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CO 120
Conservation 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. L~- ~-~- Conservation Order Category Identifier Organizing RESCAN (;~olor item [] Grayscale items: [] Poor Quality Originals: [] Other: NOTES: DIGITAL DATA [] Diskettes, No. [] Other, NofType OVERSIZED (Scannable with large [;~~aepr/scanner) [] Other items OVERSIZED (Not suitable for plotter/scanner, may work with 'log' scanner) [] Logs of various kinds [] Other BY: ,,/~ARIA Scanning Preparation DATE: ~) -(~ '"'~k.~ /S/~'~.~..~ TOTAL PAGES /,~=~ ~ Production Scanning Stage1 PAGE COUNT FROM SCANNED DOCUMENT: / ~"~9 PAGE COUNT MATCHES NUMBER IN SCANNING PREPARATION: ¢ YES NO BY: Stage 2 /~ MARIA 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 Consen/OrdCvrPg.wpd STATE OF ALASKA DEPARTMENT OF NATllRAL RESO!IRRES DIVlSIOH OF OIL ANn GAS Alaska Oil and qas Conservation Committee 3001 Porcumine r)rive Anchora.qe, Alaska ~9501 Re: The apolication of l.lnion Oil ) Company of California for an ) amendment to Rule No. 2 of Con-) servation Order Ho. 104 to ) authorize flaring or venting of) casinghead gas from the ~,4c- ) Arthur River Field in cases of ) emergency or operational ) necess i ry. ) Con servation Order !,1o. 120 McArthur River Field ~4iddle Kenai ~'R" Oil Pool Hemlock Oil Pool West Foreland Oil Pool August 22, In73 IT APPEARING THAT: I. Union Oil Company of California submitted the referenced application dated February 8, 1973 on behalf of itself and ~.qarathon Oil Company. 2. Notice of public hearing was published in the Anchorage Daily News on February 13, 1973. 3. An emergency order was written to permit flaring of some plant gas be- cause its liquids were condensing in the Cook Inlet Gas System making it inoperable. The emergency order expired at 7:00 AM February 24, IC~73. 4. A public hearing was held on February 23, Iq73 in the Community Center Building, Anchorage, Alaska at which time the applicants were heard. 5. Conservation Order Fi les Nos. I10 and 120 both pertain to the same problem and we re combined. 6. The Oil and Gas Conservation Committee orally issued the substance of Rules Nos. I, 4, 5 and a portion of Rule Wo. 2 of this order during the hearinp. FI ND I NGS: I. A pipeline has been completed to carry casinghead gas produced from the referenced .pools and other pools to the hlikiski area on the east shore of Cook Inlet. Conservation Order No. 120 Page 2 August 22, 1973 2. The volume of casinghead .qas produced from the Tradinp Ray Field, which is commingled with the gas from the referenced pools, is about I/3 of that anticipated when the line was designed, resulting in less refriqeration being developed by gas drying equipment, and resulting in the residue qas being rich in heavier hydrocarbon components. 3. Ilnforeseen retroqrade condensation of residue Rases in the pipeline has resulted in liquids accumulating in the lowest portion of the line and has caused surging of fluids, exceeding the desiqn capacity of liquid recovery and storage facilities at the eastern terminus of the line. 4. Flaring of some of the rich vapors from the depropanizer equipment at the West Foreland onshore facility results in reduced pipeline condensation. 5. No beneficial use exists for most of the variable volume of liquids and flash-stabilized gas available at the eastern terminus of the pipeline. 6. Alternative methods of eliminating the condensation problem or bene- ficially utilizing flared gas have been considered by the operator and studies are continuing. CONCLUSIONS: i. The unforeseen condensation of hydrocarbon gases in the Cook Inlet gas pipeline has necessitated flaring a small amount of gas from the West Fore- land onshore facility to allow an uninterrupted flow of the residue gas through the pipeline to the Nikiski onshore area. 2. A reasonable period of time is required to determine the most feasible method of eliminating the condensation problem or of beneficially utilizing flared gas and to acquire and install necessary equipment. NOW THEREFORE, IT IS ORDERED: Rule I. Rule 2 of Conservation Order hip. 102~ is hereby amended to read as follows: "Effective no later than 7:00 AM A.S.T. November I, In72, the flaring or venting of casinghead gas from the ~cArthur River Field is prohi- bited except for the amount necessary for adequate safety flares or emer- gencies or as may be authorized by the Committee in cases of operational necessity exceeding 96 hours. ~ Rule 2. Any flaring or venting of gas in excess of 15 days per calendar quarter per platform, other than that required for safety, shall require Committee approval. Flaring or venting of gas in excess of the volume required for safety at a location other than a platform shall be deemed to have taken place at each platform. Conservation ~hrde ri Paf~e 3 -' Au,n. ust ,°_2, Ir~73 P, ule 3. P, ommencinm with the calendar quarter beainning r)ctoher I, In73, the operator of each platform or facilitv in or servina the referenced pools shall report in writinm to the Committee the number of davs nas was flared or vented in excess of the volume rer~uired f~r safety, the reason for the flarin.q or ventin.n, and shall identify the !~latform or facilitv. The report shall be submitted within 3a davs followina each calendar cluarter. Rule 4. Flaring of gas from the depronanizer overhead as rectuired to avoid condensation of excess liquids in the P, ook Inlet gas Pilpeline System is authorized until 7-r~r) AM ADST, I~arch 24, la73. Rule 5. The m, ommittee may extend Rule 4 of this order by administrative approval or approvals but not beyond 7-~0 A~ September I, la73. I]OHE at AnchoraRe, Alaska, and dated August 2~, I~73. Thomas R. ~arshall, Jr., Executive Secretary Alaska Oil and Gas Ronservation P, ommittee ?,oncurrence: ~~ [omer L. 13urrell, m. ha~rman Alaska Oil and P-,as Conservation ~ommittee O. K. r~ilbreth, Jr., ~er Alaska Oil and Gas ~onservation ~ommittee Telecopy ~No. (907) 276-7542 August 31, 1990 A D M i N I S T R A T i V E A P P R O V A L N O. 120.4i Re: Additional excess ~lare days, Grayling Platform, McArthur River Field, Trading Bay Unit. · Faye W Sullivan Environmental Coordinator UNOCAL P 0 Box 190247 Anchorage, AK 99519-0247 Dear Ms Sullivan We have received your letter of August. 28, 1990 requesting additional excess flare days for third quarter 1990 for the Grayling Platform. Excess ga~ is being flared at the platform due to startup following replacement of the test and gross separators. The Commission finds the additional flaring to be an opera- tional necessity, and hereby approves flaring excess gas from the Grayling Platform until September 10, 1990. 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 2000 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 jo/3.AA120 Telecopy No. (907) 276-7542 February 22, 1989 ADMINISTRATIVE APPROVAL NO. 120.40 Re: Additional excess flare days, Trading Bay' Production Facility, McArthur River Field G A Graham District Operations Mgr UNOCAL P 0 Box~190247 Anchorage, AK 99519-0247 Dear Mr Graham: We have received your letter of January 31, 1989 requesting additional excess flare days for first quarter 1989 for the Trading Bay Production Facility, Excess gas is being flared at the onshore facility due.to gas heading of platform production wells. Modifications to the pressure regulating valves on the gas lines at the onshore site are being performed, and are expected to alleviate the surge gas problem. ' The Commission finds the additional flaring to be an operational necessity, and hereby approves an additional 45 excess flare days during first quarter 1989 for the Trading Bay Production Facility. Should the operators require any further excess flare days for first quarter 1989, the Commission will require a meeting with the appropriate parties to discuss the problem and its solution. Sincerely, ............ c~' Smith Commis s ioner BY ORDER OF THE COMMISSION jo/3.AA120 Telecopy No. (907) 276-7542 November 22, 1988 ADMINISTRATIVE APPROVAL NO. 120.39 Re: Additional excess flare days, Trading Bay Production Facility, McArthur River Field G A Graham District Operations Mgr UNOCAL P O Box 190247 Anchorage, AK 99519-0247 Dear Mr Graham: We have received your letter of November 16, 1988 requesting additional excess flare days for fourth quarter 1988 for the Trading Bay Production Facility. Plans are to leave the Liquid Extraction Plant at the facility shut down. The system to utilize the oil flash vapors and reduce flaring is not yet operational, and work continues in that regard. ~. The Commission finds the additional flaring to be .an operational necessity, and hereby approves an additional 51 excess flare days during fourth quarter 1988 for the Trading Bay Production Facility. Sincerely, Commissioner BY ORDER OF THE COMMISSION jo/3.AA120 Telecopy No. (907) 276-7542 October 24, 1988 ADMINISTRATIVE APPROVAL NO. 120.38 Re: Additional excess flare days, King Salmon Platform, McArthur River Field G A Graham District Operations Mgr UNOCAL P 0 Box 190247 Anchorage, AK 99519-0247 Dear Mr Graham: 'We have received your letter of October 20, 1988 requesting additional excess flare days during the fourth quarter for the King Salmon Platform. Due to continuing mechanical problems and a scheduled platform shutdown, an additional 30 excess flare days for fourth quarter 1988 are required. The Commission finds the additional flaring to be an operational necessity for safety and proper reservoir management to maximize oil recovery. The Commission hereby approves an additional 30 excess flare days during fourth quarter 1988 for the King Salmon Platform, McArthur River Field. BY ORDER OF THE CO~MMISSION Jo/3.AA120 Teiecopy f~o. (907) 276-7542 October 24, 1988 A D M I N I S T R A T I V E A P P R O V A L N O. i20.37 Re: Additional excess flare days, Trading Bay Production Facility, McArthur River Field G A Graham District Operations Mgr UNOCAL P 0 Box 190247 Anchorage, AK 99519-0247 Dear Mr Graham We have received your letter of October 20, 1.988 requesting additional excess flare days for fourth quarter 1988 for the Trading. Bay Production Facility. Since the Grayling platform is unable to ship gas to shore while repairing their oil pipeline, the LEX plant, does not have sufficient gas to operate. Therefore, crude flash vapors that would normally go to the LEX plant must be flared. The Co~mission finds the additional flaring to be an operational necessity for safety' and proper reservoir management to maximize oil recovery. The Commission hereby approves an additional 26 excess flare days during fourth quarter 1988 for the Trading Bay Production Facility. Sincerely, Lonnie C Smith Commzssioner .........co sszo J o/3 Telecopy No. (907) 276-7542 October 14, 1988 ADMINISTRATIVE APPROVAL NO. 120.36 Re: Excess flare days, Unocal Grayling Platform, McArthur River Field Gerry A Graham District Operations Mgr UNOCAL P O Box 190247 Anchorage, AK 99519,0247 Dear 'Mr Graham We have received your letter of October 13, 1988. On behalf of Unocal you have requested an additional 26~ excess flaring days for the Grayling platform in the McArthur River Field. Repairs to t'he oil 'pipeline to shore are expected to be complete around November 10, ~988, at which time excess flaring will cease. The Commission determines the excess flaring to be an operational necessity, and hereby authorizes an additional 26 days of' excess flaring for the Grayling platform, McArt'hur River Field. BY ORDER 'OF THE COMMISSION jo/3.AA120 Telecopy No. (907) 276-7542 September 10, 1988 A D M I N I S T R A T I V E A P P R 0 V A L N O. 120.35 Additional flare volume, King Salmon platform, McArthur River Field. Gerry A Graham District Operation Mgr Unocal Corp P O Box 190247 Anchorage, AK 99519-0247 Dear Mr Graham: We have received your letters of September 9 and September 29, 1988 requesting additional excess flare days for third quarter 1988. DUe to continuing mechanical problems on the King Salmon platform an additional 25 excess flare days are required for third quarter 1988.. The Co'~nission finds the additional flaring to be an operational necessity for safety and proper reservoir management to maximize oil recovery. The Commission hereby approves an additional 25 excess flare days during the third quarter of 1988 for the King Salmon platform, McArthur River Field. Lonni~ C Smith Commissioner BY ORDER OF THE COMMISSION dlf/3.AA120 c: Brett Allard, ARCO August 19, 1985 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. 120.34 Re: .Additional flaring for operational necessiny, third quarter 1988, King Salmon platfo~n, McArthur River Field Gerry A Graham District Operation Mgr Unocal Corp P 0 Box 190247 Anchorage, AK 99519-0247 Dear Mr Graham: By phone conversation on August 4, 1988, a representative of ARCO Alaska, Inc informed the Commission of problems on the King Salmon platform which will require additional flaring beyond the 15 days allowable set by Conservation Order No. 120. As outlined in a follow-up letter of August 4, 1988, the majority of flaring is a result of a major overhaul of the Ruston/Clark gas lift compressor. Ina subsequent phone conversation between Russ Douglass of our office and Brett Allard of ARCO, it was decided .a total of 30 flaring days above allowable flare volume for the third quarter of 1988 is neaded to deal with the current problem. We have received your letter of August 17, 1988 as operator of the Trading Bay Unit requesting additional excess flare days. The Commission finds tt{~additional flaring on the King Salmon platform to be an operational necessity for safety and proper reservoir management to maximize recovery. The Commission hereby approves an additional 15 excess flare days during the third .quarter of 1988 for the King Salmon platform, McArthur. River Field. ~,; ~, t,'/ \,,.,.., ~..,, "~ ,~, '1:~' V Chat.~ Chairman jo/3 .AA120 c: Brett Ailard, ARCO February 18, 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 0. 120.33 Re: Additional flaring for operational necessity, first quarter 1988, Dolly Varden platform, McArthur River Field W E Cissell Marathon Oil Company P 0 Box 7619 Nikiski, AK 99635 Dear Mr Cissell: By correspondence dated February 17, 1988 on behalf of Marathon Oil Company, you requested 10 additional flare days for the Dolly Varden Platform facility in the first quarter of 1988.. In your letter and through phone conversations you have apprised the Commission of the situation at the facility which necessitates the additional flare days.. The Commission hereby approves an additional 10 excess flare days for operational necessity at the Marathon Dolly Varden Platform facility during the first quarter of 1988. This brings the tot.al approved flare days for the first quarter of 1988 to 45 (Conser- vation Order No. 120, Administrative Approval No. 120.31, Administrative Approval No. 120.32). It is understood that Marathon will continue: its efforts to alleviate the cause of the excess flare, and inform, the Commission of its progress. All excess gas flared under this authorization shall be metered and is subject to AS 43.55.020(e). o / ? Slgcere!y~ / /' Lonnie ~Smith Commissioner jo/3.AA120 c: John Beitia, Unocal February 4, 1988 Telecopy No. (907) 276-7542 ADMINISTRATIVE APPROVAL NO. 120.32 Re: Additional flaring for operational necessity, first quarter 1988, Dolly Varden platform, McArthur River Field W E Cissell Marathon Oil Company P 0 Box 7619 Nikiski, AK 99635 Dear Mr Cissell: By correspondence dated February 2, 1988 on behalf of Marathon Oil Company, you requested 10 additional flare days for the Dolly Varden Platform facility in the first quarter of 1988. In your letter and through phone conversations you have apprised the Commission of the situation at the facility which necessitates the additional flare days. The Commission hereby approves an additional 10 excess~flare days for operational necessity at the Marathon Dolly Varden Platform facility during the first quarter of 1988. 'This brings the total approved flare days for the first quarter of 1988 to 35 (Conser- vation Order No. 120 - 15 flare days; and Administrative Approval No. 120.31- 10 excess flare days). It is understood that Marathon will continue its efforts to alleviate the cause of the excess flare, and inform the Commission of its progress. Ail excess gas flared under this authorization shall be metered and is subject to AS 43.55.020(e). S inc~r ely,/~ ? Lonnie C Smith Commissioner jo/3.AA120 c: John Beitia, Unocal TELECOPY NO: (907)276-7542 January 29, 1988 ADMINISTRATIVE APPROVAL NO. 120.31 Mr. Wayn~ E. Cissei1 Production Technician Marathon Oil Company P. O. Box 7619 Nikiski, AK 99635 Re: Additional flaring for operational necessity, Dolly Varden platform. Dear Mr. Cissell: By correspondence dated January 21, 1988 on behalf of Maratb_on Oil Company, you requested an additional 10 days of excess flaring for the first quarter' of 1988 for the Dolly Varden platform. As of the 21st, eleven excess flare days of the total allowed by Conservation Order 120 have already been used. The reason for the excess flaring is as yet undetermined for the majority of 'the days in question. Currently you are investigat- ing possible metering problems which indicate excess flare volumes that do not actually exist. The Commission hereby approves an additional !0 excess flare days for the first calendar quarter of 1988 for the Dolly Varden platform. All excess gas flared under this authorization shall be metered and is subject to AS 43.55.020(e). In addition the Commission requests that weekly progress reports concerning the metering investigation be conveyed verbally to Russ Douglass at 279-1433. Very truly yours, ...... ,": "">'~" ' ....... "'" ............. '" ' ~'~l"~" ........... Lonnie C. Smith Commissioner BY ORDER OF THE CO~,'fISSION dlf: 1.P~iD. 3 August 14, 1987 Teleeopy No. (907) 276-75~2 A D M I N I S T R A T I V E A P P R 0 V A L N O. 119.5 & 120.30 Re: Request for extension, pursuant to Rule 2 of Conservatiom Orders No. 119 amd 1,20 to permit the flaring of gas for more than 15 days per calendar quarter for all platforms producing to the onshore Trading Bay Production Facility. Thomas R. Brooks Environmental & Safety Supervisor Marathon Oil Company P. O. Box 102380 Anchorage, AK 99510 Dear Mr. Brooks: The Alaska Otl and Gas Conservation Commission has' considered your request for extended flaring days during the third and fourth calemdar quarters due to the extensive repairs necessary to the Cook Inlet Gas Gathering System 16" pipeline which ruptured on August 11, 1987. It is understood that the gas flared at the Trading Bay Production Facilities is associated gas from the four McArthur River Field platforms (Grayling, Dolly Varden, King Salmon, and Steelhead) and from the Trading Bay Field, Monopod platform. The Commission finds that associated gas flaring until pipeline repairs are completed is an operational necessity. The Commission hereby approves flaring up to 15 MMSCF per day at the onshore Trading Bay Production Facility which commenced on August 11, 1987 and will end on September 25, ]987, or when the pipeline and all facilities have been restored to operational status. Administrative Approval No. 119.5 & 120.30 August 14, 1987 Page 2 It is understood that the flare volume will be metered and is subject to AS 4~.55.020(e). Sincerely, ~ Lonnie C. Smith Commissioner jo/3.AAll9 c: Robert T. Anderson, Unocal Tom Wellman, ARCO Alaska, Inc. December 5, 1984 ADMINISTRATIVE APPROVAL NO. 120.29 Re: Request for extension, pursuant to Conservation Order No. 120, Rule 2, to permit the flaring of casinghead gas originating from the McArthur River Oil Field, King Salmon Platform for more than 15 days per calendar quarter. Mr. J. W. Styler Area Engineer New Projects - Cook Inlet ARCO Alaska, Inc. P. O. Box 100360 Anchorage, Alaska 99510-0360 Dear Mr. Styler: The Alaska Oil and Gas Conservation Commission has considered your request for an extension o.f Rule 2, Conservation Order No. 120 for the King Salmon Platform for the rest of the fourth quarter of 1984 due to failure of the Rustin York compressor. The shut down of production of the King Salmon Platform could damage the reservoir and result in a loss of ultimate recovery. Accordingly, the extension is hereby granted. Ail gas flared under this permit shall be reported and the volume of gas over that which was permitted for safety is subject to AS 43.55.020(e). Yours very truly, Commissioner BY ORDER OF THE COM}{ISSION be: 1. 120 October 1, 1984 A D M I N I S T R A T I V E A P P R O V A L NO. 120.28 Re: Request for extension, pursuant to Conservation Order No. 120, Rule 2, to permit the flaring of casinghead gas origtniating from the McArthur River Oil Field, King Salmon Platform for more than 15 days per calendar quarter. Mr. J. W. Styler Area Engineer New Projects - Cook Inlet ARCO Alaska, Inc. P.O. Box 100360 Anchorage, Alaska 99510-0360 Dear Mr. Styler: The Alaska Oil and Gas Conservation Commission has considered your request for a one day extension of Rule 2, Conservation Order 120 for the King Salmon Platform for the third quarter of 1984 due to failure of. two compressors. The shut down of production of the King Salmon Platfom could have damaged the reservoir and resulted iu~ a loss of ultimate recovery. AccordinglY, the' extension is hereby granted. Ail gas flared under this permit shall be reported and the volume of gas over that which was permitted for safety is subject to AS 43.55.020(e). Your s very truly, Lonnie C. Smith Commissioner BY ORDER OF THE COMMISSION be:l June 28, 1984 A D M I N I S T R A T I V E A P P R O V A L I~0. 120.27 Re: The request pursuant to Rule 2, Conservation Order No. 120, to permit the flaring of casinghead gas originating from the McArthur River Oil Field, Dolly Varden Platform, for more than 15 days par calendar quarter. Mr. D. F. Stover District Operations Engineer Marathon Oil Company P. O. Box 102380 Anchorage, Alaska 99510-2380 Dear Mr. Stover~ The Alaska Oil and Gas Conservation Commission has considered your application of June 28, 1984 for an extension of the 15 day flare period for the second quarter of 1984 due .to oil pipeline repairs. Since the "15 days per calendar quarter" quota will be used on this date and the oil pipeline is still not in. operation, an. extension to Rule 2 of Conservation Order No. 120 for two days is hereby granted. Ail gas flared under this permit shall be metered and the volume of gas over that which is permitted for safety is subject to AS 43.55.020(e). Yours very truly, Harry W." Kug!er Commissioner BY ORDER OF THE COMMISSION be: 3 June 26, 1984 A D M I N I S T R A T I V E A .P P R O V A L NO. 120.26 Re: Request for extension, pursuant to Conservation Order No. 120, Rule 2, to permit the flaring of casinghead gas originating from the McArthur River Oil Field, King Salmon Platform for more than 15 days per calendar quarter. Mr. J. P. Green Area Engineer New Developments -Cook Inlet ARCO AlaSka, Inc. P. O. Box 100360 Anchorage, Alaska 99510-0360 Dear Mr. Green The. Alas. kc Oil and Gas ConserVation Commission has considered your application of June 26, 1984 for an extension of the 15 day flare period for the second quarter of ].984 due to failure of 'three compressors. Since the "15 days per calendar quarter" quota wiI1 be used by midnight and the shut down of production of the King Salmon Platform could damage the reservoi=i, an extension to Rule 2 of onservation Order No. 120 for four',~ days is hereby granted All gas flared under this permit shall be metered and the volume of gas over that which is permitted for safety is subject to AS 43.55.020(e). Yours very truly, 'HarrY W. Kugler/ Commis s loner " BY ORDER OF THE COMMISSION ~:arch 1(~, 19~2 Re: ~equest for extension, pursuant to Conservation Order No. 120, Rule 2, to permit the flaring of casinghead gas originating fron? the ~:icArtI:ur River Oil Field, King Sal~n ?latform for n~ore than 15 days per calendar quarter. ~,Jr. W. C. ~artel ~enior Operations Engineer Cook Inlet Enineertn~ A~.CO Alaska, Inc. P. O. Box 360 Anchorage, Alaska 99'510 [!ear ~::r. Bart'el: The Alaska Oil and (las Conservation. Co~'~misston has considered your appliealion of ~iareh 15, 19~2 for another eatension of the 15 day flare, period, for the first quarter of 19~{2 due to failure of a a~nerator and the shut down of the plat fort;'~. ~ince the "1..5. day~ per calendar quarter" quota has been used and the slmt doyen o:f production on the King Saln~n Platform could damage tl~e reservoir, an extension to lqxlle 2 of Conserva- tion Order N'o. 12{) for one day' is hereby granted. Yours very truly, t:arry W. }i:ugler Cot:trot s s i one r BY THE ORDEt~ OF T~:E March 9, 1982 Re: Request for extension, pursuant to Conservation Order No. 120, Rule 2, to permit the flaring of casinghead gas originating from the McArthur River Oil Field, King Salmon Platform for more than 15 days per calendar quarter. Mr. Don E. Andrews ARCO Alaska, Inc, ?. O. Box 360 Anchorage, Alaska 99510 Dear Mr. Andrews: The Alaska Oil and Gas Conservation Cow.mission has considered your application of }~Iarch 9, 1982 for another extension of the 15 day flare period for the first quarter of 1982 due to failure of a tube in an associated heat exchanger arid the shut down of a compressor. Since the "15 days per calendar quarter" quota has. been used and the shut down of production on the King Salmon Platform could damage the reservoir, an extension to Rule 2 of Conserva- tion Order No. 120 for one day is hereby granted. Yours very truly', Hat ry W. I<ug 1 e r / Commi ss ioner BY THE ORDER OF THE COt~[MISSION ~tWX :be ~arch 4, 1982 l~e: Request for extension, pursuant to Conservation Order No. 120, Rule 2, to permit the flaring of casinghead gas originating' from the MeArthur .River Oil Field, King Salmon Platform for more than 15 days per calendar quarter. Mr. Don E. Andrews ARCO Alaska, Inc. P. O. Box 3(;0 Anchorage, Alaska 99510 Dear Mr. Andrews: The Alaska Oil and Gas Conservation Commission has considered your application of March 4, 1982 for another extension of the 15 day flare period for the first quarter of 1982 due to failure of the electric motor' on the fin fan lube oil Cooler. Since the "15 days per calendar quarter" quota has been used and the shut down of production on the King Salmon Platform could damage the reservoir, an extension t.o Rule 2 of Conserva- tion Order No. 120 for two days or until the motor is repaired, ..... whichever comes first, is hereby granted. Yours very truly:, Harry.W. Kugler Commi s s i one r BY THE ORDER OF THE C~MMISSION February 3, 1982 Re: Request for extension, pursuant to Conservation Order Mo. 120, l~tle 2, to permit the flaring of casinghead gas originating from the ~.eArthur l~.tver. Oil Field, King Salmon Platform for more than. 15 days per calendar quarter. ~r-. Don E. Andrews AE'.CD Alaska Inc. P. O. Box 360 Anchorage, Alaska 995 Dear Mr. Andrews: The Alaska Oil. and Gas Conservati.on Commission has considered your application, of February 3, 1982 for the extension of the 15 day flare period for the first quarter of 19~2 due to failure of the ~uston York gas compressor. Since the "15 days per calendar quarter" quota, has been utilized and the compressor is still inoperable, an extension to Rule 2 of Conservation Order No. 1.20 for 14 days, or until the compressor is repaired, wlatchever comes fir'st, is hereby grant ed. yours very truly, l{arry ~';' 'Kugler, Commi s s, i.one r BY T~{E ORDER OF T?~E ,GB'b~ff SS ION' December 8, 1981 A D M I N I S T R A T I V E A P P It O V A L /No. 120.21 Re~ Request for extension, purs~snt lo Conservation Order No. 120~ ~ule 2~ ~e per~i~ ~he fla~ing of cssinghesd gas criginsting fr~m ~he McArthur Eiver Oil Field. ~ing Ssl~n Platfo~ for n~re than 15 days per, calendar quarter. ~,~r. Don E. Andrews ARGO AlaSka Inc. P. O. Box, 360 Anchorage, .Alaska 99510 Dear Mr. Andrews:. The Alaska Oil and Gas Conservation Commission has considered your application of December 7, 1.981 for the extension of the 15 day flare period, for the fourth quarter of 1981 due to vibration probl'ems on the gas compressor. Since the "15 days per calendar quarter" quota has been utilized and. the .compressor is still inoperable, an extension to Rule 2 of Conservation Order No. 120 for five days, or until the compressor is repaired, whichever comes first, is hereby grant ed. Yours very truly, Harry W. Kugler, Commi ss ioner BY THE ORDER OF THE COMMISSION HWK: be December 1, 1981 Re: Request for extension, pursuant to Conservation Order No. 120, Rule 2., to permit the flaring of casinghead gas originating from the McArthur River Oil Field, King Salmon Platform for more than 15 days per calendar quarter. Mr. Don E. Andrews ARCO Alaska Inc. P. O. Box 360 Anchorage, Alaska 99510 Dear Mr. Andrews: The Alaska Oil and Gas Conservation Commission has considered your application of November 30, 1981 for the extension of the 1.5 day flare period for the fourth quarter of 1981 due to bearing failures on the gas compressor. Since the "15 days per calendar quarter" quota has been utilized and the compressor is still inoperable, an extension to Rule 2 of Conservation Order No. 120 for six days, or until the compressor' is repaired, whichever comes 'first, is hereby granted. .Yours very truly, Harry W. Kugler, Commissioner BY THE ORDER OF THE COMMISSION November 27, 1981 A D M I N I S T R A T I V E A P P R 0 V A L ~._N6~'2~ 120.19 ...... ~:~.:::r: :- .~:::~-~ .. :--.-: ; :::~.: -::~ ~: ::: ~ ~ : ~: : .,, ~,,.=,,,~,., ,,,,,,,, . ~: :: ,,,,~,,,.,~,,.,.~ , ~, ~ ..... ~ .,~', -~ ...... Re: Request for extension, pursuant to Conservation Order No. 120, Rule 2, to permit the flaring of casinghead gas originating from the McArthur River Oil Field, Grayling Platform for more than 15 days per calendar quarter. Mr. Paul T. %~est Union Oil Company of California P. O. Box 6247 Anchorage,. Alaska 99502 Dear Mr. West: The Alaska Oil. and GaS Conservation Commission has considered your application of Novem~ber 23, 1981 for the extension of the. 15 day flare period for the fourth quarter of 1981 d. ue to the. necessity to repair the gas compressor. .Since t'he "15 days per calendar .quarter" quota has been utilized, an extension of six days, or until the repairs'are completed, whichever comes first, is hereby granted. Yours very truly, BY THE ORDER ~OF THE COMMISSION November 23, 1981 Re: Request for extension, pursuant to Conservation Order No. 120, Rule 2, to permit the flaring of casinghead gas originating from the McArthur River Oil Field, King Salmon Platform for lo'nger than 15 days per calendar quarter. Mr. Ken Porter ARCO Alaska, Inc. P.. O. Box 360 Anchorage, Alaska 99520 .Dear Mr. Porter: The Alaska Oil and Gas Conservation Commission has considered 'your oral application of November 23, 1981 for the extension of the 15 day flare Period for the fourth quarter of 1981 due to . the necessity to repair and get back on line the back-uP gas compressor. Since the "15 days. per calendar quarter" quota has been utilized, an extension of five days, or until the repairs are completed, whichever comes first, is hereby granted.. Yours very truly, Harry W. Kugler, Commissioner BY THE ORDER OF THE COMMISSION cc: Mr. D. E. Andrews August 21, 1981 A D M I N I S T R A T I V E A P P R O V A L NO. 120.17 Re: Request for extension, pursuant to Conservation Order No. 120, Rule 2, to permit the flaring of casinghead gas originating from the McArthur River Oil Pield, King Salmon Platform for longer than 15 days per calendar guarter. Mr. D.. E. Andrews ARCO Alaska, inc. P. O. Box 360 Anchorage, Alaska 99510 Dear Mr.. Andrews: The Alaska Oil and Gas Conservation Commission has considered your application of August 20, 1981 for the extension of 'the 15 day flare period for the third quarter of 1981 due to the necessity to~ repair and. get back on line the main gas compres- sor. An extension, following full utilization of your 15 days plus the six (6) days extension per A.A. No. ~20.16, is hereby granted for an additional seven (7) days in this calendar quarter,, or until the compressor becomes fully operable. 'YoUrs very truly, ~arry W. Kugle~' Commissioner BY THE O.RDER OF T~{E COMMISSION HWK:be August 17, 1981 NO. 120.16 Re: Request for extension, pursuant to Conservation Order No. 120, Rule 2, to permit the flaring of casinghead gas originating from the McArthur River Oil Field, King Salmon Platform for longer than 15 days per calendar quarter. Mr. D. E. Andrews ARCO Alaska, Inc. Pe O. BoX 360 Anchorage, Alaska 99510 Dear Mr. Andrews The Alaska Oil and Gas Conservation Commission has considered your application of August 17, 1981 for the extension of the 1.5 day flare period for the third quarter of 1981 due to the necessity to repair and get back on line the main gas compres- sore An extension, following full utilization of your 15 days, is hereby granted for an additional six (6)..days in this calen- dar quarter, or until the compressor becomes fully operable.' Yours Very truly, Harry W. Kugler' ' Commissioner BY T~{E ORDER OF THE COMMISSION March 27, 1980 Re: Request for extension, pursuant to .Conservation Order No. 120, Rule 2, to permit the flaring of, casinghead gas originating from the McArthur River 0il Field, King Salmon Platform for longer than 15 days per calendar .quarter. Mr. D. E. Andrews ARCO 0il & Gas Company P. O. Box 360 Anchorage, Alaska 99510 Dear Mr. Andrew's: The Alaska Oil and Gas Conservation Commission has considered your application o.f 5~arch 26, 1979 for the extension of the 15. day flare period for the first quarter of 1980 due to the necessity to repair and get' back on line the Worthington No. 2 gas compressor- An extension for the referenced request, following full utilization of your 15 days, is hereby granted for an additional five. (5) days in this calendar quarter, as requested, unless the compressor becomes fully operable before the end of the calendar q~zarter. Yours very truly, Harry W. Kugler Commissioner ? BY THE ORDER OF THE COMMISSION ~WE ~ he September 26, 1979 ADMINISTRATIVE APPROVAL NO. 120.14 Re: Request 'for extension pursuant to Conservation Order No. 120 Rule 2 to permit the flaring of casinghead gas originating from t.he McArthur River Oil Field, King Salmon Platform for longer than I5 days per calendar quarter. ,, Mr. D, E. Andrews ARC© Oil & Gas Company P.. O. Box 360 Anchorage, Alaska 99510 Dear Mr. Andrews: The Alaska Oil and Gas Conservation Commission has considered your application of September 25, 1979 for the extension of the 15 day flare period for the third quarter of 1979 due to the necessity to rep.air and get back on line two gas lift compres- sors. An extension for the referenced request, following full utilization of your 15 days., is hereby granted for an addi- tional five (5) days in this calendar quarter as requested., unless the compressors become fully operable before the end of the. calendar ~quarter. Yours very truly, Harry W. ~Kugler Commissioner' BY THE ORDER OF THE COMMISSION H~K: he September 19, 1979 ADMINISTRATIVE APPROVAL NO. 120.13 Re: Request for extension pursuant to Conservation Order No. 120 ~..ule 2 to permit the flaring of casinghead gas originating from the McArthur River Oil Field, King Salmon Platform for longer than 15 days per calendar quarter. Mr. D. E. Andrews ARCO Oil & Gas Company P. O..Box 360 Anchorage, Alaska 99510 Dear Mr. 'Andrews: The Alaska Oil. and Gas Conservation Commission has considered your application of September 18, 1~979 for the extension of the 15. day flare period for the third quarter of 1979 due to the necessity to repair and get back on line two gas lift compres- sors. An extension for the referenced request, following full utilization of .your 15 days, is hereby granted for an addi- tional five (5) days in this c. alendar quarter as requested, unless the compr.essors become, fully operable before the end of the .calendar quarter. Yours very truly, Ho' e H. Hamtlton Chairman/Commiss loner BY T'~.E ORDER OF THE COMMISSION March 19, 1979 Re: ADMINISTRATIVE APPROVAL ~,,~ o. 120..%2 Request for extension pursuant to Conservation Ord. er 1.]o. !20 Rule 2 to permit the flaring of casinghead gas originating from the McArthur River Oil Field, King Salmon Platforn~ for longer than 15 days per calendar quarter. ~r. J. T. Casey Mechanical Engineer Atl.antic Richfield Company P. O. Box 360 Anchorage, Alaska 99510 Dear Mr. CaseY: The Alaska Oil and. Gas Conservation Commission has considered your application of March 16, 1,979 for the extension of the 15 day flare period for the first quarter ,of 1979 due to the necessity t° replace your Solar turbine and overhaul the York sales gas compressor. An extension for the referenced request, following full utilization of your 15 days, is hereby granted for the remainder of the calendar quarter unless the compressor becomes fully operable before the end of the calendar quarter. VeU tru~ ~o~rs, Lonnie C. Smith Commissioner BY ORDER OF THE' COMMISSION February 28, 1979 Request for extension pursuant to Conservation Order No. 120 Rule 2 to permit the flaring of casinghead gas originiating from the McArthur RAver Oii Field, King Salmon Platform for longer than 15 days 'Per calendar quarter. Mr. J. T. Casey Mechanical ~ng.ineer Atlantic Richfield Company P. O. Box 360 Anchorage' Alaska 99510 Dear Mr. Casey.: The Alaska Oil and Gas Conservation Commission has considered your application of February 26, 1979 .for the extension of the 15 day flare period for the first quarter' of 1979; due to the necessity to overhaul your Worthington %1 Gas Lift cOmpress.or commencing on March 5., 1979. An extension for the referenced request is hereby granted for 21 days or until .the compressor becomes fully operable, whichever comes first. Very tru f~ours, Lonnie C. Smith Commissioner June 30, 1978 ~que~ for extensicn pursuant to Cc~servat~ ~ No. 120 Rule. 2to ~t the f].~ing of cas~ gas origi%~attng fr(xa. Mckrthur Ri~ar Oil Field, Dolly Varden Platform for longer than 15 days per calendar qua~. ~arath~n Oil ~y ~/ P. O. Box 2380 An~ge, Alaska 99510 Oil ~ cms. 'O~arvat/on (km~ittee: has cc~sidered your ~1i~~% ~ J~ 27', 1978 f~ ~i~ of ~ 15 ~ f~ ~i~ for ~ ~ of 197'8 ~ ~ ~~~~ ~l~~s. ~ ~~ for ~ ~f~~ ~st is ~r~y ~~ f~ ~ (2): very truly yours., June 29, 1978 ADMINISTRATIVE APPROVAL frum ~Thur Rimer Oil Field, Dolly Varden Platfc~m lc~ger ~ 15 ~s ~ ~1~ ~. The Oil and Gas Oonservaticn Cnmmittee has co~si~ your applicatic~ dated June 27, 1978 f~r a (me day extensic~ of the 15 .day flare ~~l for the second quarter of 1978 .due to .qms leakage problems. An ~sion f~r the r~fere~c~dI ~t is ~ .~anted. Very~ truly yours, I ~ 'I R' Marshall, Jr. I ~ Oil ,and Gas iC~servati~ ~ttee May 8, 1978 , ,~ , ADMINISTRATIVE APPROVAL N~ 120.8 ~,. ~quest for .extensic~ pt%rs%~t to Ccoservatic~ Order No. 120 Rule 2 to permit the flaring of casin.9~ead gas originating from McArthur River Oil Field, Dolly Varden Platform for l~ger than 15 days per calendar quarter. ~mra~ Oil ~y J P. O. Box 2380 An~,~ 99510 .Oil and Gas ~mser~atie~ CUa~ttee has ~si~ ~ ~ ~ ~ ~y f~ '~i~. for ~ ~ ~ p~~ ~ ari~ ~t ~ a~~ ~ ~. ~y ~ Pl~. ~ ~si~ of ~ ~f~ ~t iS ~~ f~ 10 ~ys ~ ~~ ~ pi~~ ~ ~~ ~~..,. ~~ ~s f~. AS .a provi~ to this app--, a detailed report of' the effcxis to ~.ze the ~1~ of .gas' flared is ~d wi~ 10 days cc~pletion of the ~cn. May 1.~ 1978 ADMINISTRATIVE APPROVAL ~.O. 120.7 Request for extension pursuant to (kwmervatio~ Order ~. 120 ~ 2 to .pers~t the f/arin~ of casinghead gas originating.. fz~a McArthur Ri%~r Oil Field., Dolly Varden Platform for Divisi~ O~raticns ~ Mara~ 0il ~ ~, P. O. Box 2,380 Anchozage, Alaska 99510 1978 due to ~ressor ~~ probl~. An for the refex~nced ~st is ~ grante~ for three (:3) days or until the ~ssor becores fully oper~, whi~ ,~S first. A].aska Oil and .Gas ~ticm ~ttee 15, 1978 Be: ~:St f~r exte~sic~ ~t to (~~~°O~r"l'~'J""120" .mg, e 2 to pencCt the f~.~ring of casing~d gas originat/ng frc~ the ~Arthur Rib, er Oil Field, K~g ~..~a~ Platfon~ for l¢~ger than 15 days .per calendar quar~. Mr. R. L. ~ik ~ Inlet Area Engineer ?',AtL~tic Richfield Ccz~any p. O. Box 360 Anchor~, Alaska 99510 for the ~eferenc~d request is ~y ..granted until '7:00 AM, ADST~ ~ ,1, 1978 ,or until the., compressor ~ fully operable. Very truly yours, Tlx~. R. Marshall, Jr.. C~nserva~ . Feb~..ry..' 6, 1978 Mr. Ai~, Jr. Divisic~ Opera.ticfls }~nag~r M~.a~ Oil C~any P,O. ~ 2380 Ancil(lrage, Alaska 99510 The Oil and CAs Ccmsexvation ~ttee has comsidere~ ,your aI~licaticm f~r exten~ due tm the necessity to rep~_ ir a leak in the oil pipeline and. cc~lvert it %0 shipping gas to ~e.. An extensic~ far the refer- ~ '~t is hereby granted until 7:00 AM, ADST, Fe~ 15, 1978 or ~nti. l the,: repaired lin~ ~s .operable. Very truly yours, OIL AND GAS ~m~ ~ De~ 28, 1977 A D M I N I S T RAT I VE A ~t for extmmsi~ pursuant to Cc~serva~ Order No. 120 B~%e, 2 to permit the flaring of casinghe~d gas originating frc~ the ~%rthur Ri~r, Oil Fie/d, King Saln~ Platform for longe~r than 15 days per cal~ Mr. D. E. ~s Cook Inlet Area Engineer Atlantic Richfield ~y P. o. Box 360 Anchorage, Alaska 99510 The Oil and C~s Cc~serva~ Cxxa~ittee has ~msid~red your applicatic~ for ~ticn due to the necessity to ~ptace ~ rotat/ng elem~/~t of the largest gas cc~ssor. An ~ion for the z~f~ request is hereby gran~ until 7:00..AM, ADST, January 1, 1978 or until the .compressor ~s ~ully operable. Ve~ truly yours, Thos. R. ~shall, Jr. ALASKA OIL A,~.~D GAS CONSERVATIO..I COk~MITTEE May 31, 1973 A D M I t~;I I S T RAT I V E A P P ROCJ V A L HO. t20.3 Re: Request for extension pursuant to Conservation Order No. t20 to permit the flaring of castnghead gas from the deprop.anizer overhead ortglnatin.g from the McArthur River Oil Field as required to a~otd condensation of excess liquids 'in the Cook I n let Gas System. ~.~r.. Robert T. Anderson District Land Manager Union Oil Co~pany of California 909 Wo 9th Avenue Anchorage, Alaska 99501 Dear ,~,~r. Anderson: An extension for the referenced request is hereby granted until 7:00 A~4, ADST', September t, '197.3. Very truly yours,, , , ,,' ,' · :'" : Thomas R. Marshal I, Jr. Exe.cut tve Secreta.ry Oil and Gas Conservation Cx~mittee April 30~ 1973 Re: Request for extension pursuant to Conservation Order No. 120 to permit the flaring.of caslnghead gas f~om the depropantzer overhead originating from the Hc^rthur River 011 Field as required to avoid condensation of excess liquids in the Cook Inlet Gas System. Mr. Robert T. Anderson District Land Manager Union Oil Company of California 909 ~. 9th Avenue Anchorage, Alaska 99.501 D~a,r Mr. Anderson: A.n e.xten.s ~on for the referenced req'.ues, t i s. hereby granted u.nt i t 7: O0 AM, ADST, June I, 1973. Very truly yours, .i,~, ,',, ~', .~:],~,~, ,;,~ ,~,,, · ,~,,.:, ,~. .,;, ,~,, , .ii,i; Thomas R. Marshal I, Jr. Execuf tve S~crefary Re: Raque5? for. exteaslon-pursuant to Con~ervaTlon Order-No. 120 - :: .. to. per~It-the flaring of caslnghead gas fro~ the depropanlzer .... .overhead, .orlglnatlng-.fro~ the McArthur River 011 Field es .... . :.:.:::~,,,,~.:..~:s,,.~,..;::.:.:'.'.:::.:~::: :.?::"::::.::::'.:.:,~-.~':...::: :.-:,:.,.'.,. :. :.> :.":...: _..:-..: ,.:.. ".',-.' .. "~ :.:..-.-'::, · "~ ~:'. .... . .... , :-<,;,,,., . ...... '.: -.. ....... -~,:,~ ".-..,..-: :~.:,'..,v.::.'~ '...'~:,-':-:': '.:-?.:':.77.?.~:~:,,~?':F~?~::~:..'.:..':.:". :?'. ~.;:..' :L ' '.': -.,'; :'.":' · . ~.o - . , .... r · ~ · '" · ," · .... . : ',, ',':T~ ,'-,~:~ -~,~m~,T~',~',."' '., -, , - · , - ' · : o . ' . ': . ,.. ~.'.'o.'. ,. · ' , ,:, '. ', .. . ..,.: .. , ..-.... ~,~.:~:',,:?G~.:~j,~: :.,~.~. :~;~,~,,,~:v~.,'~,,...,~,~,v:',., .,..~.. ,., ,, .:,.,..,.,... ', :~L:. ,' , . " ~" · '~.'T" "," "..:' . .... .'...., '.,:,:'"::::: ..... - ': '." ":. '! -.&: .; ".', ' .. · '.. ': ,': '. '.' .'- .: '.%"~., ";., ' .,,' '~,i~'i~.; ,,.::~':. ,'... ', ":':,::. . ..'.. An ext~m.Si'on for the referenced requeSt Is hereby granted unTII 7:00 AM,. M~ I';'. 197:5. Thomas R...' ~arshal I. Jr. Ex~ufI~ .., · . G. A. Graham District Operations Manager Alaska District Unocal Corporation RO. Box 190247 'COMM - Anchorage, Alaska 99519-0247 Telephone (907) 276-7600 COMM '1, Mr. Chat Chatterton Alaska Oil & Gas Conservation Commission 3001 Porcupine Drive Anchorage, AK 99510 Dear Mr. Chatterton' EXCESS FLARE DAYS TRADING BAY PRODUCTION FACILITY The Liquid Extraction Unit at the Trading Bay Production Facility has become uneconomical and is now shut down. The gas produced off the Grayling, Dolly Varden and King Salmon platforms is used as fuel or for the safety flares for the three platforms and onshore treating facility. Heading of the production wells creates a surge effect in the gas pipelines leading to increased flaring at the onshore facility over the allowable limit. Modification of the pressure regulating valves on the gas lines at the onshore site should remedy this problem. It is anticipated that the problem will be corrected by March 1, 1989. Forty four additional excess flare days are requested for the first quarter of 1989 for the Trading Bay Production Facility. Very truly yours, Gerry A. Graham District Operations Manager GAG/lew RECEIVED FEB-3 t9~,a. .Alaska. ~ii & Gas Cons,. Commission '.,~. ~r~chorage ~ G. A. Graham District Operations Manager Alaska District Unocal Oil & Gas Div Unocal Corporation RO. Box 190247 . ,/"~ Anchorage, Alaska 99519-0247 Telephone (907) 276-7600 _ _ -~- C[~;l',,:~M'------~ UNOCAL ff LGEOL ASST Novembe~ 16, 1988 Mr. Chat Chatterton, Commissioner AOGCC 3001 Porcupine Drive Anchorage, AK 99501 Dear Mr. Chatterton: REQUEST FOR FLARE EXTENSION AT TRADING BAY PRODUCTION FACILITY The Liquid Extraction Plant (LEX) at the Trading Bay Production Facility was shut down following the failure of the Grayling oil pipeline. Plans are to leave the LEX down and use the relatively small volume of produced oil well gas to help meet operational fuel requirements within the Trading Bay Unit. Following the LEX and compressor plant shutdown, a smaller compressor was installed to handle the oil flash vapors in order to use them as fuel gas. The volume of gas was higher than expected, so liquid carryover through the discharge scrubber was excessive and created heater treater burner problems. A reconfigured cooling system is now being installed. It is anticipated the modification will be completed by the end of November, 1988. In order to compensate for startup problems, it is requested that an additional 51 days of excess flare days be allowed during the fourth quarter 1988 for the Trading 8ay Production Facility. .RECEIVED AJaska Oil A Gas Cons. Commission Sincerely, Marathon Oil Company October 30, 1987 Alask~t ,strict Production United States P.O. Box 102380 Anchorage, Alaska 99510 Telephone 907/561-5311 Mr. Lonnie C. Smith Alaska Oil & Gas Conservation Com~ission 3001 Porcupine Drive Anchorage, AK 99501 · ~ ,. .~.,. . ,,.,. ~ Re: ..,~~.., 119.5 & ~: '-'--~GGS Pipeline Repair Dear Mr. Smith: On August 14, 1987, the Alaska Oil and Gas Conservation Commission issued to Marathon administrative relief to extend flaring days during the third and fourth calendar quarters due to extensive repair of the Cook Inlet Gas Gathering System. Repair of the CIGGS was successfully completed and associated flaring of natural gas from the McArthur River and Trading Bay Fields was ceased on October 7, 1987. During the period August 11 to October 7, 1987, a total of 331,354 MSCF of gas were flared. Also, there were a total of 53 flaring days for this period. The maximum flaring rate did not exceed 15 MMSCFD. .'. . ,, Marathon extends its appreciation to the AOGCC for your cooperation during this unfortunate event. If you should have any questions or require addi- tional information, please call me at. 564-6350. Sincerely, TIt0MAS R. BROOKS Environmental & Safety Supervisor DEB:cas:ES8:55 RECEIVED Alaska Oil & Gas Cons. Commission Anchorage Marathon Oil Company August 14, 1987 Mr. Lonnie C. Smith, Commissioner Alaska Oil & Gas Conservation Commission 3001 Porcupine Drive Anchorage, AK 99501 Production United States P.O. Box 102380 Anchorage, Alaska 99510 Telephone 907/561-5311 Dear Mr. Smith: On August 11, 1987 the Cook Inlet Gas Gathering System ruptured approxi- mately two miles southwest of McArthur River (West Forelands), releasing natural gas into the atmosphere. As an operational necessity, the CIGGS line was blocked and incoming gas from offshore wells is being flared at our Trading Bay Production Facility. A 96-hour verbal authorization to flare was received from Alaska Oil and Gas Conservation Commission on August 11. Repair of the rupture and other sections of concern will commence about August 16, 1987 and is anticipated to continue through September 25, 1987. To maintain production status, it will be necessary to flare gas at Trading ~Bay until repairs are completed and the line is re-commissioned. This flaring activity, however, will exceed our maximum allowable rate and duration for this quarter. · Therefore, Marathon requests a Special Permit to flare natural gas at our Trading Bay Production Facili'ty for the duration of the repair and inspec- tion operation. We anticipate a flare rate of 15 MMCFD. Attachments I, II, and III present a description of the proposed project. Should you have any questions, please call me at 564-6350. Sincerely, TI-IOI~S R. BROOKS Environmental & Safety Supervisor cas:ES7:65 RECEIVED AUG 1.~ 1987 7"~' ~aska oil & Gas Cons. commission ~nc~ora~e ATTACHMENT I DESCRIPTION OF THE PROJECT PURPOSE OF PROJECT The 16" Cook Inlet Gas Gathering System (CIGGS) requires the repair of a rupture shown on Attachment II. Repairs will also be made to the two Gr~ #2 locations shown on Attachment II. In addition, Grade #1 problem area~ may be dug and surveyed. TIME FRAME )MM SR GEO~ ENG ASS' The planned start date is August 16, 1987 with the project anticipated to be completed on September 25, 1987. Mobilization to the rupture is esti- mated at 3 days. Each repair is estimated at 5 days. Survey work is estimated at 1 day per location. WORK PLAN Mobilization/Demobilization to/from Site Heavy equipment will be mobilized, by barge up McArthur River to the CIGGS right-of-way. The equipment (2 backhoes) will be offloaded and proceed to the rupture location utilizing steel mats. If low water levels prevent the barge from reaching the CIGGS right-of-way, the.barge would go up river as far as possible and await ADF&G personnel to clear an appropriate access route to the right-of-way. Additional materials and equipment to include: pipe; a compressor; two welding machines; and various miscellaneous equipment will be mobilized to the job site by helicopter from a barge anchored offshore. All helicopter traffic will maintain a minimum flying distance of 1500 feet over the pri- mary waterfowl habitat identified in Attachment III. Personnel will be mobilized and demobilized from Marathon's Trading Bay Production Facility. Personnel helicopter traffic will not be over primary waterfowl habitat. Demobilization will occur in the reverse order of mobilization. Site Preparation Once on location, the CIGGS line will be excavated. The hole will be dewatered by pumping to the marsh. Pipeline Repair New sections of pipe or sleeves will be inserted in damaged or suspect sections as appropriate. Pipeline coating will be placed and the pipe tested. Clean-Up The excavation will be backfilled and restored to original grades. REdEIVED AUG 1987 Alaska 0il & Gas Cons. Commk Anchorage ~E~SO~EL ~QUZ~ About ten people will be at the job location. EXCAVATION QUANTITIES About 270 cubic yards of material will be excavated at each location. RECEIVED AUG 1~ ]987 Alaska Oil & Gas Cons. Commission Anchorage - 2 - ECEIVED °~-~ Gas Cons. Cotnmission Anchorage I II I i l &--.ll..ll.---- [ i i I l~ ~] ~[ 'll, l il[ I · ...... ~ iI l'll ,~'~ ~'! l:l~lll ill~ I1~ ~ ..... ~ ~ III ~II ~ ........ 1 .... ~ ..... · 1,11 ~ .l.~ ,. · , ~ 1. ~ i&. I i i i iii Jj. , i ~ I i I ii i i i 1 ~ ~ I ~1 S l.,,1 il I i1. ' I iI lll~' ' ll,I I ' ll % ........ i '' . ~ ~ , I I1 i I ~ ' i I ~ I i ~1 I~l I .I llj 'l~ ~'lll~ i i1. . I I ' iI '~ illl' ~I , .... i Ill I ...... l. ll I l'l ll~:ll ..... :~ I ~ I1 I I I' ...... ' '1. i I . I ~" ~ .... I . ~ I I i ill ~ i I 1 I IJ I, ~ i ./ I '} ~ I I I1'1 % '1 J J i' J I J j I J I I .... I .... i i I i ;~ ' & .... Iii I I~ Il'Il ~ I I : ......... I' I .....~/ % ''I Ill I ..... I /Il,,1 I , i i i iI'1~ lllI1 ' ~ I I ' . , i ~ I ~ i i iI1 ' ' i '' i ~ ~ I ~ , 1 .... . ~ I I i ~ , I' II l'~l, . I 'l '1I 'lI i,, I'l ll i ' ~l . ' . ii ~ II I I I l'l 'l I ~ I I ' ' ''1 '" ' 'l I ~ ~ '~ll ' ' I ll~ II 'I'll I I ' I .~'l ,* , Ill - [ i Il' ' i ' '~' ,' ~ I :l ' I SCALE 1' 250,000 · 'RADi. NG ".. · . . ' 'i ' $ 0 $ I0 '; HABITAT DIVISION "T ' ' ' ' ' ' ' ' "' :" . ' . . ~E$ . . , ff.::~;.i !". ,,.. .'..':; , ....~ ,_Z" '. ':'State Game Reft'ge. ':... ,,4. JULYl~83 .., · . ' .',, ~u~.z~l~y .:-.:. . ,~.. : ......,.. .'...'::. . : · , .. . . ~: · . : ~ .: .. :~ ~' ,:"~..:....:,: ~',~..,, :. . .'.:. :..'~: . : :' ~ Oil ~ ~~ ..... ~....:'" · ~'; ~.:'~.'..... ~'.. ~:':t.. ...... ' ' "' ..... "::'" .' .' . "":" ":~;~"~'~' :'- .~ .~ ,.:'~:.~ ~" ""~:~:'~::i~l,~ ,:.: ..... -..u.. ;'""' "" ' - '" ~ "'"':: ';' . ' ~:~ .. ' .' .' · . . ".. ~~ ~": . ' · ' .:" ' .' . ~': '.. ~ ' ' :.'I ~ .:' :' :... ' .... ::',..,',,?;;~:~.~'.'.j :.t.:~.'., .' . . : .,~4 .,':~.',~ ;:':~l'.~'..':~:;.~h~.' ~'~:'~*~"~'~:~1 . .... ......... , ,, ,, ARCO Alaska, Inc. t' Post Office IB~,. 560 Anchorage, Alaska 99510 Telephone 907 277 5637 March 15, 1982 Mr. Lonnie Smith, Commissioner Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 Subject: Gas Flaring King Salmon Platform Cook Inlet, Alaska Dear Mr. Smith: This letter is to confirm the verbal request made on March 12 by Don Gann to Russ Douglas. ARCO Alaska, Inc. requests an extension of Rule 2, Conservation Order 120 for this facility. When Don Gann called, we had already used the 15 days per quarter allowed for overflaring. Therefore, he requested permission to overflare the 800mcfd safety flare rate until the situation discussed below was under control. At about 7 P,M. on March 12, 1982, an electrical short developed in one of the two primary AC generators on the platform. This short resulted in a shutdown of both electrical generators. This, in turn, caused a production shutdown. When a total power failure occurs, controls automatically vent gases to the flare in order to protect personnel and equiPment. After the small standby generator was started, it was then necessary to lift wells using dry gas well in order to minimize damage to wells. Dry gas was used until the generators and the gas compressors were back on line (2 A.M., March 13). The above problems resulted in exceeding the 800mcfd safety flare rate for March 12. Therefore, we are requesting a one day extension of Rule 2, Conservation Order 120. If there are any questions, please contact me at 265-6538, or .~allas Burford at our Kenai Office, 283-7147. Very truly yours, .... W. G. Bartel Senior Operations Engineer Cook Inlet Engineering WGB:ml RECEIVED MAR 1 5 1982 Alaska 011 & Gas Cons. CommissJOll Ntchorage ARCO Alask.s, l~c. is a subsidiary o~ A~tl~nticRichfieldCo~p~n~ ARCO Alaska, Inc.'~'~ Post Office BO,. 360 Anchorage, Alaska 99510 Telephone 907 277 5637 March 9, 1982 5~. Lonnie Smith, Commissioner Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 Subject: Gas Flaring King Salmon Platform Cook Inlet, Alaska Dear Mr. Smith: ARCO Alaska, Inc., requests an extension of Rule 2, Conservation Order 120 for this facility. This letter will confirm the verbal request made to you earlier today by D. W. Burford. Our ~1 Worthington Gas Lift compressor was shut down at 7:30 a.m. today following a tube failure in one of the associated heat exchangers. The ccmpressor is a three-stage reciprocal compressor which compresses gas from 55 psig to 1280 psig. The tube failure occurred in the exchanger which cools the gas following the second stage of compression. While the machine is down, we need to use our dry gas well to supplement the other gas lift compressors in order to keep all our oil wells flowing.. This will result in excess flaring... Without the use of this well, three of our high water cut wells will die. This will d~nage their producibility and hurt their ultimate recovery. As such, we view the request as an operational necessity. We have already used the 15 days/quarter allowed for overflaring. We are therefore requesting permission to overflare the 800 MCFD safety flare rate until 12:01 a.m.. March 10, 1982. 5he compressor should be operative by that time. If there are any questions, please contact me at 265-6538, or Dallas Burford at our Kenai Office, 283-7147. Very truly yours, .W.G. Bartel Senior Operations Engineer Cook Inlet Engineering WGB/kmh RECEIVED MAR 0 ~ ~,982 Alaska OiJ & (~as Cons. Cornmissior~ Anchorage ARCO Alaska, inc. is a Subsidiary of AtlanticRichfieldCompany ARCO Alaska, Inc. ~'~ Post Office[~ 360 Anchorage~ A~aska 99510 Telephone 907 277 5637 February 1, 1982 Mr. Harry W. Kugler, Commissioner Alaska Oil & Gas Conservation Comm. 3001 Porcupine Drive Anchorage, Alaska 99501 SUBJECT: Gas Flaring King Salmon Platform Cook Inlet, Alaska Dear Mr. Kugler: ARCO Alaska, Inc., requests an extension of Rule 2, Conservation Order 120 for this facility. This letter will confirm the verbal request made to you earlier today by K. C. Porter. On January 19, we experienced a failure on the high pressure stage of our Ruston York gas compressor. An overhaul was started the same day using spare parts from our warehouse. As part of the overhaul, a new compressor rotor was installed. The overhaul was completed on January 27 and the normal "bump- in-runs" were made. During one of the bump-in-runs, problems were experienced again in the high pressure stage. (We now believe problems resulted from an improperly balanced rotor from the factory.) The compressor was disassembled once more. While attempting to rebalance the two rotors (the original rotor and the rotor that had just been installed) it was found that both rotor shafts were bent. Presently our Maintenance Supervisor is at the factory in York, Pennsylvania with both damaged rotors. At this time we are not certain how long it will take for repair and/or replacement of one of the rotors. However, it is unlikely that an accept- able rotor can be obtained, the compressor reassembled, and the unit started in less than a week or so. Today will be the 14th day this Quarter that we have exceeded the 800 mcfd allowable safety flare rate. Therefore, we are requesting permission to continue to exceed the 800 mcfd safety flare rate while the compressor is being repaired. If there are any questions, please contact me at 265-6221 or our Kenai office at 283-7147. Sincerely, D. E. Andrews vl Alaska Oil & Gas' Cons. Anchorage C°mr;;issioe ARCO Alaska, Inc. is a subsidiary of AtlanticRichfieldCompany ARCO Alaska, Inc. Post Office, ~,.~., Anchorage, At~ska 99510 Telephone 907' 277 5637 /)/2 December 7, 1981 Mr. Henry W. Kugler, Commissioner Alaska Oil & Gas Conservation Comm. 3001 Porcupine Drive Anchorage, Alaska 99501 RECEIVED DECO ". 't"." Oil I Gas Cons. Commi881on Anchorage ':' SUBJECT: Gas F_!&.r~ir~g King.. Salmon... P!.atform Cook Inlet, Alas~'~ ..... Dear Mr. Kugler: ARCO Alaska Inc., requests an extension of Rule 2, Conservation Order 120 for this facility. This letter will confirm the verbal request made to you earlier today by K. C. Porter. During the week-end, our main gas compressor~ (Ruston/York) developed a serious vibration in the gear box. We took the machine off line to investigate the problem, and found skids misaligned which very probably has produced journal bearing and other problems. We estimate that it will take four to five days to fully investigate and repair the situation. Permission is requested to overflare the 800 MCFPD safety allowable while the machine is being repaired. If there are any questions, please contact me at 265-6221 or our Kenai office at 283-7147. Sincerely, D. E. Andrews vl ARCO Alaska, Inc, is a subsidiary of AtlanticRichfieldCompany Mr. Lonnie Smith Alaska Department of Natural Resources Division of Oil and Gas 3001 Porcupine Drive Anchorage, Alaska 99501 Dear Mr. Smith: Union Oil and Gas I~.;.'"";'~n: Western Region Union Oil Company OT ,.,alifornia P.O. Box 6247, Anchorage, Alaska 99502 Telephone: (907) 276-7600 union November 23, 1981 RE: Excess Gas Flaring Grayling Platform Cook Inlet, Alaska Union Oil Company of California respectfully requests an extension to Rule 2, Conservation Order 120 for our Grayling Platform, Trading Bay Unit, Cook Inlet, Alaska, for the 4th Quarter of 1981. The Grayling is currently flaring approximately 7 MMSCFD over the normal pilot flare volume due to down time on the Centaur gas lift package. Excessive flaring was reported by letter to you on November 13, 1981 for four days 17 1/2 hours, while conducting an annual inspection on the Guy T. Martin gas lift package's heat exchanger. The Centaur gas lift package has since encountered compressor problems and has been idle since November 12, 1981, as reported to you November 13, by telephone. We anticipated completing repairs this past weekend, however, a lack of available parts and additional problems with the third stage compressor prevented returning the unit to operation and has caused us to exceed the 15 day excess flare limit for this quarter. This was explained verbally to Mr. Blair Wandzel this morning. It is anticipated that the Centaur compressor will be operable by November 27th, resulting in a total excess flare period of 20 days, 10 1/2 hours. No other down time is scheduled for the remainder of this quarter. Should further information be needed for this request, please contact me, or Mr. R. R. Culver in our Kenai office in my absence. PTW/fws cc: Mr. Ken Thoma Marathon Oil Compa~ Very truly yours, Paul T. West Dist. Production Supt. .-? 0, ARCO Alaska, Inc."~" Post Office Bo~ 360 Anchorage, A~aska 99510 'Telephone 907' £7'7 5637 November 23, 1981 Mr. Lonnie Smith Division of Oil & Gas Conservation State of Alaska 3001 Porcupine Drive Anchorage, Alaska 99501 SUBJECT: Gas Flaring, King_.,_S..a.,!,.~.o.,.,.n...,.,.,.~.9,,~.,..f..~,~, Cook I--~n-]~t, Alaska De ar Mr. Smith: Per the telephone conversation with our Kenai office, ARCO Alaska, Inc., requests an ex- tension of Rule 2, Conservation Order 120 for our King Salmon Platform. This flaring request is the result of a broken second stage piston and liner on our No. 2 Wor- thington gas lift compressor. This facility has accumulated 12 overflare days for this Quarter year, which is the reduced limit set by commission letter dated October 1, 1981. Therefore, permission is requested to overflare the 800 MCFPD safety allowable while the machine is being re- paired. We expect to have it back on-line in several days. If there are any questions, please call me at 265-6221, or our Kenai office, at 283-7147. Sincerely, D. E. Andrews EEEIVED' NOV 2 198l Alaska Oil & Gas Cons. Commission Anch0mge ARCO Alaska, Inc. is a subsidiary of AtlanticRichfieldCompany ARCO Alaska, Inc.''~' Post Office Bu× 360 Anchorage., A~aska 99510 Telephone 907' 277 5637 August 20, 1981 Mr. Lonnie Smith Division of Oil & Gas Conservation State of Alaska 3001 Porcupine Drive Anchorage, Alaska 99501 ~SUBJECT: Gas Flaring, King Salmon Platform Cook Inlet, Alaska Dear Mr. Smith: I am requesting a second extension of Rule 2, Conservation Order 120 for our King Salmon Platform. The major repairs to our Ruston/York gas compressor, have extended beyond the period we anticipated and outlined to you in my letter of August 17, 1981 (attached). As I detailed earlier, we would like to continue flaring in excess of the 800 MCFPD allowed for safety in order to keep high water cut wells flowing. Our main problem with getting this machine operational stems from obtaining parts and a Specialist from England. Both should arrive tonight. We now plan to have the repair complete on August 30, therefore I am requesting that the Commission grant us permission to overflare the safety limit until that time. Our overflare day count for the yearly quarter would be 28 days on August 30. We appreciate your cooperation and timely response on this request. If you desire more :discussion, please contact me at 265-6221. In my absence, feel free to contact D. W. Burford in our Kenai offiCe (283-7147). 'Very truly yours, -D. E. Andrews vl ARCO Alaska, inc. is a subsidiary of AtlanticRichfieldCompany AUG 20 198] Alaska 0il & Gas Cons. Commission Anch0rags ARCO Alaska, InC. B~"~ Post Office .... 360 Anchorage, Alaska 99510 Telephone 907 277 5637 August 17, 1981 Mr. Lonnie Smith Division of Oil & Gas Conservation State of Alaska 3001 Porcupine Drive Anchorage, AK 99501 Subject: Gas Flaring, King Salmon Platform Cook Inlet, Alaska Dear Mr. Smith: This letter is to request an extension of Rule 2, Conservation Order 120. This order requires State approval to vent gas in excess of the fifteen (15) days allowed per calendar quarter per platform. We are continuing to repair our main gas lift compressor per our letter to you on August 4, 1981. The two-year routine maintenance inspection on the turbine uncovered massive internal problems associated with its rotor. This has necessitated replacing all the internal rotor wheels, stators, bearings and other moving parts. We are projecting that the machine will be back on-line August 20, 1981. During this repair period we are using our dry gas well to lift several high water cut wells in order to minimize well bore damage and lost reserves on these marginal producers. This extra gas coming onboard cannot all be' compressed for sales, therefore, some gas is vented thru the safety flare~ 'We are burning an average of 1193 MCF per day which exceeds the 800 MCF per day allowed. This excess flare volume (approximately 400 MCFPD) has now occurred for 15 days. Therefore, I am requesting an extension of Order 120 for an additional six days so we may continue to operate the marginal wells until the compressor in on-line. We appreciate your timely cooperation and approval of this request. If you have any further questions, please call me at 265-6221. Very truly yours, D. E. Andrews cac ARCO Alaska, Inc. is a Subsidiary of AtlanticRichfieldCompany ARCO Oil and Ga~'"" ipany South A]as~¢~ .~,,strict Post Office E~ox 350 Anchorage, Alaska 99510 Telephone 907 277 5637 March 26, 1980 Mr. Lonnie Smith Division of Oil & Gas Conservation State of Alaska 3001 Porcupine Drive Anchorage, Alaska 99501 Subject: Gas Flaring, King Salmon Platform Cook Inlet, Alaska Dear Mr. Smith: This letter will confirm my telephone request for an extension of Rule 2, Conservation Order 120, which limits venting of excess gas to 15 days per calendar quarter. Due to problems with our Worthington ~2 gas compressor, we need to shut it down and repair the two high stage compression pistons. As of this date, I estimate that we have accumulated the 15 days normally permitted. Therefore, I am requesting an extension of 5 additional days for overflaring. By granting us permission to overflare approximately 1 MMCF per day for this period, we will not have to shut in any producing wells. This will let us maintain rate and thus increase the ultimate recovery from our higher water cut wells. We appreciate your timely cooperation and approval of this request. If you have any further questions, please call me at 265-6221. Very truly yours, D. E. Andrews DEA:vl ARCO Oil and Gas Company is a Division of AtlanticRichfieldCompany Anchor~ ivision Production, Operations US & Canada Marathon Oil Company PO Box 2380 Anchorage Alaska 99510 Telephone 907/274 1511 June 27, 1978 Mr. T. R. Marshall State of Alaska Dept. of Natural Resources Division of Oil and Gas 3001 Porcupine Drive Anchorage, Alaska 99501 Re: Emergency Flaring of Oil Well Gas Due to Instrumentation Malfunctions on June 23 - 24, 1978, Trading Bay Production Facility LEX Plant; Request For One to Two Days Extension of Conservation Order No. 120, McArthur River Field, For Allocated Dolly Varden Platform Flare Time Beyond Fifteen Days Per Calendar Quarter. Dear Mr. Marshall:. in reference to our telephone conversations on the evening of June 23, 1978, and in the afternoon of June 26, 1978, we hereby submit the following report. Intermittent malfunctions of the automatic control valves on the LEX plant inlet and on the plant bypass commenced at 7:00 AM on June 23, 1978, followed with failure of the controller functions at 11:00 AM, which prevented these valves from opening. After several attempts to trace and remedy the problem, Mr. H. H. Hamilton was contacted at 5:45 PM and verbal approval was obtained in order to temporarily continue flaring to maintain pressure on the system for functional tests of the controllers and for tracing the malfunction. It was reported that crude flash gas was being shipped down the pipeline, but that produced gas separated on the platforms would be flared. This rate was reported to be approximately 28.0 MMCFD for an unknown temporary period, until the controller problems were found, and it was understood that the gas would be manually bypassed into the line if extended repair time was required. The valves were forced to open and gas returned through the plant at 8:00 PM on June 23, 1978, but the controllers continued to function improperly. Intermitten malfunctions and repair attempts also recurred from 6:30 AM to 11:00 PM on June 24, 1978, afterwhich the controllers seemed to be functioning in a marginal manner. However, no serious problems could be found except for minute quantities of oil in the controller elements and a few slight leaks, none of which is believed sufficient to cause the problem. The instrumentation engineer who designed the current control system was contacted in Houston and further evaluation will continue. The total excess gas flared, which is allocable to the platforms, was 18,311 MCF on June 23, 1978 and 906 MCF on June 24, 1978. During the flare period, gas allocated to the Dolly Varden Platform (2,498 MCF) combined with the safety flare (244 MCF) on June 23, 1978 results in an exc~s~l~r~f~,~ (,. JUN 2 8 19'7'8 t2ivision of Oil ,~nd Gas L;onserwt. io~ Anchorage Mr. T. R. Marshall June 27, 1978 Page 2 1,742 MCF over the 1,000 MCF allowed safety flare. The allocated gas flare and the platform safety flare was not in excess on June 24, 1978. Therefore, one flare day in excess was incurred. The other platform operators of the Grayling, King Salmon, and Monopod (Trading Bay Field) platforms were also contacted on June 23, 1978, but they indicated no serious depletion of their remaining flare time could be anticipated. A~ain, we appreciate your considerations in this matter. Sincerely, A. L. Radke Operations Engineer ALR/wm Anchora~ ivision Producb'o,, Operations US & Canada Marathon Oil Company Mr. H. W. Kugler State of Alaska Dept. of Natural Resources Division of Oil and Gas 3001 Porcupine Drive Anchorage, Alaska 99501 PO Box 2380 Anchorage Alaska 99510 Telephone 907/274 1511 June 27, 1978 Re: Emergency Flaring of Oil Well Gas Due to Compressor Disch:arge ...... .t Valve Leak on June 21, 1978, Dolly Varden Platform; Request fo':'r"~'one ;~ Day Extension of Conservation Order No. 120, Rule 2, McArthur River Field, For Flare Time Beyond Fifteen Days Per Calendar Quarter. Dear Mr. Kugler: In reference.to our telephone request for said extension and your verbal approval on the morning of June 21, 1978, we hereby submit the following report. A gas leak was discovered from the bonnett on the automatic discharge valve of gas lift compressor No. 1. Repair was necessary to avoid a hazardous accumulation of gas and the compressor was shut down at '9:00 AM. However, produced gas from the oil wells was greater than the remaining two gas lift compressors could handle. Therefore, it was necessary to request flaring a portion of this gas volume. Compressor No. 1 normally handles approximately 13.5 MMCFD and it was reported that five hours were expected for these repairs, which could result in an excess flare volume of 1.5 to 2.0 MMCFD over the allowed safety flare. Adjustments were made to the other compressors and the gas lift rates to wells in order to minimize the flare. Valve bonnett repairs were attempted and the compressor was started at 1:30 PM, but the bonnett seal repairs failed to hold. Proper O-ring seal material was located and transported to the platform. A status report was telephoned to you at 2:00 PM with a request for an additional three hours of flare, which was approved. Repairs were completed and the compressor was returned to service at 3:15 PM, afterwhich the valve actuator was installed and you were notified of our ceased flare. Total excess gas flared during these repairs was lower than expected, due to the compressor and gas lift rate adjustments. The excess volume flared was determined to be 535 MCF over the 1000 MCF allowed for safety flare. We appreciate your considerations in this matter. Sincerely, A. L, Radke Operations Engineer ALR/wm Al Mecl~' .Ir. Manage~. ;horage Division Production Operations, U.S. & Canada Marathon Oil Company P.O. Box 2380 Anchorage, Alaska 99510 Telephone 907/274-1511 April 28, 1978 Mr. 0. K. Gilbreth State of Alaska Division of 0il and Gas Conservation 3001 Porcupine Drive Anchorage, AK 99501 In reference to a telephone conversation with Russ Douglass, on April 28, 1978, Marathon 0il Company.~_e_s~s- an ~xtension of the 15-day flare period for this e x c e s s o ~-~-a~- yf~-e-q~~n-h-r~-7 ...... Th-e-"-C'B--'~ comp re s s o r o ve rh a ul which was reported to Mr. Hoyle Hamilton on April 20, 1978, haS taken longer than expected. The compressor is expected to go back on line tonight (April 28) and will require a run~-in of approximately three days at half load to seat the rings. However, we will consume our 15-day excess flare period by 7 AM on Saturday morning, April 29. The run-in is expected to be complete and the compressor returned to full load by Tuesday, May 2, after which the flare rate will return to normal. Therefore, we respectfully request an extension of three days. We thank you for this consideration. If you have any questions, please advise. A report will be sen~ to you next week with the volumes flared and circumstances related thereto. ALR:i A. ME CHLER~ JR. '- ~ Division Operations Manager AtlanticRichfieldCompany North Ame!j: J Producing Division South Alas~~ istrict Post Office Box 360 Anchorage, Alaska 99510 Telephone 907 277 5637 December 28, 1977 Division of Oil & Gas Conservation State of Alaska 3001 Porcupine Drive Anchorage, AK 99501 SUBJECT: Gas Flaring '?i I ~, King Salmon Platform Cook Inlet, Alaska Gentl~: Atlantic Richfield requests an extension of Rule 2, Conservation Order 120, that requires State approval to Vent Gas in excess of the 15 days allowed per calender quarter per platform. As of December 1, 1977, we had recorded 10 days in which our flare exceeded the 800 MCF/D allowed for safety. During the past week we estimate an additional four days were accumulated. The flared volumes calculated onboard the platform were at, or very near, the 800 MCF/D level. Typically there is a 3-5 percent deviation between numbers generated on the platform and the official numbers generated in our Gas Accounting depart3nent. Allowing for this uncertainty gives us a total estimated count for the quarter of 14 days. At the present time our largest gas compressor is disassembled with the high stage rotating element being replaced. Restarting this machine is scheduled for December 29, 1977. We have very rarely been able to bring this unit back on line after an extended shutdown without going thru numerous restart sequences. This activity generates surging in the gas process system and will most certainly create at least one additional overflared day. We appreciate your cooperation and approval of this request. If you have questions or desire additional information, please contact me. Very truly yours, Union Oil and Gas ~7' ion' Western Region Union Oil Company of California 909 W. 9th Avenue, Anchorage, Alaska 99501 Telephone: (907) 279-7681 union Robert T. Anderson District Land Manager ,. -May '31, 1973 State of Alaska Oil and Gas Conservation Committee 3001 Porcupine Drive Anchorage, Alaska 99504 CONSERVATION ORDER NO. 120 APPLICATION FOR EXTENSION Gentlemen: Pursuant to the provisions of Conservation Order No. 120, Union 0il Company of California, as Operator of the Trading Bay Unit, requests an extension of said order until September 1, 1973. Interim progress reports will be submitted on July 1 and August 1, 1973. The attached report summarizes the progress since the April 30 report and outlines plans for the ultimate solution of the condensation problem. As is apparent, it is not likely the necessity of flaring will be eliminated prior to September' 1. Extension of a lesser period of time will only cause increased burden on the Committee as it must review and act on additional applications for extension. Submitting interim reports will however allow the Committee to keep abreast of the progress of this project and insure the best interests of the State are being protected. Your favorable consideration of this application is respectfully requested. Very truly yours, MAY 3 ! 1973 DIVi$IC.N CF OIL AND GAS ANCHORAGE UNION OIL COMPANY OF CALIFORNIA Unit Operator By / 1 / / .. REPORT TO ACCOMPANY APPLICATIONS FOR EXTENSIONS OF CONSERVATION ORDERS 119 AND 120 During the month of May, we have continued investigation of methods to eliminate or minimize 'the liquid condensation problem in the Cook Inlet Gas System. On May 29, the report was received from Gore I...ab showing the ,, results of dew point determinations at various pressures and the amount of liquid condensatiOn and phase composition at 1200 psig and 25°F. In summary, the tests showed the dew point to be 51°F a'~- 1000 psig, 44°F' at 1200 psig, 36 °F at 1400 psig and below' 0.0F at 1600 psig. These dew point data show '[hat. we are operating in the retrograde region; and 'that if 'the operating pressure were increased to;.' 1600 psig, the ! dew point Would be below normal operating temperature. However, as has been mentioned before, we are presently limited to a maximum pressure of about 1400 psig due to equipment limitations. At 25° and 1200 psig, th~'laboratory test showed that the liquid phase was 4.44% of the total volume which would correspond to about 55 barrels per MMSCF. From the.vapor'and liquid composition at 25° and 1200 ps[g, we will calculate vapor-liquid equilibrium constants for each component. Hopefully, from these results we will be able to obtain a correlation that will enable us to predict equilibrium values at other conditions so that we can better evalua'[e the alternate methods of reducing liquid dropout. A tentative design for the depropanizer overhead-air mixture fuel system has been received from Ghem-Gas Construction Company. We are investigating safety aspects of the system and flexibility of the system at varying operat.ing conditions. We expect to have design finalized within the next week to ten days. Our proposed test to use some gas well gas for lift gas was delayed when a closer look at the operation showed that compressor horsepower, rod load and operating pressure were more critical than had been expected. We still believe 'the project is feasible; bUt 'the safety controls and Shut down will have to be carefully set for the new operating conditions and horsepower loading on the transportation service will have to be checked closely. We plan to make a test run within the next few weeks. Union Oil and Gas Dii . Western Region Union Oil Company of California 909 W. 9th Avenue, Anchorage, Alaska 99501 Telephone: (907) 279-7681 Robert T. Anderson District Land Manager union · April 30, 1973 Gentlemen: State of Alaska Oil & Gas Conservation Committee 3 001 Porcupine Drive Anchorage, Alaska 99504 Re- CONSERVATION ORDER NO. 120 APPLICATION FOR EXTENSION .['. ('. O,./z.o Pursuant to the provisions of Conservation Order No. 120 Union Oil Company of California, on behalf of itself and Marathon Oil Company, requests an extension of said Order until July l, 1973, with an interim written progress report submitted on June 1, 1973. Granting of the requested extension will allow additional field tests and engineering studies to be conducted in an effort to solve the condensation problem in the pipeline. Depending on the results of such tests and studies, further extensions may be required as pro- vided in the order. As indicated in the enclosed report our attempts to solve our problem has met with limited success. It is apparent 'that there is not a short term solution and therefore a more realistic extension period of 60 days is requested to allow adequate time in which to continue the test program outlined in the report. Very truly yours, enclosure UNION OIL ,G,,~MPANY OF CALIFORNIA REPORT TO ACCOMPANY APPLICATIONS FOR EXTENSIONS OF CONSERVATION ORDERS 119 AND On March 28, 1973, the West Forelands Plant was shut down for 2½ hours to change the turbo-expander controls. This change was made to enable 'the turbo-expander to recover more quickly from upsets caused by changes in op- erations on the West Forelands production platforms and onshore production facilities. We have been very pleased with the improved performance result- lng from the instrumentive changes. Recovery from upsets is much more rapid, thus maintaining better overall plant liquids recovery and resulting in less heavy hydrocarbons entering the Cook Inlet Gas System. The following steps were taken in preparation for a test to determine liquid dropout at a higher operating pressure: 1. At Granite Point, the liquid detecting and diverting system was calibrated and put in working condition. . Piping and instrumentation at the East Shore facilities have been modified 'to provide more uniform liquid flow and increase continu- ity of operations. . The west shore line and 'the cross inlet lines were pigged to remove all liquids so 'that liquid dropout during the high pressure test could be more accurately determined. The pigs made their runs at near the predicted elapsed times, arriving without delivering large amounts of liquids. The plant depropanizer overhead was turned into the Cook Inlet Gas System on April 16. The line pressure was gradually increased from 1300 psig, reaching the operating point of 1400 psig on April 19 which corresponds to East Forelands pressure of approximately 1300-1350 psig. On April 19, with the plant depropanizer overhead having been turned into the Cook Inlet Gas System for three days, large amounts of liquids began arriving at the East Forelands facilities. Since that time the liquids separating and vaporization facilities at East Forelands have been fully loaded much of the 'time with intermittent high level alarm line shut-ins and consequent occasional flar- ing at West Forelands. The turbo-expander instrument changes, 'the higher gas system operating pre- sure, 'the modifications at the East Shore facilities, and proper operation of the Granite Point liquid diverting system have not reduced the liquids problem 'to manageable proportions. Investigation into other methods continues. As our next step we plan to use gas well gas 'to supplement compressed lift gas on the Dolly Varden. After minor modifications are completed on the platform, 3 to 5 MMCFD of dry gas well gas can be utilized as lift gas. When this additional gas reaches 'the onshore facilities it will increase the turbo-expander throughput which will increase the plant refrigeration and reduce 'the butanes and heavier hydrocarbons left in the residue gas. The gas well gas will also dilute the butanes and heavier hydrocarbons remaining in the residue gas. We expect to try this procedure within the next two weeks. As reported on March 23, gas samples were sent to Gore Laboratories in Dallas, Texas, to obtain dew point and equilibrium data to better evaluate various alternatives. The shipper caused some delay enroute, but the samples have reached Dallas and testing is in progress. Core Laboratories expects to complete the work in about 'two weeks. Use of the depropanizer overhead product as lease fuel at the Wes'[ Forelands facilities is being investigated. A safe system with a high degree of reliabil- ity is required. We have had numerous conversations with Chem-Gas Company of St. Paul discussing the 'type and size equipment, safety and operating con- trols and delivery of equipment. The latest proposal from Chem-Gas Company is in 'the mails. When received, this proposal should enable us to determine 'the feasibility of using the depropanizer overhead for fuel. Fluor Corporation is working with Rotoflow, the turbo-expander manufacturer, to specify new impeller and turbine 'wheels for maximum efficiency at present and future gas rates. The design cannot be finalized until the above outlined · tests have been completed. -2- Robert T. Anderson l'ust ict Land Manage~ , ,' ..... ! ~ ~ , i ....... ,~ ,;) ,n'Western Region .~ ¢- .... ' - ' .......... '~' ~-~"~ .... ~7 ...... ..,..- - .... ' . '~__ (C :',= ~~ Un,on~Compan~alifornia ~_ :.'~'_' .L:',,"; ~ 909 W. 9th Avenue. Anchorage, Alaska 99501 Gentlemen: Telephone' (907) 279-7681 March 23, 1973 State of Alaska Oil & Gas Conservation Committee 3001 Porcupine Drive Anchorage, Alaska 99504 Re' CONSERVATION ORDER NO. 120 APPLICATION FOR EXTENSION CO. Pursuant to the provisions of Conservation Order No. 120, Union Oil Company of California, as Operator of the Trading Bay Un[t, requests an extension of said Order until May 1, 1973. Granting of the requested extension will allow additional field tests and engineering studies to be condUcted in an effort to solve, the condensation problem in the pipeline. Depending on the results of such tests and studies, further extension may be required, as provided in the Order. The enclosed report is sub- mitted as additional support for this request. Very truly yours I iAR 2 ,:S ;973 DIV:SION C,,/: OIL AND GAS ANCHORAGE UNION OIL COMPANY OF CALIFORNIA Unit Operator /"' . ~, ~. /? ., By: IZ~,-~":-.C> "///..// //~,z.5 ~ ..... ' ~ I REPORT TO ACCOMPANY APPLICATIONS FOR EXTENSION OF CONSERVATION ORDERS 119 AND 120 On February 22, 1973, the depropanizer overhead vapors were returned to the Cook inlet gas system flow stream as testified in the public hearing of February 23, 1973. Operating pressures at the West Foreland Plant were in- creased to 1300 psig. This procedure was an attempt to evaluate the concept of increased pressure base operations for the purpose of maintaining conden- sable liquids in the vapor phase in the Cook Inlet gas system between the West Foreland Plant and the East Foreland onshore facility. Operations were.essentially normal or as anticipated with no significant increase in pressure drop across the Cook Inlet in the dual marine pipelines until the morning of February 28, when line number 2 began, intermittent slug flow of condensable liquids. The flash vapors from these condensed liquids ranged between 3 and 4 mill ion feet per day during the day, dropping in volume to between 1.5 and 3 MMMCF during the early evening hours. Operating pressures at this time were as follows: West Foreland discharge 1300 psi East Foreland dual marine pipeline pressure 1250 psi Condensate receiver pressure 1050 psi During this period, no 'liquid slug flow was observed in the flow stream of marine pipeline No. 1. . Between February 28 and March 5, operations were essentially as described . _, above with intermittent slug flow and liquid production being observed in line No. 2, with line No. 1 being essentially liquid free. Difficulties were t ~tlI ,/ also being experienced in maintaini.ng control of the temporary pressure · control valves installed at East Foreland as part of the high pressure operational procedures. By March 5, these problems had been eliminated and a abnormal pressure drop between East Fore,land and the KPL Junct'ion was observed in the 16" East Side high pressure line. On the morning of March 5, an attempt was made to clear an apparent liquid buildup in the East Side high pressure l ihe by launching a pig from East Foreland toward the KPL junction. By mid-morning, a Significant volume · of liquid had been expelled from the 16" onshore line through the KPL scrubber and into Union's 10" low pressure line. These liquids flow from the KPL scrubber through a ,liquid dump l~ne to the l~O" low pressure line and are flashed to 190 lb. (the operating pressure ~of the low pre~sure system), with any remaining liquids being collected in a condensate storage tank located at the Collier Plant. The volume of condensate remaining following the flashing process from the KP/ scrubber liquid dump line to the low pressure line was in excess of the tank storage capacity and as a result, the system was shut in. At this point,, the 16" high pressur~ line pigging operation was incomplete as the volume of condensate liquids exceeded the storage capacity of the condensate storage tank at Collier, the scrubbers and pipeline in the low pressure system were filled to capacity and shut in, the KPL scrubber was filled to capacity~and was shut in, and a pig and unknown volume of liquid remained in the 16" high pressure line between East Foreland and the KPL Junction. Because of the lack of flow in the 16" high pressure line, the dual marine pipelines had automatically shut in, the dual marine pipelines and the West Side 16'" high pressure pipeline pressure had increased to 1350 psi, and the 16" West Side pipeline was shut in. -2- This condition resulted in the decision to remove the overhead vapors from the gas stream to allow purging of accumulated condensable liquids follow- ing the re-establishment of normal operations. By 6:00 p.m. of March 5, operation of the Cook Inlet gas system had resumed, liquids had been re- moved from the low pressure system, and the West Foreland Plant was again onstream. At this point, the. depropanizer overhead vapors were being flared and have been flared since 6:00 p.m. on March 5, with the exception of short time periods when they have been returned to the system for plant perfor- mance analysis. From that time through March 22, a total of 30,429 MCF of depropanizer has been flared. We are continuing to investigate the various methods of solving the liquid problem as testified to in the February 23 Hearing. To reiterate, the pos- sible solutions are basically two: 1. Eliminate or minimize liquid drop out. 2. Improve. methods of handling liquid drop out. In order to investigate properly the various methods of reducing liquid drop out, it would be highly desirable to have a reliable set ot~ vapor-liquid equilibrium valves. Dew points and..the amount of condensation could then be calculated at varying pressure and composition. It is difficult, at best, to use the entire pipeline system as a laboratory to test the effect of various changes. With that goal in mind, we have made numerous dew point determinations with the Bureau of Mines test equipment at varying pressure and composition to determine whether the system is best fitted by the Chaa-Seader or Grayson-Streed correlation. Unfortunately, the data indi- cates that it fits neither. However, both measured and theoretical data show the point of maximum dew point is at lO00 psig; indicating that an increase in pipeline operating pressure would be beneficial. ! The determination of hydrocarbon dew points with the Bureau of Mines tester is subject to some error. Further, we' observed what appeared to be con- siderable variation in dew point from operational changes. Because of the possibility of field error, we have collected duplicate samples and sent them to Core Laboratories for determination of dew point at varying pressure and liquid-vapor ratio at 1200 psig and 25° F. Core Lab has said that such de- terminations are quite time consuming and will require six to eight ~weeks. We will, of course, attempt to accelerate the testing. As mentioned previously, both theoretical calculations and measured dew point data.show that liquid dropout would be decreased by increasing line pressure. We doubt that the test during late February and early March was a good indi- cation of the effect of pressure. The lines had not been pigged prior to the test and considerable liquid undoubtedly remained in the line. We plan to pig the lines thoroughly as soon as the necessary line checks and equip- ment changes have been made and then to operate the line at some 1400 to 1450 psig. The lines will then be pigged on a regular basis so as to give at least a rough idea of the amount of liquid dropout. We have considered two methods of utilizing the depropanizer overhead as · burner fuel. The overhead could be used directly as fuel but this would re- quire a change in burner orifices on all heaters. Since the same fuel must be supplied to all heaters, all orifices would have to be changed at the same time, which would require a complete shut down of the entire Trading Bay Pro- duction Facilities. Further, propane storage and vaporization equipment would have to be installed to supply rich gas to the burners when the LEX unit is out of service. -4- A more logical method of utilizing depropanizer overhead as fuel would be to install a system to mix air with the overhead to obtain a mixture having approximately the same burning characteristics as the present fuel. We are now talking with the Chem-Gas Company to determine if such a system can be made to be both s~ife and reliable. We hope to have the study completed within three to four weeks. We have investigated the use of gas well gas to supplement or partially re- place compressed lift gas on the Dolly Varden platform. The study shows that some 4 to 5 MMCFD of gas well gas can be introduced into the fas lift system without over loading existing equipment. As indicated earlier, this would have two useful effects: (1) The turbo expander throughput would be increased which would increase expander efficiency, thus increasing butane removal from the residue gas; (2) the lean gas well gas would dilute the residue gas. We plan to make a trial run on this procedure within the next two weeks. The Fluor Corporation has designed a new system of turbo-expander control instrumentation which they feel will enable the unit to recover from upsets · . more rapidly. During the recent .series of dew point determinations, we saw evidence that the dew point may increase some 20 to 30° during turbo expander upsets. Within the next few days we should receive the details on Fluor's proposed changes. If the system is acceptable, we expect to make the instru- mentation change within the next two to three weeks. We have not yet deter- mined whether the change will require a plant shutdown. Fluor has also been working with Rotoflow, the manufacturer of the turbo expander, on determining the optimum design of the compressor and expander wheels for maximum efficiency at present and near future throughputs and whether operation can be improved by recycling residue gas. Final selection on design may take one to two months. Equipment delivery and installation could require a month to six weeks. The liquid detecting and diverting system at Granite Point has been inspected. The d/p cell, which detects the passage of liquid, was found to be in work- .. lng condition; however, the pneumatic relay that receives the d/p cell signal and actuates the diverting valves was found to be inoperable. Attempts to repair it were unsuccessful and a new relay has been ordered~ Delivery may require two weeks or so. The liquid handling capabilities of the East Side low pressure and high pres- sure system have been improved by installing modified control equipment in order to handle higher volumes of condensable liquids. To date, all neces- sary controls have been installed or ordered, with the longest delivery items being high level alarm switches presently scheduled for delivery on April 6, and installation 'by April 15, 1973. Contingent on material delivery and installation, it is planned to clear the Cook Inlet gas system pipelines of all condensable liquids and increase the operating pressure to between 1400 psi and 1450 psi. on April 15, 1973, and conduct the field trial as descr bed above. TESTIMONY TO ESTABLISH THE EMERG'ENCY NATURE OF FLARING DEPROPANIZER OVERHEAD VAPORS - TRADING BAY PRODUCTION FACILITY - PRESENTED BEFORE THE ALASKA STATE OIL AND GAS CONSERVATION COMMITTEE ON FEBRUARY 23, 1973 - CONSERVATION FILES 119 AND 120 Testimony by Ray M. Barnds My name is Ray Barnds. I am the District Production Superintendent for the Union Oil Company of California, Anchorage~District, Alaska. My purpose here today is to discuss the problem of operating the dual marine pipeline and the East Foreland liquid handling facilities, which have necessitated the flaring of the depropanizer overhead vapors at the Trading Bay Production Facility. As Mr. Roberts has testified and Mr. James testified, during the' May ll, 1972, public at the East Foreland marine line terminus potential condensed liquids in the marine rate. Previous testimony .has established designed to operate during pipeline pigging those times that the Liquid Extraction Plant in.an upset condition. E. Church has previously hearing, the facilities were designed to handle pipelines at a controlled that these facilities were operations and during was bypassed or operating The operating plan developed for which the facilities were designed was to pig any accumulated liquids out of the 16" West Side onshore lines. These liquids were to be pigged from the West Foreland produc- tion facility .to Granite Point, at which point instrumentation was installed to divert liquids into one of the two marine pipelines. The liquid storage capacity of each of the two marine lines is in excess of 9,000 barrels, each line therefo're, provides the 'needed liquid storage capacity for the liquid accumulat'ion resulting from as much as 7 days downtime at the LEX Plant to be removed from the return to normal at this point in pipeline pigs 16" West Side pipeline. Following removal of the liquids from the 16" onshore line, the fluid diverting valve would open and the second of the two marine pipelines would gas delivery service. Referring to Exhibit A, the liquid removal program, it was planned to launch at Granite Point in the marine pipeline containing the liquid. The liquid would then be displaced from the pipeline at a controlled rate through the liquid recovery facilities at the East Foreland Onshore Site. It should be noted that at this point, it was planned that one marine line would be in gas service maintaining a constant flow of casi'nghead gas to the East Side delivery points. The second marine line flow controller governs the rate of liquid removal consistent with l~quid levels in the condensate receiver. Free gas is separated in the receiver and put in the 16" East Side onshore pipeline for delivery. Condensate from the receiver then flows through two stage fl ash stabilization equipment. Gas evolving put into the 10" Carbon ahd Chemical is collected in a to fl ash from the stabilization process is recovered and low pressure pipeline for use in the Collier Plant fuel system. Any remaining condensate densate storage tank. These facilities were designed stabilize condensate from the system at maximum daily excess of 1,500 BPD, In actual practice, it has been that the equipment performs slightly in excess of parameters. con - rates in demonstrated rated designed During the past winter months, the Liquid Extraction Plant has operating as indicated by Mr. Roberts, and liquids have be~n condensing in the system at rates estimated to .... be in excess of been -2- 1,O00 B/D. Operational problems, due primarily to the relatively large pipeline diameter in relationship to the casinghead gas through- put, have resulted in difficulties in pipeline pigging operations necessary to remove accumulated condensate liquids. Due to the combined effects or relatively low velocity and the fact that gas is used to displace pipeline pigs, considerable bypassing occurs during the pigging operation resulting in inefficient liquid displacement. Mr. Roberts has explained the nature of the retrograde condensation phenomena occurring in the p.ipeline system. Liquid has been conden- , , .. sing throughout the pipeline system as a result of the physical nature of the plant residue gas, The condensed .both pipelines rate through 'a liquids arrive at the East Foreland facility in as a result of slug flow rather than at a controlled single line. It is these conden'sate slugs which operation of the liquid handling facilities at The reason for this is, individual slugs of varying at a velocity equivalent to a 75,000 B/D liquid through- presently hamper East Foreland. volume arrive put rate. hour day is arrives in at rates-of faci 1 i ti es In otherwords, while the total condensation for a 24- estimated to be slightly in excess of 1,000 bbls., it both pipelines in slugs which would have to be handled 75,000 B/D to maintain continuous gas delivery.. These were not constructed for this condition. It should be noted that had the exceedingly large -3- facility required these liquid slugs been installed, the gas resulting stabilizing liquids would have evolved at a rate in to handle from fl ash excess of llO,O00 MCF/D. There is no facility or consumer capable of beneficially using a variable supply of high BTU gas peaking at the rate of 110,000 MCF/D for one hour or less. Accordingly, the facilities, as previously testified, were designed and installed to flash stabilize the pipeline condensate at a rate at which the flash gas could be utilized in the Collier Carbon and Chemical Plant for fuel in a recently modified plant system. The problem confronting System'at this time is, manner that condensable vapors arrive at a rate at which they may be flash utilized.. The emergency procedure of the operators of the Cook Inlet Gas therefore, to modify operations in at the East Foreland such a Facility stabilized and beneficially flaring the 2.5 million CF/D of depropanizer overhead vapors resulted in our being able to utilize the balance of the casinghead gas volume of 32.5 million in a continuous manner while working on the development of a solution for handling the total stream. CF/D As a first step toward solving the problem, we have, within the past two weeks, completed test modifications to the system at East Foreland. These changes have allowed us to elevate the pressure in the pipeline system. The pressure will be increased in steps in an attempt to find a point at which the condensable liquids remai.n in the vapor state, between the Trading Bay Production Facility and the East Forel.and marine line terminus. At East Foreland the pressure is being reduced through a control ,valve in an attempt to condense liquids in a continuous manner, directly proportional -4- to the pipeline throughput, or, about 1,O00 B/D for a throughput rate of 30 million CF/D. The results of these modifications have not been evaluated as of this date. This is due to the relatively short online time since establishing the new pressure base, and the fact that the gas composition has not been stabilized since returning the depropanizer overhead vapors to the gas stream. Therefore it is not known at this time whether or not the 2.5 million CF/D of propane rich vapors can be handled in a manner enabling us to flash stabilize the condensate for fuel useage. Mr..Roberts will now discuss other steps being taken toward solving the problem. TESTII:i0~iY TO ESYA~LISH THE EMERGE[~ICY ?,IATURE OF FLARI!'iG DEPRGPA[~IIZER OVERHEAD VAPORS - TRADING ~AY P,~0DUCTI0!~ FACILITY - PRESEI'ITED ~.EFORE Tt!E ALASKA STATE 0IL AND GAS COI:iSERVATI01~I COMMITTEE ON FEBRUARY 23, 1973 - CONSERVATI0~I FILES 119 A~ID .120 TESTIM01'.!Y BY C, L, ROBERTS MY NAME IS CLAUDE ROBERTS AND I AM THE ANCHORAGE DIV.ISlON PETROLEUM ENGINEER FOR MARATHON 0IL COMPANY, IN ADDITION, SERVED AS CO-CHAIRMAN OF THE MECHANICAL COORDINATING SUBCOMMITTEE OF A JOINT MARATHON-UNION TASK FORCE ESTABLISHED TO DESIGN AND INSTALL THE COOK INLET GAS SYSTEM, IT IS IN THIS LATTER CAPACITY THAT I TESTIFY TODAY, MY TESTIMONY WILL BRIEFLY DESCRIBE THE ENTIRE COOK INLET GAS SYSTEM, INCLUDING THE LIQUID EXTRACTION PLANT AT 'I/lEST FORELAND, THE TRANSPORTATION COMPRESSOR STATION, THE PIPELINE SYSTEM, AND THE EAST FORELAND LIQUID RANDLING FACILI- TIES, THIS TOTAL SYSTEM COST IN EXCESS OF 26 MILLION DOLLARS WI.TH THE DESIGN AND CONSTRUCTION COMMENCING SHORTLY' AFTER JULY 1, !971, I WILL GIVE IN MORE DETAIL THE DESIGN PARAMETERS FOR THE LIQUID EXTRACTION PLANT, HOW THEY DIFFER FROM ACTUAL OPERATING CONDITIONS, AND THE RESULTANT PROBLEM OF LIQUID DROP-OUT IN THE PIPELINE SYSTEM THAT IS CAUSING THE CURRE,~!T EI.'iERGENCY SITUATION, MR, ~ARNDS WITH UNION OIL COt,'IPA,NY WILL DESCRIBE THE PROBLEMS CONNECTED WITH OPERATING THE.MARINE LINES AND THE HANDLING OF LIQUIDS AT THE EAST FORELAND FACILITIES, AND FINALLY WE WILL DESCRIBE FOR YOU SOME OF THE ALTERNAT'IVE'METHODS WE ARE 'CONSIDERING FOR 'SOLVING THIS COM- :PLEX PROBLEM, MARATHON EXHIBIT #][ ILLUSTRATES THIS GAS SYSTEM AND. ITS ORIEN- TATION TO THE CASINGHEAD GAS PRODUCTION FROM THE MCARTHUR RIVER AND TRADING 'BAY FIELDS. THE TOTAL SYSTEM CONSISTS OF THE LIQUID l>'I'',/, ,,~ ,, ,, ..... EXTRACTION-'-'~:N?I!:'T' AT WEST FORELAND, THE LARGE COMPRESSOR FACILITY LOCATED THERE,. A ].6" PIPELINE .TO GRANITE POINT COMPLETE WITH PIGGING FACILITIES, DUAL 10" SUBMARINE LINES TO EAST FORELAND COMPLETE WITH PIGGING FACILITIES, LIQUID HANDLING FACILITIES AT EAST FORELAND, AND FINALLY A ]6" PIPELINE INTO THE NIKISKI AREA COMPLETE WITH PIGGING FACILITIESi THE NEXT EXHIBIT, MARATHON EXHIBIT #2, ILLUSTRATES A SIMPLI- FI ED DRAWING OF THE TRAD I NG BAY PRODUCT I ON FAC ILI TY I NCLUDI NG GAS SEPARATION, COMPRESSION, AND THE LIQUID EXTRACTION PLANT, You -3- WILL NOTE THAT FEED TO THE PLANT CONSISTS OF GAS PRODUCED FROM THE THREE PLATFORHS SERVING THE ~CARTHUR RIVER FIELD, THE TRADir,'G SAY FIELD HONOPOD, AND FLAStt VAPORS RESULTING FROM TREATING THE CRUDE OIL PRODUCED FROM THESE TWO FIELDS, RICH VAPORS FROM THE STORAGE TANKS ARE ALSO ACCUMULATED AND ARE INCLUDED IN THIS FEED · STREAM, THESE PLANT FACILITIES WERE ORIGINALLY PLACED IN OPERATION DURING FEBRUARY, 1970, THEY WERE DESIGNED TO EXTRACT BUTANES AND HEAVIER HYDROCARBONS FROM THE GAS CRYOGENICALLY, EMPLOYING A TURBO-EXPANDER FOR REFRIGERATION, PRIOR TO THE CONSTRUCTION OF THE COOK INLET GAS SYSTEM, PROPANE AND LIGHTER HYDROCARBONS WERE: 'FLARED FOR LACK OF A MARKET, THIS ESSENTIALLY WAS THE STATUS OF OUR OPERATION ON JULY 1, 1971, THE DATE OF THE "No FLARE" ORDERS, As EXPLAINED IN TESTIMONY GIVEN LAST MAY, CONSIDERABLE ENGI- NEERING EFFORT WAS NECESSARY TO OBTAIN UPDATED GAS PRODUCTION FORECASTS AND ANALYSES TO PROPERLY DETERMINE THE REQUIRED MODIFI- CATIONS AND ADDITIONS TO OUR EXISTI'NG FACILITIES TO MAKE THE GAS DELiV'ERABLE, THE RESULT OF THIS DATA ACQUISITION IS SUMMARIZED ON !'~ARATHON EXHI B I T #2 TO HELP EXPLAIN THE CURRENT EMERGENCY S I TUAT ION EXPER I- ENCED, THE RATES AND ANALYSES OF GAS FROM THE MCARTHUR RIVER FIELD AND THE TRADING BAY FIELD, AS WELL AS THAT OF CRUDE FLASH YA, PORS, ,,WERE ,,USED FOR DESIGN, PLEASE NOTE TI-~E HIG, H PROPANE CO'NTENT OF THE MCARTHUR RIVER GAS, 11 PERCENT: AND THE EVEN HIGHER PROPANE CONTENT OF THE CRUDE FLASH VAPORS, 30 PERCENT, ALL THESE GAS STREAMS ARE COMBINED THROUGH VARIOUS STAGES OF COMPRESSION AND ENTER THE DRY BED DEHYDRATORS FOR WATER REMOVAL PRIOR TO GOING TO THE TURBO-EXPANDER PORTION OF THE LEX PLANT, PERHAPS A BRIEF EXPLANATION OF HOW AN EXPANDER FUNCTIONS IS IN ORDER: WHEN GAS IS EXPANDED FROM A HIGH PRESSURE TO A LOWER PRESSURE ACROSS A CHOKE, A CERTAIN AMOUNT OF COOLING TAKES PLACE, THIS IS KNOWN AS THE JOULE-THOMPSON EFFECT, I AM SURE YOU HAVE ALL OBSERVED THIS EFFECT WHEN CONTROLLING A HIGH PRESSURE GAS WELL WITH ,RESULTANT FROST FORMING ON THE PIPING ADJACENT TO THE CHOKE, ADDITIONAL HEAT CAN BE REMOVED FROM THE GAS IF THE EXPAN- SION PROCESS CAN BE MADE TO PERFORM WORK, IN THE CASE OF A -5- TURBO-EXPANDER, THE GAS IS EXPANDED THROUGH A WHEEL '(~S'-~M-I'LAR TO A WATER'WHEEL) TO WHICH IS ATTACHED A SHAFT CONNECTING TO A WORK SOURCE, IN OUR CASE A CENTRIFUGAL COMPRESSOR, BY FIRST COMI:'RESSING THE FEED GAS (3¢I-N-G--WOR-K') THROUGH THIS CENTRIFUGAL COMPRESSOR AND THEN EXPANDING IT BACK THROUGH THE EXPANDER END (~R:=~ND), A · HIGH LEVEL OF REFRIGERATION IS IMPARTED TO THE GAS, THIS PROCESS IS AMPLIFIED BY COOLING THE GAS PRIOR TO EXPANSION BY BACK EXCHANGE WITH THE COLD RESIDUE GAS. AN IMPORTANT FACTOR TO REMEMBER .- THE LEANER THE GAS, THE LOWER THE TEMPERATURE WILL BE FROM THE EXPAN- SION PROCESS, THE DEEP REFRIGERATION IMPARTED TO THE GAS CAUSES THE HEAVIER HYDROCARBONS TO CONDENSE, ALONG WITH A PORTION OF PRO.PANE, ETHANE, AND METHANE, TttESE LIQUIDS ARE THEN SEPARATED FROM THE RESIDUE GAS AND ARE DELIVERED AS FEED TO THE DEPROPANIZER. STATING IT SIMPLY, THIS DEPROPANIZER TOWER S.TABILIZES THE LIQUIDS BY REMOVING THE PROPANE AND L IGttTER HYDROCARBONS OVERHEAD', WITH THE BUTANE AND HEAVIER HYDROCARBONS LEAVING THE BOTTOM AND BEING 'INJECTED I NI:O THE CRUDE STREAM. -6- THE EXPANSION PROCESS LEAVES THE RESIDUE GAS AT LOW PRESSURE THEREBY REQUIRING ADDITIONAL COMPRESSION TO ENTER THE PIPELINE SYSTEM, THE TWO DRY BED DEHYDRATOR TOWERS, MENTIONED 'EARLIER, MUST FREQUENTLY BE SWITCHED TO THEIR DRYING CYCLE' FOR 'REACTIVATION, HOT GAS FLOWS THROUGH THE BED BEING REACTIVATED, STRIPPING OUT THE WATER VAPOR, UNFORTUNATELY THE DRYING AGENT, ACTIVATED ALUMINA, ADSORBS SOME HEAVY HYDROCARBONS WHICH ARE ALSO STRIPPED OUT IN THE DRYING PROCESS, SINCE ONE OR THE OTHER TOWER IS ON THE DRYING CYCLE AT ALL TIMES, THE DRYING GAS IS A CO'NTINUOUS FLOW AND AMOUNTS TO ABOUT FOUR MILLION C'UBIC FEETPER DAY, THIS GAS STREAM AS WELL AS THE' DEPROPANIZER OVERHEAD VAPORS MUST BE DEHYDRATED AND COM- PRESSED TO ENTER TH'E pIpELINE, PLEASE NOTE THAT THE DEPROPANIZER OVERHEAD STREAM CONTAINS AN EXTREMELY HIGH PERCENTAGE OF PROPANE, ABOUT 60 pERCENT, THE COMBINED STREAM OF EXPANDER RESIDUE, DEHYDRATOR DRYING GAS',, AND DEPROPANIZER OVERHEAD VAPORS MAKES UP THE !'FEED.TO THE COOK INLET GAS SYSTEM, THE PERCENT OF PROPANE AND BUTANE IN THIS COMBINED STREAM IS CRITICAL AS TO WHETHER OR NOT IT WILL STAY I.N -7- THE VAPOR PHASE THROUGHOUT THE PIPELINE SYSTEM AT THE PRESSURES AND TEMPERATURES IT IS TO 'ENCOUNTER, THIS WAS OF GREAT CONCERN .. · FROM THE,BEGINNING AND WAS ONE OF OUR MOST IMPORTANT DESIGN PARA- METERS, THE COMBINED STREAM GOING INTO THE COOK INLET GAS SYSTEM WAS TO HAVE A HYDROCARBON DEWPOINT NOT HIGHER THAN 20°F, MARATHON'S CALCULATIONS INDICATED A HYDROCARBON DEWPOINT OF ABOUT 13°F AT 1200 'PSI, EVEN WITH A COMBINED RESIDUE GAS FROM A PLANT SYSTEM RECOVERING ONLY 75 PERCENT BUTANES, HOWEVER, DEPEND- ING UPON WHICH EQUILIBRIUM FACTOR CORRELATION WAS USED, WE RECOG- NIZED IT WAS POSSIBLE THAT RETROGRADE CONDENSATION COULD OCCUR RESULTING IN LIQUID FALL-OUT IN THE PIPELINE AT HIGHER TEMPERATURES, MARATHON AND UNION ELECTED TO INSTALL AN EXTENSIVE LIQUID REMOVAL SYSTEM AT EAST FORELAND TO COVER THE CONTINGENCY OF A PLANT UPSET AND IN,CASE RETROGRADE CONDENSATION DID OCCUR, THIS / LIQUID REMOVAL SYSTEM COST IN EXCESS OF 500 THOUSAND DOLLARS, MR, BARNDS OF UNION 0IL COMPANY WILL EXPLAIN THE SYSTEM IN MORE DETAIL AND A BRIEF DESCRIPTION HERE IS INTENDED ONLY TO SHOW THE. EXTENT OF OUR DESIGN CONSIDERATIONS, -8- OUR DESIGN WAS }~ASED UPON THE FOLLOWII'~G METMOD OF OPERATION: A PIG WOULD PERIODICALLY BE LAUNCHED AT I'IEST FORELAND PUSHING ANY LIQUID HYDROCARBONS TOWARDS GRANITE POI,NT, IF LIQUIDS WERE PRESENT, THEY WOULD AUTOMATICALLY BE DIVERTED INTO ONLY ONE OF THE TWO MARINE LINES, THE LINE~CONTAINING THE LIQUIDS COULD THEN BE PIGGED AT A CONTROLLED RATE PUSHING THE LIQUID HYDROCARBONS TOWARD EAST FORELAND, EACH MARINE LINE HAS A LARGE, HIGH-PRESSURE SCRUBBER AT THE EAST FORELAND TERMINUS, LIQUIDS WOULD BE SCRUBBED FROM THE GAS WITH THE GAS FLOWING INTO THE EAST SIDE ]..~" LINE GOING INTO THE NIKISKI AREA, THE LIQUIDS WOULD THEN FLOW INTO A FLASH STABILIZA- TION SYSTEM AND THE RESULTANT VAPORS WOULD ENTER'UNION'S 10¢~ SYSTEM, DELIVERING THE SHELL-AMoco GAS TO COLLIER, THE STABILIZED LIQUID REMAINING WOULD THEN BE STORED FOR DISPOSAL, SINCE' THE SCRUBBERS WERE LIMITED IN SIZE DUE TO THE HIGH PRESSURE APPLICATION', LIQUIDS MUST BE REMOVED FROM THIS LINE AT. A CONTROLLED RATE TO PREVENT LIQUID CARRYOVER INTO THE ~ ~,SYSTEM, SINCE THE OTHER LINE WOULD BE DELIVERING DRY GAS, THIS SCHEME ~:,:?. ~: <:% ~,, ?' ~ ,':,'" ~/!,'~' -A-PP-E-A-R-E-D'""TO BE WELL CONCEIVED, ENOUGH ON DESIGN PARAMETER ,~'I'LET US NOW DISCUSS THE ACTUAL CONDITIONS AND THEIR EFFECT ON THE DESIGN, UNFORTUNATELY, WE ANTICIPATED MUCH TOO HIGH A 'GAS VOLUME FORE- CAST FOR THE TRADING BAY FIELD, INSTEAD OF SLIGHTLY LESS THAN 26 MMCF PER DAY, WE HAVE ONLY 8 MMCF PER DAY, THE GAS FORECAST FOR THE MCARTHUR RIVER FIELD AND THE CRUDE FLASH VAPORS, FOR ALL PRAC- TICAL PURPOSES, WERE FAIRLY ACCURATE, THE LOWER THAN ANTICIPATED MONOPOD GAS PRODUCTION HAS THREE ADVERSE EFFECTS, ONE, THE TURBO- EXPANDER BEING SIZED FOR LARGER RATES, OPERATES AT A LOWER SPEED, · .. _.C:~ESULTING IN LESS REFRIGERATION BEING DEVELOPED, LEAVING A RICHER RESIDUE GAS; TWO, THE HIGHER RELATIVE PERCENTAGE OF THE RICHER MCARTHUR RIVER AND CRUDE FLASH VAPORS GIVE A HEAVIER PLANT FEED, RESULTING IN LESS TEMPERATURE REDUCTION; AND FINALLY THE COMPOSITE RESIDUE STREAM GOING TO THE COOK INLET GAS SYSTEM IS RICHER IN PROPANE SIMPLY BECAUSE THERE IS LESS METHANE AVAILABLE, THE COMBINATION OF THE FIRST TWO FACTORS HAS RESULTED IN AN EXPANDER SPEED OF ONLY 17,000 RPM INSTEAD OF THE DESIGN SPEED OF 25,000 RPM, THE ACTUAL DISCHARGE TEMPERATURE IS -40°F INSTEAD -10- OF THE -68°F ANTI CI PATED AND THE BUTANE RECOVERY EFFI C I ENCY I S ABOUT 77 PERCENT INSTEAD OF A DESIGN OF 94 PERCENT, CONSEQUENTLY, THE ACTUAL RECOMBINED RESIDUE GAS IS MUCH RICHER IN PROPANE THAN THE DESIGN STREAM, FURTHER, IT APPEARS THAT THE HIGHER EQUILIBRIUM FACTORS ARE THE MORE VALID OF THE TWO CORRELA- · . TIONS AS WE ARE EXPERIENCING A RETROGRADE CONDITION RESULTING IN LIQUID FALL-OUT IN THE PIPELINE SYSTEM, RETROGRADE CONDENSATION IS A PHENOMENA .LONG RECOGNIZED 'IN THE Oil. INDUSTRY WHEREBY THE HYDROCARBON SYSTEM DOES JUST THE OPPOSITE OF WHAT YOU WOULD LOGICALLY ASSUME, IF' OUR SYSTEM IS IN THE RETROGRADE CONDENSATI'ON RANGE AND THE PRESSURE IS RAISED SUFFICIENTLY HIGHER, THE HYDROCARBON SYSTEM TENDS TO BE MORE IN THE VAPOR PHASE AND HAVE A LOWER DEWPOINT TEMPERATURE, THE QUESTION IS CAN THE PRESSURE BE RAISED SUFFICIENTLY HIGH ENOUGH IN OUR SYSTEM SO THAT AT 26°F, THE MINIMUM ANTICIPATED TEMPERATURE, THE HYDROCARBONS WILL REMAIN IN THE VAPOR PHASE, SINCE PLACING THE SYSTEM INTO OPERATION~AND OBSERVING THE LARGE 'AMOUNT OF LIQUID CONDENSATION,. ~....-,~...~:~ ,. "!_..¥, ~. WE ARE STUDYING THE PHASE BEHAVIOR OF THE SYSTEM, ONE SET OF -11- EQUILIBRIUM FACTORS INDICATES THAT IF WE RAISE THE LI~']E PRESSURE ,, ., .- 'ABOUT 200 P$-I TO AN OPERATING PRESSURE OF 1300 PSI, THE HYDROCAR]BON SYSTEM WILL REMAIN IN THE VAPOR PHASE, HOWEVER, THE OTHER CORRE'- LATION INDICATES THAT WE WILL EXPERIENCE HIGH DEWPOINTS EVEN AT 1500cP-S'"-I''-.WHICH EXCEEDS OUR MAXIMUM OPERATING PRESSURE, YOU WILL NOTICE THE HIGH PROPANE CONTENT OF THE DEPROPANIZER OVERHEAD STREAM,~ THIS STREAM IS A RELATIVELY SMALL VOLUME, RANGING FROM TWO MILLION CUBIC FEET PER DAY IN THE WINTER MONTHS TO FOUR MILLION CUBIC FEET PER DAY DURING THE SUMMER, AND REPRESENTS ABOUT 1/16 OF THE VOLUME DELIVERED TO THE TRADING BAY PRODUCTION FACILITY, WE HAVE ON TWO OCCASIONS, SINCE INITIAL START-UP LAST OCTOBER, DIVERTED THE DEPROPANIZER OVERHEAD TO FLARE AND THE LIQUID PROBLEM IN THE LINES HAS GREATLY DECLINED EACH TIME, As YOU WILL RECALL, THE COMMITTEE WAS ADVISED ON EACH OF THESE OCCASIONS, I WOULD LIKE TO AMPLIFY THE HIGH PROPANE CONTENT OF THE GAS GOING TO THE COOK INLET GAS SYSTEM BY BRIEFLY EXPLAINING THE PRO- PANE MATERIAL BALANCE PRESENTED ON MARATHON EXHIBIT ,: · -12- TOTAL PROPANE CONTENT IN THE CASINGHEAD GAS FEEDING THE LEX PLANT UNDER DESIGN CONDITIONS WAS ESTIMATED TO BE ABOUT 3300 BARRELS PER DAY, ACTUAL CONDITIONS HAVE RESULTED IN 2900 BARRELS PER DAY, SOME q00 BARRELS PER DAY LESS EVEN THOLIGH THE INLET GAS VOLUME CHANGED FROM 55 MMC~FD"TO 35 MMCFD', THE PROPANE CONTENT OF THE EXPANDER RESIDUE GAS IS 1800 BARRELS PER DAY UNDER ACTUAL CONDITIONS WHILE DESIGN ESTIMATES CONTEMPLATED ONLY 900 BARRELS PER DAY, PLEASE REMEMBER THAT IF THE PROPANE CONTENT IS REDUCED IN THE EXPANDER RESIDUE BY ADDI- ,, TIONAL REFRIGERATION CAUSING MORE OF IT TO CONDENSE, THE PROPANE NECESSARILY WILL BE 'IN THE DEPROPANIZER OVERHEAD AND ADDED BACK INTO THE--S-T~E-A~I GOING TO THE COOK INLET GAS SYSTEM, 'Ti,'~' ....... C '~? '~ WHETHER THE PROPANE IS LEFT IN THE EXPANDER RESIDUE OR IS IN THE DEPROPANIZER OVERHEAD STREAM, THE RESULTANT FEED TO THE COOK INLET GAS SYSTEM ACTUALLY CONTAINS 2400 BARRELS PER DAY OF PROPANE AS COMPARED TO 3100 BARRELS PER DAY UNDER DESIGN CONDITIONS, HOWEVER, THE CRITICAL POINT IS TO RELATE THESE VOLUMES OF PROPANE TO THE TOTAL VOLUME OF GAS GOING TO THE COOK INLET GAS SYSTEM IN -13- EACH CASE, PROPANE CONTENT ACTUALLY INCREASED FROM 67,4 BARRELS , , , PER qtq~qC-F IN THE DESIGN CASE TO 87,8 BARRELS PER MMCF ~N THE ACTUAL CASE FOR AN INCREASE OF 30 PERCENT OVER DESIGN, IT IS THIS HYDROCARBON SYSTEM THAT IS CURRENTLY CAUSING THE LIQUID DROP- OUT PROBLEM, MR, BARNDS WILL NOW DESCRIBE IN MORE DETAIL THE EAST FORELAND FACILITIES AND THE PROBLEMS EXPERIENCED WITH OPERATING THE MARINE LINES, WE WILL THEN FURTHER DESCRIBE SOME OF THE AREAS WE ARE NOW INVESTIGATING TO CORRECT THIS PROBLEM, (MR, BARNDS' TESTIMONY) -14- MR, }BARNDS HAS DESCRIBED OUR CURRENT EFFORTS TO TRY TO FIND SATISFACTORY OPERATING PROCEDURE WHEREBY THE DEPROPANIZER OVER- HEAD.CONTINUES TO BE INJECTED INTO THE PIPELINE SYSTEM, THE DEPROPANIZER OVERHEAD VAPORS ARE GOING INTO THE PI'PELINE SYSTEM OPERATED AT THE'ELEVATED PRESSURE, AND AT THIS TIME NO GAS IS BEING FLARED FROM ANY FACILITY OTHER THAN THAT FOR SAFETY PILOT, OTHER POSSIBILITIES ARE BEING CONSIDERED FOR SOLVING THE LIQUID DROP-OUT PROBLEM IN THE EVENT .OPERATING THE SYSTEM AT HIGHER PRESSURE~; DOES NOT OFFER A SOLUTION, ONE OF THESE POSSIBILITIES IS TO REDUCE THE VOLUME OF DEPROPANIZER OVERHEAD WHICH MUST BE INJECTED INTO THE STREAM.GOING TO THE COOK INLET GAS SYSTEM, IF WE CAN 'DEVELOP A SATISFACTORY FUEL SYSTEM WHEREBY :THIS PROPANE 'ENRIC'HED STREAM CAN BE USED FOR FUEL IN THE CRUDE' TREATERS, A SIGNIFICANT REDUCTION COULD BE MADE IN THE VOLUME REMAINING FOR INJECTION INTO THE COOK INLET GAS SYSTEM, WE ESTIMATE.THAT ABOUT 1,1 'MMCFD WOULD" BE USED IF A RELIABLE FUEL .SYSTEM CAN BE DEVELOPED, THE OUESTION REMAINS - IS THIS SUFFICIENT TO ELIMINATE THE LIQUID DROP-OUT PROBLEM? IT CERTAINLY WOULD HELP AND THEREFORE WE ARE NOW DISCUSSING IT WITH -15- EQUIPMENT MANUFACTURERS, BOTH TO DETERMIHE THE FEASIBILITY AND THE TIME REQUIRED TO DESIGN, PURCHASE, AND INSTALL THE NECESSARY FACILITIES, ANOTHER AREA UNDER REVIEW IS TO PRODUCE DRY GAS WELL GAS FROM THE TRADING ]~AY UNIT PLATFORMS THROUGH THESE GAS HANDLING FACILITIES RESULTING IN A DRY RESIDUE GAS STREAM GOING TO THE COOK INLET GAs S. YSTEM. THIS WOULD, OF COURSE, HAVE THE EFFECT OF FORCING THE RESIDUE GAS TO BE MORE NEARLY LIKE THAT CONTEMPLATED UNDER DESIGN CONDITIONS AND SHOULD HELP THE LIQUID DROP-OUT PROBLEM. t'!ELL CAPACITY AND GAS HANDLING EQUIPMENT LIMITATIONS ON THE PLATFORMS MAY LIMIT THE EFFECTIVENESS OF THIS POSSIBLE SOLUTION. ONE OTHER AREA WHICH HAS BEEN UNDER STUDY SINCE EARLY DECEMBER IS THE REDESIGN OF THE TURBO-EXPANDER FOR GREAT.ER RECOVERY EFFI- CIENCY UNDER ACTUAL FLOW RATES, WHILE THIS WILL HAVE LITTLE EFFEC'T ON THE PROPANE CONTENT OF THE GAS GOING TO THE COOK INLET GAS SYSTEM, IT WILL REMOVE MORE BUTANES AND THIS WILL HELP LOWER THE DEWPOINT TEMPERATURE OF THE RESIDUE GAS. ACTUAL TES.T DATA WAS ACQUIRED LATE IN DECEMBER AND TRANSMITTED TO OUR ENGINEERING FIRM -16- FOR REDESIGN OF THE EXPANDER, A COMPLETE HEAT AND MATERIAL BALANCE IS CURRENTLY BEING CALCULATED USING THE NEW TEST DATA AFTER WHICH THE EXPANDER MANUFACTUI~ER CAN REDESIGN HIS EQUIPMENT, WE EXPECT THE RESULTS OF THIS EFFORT VERY SHORTLY, AND HOPEFULLY, MODI FICA- TIONS CAN BE MADE THIS SPRING, AGAIN, I MUST REITERATE THAT THIS ALONE WILL NOT BE A COMPLETE SOLUTION, IN FACT, THE FINAL SOLUTION COULD VERY WELL BE A COMBINATION OF SOME OR ALL OF THE AREAS NOW UNDER CONSIDERATION, OR NEW AREAS WHICH MAY BE DEVELOPED, ANY SOLUTION WILL DEFINITELY REQUIRE SOME MODI'FICATION TO OUR SYSTEM,, IT IS DIFFICULT TO ESTIMATE EXACTLY THE DELIVERY TIME REQUI RED FOR EQU I PMENT, BUT PAST EXPER I ENCE INDICATES THAT SEVERAL MONTHS ARE USUALLY REQUIRED EVEN FOR RELATIVELY MINOR ITEMS, IN ADDITION, WE WILL QUITE LIKELY REQUIRE A GOOD PORTION 'OF THE SPRING · AND SUMMER CONSTRUCTION SEASON FOR THE INSTALLATION OF THE NECESSARY EQUIPMENT, ALTHOUGH WE ARE NOT SURE THAT THE ELEVATED PRESSURE OPERATION CURRENTLY UNDER TEST WILL RESULT IN A TOTAL SOLUTION DURING THE COLD MONTHS, WE ARE HOPEFUL THAT DURING THE WARMER MONTHS ALL OR A -17- PORTION OF THE DEPROPANIZER OVER,lEAD VAPORS CAN BE INJECTED INTO THE STREAM GOI[~G INTO THE COOK INLET GAS SYSTEM, IN ORDER TO PROVIDE SUFFICIENT TIHE TO EVALUATE, DESIGN, RECEIVE, AND INSTALL THE POSSIBLE NEEDED FACILITIES TO ELIMINATE THE LIQUID DROP-OUT PROBLEM OCCURRING IN THE COOK INLET GAS SYSTEM, · . WE W~ILL NEED PERMISSION TO CONTINUE FLARING THE DEPROPANIZER OVER- HEAD VAPORS, AS NECESSARY, UNTIL SEPTEMBER 1, 1973, THAN K, YOU, SCALE ~N MILES NORTH TRADING BAY FIELD o. P. TRADING BAY FIELD oO ! MC' ARTHUR RIVER FIELD WEST FORELAND FIELD ! RIG TENDERS, STD., LNG & COLLIER DOCKS KENAI ',".'~,.~ :N. COOK i..::: :~..:/.:; INLET FIELD BARROW Bill ALASKA GuLF OF ALASKA Paci fie o LEGEND OIL FIELD ~--I GAS FIELD ~ EXISTING PIPELINES ~ MARATHON OPERATED ~ OUTSIDE OPERATED MARATHON -UNION COOK INLET GAS SYSTEM MARATHON EXHIBIT I ,, STATE OF ALASKA DEPARTMENT OF NATURAL RESOURCES DIVISION OF OIL AND GAS Alaska 0II and Gas Conservation Committee 3001 Porcupine Drive Anchorage, Alaska 99501 Re: Emergency Order February 9, 1973 Conservation File No. 120 Union 0II Company of California Trading Bay Field The Union 0II Company of California has petitioned the Alaska Oil and Gas Conservation Committee for an emergency order allowing exception to Rule 2 of Conservation Order 103 to permit the flaring of caslnghead gas originating from the McArthur River Field In excess of the amount necessary for an adequate safety flare. The unforeseen condensation of hydrocarbon gases in the submarine caslnghead gas pipeline has resulted in the necessity to flare a relatively small portion of the total volume of gas to allow an uninterrupted flow of the remainder of the gas from the West Foreland production facility to the Nlklski area. An emergency order is hereby granted pursuant to Title II, Alaska Administrative Code, Section 2012, permittlng the flaring of gas ori- glnatlng from the McArthur River Field in excess of the amount necessary for an adequate safety flare at the West Foreland production facility untll 7:00 AM February 24, 1973. Thomas R. Marshall, Jr. Executive Secretary STATE OF ALASKA DEPARTMENT OF NATURAL RESOURCES DIViSiON OF OiL AND GAS Alaska 011 and Gas Conservation Committee CONSERVATION ORDER NO. 119 & No. 120 Trading Bay Field McArthur Field HEAR I NG February 23, ~973 PROCEEDINGS Mr. Burrell: Good morning Gentlemen. This Is a hearing of the Alaska Oil and Gas Conservation Committee, Conservation FI les No. 119 and No. 120, both of which relate to the application of Unlon 0II Company of California for amendment to Rule No. 2 of Conservatlon Orders numbers 103 and 104 respectively, to authorize the the 011 and Gas Conservation Committee to authorize flaring or venting of caslnghead gas in Tradlng Field and the McArthur River Field, respectively, In cases of emergency or operational necessity. It Is a proposed change to order, that is, to Rule No. 2 of both orders, which essentlally provides one addltlon, which Is: "and except as may be authorized by the Committee In cases of emergency or operational necessity." In other words the change relates to the addltlon of the language or operatl ona I necessity." Reason g i yen I s unforeseen operatl ng condl tions due to the condensation of hydrocarbons In the gas lines, and they request authority to flare for this reason. And both notices were published February 13, 1973, In the Anchorage Dally News, and we'll take these two hearings In sequence. In both cases there's been an emergency order issued which expires at 7:00 AM tomorrow morning, to permit the flaring. My name Is Homer Burrell and I'm Chalrman of the Alaska 0II and Gas Conservation Committee; to my right Is Mr. Tom Marshall, Executive Secretary of the Conservation Committee; to my left ls Mr. O. K. Gl ibreth, member of the Committee; and to my extreme right is Mr. John Reeder, the Attorney General's Office. Owing to the fact that the emergency order expires at 7:00 tomorrow morning, It will be necessary to rule today on this matter, at conclusion of thls hearing. Now I'll ask everybody to try and speak Into the microphone. I apologlze for my cold, I'm having dlfflculty and hope they can plck me up. Is the applicant ready to testlfy? Mr. Anderson: Yes. Mr. Chairman and members of the Commltte, my name is Robert H. Anderson, attorney for Marathon Oil Company In Anchorage. As the notice of hearlng specifies In the request, Union 0II Company of Callfornla fi led the request In behalf of Itself and Marathon 0II Company. Now i am appearing here today in behalf of both companles. We would request that since the caslnghead gas from the Trading Bay Field, which Is subject to Conservatlon Order 103, and the caslnghead gas from McArthur Rlver Field, whlch ls subject to Conservation Order 104, both go Into the Union-Marathon system, and Inasmuch as Rule 2 of 103 and 104 Is Identlcal In language, we request that the hearing be consolidated on the Conservation Orders 119 and 120. Mr. Burrell: Unless there is an objection we'll consolldate the hearing, recognizing the fact that the evidence mlght have to be different, dlfferentiated between the two productions Mr. Anderson: Alrlght. We also request that alt previous testlmony given before this Committee at the May II, 1972 hearing, concerning Con- servatlon Orders 102 through 105, Insofar as It pertalns to Conservation Orders 103 and 104, pertaining to the Marathon-Unlon system, and to the effects of shutting In production, be Incorporated into this record and made a part of thls hearlng. Mr. Burrell: Without objectlon,.we'll Include them as part of the record. -2- Mr. Anderson: Just briefly I'd like to set forth the order of hearings, subject to your approval. We'd like to divide them Into two parts; one would be concerned with the continuing need to flare periodically, the depro- panlzer overhead volumes, which will be explained In the testimony; and the other part would relate to the need ,o amend the rule for operational necesslt~/ In cases of certain needs. We' II present two witnesses, In the flrst part, Mr. Claude L. Roberts, Marathon 0II Company, who wlll testify brlefly describing the system and descrlblng the nature of the current problem. Mr. Ray Barnds, of Union 011 Company of Callfornla, will then testify concernlng the operation of the marine lines and the east slde Ilquld handling faclll,les. Mr. Barnds will then ,estlfy as to one area under study for solution of the problem. Mr. Rober,s will then come back and testify as ,o another area under consideration for solution of the problem. We will ,hen go to part two, and Mr. Barnds will ,eStlfy In connection with the operational necessll~/. Now, questions are welc~e at anytime. ~/e~re suggestlng that questions be held to the end of each part unless It goes to clariflcatlon of the testimony at that partlcular point, and the reason I say this Is that the subsequent testlmony of the glven witness i may explaln the question which you had In your mlnd at that time. I thlnk It would be appropriate to swear both witnesses at ,hls time. ,, Mr. Burrell: Alrlght, Mr. Marshall . Mr. Harshall: Please rise and ralse your right hand. In the matter now at hearing do you swear to tell the truth, the w'hole truth and nothing but the truth, so help you God? -3- Mr. Roberts: I do. Mr. Barnds: I do. Mr. Marshall: You may be seated, 'thank you. Mr. Burrell: Let the record show that Mr. Ray Barnds and Mr. Claude Roberts are both sworn In. Mr. Anderson: Mr. Claude Roberts of Marathon Is our flrst witness, and I th lnk you'll recall that at the May II, 1972 hearlng, Mr. Roberts was qualifled as an expert witness and we ask that his quallflcatlons be accepted for the purpose of thls hearing and that he testlfy as an expert w I tness. Mr. Burrell: Hls qualiflcatlons are accepted as an expert witness. Mr. Roberts: Thank you. I'd ilke to ask Mr. Perdy to aid me 'In my testimony by polntlng out salient features on both eXhlblt, Marathon Exhibit No. I and Marathon Exhlblt No. 2. My name Is Claude Roberts and I am the Anchorage Dlvtslon Petroleum Engineer for Marathon 011 Company. in addltlon, I served as Co'Cl~alrman of the Mechanlcal Coordlnatlng Subc°mmlttee Of a joint Marathon-Union Task Force established to design and Install the Cook Inlet Gas System. it Is In thls latter capaclty that I .testify today. My testimony wlll b'rlefly descrlbe the entire Cook Inlet Gas System, lncludlng the Llquld Extraction Plant at West Foreland, the TransPortation Compressor Station, the. Pipeline System, and the East Foreland Liquid Handllng Facilities. This total system cost In excess of 26 mi Ilion dollars, with the design and construction commencing shortly after July I, 1971, I wlll give in more detail the deslgn parameters for the Llquld Extraction Plant, how they differ from actual operating conditlons, and the resultant problem of Ilquld drop- out In the pipeline, which Is what Is causing the current emergency situation. Hr. Barnds with Union OII Company wi II descrlbe the problems connected with operating the marine lines and the handling of liquids at the East Foreland facllltles, and finally we will descrlbe for you some of the alternative methods we are conslderlng for the solving of this complex problem. Harathon Exhlblt //I II lustrates this gas system and Its orientation to the caslnghead gas production from the Hc^rthur RIver Field and the Trading Bay Field. The total system consists of the Llquld Extraction Plant at West Foreland, the large compressor facl I it~/ located there, a' 15' pipeline to Granite Point complete with plgging facilities, the dual. 10' submarlne Ilne to East Foreland complete with plgglng facilities, Ilquld handling facilltles at East Foreland, and flnally.a 16" plpellne Into the Nlklskl area complete with pigging facllltles. The next exhlblt, ~4arathon Exhibit //2, Illustrates a slmpllfled drawing of the Trading Bay Production Facl l It~/ Including gas separatlon, compresslon, and the Ilquld extraction plant. You wlll note that the feed to the plant consists of gas produced from the three platforms serving the McArthur Rlver Field, the Tradlng Bay Field Monopod, and flash vapors resultlng from treatlng the crude oil produced from these two flelds. Rich vapors from the storage tanks are also accumulated and are Included In thls feed stream. These plant facllltles were orlglnally placed In operation during February, 1970. They were designed to extract butanes and heavler hydrocarbons from the gas cryogenlcally, employing a turboexpander for refrigeration. Prior to the construction of the Cook Inlet Gas System, propane and lighter hydrocarbons were flared for lack of a market. This essentlally was the status of our operation on July I, 1971, the date of the 'No Flare" orders. As explained in testimony given last May, considerable engineering effort was necessary to ob,aln updated gas producflon forecasts and analyses to properly determine the required modiflcatlons and additions to our exls,lng facilities to make the gas deliverable. The result of thls data acqulstlon Is summarized on Harathon Exhibit · No. 2 to help explal n the current emergency sl tuatlon experienced. The rates and analyses of gas from the Hc^rthur River F.l~ld and ,he Tradlng Bay Field, as well as ,ha, of the crude flash vapors, listed ,here under the design column, were used for design. Please note the high pro~ane content of the McArthur River Gas,..ll percent; and the even higher propane content of the crude flash vapors, 30 percent. All these gas streams are comblned through various stages of compressl°n and enter the dry bed dehydrators ,, for water removal prior to. going to the turbo-expander portlon of the LEX p'l ant. Perhaps a brief explanatlon of how an expander ..functlons is In order: , , When gas Is expanded from a high pressure to a lower pressure across a choke, a certain amount of coollng takes place. Thi~ Is known as the Joule- Thompson effect, I am sure you have all observed 'this effect when control I lng a high pressure gas well wlth resul.tant frost forming on ,he piping adjacent ,o the choke, ^ddltlonal heat can be removed from the gas If the expansion process can be made to perform work. In the case of a turbo-expander, the gas Is expanded through a wheel, to which Is atfached a shaft connecting , to a work source, In our case a centrifugal compressor, b.¥ f!rst compresslng -6- the feed gas through thls centrlfugal compressor and then expanding It back through the expander, a high level of refrigeration Is Imparted to the gas. This process Is ampllfled by cool lng the gas prior to expansion by back exchange wifh the cold residue gas. An Important factor to remember - the leaner the gas, the lower the temperature'~:wl'll be:..~f...rom the expansion process. The deep refrlgeratlon Imparted to the gas causes the heavier hydro- carbons to condense, along wlth a portion of propane, ethane, and methane. These liquids are then separated from the resldue gas and delivered .as feed to the depropanlzer. Stating It slmply, this depropanlzer tower stabl Ilzes the I lqulds by removing the propane and ilghter hydrocarbons overhead, with the butane and heavier hydrocarbons leaving the 'bottom and being Injected i n~o the crude stream. The expansion process leaves the residue gas at Iow pressure, thereby requiring additional compression to enter the 'pipeline system. The .~wo dry bed dehydrator towers, mentloned earlier, must frequently be switched to their drylng cycle for reactivation. Hot gas flows through the bed being reactivated, strlpplng out the water vapor. Unfortunately the drying .. agent, activated alumina, absorbs some heavy hydrocarbons whlch are also , stripped out In the drying process. Since one tower or the other Is on the drying cycle at all tlmes, the drying gas Is a continuous flow and amounts to about four ml Ilion cublc feet per:day. Thls gas stream, as well as the depropanizer overhead vapors, must be dehydrated and compressed to enter the pipeline. Please note that the depropa~Izer overhead stream contains an extremely high percentage of propane, about 60 percent. -7- The combined stream of expander residue, dehydrator drylng gas, and depropanlzer overhead vapors makes up the total feed to the Cook Inlet Gas System. The percent of propane and butane In this combined stream Is critical as to whether or not it wl II stay In the vapor phase through- out the plpellne system at the pressures and temperatures It Is to encounter. This was of great concern from the very beginning and was one of our most Important design parameters. The combined stream golng Into the Cook inlet Gas SYstem was to have a hydrocarbon dewpolnt not higher than 200 F. Marathon's calculations Indlcated a hydrocarbon dewpolnt of about 13°F at 1200 pounds, even wlth a comblned residue gas from a plant recover- lng only 75 percent butanes. However, depending upon which equlllbrlum factor correlation was used, we recognized It was poSslble that retrograde condensation could occur resulting in liquid fall-out In the pipeline at h lgher temperatures. Marathon and Union elected to Install an extensive liquid removal system at East Foreland to cover the contlngency of a plant upset and In .,, the case retrograde condensation did occur. Thls I lq.uld removal system cost In excess of 500 thousand dollars. Mr. Barnds .will expla.ln the system In more detail and a brief descrlptlon, here is intended only to show the extent of our design considerations. Our design was based upon the followlng method Of operatlon: A plg would be perlodlcally launched at West Foreland pushlng any Ilquld hydrocarbons towards Granite Polnt. if Ilquids were present, the~ would automatlcally be diverted Into only one of the two marine Ilnes. The lines contalnlng the liquids could then be pigged at a controlled rate pushl.ng the liquld -8- hydrocarbons towards East Foreland. Each marlne line has a large, high- pressure scrubber at the East Foreland terminus. Liquids would be scrubbed from the gas with the gas flowing Into the east side 16" line going Into the Nlklskl area. The Ilqulds would then flow into a flash stabilization system and the resultant vapors would enter Unlon's I0" system, delivering the Shell-Amoco gas to Collier. The stabilized IlqUl'd remaining would then be stored for disposal. Since the scrubbers were Ilmlted in slze due t° the high pressure appllcatlon, liquids must be removed from thls Ilne at a controlled rate , , to prevent liquid carryover Into the 16" gas system. Since the other Ilne : :' would be delivering dry gas, thls scheme seemed to be well conceived. Enough on deslgn parameters, for the moment, let us now discuss the actual conditions and thelr effect on the design. Unfortunately, we antlcipated much too high a gas volume forecast , for the Trading Bay Fleld. Instead of slightly less than 26 mllllon per day, we have only 8 mlllion per day. The gas forecast for the McArthur : River Field and the crude flash vapors, for all practical purposes, were fairly accurate. The lower than antlclpated Monopod gas production has three adverse effects. One, the turbo-expander being sized for larger rates, operates at a lower speed, resulting In less refrigeration being developed, leavlng a rlcher residue gas: two, the higher relative percentage of the rlcher McArthur River and crude flash vapors give a heavier plant , feed,.resultlng In less temperature reduction; and flnally, the composite · : residue stream going to the Cook Inlet Gas System ls rlcher In propane simply because there Is less methane available. -9- The comblnatlon of the first no factors has resulted In an expander speed of only 17,000 RPH Instead of the design speed of 25,000 RPM. The actual dlscharge temperature Is -4~F Instead of the -68OF anticipated and the butane recovery efflclency Is about 77 percent Instead of a design .of 94 percent. Consequently, the actual recomblned residue gas Is much richer In propane than the design stream. Further, It appears that the higher equi librium factors are the more valid of the ~o correlations, as we are experlencing ,,, a retrograde condltion resulting In llquld fall-out In the plpellne system. Retrograde condensation Is a phenomena long .recognized In the oll Industry whereby the hydrocarbon system does just the opposite of what you would logical ly assume, if our system Is :In the retrograde cOnden- Sation range and the pressure is raised sufflclently higher, the hydro- carbon system tends to be more in the vapor phase and have a lower dew- point temperature. The question is, can the pressure 'be ralsed sufflclently high enough In our system so that at 26OF, the minlmum antlclpated temper- ature, the hydrocarbons will. remain In the vapor phase. Since placing the , system Into operation In October of last year and observlng the large amount of liquid condensation, we are studylng the.phase behavior once again of this system, One set of equilibrium factors l.ndlcates that If we raise the line pressure about 200 pounds to an operatlng pressure of 1300 pounds, , ,;. the hydrocarbon system wlll remain in the vapor phase. However, the other correlation Indicates that we wi II experience high dewpoints even at 1500 pounds, whlch exceeds our maximum operating pressure. -lO- You will notice the high propane content of the depropanizer over- head stream, some 60 percent. This stream is a relatively small volume, ranging from two million cubic feet per day In the wlnter months fo four million cubic feet per day during the summer, and represents about 1/16 of the volume delivered to the Tradlng Bay Production Faclllfyo We have on two occasions, slnce Inltlal start-up last October, diverted the depro- panlzer overhead to flare and the Ilquid problem In the lines has greatly declined each time. As you will recall, the Commltfee was advised on each of these occasions. I would like to amplify the high propane content of the gas golng to the Cook Inlet Gas System by briefly explaining the propane material balance presented on Harathon Exhlblt No, 2, and highlighted !n red. ' Total propane content I n the casi nghead gas feeding the LEX plant under design condltlons was estimated to be about 3300 barrels per day. ^ctual conditions have resu Ired In 2900 barrels per day, some 400 barrels per day less even though the Inlet gas volume changed from 55 roll lion to 35 mlllion. The propane content of the expander residue gas Is 1800 barrels, per day under actual conditions whlle design estimates contemplated only 900 barrels per day. Please remember that If the propane content is reduced in the expander residue by addltlonal refrigeration causing more of It to condense, the propane necessarily wi II be In the depropanlzer overhead and added back Into the system golng to the Cook Inlet Gas System. Therefore, whether the propane Is left in the expander residue or Is In the depropanlzer overhead stream, the resultant feed to the Cook inlet Gas System actual ly contal'ns ?_400 barrels per day of propane as compared -II- ,o 3100 barrels per day under design condi,lons. However. ,he cri,lcal poln, Is ,o rela,e ,hese volumes of propane ,o ,he ,o,al volume of gas going ,o ~ ,he Cook Inle, Gas Sys,em In each case. Propoane con,eh, ac, ual ly has Increased from 67.4 barrels per million in ,he design case ,o 87.8 barrels per mllllon In ,he ac, ual case. for an Increase of 30 percen,. i, Is ,hls hydrocarbon sys,em ,ha, is curren, ly causing ,he liquid drop- ou, prob leto. I think this Is the proper time to turn the program over ,o Mr. Barnds, to describe In more detall the East Foreland facllltles and the problems experienced wlth operating the marine lines, and we wi ii then further describe . some of the areas we are Investigating to correct th l's problem. Mr. Anderson: Just one minute, with respect to Marathon Exhlblt i and 2, Mr. Roberts, were these prepared by you, or under your supervision? Mr. Roberts: Yes, they were. Mr. Anderson: We ask that Marathon Exhlblts. I and 2 be' admitted In ev I dence. Mr. Burrell: You don't by any chance have a small copy? Mr. Anderson: Yes sir, we will furnish you a small copy of Exhlblt I and a blue line copy of Exhibit 2 to be replaced by a smaller copy when we can shoot It down. Will that be acceptable? Mr. Burrell: We wi II have reproduced reproductions of both exhibits, Is tha, right? Mr. Anderson: Yes. Mr. Burrell: Our fl les wi I I be complete. Mr. Anderson: ~Rlght. -12- l~r. Burrell: Without objection, that wlll be flne, Hr, Anderson; Fine. Also Hr, Ray Barnds has not been qualified before this Committee.,as~an,,-~expert'?'wltness, and w~ would Ilke to do that at thls time. Hr. Barnds, would you please state your quallflcatlons for the benefit of the Committee. Hr. Barnds; Thank you. I received a Bachelor of Engineering degree In Petroleum Engineering in 1957, and a Hasters of Sclence Degree In Petro- leum Engineering In 1959, both at the School of Englneering at the University Southern Callfornla. Hy experience In the oll Industry and engineerlng and operations begab~"~in 1956 when ! was employed by the Unlon 011 Company of California. I~ve held several positions since that time with the Union 011 Company and two oli producing companles~,other then Union 011 Company of Callfornlao These positions Include both staff and supervisory positlons, with drill lng and reservoir and production englneerlng and drilling and production operations. Hy experience In Alaska began In September 1971, ,when I was appolnted Distrlct Production Superlntendant of the Alaska Dlstrlct to the Union 011 Company of Californla, In July 1971 I began serving as the Co-Chairman of the Joint ~larathon-Unlon Task Force Hechanlcal Coodl- natlng Subcommittee, established to deslgn and const'ruct the Cook inlet Gas : Gathering system. I subsequently served as Project ?~anager for Unlon 011 Company during the construction of the dual marine plpellne, East Side Ilquld handling facllltles and East Side pipeline for the Cook Inlet gas, Hr, Anderson: Now we would ask that Hr. Barn'ds~ qualifications be accepted in order that he may testify as an expert witness. -13- Mr. Burrell: Wlthout objection, we accept Mr. Barnd's qualiflcations as an expert wltness. Mr. Barnds: Thank you. Mr. Keller wlll follow along with part of the testimony wlth Unlon's Exhibit 8, a schematic flow dlagram of the East Side facl Ilty. My name Is Ray Barnds. I am DistriCt Production Superintendent for the Union 0II Company of California, Anchorage..Dlstrlct, Alaska. My purpose here today is to discuss the prob,lem of operatlng the dual marlne plpellne and the East Foreland Ilquld handling facllltles, which have n'ecessltated the f larlng of the depropanlzer overhead vapors at the Tradlng Bay Productlon Facl I I ry. As Mr. Roberts has testified, and Mr. James E. Church has previously testlfled durlng the May II, 1972 public hearing, the facllltles at the East Foreland marlne line termlnus were designed to handle potentlal con- densed Ilqulds In the marine pipelines at a controlled rate. Prevlous test- tlmony has established that these faci I itles were deslgned to operate during plpellne plgglng operations and during those tlmes that the Liquid ~: : E~t'ra'.ct~l, on Plant was bypassed or operatlng In an upset condition. The operating plan developed for which the facllltleS were designed was to pig any accumulated liquids out of the 16" West Side , onshore lines. These Ilqulds were to be pigged from the West Foreland production facl Ilty to Granite Point, at which point Instrumentation was Installed to divert Ilquids into one of the two marine pipelines. The liquid storage'capacity of each of the two marine lines Is In excess of 9,000 barrels. Each line therefore provides the needed liquid storage capacity for the liquid accmumlatlon resulting from as much as seven -14- days downtime at the LEX Plant to be removed from the 16" ~/est Side plpellne. Following removal of the Ilqulds from the 16" onshore line, the fluid diverting valve would open and ~he second of the no marine plpelines would return to normal gas delivery service. Referring to Exhlblt A, at this point in the liquid removal program It was planned to launch pipeline pigs at Granlte Point In the marine pipeline con- talnlng the liquid. The liquid would then be dlsplaced from the pipeline at a control led rate through the liquid recovery facl I ltles at the East Foreland Onshore Site. It should be noted that at thls polnt It was planned that one marlne line would be In gas service maintaining a constant flow of casinghead gas to the East Side delivery points. The second marine line flow controller governs the rate of liquid removal consistent with liquid levels in the condensate receiver. Free gas is separated In the receiver and put in the 16" East Side onshore Pipeline for delivery. Condensate from the receiver then flows through the 1~o stage flash Stablllzatlon equipment. Gas evolving from the stabill- zatlon process is recovered and put Into the I0" Iow pressure pipeline for use In the Collier Carbon and Chemical Plant fuel system. Any remalnlng ~ :, condensate Is collected In a condensate storage tank. These facilities , were designed to flash stabl I lze condensate from the ~ system at maximum dally rates In excess of 1,500 barrels per day. In actual practice, It has been demonstrated that the equipment performs slightly In excess of , rated designed parameters. During the past winter months, the Llquid Extraction Plant . has been ope~atlng as Indicated by Hr. Roberts, and liquids have been -15- condensing in the system at rates estimated to be In excess of 1,000 barrels per day. Operational problems, due primarily to the relatively large plpellne diameter in relationship to the caslnghead gas throughput, have resulted In dlfflcult in pipeline pigglng operations necessary to remove accumulated condensate Ilqulds. Due to the combined effects of relatively Iow velocitY and the fact that gas is used to dlsplace pipe- line plgs, considerable bypassing occurs during the plgging operation resulting In Inefficient liquid displacement. Hr. Roberts has explained the nature of the retrograde conden- satlon phenomena occurring In the pipeline system. Liquid has been conden- sing throughout the pipeline system as a result of. the physlcal nature of the plant residue gas. The condensed I iqulds arrive at the East Foreland facility in both pipelines as a result of slug flow rather than at a controlled rate through a single line. It is these condensate slugs.which presently hamper operation of the liquid handling facllltles at East Foreland. The reason for this Is~ lndivldual slugs of varying volume arrive at a velocity equivalent to a 75,000 barrel per day liquid throughput rate. In other- words, whlle the total condensation for a 24-hour day Is estimated to be slightly in excess of 1,000 barrels, It arrives In both pipelines In slugs which would have to be handled at rates of 75,000 .barrels per day to main- tain continuous gas delivery. These facllltles were not constructed for , this condition. It should be noted that had the exceedingly large facl Iit¥ required to handle these liquid slugs been Installed, the gas resulting ,, from flash stablllzlng Ilqulds would have evolved at a rate In excess of I10 million cubic feet per day. There Is no facility or consumer capable of beneflclally using a variable supply of high BTU gas peaking at the rate of I10,000 MCF per day for one hour or less. Accordingly, the facllitles, as previously testlfied, were designed and Installed to flash stablllze the plpellne condensate at a rate at which the flash gas could be utilized in the Collier Carbon and Chemical Plant for fuel in a recently modlfled plant system. The problem confronting the operators of the Cook Inlet Gas System at this time Is, therefore, to modify operations in such a manner that condensable vapors arrive at the East Foreland Faci Ilty at a rate at which they may be flash stablllzed and beneflclally utlllzed. The emergency pro- cedure of flaring the 2.5 million cublc feet per day of depropanizer overhead vapors resulted in our being able to utilize the balance of the caslnghead gas volume of 32.5 million cubic feet per day In a contin- uous manner whlle working on the development of a solution for handling the total stream. As a first step toward solvlng the problem, we have, within the past two Weeks, completed test modlflcatlons to the system at East Foreland. These changes have allowed us to elevate the pressure In the pipeline system. The pressure will be Increased In steps In an attempt to find a point at whlch the condensable liquids remain In the vapor state between the Trading Bay Production Facl I lty and the East Foreland marine I lne terminus, At East Foreland the pressure is belng reduced through a control valve In an attempt to condense Ilqulds in a continuous manner -17- directly proportional to the pipeline throughput, or, about 1,000 barrels per day for a throughput rate of 30 milllon cubic feet per day. The results of these modifications have not been evaluated as of this date. This Is due ,o the relatively short online time since establishing the new pressure base, and the fact that the gas composition has not been stabi I ized since re,urnlng the depropanlzer overhead vapors to the gas stream. Therefore, It Is not known at thls tlme whether or not the 2.5 million cubic feet per day of propane rich vapors can be handled In a manner enabling us to flash stabilize the condensate for fuel usage. Mr. Roberts will now dlscuss other steps being taken toward solving the problem. Mr. Anderson: Mr. Barnds, Is Union's Exhlblt ~A'~, was It prepared by you or under your supervision. Mr. Barnds: Yes It was. Mr. Anderson: We request that Union Exhibit ~'A~, be admitted in ev I dence. Mr. Burrell: WIll we again have a reduced copy? Mr. Anderson: Yes , Mr. Burrell: Which will be a duplicate? Mr. Anderson: . Yes, correct. Mr. Roberts will now testify con- cerning the various areas of study under consideration for solution of the prob leto. Mr. Roberts: Thank you. Mr. Barnds has described our current efforts to try to find a satisfactory operating procedure whereby the depropanizer overhead vapors continue to be Injected Into the pipeline system. The depropanl zer overhead vapors are golng Into the plpel Ine system now belng operated at ,he elevated pressure and to my knowledge at thls tlme no gas Is being flared from any facl Ilty other than that for safety pilot. Other possibllltles are belng considered for solvlng the liquid drop-out problem In the event operating the sys,em at higher pressure does no, offer a solution. One of these posslbllltles Is to reduce the volume of depropanl zer overhead which mus, be Injected Into the stream gol ng ,o the Cook Inle, Gas System. If we can develop asa, isfac,ory fuel sys,em whereby this propane enriched stream can be used for fuel In the crude ,reuters, a slgnlflcant reduction could be made in the volume remainlng for injectlon into the Cook inlet Gas System. We estimate ,ha, about I.I milllon cublc feet per day would be used if a reliable fuel sys,em can be developed. Hr. Gl Ibreth: ~/ha, was ,ha, again? Hr. Roberts: I.I. The questlon remalns - Is ,his sufflclent to ellmina,e the liquid drop-out problem? It cer,alnly would help and there- fore we are now discussing It wl,h equlpmen, manufac,ures, bo,h to determine the feasiblll,y and the ,ime required ,o deslgn, purchase, and Install the necessary facl Iltles. Another area under review Is ~o produce dry gas well gas from ,he Trading Bay Unit Platforms ,hrough ,hese gas handling faclll,les resul,lng In a dry residue gas s,ream going ,o the Cook Inle, Gas System. This would, of course, have the effec, of forclng the resldue gas to be more nearly like that contempla,ed under design condltlons and should help ,he liquid drop-ou, problem. Well capaclty and gas handllng equipment limitations on the platforms may limit the effectiveness of this possible sol uti on. -19- One other area which has been under study since early December Is the redesign of the turbo-expander for grea,er recovery eff lclency under actual flow rates. Whlle thls wlll have Ilttle effect on the propane content of the gas going to the Cook Inlet Gas System, It wlll remove more butanes and this will help lower ,he dewpolnt temperature of the residue gas. Actual test data was acquired late In December and transmltted to our englneerlng firm for redesign of the expander. A complete heat and material balance is curren, ly being calculated using the new test data after which the expander manufacturer can redesign his equipment. We expect the resul,s of ,his effort very shortly, and hopefully, modifications can be made th.Is spring. Again, I must reiterate that thls alone will no, be a complete solu,lon. In fact, the final solution could very well be a combination of some or all of the areas now under consid- eratlon, or new areas which may be developed. Any solu,lon will deflnltely requlre some modlflcatlon to our system. It Is difficult to estimate exactly the delivery time required for equipment, but past experience Indicates that several months are usually requlred even for relatively minor Items. In addltlon, we wlll qulte Ilkely require a good portion of the spring and summer construction season for the Instal latlon of the necessary equlpment. Although we are no, sure that the elevated pressure operation currently under test will result In a total solution during ,he cold months, we are hopeful that during the warmer months all or a portlon of the depropanl zer overhead vapors can be Injected in,O the stream going Into the Cook Inlet Gas System. -20- In order to provlde sufficient tlme to evaluate, deslgn, receive, and Install the possible needed facllltles to el lmlna,e the liquid drop-out problem occurring In the Cook Inlet Gas System, we will need permisslon to continm:...-., f lar,t'ng the depropanlzer overhead vapors, as necessary, until September I, 1973. Mr. Anderson: Mr. Chairman, that concludes part I of the hearing that was outlined to you previously, and I~m sure that these witnesses will be pleased to answer any questions that you may have. Mr. Burrell: Thank you, Mr. Anderson. Do you have any questlons at this tlme Mr. Marshall? Mr. Marshall: Well, I hate to ask this question because of, I~m not speaking from the posltlon of experience with underwater plpellnes. I just like to ask this naive question, If there Is any way of removing the condensed Ilqulds from the plpellne by a, or I guess you might call It a stinger or small in,ernal liquid line which would go Inside of the sub-marine plpellne and in effect siphon off the liquids from the Iow point In the line, if It would be anywhere near the onshore facllit~/? : In other words, If there Is a Iow part In the line could ,here be a, for Instance a reeled plastic stinger to go Into that line and remove the condensed liquid at the Iow spot, rather then a plggl, ng operatlon~. Is this, Is there any posslbllity of thls? Mr. Barnds: This has been discussed, the problem, the Iow point, the major Iow point In a pipeline Is about, ltd estimate 18 mi les from the place that we need to get the liquid to trea,ment. Mr. Marshall: It's on the wrong side, Isn't -2_1- Mr. Barnds: That's rlght. There are more than one Iow spots in the pipeline system, according to our profile, but we did talk about this and we prefer to remove liquid in a different manner than this particular one. Mr. Marshall: Thank you, Mr. Barnds. Mr. Burrell: I don't care who answer this, In fact I'm going to kind of make a statement wh~ich Includes a question probably. The intent Is to somewhat summarize. As i understand It this line dld not go into operation last summer, its been In operation durlng the wlnter season and there's been no summer experience with It at all. The condensation problem which has arisen comes about for atleast two reasons; one, cold weather; secondly, call It an error, ~f you will, In the estimate of the amount of drier gas from the Monopod which would be avallable to the system. The result of that belng that you have an excessive II~lu~d drop-out, which you are~unable to handle on the East Side and therefore had to f~are the propane depropanlzer overhead at approximately what rate, for what period of tlme? There Is a question mark there. Mr. Roberts: i believe we asked for permlsslon, or notified you that we had to go on emergency flare for a couple of days, In December at the rate of about two mill ion cubic feet per day for each of those days, and on January 22, as I recall, we asked again for permlsssion to, that was during the extreme cold, as you mlght recall. We asked for, informed you agaln of the emergency sltuatlon and that we were on flare with the propanlzer overhead vapors, which agaln amounted to about two mllllon cubic feet per day, 2.1 to be perclse. These were flared untll we modlfled the facilities at East Foreland, allowing us elevate the pressures, where once again It was our plan to put the depropanalzer overhead vapor back -22- into ~he system, which we dld. It was probably about a month, that time of flare of that depropanizer overhead.the second tlme lasted essentlally one month. Mr. Burrell: Thank you, Mr. Roberts. Did I state everything correctly as far as It went? Would you like to qualify what I sald? Mr. Roberts: Well, I don't want to present my testimony over again, but Mr. Burrell: Correct what I sald, please. Mr. Roberts: There were several things, those Items that you just mentioned certalnly are true and agaln I think, I think we place a lot of Importance on the fact that we are operating wlth a system in a range that leaves some question as to what data Is actual ly right In the area of equilibrium factors. We're In the, we're out near the crltlcal point. There has not been a whole lot of experimental data performed on a methane- propane system at 1200 pounds at 26 . There's just not too many systems like that around. Wlth that addition to your comment, ! thlnk I would say you pretty well phrased It. Mr. Burrell: You added one thing that essentially, that Is, It's a new system, it's a new type of system. There hasn't been much experience with this, essentlally. Mr. Roberts: Well, from an experimental standpoint, in trying to anticipate what will occur In advance of it actually belng placed in operation, which was our asslgnment to design a system, we used with the best data available to us and we still haven't discovered whether It was accurate or not, but we're, we have licked the problem. Mr. Burrell: Do you have four proposed solutions to this problem which you have testl fled to? -23- Mr. Roberts: We have four Mr. Burrell: At least four? Mr. Roberts' At least four, all of whlch are under study. Mr. Burrell' One of which Is actually operational, Increased pressure? Mr. Roberts: One Is, we are actually performing under one method of correction, yes. Mr. Burrell: Mr. Gllbreth? Mr. Gl Ibreth: Yes, I have some. I understand you are getting quite a few Ilqulds to the East Side and they're coming through in slug fashion more or less. Are these mostly propane? Are they all propane? Mr. Barnds: No, this ls a combination. The analysis I can't recall, ~ thlnk l,'s about 40 percent propane, the balance belng butanes or heavier hydrocarbons. Mr. Gl I breth: Is there any market or any use for this on the East S I de? Mr. Barnds: There, we are, yes, there is a market for lt. We are flash stabilizing the liquid through our system and putting In the 190 pound or 160 pound Iow pressure fuel system. Those flash vapors are then being burned In the Collier Plant, as fuel, In their.modified fuel system. Residue liquids are being delivered to the Tesoro Refinery, when we're able to and they'~a~e being utlllzed as boiler fuel stock. Mr. Roberts: Pardon me, Mr. Gi lbreth. I would llke to, I think, correct one statement there. If I may i'd like to refer to the analysis. I believe Ray Indicated that It was 40 percent propane wlth the rest being butanes and heavier. I think he meant to say, with the rest being ethane and lighter, with a very small amount of butane, it's about 33 percent me,bane, about 44 percent, pardon me. -24- Mr. Gl lbreth: Is It possible to install enough storage on the East Slde or enough equipment to take care of this slug capacity? Would It be possible to utilize the Ilqulds that are being dropped, or are these coming~ In such a volume that they couldn't be? Mr. Barnds- you're talking about the rate or the volume? Mr. Gl Ibreth: Yes. Mr. Barnds: Well, the volume Is 1000 barrels a day and we have no problem If we can take a I000 barrels per day at a control led rate through our flash stablllzatlon process and then in delivering gas volumes. Mr. Gl lbreth: Okay, you could use a 1000. Mr. Barnds: There's no problem with that. Mr. Gllbreth: Right. Mr. Barnds: The problem Is the rate at whlch they arrive as a result of slugs coming much as Ilquid flows through a soda straw. Mr. Gl lbreth: I see. I believe Mr. Barnds you testlfled that these are coming through at maybe a rate of 75,000 barrels per day? Mr. Barnds: Yes sir. Mr. Gl Ibreth: Does thls occur for, say, your whole slug to come through, or Is It while you're pigging. Is It Intermittent or Mr. Barnds: Well the problem is we don't have fluid arriving as ,, the result of pigging. We have it as a result of bypassing gas or on line, and these Iiquld slugs are, I sald they were typlcal, but they are of variable size. These flash recelvers, these condensate receivers, ;i have about a 25 barrel working capaclty. Now, at a 75,000 barrel per day rate you can recelve.ll,O00 barrels In something like 20 mlnutes. You can appreciate the problem when we get It, a slug of 500 barrels or 200 barrels -25- going into the condensate receiver. WI'th control valves, even snap acting control valves, we can't shut that thing down in tlme to catch and control the liquid flood Into one of the condensate receivers and flash the gas off. Even If we could do this, we~d have problems with carry over. What happens Is the level goes to the top of the receiver and we shut In the marlne line until that liquid Is able to go off through the faclllt¥, so wetre In a posltlon of Interrupting gas service, stopplng processing, opening up. Mr. Gllbreth: Durlng this time that you're swltchlng and so forth, are you just packlng your marlne line, the other line? Mr. Barnds: Yes, In the event, I should quallfy that, If both the marine lines have Ilquld arriving at the same time, and this does happen. Because of our - volume of the slug, capacity/ of the equipment we can't get liquid In both marine Ilnes at the faclll~/ at one tlme, In whlch case both lines are shut-In and then we pack the system. Mr..Gllbreth: I belleve Mr. Roberts, talking about your, the vapors from your depropanlzer that you have had to flare. ~ understand you to say that during that period of time these worked better and you experienced no problem, and I know that you have turned them In and out Intermittently. Do you have any guess as to just how much of the stream would be necessary to flare, to let you continue to operate, or Is It necessary to turn it out a hundred percent of the time? Now¥~ou'r call of hearing here doesn't give any idea, it just says flaring for operational necessity. I~m just wondering, does this just mean 50 percent of the tlme or i00 percent of the time or I0 percent of the time? -?_6- Mr. Roberts: Mr. Gilbreth, If our operating at the h. igher pressure range prove successful, we won't, we will not flare them again. Mr. Gllbreth: I reallze that, but now If I, doesn't, based on the experience you have now, what would 1, be necessary to flare? Mr. Roberts: If I, acts exactly the same way, we're kind of living on borrowed tlme to be putting the depropanl'zer overhead stream Into the pipeline system, knowing that we'll get by for a week or ten days and .. then have a massive problem on our hands,, requiring that we flare a full 35 million a day. So, ~ can't, J guess we haven't set down and really estimated how, how this wl II effect the overall amount, the total volume of gas that would be flared In each case, but ~ can assure you It would be much greater operating the way you suggested, than the way we're requesting. Mr. Gllbreth: The 2½ million a day that you have on the depropanlzer, Is It possible to turn just a certain portion of that Into the system, or do you have to turn it either all in or all out? Mr. Roberts: This Is one of the areas that we are going to be Invest- Igatlng, and as we Indicated one of our plans Is to, during the warmer months, divert as much of that depropanlzer overhead Into the system and we'll use that same logic too.';, If we have a problem with a hundred percent of the propane going Into the system we will certaln!y attempt to flnd , , out If we have a problem with nine percent going into the system, or 50 percent going Into the system and operate at the .level that we can flare less gas. Our intention, of course, ls to deliiver the maximum amount of gas to the East Side. I Mr. Gl Ibreth: You haven't had the tlme yet to arrive at anything I1 ke that? -27- Mr. Roberts: That is right, we're - we're of course very hopeful that we won't have to flare any more gas, but we just simply can't say that we won't have to. Mr. Gl Ibreth: Your gas, after It comes to the East Side, some of It goes on toward Swanson River. Is it possible that these liquids in anyway could move on down the line to Swanson Rl ver and be re lnjected there or does It go through the compressor station? Mr. Roberts: Contractually we're limited to no free liquids In the line going to Swanson River. Mr. Burrell: Excuse me, Mr. Gl Ibreth, If you'l I walt just a second, what~.. Is the mechanical problem? I understand the contractUal problem, but I don't understand the mechanlcal one, please explain why. Mr. Barnds: Mr. Keller, get up and we!Il go. through the flow. We're talking now In the event we have~..~a.:~,,tlquld carry-over? Mr. Butte I I: Yes. Mr. Barnds: A ilquld carry-over, If It did result, would go down the ,: 16 Inch pipeline to the KPL junction, and there we have a high pressure large volume scrubber Installed. This scrubber will then trap Ilqulds and al Iow the gas to 'flow into the Swanson RIver Fle!d through a control valve. The Ilqulds are dropped into the I0" Iow pressure gas line. They then run to the Col Iler Plant and are recovered In a serles of scrubber arrangements through the tank and then they're carried Into the liquid storage at that point, kind of similar to the Ilqulds at East Foreland. .. The reason for thls Is virtually that at both the Collier Plant and the Swanson River, Plant we're golng rlght to a samll capa~,t.~t~ scrubber into the field compressor, and they can't handle that gas. Mr. Burrell: The answer to the question Is the capacity doesn't consist In Swanson River to scrub out those liquids, is that right? -28- Mr. Barnds: Yes, well we have the capaclty Instal led at the KPL junction. Mr. Burrell: Yes, but you can't with the compressor you've got. At the moment the compressor can't handle that. Mr. Barnds: Yes, that's right. Mr. Burrell~ Thank you. Excuse me, Mr. Gilbreth, go ahead. Mr. Gilbreth~ I think that I can see why, but I'd llke to ask, why can't you restrict your production rates to minimize the problem? Mr. Roberts~ We can. Mr. Gilbreth~ Can you, can you restrict production rates ? Mr. Roberts~' Yes slr. Mr. Gl lb reth ~' By what? Mr. Roberts~ From about I10,000 barrels a day to about 30,000 barrels a day, so maybe a 1,000 barrels a day would have to be shut-in. Mr. Gllbreth: Or 2½ million cubic feet a day? Mr. Roberts~ Yes slr. Mr. Gilbreth: You mentioned, Mr~ Roberts, in your testimony, that fr~m your turblne expander you were't running at capaclty or needed more throughput all the way through. Is it possible to recycle any of the material that Is going through with your hlgh content without dropout? Mr. Barnds~' Yes' Mr. Gl lbreth, that Is, if you'll vlsuallze that a little bit, you'll see that you'll have a stream going around and around with the, with the same volume resulting going down the pipellne~ and still with ~the same amount of propane, that eventually has to get into that line. Mr. Gllbre~h~ I mlsunderstood, I thought you sald It would be more efficient and It would drop-out more If it were operating at more nearly des I gned capacl Mr. Roberts: That's, that's true but it follows a path, John, If you don't mind helplng me. Mr. Gilbreth: That leads Into my next question. Mr. Roberts: As we condense more in the expander it will fall out into that drum right there and be fed to the depropanlzer. The propane must go overhead and simply be added back Into the gas system. So If have the expander running at maximum efficiency, I still have propane. If you're referring to the comment made about butane, that Is true, we would remove the butanes, which Is only a very small amount of the total liquid condensation, and we think the proper way to s°lve that problem Is redesign of the expander, but we do not think It would affect the solution to the p rob I em. Mr. GI Ibreth: You've had thls problem now for a month, a month and a half? Mr. Roberts: Yes sir. Mr. (;I Ibreth: I know from contact you've made with the Committee that you have been looking at It for quite some time. Do you have any feel at all right now for the flinging that you're Iooklng at, for a solutiori:~? ~l~.:'know dep®nds .. on a lot of things, .What's your best guess right now as to when you wl II be able to solve this problem? Mr. Roberts: Well, th'at's, that's been Mr. GI Ibreth: I know you asked ti II September I, but think we'll have the solution to the type of procedure that we want to operate at, you know, how we want to operate the system, by late spring, but then to get the facl I ltles that are required to let us operate under that schedule, wlll require longer, more than tlkely longer than normal de IIvery times and then the time to lnsta I I them Is added into our estimate of September I. Mr. Gllbreth: Do you antlclpate that this problem wlll exist after the temperatures warm up? Mr. Roberts: We're very hopeful that they will not, but we have no assurance. One set of our data says that we will have. Mr. Gilbreth: I belleve you made the statement somewhere that you dld not expect temperature to drop below 26 degrees F. Are your lines hurled all the way? Mr. Roberts: Yes, on shore they are. Mr. Gilbreth: Yes, onshore I mean. Mr. Roberts: Yes. Mr. Gl Ibreth: Do you have any temperature profl les or measurements on the I lne to know what happen? Mr. Roberts? Wel I, we know that depending upon the ambient temperature being experienced at the time that we operate we have experienced some 26 degree temperatures both at Granite Point Junction and at, my under- . standing, at the East Foreland complex. Currently, "1 believe those temper- atures are about 30 degrees and 28 degrees, an additional two degree drop through the Inlet. Mr. Gllbreth: Did you testify, Mr. Roberts, that one of these posslbil- ltles was using, maybe, I.I mllllon a day for the treater? You did say that you did not know whether a portion of thls stream might be able to go in. You didn't have information on that, but might it not be possible that if you could use I.I million per day for the treaters, the remainder of the depropanizer could go into the system and not be any trouble? Mr. Roberts: Of course we can calculate again using the two correlations and we've done this.by removing a volume of depropanlzer overhead and then calculating the results of dewpoint, so the total residue stream, we find that It definitely helps, but that in case of the lower correlation we don't need any help and In the case of the higher correlation we still have a slight problem. This Is the reason I'm saying, that led me to the conclusion that It Is quite likely that it will be a combination. We'll take a little depropanizer overhead out, we might have to add a little dry gas, we'll operate at a slightly hlgher pressure. We'll do a combination: In my viewpoint at this very early date, It's qulte likely we'll do a comblnatlon of things to solve the problem. Hopefully by removing some depropanlzer overhead and operating at a higher pressure level we will not have a liquid problem year round and we'll not have to use dry gas. Mr. Marshall: I have a little problem with the use of words In your application. The real essence of what you're asking for Is that we add unto Rule 2 of Conservation Order 103 and 104, merely the Words: ~ or operatlonal necessity." Now I'd like to pose this questlon. Do you feel that this problem that we're looking at thls morning is baslcally a pipe- IIne shake-down problem? Mr. Roberts: I think it Is more extenslve than that, sir. Mr. Marshall: Do you look at it as a temporary problem resulting from a unforeseen Pipeline shake-down operations through extreme physical circumstance? is this basically what we're looking at? Mr. Roberts: We sort of think it is a temporary thing, or we would have asked for a much longer period than September I. We think It can -32- be solved, we think It was an undetermlnant problem at the time we were maklng the design. Mr. Marshall: Well then, then I, appears to me that, that rather then just operational necessity, which has no Implication at all of any sort of emergency situation, that what we're really looking at, I would like to think, in my mlnd, we're looking at an emergency operational necessl,y. The reason I'm suggestlng this, because just the word operational necessi,y Itself, has no Implication of any kind of time limit or any klnd of unusual circumstances. Operational necessity is, for Instance Its an operational necessity to store oil that you produce from o11 wel Is, until you can ship It. We we have used thls word operational necesslty In tlmes before we had our no-flare orders, that the flaring of caslnghead gas was an · operational necesslty. I think this 'Is a different kettle of fish we're talking about now and I look at an emergency as one where there's maybe human safe,y or operatlonal safety Involved and I really believe ,hat just the words operational necessity, don't glve us ,he real, true Plc,ure. I, myself, feel that you're In a more despara,e s,ral, than just a operational necessl,y. Thls ls, Is something ,ha, happened, ,hat was unforeseen, you .; certainly didn't design the pipeline to act thls way, It's something that . was an extremely complex problem. It developed there were hazards, and there were operational problems that fit Into this thing but basically we're not going to.have thls problem next summer because the bugs will be out of the system and I look at I, as a sort of a short term tt~Ing. Not necessarlly~just an operational necessity. It's more than that, it's ~omethlng th~t~was unforeseen and It Is, I thlnk, an emergency type of operational necessity. -33- Mr. Anderson: Mr. Marshall, If I may, when I set Out the order of the hearing, we are going to ask for an amendment of the rule to Include operational necessity based upon Items of equipment, maintenance and other items. The first part of the hearing has been concerned with the necessity of the continuing of the flaring of the depropanlzer overhead, on an emergency basis. I generally agree with your analysls of this situation .... The term emergency Is very difficult to deflne and of course invariably unfore- seeable ability Is often in the definition and sometimes It is not. Often times emergency Is called a pressing necessity or exigency, requiring Immediate action. And I think irrespective of the which definltlon you maybe 'use, you have a true emergency sltuatlon here because It was unforeseeable, although that may not always be an element. The companies did~not~",de~.l~gn the system not to work, so therefore it was unforeseeable. It certainly requires Immediate actlon, that's one of the reasons we're having the hearing today. The Other part of the Immediate action Is our urgent studies that are going on to solve the problem and of course, 'lastly, 'if you want to Incorporate the concept of pressing need, we certainly have a pressing need. So, therefore, our request Is couched In terms of emergency and we will also request amendment of the rule to recognl ze operatlonal necesslty based on the later testimony. Does that clarify? Mr. Marshall: Well, would you be in any way then modlfying your language that you composed In your application? Mr. Anderson: No sir, we would not. We would stlll retaln operational necessity.'fTh.~t,.,~wodilid be based on testimony yet to be presented. Mr. Marshall: Well, I'll save any further questlons till I hear further testimony, but as I said, I stlll have problems with the words just -34- operational necessity, because I believe that with just those words, some could say well, operational necessity is almost, you have to operate to produce oil or gas. Mr. Anderson: To make It clear, once more, in thls first part of this testimony we are not making this request on the basis of the amendment proposed, we are making It on the basls of emergency, That's for clarlflcatlon. Mr. Marshal I: Thank you. Mr. Burrell: Mr. Anderson, that helps a bit. As I understand Mr. Roberts's request was to be al lowed to flare the depropanlzer overhead ti I I September I, 1973 and that's not Included ln...the cai I of hearlng or your request then. This is the emergency situation which you addressed yourself to, with that In questlon, is that correct, sir? And that would be at the rate of 2 to 4 mi lllon a day, a maxlmum of 4, a mlnlmum of 2. Is that correct, sir? Mr. Roberts: Pardon me, that's the volume of the depropanlzer overhead and we mlght have to flare the total now, or we mlghf have to flare something less. We're only going to flare what Is necessary. Mr. Burre l I: I understand that. Mr. Roberts: Not to exceed the 4 mill Ion. Mr. Butte I I: Not to exceed ,4ii and~'::.l~.,t, ml ght be 2. Mr. Roberts: Yes. Mr. Burrell: Mlght even be less than 2. Mr.. Roberts: Yes. Mr. Burrell: ~f you can u,illze part of I, Mr. Rober,s: Yes sir. .: Mr. Burrell: What Is the total amount you're currently allowed to flare under Conserva,lon Order No~.'l14, a, the three platforms and the -35- West Foreland Productlon site? Mr. Roberts: As I recall, we're allowed to flare for' safety. Mr. Burrell: Excuse me, this Is the safety flare. Mr. Roberts: There is a safety pi lot for each flare boom on the three, on the four, platforms we're concerned with. It's I million for flare booms and on Klng Salmon It's 1.3, and we're al lowed 300,000 at the onshore facl I I ty. Mr. Burrell: What's that total? Mr. Roberts: Six, It's one, two, three, four, five, six, about 6.3 l.n the area. Mr. Burrell: Your al lowed to flare a total of 6.3, does that. Include the onshore production site too? Mr. Roberts: Yes, that's correct. Mr. Burrell: So, you're currently al lowed, for Safety flares, 6.3. You're proposing to .Increase that by some 40 percent maxlmum, to roughly ten or so, is that correct? You~'re asking to flare no more than 10.3 total, safety flare and depropanizer overhead at maximum flare, Is that correct? Mr. Roberts: Yes sir. Mr. Burrell: J just wanted to get some correlation between the numbers here. That would be you maximum request under this first part of the hearing for emergency situation? Mr. Roberts: Well, I hate to put it together, and that explains my --- Mr. Burrell: I'm trying to just draw some type of 'comparison between what you're currently al lowed to fiare for safety and:'how much more you're now asking for, -36- Mr. Burrell: Is that accurate for that purpose then? Mr. Anderson: Yes, and as long as Its clear that we're not requesting a tota I. Mr. Burrell: 6.3 you're currently allowed for safety flare? Your asking for a maximum of an addltlonal four million cubic feet per day? Mr. Anderson: Yes Mr. Burre ll: Of depropanlzer overhead ti Ii September I? Mr. Anderson: As I understand the testimony, hopefully it wlll be something substantlally less. · Mr. Roberts: We're gettlng Into sllghtly a difficult area and let me explain why. We're talking about an instance of an emergency situation that we're requesting some time to solve and we're adding numbers together. Thls Isn't to preclude the fact that other emergencies might not arise and that's the reason I hate .... Mr. Burrel I: Mr. Roberts, your request as I understood It, your emergency request, if you wlll, the first part of the hearing, was to flare a maximum of 4 million cubic feet per day from the depropanizer overhead. Is that right? Mr. Roberts: Right. Mr. Burrell: TIll September I. Mr. Roberts: Yes. Mr. Anderson: A point of verlflcatlon. I think 'the Committee recog- nizes that If other emergency situations came up not related to this problem, that then we would have to request additional authority if that were necessary. Mr. Burrell: Well, the existing order already provldes that you f late In the event of emergency. -37- Mr. Anderson: Yes. Mr. Burrell: Then our problem is to define emergency, and ! don't want to open that can of peaches. Mr. Gl Ibreth? Mr. Gllbreth: With regard to this depropanlzer volume that's being flared, Mr. Roberts. The safety, the volume that's already permit-fed for the safe~/ flare at the West Foreland facl Ilty. if it becomes necessary to turn the depropanlzer to flare, could any part of thls be preserved, the exlstlng amount belng flared. In other words If you have 300,000 a day to the flare now, and you're going to put another 4 million in there, or whatever it wlll be, is your piping and everythln9 such that you can shut off the first 300,0007 Mr. Roberts: Yes slr. Mr. Burrell: I think that covers the flrst part of the testimony. We'll take a fifteen minute meter - feeding break. Mr. Burrell: We'll reconvene the hearlng at this time. Mr. Anderson. Mr. Anderson: Yes. Mr. Burrell: We'll proceed with the second portion of this hearlng. Mr. Anderson: Yes, we will now have testimony presented by Mr. Ray Barnds, concernln9 the need to amend the rules to provide for relief In cases of operatlonal necesslfy occasioned by equipment malntanence and other instances. Mr. Barnds: Thank you. Mr. Burrell: Excuse me, before you go ahead, Mr. Barnds, would you run over that one more time slowly, what you just said, Mr. Anderson? Mr. Anderson: We will now deal with the testimony concerning the need to amend the rule, rules to Conservatlon Orders 103 and 104, to provide for relief under conditions of operational necessity occasioned by equipment ma lntenance or other Instances. -38- Mr. Burrell: Including the existing situation, for excluding the existing si tuation? Mr. Anderson~ We have framed this as excludlng the existing situa- tion, treating that as an emergency. Mr. Burrell: Thank you, that clarifies It very beautifully as to your intent. Mr. Barnds~ I wi II now discuss the amendment of Rule 2_ of both Con- servation Orders 103 and 104 to permit relief in cases of operational necess i ty. We are limited to the amount of redundancy we can build into our systems, especially on the offshore platforms, for space Is a design con- sideration. These systems and their components on the platforms and in the gas system require periodic planned preventative maintenance requiring temporary shutdowns. To IIlustrate, compressors require maintenance ranging from spark plug and lubricating oil changes to major overhauls. Newly installed systems require debugging and repeated shutdowns during initial startup to bring equipment on-line. Major install, at'l'~ns.,'..~s.uch~:as~:;the Trading Bay Production Facillty and Liquid Extracti~nt.~P.l'ant'i'requlre periodic plant turnarounds to depressure, purge, and inspect critical pressure vessels for safe operational reasons. I could continue with illustrative examples but in the interest of time, I will be happy to furnish a list of typical other Instances if you so request. This list will be lllustratlve only since there may be other cases which would constitute operational necessity. By amendment of Rule 2 of both Orders, thls periodic necessity will be recognized. As in the case of emergency we wi Ii propose to notify the Committee of any such occurrences within 96 hours after occurrence. I will be pleased to answer any questions which you may have. Thank you. -39- Mr. Burrell: Thank you, Mr. Barnds. Did you put a time limit on your 'Toperatlonal necessity arislng out of these types of circumstancesT'? Mr. Barnds: Well, we proposed to report them within 96 hours. Mr. Burrell: Then it could be, in theory at least, a continuing thing over the life of the field, as I understand from the way you phrased your req ues t? Mr. Barnds: Yes, a plant turn-around obviously could Involve weeks, whereas a compressor maintenance project chang lng spark plugs can consume an hour. Mr. Burrell: Do you have any thoughts on some type of restriction of time? What's the longest period of time you're going to be? Mr. Barnds: I haven't thought about the longest period of time. Examples of things of this nature - we've had a recent occurrence on the Monopod platform but I've had occasion to communicate with Mr. Gilbreth, relatlng to him the maintenance problems, with air problems that we're had. Each one of these things would have to be dealt with, I would Imaglne;~ on the situation at the time If It were a lengthy shut-down period. Certainly a plant turn-around Is pre-planned, but its at least a year in advance. Mr. Burrell: What would be the time that you would want to go to flare at the plant terminal? What would you anticipate you would need at the plant ferminal? Mr. Barnds: I might defer to Mr. Roberts. He might have an Idea. A plant turn-around, the ones that I've been involved in, these are not in the State of Alaska, can last for two months or tWo weeks depending on what the project Is. A turn-around is an all inclusive descriptlon. Mr. Burrell: Any addltlonal comments on that, Mr. Roberts? -40- Mr. Roberts: I might add this, that the type of equipment that we're looking at, and again we get Into the definition, I guess, but ! think If a turn-around or a preventative maintenance program exceeded ten days or two weeks, It would probably be because of an emergency situation. Mr. Burrel.l~ Thank you, Mr. Roberts. Are there any questions? Mr. Roberts~ I'11, let me say this, In that respect, the reason it would be strung out is that something that you didn't anticipate occured In your program. Inspecting your equipment you found the wal Is of the vessel exceedingly thin, and Instead of putting it back Into operation you now have something that you dldn't contemplate. Mr. Burrel I: An operational emergency, perhaps? Mr. Roberts: ~ don't want to leave the lmpresslon that ! think we're going to be turnlng the plant around that, that would last, you know, months or weeks. However to qualify them any d~fferently - the very next time we have one, something will occur that didn't we didn't contemplate. it's very difficult to .... Mr. Anderson~ Mr. Chairman, as t understand Mr. Roberts's testimony and Mr. Barnds's, the operational necessity would be a planned, predictable program whereby equipment would be examined, say In the turn-around situa- tion, and in the course of that examination a piece of equipment may be to the point where It needs complete replacement, perhaps, In which case this Is an unforeseen condition, originally, coming out of the operational necessity, so that you actually would be In an emergency situation under those condl tions, because you had not anti cl pated the equ i pment rep I ace- ment. Of course -41- Mr. Burrell~ Mr. Anderson, would it be fair to say then that you would commence a scheduled turn-around, say the last week. During that period while you flare, that would be operational necessity. If, during the course of that week you discover thln walls on some bol let or some- thing and it's going to be another week or month, then It becomes an emergency to swltch from one to another, is that as It appears? Mr. Anderson: That would be my understanding. Mr~ Burrell~ Mr. Gilbreth? Mr. Gi lbreth: Well, I don't know If I agree with that, to me you're in the buslness to produce oil and gas out here and you have equipment falling all the time. That's one of the hazards of the operation, and that's the purpose of your turn-around~ even If you do have a thin wall section. I don't think It's an emergency, as you. think. That's the purpose of It, but I'm just making a statement. This Periodic necessity that we're talking about~ ~ don't understand how it Could function as you proposed. I believe the wording that you proposed Is that the gas to be flared upon Committee approval could not be flared except ~S may be authorized by the Committee in case of emergency or operational necesslty. Do you intend by requesting this approval this way that you will get Committee approval everytlme that you want to shut-in a piece of equipment you're going to have to flare some gas on it as operational necessity? Are you golng to be down for a day inspecting something or something like that? Mr. AndersOn: That would be my understanding, that you would. Mr. Gl lbreth~ I'm having trouble in my own mind trying to decipher what we're trying to do here in terms of, you know, emergency and normal operating needs and how they would relate to the flaring of gas. Of course the Committee Is concerned about mlnlmlzlng gas flaring and I wonder If you could go on just a Ill-~le bit deeper, on what this operational necessity, under what conditions, how it will function. Mr. Roberts: Mr. Gl Ibreth, let me , may be perhaps I could ask a question. As the rules now read, we're not permitted to flare gas except the safety pilot or emergency situation? Mr. Gilbreth: Yes sir. Mr. Roberts: Alrlght, as operator we have a problem of saying we've got to shut-down the compressor to change a spark plug and Its that type of a example that we're saylng:,'¢an,.,:we call that an emergency, or do we have to shut-in the oli field while we're changlng the spark plug? And Its wording, some slmple word, phrase that would let us change the spark plugs, you know wlthout breaking the law? Mr. Gl Ibreth: Sure. Mr. Roberts: And that's our, that's our request In a nut shell. That's our need for having the words of that nature in there. Mr. Anderson: The wordlng is designed to differentiate between the two situations, emergency and operational necesslty. Mr. Burrell: And we'd like It very much If you would dlfferentlate, of course. Th at's our problem. Mr. Anderson: Well i'11 take a try here. An emergency sltuatlon, without being locked Into any definltlve term, ordinarily contemplates an unexpec~ed"':or sudden occurrence of an event which requires Immediate action. Alright, In the situation of the depropanlzer overhead vapor flaring request, this falls into that category, because of the sudden accumulation of the liquids In this line. It was unforeseeable, or unpredictable, thereby creating the emergency. As distinguished from that term, we know, -43- and as Mr. Gilbreth has pointed out, that the equlpment at the facllitles and on the platform Is golng to requlre periodic maintenance? That's the nature of the animal. To classify that instance as an emergency, It is somewhat difficult, because this Is a predictable, and not a pressing necessity, but its a routlne or normally predlctable necessity, whlch can be planned ahead, and that would be my distlnctlon If this helps the Corem i ttee. Mr. Marshall: Pardon me, if you had used up, I think we're all just groping with words now, and I think we have to grope with them, we've got to flnd the right word, the matters of repairs and malntenance. Do you think that this, these words cover what we're looking at? Operational necessities required by crltical repairs or maintenance, in other words puttlng In spark plugs is critical, you're not going to work without. It. Does thls language help you any, critical repair maintenance? Mr. Anderson: I confer here, but the only, I would, are you relating critical to maintenance, as well as to repairs? Mr. Marshall: ~t's critical as far as the operation goes. in other words, no spark plugs, its not going to work. However, shutting-down to paint the'cylinder block wouldn't fall in that category. I'm just trying to relate It to some requlred operation. ! use the word critical, meaning critical to the operation.~ Mr. Roberts: Either, either at that polnt in time, or will become critical If you don't do something about lt. Llke an oil change, you don't have, you don't have to shut-down to change the oil on that particular day, but If you don't change it, In a week from now It's going to fall apart. -44- Mr. Gl Ibreth: What, let me ask a questlon of Mr. Roberts, your normal maintenance shut-downs, ! know we've had some testimony in cases In the past, but I don't have any Information readily at hand here, but my recollection, if your normal maintenance shutdown in the past your'ye had up until now, perhaps less than 15 days per quarter, for normal maintenance and repalrs. ~s this about your experience? Mr. Roberts: i belleve you're referring, correct me if I'm wrong,'~'your referring to an order that al lows us to use gas well gas for lift and then f late 15 days per quarter. Mr. Gl Ibreth: I believe that was based on testimony that you presented showing that was your frequence, wasn't It? Mr. Roberts~ Well you see 15 days a quarter would allow us to take care of the emergency type situations, and would also al Iow us to take care of the lengthy turn-around sltuatlon If we could get our 15 days a quarter In the right part of the quarter. But It was for different purposes. It was relating Itself to gas well gas. Mr. Gilbreth: Yes, i realize that~ but I was saying, or trying to recall some of the testimony with regard to your shut-down and maintenance. i and so forth. Mr. Roberts.' Are you Mr. Gilbreth: Alright, let me ask this, Mr. Roberts: Well, let me ask this question first, Mr. Gi lbreth, If you don't mind. Are you asklng, can we plan routine maintenance to a period of days in a quarter? Mr. Gi Ibreth: No, that wasn't my question. I was trying to get some idea of how much time you're actual ly having the shut-down or repal.r for routlne maintenance. Are we talklng a 180 days a year, or one day a month, or what? i don't think the Committee would want to give you a blanket~ -45- say just any time you want to shut-down to do somethl.ng, you know. I was wondering what kind of volume. Mr. Roberts: Well, plugs, plugs sometlmes require a change once a month, and sometimes once a week. You get, sometlmes you get four plugs, I don't know how to answer your questlon, to be honest with you. Mr. Howard: Mr. Chairman, would you consider going off the record here for a minute to let us discuss thls thing. Mr. Burrell: Yes, we'll go off the record, Mr. Howard. Mr. Burrell: Back on the record. Does anybody have any additional questions of the witness? Mr. Anderson: That concludes that part of the testimony, Mr. Chairman. Mr. Burrell: Thank you, Mr. Anderson. Mr. Anderson: And If I may I'd like to wrap things up a blt. Mr. Burrell: Please do. Mr. Anderson: Gentlemen, you've heard the testimony here this morning and briefly summarized, Mr. Roberts testified as to the complexltles of the Marathon-Union system and this system was Installed at an expenditure of approximately 26 mllllon dollars. He also testlfled with respect to the problem of Ilquid accumulations In the system, that the system was designed with the greatest care and the best technology and judgment available, but in spite of this utmost care, this liquid accumulatlon problem has occurred creating a emergency situation which requlres immediate relief. I think It is particularly Important to stress the testimony of both witnesses, that out of a total approximately 35 million cubic feet per day of gas taken Into the system, under this proposal only approxlmately 2-" .2 million cubic feet per day would be flared, at least In the winter , , -46- months, till the problem can be solved and this, we're talking about the depropanizer overhead vapors. Mr. Barnds testified concerning the problems In connection with the submarine portions of the line, clearing the line of liquids and the handllng of liquid surge at the onshore facilities on the East Slde. You've also heard testimony concerning our plans and areas of study to solve the problem. Mr. Roberts testified, I believe, that In the course of these urgent and ongoing studies, other areas may be developed. Therefore, we request that the order which the Committee may enter allow the continued emergency flaring as necessary of the depropanlzer overhead vapors until September I, 1973. The testimony revealed that, hopefully, this entire period will not be required and that flaring will not be required at all tlmes. We wi'Il of course keep you fully advised of the progress of these studies and be pleased to furnish any specific Information, other specific information, whlch you may request. You've also heard testimony concernlng the need for relief in cases of operational necessity. In recognition of the probably future occurrence of these events, we request that Rules i and 2 be amended ... as set forth in the Notice of Hearings, so as to recognlze the matter of operatlonal necessity. Thank you. Mr. Burrell: Thank you Mr. Anderson. Is there anybody in the audience who has any questions, comments or chooses to make a statement or testify? Do you have any questions? Mr. Marshall: Just one further question of Mr. Anderson. J n your closing statement, I believe you did, In your final sentence, ask that Rule I and 2 be modified? -47- Mr. Anderson: That should be corrected, Mr. Marshall, If I did say that. Both Rules 2, Conservation Order 103 and 104. Mr. Marshall: Thank you. Mr. Burrel I: Any further questions, Mr. Reeder do you have any? Mr. Reede.r: No. Mr. Burrell: We'll go off the record here. Mr. Burrell: To get back to the record now, in view of the time problem here we've got to issue an order today. And the first portion of it, needless to say this will be smoothed up a bit, It was written rather hastily. The first portion of it deals with the Initial request with respect to the depropanizer overhead and that is as follows: '~Flaring and gas from the depropanlzer overhead as required to avoid condensation of excess liquids In the Cook Inlet Gas System, is hereby authorized until 7:00 AM, M~rch 24, 1973. "The. Commlttee may extend this authorlzatlon by Administratlve Order or orders but not beyond 7:00 AM September I, 1973. The second part deals with the written request to amend' Rule 2, and thls by the way, applies to both 103 and 104, both the Trading Bey Fleld and the McArthUr Fleld. The Order as requested will be granted, with the roi lOWing sentence added to It. "Any such flaring or ventlng of any gas In cases of operational necesslty, in excess of 15 days per calendar quarter per platform, other than that required for safety flares shall require committee approval. The Intent there is to this covers th'e same 15 days as currently permitted for flaring gas well gas In cases of operational necessity. The two periods are not cummulative. ~t's a maximum period of fiarlng any gas from any platform for 15 days per calendar quarter -48- without Committee approval. That's true whether Its flaring at the platform or at the Trading Bay Productlon Facl l ity. Are there any questions on that? We'll adjourn. -49- AFFIDAVIT OF PUBLICATION STATE OF ALASKA, THIRD JUDICIAL DISTRICT, ) ss. being first duly sworn on oath deposes a.nd says that .... ~.e. ...... is the ..... ~.e.g.a...1....C..Z...e.~ .... of the Anchorage News, a daily news- paper. That said newspaper has been approved as a legal news- paper by the Third Judicial Court, Anchorage, Alaska, and it is now and has been published in the English language continually as a daily newspaper in Anchorage, Alaska, and Jt Js now and during all of said time was printed in an office maintained at the aforesaid place of publication of said news- paper. That the annexed is a true copy of a ...~.:.e.~,l..~.o.t.~,c.e...~.195 as it was published in regular issues (and not in supplemet~tal form) of said newspaper for. a period of ...... .o.b.e. ...... insertions, commencing on the ..]:P. ...... day of ...... ~'.e. bz:uz~.~..,19.7-~., and ending on the ....... .]:3 ........ day of of .?].e...b.~..~..~. ............ , 19.Z~..., both dates inclusive, and that such newspaper was regularly distributed to its subscribers dur- ing all of sa,id period. That the full amount of the fee charged for the foregoing publication is the sum of $ 18.75 which amount has been paid in full at the rate of 25¢ per line; Mini- mum charge $7.50. SulSscribed a./fl sworn to before · 1~ "ebruary me this ........ day of .................... , 19.~.. Notary Public in and(,f't~r the State of Alaska, Third Division, Anchorage, Alaska MY CONtu~ISSION EXPIRES .... ........ ../.../....., NOTIOE OF 'PUBLIC HEARING STATE OF ALASKA DBp&Rll/~ENT OF NA't'URAL RESOURCES DIVISION OF OIL .~N',D GAS Alaska 0i'l and GaS Conservation .Committee 3001 Porct~pi,ne Drive ..' Anchorag,~,.. Alaska' 99501 Conser¥~tio0,,' Fi, le~?e. 120 ,. 'Re: The aPpliCation ~f 'lJnion 011' Corn- pa,ny of lC.~l:jf(i.Fnia for an emend- ment to I~bl~ No...2 .of Conserva- tion Order No. ,:.104 tO authorize the /0il. ,[ail~'' "Gas" Cortsel'vafio'~ ' ~.om.r~ltta~"i.to 'i.a~Jthorize flaring. or ~enti~i~il;.af...easing~head aas 'fromm, the ~,ff'hu,r: Ri'verReId in cases of .emergency' or opera,fi.on-' ' , · .. al necessity..'.' .' ' Notice. Is l~e~;eb.~,"'~:JVe" that .Union Oi,I ' company ' 0f 'Cali[0rn:ia O~ ~beh'a'l~ ' itself,, a'~d ~ath'~n~ oi,I :'Compa,n~ [ ' re~;uests that.',R~l~,;~'~[~' ;:~ "fh~e su~- ~ ie~oraer be',ame~d~t,m ~d a's fol. ~ A~S..T." N0ve~er~ ~,~' 1~2' the 'lIar' ~': ,,in~" ,or Venting ~""~es~nghea,d , , from:,}he,' ,,~,~th,~,"~War :FIeld, p~bt~ite'~?' e~c'ept J,O,r, the am ', ,neCe~Sa, ry for"a'~e%~te safety fl,a, res and,exC~f as ,may be autE°fl~ed ] ,, +h. cbm,~itfee'in'~,¢a'~es,of em'ergen. ' U,n~orseen °Pe~ating :eo,n,dlfl~nl due 're fhe, '~ense~i~n ~,,,'~~r~a'rb~n · ~IneJi~,e wh'i~ carri~,:'~as!nghea:d 'g~s, . ,Nikiski. arla.' ,hal ~ia,us~ 'Pres~u'r'e creases ~hi:h= ,muSt. be relieved./ / through, sa,feW vel~es", et. the West small partion'.~ fha ~otel. Wl6me ~: ~.;,, fl.are~":at'"".~est ~Forel~a,nd':;undetJ J 9,"197~" Altetn:~ives'~to fhis. proce- / adre ale actively bei.n.g investigate~':~ ' ': ' ': ' "~ ~"/ '~' ' 0 ~ ~he hearing~i'li be.:held at ~ .~.~M.~ Febru.a.rY 2~,' 1973~i~'~°em 101. J [. 'df' ..fhe c~m~unity: Ceq~e[ Building, ~.. 607 '. West~' eh.. Av~'ue;: .~An.ch.orage, /::'~.Al'aska,' ~' ~ich time the'operator J' 'jn.a effected. aha in.teres~ee p.erti~s/ ~ j. will be .heard. · '. " "~'~. ~.. ' ~homa. s R. E~ecufive Seo~eta,ty ~' P~ob.li'~b: February. 1~3, 1973 ~' Lega~l Notice No. 8195' NOT ICE OF PUBLIC HEARING STATE OF ALASKA DEPARTMENT OF NATURAL RESOURCES DIVISION OF OIL AND GAS Alaska Oil and Gas Conservation Committee 3001 Porcupine Drive Anchorage, Alaska, 99501 Conservation File No. 120 Re: The application of Union Oil Company of California for an amendment to Rule No. 2 of Conservation Order No. 104 to authorize the Oil and Gas Conservation Committee to authorize flaring or venting of casinghead gas from the McArthur River Field in cases of emergency or operational necessity. Notice is hereby given that Union Oil Company of California on behalf of itself and Marathon Oil Company requests that Rule No. 2 of the subject order be amended to read as follows: "Effective no later than 7:00 A.M., A.S.T., November I, 1972, the flaring or venting of casinghead gas from the McArthur River Field is prohibited, except for the amount necessary for adequate safety flares and except as may be authorized by the Committee in cases of emergency or ope rational necessity." Unforseen operating conditions due to the condensation of hydro- carbon gases in the newly constructed gas pipeline which carries casing- head gas from the West Foreland plant to the Nikiski area has caused pressure increases which must be relieved through safety valves at the West Foreland liquid extraction facility. To eliminate the source of these liquids thereby al lowing continuous gas flow in the system, a relatively small portion of the total volume is being flared at WeSt Foreland under an emer.§'ency order dated 'February 9, 1973. Alternatives to this procedure are actively being investigated. The hearing will be held at 9:30 A.M., February 23, 1973 in Room I01 of the Community Center Building, 607 West 6th Avenue, Anchorage, Alaska, at which time the operator and affected and interested parties will be Thomas R. Marshall, Jr. Execut i ve Secretary Publish: February 13; 1973 Robert T. Anderson District Land Manager Union Oil and Gas~ ',ision: Western Region Union Oil Company of California 909 W. 9th Avenue, Anchorage, Alaska 99501 Telephone: (907) 279-7681 February 8, 1973 unl nx" State of Alaska Oil and Gas Conservation Committee 3001 Porcupine Drive Anchorage, Alaska 99504 CONSERVATION ORDER 104 APPLICATION FOR AMENDMENT -O b~.dL vi: ---I'--~-'-E'N~ ..... I 3 ENG ....................... J 4 ENG · -l.-.~..kN.d ---)'q"'OF.0~' .... ...... j'-'~-'gEOL ...... J""~--~O~"- .... J___?Z , J DRAFT .... [.. .... SEC CONFER: Gentlemen: Pursuant to the 0il and Gas Conservation Regulations and applicable statutes of the State of Alaska, Union 0il Company of California, as Operator of the Trading Bay Unit, requests Rule 2 of the subject order as amended be further amended to read as follows: "Effective no later than 7:00 A.M., A.S.T., November 1, 1972, 'the flaring or venti.ng of casi.nghead gas from the McArthur River Field is prohibited, except for the amount necessary for adequate safety flares and except as may be authorized by the Committee in cases of emergency or operational necessity." Union and Marathon Oil Company independently constructed a 52 mile pipe- line system to transport excess casinghead gas from the subject field to the Nikiski area on the East Side of Cook Inlet. A highly complex hydrocarbon phase relationship exists in this casinghead gas. Research scientists have devised different methods of calculating the behavior of this type of gas. Design calculations originally used indicated gas in this system would remain gaseous. Actual operating experience, however, has shown hydrocarbon liquids condense in the pipeline system and settle in the low portions of the pipeline which effectively shuts off gas flow. When this occurs, pipeline pressures build up until the gas is relieved through safety valves at the West Foreland Plant. To eliminate the source of these liquids thereby allowi.ng continous gas flow in the system, a relatively small portion of the total volume must be flared at the West Foreland liquid extraction facility. This process has dried out the system and has allowed an uninterrupted flow of the remainder of the gas to Nikiski. Alternatives to this procedure are now being investigated. Due to the complexities involved, it is conceivable that more than one alternative will be implemented before the most effective solution to the problem is derived. In this event, it may. be operationally necessary to periodically flare gas in excess of the amount normally Oil and Gas Conservation Committee Conservation Order 104 -2- February 8, 1973 necessary for adequate safety ~:lares. The ~equested amendment ~ill al low t l~i s~. proces, s. It i~ respectfully requested that a hearing on thils matter be called for February 23, 1973. It is further requested in accordance with Section 20]2 of the Oil and Gas Conservation Regulations that a 15 day emergency order be issued for the flaring of gas at the West Foreland production facility servicing the McArthur River and Trading Bay Fields in excess of the amount necessary for an adequate sa'fety flare. Very. truly yours, UN ION OIL COMPANY OF CALIFORNIA Unit Operato,r ,
