bay Field and other matters relating to gas flaring in the field. With me this morning is the Conservation Committee. On my right, Mr. Hoyle Hamilton, member of the con~nittee, on n~ left, Mr. Tom Marshall, executive secretary of the conmittee, and my. name is O. K. Gilbreth, chairman of the cor~nittee. On Mr. Marshall's left is ~lr. Jeffrey Lowenfels, attorney with the Attorney General' s department for the State of Alaska. The authority to hold this hearing is found in Title 11, the Alaska Administrative code 22.540. Notice of the hearing was published in the Anchorage Daily News on November 12, 1977 and that notice read as follows: -1 Notice is hereby given that the Alaska Oil and Gas Conservation Con%~ittee on its ~A~ motion will hold a public hearing to determine the amount of gas that is necessary to be flared in order to purge and maintain safety flares which ignite gas vented fr~m vessels and lines under pressure in the event of an operational upset, fire, or unforeseen catastrophe. Other m~Itters that relate to gas flaring in the Prudhoe Bay Field will also be heard, such as the relationship of flaring to the function of production equipment. The hearing will be held pursuant to 11 AAC 22.540 and will be held at 9:00 AM in the basement of the Pioneer Schoolhouse, Third and Eagle Streets, Anchorage, Alaska on November 29, 1977. MR. GILBRE~{: Since it is now 9:23 ~ we are a little bit late in starting. I've been advised that the Atlantic Richfield Company and BP Alaska have testimonv to offer this morning in this case. Now the conservation cc~mittee had also advertised another case to be held immediately after this one or at 11:00 AM, whichever came first, and I'd like to ask ~. Marshall to report on that hearing at this time. ~. MAP~HALL: Mr. Chairman, the hearing on Conservation Order 145B was cancelled by re.quest of the operator. I believe the exact phrasing was it was suspended indefinitely and therefore we will not have hearing on that order 145 B at 11:00 o'clock this morning. -2 MR. GII,BRETH: That hearing was at the r .equ~ est of the operator and it will be placed in suspended status. Insofar as the testimony today is concerned we have been advised that Atlantic Richfield and BP have testimony to offer. Any other .party who wishes to testify or make a statement should, give his name to Barbara Morgan sitting at the end of the table here with the recording equipment. And you will be added to the list of witnesses in the order that your request is received. As a basis for this hearing TAPS pipeline began accepting oil from the Prudhoe Bay Field on or about June the 20th of this year. Since that time numerous events have occurred which have caused interrUption in the flow of oil in the pipeline itself and in the various field facilities. The cc~nittee has recognized that due to these interruptions and conmtissioning of all new equipment in the field that it has been necessary to flare gas in excess of the volume that normally would be required for safety pilots. Now with five months of operating history in the field, the conmittee feels it is timely to review these data in order to establish meaningful rules regarding flaring and future operations at Prudhoe. The committee will receive both sworn testimony and unsworn statements. It will give greater weight in its deliberations to the sworn testimony. When anyone is testifying or making a statement we request that they use the recording microphones located in the front of the room. Each witness is asked to state his or her name and who they represent. Each witness will also be asked to give their .qualifications if they wish to give expert testimony. Witnesses will be subject to questions by the cc~mittee, however, this is a data gathering hearing and not an adversary hearing. M~mbers of the audience will not be permitted to ask questions to the witnesses directly. Should you wish a question directed to a witness please write it do%~ and give it to ~rs. Morgan, seated at the end of the table. Be sure to indicate to whc~ your question is directed. Before the end of the hearing, the cc~mittee will review these questions and ask those that they believe will be helpful in eliciting information needed by the cc~mittee. All questions will be included in the hearing. If the cc~mittee declines to ask a question submitted by the audience, ~ will state on the record its reasons for not asking the question. Anyone wishing to submit a written statement at the conclusion of the oral testimony may do so until the hearing record is closed. The time proposed for the hearing record will be announced just prior to the end of the hearing. Before we start the testimony today let me ask if there are any .questions frc~ anyone in the audience that doesn't understand t2~e way we plan to carry. out the hearing? There being none then, are the operators ready at this point to present their...? MR. S INCJ~ET~Y: We are, ~r. Chairman. MR. GILBRETH: All right, would you proceed, Mr. Singletary? MR. S INGLETARY: Oki/. Mr. Chairman, msmbers of the cc~mittee, representatives of Atlantic Richfield Cc~pany and BP Alaska Inc., acting in their capacity of the Prudhoe Bay Unit are here today for purposes of presenting testimony in response to your notice of hearing dated November 12, -4 1977, concerning the conservation of gas in the Pr~3_dhoe Oil Pool. For the record, I am Mark Singletary. I am a ~ in good standing of the Alaska Bar Association and have served as Regional Attorney for Atlantic Richfield Cc~pan~v in Anchorage since January of 1971. Subject to your concurrence, I have a brief introductory statement which I have been authorized to make on behalf of the working interest owners of the Prudhoe Bay Unit and let me introduce our witnesses for purposes of establishing their credentials as experts in presenting the balance of our testimony. Both Atlantic Richfield Cc~pany and BP Alaska Inc. have found it necessary to flare certain .quantities of gas produced frcm the Prudhoe Bay Field and generally for reasons of safety in the further exploration and development of the field including more recently the cor~issioning testing, and purging of the production facilities, we are con~itted to the conservation of this valu~31e natural resource; and we are satisfied~ that our presentation today will confirm this con~i~nt. This Committee issued its first Pool Rules in early 1970 for production and drilling operations in the Prudhoe Bay Field, and has consistently utilized identical language with respect to the venting or flaring of gas in each succeeding revision of these rules. . Rule 8 currently reads as follows: "The venting or flaring of gas is prohibited except as may be authorized by the Corm%ittee in cases of emergency or operational necessity." From the discovery of the field in 1968 until June of 1977 there was -5 essentially no production other than that necessary for the Crude Oil Topping Plant (COTP) cwned by Atlantic Richfield Ccmpany and F~on Corporation and a small amount of gas production used as fuel for operation of the Central Power Station. The Cc~mittee has issued a number of conservation orders allowing the flaring of certain .quantities of casinghead gas resulting frcm the processing of crude oil at the Crude Oil Topping Plant. Although the matter of the COTP is a separate situation apart frc~ the production facilities for the Prudhoe Bay Unit, those orders dealing with the COTP are illustrative of the Cc~ittee's continued involvement and commitment to the conservation of natural gas from the Prudhoe Bay Field. With the ccmpletion of the construction of production, treating, processing and related facilities in the Purdhoe Bay Unit, including the first %~o Flow Stations and Gathering Centers and the Central Compressor Plant, and with the startup of the TransAlaska Pipeline System imminent, the Con~ittee authorized the Operators to flare gas necessary for the essential but limited purpose of cc~missioning, testing and purging these new facilities pending the further orders of this Committee. The field has been on production for five months and the initial facility operating problems and need for flaring of gas have been largely identified by the Operators. It is therefore appropriate at this time to establish the quantities of gas needed for safety pilot and purging purposes in the field on an ongoing basis, establish basic ground rules under which the Operators will be permitted to flare gas under conditions of emergencies or operational necessity, and the conditions under which the Operators must report these incidents to the Committee. At the -6 conclusion of this hearing we will present to you proposed rules which we believe set high, but achievable standards for the Operators in their efforts to conserve gas and would ad ~equately protect the interests of the State in the conservation of gas. Before the Working Interest C~mers and the Operators co~Lld develop a proposed rule regarding flaring for the Prudhoe Bay Field, basic policy had to be formulated keeping in mind the prior rulings of this Cc~mittee, our .operating e .xperience, as well as the unique characteristics of the Prudhoe Bay Field. After considerable discussion and thought among the Operators and the Working Interest Owners, the following policy has been agreed upon: The Working Interest Owners have directed the Operators to maximize the conservation of gas and to seek rules frcm this Cc~mittee permitting the flaring of gas only for the following reasons: (1) for safety pilot and purging purposes; (2) for emergencies; and (3) those volumes required as a result of operational necessity in the shutting down or starting up of facilities or for a reasonable period of time to analyze and correct a malfunction. Thus with respect to operational necessity, the Working Interest C~ners have directed the Operators to limit flaring to that required as a result of the shutting down or starting up of a facility or to analyze and correct minor malfunctions, unless the Committee gives approval to additional flaring for a specific purpose. In the presentation which follows, ~.~. Cecil Chapman of Atlantic Richfield Company will describe the design, gas handling capability, -7 and operating parameters of the ARCo operated Flow Stations, Central Compressor Plant and Field Fuel Gas Unit. His presentation will be followed by that of ~. Ken Chadwick of BP Alaska Inc. who will similarly describe the Gathering Centers operated by it. Mr. Louis Berdon of Atlantic Richfield Cc~pany will then outline the necessities for flaring within the policy guideline I have just stated. Finally, ~r. John Reeder of BP Alaska Inc. will present proposed conservation rules to the Corm~ttee for its consideration. That concludes my statement, ~r. Chairman, and now, with your concur- rence, I ' d like to introduce Mr. Chadwick, Mr. Chapman, Mr. Berdon, for purposes of their presenting to you their credentials as ext~ rt witnesses. MR. GILBRETH: Thank you, Mr. Singletary. MR. SINGI.~ARY: Gentlemen, now step forward and read their... MR. CHAPS~: ~r. Chairman, members of the Conm~ttee, my name is Cecil Chapman. I am eaployed with Atlantic Richfield Cc~pany as District Facilities Engineer for the North Alaska District. I joined Atlantic Richfield in 1956 after graduation frc~ Texas A & M University. I hold Bachelor of Sciences Degrees in Petroleum Engineering and Chemical Engineering and am a member of several technical and professional societies. Prior to moving to Alaska in 1969, I acquired drilling, production, reservoir and project engineering expe~, rience in various lower 48 locations. I^~ile in Alaska, my work has been concentrated on development, startup -8 and operation of the Prudhoe Bay Field. In my present capacity, I am responsible for project engineering, operations engineering and develop- ment planning for surface facilities in the ARCo operating area of the Field. MR. CHADWICK: Mr. Chairman, members of the committee, my name is Kenneth F. Chadwick. Myposition is manager of production for BP Alaska Inc. ~I went to school at the University of Exerter in Denton where I graduated with a degree in Physics and ~l~thematics in 1951. I have been actively engaged in production operations in the oil industry since 1953. I have been withBritish Petroleum since February of 1959. I have been associated with the develo~t of the production facilities at Prudhoe Bay inter- mittently since 1970. I presently .handle the production division and am responsible for the direction of oil production related activities in the west operating area of the Prudhoe Bay Unit. MR. GILBRETH: ~. Berdon. MR. BERDON: My name is Louis Berdon. I am Operations Coordinator for Atlantic Richfie!d's North District Operations. I received a B.S. Degree in Petroleum Geology in 1957 and did some graduate work at Louisiana State University. I immediately went to work in field operations with Texas Eastern Gas Transmission Company and spent several years with that company and later Sinclair Oil and Gas Company in gas measurement, .quality control, instrumentation and well -9 testing. Subsequently, I held various positions in field operations involving direct supervision of gas production, gas gathering and gas plant cc~pressor and process operation and maintenance. I was transferred to Alaska in 1969, and since July of 1969 when initial Prudhce Field development operations were established at Prudhoe Bay, I have been involved in ~.~st phases of the Atlantic Richfield Prudhoe Bay Operation; directly supervising in the field for 3'l/2'~years as Operations Supervisor and Field Coordinator at Prudhoe Bay and then in staff functions in Anchorage as District Production Supervisor, Training Coordinator and ~Operations Coordinator. ~aile serving in staff positions in Anchorage I was involved in much of the operational design review of the present Atlantic Richfield facilities. My present position as Operations Coordinator, which I have held since February 1975, is involved with assisting in the management and coordination of the Prudhoe Unit operation primarily in matters associated with gas. ~R. GILBRETH: Will the cc~ttee accept Mr. Berdon's testimc~y? ?..~' : Mr. Chairman, I move that they be accepted as expert witnesses for purposes of presenting testimony for this con~ttee. MR. GILBRETH: Would you have the witnesses stand then and we'll have Mr. Marshall swear them in? -10 MR. MARSHAT.T.: Will you raise your right hand. In the matter now at hearing do you swear to tell the truth, the whole truth and nothing but the truth, so help you God? AT.T.: I do. MR. MARSHAT,T.: You may be seated. MR. GILBRETH: You may proceed, Mr. Singletary. MR. CHAPMAN: Atlantic Richfield Company has been designated Operator of the Prudhoe Bay Unit East Area. The wells in this area are directionally drilled frc~ strategically located drill sites. Six sites are in operation at present, with anticipated future expansion to fifteen. Exhibit 1 shows schematically directional drilling from a typical drill site. Individual drill site lines connect each well to its respective drill site manifold. At the manifold, which is housed in a building adajacent to each site, production from all wells at that drill site is presently cc~bined into two cc~aon flow lines for delivery to a Flow Station. Well tests are performed at each drill site using a test separator housed in the sam~ building as the drill site manifolds. Exhibit 2 is a map of the ARCo-operated area. Flow Stations 1 and 2, respectively, serve the central and eastern .portion of the area. A future separation facility, Flow Station 3, is planned to serve the -11 western portion of the ARCo-operated areas. At the flow station, the well fluids are separated into crude oil, gas and water. The crude oil is delivered through an oil gathering system to the Alyeska Pipeline Service Cc~pany Pump Station 1. The gas is dehydrated and delivered through a gas gathering system to the Central Cc~pressor Plant. The produced water is injected into a water disposal well which is located adjacent to each Flow Station. The Central Compressor Plant. (CCP) handles produced gas frc~ both the ARCo and BP operating areas. The gas is ccmpressed through two stages and injected into ten gas injection wells, which are completed in the Prudhoe Oil Pool gas cap. The CCP will ultimately have a total of twelve compressors, eight first stage and four second stage. The Field Fuel Gas Unit or (FFGU) is housed in separate modules a safe distance frcm the CCP. It is connected to the CCP by utility hallways. Feed gas for the FFGU is taken frc~ the interstage header at the CCP during normal operation; however, during emergencies, CCP shut downs, feed can be taken by reverse flow of a gas injection well. The gas is conditioned and delivered for fuel to both operating areas plus the first four Alyeska pump stations. Exhibit 3 is a simplified flow schematic which traces the oil, water and gas flows from the wells through a Flow Station, the Central Ccmpressor Plant and the Field Fuel Gas Unit. The purpo~ se of a flow station is to separate crude oil, gas and water. Both Flow Station 1 and Flow Station 2 -12 are presently designed to process 360,000 barrels per day (BPD) crude oil, 495,000 million standard cubic feet per day (MSCFD) of gas (1375 GOR) and 13,000 BPD of produced water in three equally sized separation trains. Well fluid enters the flow station through common flowlines frc~n the drillsites, and is then diverted into one of the three parallel separation trains. Initial separation of gas and liquids takes place in the High Pressure (HP) separator. Normal operating conditions are 650 psig and 170° F. Liquid frc~ the HP separator is routed to the Intermediate Pressure or (IP) separator with the gas going to the HP gas conditioning section. Three-phase separation of oil, water, and gas occurs in the IP separator. Oil from the IP separator then enters the treater flash. Water from the IP separator is routed to a produced water drum for the third stage of separation. Normal operating conditions of the IP separator are 85 psig and 153° F. The flash drums and electro-static treators operate as a unit at 25 psig and 151° F. Gas separates in the flash drum and enters the Stock Tank Vapor or (STV) gas system while oil and/or oil-water emulsion flows by gravity to the electrical coalescing section of the treater. The treater water is combined with water frc~a the other separation trains and is dumped to the produced water drum. Crude oil from each of the three parallel treaters is routed to a con,on crude oil surge drum which operates at 148°F and 1.5 psig. -13 The crude oil is t~en pumped through an oil gathering system to the Alyeska Pipeline Service Cc~pany origin station. The water handling facilities at each flow station inject the produced water into a water disposal well located at each of the facilities. Flow station gas facilities are installed for recovery and conditioninq of HP, IP, Treater and Stock Tank Vapors to permit transfer to the CCP for injection into the Prudhoe Oil Pool gas cap. This is a conservation measure of major proportions. Feed gas to the HP gas conditioning facilities is gathered frcm the oil separators at three different pressure levels; HP gas at 650 psig, IP gas at 85 psig, and STV gas at 1.5 psig. Treater and oil surge tank vapors are combined as Stock Tank Vapor or (STV). IP and STV gas is compressed, cooled, and ccmbined with }~? gas frcm the HP gas scrubbers. The resulting total HP gas can then be split between two 50% (247.5 ~CFD each) gas conditioning trains rated~ and these trains are rated; for delivery to the Central Compressor Plant, while condensed liquids are recycled to the oil facilities. Each gas conditioning train consists of five parts: . e Two HP gas coolers, each consisting of two air-cooled, force draft bays in parallel control of hydrocarbon dewpoint. Residue gas scrubbers and gas filter/separator from which separated, hydrocarbon condensate is flashed to the IP suction scrubber and water is routed to the produced water drum. -14 3. Glycol contactors and associated glycol knock out drums where the wet gas is dehydrated to minus 40° F water dewpoint by contact with triethylene glycol (TEG). 4. Residue gas heaters to maintain the residue gas stream at a level about 10° F above its hydrocarbon dewpoint at the entry to the Central Cc~pressor Plant. 5. A glycol regenerator package to reconcentrate the T~G solution. Ingersoll-Rand multistage centrifugal cc~pressors are utilized for both STV gas and IP gas compression. Each unit is a six-stage horizontal- type cc~pressor. The two STV gas cc~pressors are identical and the two IP gas compressors are identical for ease of operation and maintenance. The flow station gas facilities have the capability of handling a design rate of 495 ~CFD with one of the two STV/IP compressor/turbine sets out of operation. Normally one turbine drives one STV and one IP compressor at full loading on each. The second turbine is on standby service wit/~ no load on either of its ccmpressors. The design capacities are 15 ~CFD and 55 ~4SCFD for the STV and IP compressors, respectively; therefore the STV gas is 3% and the IP gas is 11% of the total flow station gas capacity. C~neral Electric LM 1500 gas generators were selected to drive Ingersoll-Rand power (hot gas expansion) turbines. This generator/ turbine set has the capability of producing over 12,000 HP at site conditions of 40°F and sea level. Upsets in operating conditions or failure of mechanical devices that cause flow interruption can result in a surge condition in a ccmpressor. -15 A surge condition must be avoided at all times or it will cause extensive damage to the cc~pressor, requiring costly repairs and down~. Therefore, an antisurge recycle loop protects each cc~pressor. This feature permits recirculation of discharge gases back to the cc~pressor suction to insure inlet volume avails. Extremely sensitive differential pressure and flow elements using very rapid-response instrumentation, control the antisurge control valve. The control valve is closed during normal operations; however, during startup operation or upsets in flow condition, the control valve will recycle part or all of the capacity of the ccmpressors to avoid a compressor surge condition, thus minimizing the need to flare gas until stabilized cc~pressor suction volumes are available' In the event of fire, power loss, or equipment malfunction, and during startup operations, HP gas contained in a flow station must be discharged for the protectic~ of life and property. The flow station flare system will safely and cc~pletely burn this gas. Additionally, process piping and process vessels are protected by relief valves. All reliefs are sent to the flare system for proper disposal. Exhibit 4 is an aerial vie~ of a flow station flare. The Flow Station Flare System consists of several burners mounted on multiple horizontal headers near ground level over a lake area. Two parallel systems handle a wide range of possible flare loadings. One system handles STV gas while the second flares IP and. I{P gas. .The total capacity of the STV ground flare is 20 ~SCFD. The ultimate capacity (~SCFD) of the IP/HP flare is 495 million. This volume is based on emergency shutdown of the HP gas facilities. The initial capacity of the IP/HP -16 flare is 300 MMSCFD due to the lower C~DR during the early stages of production. These flare systems were installed to satisfy the conditions of a smokeless burn and w~re approved by the Alaska State Depart~_nt of Enviro~tal Conservation. STV, IP and HP flare gases pass through knockout drums located away frc~n the flare area. These vessels remove liquids entrained in the flare gases to insure efficient flaring, although the flare can handle small amounts of liquid. Three parallel pipelines, one each for the STV, IP and HP systems, transport the gas to a flare manifold building. In the manifold building, the STV line tees into the STV manifold and. the IP and HP lines tee into the IP/HP manifold. The STV gas arrives at the STV flare header slightly above atmospheric pressure and in order to achieve smokeless cc~bustion an assist gas is used. An assist gas header parallels each STV header and each burner element on the assist gas header has a Venturi orifice. The STV gas is piped to the bottcm of the Venturi where it is entrained and burned with the assist gas. The STV stream is subdivided into five stages and the IP/}tP stream is subdivided into four stages. Quick acting valves are located at the inlet to each header to sequence or stage the flow of flare gases. Staging has been engineered so the proper volume of gas is transmitted, at the proper operating pressure in each header, thus assuring efficient operation of each burner. Full capacity backup systems exist for the STV, and IP/HP flares and operate only when the respective primary system is under repair or malfunctions. -17 Since the ground flares rarely operate, air may penetrate the headers leading to the burners and form an explosive mixture of air and flare gas. In order to prevent this condition, a constant volume of purge gas is fed through the STV, IP and HP pipelines. The first stage header on both the STV and IP/HP Flare Systems allows purge gas to pass through the first stage burners. The safety pilot gas ignition system consists of a supply of natural gas fed by a series of lines to continuously burning pilots. A gas ignition system remotely ignites the pilots. Thermocouples placed on key pilots monitor their operation and initiate an alarm in the main control room if they malfunction. Operating experience to date indicates that a safety pilot and purge gas volume of 1000 MSCFD per day per flow station is sufficient for operating purposes. i'. The Central Compressor Plant (CCP) is .used to compare gas received from each of the flow stations and gathering centers for injection into the Prudhoe Oil Pool Gas Cap. Thus, this major facility has gas conservation as its primary purpose. The CCP has the capability of handling a design plant inlet rate of 1760 ~4SCFD with one cc~pressor/turbine unit out of operation. If a first- stage unit is shut down, the interstage pressure decreases, the rpm of the other units will increase, and the design rate is maintained. Con- versely, if a second-stage unit is shut down, the interstage pressure increases, the rpm of the other units increases, and the design rate is maintained. -18 Referring again to Exhibit 3, gas enters the CCP through two lines; one frcm the West side or (BP) of the field and one frcm the East (ARCo). Normally, the gas stream will be free of liquids; however, small amounts of glycol may be present in the gas leaving the Flow Stations and Gathering Centers. In addition, liquid can enter the lines as a result of process upsets, insulation failure, or startup conditions. Liquids are removed frc~ the lines by launching spheres at the flow stations and ball receivers located at the entrance of the CCP are used to retrieve the spheres. Large volume inlet separators are provided for each line to trap out entrained liquids. The volume of liquid received as a slug at the inlet separators during normal operations can be controlled by the frequent%7 of line pigging. After leaving the inlet separator, the gas enters one of four inlet filter/separators for removal of trace solid and liquid contaminants. The gas then enters the cc~pressor inlet header, which mainfolds the eight first-stage compressor trains together, at 600 psig and is ccmpressed to 2075 psig under normal operations. Ccmpression of the gas is acccmloanied by a rise in the gas tenl0erature of approximately 200° F due to work done on the gas. Therefore, an interstage cooler is required to cool the discharge gas of each first-stage cc~pressor to an acceptable temperature of 85°F for second-stage cc~pression. Cooling the gas to 85° F has the added advantage of lowering horsepower required in the second stage of cc~pression. The design rate for each first-stage compressor is 215 MMSCFD. -19 Gas frc~ the first-stage coolers discharges into the interstage header, which manifolds the four second-stage cc~pressor trains together, and is cc~pressed by the second-stage units frcm 2,075 to 4,500 psig. As before, this cc~pression is accc~panied by a rise in the gas t~rature. After- coolers are required to cool the gas before injection. The design rate for each second-stage ccmpressor is 415 ~SCFD. Dresser-Clark multistage centrifugal ccmpressors were selected for both first and second-stage compression. Each unit is a six-stage barrel- type compressor. The eight parallel first stage cc~pressors and the four second-stage cc~pressors are identical for ease of operation and maintenance. General Electric Frame 5 single-shaft gas turbines were selected as the prim~ movers for the cc~pressors. All twelve gas turbines have the capability of producing over 25,000 hp at site conditions of 40° F and sea level. Fuel gas to the turbines is normally supplied from the CCP low- temperature separation unit with the design capacity of 80 MMSCFD. Backup fuel is supplied frcm the fie~d fuel gas unit (FFGU). As is the case with the flow station compressors previously discussed, upsets in operating conditions or failure of mechanical devices causing flow interruption can result in a surge condition in the compressors. Thus, to assure stabilized conditions and to minimize flaring, each CCP compressor is protected with one antisurge rec~cle loop. This loop permits recycle -20 of discharge gases back to the compressor suction during periods of startup or upsets J~ the flow conditions. The Field Fuel Gas Unit or (FFGU) conditions gas for use as a fuel by all Prudhoe Bay Facilities as well as the first four Alyeska Pump Stations. A water dewpoint of -60°F and a hydrocarbon dewpoint of -40°F ~.~re selected as the design basis for the fuel gas. A total of 100 ~SCFD of fuel gas can be conditioned by each of the two hydrocarbon and water dewpoint control trains. Normally the supply to the FFGU is a compressed gas stream from the interstage header in the CCP. Gas pressure is reduced to 1740 psig through a pressure control valve and the gas enters filter/separators for removal of liquid and solid contaminants. The gas stream is next contacted with lean triethylene glycol (TEG) in fourteen-tray glycol contactors where a water dewpoint of -60° F is attained. Each glycol contactor has an associated glycol regeneration unit. The dehydrated gas stream is then expanded through a throttle valve from 1740 to 850 psig. The gas and liquids in the expansion stream are separated in the low temperature separator (LTS). The sudden expansion of the gas results in a temperature of -40°F in the separator, which is the approximate hydrocarbon dewpoint of the gas. The gas leaving the low temperature separator is reheated by the incoming feed gas and enters the fuel gas system at approximately 840 psig and 35° F. -21 For initial startup, the feed stream for the FFGU was gas cap well stream fluid produced by backflc~ frc~ a gas injection well. Tw~ gas injection wells are specifically equipped for this purpose. This gas is cooled or heated as recruited to maintain a gas cap inlet separator temperature of 85° F. Any produced water is separated frc~ the Natural Gas Liquid or (NGL) and transferred to the waste water system. ~GL is dumped to the NGL flash drum. The gas leaving the gas cap inlet separator is fed to the FFGU inlet filter/separator. Natural gas liquids (NGL) are collected at the CCP in the inlet separators, inlet filter/separators, first and second-stage suction scrubbers, and the LTS unit. Natural gas liquids are also collected at the FFGU in the gas cap inlet separator, inlet filter/separator, and the low temperature separator. These natural gas liquids are fed to one of two NGL flash drums which operate at 635 psig and 3° F. The vapors frcm these drums are fed to the inlet filter/separators at the CCP. The remaining NGL is boosted, filtered and injected into the Prudhoe Oil Pool gas cap. Thus, conservation of both hydrocarbon liquids and vapors is an integral part of the process. As noted with the Flow Stations, the high pressure gas being processed in the CCP and FFGU must be discharged in the event of fire, power loss, or equipment malfunction and during startup operations. Also, all process piping and process vessels are protected by relief valves. All relief gases wil be sent to the flare system for proper disposal. The flare system, therefore, is essential to safe and efficient facility operation. -22 The Central Ccmpressor Plant ground flare is situated over a lake area and is separated into two parallel systems identified as the High Pressure (HP) Ground Flare and. the Low Pressure (LP) Ground Flare. The two systems are necessary to provide the flexibility required to handle the range of possible emergencies. Exhibit 5 is an aerial vie~ of the CCP Flare. Both the }~? and. LP flare gases first pass through specially designed knock-out drums located in the CCP, which remove a major portion of the entrained li_c~lid in the flare gases. Removal of this liquid is necessary.. for efficient flaring, although small amounts of liquid can be efficiently burned by the flare. Two parallel pipelines, one HP and one LP, transport the gases to the flare manifold building. The manifolds in this building distribute the HP and LP flare gases through a series of headers. The main stream of either the HP or LP system is subdivided into five stages. Quick acting valves are located at the inlet to each header to sequence or (stage) the flow of flare gases to the headers. The staging of the flare gases has been carefully engineered so the proper volume of gas is transmitted at the proper operating pressure in each header, thus assuring efficient operation of each burner. As a safety measure, two separate backup systems are incorporated into the overall design. These are identified as the High Pressure Backup Flare and the Low Pressure Backup Flare. These systems provide 100 percent standby for their respective primary, system. Both will operate only when the primary system is down for repairs or fails to function properly. -23 Since the High and Lc~ Pressure Flare Systems are normally inactive and operate only in the event of an emergenc~, there is the ~cossibility of air penetrating the supply headers leading to the burners and forming an explosive mixture of air and flare gas. In order to eliminate this condi- tion, a constant volume of purge gas is fed through the LP and HP pipelines. The first stage header on both High and Low Pressure Flare Systems is constantly open, thus allowing purge gas to pass through the first stage burners. The safety pilot gas ignition system consists of continuously burning pilots. Experience obtained thus far indicates that a safety pilot and purge gas volume of 1000 ~CFD will be sufficient for operating purposes. Exhibit 6 is an aerial view showing the Crude Oil Topping Plant. The Crude Oil Topping Plant, located i~uediately to the west of the ARCo base camp, while not a Prudhoe Bay Unit facility, was initially constructed and subsequently enlarged for the purpose of providing fuel for the further exploration and development of Prudhoe Bay Field. The Plant is currently subject to Administrative Approval No. 98-B.6, which established a maximum safety pilot volume of 400 MSCF/D. The Crude Oil Topping Plant is designed to supply up to 3500 barrels of diesel fuel and naptha (motor fuel) per day frc~ a total crude oil charge of approximately 15,000 BOPD. The crude oil charge is taken from the gathering system between Flow Station 2 and Flow Station 1. After the diesel and naptha products have been recovered, the remaining crude (residual) is returned to the gathering system. -24 Mr. Cha/iTaan, this concludes my testimony on the description of facilities in the East Operating Area. At this point, Mr. Ken Chadwick of BP Alaska Inc. will describe facilities in the West Operating Area. MR. CHADWICK: BP Alaska, Inc., as Operator of the West Area of the Prudhoe Bay Field, will ultimately operate three Gathering Centers and the Central Power Station. Slide No. 1 is an aerial photo of Gathering Center No. 1, Slide No. 2 is a photo of Gathering Center No. 2. The basic purpose of each Gathering Center is to separate oil, water, and gas. Each plant, located in an extremely hostile environment, is complicated, heavily instru- mented for minimum manning, and 10 to 100 fold larger than other domestic oil production facilities. As can be seen, all facilities are enclosed; the flare pad, which will be discussed later, is in the upper left of the photo and the burn pit can be seen on the upper right hand side of the slide. Copies of these photos, as well as our other exhibits, are included at the end of our prepared testimony. The following discussion will describe the function, operating parameters, and capacity of the oil, water, and gas systems and discuss the operational necessity and safety requirements for intermittent flaring of gas. The nominal design throughput capacity of each Gathering Center is 300,000 barrels of stabilized crude oil per day. Slide No. 3 shows a basic flow diagram for a Gathering Center. Each Gathering Center is equipped with four production separator banks, each designed to process -25 75,000 barrels per day of stock tank oil, and one test separator bank designed to process 25,000 barrels per day of stock tank oil. The system is designed for three stage separation of oil, water, and gas with the high pressure separator operating at 650 psig, the inter- mediate pressure separator at 95 psig, and the low pressure separator at 2 psig. Chemelectric dehydration and interstage cooling for vapor pressure control of the crude are provided between the second and third stages of separation. The stabilized crude oil is pumped frcm the low pressure separators at 150°F, through subcoolers, and into the 34" oil transit line at about 140° F. Produced water from the crude oil separators, chemelectric dehydrators, gas plant scrubbers, and the TEG regeneration system is treated in the water clarification plant to remove oil and solid particles prior to injection into the two water disposal wells at each Gathering Center. The water clarification plant, rated at up to a 10% water cut or 30,000 barrels of water per day, incorporates two identical 15,000 barrels per day treatment trains for increased operational flexibility. Ccmmon to both trains are an inlet oil skin~er, injection pump ~charge tank, slop oil tank, and three parallel-operated, centrifugal water injection pumps. Each train contains individual dissolved gas flotation units, water booster pumps, and filters. Oil that is removed from the produced water is returned to a low pressure separator in the oil plant. -26 The gas processing system at each Gathering Center is designed to handle 480 MMSCFD of off gas. Gas processing consists of cc~pressing the low pressure and inte~iate pressure separator off gas sufficiently to ccmbine it with the high pressure separator off gas. The c~mbined gas streams are then dehydrated to prevent condensation, corrosion, and hydrate formation during shipment in the gas transit line to the Central Cc~pressor Plant for injection into the gas cap. Three functional subsystems of the Gathering Center gas processing system are the low pressure or (LP) cc~pressors, intermediate pressure or (IP) cc~pressors, and the high pressure or (~P) gas dehydration/triethylene glycol or (TEG) regeneration system. Each subsystem will be briefly discussed. Low pressure separator off gas from the third stage separators is cooled to 90°F and scrubbed to remove any liquids before cc~pression to intermediate pressure. Between the low pressure compressure suction scrubber and the low pressure ccmpressor, a take off from the low pressure process header is provided for flaring low pressure gas during operational upsets. Low pressure gas can be flared at the burn pit or burned smoke- lessly by the Coan~a flares with the addition of drive gas. Low pressure separator off gas is cc~pressed from 1 psig to the intermediate system pressure of 90 psig by two DeLaval 1,500 horsepower, motor-driven centri- fugal ccmpressors, each rated at 8 ~CFD. The two machines, connected by cc~non suction and discharge headers, are operated in parallel. At Gathering Center design throughput, the two machines will cc~press the -27 12 M~CFD of low pressure off gas plus about 2 MMSCFD of reclaimed triethylene glycol regeneration reboiler effluent stripping gas, or a total of 14 MMSCFD. Therefore, at design rate, the machines will be 88% loaded. Operations to date have verified the design throughputs. Intermsdiate pressure separator off gas is compressed frc~ 90 psig to the high pressure system pressure of 620 psig by two DeLaval 4,000 horsepower, motor-driven centrifugal cc~pressors, each rated at 27 ~SCFD. As for the LP cc~pressors, the two intermediate pressure machines are connected by cc~mon suction and discharge headers for parallel operation. At maximum Gathering Center capacity, the intermediate pressure machines will ccmpress the intermediate pressure separator off gas plus the compressed low pressure gas, or a total of 47 MMSCFD. Therefore, the intermediate pressure cc~pressors should see a maximum loading of about 88% at Gathering Center design throughput. As for the LP machines, operations to date have verified the design throughputs. It should be noted that the low pressure and intermediate pressure gas volumss will change by only minor amounts as the average field C~R increases. The additional gas will be removed fr~m the crude oil in the first stage, high pressure separators and, therefore, the high pressure off gas system had to be designed to handle twice the current volumes of high pressure gas at the Gathering Center design oil rate. In contrast, the intermediate pressure, second stage and low pressure, third stage Gas/Oil ratios will remain relatively insensitive to the increase in well Gas/Oil ratio. Simply stated, the increase in volumes of gas that -28 must be processed will not cause additional loading on either the LP or IP compressors. The only way to change the volume of gas in either the LP or IP systems is to change the oil throughput of the facility.. While maximum gas rate capacities of cc~pression facilities are an important consideration in conservation of gas, minimum gas rate capa- bilities of the cc~pressors are equally, if not more so, important in minimizing flaring due to operational necessity. All cc~pressors are equipped with piping to recycle compressed gas frcm the discharge back to suction to ensure an adequate gas supply to the machines when oil rates and associated ~e~arator off gas rates are low. This is necessary to prevent a condition known as "surging", which occurs when the gas flow through the cc~pressor becomes so low that the high pressure gas at the ccmpressor discharge actually flows backwards through the machine to the low pressure suction. Surging puts extreme loading on the compressor bearing system and can very quickly destroy a machine. The recycle gas, being taken from the compressor discharge and having been heated from 90° F to 340° F due to heat of compression as it passes through the machine must be cooled and then scrubbed to remove the heavier liquid ccmponents formed by condensation during cooling. The cool, scrubbed recycle gas, now suitable for recycle use, is actually lighter than the separator off gas for which the compressor is designed. Therefore, the lower the oil rate and associated separator off gas rate to the compressors, the greater will be the demand for recycle gas and, also, due to continuous stripping out of the heavier ccmponents d~ring -29 recycling, the lighter the recycle gas will becc~e. Stated differently, at scme minimum oil rate, the amount of recycling re_c~ired to prevent surging causes excessive stripping of the heavier gas cc~ponents in the recycle flow and the cc~posite gas (recycle plus minimum separator off gas) being fed to the machine beccmes too light for safe and proper operation. Operational experience has shown that an oil rate of 60,000 barrels of oil per day per GC (Gathering Center) is the minimum rate to supply adequate separator off gas for cc~pressor operation. At rates less than this, there is so much low molecular weight recycle gas that the compressors simply fail to pump. The risk of losing a cc~pressor train bv trying to run the machines at oil rates of less than 60,000 barrels of oil per day does not justify the probable consequences on operational flexibility. Gas dehydration/triethylene glycol regeneration facilities are typical of those found in oil field operations with the exception that the triethylene glycol (TEG) reboiler effluent stripping gas is reclaimed by low pressure compression. The system is made up of two independent trains, the gas contactors being designed for a future Gas/Oil ratio of 1,450 standard cubic feet per barrel (SCF/STB), or a total gas rate of 480 MMSCFD. At present Gas/Oil ratios, each train can dehydrate the total volume of gas at Gathering Center design oil rate. Three TEG booster pumps and three TEG high pressure pumps are cross-manifolded to provide an operating spare for either train at maximum design rate. The gas dehydration facilities are designed to dehydrate a water saturated gas feed at 90° F to a dry gas product having a water dew point of -40° F at the gas transit line pressure of 610 psig. -30 This concludes the general facility process descriptions and operational restrictions related to gas conservation that are determined by equivalent rates and capacity requir~ts. Safety features must be designed into every facility to prevent the disasterous consequences to personnel and equipment which could result frcm overpressuring, whether caused by operator error, equ~ ipment failure, or environmental conditions. Every vessel must be equipped with pressure relief valves; off gas systems are designed to vent under excess pressure, and vital equipment is protected by mechanical failure shutdowns which aut(x~atically result in the venting of gas. At a predicted future Gas/Oil ratio of approximately 1,450 standard cubic feet per barrel (SCF/STB) associated with a Gathering Center design capacity of 300,000 barrels of oil per day, a flare system with a safety relief capacity in excess of 450 Mk~CFD had to be designed which met all environmental standards and produced a minimum of thaw damage to the tundra. The Coanda flare system was designed to conform to U. S. Federal Agency and Alaska State Agency requirements and has been so approved. These constraints have resulted in a system of seven flares per Gathering Center in order to cater for the maximum gas volumes. Slide No. 4 shows the basic piping and headers which connect these flares to the Gathering Center pressure relief system. One of the main problems associated with mseting envi~tal demands was to develop a flare which would burn "smokeless" even with heavy liquid carryover in the gas or when burning low pressure or atmospheric stock -31 tank gas vapors. The Coanda flare accc~plishes this by aspirating excess air into the high pressure gas stream as it exits a narrc~ slot around the circumference at the top of the flare stack. The high pressure flare header operates at pressures frc~ 20 to 50 psig to maintain exiting gas velocity adequate for proper aspiration. The heavier low pressure gas is injected through the center of the flare stack into the high pressure gas flame at a maximum %~ight ratio of 1 pound of low pressure gas to 1.5 pounds high pressure gas (or equal to a volume ratio of 1 standard cubic foot (SCF) of low pressure gas to 3 SCF of high pressure gas). Note that the high pressure flare header gas can be either high pressure separator off gas or intermediate pressure separator off gas, since both are vented through the high pressure flare header. Flare Nos. 1-4 are combination high pressure/iow pressure flares and have maximum high pressure volume capacities equal to essentially three times the maximum low pressure volume capacity. Flare Nos. 5, 6 and 7 are high volume capacity high pressure flares only. The minimum rate for flaring high pressure flare header gas by the Coandas is 8 ~CFD at a 20 psig flare header pressure. Facility operation has been modified in the interest of gas conservation. Previously, minor pressure upsets in the low pressure separator off gas system would result in pressure venting to the flare system. When this occurred, a minimum rate of 8 to 40 ~.~CFD of high pressure drive gas was automatically flared so as to burn the low pressure gas smokelessly. After modifications, an upset in the low pressure separator off gas system -32 now results in pressure relief directly to the burn pit, eliminating the need for the 8 to 40 ~CFD rate of high pressure drive gas. If, in fact, the upset appears to be of long duration, the Coanda flare system can be operated manually by the addition of high pressure drive gas, thus enabling the burning of the low pressure gas smokeless by the flares. In the event of pressure surges in the high pressure or intermediate pressure separator off gas systems, the excess high pressure or inter- mediate pressure gas is autc~atically burned by the Coanda flares via the high pressure flare header. In that the flare system is an integral part of the Gathering Center pressure relief process and must be ready for instant use at all times, it is mandatory t/~at all headers, risers, and piping be maintained in safe operating condition. Air entry into the flare system piping must be prevented because the consequences could be disasterous if an explosive mixture of air and gas ignited. To prevent possible internal formation of cc~bustible mixtures, the piping to each flare and the burn pit is continuously purged with dry natural gas at design rates which prevent explosive oxygen concentrations. Equally as important as maintaining proper purge rates is the need for a reliable pilot system since the release of unburned hydrocarbons would be extremsly hazardous. The safety pilot system used with the Coanda flares is designed by Westech and incorporates a three finger, remotely lit pilot for each flare and the burn pit. In addition, the burn pit has four atmos- pheric burners for back up in the event of failure of the burn pit pilot. -33 Operating experience to date indicates the necessary daily safety pilot and purge gas volumss required at each Gathering Center total 1100 M£CF. Contraction purge is an additional purge volume added to the flare piping after a burn. The contraction purge is activated by closure of the flare sequencing valve and its purpose is to prevent entry of air into the flare stack and flare piping due to rapid cooling and contraction of the internal gas after flaring. The volume of contraction purge gas added is controlled by a separate timer on each flare and is a maximum volume of 2 MSCF per flare, per burn. In addition to the Gathering Centers, BP Alaska also operates a centrally located electric generating station which is powered by gas turbines and provides electric power for Unit operations. Slide No. 5 shows an aerial photo of the .p~r station. Current plans provide for a total of seven turbine generators opera- tional during 1978. Five units will be capable of supplying the required electrical power at any given time with the two additional units available for routine maintenance, overhaul, and standby. Electrical distribution is acccmplished at 69,000 volts by overhead transmission lines which feed separate cc~plete loops to each operating area of the field. Each separate loop contains power substations which provide 69 KV voltage reduction for consumption at 4,160 volts, 480 volts, and 120 volts. -34 Current fuel gas c~nsumption at the Central Power Station is averaging approximately 14 MMSCFD. Fuel gas is normally supplied to the Power Static~ frc~n the Field Fuel Gas Unit at a hydrocarbon dew point of -40° F and a water dew point of -60° F. ~-as fee~ to the Field Fuel Gas Unit normally is cc~pressed interstage gas frc~. the Central Compressor Plant or, alternatively, gas cap gas from a gas well. In the event of a cc~plete loss of capability of the Field Fuel Gas Unit to furnish fuel gas to the Central Power Station, a gas spur line has been connected frc~ the gas transit line at Gathering Center No. 3 to the Central Power Station. Therefore, conditioned gas frc~ the BP gas transit line can be supplied to the Power Station for fuel gas during emergencies at the Field Fuel Gas Unit and Central Ccmpressor Plant. Mr. Chairman, this concludes my testimony. the necessities for flaring. Mr. Berdon will now address MR. GILBREI~{: Thank you. MR. BERDON: ~r. Chairman, members of the committee, safety was a primary consideration in the design and operation of the facilities for the Prudhoe Bay Field, including those facilities related to the flaring of gas. The necessity for flaring of gas can be placed in five general categories: 1. Safety pilots and'purging. 2. Equipment malfunctions. 3. Facility startup after shutdown. -35 4. ~ssioning of new facilities. 5. Engineering and well testing. We have previously testified about the necessity for flaring for safety pilot and purging purposes. The remaining categories will nc~ be generally discussed. Equipment Malfunctions Unlike planned preventive maintenance shutdowns where process capacity of oil and gas handling can be switched to standby e .qui~pment or other facilities, equipmsnt malfunctions are unplanned and unwanted, and usually create an emergency situation. All piping and vessels are protected from overpressure by spring operated relief valves or instrumented pressure controllers. Overpressure conditions caused by such things as instrument failures or accidental blocking of systems can usually be corrected, quickly and do not constitute a major flaring necessity. Although other equipment malfunctions as well as operator error can cause flaring, because of the nature of the Prudhoe operation and the large volumes of gas being handled, failure of compressors represents the largest potential necessity for flaring. -36 The gas cc~pressors in the Prudhoe Bay Unit operation are large, sophisticated machines with highly instrumented safety shutdc~n systems for protection of equipment and personnel. Unexpected shutdowns could require the release of gas to flare. Cc~oressors are within the mainstream of process flow and process mc~sntum requires that movement of gas continue until the operation can be turned down. At Prudhoe, decreasing gas flow necessitates decreasing oil flow frcm the wells. It is important to note that a single compressor failure at a Flow Station or Gathering Center results in the flaring of intermediate and/or low pressure gas only, which presently constitutes a maximum of twenty percent of total facility throughput. To accommodate the operation of compressors and the time required to decrease oil flow, it therefore becomes necessary for the Unit Operators to have authority to flare gas for some period of time should an e~qui.pm~nt malfunction occur. Production experience to date has indicated thatmost malfunctions can.be remedied and normal operations resumed within twelve hours after the conm~_nc~t of flaring caused by equipment failure. Prudent operations dictate that during this period measuresbe taken to eliminate or minimize the volume of gas flared as soon after the c~ce- ment of flaring as is operationally feasible. These measures involve reducing gas flow at the affected facility by reducing oil flow, possible attempts to correct the equipmant failure, and a well coordinated field-wide effort to smoothly redistribute production to prevent potential flaring at other facilities. It should be emphasized that rapid, uncoordinated attempts to shift production can easilyand most probably will lead to -37 excessive flaring at other facilities. Again, production experience to date has indicated it can take as long as four hours to assess an e_.c~pmant malfunction, and either correct the problem or begin shifting production to other facilities. The follc~ing are estimates of max~ potential flare volumes associated with a single cc~pressor failure at either a Flow Station or Gathering Center: Flow Station - 2.3 ~4SCFH (million standard cubic feet per hour) Gathering Center IP - 1.1 MMSCFH Gathering Center LP - 0.3 ~CFH Similar volume estimates for individual compressor failures at the Central Compressor Plant or (CCP) are most difficult to make because of the number of cc~pressor cc~binations and the range of first stage and second stage discharge pressures. As mentioned, the CCP was designed to ulti- mately compress 1760 ~4SCFD with one ccmpressor, of a total of twelve, out of operation. This extra capacity was installed to minimize the necessity for flaring caused by CCP compressor failures. For estimating flare volumes that might result frc~ CCP compressor failures, the design capacity of each first stage cc~pressor is about 9 MMSCFt{ and the design capacity of each second stage compressor is about 17 MMSCFH. Facility Startup After Shutdown gas. The restart of any of the Prudhoe facilites requires sc~e flaring of Vessels and piping must be pressured and minimum flow rates must be -38 established before cc~pressors and process can be placed in operation. M~tallurgy restrictions on many of the high pressure vessels require minimum operating ~ratures before they can be raised to full operating pressure. This re_quires warm flows of oil and gas frcm the wells and through the facilities. There is over 2000 feet of permafrost at Prudhoe Bay and surface temperature changes of 100 fahrenheit degrees frc~ summsr to winter occur. The time required to establish warm flows in wells and facilities varies significantly and is dependent on the season and the len_~ch of time a facility has been down. There is a tremandous difference in the time required to restart a facility that has been down a few hours in sunnier and the tim~ required to restart a facility that has been down for days or weeks in mid-winter. We estimate that restarting a single flow station or gathering center will require flaring as little as 2 to over 100 MMSCF of gas, depending on the season and the length of time the facility has been down. Restarting of the entire field would, of course, result in the flaring of much larger volumes. The Operators are implen~nting restarting procedures that emphasize the maximum conservation of gas. The following criteria are presented to illuStrate the startup philosophy developed around the concept of maximum conservation of gas. 1. Separator train or (production bank) stability can be obtained much quicker by producing a few good wells at higher rates -39 than by producing as many wells as possible at necessarily reduced rates. Fewer good wells produced at higher rates will heat up faster, thus minimizing the time and amount of gas flared until the gas processing facilities are on stream. 2. A minimum number of separator trains (production banks) will be used while flaring gas during startup. Separator train or (production bank) stability cannot be obtained below minimum rates. [~en production rates reach this minimum, there will be no more increase until the gas processing facilities are on stream. 3. When high pressure separator temperatures approach 140° F, the high pressure separator off gas can be shifted from the flares to the gas dehydration facilities for dehydration and. transport to the Central Ccmpressor Plant. 4. After the gas dehydration facilities are on line and stable, cc~pression of the intermediate and low pressure gas can con~aance, thus eliminating gas flaring at the facility. 5. With the Flow Station/C~thering Center cc~pletely on line, the oil rate can be increased. Additional cold wells can be warmed slowly at low initial rates into the hot separators because the hot wells supply the heat required to flash the off gas from the cold wells without causing system upsets. This general procedure is used for cold startups to maximize the conservation of gas. It is based around quickly obtaining separator -40 rate and thermal stability at minimum rates until the gas processing facilities are on stream. Although the amount of time r ..equired to get a production facility up to design rate is prolonged, conservation of gas is maximized. Cc~nissioning of New Facilities With the continued development of the Prudhoe Bay Field, new facilities will be brought into operation for the first time. BP Alaska is scheduled to accept Gathering Center No. 3 for conmtissioning in April, 1978. Like- wise ARCo's third production facility, Flow Station 3, will be ready for conmissioning in 1979. The volumes of gas flared during commissioning of these new facilities willbeminimized by using the same general techni.ques described for operational facility restart. The additional gas flaring required for commissioning a new facilitY, over that re.quired for startup of a fully operational facility, will be due to the high number of shutdowns caused by process control problems and general commissioning problems associated with starting new equipment. However, by holdingthe production to a minimum rate until gas dehydration and ccmpression facilities are com- missioned and operable, the volume of gas flared can be kept at an absolute minimum. Application for startup flaring will be submitted to the Ccmmtittee at that time. -41 Engineering and Well Testing FrGm tims to tims it will be necessary to flare in conjunction with special equipment or well tests. In these instances applications will be submitted to the Committee for approval prior to the need. ~. Chairman, this concludes n~3 testimony. At this point ~r. John Reeder will sunm~3rize our testimony and present proposed rules. MR. GILBRETH: Thank you, Mr. Reeder. MR. REEDER: Mr. Chairman, members of the Oil and Gas Conservation Cc~ttee, my name is John Reeder, and I serve as Regional Attorney for BP Alaska Inc. The Field Operators on behalf of the Working Interst Owners have presented testimony today describing the facilities operated by them in the Prudhoe Bay Field which contain gas handling and gas flaring equipment. They have reviewed the requiremants for flaring gas, along with the conclusions they have reached concerning the capabilities of the equipment in the Prudhoe Bay Field. All of the testimony presented demonstrates the manner in which flaring should occur to accommodate both safe operation of field facilities as well as conservation of gas. We feel it is evident that the Prudhoe Bay Field is unique in terms of the location, operation and design of production facilities, and we are hopeful that the Cc~mittee will take -42 these factors into consideration in formulating and adopting rules regarding the conservation of gas at Prudhoe Bay. Our production facilities, the Gathering Centers, Flow Stations, and their associated well pads and flow lines, are designed to ultimately allow one unit of the total six to be out of service and still meet projected production re..c~ir~ts. Upon adoption of final rules governing flaring by the Ccxm%ittee, the Operators intend to formalize procedures to coordinate production both in a manner consistent with the field rules and to achieve the max~ conservaticn of gas. The Operators wish to present at this time proposed rules which are intended to acccmplish the policy objective stated at the beginning of this testimony. The purpose of the proposed rules is to prohibit the flaring of gas, other than those amounts necessary for safety pilot and purging of gas handling facilities, for emergencies or as a result of operatiOnal necessity. To this end, the rules proposed specify the average daily volume of gas permitted for safety pilot and purging purposes for each facility which flares gas, and specify a limited period of time during which flaring can occur at a facility arising as a result of an emergency or operational necessity. As stated in the testimony, experience to date indicates that most equi~t malfunctions causing flaring incidents can be dealt with and corrected within a 12 hour period. The rules proposed contemplate that any flaring incident which requires flaring of gas in excess of 12 hours after the ~cement of the incident will proceed only after prior approval has been obtained frc~ the Conm~ttee or its designated representative. If operational -43 necessity re~res flaring in excess of that time, the matter is to be presented before the Cc~mittee for action on a case by case basis. Finally, the rules proposed include a provision to ensure the reporting of all such incidents, in writing, to the Cc~m%ittee monthly. I would now like to read the proposed rules for the record. Rule A reads as follows: Effective, and we left a space for the date, the flaring of gas from the Prudhoe Oil Pool is prohibited except for those amounts necessary for ade.quate safety pilot and purging of gas handling facilities, emergencies or as a result of operational necessity. The flaring for such purposes is limited by Rules B and C, unless prior authorization has been received from the Cc~mittee by the Operators. Rule B reads as follows: The following daily volumss of gas re~quired for safety pilot and purging of gas handling facilities are hereby established for the listed facilities utilized in the production, treating and processing of oil and gas frcm the Prudhoe Oil Pool. Gathering Center No. 1, Gathering Center No. 2, and Gathering Center No. 3, 1,100 MSCF; Flow Station No. 1, Flow Station No. 2, and Flow Station No. 3, 1,000 MSCF; Field Fuel Gas Unit and Central CGmpressor Plant, 1,000 ~CF. These amounts are average dailv volumes calculated on a monthly basis. -44 Rule C reads as follows: As soon as reasonably possible, but in any case not more than four hours after the commencen~nt of any flaring incident at a facility listed in Rule B arising as a result of an emergency or operational necessity, Operators shall take appropriate action to initiate reduction of flaring to the minimum volume reasonably possible consistent with the efficient operation of the field. In any event, no flaring as a result of an emergency or operational necessity shall be permitted longer than twelve hours after the cc~nencement of such an incident without approval of the Committee. Such approval may be obtained by the Operators without hearing, provided that this Committee, or its designated representative, make a finding that immediate action is required, and provided further that any approval subsequently issued shall not be effective for more than 15 days. On a monthly basis, the Operator shall report to the Conmtittee or its designated representative, in writing, the conmencement, nature, and tenmination of all incidents requiring the flaring of gas in excess of those volumes permitted in Rule B. Members of the Conmittee, this concludes the presentation of the Prudhoe Bay Field Operators in this matter. At this time I would like to ask that all those giving testimony at this hearing on behalf of the Operators come forward and be available for questions should the Committee wish to discuss any particular point of our testimony. Thank you. -45 MR. GILBRETH: Why don't we at this point have a ten minute break and then we '11 start questioning. BREAK MR. GILBRETH: Will the hearing ccme back to order, please. ~rs. ~organ tells me that no one else has indicated their desire to testify in this case. If anvone does wish to, please advise her ( ) immediately. These are the questions 1%~uld like to ask the participants. The volumes of gas that you have indicated here that need to be flared for safety or the different burners and lines and so forth, how are those volumes determined? Are they measured volumes or calculated volumes ( ) MR. CHADWICK: We took them by ( ) the pilot. MR. GILBRE~t: Yes, the pilot. MR. CHADWICK: Fundamentally these were designed by the ( ) and we have since tested them and those are the volumes that we are actually using. Approximately 1076 mscf. MR. GILBRE~/~: Is it possible, for example on a still day, on a very still day, to use less gas than that? Yes, it is. -46- MR. GILBRETH: Or is this a volume that has to be constant throughout? MR. CHADWICK: It is possible to reduce the volume on a still day but it would be very unadvisable. MR. GI-I~RETH: ?~y is that? MR. CHADWICK: It' s largely because we can' t really determine the conditions. We need to be ready to cc~e back to full volume if conditions change. This is the real problem. We just establish the conditions and keep it steady. MR. GILBRETH: I don't know, just sitting back and flaring a million cubic feet sounds like one heck of a lot of gas for a pilot light and I'm wondering. We found in the Cook Inlet, for example, that the volumes could be cut down in some cases 30, 40, 50% on still days when they didn't need the volumes. I'm wondering if that would be possible. be sure. Possible. I wouldn't like to cut down the volume and not MR. GILBRETH: In your testimony you mentioned several instances where it would be necessary to flare gas and it takes about four hours, can take up to four hours to evaluate a condition, make your burner ( ) and presumably, the way I read your testimony, continuing to flare during this four hours. Is it possible to restrict production during that time and. if so, how long would it take to restrict production or maybe close in more or less mcmentarily? -47 MR. BERDON: I think we've determined, ~r. Chairman, that it takes approxi- mately four hours to thoroughly evaluate a problem as well as correct sc~e problem ( ) either correct or to evaluate the current situation ( ) MR. GILBRETH: My question then is when the malfunction occurs, why don't you close in everything at that point? MR. BERDON: I 'd say most of the malfunctions that you are faced with in facilities require continued production to correct that problem so that you have, for example, in a ccmpressor failure, you have gas to restart your compressor with so that as part of the evaluation process and as part of the attempting to correct these problems you need a volume of gas to work with. MR. GIT.BRETH: You need the full stream in all cases or just part of the time? MR. BERDON: In this short evaluation period we feel that Jmterrupting the normal flow might be more disruptive to the operation. It seems it could cause sc~e upset conditions as with temperature, accentuate the problem. MR. GILBR55~: Gentlemen, bear in mind that we are not well versed in all the intricacies of your equipment up there and how it operates. There are lots of question marks in our minds as what can be done and what can't be done, why it's not being done and that sort of thing. -48 How long would it take you to close in a gathering center in just a normal closedown, let's say not an emergency closedc~n? If 5~u w~re just going to routinely close down a gathering center, how long would it take? MR. C~DWICK: There are two methods of closing down. One is to hit the panic plug which is in this case a matter of minutes, but it's not the recc~m~_nded route in security to cc~e down. The more normal route would be closing down within an hour if you had the reason to ccme down. MR. GILBRETH: I see. In the testimony you indicated the volume of gas is flared reaches temperature equilibrum. Have you given any thought to trying to maintain temperature equilibrium, let's say, on the BP side, circulating frcm the top d°wn to ( )? Have you given thought to possibly circulating hot fluids or steam or scmething else to keep the equipment warm during the shutdown? MR. CHADWICK: The problem is not so much the equipment as the flow lines. The flow lines cooled down and you then have to restart them with cold oil ( ) plus a few thousand feet of permafrost ( ) . It de~pends how long you're dc~ how low the temperature goes down. ~en it comes down to below about 50© F then when you restart you have semewhat of a problem ( ) you have to ( ). We've determined the best route is to cc~e back with a few wells on a cold start to get the temperature up and this works very well, but it doesn't mean that ( ) prolongs the startup time oil production we can get to the point where we can turn the t{P gas over to CCP real quickly. The last shutdown was about 4 or 6 hours at the point where we turned the high pressure gas back down and the point where we turned the station ( ). Cold has a very curious ( ). -49 MR. GTT.RRETH: Just sounds like based on your testimony that everything has to be fine tuned down to a hair line when you need a replacement it's going to necessity to flare while you're getting .equilibrium. Is that pretty much the way it' s going? )~. CHADWICK: No, I think we've learned to drive the system fairly well. If you go on the guidelines of bringing a few wells into one or two separators, pulling them through to the point where you can establish your 60,000 barrel level and that your gas temperatures are, say well over 100 degrees, this takes say 4 to 6 hours, depending on the ambient temperature. Then you're in good shape. You can turn that gas over to CCP and it doesn't really matter from then on how long you take to bring the rest on stream without burning any gas, MR. HAMILTON: Earlier this year we have some preliminary figures on the estimates of the .quantity for safety pilot and purge gas. ( ) MR. CHADWICK: No, the basic change was not in the pilot but in the change of the burn pits, the pit design. We took out the ao burner there because it got destroyed, there's bound to be liquids in the burn pit line and it didn't take long to get crude oil in the line and it destroyed itself, so we changed the design of that, we added scme more to an open tip burner and this required us to (~ ) up slightly. For greater security ( ) we had to ( ) the pilots. MR. HAMILTON: I have a similar question for Arco, )~. Chapman, regarding flaring requirements... ( ) 600 mcf or so per day ( ) -50 MR. CHAPMAN: I think we're asking for this volume because this is fuel gas for a very inloortant safety system and facilities and %~ want to make sure that we have adequate volume to operate those safely to handle any atmospheric conditions that may change like high winds what not, and we would make every attempt possible to minimize those volumes but we feel that with this flexibility of 1 million feet per day we will be able to handle any situation in the system, but we would attempt to minimize those volumes. MR. HAMILTON: ( less than that. ) It could work out that you could be operating with volumes MR. CHAPMAN: Yes. MR. HAMILTON: Mr. Chapman, in your testimony this morning regarding flow station gas you indicated that you have a standby turbine available. If something should happen to the turbine in operation and you have to switch to the standby turbine would this require flaring? MR. CHAP~iAN: Yes, it could, Mr. Hamilton, depending on the condition we could cut it up to 200. ~R. ~iARSHAI.I.: I have a question about Rule C as proposed in the presentation this morning. I'll address this to Mr. Reeder. It appears_in the first sentence of the rule, it sort of implies there will be a 4 hour period before the operator, or I mean is this an implication there's a 4 hour period of flaring before the operator takes "appropriate action to initiate -51 reduction of flaring to the minimum volume reasonably possible consistent with efficient operation of the field." Is that the implication, would you explain how this might relate to the actual mechanical situation in the field? MR. REEDER: question. obligation. I can't, I probably should not address the last part of the I'd rather pass that on to ~. ( ) who is .qualified. ( ) As far as what could actually happen. MR. ~iARSHAI~.: Well, I believe you've answered my question, John. You're feeling that there's sort of a 4 hour period in which people react to the shock to whatever emergencies or situation it is before they take steps to reduce the amount of flaring. I . . . MR. REEDER: allows... I khJ_nk their obligation is to react immediately. Four hours MR. MARSIiAI.I.: I think my concern is that I don't think you can pull a figure like 4 hours out. I think each situation is going to be quite different. It could be a big one, it could be a small thing. I, it doesn't bother me to eliminate the four hours ccmpletely, and just say the operator will take necessary steps to reduce flaring. That' s, the four hour thing, I just don't know how meaningful it is. I don't think the cca~nittee, speaking for myself here at this particular point. Four hours is an extremely difficult thing to keep a tag on a four hour period and it' s, I think we want the operator to be very conscious and, of course you are, we both are trying to minimize this flaring, but I think it's sc~t~ing that you're going to be tending to just as soon as you recover your wits about emergency situation and that you will in~e~ately coordinate an effort to reduce the flaring. It's not a great big issue, but I found in the past that putting a few hour period in an order is very difficult to documsnt even if we wanted to use it for sc~e particular reason. I think the important thing is that as soon as possible we all try to work on it. It's just a ~t. Another one, another phrase in that Rule C, "in any event, no flaring as a result of emergency or operational necessity shall be permitted longer than 12 hours after ccmmencemsnt of such incident without approval of the cc~mittee." Now, in other words, if sc~e flaring incident exceeded 12 hours, the cc~m%ittee's approval would be required. I think probably we will want to specify ifwe would accept this suggestion that it be a particular kind of approval. Now if you can not get a written approval in 12 hours, but ordinarily the way we've been going, at least in the Prudhoe Bay we have been issuing administrative approvals which are written and these have been laid out in advance with a particular situation like we're going to start up a certain facility, we need to flare to purge line and this sort of thing, and we write an administrative approval pursuant to what would now be Conservation Order No. 145. Do you envision this 12 hour thing to be like verbal approval, where you would call sc~e member of the con~ittee or the staff and receive a verbal approval within ~welve hours of the flaring? MR. R~EDER: That's correct. I think that you realize for planned attempts such as startupwe know what ( ) well in advance. This would -¸53 take care of the unanticipated situations at scme point in the 12 hour period and it is felt we would at scme point seek approval. MR. MARSHALL: I'm just trying to, do you envision then that after the 12 hour period that's when you need verbal approval? MR. REEDER: That' s correct. MR. ~RSHAT.T.: What if it looks like the situation is going to be a 36 hour flaring situation? Would you, after 12 hours, then have verbal approval to flare for scme period of time, say another 2 days? ~. REt~ER: As I see it, Mr. ~%rshall, it' s procedural. be possible for the ccmmittee to give verbal approval . . ~he next day . . . and ( ) ( ) It would . r ~equire. . . .~k~. ~.~ARS}~: In our custcmary practice we would ordinarily have sc~e sort of a written application, for instance, a letter (a letter would be fine) to proceed with an administrative approval. That way we have a documentation for our files that you have re ~quested scmething, we have acted on it. I'm just wondering if the system here has enough flexibility or will we be writing many administrative approvals? Well, let's look in the histo~../ of the last month. You know, I think we would probably have written quite a fe~z administrative approvals to handle the flaring situation in the Prudhoe Bay field in the last month. Now, I'm not, what would you think about that? Would you think that we would have exercised this administrative approval for flaring incidents over 12 hours msn].~ timas in the last month or do you think the last month is, of course it's probably not -54 typical of the future, probably in the last month it would appear to me that there would be many occasions where we would have exercised this paperwork thing of an administrative approval. Nc~, I'm wondering if we should extend that 12 hour period or do scmething else. I'd like cc~nent frc~ the operator people. MR. CHADWICK: We talk about November which I have sc~ae figures here up to the 27th. ~ had a startup problem at GC 1. That we would have covered with a prior application because we would have know we were going to flare some gas there. We flared about 13 million cubic feet there. So that would have been handled with a previous requ., est. We had an unexpected shutdown on C~ 2 which flared gas about 40 million. That was just about 12 hours ( ). The others were very minor flaring. ( ). MR. BERDON: Atlantic Richfield did . . . MR. MARSHALl,: Louis Berdon, how about your side of the fence? MR. BERDON: We did not have any flaring incidents that went beyond 12 hours and I think we should say here that even though there is a 4 hour period of time designated in the proposed rules that if we determine after short periods of time, say an hour, that we had a major problem that could not be corrected in 12 hours, we would not wait 12 hours to notify the ccmmittee and get approval or discuss the situation. I think we would immediately determine that we had a major problem and we would come to you at that point in time. -55 MR. MAlqSHALT.: Okay, naw you mentioned that you would get the proper approval~ you wouldn't wait the 12 hours, that presumably there is the verbal approval that John was talking about and I 'm trying, I think we need scme words in here as to when we get away fram verbal approval and get to an administrative approval. Naw we've all talked about administrative approval when we anticipate sanething cc~/ng up, say next week we're going to shut scmething dawn. But what happens if, let's say you want to flare sc~e gas for 4 days or 6 days, you anticipate this would be on a verbal approval? MR. REEDER: I think ( ) likely what we would, I think if we contacted you verbally it would be a situation where could, I think the concept of verbal approval would deal with the situation ( ). MR. CHADWICK: We're talking primarily about the unplanned flaring incidents. The planned ones are no problem, but the unplanned ones can happen anytime of the day or night. ( MR. MARSHAT.T.: One final question on this Rule C. You use a 15 day period, I believe this would be in about the third sentence, "such approval may be obtained by the .Operators without hearing, provided that this cc~mittee or its designated representative makes a finding that inxned, iate action is required, and provided further that any approval subsequently issued shall not be effective for more than 15 days." Now are you suggesting then that our administrative approvals for a larger gas flaring would be limited to 15 days? I personally think that we would be all, we would bind our- selves up with that, we probably the cc~mittee should make a decision as to how' long that should be on a case by case basis depending on what's -56 your best evaluation of the problem. For instance, in the inlet here, we've had people ccme up with a bent crank shaft and that may take several months. Course riley had a problem of limited storage and no standby and that sort of thing down there, but I'm just thinking that your suggestion actually probably limits both of us unnecessarily. I think if we look at the probl~, if this approval that we are talking about here is our %~itten approval, is the 15 days apply to the written approval as you envision? ~.~. R~ER: Well, it's that idea that ( ) and obviously if . . . MR. MARSHAT.L: Sure, that' s very true. Thank you. MR. GILBRETH: I have sc~e more _questions here. During the past month or so I have been in contact with BP ~quite a bit about some problems they were having but for the record, could Mr. Chadwick or Chapman, either one, could you tell us scme of the unusual things that have happened in this startup that you normally would not anticipate in one of these fields? We've heard several things and of course it's pretty hard for scme of the public to understand how these things happen and you keep having a necessity to flare gas. MR. ~LADWICK: During the last few months? ~R. GILBRETH: Yes, sir. -57 MR. CHAP~AN: I might offer a f~ cc~ments along these lines. During the startup period, course we're going through, operations have been getting lined out, so to speak, and we have in fact activated sc~e pretty significant pieces of equipment; there have been areas certainly both in the flc~ stations and the central cc~pressor plant where probl~ns have cropped up and resulted in flaring. Flow station, gas ccmpressors, had varied problems associated with instrumantation, vibration probes, temperature probes, and so on which were taken steps to correct, but nevertheless they have created problems for us. And the central ccmpressor plant also areas there that we're working on. Scme of these anti-surge systems that we' ve talked about, the ccmpressor recT~cle, we' ve experienced scme difficulties, vibrations in those pieces of e_c~i~t and those are problems that are being methodically worked, it's just part of the normal process of lining out the facilities after startup, but nevertheless they have re~quired . . . and flaring . . . to correct these problems, very intensive effort, because this type of shutdown is, in addition to being, resulting in flaring of gas, is a great handicap for just our normal day to day operations . . . ( ) but I think frcm our standpoint we can handle the. ~. CHADWICK: In support of what Cecil said, I think much of the large equipment necessary to handle large volumes at Prudhoe were designed for the first time. for this particular application particularly.., and even though we took extensive measures to get seine of the problems solved before we installed them, for example putting these ccmpressors on the test stand at the manufacturers and actually running natural gas through them - even though we took all these measures before operation you just find many things that you have not corrected. That's what we have the intention to do -58 to correct these problems with this new equipment used for the first time anywhere. We've brought in everyone t]~at we could possibly bring in, the manufacturers, experts in the field to assist us in solving these new problems. Certain things were special, everything was new. MR. GILBRETH: I believe we had a recount last week of an O ring failing sc~where. Was it in one of the turbines? turbines. That's right, that was one of the central ccmpressor plant's This was one of the problems that I was referring to. MR. GILBRETH: How long did it take to repair it and what did it cost? MR. BERDON: Of course, we had standby equipment to take care of the gas, but to get to that particular 0 ring that failed r ~equired removing the gear box and the whole cc~pressor case and with round the clock crew it took them a week to change that 0 ring.· This was a problem of deterioration of the 0 ring material that we're thinking maybe caused by the CO2 in the gas. That certainly wasn't expected. The manufacturer didn't expect it because he certainly didn't design the machine for that particular 0 ring to be changed conveniently. MR. GILBRETH: Have you had any other problems... MR. BERDON: I don't recall any other stripping problems like this... -59 MR. GILBRETH: I'm asking these questions because we're getting a lot of criticism frcm the public on the volume of gas being flared and offer you an opportunity here to explain why you are flaring that gas. ~. CHADWICK: As far as the BP side is concerned, we had 5 significant flarings frcm the time that we had ccn~nissioned the ccmpressors up to the end of October and of those 2 of them were primarily caused by a failure of the power station. One was because scme li.quid got in the fuel gas line and shut the power station down and the other was because of ice and other dirt building up on the insulators frcm the 69 KV system outside the power station which brought the transmission system down. In both cases it was a total field shutdown and there was a significant loss of gas in trying to get back up on line again. On the second of those occasions CCP had scme problems with valves because the electrical problems delayed the restart. ( ) again. One occasion was a day's partial flaring at C~2 2 to change the recycle valves on the cc~pressors once we had commissioned the conpressors the recycle valves failed very quickly and we had to change the recycle valves. We did that at C~2 2, we did that at C~ 1 in November, but not a total shutdown of the plant. MR. GILBRETH: Were those the type of valve that normally has been used in the oil patch for years, or were they a special valve? MR. CHADWICK: They have been used for many years, but it was a vibration problem ( ) jUst snapped the stems and we had to change the type of valve, · . . just couldn't stand up to the conditions. MR. GILBRETH: Do you as operators have any feel for how long it will take to shake out cc~mon problems like this or unusual problems? MR. CHADWICK: Our problems are largely sl~uken out at C~ 1 and 2. We've had very reliable operations during November except for the shut dc~aq at GC 1 which was a constant shut down and w~ started flaring fluid when w~ could ccme back up. We've only had one occasion where C~2 2 tripped out on a ve~3 minor thing and ~e had to restart the whole station and that cost us a lot of gas because we hadn't at that time instituted the minim%~ flaring system to bringing the station back on line. We tried at GC 1 what we had tried on GC 2, so it cost us essentially ( ) 40 million ( ) a hot startup, we are taking into consideration the conservation of gas with 3 million to ccme back on GC 1 under the same conditions ( ) so we can obviously reduce the flaring that way consistently... ( ) but those are the only two occasions really for both stations where we have flared significant gas or we've had significant problems and our gas flare for November was down to 1.4% which is a big improv~t. MR. GILBRETH: What about Arco? Are you still having problems? I noticed your flared volumes seem to be up. MR. BERDC~: We had problems in October primarily with the flow station compressors and these are scme of the things that showed up after we had been on line awhile, vibration probes, we had some thrust bearing problems and instrument problems in the surge system. We are getting a handle on these problems as we get experience wit/q them. In the case of the central cc~%~ressor plant the 2 major pr, oblems that we've had there have been in -61 association with the drive couplings to the cc~pressors and the recycle valves on the anti-surge system. We have discovered scme fixes on couplings and we hope we are getting a good handle on that problem. The anti-surge valve problem has not been ccmpletely resolved, but we }mow more, a lot more about it than when we started and it is a very unique problem, it involves quite a number of ~ts in the field, but we are, have learned a lot about it, and the situation is improved. MR. GILBRETH: Do most of the operators, BP, Arco, now feel relatively cc~fortable with your shaking out period about behind you? ~R. C?LAD~ICK: Yes, as far as C~ 1 and 2, we have scme modifications to make, but primarily we' re operating ( ). MR. GILBRE~{: And Arco? MR. CHAP~q: I. think so. MR. GILBRETH: Follow up on a .question asked awhile ago about the pilot gas, is it possible or are you rigged up to meter the volume of gas that you use for pilots? MR. CHADWICK: Yes, we do meter it. MR. }LAMILTON: Mr. Berdon, your ccmpressor repair job that you just talked about, what did that cost? MR. BERDON: We call that our million dollar 0 ring. overhaul, disassembly, a chore to get to that problem. are somewhere around that figure. It was a very. major I think the estimates -62 MR. HAMTT,TON: I understand there is scme standby pc~er, isn't there at each facility up there? MR. BERDON: We have a standby turbine generator set at the central compressor plant that we can maintain operations first stage cc~pressors and two second stage ccmpressors and the field fuel gas unit. And we have used that, that particular generator. centers? How about at your flow stations, and BP at your gathering MR. CHADWICK: No, the assembled standby syste~, is purely for last of ( ). MR. HAMILTON: Is it true then that if there was a major power loss at both the flow stations and gathering centers ( ). MR. BERDON: In our. case we have 1500 KW power at each of the flow stations. Flow station 3 is being designed for 2500 KW. We do have emergencT. ( ) which allows us to use spare capacity at the operations center and at the main construction camp to tie into the excessing flow stations. ¥~ feel by tying into the excess power that we have at those two locations and ccmbining it with the emergency generators at the flow stations we could ( ). MR. HAM_ILTON: ( ). Until you tie into this system, is it possible to keep the -63 ~. BERDON: It' s tied. in now other than ( ). ~R. HAMILTON: This is a question for both Arco and BP. Throughout the testimony in various places where you mention the flare systems are designed to burn with a smokeless flame, you mentioned assist gas is used %0 achieve this. Could you both tell me how much gas are you using to achieve this smokeless flares to conform to the r ~egulations of the Department of Environ- mental Conservation? .MR. CHAPlain: In our case we are using approximately eight tenths ( ). MR. CHADWICK: We need a 3 to 1 ratio of high pressure to low pressure gas to burn ~nokelessly ( ). (?) MR. GILBRETH: With that does this imply that you have to go to DEC each time that you want to flare the low pressure gas, if you're not going this smokeless route? MR. C~-LAD%fICK: ( ) so far yes. ~R. GILBRETH: If you had a mc~ntary upset in the field, would you be requ~ ired to go in and put high pressure gas with ( ). -64 MR. BERDON: You can take the option of burning more gas or having a smoke, that's really the only option. You can't use steam or water to make it smokeless ( ). MR. C~LAD~CK: We are r ..equired to file a smoking incid, ent with the DEC everytime that a smoking incident occurs and of course we can't predict when we might have an equipmant failure that would require that but we do file the smoking incident with the DEC. k~R. HAMILTON: I guess what I'm getting down to the volumes that you're asking for the pilot and purge gas, what's the volume, or what percent of that volume is high pressure gas or gas needed to burn together to achieve smokeless flame? MR. CHADWICK: Assist gas, none at all. It's taken frcm the main flare reading. Our assist gas is reported as flared. MR. HAMILTON: If your pilots are burning with a smokeless flame (' )? MR. CHADWICK: We put air down withgas to achieve a smokeless flame. MR. I-L%MILTON: How about Arco? MR. BERDO~: The assist gas is not involved with the volumes. fuel gas frc~ the central ccmpressor ( ). We use -65 MiR. GILBRETH: plant? Mr. Berdon, is gas still being flared at the Prudhoe topping MR. BERDON: pilot. We are burning scme gas out there that's serving as a safety MR. GTT.RRETH: safety ( ) ? Is there anythingbeyond just the volumes you're burning for MR. BERDC~: No. We are under what has been approved as a safe pilot light. MR. HAMTT,TON: ,As I understand looking back at the reported flared volumes to the topping plant over the last 5 months have been ranging 149 mcr a day to 222 mcf ad ay, considerably belowthe 400 mcf per day limitation. Is this an indication that the limitation is too high? MR. BERIXlq: The only source of gas at the crude oil topping plant at this point in time is the vapor flow frcm the naptha accumulator, s. The crude is ccming in or the source of crude now is proved ccming frcm the gathering system and has been processed through the flow statior5 then the only gas available or the only source of gas is the flash gas from the process and that would be dependent on the crude throughput of the plant. MR. GILBRER~{: the pilot? Do you mean by that that you don't have any outside gas for -66 MiR. BERDON: No, we do not. MR. GILBRETH: ~at volume of natural gas liquid is now being reinjected? MR. BERDON(?): We're reinjecting about 1500 barrels a day. ~R. GILBRETH: Then talking about injecting it back into the gas cap. MR. BERDON: Yes, sir. ~.~. GILBRETH: ~at kind of a volume is going to ( ) MR. GILBRETH: Would the natural gas liquids that are being reinjected into the gas cap, would those ultimately be recovered? : In the opinion of . . . MR. GILBRETH: Did I understand the testimony correctly in talking about the startup and the volumms of high pressure gas necessary for flaring equipment, etc.? Am I assuming wrong if I assume that there is too much gas there to be diverted into an intermediate or low pressure syste~ to keep from flaring during startup or are there other triggering problems associated with it? In other words, you open up your well, you take the high pressure gas and it's all going out ( ) What are the reasons if you can't cross fl~ it or switch it into intermediate system at that stage? -67 MR. CHAE~ICK: Our probl~n primarily is one of t~rature. When the oil is cold the gas cc~es off extremely cold. You can't really start ccmmissioning ( ) in the neighborhood of 100 degrees F ( ) up, until that point really ( ) it's a large volume of gas relatively to the oil ( ) as you take 4 - 6 hours to get your temperatures, that's quite a significant volume of gas up to most of the ( ) subs ~equant to turning over the HP in the PG system gas the remainder of the gas ( ) you can't really have until you get the temperature up. MR. GILBRETH: I assume that you people looked over the possibilities of trying to accelerate the temperature and have concluded that the only way is to bring on some good wells in a hurry. MR. CHADWICK: Yes, sir. If you try to accelerate it too much the oil goes over the top of the ) as and well. MR. HAMILTCN: In your testimony, Mr. Berdon, I believe you testified that in the case of a ccmpressor failure flare volumes at the flow stations of 2.3 million cubic feet per hour)I gather that the cc~bination of both the IP LP is 1.4 million cubic feet per hour. And yet in your earlier testimony at a flow station I understand you have a ccmplete standby but at the gathering centers it looks as though you are operating at 88% capacity ( ). MR. CHADWICK: This is right. -68 .MR. HA~iILTON: flow station ( ~question is why does it require to flare more gas at the than it does at the gathering center with no standby? MR. BERDON: That was assuming that the standby capacity was not available, that is the amount of gas, actual amount of gas ~e %~uld flare, if we did not have this standby capacity available and we lost the ccmpressor. If we did have it available, then of course we could handle that full volume through the standby ccml0ressor and not flare at all. MR. HAMILT(~: This is a .question 'addressed to both operators, are there any types of equi~t where you foresee maintenance procedures where you anticipate shut dc~m that would result in flaring? ~. BERDON: I think any routine or planned maintenance that can be planned and you do have and as we testified, the flexibility to switch production to other facilities, so that in a planned situation we would ( ) other than that amount required to bring a facility down and start it back up. MR. HAMILTON: Do you have any plans ( ). MR. CHADWICI{: ( ) Require flaring during the actual maintenance because once we get GC 3 on line ( ) production but if you bring a station d~ too quickly ( ) then ( ) planned shutdown ( ) one or two key items scme of the scrubbers which are covered to the flow stations ( ) frc~n time to time but not ( : What would happen ( ) intermediate pressure both -69 : Yes, each compressor can operate LP machinery, no problem .equit~nent ( ) hours a day the IP machines ( ) hours a day, problem to bring the ( ) down or the machines and that's our only way of knowing ( ) MR. HAMILTON: This rate can be brought down fairly rapidly? MR. CHADWICK: Under those conditions it can be brought down fairly rapidly, yes. It would take us rather long to jack the rate up elsewhere ( ). MR. HAMILTON: ( ) ? MR. CHAE~ICK: The answer to that, Mr. Hamilton, in many of these conditions where the ( ) goes out the reason for the failure is a very small control problem, it's very tricky ( ) 15 minutes - 20 minutes, in which case it just isn't worth reassigning production, trying to ( ) them out. Normally we just have to flare for a few minutes and then bring it straight back on again and this has happened relatively frequently in the last two months and that seems to be the most ccmm~n cause for the failures. MR. GILBRETH: How do you determine the trade off between flaring or shutdown? It's not meant to be a loaded question. : It depends on the ( ) ~R. CHADWICK: That's a very difficult question to answer because it depends on the case concerned and really the best approach to it I think would be to perhaps set up a series of possible ( ) with normal guideline of reaction -70 that would be proposed to handle it. sure I can handle it. That'is really the cnly way I can be MR. GYI.RRETH: Mr. Berdon, you mentioned in your testimony several things that can occur and one of them is engineering and well testing as a possibility. Could you elaborate just a ~t and give me scme examples of the way it would be necessary to flare during the engineering and well testing category. ~at would you ( ) MR. BERDON: Engineering well testing might include equipment evaluation, for example, scme of these burner tips that will burn crude oil clean and the testing that we have had tests, run tests on those, sc~e of our wells that required acidizing and we've had to burn the well fluids because of their corrosiveness rather than be taken in the facilities and it's these types of things. MR. GILBRE~t: Do you have the capability to isolate a well that way so that you don't flare all the production, or you have to flare production frcm several wells ( ). MR. BERDON: In the cases where we've done this acid stimulation work we do isolate the well. We have to put in individual piping to get to a burn pit with it, but the normal flowlines do not allow us to take it to the burn pit. MR. GILBRETH: This is a question I will address to both ccmpanies and you may want to have scmeone else answer them, I don't know. I would like to know if the shutdown of the field, or the shutdown of a well, so far as you -71 knc~ now results in any damage to the reservoir or loss of ultimate recovery? I think that ~ould be a question for our reservoir .people to MR. GILBRETH: That's why I'm asking because it has a bearing on %~at kind of an order we might issue on flaring. : All right, sir, that will be fine. ~. BERDON: ~r. Chairman. MR. GILBRETH: Yes, sir. MR. BERDON: Would you mind repeating that ..question ( ) MR. GTT.RRETH: My question was and I don't kn~l whether I can repeat it exactly or not, but will a shutdown of the field or a shutdown of individual wells cause damage to the reservoir or result in the loss of ultimate recovery frcm the reservoir? We have a situation in Cook Inlet where possibly there are scme problems if you shut-in a well and we know on the North Slope at Prudhoe Bay if you result in damage when you shut in a well or if it's production is restricted to prevent flaring. MR. GILBRETH: That's all the questions I have. -72 MR. HAMILTON: It's my understanding, correct me if I'm wrong, that the need for this purging system ( ) is required because of the arctic environr0ent ( ). MR. CHADWICK: No, fundamentally it's r _equired to stop air infiltrating into the end of the flare lines causing flan~mable mixtures. It's not necessary ( ). Yes, you could use any gas ( ) bringing stations long enough after shutdc~n ( ) 16,000 barrels a day, waiting crude oil, that's the minimum ( ) MR. CHADWICK: No, that's the minimum rate required to putting a compressor ( ) on the last two occasions when we brought GC 1 up on the planned program to minimize flaring we turned the gas over to CCP at about 50,000 barrel rate and then increased the rate to about 60,000 barrels per day rate. ( ) MR. CHADWICK: On a cold start on the 18th of November C~ 1 had been down for 11 days and the conditions were really quite cold, the flow lines were all down to ambient temperature or near ambient temperature. .The ambient was around -20 and it took us 24 hours to cc~e up fully on line and it took 7 hours to reach the 120 degree level at which we could ~ssion the TEG systems bringing on cold wells. We had a short hitch the following day which shut the station dc~n again and it was down for about 18 hours. We came back up and this would be considered a hot start, as everything had already been warmed. It took us 3 hours, a little less than 3 hours to reach the same 20 degree level and it took us scmething like 4 hours to -73 have the cc~plete station on line to the point where we could ( really is the difference between cold and a hot start. ). That MR. HAMILTC~]: Mr. Berdon, according to your testimony you indicated that ( ). Could you explain this a little bit? ~. BERDON: Yes, I think if we would attempt to bring wells, additional wells at other facilities ( ) foaming and control problems in the separator trains and create scme situations, so that the carryovers into the c~mpressor scrubbers and what not that creates flaring as a result ( ) formal testimony ( ) MR. GILBRETH: ( ) without objection be made a part ( ) just a mc~ent... MR. GILBRETH: Gentlemen, we understand that you will submit som~ additional information on the possibilities of reservoir damage and we %~uld like to keep the record open for 2 weeks from today to give you an opportunity to submit that information at that time, then the records will be closed. By virtue of the regulations we are requ~ ired to issue an order within 30 days after the record is closed, which if the full thirty days was used would put us beyond January. I understand Arco now has approval to go I believe until January 2 under the existing administrative approval and the cc~m~ittee will extend that administrative approval until the date of an order, whatever date that is. That's all we have unless you. -74 Is there anyone frc~ the audience who wishes to make a statement? All right, then we will declare this hearing closed. -75 ~kmcnded Notice o~' ]h9~lic ]lear. lng State of Alaska Dep~tment of Nat~n_~a~ Resources Division of Oil and Gas Conservation Alaska Oil ~d Gas Conservation Committee Consel~ation Order No. 145A Re: The motion of the Alaska Oil and Gas Conservation Ccmmittee to hold a public hearing to hear testimony to determine the proper amount of gas robe flared as safety flares at oil producing and related facilities in the Prudhoe Oil Field and other matters relating to gas flaring in this field. Notice is hereby given that the Alaska Oil and Gas Conservation Cc~mittee on its own motion will hold a public hearing to deter~f~ne the amount of gas that is necessary to be flared in order to purge and maintain safety flares which ignite gas vented from vessels and lines under pressure in the event of an operational upset, fire, or unforeseen catastrophe. Other matters that relate to gas flaring in the Prudhoe Bay Field will also be heard, such as the relationship of flaring to the function of production equipment. The hearing will be held pursuant to 11 AAC 22.540 and will be held at 9:00 A~4 in ~e basement of the Pioneer Schoolhouse, Third and Eagle Streets, Anchorage, Alaska on November 29, ~977. Thos. R. Marshall, Jr. Executive Secretary Alaska. Oil and Gas Conservation Ccrs~..ttee 3001 Porcupine Drive Anchorage, Alaska 99501 Publish: Novem%er 12, 1977 STATEMENT OF QUALIFICATION FOR CECIL CHAPMAN Mr. Chairman, members of the Committee, my name is Cecil Chapman. I am employed with Atlantic Richfield Company as District Facilities Engineer for the North Alaska District. I joined Atlantic Richfield in 1956 after graduation from Texas A & M University. I hold Bachelor of Science Degrees in Petroleum Bngineering and Chemical Engineering and am a member of several technical and professional societies .... Prior to moving to Alaska in 1969, I acquired drilling, production, reservoir and project engineering experience in various Lower 48 locations. While in Alaska, my work. has been concentrated on development, startup and operation of the Prudhoe Bay Field. In my present capacity, I am responsible for project engineering, operations engineering and development planning for surface facilities in the ARCo operating area of the Field. QUALIFICATION STATEMENT My 'name is Louis Berdon. I am Operations Coordinator for Atlantic Richfield's North District Operations. I received a B.S. Degree in Petroleum-Geology in 1957 and did some graduate work at Louisiana State University. I immediately went to work in field operations with Texas ~astern Gas Transmission Company and spent several years with.that company and later Sinclair Oil and Gas Company in gas measurement, .quality control, instrumentation and.well testing. Subsequently, I held various positions · in field operations involving direct supervision of gas production, gas gat~'~ring and gas plant compressor and process operation and maintenance. I was transferred to Alaska in 1969, and since July of 1969 when initial Prudhoe Field development operations were established at Prudhoe Bay, I have been involved in most phases of the Atlantic Richfield Prudhoe Bay Operation; directly supervising in the field for 3-1/2 years as Operations Supervisor and Field Coordinator at Prudhoe Bay and then in staff functions in Anchorage as District Production Supervisor, Training Coordinator and Operations Coordinator. ,:'~?ii..'i~OL¥! ~'~'? While serving in staff positions in Anchorage I was involved in much of the operational design review of the present Atlantic Richfield facilities. My present position as Operations Coordinator, which I have held since February 1975, is involved with assisting in the management and coordination of the Prudhoe Unit operation.primarily in matters associated with gas. MY NAME IS KENNETH F. CHAD!~ICK. MY POSITION IS MANAGER OF PRODUCTION FOR BP ALASKA, INC. I WENT TO SCHOOL AT THE UNIVERSITY OF EXETER, DEVON, WHERE I GRADUATED WITH A DEGREE IN PHYSICS AND MATHEMATICS IN 1951. I HAVE BEEN ACTIVELY ENGAGED IN PRODUCTION OPERATIONS IN THE OIL INDUSTRY, WORLD-WIDE, SINCE 1953. I HAVE BEEN WITH BRITISH PETROLEUM LTD SINCE FEBRUARY 1959. I HAVE BEEN ASSOCIATED WITH THE DEVELOPMENT OF THE PRODUCTION FACILITIES AT PRUDHOE BAY INTERMITTENTLY SINCE 1970. I PRESENTLY HEAD THE PRODUCTION DIVISION AND AM RESPONSIBLE FOR THE DIRECTION OF ALL PRODUCTION-RELATED ACTIVITIES IN THE WEST OPERATING AREA OF THE PRUDHOE BAY UNIT. PUBLIC HEARING STATE OF ALASKA DEPART~ENT OF NATURAL RESOURCES DIV. OF OIL AND GAS CONSERVATION ALASKA OIL AND GAS CONSERVATION CO~ITTEE Conservation Orde'r No. 145A INTRODUCTORY STATEMENT - PUBLIC HEARING REGARDING CONSERVATION ORDER NO. 145A Mr. Chairman, members of the Committee, representatives of Atlantic Richfield Company and BP Alaska Inc., acting in their capacity as Operators of the Prudhoe Bay Unit, are here today for purposes of presenting testimony in response to your Notice of Hearing dated November 12, 1977 concerning the conservation of gas produced from the Prudhoe Oil Pool. For the record, I am Mark Singletary. I am a member, in good standing, of the Alaska Bar AssOciation and have served as Regional AttorneY for Atlantic Richfield Company in Anchorage since January of 1971. Subject to your concurrence I will make a brief introductory statement which I have been authorized to make on behalf of'the Working Interest OWners of the Prudhoe Bay Unit and then introduce our witnesses for purposes of establishing their credentials as experts and presenting the balance of our testimony. While both Atlantic Richfield Company and BP Alaska Inc. have found it necessary frOm time to time to flare certain quantities of gas Produced from the Prudhoe Bay Field, and generally for reasons of safety and the further exploration and development of the Field, including more recently the commissioning, testing, and purging of the production facilities, we are committed to the conservation of this valuable natural resource; and we are satisfied that our Presentation today will confirm this commitment. 'This Committee issued its first Pool Rules in early 1970 for production and drilling operations in the ?rudhoe Bay Field, and has consistently utilized identical language with respect to the venting or flaring of ~gas in each succeeding revision of these rules. Rule 8 currently reads as follows: "The venting or flaring of gas is prohibited except~as may be authorized by the Committee in cases of emergency or operational necessity." From the discovery of the field in 1968 un~il~ June of 1977 there was essentially no production other than that necessary for the Crude Oil Topping Plant (COTP) owned by Atlantic Richfield Company and Exxon Corporation and a small amount of gas production used as fuel for operation of the Central Power Station. The Committee has issued a number of conservation orders allowing the flaring of certain quantities of casinghead gas resulting from the~processing of crude oil at the Crude Oil Topping Plant. Although the matter of the COTP is a separate situation apart from the production facilities for the Prudhoe Bay Unit, those orders dealing with the COTP are illustrative - 2 - of the Committee's continued involvement and commitment to the conservation of natural gas from the Prudhoe Bay Field. With the completion of the construction of production, treating, processing and related facilities in the Prudhoe Bay Unit, including the first two Flow Stations and Gathering Centers and the Central Compressor Plant, and with the startup of the TransAlaska PiPeline System imminent, the Committee authorized the Operators to flare gas necessary for the essential but limited.purpose of commissioning, testing and purging these new facilities pending the further orders of this Committee. 'The field has been on production for five months and the initial facility operating Problems and need for flaring of gas have been 1.argely identified.by the OPerators. It is therefore appropriate at this time to establish the quantities of gas needed for safety pilot and purging purposes in the field on. an ongoing basis, establish basic ground rules under which the Operators will be permitted to flare gas under conditions of emergencies or.operational necessity, and the conditions under which the Operators must report these incidents to the Committee. At the conclusion of this hearing we ~ill present to you proposed rules which we believe set high, but achievable standards for the Operators in their efforts to conserve gas and would 'adequately protect the interests of the State in the conservation of gas. Before the Working Interest Owners and the Operators could develop a proposed rule regarding flaring for the Prudhoe Bay Field, basic policy had to be formulated keeping in mind the prior rulings of this Committee, our operating experience, as well as the unique characteristics of the Prudhoe Bay Field. After considerable discussion and thought among the Operators and the Working Interest Owners, the folloWing policy has been agreed upon: The Working Interest Owners have directed the Operators to maximize the conservation of gas and to .seek rules from this Committee permitting the flaring of gas only for the following reasons: (1) for safety pilot and purging purposes; (2) for emergencies; and (3) thOse volumes required as a result of operational ne~cessity in the shutting down or starting up of facilities or for a reasonable period of time to analyze and correct a malfunction. Thus with'' respect to operational necessity, the Working Interest Owners have directed the Opera~ors to limit flaring to'that required as a result of the shutting down or starting up of a facility or to analyze and correct minor malfunctions, unless · the Committee gives approval to additional flaring for a specific purpose. In'the presentation which follows, Mr. Cecil Chapman of Atlantic Richfield Company will describe the design, gas handling capability, and operating parameters of the ARCo operated Flow Stations, Central Compressor Plant and Field Fuel Gas Unit. His presentation will be followed by that of Mr. Ken Chadwick of BP Alaska Inc. who will similarly describe the Gathering Centers operated by it. Mr. Louis Berdon of Atlantic Richfield Company will then outline the necessities for.flaring within the policy guideline I have just stated. Finally, Mr. John Reeder of BP Alaska Inc. will present proposed conservation rules to the Committee for its consideration. Introduction and qualification of witness.es. - 5 Process Flow ARCO OPERATED FACILITY DESCRIPTION Atlantic Richfield Company has been designated Operator of the Prudhoe Bay Unit EaSt Area. The wells in this area are directionally drilled from strategically located drill'sites. Six sites are in operation at present, with anticipated future expansion to fifteen. Exhibit 1 shows schematically directional drilling from a typical drill site. Individual drill site lines connect each well to its respective drill site manifold. At the manifold, which is housed in a building adjacent to each site, production from all wells at that drill site is preSently combined into two common flow lines for d~livery to a Flow Station. Well tests areperformed at each drill site using a test separator housed in the same building as the drill site manifolds. Exhibit 2 is a map of the ARCo-operated area. Flow Stations land 2, respectively, serve the central and eastern portion of the area. A future separation facility, Flow Station 3, is planned to serve the western portion of the ARCO-operated area. At the flow station, the well fluids are separated into crude oil, gas and water. The crude oil is delivered through an oil gathering system to the Alyeska Pipeline Service Company Pump Station. 1. The gas is dehydrated and delivered through a gas gathering system to the Central Compressor Plant. The produced water is injected into a water disposal well which is located adjacent to each Flow Station. The Central Compressor Plant (CC?) handles produced gas from both the ARCO and BP operating areas. The gas is compressed through two stages and injected into ten gas injection wells, which are completed in the Prudhoe Oil Pool gas cap. The CCP will ultimately have a total of twelve compressors, eight first stage and four second stage. The Field Fuel Gas Unit (FFGU) is housed in separate modules a safe distance from the CCP. It is connected'to the CCP by utility hallways. Feed gas for the FFGU is taken from the interstage header at the CCP during normal operation; however, during emergencies, feed can be taken by reverse flow of 'a gas injection well. The gas is conditioned and delivered for fuel to both operating areas plus the first four Alyeska pump stations. Flow Station Process Descript. ion Exhibit 3 is a simplified flow schematic which traces the oil,.water and gas flows from the wells through a Flow Station, the Central Compressor Plant and the Field FuelGas Unit. The purpose of a floTM station is to separate crude oil, gas and water. Both Flow Station 1 and Flow Station 2 are presently designed to process 360,000 BPD crude oil, 495,000 MSCFD ofgas (1375 GOR) and 13,000 BPD of produced water in three equally sized separation trains.. Well fluid enters the flow station through common flowlines from the drill sites, and is then · diverted into one of the three parallel separation trains. Initial separation of gas and liquids takes place in the High Pressure (HP) separator . Normal operating conditions are 650 psig and 170°F. Liquid from the HP separator is routed to the Intermediate Pressure (IP) separator with the gas going to the HP gas conditioning section. Three-phase separation of oil, water, and gas occurs in the IP separator. Water from the IP separators is routed to a produced water drum. Oil from the IP separator then enters the treater flash drum for the third stage of separation. Normal operating conditions of ~the IP separator are 85 psig and 153°F. ~ The flash'drums and electro-static treaters operate as a unit at 25 psig. and 151°F. Gas separates in the flash drum and enters the Stock Tank Vapor (STV) gas system while oil and/or oil-water emulsion flows by gravity to the electrical coalescing section of the treater. The treater water is cOmbined with water from the other separationtrains and is dumped to the produced water drum. Crude oil from each of the three parallel treaters is routed to a common crude oil surge drum which operates at 148°F and 1.5 psig. The crude oil is then pumped through the oil gathering system to the Alyeska Pipeline Service Company origin station. The water handling facilities at each flow ~tation inject the produced water into a water disposal well located at each of the facilities. Flow station gas facilities are installed for recovery and conditioning · of HP, IP, Treater and Stock Tank Vapors to permit transfer to the CCP for injection into the Prudhoe Oil Pool gas cap. This is a conservation measure of major proportions. Feed gas to the HP gas conditioning facilities is gathered from the oil separators at three different pressure levels; HP gas at 650 psig, IP gas at 85 psig, and STV gas at 1.5 psig. Treater and oil surge tank vapors are combined as Stock Tank Vapor (STV). IP and STF gas is compressed, cooled, and combined with HP gas from the HP gas scrubbers. The resulting total HP gas ~can then be split between two 50% (247.5 MMSCFD each) gas conditioning trains for delivery to the Central Compressor Plant, while Condensed liquids are recycled to the oil facilities. Each gas conditioning train consists of five parts: 1. ~Mo HP gas coolers, each consisting of two air-cooled, force draft bays in parallel control Of hydrocarbon dewpoint. 2. Residue gas scrubbers and gas filter/separator from which separated hydrocarbon condensate is flashed to the IP suction scrubber and water is routed to the produced wate~ drum. 3. Glycol contactors and associated glycol knock out' drums where the wet gas is dehydrated to minus 40°F water dewpoint by contact with triethylene glycol (TEG). 4. Residue gas heaters to maintain the residue gas stream at a level about 10°F above its hydrocarbon dewpoint at the entry to the Central Compressor Plant. 5. A glycol regenerator package to reconcentrate the TEG solution. 4 Ingersoll-Rand multistage centrifugal compressors are utilized for both STV gas and IP gas compression. £achunit is a six-stage horizontal- type compressor. The two STVgas compressors are identical and the two IP gas compressors are identical for ease of operation and maintenance. The flow station gas facilities have the capability of handling a''. ~. design rate of 495 M~SCFD with one of the two STV/IP compressor/turbine sets out of operation. Normally one turbine drives one STV and one IP compressor at full loading on each. The second turbine is on standby service with no load on either of its compressors. The design capacities are 15 MMSCFD and 55 ~.~.~CFD for the STF and IP compressors, respectively; therefore the STF gas is 3% and the IP gas is 11% of the total flow station gas capacity. General Electric D~ 1500 gas generators were selected to drive Ingersoll-Rand power (hot gas expansion) turbines. This generator/turbine set has the capability of producing over 12,000 HP at site conditions of 40°F and sea level. Upsets in operating conditions or failure of mechanical devices that cause flow interruption can result in a surge condition ina compressor. A surge condition must be avoided at all times or it will cause extensive damage to the compressor, requiring costly repairs and downtime. There- fore, an antisurge recycle loop protects eachcompressor, This feature permits recirculation of discharge gases back to the compressor suction to insure inlet volume avails. Extremely sensitive differential pressure and flow elements using very-rapid-response instrumentation, control the antisurge control valve. The control valve is closed during normal operations; however, during startup operation or upsets in flow condition, the control valve will recycle part or all of the capacity of the compressors to avoid a compressor surge condition, thus minimizing the need to flare gas until stabilized compressor suction volumes are available. Flow Station Flare System In the event of fire, power loss, or equipment malfunction, ~nd during startup operations, HP gas contained in a flow station must be discharged for the protection of life and property. The flow station flare system will safely and completely burn this gas.' Additionally, process piping and process vessels are protected by relief valves. Ail reliefs are sent to the flare system for proper disposal. Exhibit 4 is an aerial view of a flow station flare. The Flow Station Flare System consists of several burners mounted on multiple horizontal headers nearground level over a lake area. ~wo parallel systems handle a wide range of possible flare loadings. One system flares STVgas while the second flares IP and HP gas. The total capacity of the sTv ground flare is 20 ~4SCFD. The ultimate capacity of the IP/F~ ground flare will be 495 ~SCFD..r~his volume is based on emergency shutdown of the HP gas facilities. The initial capacity of the IP/HP flare is 300 ~SCFD due to the lower GORduring the early stages of production. These flare systems were installed to satisfy the conditions of smokeless burn and were approved by the Alaska State Dept. of F~vironmental Conservation. ~6 STV, IP, and HP flare gases pass through knockout drums located mvay from the flare area. These vessels remove liquids entrained in the flare gases to insure efficient flaring, although the flare can handle small amounts of liquid. Three parallel pipelines, one each for the STV, IP and ttP systems, transport the gas to a flare manifold building. In the manifold building, the STV line tees into the STV manifold and the IP and H1> lines tee into the IP/HP manifold. The S2¥ gas arrives at the STV flare header slightly above atmospheric pressure and in order to achieve smokeless combustion an assist gas is used. An assist gas header parallels each STF header and each burner element on the assist gas header has a Venturi orifice. The STV gas is piped to the bottom of the Venturi where it is entrained and burned with the assist gas. The STV stream is subdivided into five stages and the IP/HP stream is subdivided into four stages. Quick acting valves are located at the inlet' to each header to sequence or stage the flow of flare gases. ' Staging has been engineered so the proper volume of gas is transmitted at the proper operating pressure in each header, thus assuring efficient operation of each burner. Full capacity backup systems exist for the STV, and IP/HP flares and operate'only whenthe'respective primary system is under repair or malfunctions. Since the ground flares rarely operate, air may penetrate the headers leading to the' burners and form an explosive mixture of air and flare gas. In order to prevent this condition, a constant volume of purge gas is fed through the STV, IP and HP pipelines. ~e first stage header on both the STV and IP/HP Flare Systems allows purge gas to pass through the first stage burners. The safety pilot gas ignition system consists of a'supply of natural gas fed by a series of lines to continuously burning pilots. A gas ignition system remotely ignites the pilots. Thermocouples placed on key pilots monitor their operation and initiate an alarm in the main control room if they malfunction. Operating experience to date· indicates that a safety pilot and purge gas volume'of 1000 MSCFD per flo~v station is sufficient for operating purposes. Central Compressor Plant/Field Fuel Gas lMit Process The Central Compressor Plant (CC?) is used to compress gas received from each of the flow stations and gathering centers for injection into the Prudhoe Oil Pool Gas Cap. Thus, this major facility has gas conservation as its primary purpose. The CCP has the capability of handling a design plant inlet rate of 1760 ~SCFD with one compressor/turbine unit out of operation. If a first- stage unit is shut down, the interstage pressure decreases, the rpm of the other units will increase, and the design rate is maintained. Conversely, if a second-stage unit is shut down, the interstage pressure increases, the rpm of the other ~mits increases, and the design ~ate is maintained. 8 Referring again to Exhibit 3, gas enters the CCP through two lines; one from the West side (BP) of the field and one from the F~ast (ARCO). Normally, the gas stream will be free of liquids; however, small amounts of glycol may be present in the gas leaving the Flow Stations and Gathering Centers. In addition, liquid can enter the lines as a result of process upsets, insulation failure, or startup conditions. Liquids are removed from the lines by launching spheres at the flow Stations and ball receivers located at the entrance of the CCP are used to retrieve the spheres. Large volume inlet separators are provided for each line to trap out entrained liquids. The volume of liquid received 'as a slug at the 'inlet separators during normal Qperations Can be controlled by the frequency of line pigging. After leaving the inlet separator, the gas enters one of four inlet filter/separators for removal of trace solid and~liquid contaminants. The gas then enters the compressor inlet header, which mainfolds the eight first-stage compressor trains together, at 600 psig and is compressed to 2075 psig under normal operations. Compression of the gas is accompanied by a rise in the gas tmmperature of approximately 200°F due to work done on the gas. Therefore, an interstage cooler is required to cool the discharge gas of each first-stage compressor to an acceptable temperature of 85°F for second-stage compression. Cooling the gas to 85°F has the added advantage of lowering horsepower required in the second stage of compression. The design' rate for each first-stage compressor is 215 ~MSCFD. Gas from the first-stage coolers discharges into the interstage header, which manifolds the four second-stage compressor trains together, and is compressed by the second-stageunits from 2,075 to.4,500 psig. As before, this compression is accompanied by a rise in the gas temperature. Aftercoolers are required to cool the gas before injection. The design rate for each second-stage compressor is 415 ~..~CFD. Dresser-Clark multistage centrifugal compressors were selected for both first and second-stage compression. ~ach unit is a sLx-stage barrel-type. compressor. The eight parallel first-stage compressors and the four second-stage compressors are identical for ease of operation and maintenance. General F~lectric Frame 5 single-shaft gas turbines were selected as the prime movers for the compressors. Ail twelve gas. turbines have the capability'of producing over 25,000 hp at Site conditions of 40°F and sea level. Fuel gas to the turbines is normally supplied from the CCP low- temperature separation unit with a design capacity of 80 ~4SCFD. Backup fuel is supplied from the FFGU. As is the case with the flow' station compressors previously~ discussed, upsets in operating conditions or failure of mechanical devices causing flow interruption can result in a surge condition in the compressors. Thus, to assure stabilized conditions and to minimize flaring, each CCP compressor is protected with one antisurge recycle loop. This 10 loop permits recycle of discharge gases back to the compressor suction during periods of startup or upsets in the flow conditions. The Field Fuel Gas Unit (FFGU) conditions gas for use as fuel by all Prudhoe Bay Facilities as well as the first four A!yeska Pump Stations. A water dewpoint of -60°F and a hydrocarbon de~looint of -40°F were selected as the design basis for the fuel gas. A total of 100 ~SCFD of fuel gas can be conditioned by each of the two hydrocarbon and water dewpoint control trains. Normally the supply to the FFGU is a compressed gas stream from.the interstage header in the CCP. Gas pressure is reduced to 1740 psig through a pressure control valve and the gas enters filter/separators for removal of liquid and.solid contaminants. ~e gas stream isnext contacted with .lean triethylene glycol (TEG) in' fourteen-trayglycol contactOrs where a water dewpoint of -60°F is attained. Each glycol contactor has an as'sociated glycol regeneration unit. The dehydrated gas stream is then expanded through a throttle valve from 1740 to 850 psig. The gas and liquids in the expansion stream are separated in the low temperature separator (LTS). The sudden expansion of.the gas results in a temperature of -40°F in the separator, which is the approximate hydrocarbon dewpoint of the gas. The gas ' leaving the low temperature separator is reheated by the incoming feed gas and enters the fuel gas system at .approximately 840 psig and 35°F. For initial startup, the feed stream for the FFGUwas gas cap Well stream fluid produced by backflow from a gas injection well. Two gas 11 injection wells are specifically equipped for this purpose. This gas is cooled or heated as required to maintain a gas cap inlet separator temperature of 85°F. Any produced water is separated from the Natural Gas Liquid (NGL) and transferred to the waste water system. NGL is dumped to the NGL flash drum. The gas leaving the gas cap inlet separator is fed to the FFGU inlet filter/separator. Natural gas liquids (NGL) are collected at the CCP in the inlet separators, inlet filter/separators, first and second-stage suction scrubbers, and the LTS unit. Natural gas liquids are also collected at the FFGU in the gas cap inlet separator, inlet filter/separator, and the low temperature separator. These natural gas liquids'are fed to one of two NGL flash drums which operate at 635 psig and 3°F. The vapors fr~n these drums are fed to the inlet filter/separators at the CCP. The remaining NGL is boosted, filtered and injected into the Prudhoe Oil Pool gas cap. Thus, conservation of both hydrocarbon liquids and vapors is an integral part of the process. CCP Flare Process As noted with the Flow Stations, the high pressure gas being processed in the CCP and FFGUmust be discharged~in the event of fire, power loss, or equipment malfunction and~during startup operations. Also~ all process piping and process vessels are.protected by 'relief valves. All relief gases will be sent to the flare system for proper disposal. ~e flare system, therefore, is essential to safe and efficient facility operation. The Central Compressor Plant ground flare is situated over a lake area 12 and is separated into two parallel systems identified as the High Pressure (HP) Ground Flare and the Low Pressure (LP) Ground Flare. The two systems are necessary to provide the flexibility required to handle the range of possible emergencies. Exhibit 5 is an aerial view of the CCP Flare. Both the HP and LP flare gases first pass through specially designed knock-out drums located in the CCP, which remove a major portion of the entrained liquid in the flare gases. Removal of this liquid is necessary for efficient flaring, although small amounts of liquid can be efficiently burned by the flare. Two parallel pipelines, one HP and one LP, transport the gases t'o the flare manifold building. ~e manifolds in this M~ilding distribute the ~[P and'LP flare gases through. a series of headers. The main stream of either the HP.or LP. system is subdivided into five stages. Quick acting valves are located at the inlet to each header to sequence ([stage) the flow of flare, gases to the headers. The staging of the flare gases ~has been carefully engineered so the the proper volume of gas is transmitted at the proper operating pressure in each header, thus assuring efficient operation of each burner. As a safety measure, two separate backup systems are incorporated into the overall design. These are identified as the High Pressure Backup Flare and the Low Pressure Backup Flare. These systems provide 100 percent standby for their respective primary system. Both will operate 13 only when the primal7 system is do~m for repairs or fails to function properly. Since the High and Low Pressure Flare Syst~ns are normally inactive and operate only in the event of an· emergency, there is the possibility of air penetrating the supply headers leading to the burners and forming an explosive mixture of air and flare gas. In order to eliminate this condition, a ~onstant volume of purge gas is fed through the LP and t-~ pipelines. The first stage header on both High and Low Pressure Flare Systems is constantly open thus allo~ing purge gas to pass through the first stage burners. The safety pilot gas ignition system consists of continuously burning pilots. Experience obtained thus far indicates that a safety pilot and purge gas volume of 1000 ~CFD wil!.be sufficient for operating purposes. .~ Crude Oil Topping Unit Exhibit 6 is an aerial view sho~ving the Crude Oil Topping Plant. The Crude Oil Topping Plant, located immediately to the west of the ~d~Co base camp, while not a Prudhoe Bay Unit facility, was initially constructed and subsequently enlarged for the purpose of providing fuel for the further exploration and development of Prudhoe Bay. Field. The Plant is currently subject to Administrative Approval No. 98-Bo6, which established a maximum safety pilot volume of 400MSCF/D. 14 The C~mde Oil Topping Plant is designed to supply up to 3500 barrels of diesel fuel and naphtha (motor fuel) per day from a total crude oil charge of approximately 15000 BOPD. The crude oil charge is taken from the gathering system between Flow Station 2 and Flow Station 1. After the diesel and naphtha products have been recovered, the remaining crude (residual) is returned to the gathering system. This concludes my testimony on the description of facilities in th~ East Operating Area. At this point, Mr. Ken Chadwick of BP Alaska, I'nc. will describe facilities in the West Operating Area. 15 TYPICAL DRILL SITE SCHEMATIC Exhibit #1 ARCO OPERATED · · CENTRAL GAS : :FACiLITtESi · LEGEND ROADS ~DRILL SITES ~ FLOW STATIONS .... L.,_~_: GAS GATHERING LINE. ---*--- CRUDE OIL OATHERING LINE ,-----FLOW LINE &.MAINTENAGE ROAD #2 Exhibit #4 , J Exhibit BP AlASKA-OPERATED FACILITY DESfRIIPTIONS BP Alaska Inc., as Operator of the West Area of the Prudhoe Bay Field, will ultimately operate three Gathering Centers and the Central Power Station. Slide No. 1 is an aerial photo of Gathering Center No. 1; Slide No. 2 is a photo of Gathering Center No. 2. The basic purpose of each Gathering Center is to separate oil, water, and gas. Each plant, located in an extremely hostile environment, is complicated, heavily instrumented for rain/mum manning, and 10 to 100 fold larger than other dc~estic oil production facilities.~ As can'be seen, all facilities are enclosed; the flare pad, which will be discussed later, is in the upper left of the photo and the burn pit can be seen on the upper right side of the Slide. Copies of these photos as well as other exhibits are included at the end of our prepared testimony. o. The following discussion will describe the function, operating parameters, and capacity of the oil, water, and gas systems and discuss the opera- tional necessity and safety requirements for intermittent flaring of gas. "OIL"SYSTEM The nominal design throughput capacity of each GatheringCenter is 300,000 barrels of stabilized crude oil per day. Slide No. 3 shows a basic flow~diagram for a Gathering Center. Each Gathering Center is ,! equipped with four production separator banks, each designed to process 75,000 barrels per day of stock tank oil, and one test separator bank designed to process 25,000 barrels per day of stock tank oil. The syst~ is designed for three stage separation of oil, water, and gas with the high pressure separator operating at 650 psig, the int~iate pressure separator at 95 psig, and the low pressure separator at 2 psig. Chemelectric dehydration and interstage cooling for vapor pressure control of the crude are provided between the second and third stages of separation. The stabilized crude oil is pumped frc~ the low pressure separators at 150OF, through subcoolers, and into the 34" oil transit line at about 140OF. ~TER ' SYS~M Produced water'from the crude oil separators, chemelectric dehydrators, gas plant scrubbers, and the T~G regeneration system is treated in the water clarification plant to remove oil and solid particles prior to injection into the two water disposal wells at each Gathering Center. The water Clarification plant, rated at up to a 10% water cut or 30,000 barrels of water per day, incorporates tw~ identical 15,000 barrels per day treatment trains for increased operational flexibility. Ccmmon to both trains are an inlet oil skimmer, injection pump charge tank, slop oil tank, and three parallel-operated, centrifugal water injection pumps. Each train c~ntains individual dissolved gas flotation units, water booster pumps, and filters. Oil that is removed from the produced .water is returned to a low pressure separator in the oil plant. GAS SYSTEM The gas processing system at each Gathering Center is designed to handle 480 MMSCS~ of off gas. Gas processing consists of cc~pressing low pressure and intermediate pressure separator off gas sufficiently to combine it with the high pressure separator off gas. The combined gas streams are then dehydrated to prevent condensation, corrosion, and hydrate formation during shipment in the gas transit line to the Central Compressor Plant for injection into the gas cap. Three. functional subsystems of the Gathering Center gas processing · system are the low pressure (LP) cc~pressors, intermediate pressure (IP) compressors, and the high pressure (HP) gas dehydration/triethylene glycol (TEG) regeneration equi~nent. Each subsystem will be briefly discussed. Low'Pressure~GasCompression Low pressure separator off gas fremthe third stage separators is cooled to 90°F and scrubbed to remove any liquids before compression to inter- mediate pressure. Between the low pressure compressor suction scrubber and the low pressure compressor, a take off from the low pressure process header is provided for flaring low pressure gas during operational , upsets. Low pressure gas can be flared at the burn pit or burned smokelesslyby the Coanda flares with the addition of drive gas. Low pressure separator off gas is compressed from 1 psig to the intermediate system pressure of 90 psig by two DeLaval 1,500 horsepower, motor-driven centrifugal compressors, each rated at 8 MMSCFD. The two machines, connected by cc~ron suction and discharge headers, are operated in parallel. At Gathering Center design throug~ut, the two machines will ~ress the 12 MMSCFD of low pressure off gas plus about 2 MMSCFD of reclaimed triethylene glycol regeneration reboiler effluent stripping gas, or a total of 14 MMSCFD. Therefore, at design rate, the machines will be 88% loaded. Operations to date have verified the design throughputs. Intermediate 'Pressure ~Gas 'Compression Intermediate pressure separator off gas is ccmpressed frcm 90 psig to' the high pressure system pressure of 620 psig by two DeLaval 4,000 horsepower, motor-driven centrifugal ccmpressors, each rated at 27 MMSCFD. As with the low pressure compressors, the two intenuediate pressure machines are connected by contain suction and discharge headers for parallel operation. At maximuuu Gathering Center capacity, the intermediate pressure machines will cc~press the int~ate pressure separator off gas plus the compressed low pressure gas, or a total of 47 MMSCFD. Therefore, the intermediate pressure compressors should see a maximum loading of about 88% at Gathering Center design capacity. As with the low pressure ccmpressors, operations to date have verified the design throughputs. It should be noted that the low pressure and int~iate pressure gas' volumes will change by only minor amounts as the average field GaS/Oil ratio increases. The additional gas will be r~oved frc~ the crude oil in the first stage, high pressure separators and, therefore, the high pressure off gas system had to be designed to handle twice the current volumes of high pressure gas at the Gathering Center design oil rate. In contrast, the intermediate pressure, second stage and low pressure, third stage Gas/Oil ratios will remain relatively insensitive to the increase in well Gas/Oil ratio. Simply stated, the increase in volumes of gas that must be processed will not cause additional loading on either the low pressure or intermediate pressure cc~pressors. The only way to change the volume of gas in either the low pressure or inter- mediate pressure systems is to change the oil throughput of the facility. While maximum gas rate capacities of cc~pression facilities are an important consideration in conservation of gas, minimum .gas rate Capa- bilities of the compressors are equally, if not more so, important in minimizing flaring due to operational necessity. All compressors are equipped with piping to recycle compressed gas from the discharge back to suction .to ensure .an adequate gas supply to the machines when oil rates and associated separator off gas rates are low. This is necessary to prevent a condition known as "surging", which occurs when the gas .flow through 'the compressor becc~es so low. that the high pressure gas at the c~mpressor~ discharge actually flows ba~ds through the machine to the low pressure suction. Surging puts extreme loading on the cc~pressor bearing system and can very quickly destroy a machine. The recycle gas, being taken from the compressor discharge and having been heated from 90°F to 340°F due to heat of compression as it' passes through the machine, must be cooled and then scrubbed to remove the heavier liquid components formed by condensation during cooling. The cool, scrubbed recycle gas, now suitable for recycle use, is actually lighter than the separator off gas for which the compressor is designed. Therefore, the lower the oil rate and associated separator off gas rate to the compressors, the greater will be the demand for recycle gas and, also, due to continuous stripping out of the heavier cc~ponents during recycling, the lighter the recycle gas will bec~ne. Stated differently, at some minimum oil rate, the amount of recycling required to prevent surging causes excessive stripping of the heavier gas components in the recycle flow and the cc~posite gas (recycle plus minimum separator off gas) being fed to the mchine becomes too light for safe and proper operation. Operational experience has shown that an oil rate of 60,000 barrels of oil per day is the minimum rate to supply adequate separator off gas for compressor operation. At rates less than this, there is so much low molecular weight recycle gas that ~the compressors simply fail to pump. The risk of losing a compressor train by trying to run the machines at oil rates lower than 60,000 barrels of oil per day does not justify the probable consequences on operational flexibility. Hiqh 'Pressure 'Gas 'Dehydration/Triethylene Glycol 'Regeneration Gas dehydration/triethylene glycol regeneration facilities are typical of those found in oil field operations with the exception that the triethylene glycol (TEG) reboiler effluent stripping gas is reclaimed by low pressure compression. The system is made up of two independent trains, the gas con, actors be'lng designed for a future Gas/Oil ratio of ,. 6 1,450 SCF/STB, or a total gas rate of 480 MMSCFD. At present Gas/Oil ra~ios, each train can dehydrate the total volume of gas at Gathering Center design oil rate. Three T~G boostar pumps and three T~G high pressure pumps are cross-manifolded to provide an operating spare for either train at maximum design rate. The gas dehydration facilities are designed to dehydrate a water saturated gas feed at 90°F to a dry gas product having a water dew point of -40OF at the gas transit line pressure of 610 psig. This concludes the general facility process descriptions and operational restrictions related to gas conservation that are determined by equitmnent rate and capacity requirements. Safety features must be designed into every facility to prevent the disasterous consequences to personnel and equit~ent which could result frcm overpressuring, whether caused by operator error, equi~t failure, or environmental conditions. Every vessel must be equipped with pressure relief valves; off gas systems are designed to vent under excess pressure, and vital equipment is protected by mechanical failure shukdowns which automatically result in the venting of gas. COANDA FLARE SYSTEM At a predicted future Gas/Oil ratio of approximately 1,450 SCF/STB associated with a Gathering Center design capacity of 300,000 barrels of oil per day, a flare syst~n with a safety relief capacity in excess of 450 MMSCFD had to be designed which met all environmental standards and produced a minimum of thaw damage to the tundra. The Coanda flare syste~ w-as designed to conform to U. S. Federal Agency and Alaska State Agency requirements and has been so approved. These constraints have . resulted in a system of seven flares per Gathering Center in order to cater for the maximum gas volumes. Slide No. 4 shows the basic piping and headers which connect these flares to the Gathering Center pressure relief system. One of the main problems associated with meeting environmental demands was to develop a flare which would burn "smokeless" even with heavy liquid carryover in %he gas or when burning low pressure or atmospheric stock tank gas vapors. The Coanda flare accomplishes this by aspirating excess air into the high pressure gas stream as it exits a narrow slot around the circuntference at the top of the flare stack. The high pressure flare header operates at pressures from 20 to 50 psig to maintain exiting gas velocity adequate for proper aspiration. The heavier low pressure gas is injected through the center of the flare stack into the high pressure gas flame at a maximum weight ratio of 1 pound of low pressure gas to 1.5 pounds high pressure gas (or equal to a volume ratio of 1 SCF of low pressure gas to 3 SCF of high pressure gas). Note that the high pressure flare header gas can 'be either high pressure separator off gas , or intermediate pressure separator off gas, since both are vented through the high pressure flare header. Flare Nos. 1-4 are ccmbination high pressure/low pressure flares and have maximum high pressure volume capacities equal to essentially three times the maximum low pressure volume capacity. Flare Nos. 5, 6 and 7 are high volume capacity high pressure flares only. The minimum rate for flaring high pressure flare header gas by the Coandas is 8 MMSCFD at a 20 psig flare header pressure. Facility operation has been modified in the interest of gas conservation. Previously, minor pressure upsets in the low pressure separator off gas 'system'would result in pressure venting to the flare system. When this occurred, a minimum rate of 8 to 40 ~ of high pressure drive gas was autc~atically flared so as to burn ~the low pressure gas smokelessly. After modifications, an upset in the low pressure separator off gas system now results in pressure relief directly to the burn pit, eliminating the need for the 8 to 40 P~SCFD rate of high pressure drive gas. :If, in fact, the upset appears to be of long duration, the Coanda flare system'can be operated manually by the addition of high pressure drive gas, thus enabling the burning of the low pressure gas smoke- lessly by the flares. In the event of pressure s .urges in the high pressure or intermediate pressure separator off gas systems, the excess high pressure or inter- mediate pressure gas is automatically burned by the Coanda flares via the high pressure flare header. In that the flare system is an integral part of the Gathering Center pressure relief process and must be ready for instant use at all times, it is mandatory that all headers, risers, and piping be maintained in safe operating condition. Air entry into the flare system piping must be prevented because the consequences could be disasterous if an explosive mixture of air and gas ignited. To prevent possible internal formation of ccmbustible mixtures, the piping to each flare and the burn pit is continuously purged with dry natural gas at design rates which prevent explosive oxygen concentrations. Equally as important as maintain'.~ng proper purge rates is the need for a reliable pilot system since the release of unburned hydrocarbons would be extremely hazardous. The safety pilot system used with the Coanda flares is designed by Westech and incorporates a three finger, r~motely lit pilot for each flare and the burn pit. In addition, the burn pit has four atmospheric burners for back up in the event of failure of the burn pit pilot. Operating experience to date indicates the necessary daily safety pilot and purge gas volumes required at each Gathering Center total 1100 MSCF. Contraction purge is an additional purge volume added to the flare piping after a burn. The contraction purge is activated by closure of the flare sequencing valve and its purpose is to prevent entry of air into the flare stack and flare piping due to rapid cooling and con- traction of the internal gas after flaring. The volume of contraction purge gas added is controlled by a separate timer on each flare and is a max/mum volume of 2 MSCF per flare, per burn. CENTRAL POWER STATION In addition to the Gathering Centers, BP Alaska also operates a centrally located electric generating station which is powered by gas turbines and provides electric power for Unit operations. Slide No. 5 shows an aerial photo of the power station. · Current plans provide for a total of seven turbine generators operational during '1978. Five units will be capable of supplying the required electrical power at any given ~ with the two additional units available for routine maintenance, overhaul, and standby. Electrical distribution is accomplished at '69,000 volts by overhead transmission lines which feed separate cc~plete loops to each operating area of., the field. Each separate loop contains power substations which provide 6'9 KV vol .tage reduction for consumption at 4,160 volts, 480 volts,' and 120 volts.. ,, Current fuel gas consumption at the Central Power Station is averaging approximately 14 MMSCED. Fuel gas is normally supplied to the Power Station from the' Field Fuel Gas Unit at a hydrocarbon dew point of -40OF and a water dew point of -60OF. 11 Gas feed to the Field Fuel Gas Unit normally is compressed interstage gas from the Central Cc~pressor Plant or, alternatively, gas cap gas frcm a gas well. In the event of cc~plete loss of capability of the Field Fuel Gas Unit to furnish fuel gas to the Central P~wer station, a gas spur line has been connected from the gas transit line at Gathering Center No. 3 to the Central Power Station. Therefore, conditioned gas from the BP gas transit line can be supplied to the ~ Station for fuel gas during ~uergencies at the Field Fuel Gas Unit/Central Cc~pressor Plant. This concludes my testimony. for flaring. Mr. Berdon will now address the necessities 12 o. GATHERING CENTER- BASIC FLOW DIAGRAM ' ' (;AS DEHYORATIOI~ HEATER! [ C(~OL'ER I SCRUBBER CONTACTOR 90°F 90°F 645 PSIG ~ 645 PSIG I. P. GAS ' COMPRESSED I.R GAS 650 PSIG ;OMPRESSOR GC FUEL PILOTI ~ PURGE GAS I COMPRESSO~ ~ ~ I COOLER~ SCRUBBER ~ 90°F o 90 PSIG o ]L,R GAS ~ ~ . L.P. '' Z X ~ ~ ' SCRUBBER I I COOLER I WE H.R SEPARATOR' i TO PRODUCED WATER CLARIFICATION PLANT GAS TO ARCO CCP TO Pu~p ~.~ STATIONa I FLARE DISTRIBUTION HEADERS 1~ PIPING H.R FLARE HEADER RELIEF VALVES · HP..A ~L.R FLARE L.P. FLARE HEADER RELIEF VALVES L.P. FLARE SEQUENCING VALVES L.E FLARE CONTINUOUS PURGE FLARE SEQUENCING VALVES H.R FLARE CONTINUOUS PURGE #7 a6 e5 #4 #3 **2 ~:7 H, R ~6 H.P. tt5 H.P. 4L, P. 4H, R 3L.P. ti3 H.P. 2L.E 2 H.R i L.P. IH.P, ~RGENCY RELIEF HEAOER ° NECESSITY FOR FLARING Safety was a primary consideration in the design and operation of the facilities for the Prudhoe Bay Field, including those facilities related to the flaring of gas. The necessity for flaring of.gas can be placed in five general categories' 1.' Safety pilots and Purging. 2. Equipment Malfunctions. 3. Facility startup after shutdown. 4. Commissioning of new facilities, 5. Engineering and well testing. 'We have previously ~estified about the necessity for flaring for safety pilot and purging purposes. The remaining categories will now be generally discussed. EQUIPMENT MALFUNCTIONS , . Unlike. planned preventive maintenance shutdowns where process capacity of oil and gas handling can be switched to standby equipment or other facilities, equipment malfunctions are unplanned and unwanted, and usually create an emergency situation. Ail piping and vessels are protected from overpressure by spring operated relief valves or instrumented pressure controllers. Overpressure conditions caused by such things as instrument failures or accidental blocking of systems can usually be corrected quickly and do not constitute a major flaring necessity. Although other equipment malfunctions as'well as operator error can cause flaring, because of the nature of the PruShoe operation~and the large volumes of gas being handled, failure of compressors represents the largest potential necessity for flaring. The gas compressors in the Prudhoe BaY Unit operation are large, sophisticated machines with highly instrumented safety shutdown systems for protection of the equipment and personnel. Unexpected shutdowns could require the release of gas to flare. Compressors'are within the mainstream of proces, s flow and process~ momentum requires that movement of gas~ continue until the operation can be turned do~Vn. At Prudhoe, decreasing gas flow necessitates decreasing oil flow from the wells. 'It is important to note that a single compressor failure at a Flow Station or Gathering Center results in the flaring of intermediate and/or low pressure gas only, which presently constitutes a maximum of twenty percent of total facility throughout. - 2 - To accommodate the operation of compressors and the time required to decrease oil flow, it therefore becomes necessary .for the Unit Operators to have authority to flare gas for some period of time should an equipment malfunction occur. Production experience to date has indicated that most malfunctions can be remedied and normal operations resumed within twelve hours after the commencement of flaring caused by equipment failure. Prudent operations dictate that during this period measures be taken to eliminate or minimize the volume of gas flared as soon after the commencement of flaring as is operationally feasible. These measures involve reducing gas flow at the affected facility by reducing oil flow, possible.attempts to correct the equipment failure, and a well coordinated field-Wide effort to smoothly redistribute production to prevent potential flaring at other facilities. 'It should be emphasized that rapid, uncoordinated attempts to shift production can easily and most probably will lead to excessive flaring at other facilities. Again, production experience to date has indicated it can take as long as four hours to assess an equipment malfunction, and either correct the problem or begin shifting production to other~facilities. The following are estimates of maximum potential flare volumes associated with a single compressor failure at either a Flow Station or Gathering Center: Flow Station - 2.3 MMSCFH Gathering Center IP - 1.1 MMSCFH Gathering Center LP - 0.3 MMSCFH Similar volume estimates for individual compressor failure's at the Central Compressor Plant (CCP) are more difficult to make because of the number of compressor combinations and the range of first stage and second stage discharge pressures. As mentioned, the CcP was designed to'ultimately compress 1760 MMSCFD with one compressor, of a total of twelve, out of operation. This extra capacity was installed to minimize'~the necesS~i~ty~for flaring caused by CCP compressor failures. For estimating flare volumes that might result from CCP compressor failures, the design capacity of eactl first stage compressor is abOut 9 MMSCFH' and the design capacity of each second stage.compressor is about 17 MMSCFH. - 4 - FACILITY STARTUP AFTER SHUTDOWN The restart of any of the Prudhoe facilities requires some flaring of gas. Vessels and piping must be pressured and minimum flow rates must be .established before compressors and process can be placed in operation. Metallurgy restrictions on many of the high pressure vessels require minimum operating temperatures before they can be raised to full.' operating .pressure. This requires warm.flows.of oil and gas from the wells and through'the facilities. There is over 2000 feet of permafrost at Prudhoe Bay and surface temperature changes of 100 fahrenheit degrees from summer to winter occur. The time required to establish warm flows in wells and facilities varies significantly and is dependent on the season and the length of time a facility has been down. The're is a tremendous difference in the time required to restart a facility that has been down a few hour's in summ. er and the time required to restart a faCility that 'has been down' for days or"weeks in mid-winter. We'estimate that restarting a single flow station or gathering center will require flaring as little as 2 MMSCF to over 100 MMSCF of gas, depending on the season and the length of time the facility has been down. Restarting of the entire field would, of course, result in the flaring of much larger volUmes. - 5 - The Operators are implementing restarting procedures that emphasize the maximum conservation of gas. The following criteria are presented to illustrate the startup philosophy developed around the concept of maximum conservation of gas. 1. Separator train (production bank) stability can be obtained much quicker by producing a few good wells at higher rates than by producing as many wells as .possible at necessarily reduced rates. Fewer good wells produced at higher rates will heat up faster, · thus minimizing the time and amount of'gas flared until the gas pro~c.essing facilities are~on Stream. 2. A minimum number of separator trains (production banks) will be used while flaring gas during startup. Separator train (production bank) stability cannot be obtained below minimum rates. When production rates rea~ch this minimum, there will be no more increase until the gas processing facilities are on stream. 3. When high pressure separator temperatures approach 140°F, the high pressure separator off gas can be shifted from the flares to the gas dehydration facilities for dehydration and transport to the central Compressor Plant. - 6 - 4. After the gas dehydration facilities are on line and stable, compression of the intermediate and low pressure gas can commence, thus eliminating gas flaring at the facility. 5. With the Flow Station/Gathering Center completely on line, the oil rate can be increased. Additional cold wells can be warmed slowly at low initial rates into the hot separators because the hot wells supply the heat required to flash the off gas from the cold wells.without causing system upsets. This .general procedure is used for cold startups to maximize the conservation of gas. It is based around, quickly obtaining separator rate and thermal stability at minimum rates until the gas processing facilities are on stream. Although the .amount of'time mequired t° get a production facili'ty up to' design rate is prolonged, conservation of 'gas is maximiZed. coMMISSIONING OF NEW FACILITIES With the continued development of:the Prudhoe Bay Field, new facilities will be brought into operation for the first time. BP Alaska is scheduled .to accept Gathering Center No. 3 for commissioning in April, 1978. Likewise ARCO's third production facility, Flow Station 3, will be ready for commissioning in 1979. The volumes of gas flared during con~issioning of these new facilities will be minimized by using the same general techniques described for operational facility restart. The additional gas flaring required for commissioning a new facility, over that required for startup of a fully operational facili'ty, will be due to the high nUmber of shutdowns caused by process control problems and general commissioning problems associated with starting new equipment. However, by holding the produc'tion to a minimum rate until ~ga~s dehydration and compression facilities are commisSioned and operable, the volume of.gas flared can be kept at an absolute minimum. Application for startup flaring will be submitted to the Committee at that time. F~NGINEERING AND WELL TESTING From time to ~ime it will be neces.sary to flare in conjuction with special equipment or well tests. In these instances applications will be submitted to the Committee for approval ~prior to~the need. This concludes my testimony. At this point Mr. John Reeder will summarize our testimony and present proposed rules. - 8 - CONCLUSION Mr. Chairman, members of the Oil and Gas Conservation Committee, my name is John Reeder, and I serve as Regional Attorney for BP Alaska Inc. The Field Operators on behalf of the Working Interest Owners have presented.testimonY today describing the facilities operated by them in the Prudhoe Bay Field which contain gas handling and gas flaring equipment. They have reviewed the requirements for flaring gas, along with the conclusions they have reached concerning, the capabilities of the equipment in. the Prudhoe Bay Field. All of the testimony presented demonstrates the manner in which flaring should occur to accommodate both safe operation of field facilities as well as conservation of gas. We feel it is evident~that the Prudhoe Bay Field is unique in terms of the location, operation and design of production facilities, and we are hopeful that the Committee will take these factors into consideration in formulating and adopting rules regarding the conservation of gas at Prudhoe Bay. Our production facilities, the Gathering Centers, Flow Stations, and their associated~well pads and flow lines, are designed to ultimately allow one unit of the total six to be out of service and still meet projected production requirements. Upon adoption of final rules governing flaring by the Committee, the Operators intend to formalize procedures to coordinate production both in a manner consistent with the field rules and to achieve the maximum conservation of gas. The Operators wish to present at this time proposed rules which are intended to accomplish the policy objective stated at the beginning of this testimony. The purpose of the proposed rules is to prohibit the flaring of gas, other than those amounts necessary for safety pilot and purging of gas handling facilities, for emergencies or as a result of operational necessity. To this end, the rules proposed specify the average daily volume of gas permitted for safety pilot and purging purposes for each facility which flares gas, and specify a limited period of time duri~lg which flaring can Occur at a facility arising as a result of an emergency or Operational necesSity. As stated in tt~e testimony, experience to date indicates 'that most equipment malfunctions causing flaring incidents can be dealt with an8 corrected within a 12 hour period. The rules proposed contemplate that any flaring incident which requires flaring of gas in exceSs of 12 hours after the commencement of the incident will proceed only after prior approval has been - 2 - obtained from the Committee or its designated representative. If operational necessity requires flaring in excess of that time, the matter is to be presented before the Committee for action on a case by case basis. Finally, the rules proposed include a provision to ensure the reporting of all such incidents, in writing, to the Committee monthly. I would now like to read the proposed rules for the record. Members of the Committee, this concludes the pr. esentation of the Prudhoe'Bay Field Operators in this matter. At this time I woul'd like to ask that all those giving testimony at this hearing on behalf of the Operators come forward and be available for questions should the Committee wish to discuss any particular point of our testimony. Thank you. - 3 - CONCLUSION Mr. Chairman, members of the Oil and Gas Conservation Committee, my name is John Reeder, and I serve as Regional Attorney for BP Alaska Inc. The Field Operators on behalf of the Working Interest Owners have presented testimony today describing the facilities operated by them in the Prudhoe Bay Field which contain gas handling and gas flaring equipment. They have reviewed the requirements for flaring gas, along with the conclusions they have reached concerning the capabilities of the'equipment iB. the Prudhoe.Bay Field. All of the.testimony presented demonstrates the manner in which flaring should occur'to acCommodate both safe operation of field facilities as well as conservation of gas. We feel it is evident that the Prudhoe Bay Field is unique in terms of the location, operation and design of production facilities, and we are hopeful that the Committee will take these. factors into consideration in formulating and adopting rules regarding the conservation of gas at Prudhoe Bay. Our production facilities, the Gathering Centers, Flow Stations, and their.associated well pads and flow lines, are designed to ultimately allow one unit of the total six to be out of service and still meet projected production requirements. Upon adoption of final rules governing flaring by the Committee, the Operators intend to formalize procedures to coordinate production both in a manner consistent with the field rules and to achieve the maximum conservation.of gas. The Operators wish to present at this time proposed rules which are intended to accomplish the policy objective stated at the beginning of this testimony. The purpose of the proposed rules is to prohibit the flaring of gas, other than those amounts necessary for safety pilot and purging of gas handling facilities~, for emergencies or as a result of operational necessity. To this end, the rules proposed specify thin'average daily volume of gas permitted for safety pilot and purging purposes for each facilitY which flares gas, and specify a limited period of time during which flaring can occur at a facility arising as a result of an emergency or operational necessity. As stated in the testimony, experience to date indicates that most equipment malfunctions causing flaring incidents can be dealt with and corrected within a 12 hour period. The rules proposed contemplate that any flaring incident which requires flaring of gas in excess of 12 hours after the commencement of the incident will proceed only after prior approval has been obtained from the Committee or its designated representative. If operational necessity requires flaring in excess of that time, the matter is to be presented before the Committee for action on a case by case basis. Finally, the rules proposed include a provision.to ensure the repOrting of all such incidents, in writing, to the Committee monthly. I would.now like to read the proposed rules for the record. Members of the Committee, this concludes the presentation of the Prudhoe Bay Field Operators in this matter. At this time I would like to ask that all those giving testimony at this hearing on behalf of the Operators come forward and be available for questions should the Committee wish to discuss any particular point of our testimony. Thank you. - 3 - Rule C As soon as reasonably possible, but in any case not more than four hours after the commencement of any flaring~ incident at a facility listed in Rule B arising as a result of an emergency or operational necessity, Operators shall take appropriate action to initiate reduction of flaring to 'the minimum volume reasonably possible consistent with the efficient operation of the field. In any event, no flaring as a result of an emergency or operational necessity shall be permitted longer than twelve hours after the commencement of such an incident withOut a~proval, of the Committee. ' S~ch approval may be obtained by the Operators without hearing, provided that this Committee or its.designated representative makes a finding that immediate action is required, and Provided further that any 'approval subsequently issued shall not be effective for more than 15 days. On a monthly basis, the ~Operator shall report to the Committee or its designated representative, in writing, the commencement, nature and termination of all incidents requiring the flaring of gas in excess o.f~ those volumes permitted in Rule B. - 2 - Rule A PROPOSED RULES Effective the flaring of gas from the Prudhoe Oil Pool is prohibited except for those amounts necessary for adequate safety pilot and purging of gas handling facilities, emergencies or as a result of operational necessity. The flaring for such purposes is limited by Rules B 'and C, unless prior authorization has been received from the Committee by the Operators. Rule B The following daily volume of gas required for safety pilot and purging of gas handling facilities are hereby established for the listed facilities utilized in the production, treating and processing of oil and gas from the Prudhoe Oil Pool. Facility 1. Gathering Center No. 1 2. Gathering Center No. 2 3. Gathering Center No. 3 4. Flow Station No. 1 5. Flow Station No. 2 6. Flow Sta~.ion No. 3 7. Fietd Fuel Gas Unit and Central Compressor Plant Average Daily Volume of Gas Permitted for Safety Pilot & Purging Purposes, Calculated on a Monthly Basis 1,100 MSCF 1,100 MSCF 1,10O MSCF 1,000 MSCF 1,000 MSCF 1,000 MSCF 1,000 MSCF. Amended Notice of Public Hearing State of Alaska Department of Natural Resources Division of Oil and Gas Conservation Alaska Oil and Gas Conservation Cc~mittee Conservation Order No. 145A The motion of the Alaska Oil and Gas Conservation Ccmmittee to hold a public hearing to hear testimony to determine the proper amount of gas to be flared as safety flares at oil producing and related facilities in the Prudhoe Oil Field and other matters relating to gas flaring in this field. Notice is hereby given that theAlaska Oil and Gas Conservation Cc~mittee on its own motion will hold a public hearing to determine the amount of gas that is necessary to be flared in order to purge and maintain safety flares which ignite gas vented from vessels and lines under pressure in the event of an operational upset, fire, or unforeseen catastrophe. Other matters that relate to gas flaring in the Prudhoe Bay Field will also be heard, such as the relationship of flaring to the function of production equipment. The hearing will be held pursuant to ll AAC 22.540and will be held at 9:00 AM in the basement of the Pioneer Schoolhouse, Third and Eagle Streets, Anchorage, Alaska on November 29, 1977. Thos. R. Marshall, Jr. Executive Secretary Alaska Oil and Gas Conservation Ccmmittee 3001 Porcupine Drive Anchorage, Alaska 99501 Publish: November 12, 1977 Notice of Public Hearing State of Alaska DepOt of Natural Resources Division of Oil and Gas Conservation Alaska Oil and Gas Conservation C~mmittee Conservation Order No. 145A The motion of the Alaska Oil and Gas Conservation Cc~mittee to hold a public hearing to hear testimony to determine the proper amount of gas to be flared as safety flares at oil producing and related facilities in the Prudhoe Bay Oil Field. Notice is hereby given that the Alaska Oil and Gas Conservation Cc~mittee on its own motion will hold a public hearing to determine the amount of gas that is necessary to be flared in order to maintain safety flares which ignite gas vented frcm vessels and lines under pressure in the event of an operational upset, fire or unforeseen catastrophe. The hearing will be held pursuant to 11 AAC 22.540 and will be held at 9:00 AM in the basement of the Pioneer Schoolhouse, Third and Eagle Streets, Anchorage, Alaska on November 29, 1977. Thos. R. Marshall, Jr. Executive Secretary Alaska Oil and Gas Conservation Cc~mittee 3001 Porcupine Drive Anchorage, Alaska 99501 Publish: November 3, 1977 Questions Asked by Conse~'vation Committee at Nov. ember 29, 1917.._Hearing A.. .Ques.tio. ns by Mr. Gilbreth 1. How were the safety pilot volumes determined? 2. Is it possible to useless than the safety pilot volumes specified? 3. Is it possible,~to restrict production during the four hour time period specified in proposed rule C? 4. When a malfunction occurs, why don't you close in everything quickly? 5. How long would it take 'to close down completely a gathering Center or flow station? 6. (Directed at.BP) How about the possibilities of circulating hot fluid or some other substance to keep temPeratures up in the event of a malfunction? (Gilbreth noted that ARCo has done some circulating through the COT for temperature equilibrium purposes.) B. ..Questions by Mr. Hamilton 1. (Directed to BP) BP has earlier estimated volumes of 813 MCF/D for safety pilot purposes and presently asks for 1100. MCF/D; why the difference? 2. (Directed to ARCo) Earlier the Company had est,imated volumes of 600 MCF/D for safety pilot purpose.~ ~n8 n~,~ asks for ~OOO M~zn- ~-- ,~ ~' C. Questions by Mr, Marshall 1. (Directed to BPi As to proposed rule C., is there a four hour period before 'the operator takes any action to reduce production and/or flaring. Mr. Marshall seemed to think t~at each situation will be quite different; did not think the four hour limit wou].d mean anything practically speaking. Mr. Marshall related that he thought it would be difficult to keep track of and document each event requiring the utilization of proposed rule C. and also related that it would be okay with him to leave the four hour provision out. 2. Mr. Marshall ,proposed a hypothetical, of a flaring incident which would require flaring in excess of the twelve hours specified in rule C. and noted that rule C. would require Committee approval. Mr. Marshall was concerned over what kind of approval was contemplated by the rule C. -- verbal or written approval. Mr. Marshall apparently had concern over whether or not rule C. was flexible enough. 3. Mr. Marshall also wished to knorr if it were possible to draw some 'line as to when a verbal approval would be appropriate and. when a written administrative approval would be necessary for incidents involving flaring for more than the twelve hours specified in rule C. 4. As to the fifteen day period specified in proposed rule C. for approvals, Mr. Marshall did not seem to like this provisiYn and stated that he thought it might "bind up" everyt]~ing. He suggested that perDaps Committee and the operator should have more flexibility, i.e., that the approval could be for duration of longer than the fifteen days specified .in proposed rule C. D. Questions by Mr. Gilbreth 1. What unusual things have happened during startup that have required flaring? (Mr. Gilbreth noted that the Committee had been criticized over the volumes being fl.ared at Prudhoe, that this question was to provide the opportunity for the operators to explain some of the incidents requiring flaring since startup). 2. Is the safety pilot gas metered? E. Questions by Mr. Hamilton 1. What did thel O-ring repair at the CCP cost? 2. Is there standby power at the gathering centers and flow statLo, ns? 3. How much gas is being used to achieve the "smokeless'" burn required by the Department of Environmental Conservation? F · ~uestions by Mr. Gilbreth ,. 1. Is there any gas presently being flared at the Crude Oil Topping Plant? G. Questions bY Mr. Hamilton 1. Hamilton.noted that the volumes actually reported as being used for safety pilot purposes as the Crude Oil Topping Plant are significantly smaller than the'400 MCF/D limit presently applicable to the COT, ~and questioned whether the present 400 MCF/D limit was perhaps too high. H. Questions by Mr.. Gilbreth 1. What volumes of natural gas liquids are being reinjected into the gas cap? 2. Will the reinjected natural gas liquids be recovered? ~ 3. Is there too much gas being hand'led upon startup to switch to the IP or LP systems so that gas Will not be flared? I. Questions...by Mr. Hamilton 1. As to the vOlumes quoted in the testimony on a .compressor failure, at t}~e Flow Station or Gathering Center level, Hamilton noted that ARCo's volume is higher than BP's and noted further that ARCo has standby capacity at the flow station, and asked why then more gas would be flared at a~ ARCo Flow Station than at a BP Gathering Center? 2. Are there routine maintenance proced'ures which will' require flaring? 3. What happens' at a Gathering Ccnter if compression is lost on the, IP and LP systems? J. Questions by Mr. Gilbreth 1. How do you determine trade off between shutting down and flaring? 2. As to the engineering and well testing necessity for flaring, why flare in those instances?,. 3. "Will the.shut-down of the field or indiVidual wells damage the reservoir or result in the loss of ultimate recovery from the reservoir?" (This is the question to be answered in wr'iting wi thin two weeks.) K. ~Questio.ns by Mr. Hamilton 1. lVhy is purge gas needed? The hearing was 'then concluded with the record to be left open for two weeks for the written response to the question ,quoted in J.3. above. December 12, 1977 Mr. Thomas R. Marshall, Jr. Executive Secretary Alaska Oil and Gas Conservation Committee 3001 Porcupine Drive Anchorage, Alaska 99501 Dear Mr. Marshall' Re' Conservation Order 145A During the hearing before the Alaska Oil and Gas Conservation Committee on November 29, 1977, Mr. Gilbreth asked the Operators: "Will the shut-down of the field or individual wells damage the reservoir or result in the loss of ultimate recovery from the reservoir?" The persons testifying did not come prepared to speak to this point. The Operators take this opportunity to reply to this question and request this letter be included in the record of the hearing. Based on the current knowledge of reservoir behavior, there is no reason to expect that the shutting-in of any particular well, or the field as a whole, will cause damage to the reservoir or result in loss of ultimate recovery. However, it is possible as more is known about the reservoir and as producing conditions change, evidence will develop which will support a contrary conclusion. ., As stressed in the testimony at the hearing, the need for flaring at Prudhoe Bay is nOt based on reservoir considerations but is based on safety and operational necessity arising from operating characteristics of the production and gas handling equipment. To require the shutting-in of wells and facilities upon commencement of a flaring incident, could result in operator overreaction and possibly create operational upsets or unsafe conditions at other facilities. The proposed rules for flaring offer a mode of operation which would provide the opportunity to analyze the problem source and to correct malfunctions. Such a mode of operation would vastly decrease the likelihood of human error. Mr. Thomas R. Marshall, Jr. Page 2 December 12, 1977 We believe it sufficiently critical for us to re-emphasize that it would be extremely difficult to operate the Prudhoe Bay Field in a safe and efficient manner without the type of flexibility inherent in the proposed rules. BP ALASKA INC. ATLANTIC RICHFIELD COMPANY QUALIFICATION STATEMENT My name is Louis Berdon. I am Operations Coordinator for Atlantic Richfield's North District Operations. I received a B.S. Degree in Petroleum-Geology in 1.957 and did some graduate ~¢ork at Louisiana State University. I immediately went to work in field ope.rations ~vith i Texas Eastern Gas Xransmission Company and spent several 'i years ~vi'th that company and later Sinclair Oil and Gas Company in gas measurement, quality control, instrumentat!ion and ~vell testing Subsequently, I held various positions in. field operations involving direct supervision of gas production, gas gathering and gas plant compressor and process operation and maintenance. I was transferred to Alaska in 1969, and since July · of 1969 when initial Prudhoe Field development operations were establishe'd at Prudhoe Bay, 'I have been involved in most phases of the Atlantic Richfield Prudhoe Bay Operation; directly supervising in the field for 3-1/2 years as Operations Supervisor and Field Coordinator at'Prudhoe Bay and then in staff functions in Anchorage as District iProduction Supervisor, Training Coordinator and Operations Coordinator. While serving in staff positions in Anchorage I ~as involved in much of the operational design revie~ of the present Atlantic Richfield facilities. My present position as Operations Coordinator, which I have held since February 197S, is involved with assisting in the management and co.ordination of the Prudhoe Unit operation.primarily in matters associated ~ith gas. MY NA~.tE IS KENNETH F. CHAD['!ICK. MY POSITION IS MANAGER OF PRODUCTION FOR BP ALASKA, INC. I WENT TO SCHOOL AT THE UNIVERSITY OF EXETER, DEVON, WHERE I GRADUATED WITH A DEGREE IN PHYSICS AND MATHEMATICS IN 1951. I HAVE BEEN ACTIVELY ENGAGED IN PRODUCTION OPERATIONS IN THE OIL INDUSTRY, WORLD-WIDE, SINCE 1953. I HAVE BEEN WITH BRITISH PETROLEUM LTD SINCE FEBRUARY 1959. I HAVE BEEN ASSOCIATED ~IITH THE DEVELOPMENT OF THE PRODUCTION FACILITIES AT PRUDHOE BAY INTERMITTENTLY SINCE 1970. I PRESENTLY HEAD THE · PRODUCTION DIVISION AND AM RESPONSIBLE FOR THE DIRECTION OF ALL PRODUCTION-RELATED ACTIVITIES IN THE WEST OPERATING AREA OF THE PRUDHOE BAY UNIT. ~ NOTICE TO PUBLISHER ., INVOICE MUST BE IN TRIPLICATE SHOWING ADVERT~,~,NG ORDER NO., CERTIFIED AFFIDAVIT OF PUBLICATION (PART 2 OF THIS FORM) WITH ATTACHED COPY OF ADVERTISE- MENT MUST BE SUBMITTED WITH INVOICE. Anchorage Daily Div. Oil & Gas Conservation 3001 Porcupine Anchorage, z:s.. 'v' E N DC; i-:~ N Q. 2 PUBLISHER D~:PT. ~O A.O NO, I0 4014 I D~kTE OF A.D. ?~overgber 10~ 1977 DATES ADVERTISEMENT REQ. LI!RED: THE MATERIAL BETWEEN THE DOUBLE L:NESMJST BE PRINTED iN t,; ENTIRETY ON THE DATES SHOWN. BILLING ADDRESS: AFFIDAVIT-OF-PUBLICATiON UNITED STATES OF AMERICA STATE OF Alaska _ Third DIVISION. BEFORE ME, THE UNDERSIGNED, A NOTARY PUBLIC THIS DAY PERSONALLY APPEARED Mary,L. Russ_eli .... WHO, BEING FIRST DULY SWORN, ACCORDING TO LAW, SAYS THAT HE/SHE IS THE Legal Clerk OF THA ANCHORAGE DALLY .ND, iS PUB LISHED AT Anchorage tN SAiD DIVISION Third __AND STATE OF Alaska _AND THAT THE ADVERTISEMENT, OF WHICH 'THE ANNEXED tS A TRUE COPY, WAS PUBLISHED IN SAID PIJBLICATION ON THE !2t~AY. OF November 77 no , J9__, AND THEREAFTER FOR, CONSECUTIVE DAYS, THE LAST PUBLICATION APPEARING ON THE 12th DAY OF____ November __19__2,7 AND THAT THE Ix 4% Inches $18.90 RATE CHARGED THEREON IS NOT IN EXCESS OF THE RATE CHARGED PRIVATE INDIVIDUALS. THIS!!St__DAY OF~___ Novemhe.r_19__2~ NwTAR ( PUB~_I,~ , On STATE OF a!a~. MY COMM SSION c .~ o R E M N D E R- Ai'TAC~ iNVOICES AND PROOF OF PUBL~CATiON.. Re: ven. te~t fr~n v~sels .~g.(ll.~:l. Jne~ unaer 'l~r.,~.su.r.e':in.fhe'j'~t o, an o~eratl~nd.I up~t,:,flre,~.~ unl loreseen..., catastrophe. T?.~...ther matter,Mint relate' lng in Yhe Prudh_M, ~.Y. F e c. will als~.tW' hearel;1 mi:l)' as the rel~t~P of f~ F~..IP the · :'""" ' · ~'% i~!,"% ' m~,.,~ ..... '.".t ,. ~j~..~. ...',.,..,- , ~.. ~ , T~.~..,~ ~.u~.u~ ~l~.,t ~:~ ~ ~men~ ~ th~' PI6~ ~lhou~J Third and ~.,~ ~ ~'~tr~ts. Anchorage, ~ ~ Novem Executiv~orv Alaska OIr~as ~n~rvatiofi~ommittee ~1 Porcupine Drive Anchor~e, Alaska ~. \ 2. PUBLISHER ADVERTISING ORDER NOTICE TO PUBLISHER INVOICE MUST BE IN TRIPLICATE SHOWING ADVERTISING ORDER NO., CERTIFIED AFFIDAVIT OF PUBLICATION (PART 2 OF THIS FORM) WITH ATTACHED COPY OF ADVERTISE- MENT MUST BE SUBMITTED WITH INVOICE. Divisic~ of Oil and Gas Ccssercatio~ 3001 P~rcupine Drive Anchorage, Alaska 99501 VENDOR NO. DEPT. NO. A.D. NO. DATE OF A.a. 11/3/77 DATES ADVERTISEMENT REQUIRED: /~ / ~ " ./ ""~2. THE MATERIAL BETWEEN THE DOUBLE LINES MUST BE PRINTED IN ITS ENTIRETY ON THE DATES SHOWN. BILLING ADDRESS: AFFIDAVIT-OF-PUBLICATION UNITED STATES OF AMERICA STATE OF Alaska ~ ..... DIVISION. BEFORE ME, THE UNDERSIGNED, A NOTARY PUBLIC THIS DAY PERSONALLY APPEARED Mary T.. R~_,sse11 WHO, BEING FIRST DULY SWORN, ACCORDING TO LAW, SAYS THAT HE/SHE IS THE Legal C] ark OF= PUBLISHED AT Th:irc~ND STATE OF A T!4R _ANCHOPAGE DAILY NEWS IN SAID DIVISION AND THAT THE ADVERTISEMENT, OF WHICH THE ANNEXED IS A TRUE COPY, WAS PUBLISHED IN SAID PUBLICATION ON THE 3.A~AY OF November 7 7 no Jg__, AND THEREAFTER FOR CONSECUTIVE DAYS', THE LAST PUBLICATION APPEARING ON THE. 3rd .DAY OF November 19_.2,7 A~,~::..) THAT THE lx 5 5/4 Inches $15.90 RATE CHARGED THEREON IS NOT IN EXCESS OF THE RATE Coii~'igefl0. Order No. 145A / .,"'..:.~'~' ~...~...: ..' .............. · R~',~otlon 6f the Alaska ,~(~' Gas Con~r~tion ~~tttee to hold ' "';' . ~.~.,os ,o ~,orea ".. ~'l~'~.'¢ven that the ~E"~f~&~.' Gbs~'Con--rva-. fi~~'~, .~ o~. mo- jjj~lll:~a ~lic h~ring to ~~~,tO' ee flared In ~~-¢ta~ .safety flares ~~1~:~ vented fram ~e~e. '. ~)~s'under aressure ~~e~ores~n cutes- .l~h~~me.will ~ held au~u~';~ ~,~AC ~.~0 and will be':~';.~.9~ AM_I~ th~ ba~men~)~e~P~neer Anchorage, .'.~l~Ra on NOVe - .~ 29; 1977. ~,~'~ .. T~OS; R. Ma~J.r. Alaska Oil-one~' Co~rvatlo~ Co~mltt~ ~,1. Porcu~ioe..~f~e. ,. Anchbrage, AlasKa 99~1 .. . r ,, . PuC: Nov. 3;'~ , CHARGED PRIVATE INDIVIDUALS. SUBSCRIBL~ AND SWORN TO BEFORE ME TH?.$..~?t.h DAY OF:_ , Nove?.be~ 77-. NOTARY PUBLIC FOR STATE OF Alaska MY CO, MMISSION EXPIRES December 14, 1977 REMINDER- ATTACH INVOICES AND PROOF OF PUBLICATION. Auxmde. d Notice o,' ]h~blic l Iearing State of Alaska Department of Nat~n-a~l Resot~ces Division of ©].1 ~d Gas Conse~-~at.]on Alaska Oil and Gas Consc~-~ation Conservation Order No. 145A Re: 'lZe motion of t3~e Alaska Oil and Gas Conservation Committee to hold a public hearing to hear testimony to determine the proper amouu~t of gas to be flared as safety fl~-es at oil producing a3~d related facilities in ff3~e PrUdhoe Oil Field and other matters relating to' gas flarh~g in this field. Notice is hereby given lfl~at the Alaska Oil and Gas Conservation Ccr~ittee on its own motion will hold a ptfolic hearing to determine the amount of! gas that is necessary to be flared Jm order to purge and maintain safety flares which ignite gas vented from vessels ~d lines m~der pressure in: the event of an operational upset, fire, or unforeseen catastrophe. O~ner matters that relate to gas flaring in the Prudhoe Bay Field will also be heard, such as the .relationship of flaring to the function 'of' production equipment. The he~-.~ri, ng will be .held pursu~.mnt to 11 AAC 22.540 ~d will be held at 9:00 /~.~ in the bas-chant of 'the Pioneer Schoolhouse, Third ~d Eagle Streets, Anchorage, Alaska on November 29,. i977. Thos. R. Nknrshall, Jr. Executive Secretary Alaska. Oil and 'Gas Conservation Committee 3001 Porcupine Drive Anchorage, Alaska 99501 Publish: Nov~rber 12, 1977 STATE~Vf OF QUALIFICATION FOR CECIL CFL~P,Xb~N Mr. Chairman, members of the Committee, my name is Cecil Chapman. I am employed with Atlantic Richfield Company as District Facilities Engineer for the North Alaska District. I joined Atlantic Richfield in 1956 after graduation from Texas A & M University. I hold Bachelor of Science Degrees in Petroleum Engineering and Chemical Engineering and am a member of several technical and professional societies. Prior to movingtoAlaska in 1969, I acqUired drilling, production, reservoir and project engineering experience in various LoWer48 locations. While in Alaska, my work. has been concentrated on development, startup and operation of the Prudhoe Bay Field. In my present capacity, I.amresponsible for project engineering, operations engineering and development planning for surface facilities in the ARCo operating area of the Field.