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Home My WebLink AboutCO 341 AConservation Order Cover Page XHVZE This page is required for administrative purposes in managing the scanning process. It marks the extent of scanning and identifies certain actions that have been taken. Please insure that it retains it's current location in this file. ..~~ _~ Conservation Order Category Identifier Organizing RESCAN [] Color items: [] Grayscale items: [] Poor Quality Originals: [] Other: NOTES' DIGITAL DATA [] Diskettes, No. [] Other, No/Type OVERSIZED (Scannable with large plotter/scanner) [] Maps: [] Other items OVERSIZED (Not suitable for plotter/scanner, may work with 'log' scanner) [] Logs of variOus kinds [] Other ' BY: .... '~k,._ ROBIN2 MARIA Scanning Preparation TOTAL PAGES Production Scanning Stage I PAGE COUNT FROM SCANNED DOCUMENT: /.j~ , PAGE COUNT MATCHES NUMBER IN SCANNING PREPARATION: .... YES ~ NO BY: Stage 2 IF NO IN STAGE 1, PAGE(S) DISCREPANCIES WERE FOUND: yEs NO (SCANNING IS COMPLETE ~ POINT UNLESS SPECIAL ATTENTION IS REQUIRED ON AN INDIVIDUAL PAGE BASIS DUE TO QUALITY, GRAYSCALE OR COLOR IMAGES) General Notes or Comments about this Document: 5/21/03 ConservOrdCvrPg.wpd • • INDEX CONSERVATION ORDER NO. 341A 1.) February 28, 1997 BPX requests Waiver 2.) June 5, 1997 Letter from AOGCC denying Waiver Conservation Order No. 341A STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 3001 Porcupine Drive Anchorage Alaska 99501-3192 Re: CONSOLIDATION RULES ) PERTAINING TO THE PRUDHOE ) BAY FIELD, PRUDHOE OIL POOL ) Conservation Order No. 341A Prudhoe Bay Field Prudhoe Oil Pool October 2, 'i 995 IT' APPEARING T,HAT: 1. The Alaska Oil and Gas Conservation Commission issued 'Conservation Order (C.O.)363 revising Rule 5, Conservation Order 341 on September 29, 1995. Accordingly, the rules of C.O. 341, as modified, are reissued under C.O. 34 IA. .NOW, THiEREFORE, IT IS ORDERED THAT the rules hereinafter set forth apply to the following described area referred to in this order as the affected area: UMIAT MERIDIAN T. 10N.~ R. 12E., Sections: 1,2.,3,4,10,11, 12 T. 10N., R. 13E., 1,2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 24 T. 10N., R. 14E., 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 1.2, 13, 14, 15, 16, 117, '18, 19, 20, 2'I, 22, 23, 24, 25, 26, 27, 28, 36 T. 10N., R. 15E., all T. 10N., R. 16E., 5, 6, 7, 8, '!.7, 18, 19, 20, 29, 30, 31 T. IIiN., iR. liE., T. Il'N, R. 12E., '!,2,3,4,9, 10, all 11, 12, 13, 14, 115, 24, 25 T. ll'N., 'R. 13E., all T. llN., R. 14E., al! T. liN., R. 1517.;., all Conservation Ordei' ~41A Page 2 October 2, 1995 T. llN., R. 16E., 17,18,19,30,31,32 T. 12N., R. 10E., 13,24, T. 12N., R. liE., 15,16,17, 18, 19,20, 21, 22, 25, 26, 27, 28, 29, 30, 32,33,34,35,36 T. 12N., R. 12E., 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36 T. 12N., R. 13E., 19, 20, 21, 22, 23, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35,36 T. 12N., R. 14E., 25,26,27,28,29,31,32,33,34,35,36 T. 12N., R. 15E., 25, 26, 27, 28, 29, 30,31,32, 33, 34, 35, 36 (Source: C. O. 145, page 7, expansions/contractions of initial participating area based on November 20, 1987 letter, Wade and Nelson to Eason, Re: Prudhoe Bay Unit Exhibits, Exhibit C, Part l Oil Rim Participating Area and Part II Gas Cap Participating Area.) Rule I Pool Definition and Changing the Affected Are__g_a (ref. C.O. '145) (a) The .Prudhoe Oil Pool is defined as the accumulations of oil that are common to and which correlate With the accumulations found in the Atlantic .Richfield - Humble Prudhoe Bay State No. I well between the depths of 8,110 fi~et and 8,680 feet. (Source: C.O. 145, Rule '1) (b) The Commission may adjust the description of the affected area to conform to fhture changes in the initial participating area by administrative approval. (Source: C. O. 145, Rule 12) Rule 2 Well Spacing (ref. C.O. '145, 1.74) There shall be no restrictions as to well spacing except that no pay shall be opened in a well closer than 500 feet to the boundary of the affected area. (Source: C.O. 1.'74, Rule 2) Rule 3 Casing and Cementing Requirements (ref. C.O. 145, 238) (a) Conductor casing shall be set at least 75 feet below the surface and sufficient cement shall be used to fill the annulus behind the pipe to the surface. Rigid high density polyurethane tbam may be used as an alternate to cement, upon approval by the Commission. The Commission may also administratively approve other sealing materials upon application and presentation of data which show the alternate is appropriate based on accepted engineering principles. (Source: C.O. 238, Rule 3a) Conservation Order!~ o41A Page 3 October 2, 1995 (b) Surface casing to provide proper anchorage for equipment, to prevent uncontrolled flow, to withstand anticipated internal pressure, and to protect the well from the effects of permafrost thaw-subsidence or freeze-back loadings shall be set at least 500 feet, measured depth, below the base of the permafrost but not below 5000 feet true vertical depth. Sufficient cement shall be used to fill the annulus behind the casing to the surface. The surface casing shall have minimum axial strain properties of 0.5% in tension and 0.7% in compression. (Source: C.O. 238, Rule 3b) (c) Alternate casing programs may be administratively approved by the Commission upon application and presentation of data which show the alternatives are appropriate, based upon accepted engineering principles. (Source: C.O. 238, Rule 3c) Rule 4 Blowout Prevention Equipment and Practice (ref. C.O. 145) (a) The use of blowout prevention equipment shall be in accordance with good established practice and all equipment shall, be in good operating condition at all times. All blowout prevention equipment shall be adequately protected to ensure reliable operation under the existing weather conditions. All blowout prevention equipment shall be checked for satisfactory operation during each trip. (Source: C.O. 145, Rule 4a) (b) Before drilling below the conductor string, each well shall have installed at least one remotely controlled annular type blowout preventer and flow diverter system. The annular preventer installed on the conductor casing shall be utilized to permit the diversion of hydrocarbons and other fluids. This Iow pressure, high capacity diverter system shall be installed t.o provide at least the equivalent of a 6-inch line with at least two lines venting in different directions to insure downwind diversion and shall be designed to avoid freeze-up. These lines shall be equipped with full-opening butterfly type valves or other valves approved by the Commission. A schematic diagram, list of equipment, and operational 'procedure for the diverter system shall be submitted with the application Permit to Drill or Deepen (Form 10-401) for approval. The above requirements may be waived for subsequent wells drilled from a multiple drill site. (Source: C.O. 145, Rule 4b) (c) iBefore drilling below the surface casing all wells shall have three remotely controlled blowout preventers, including one equipped with pipe rams, one with blind rams and one annular type. The blowout preventers and associated equipment shall have 3000 psi working pressure and 6000 psi test pressure. (Source: C.O. 145, Rule 4c) (d) Before drilling into the Prudhoe Oil Pool, the blowout preventers and associated equipment required in (c) above shall have 5000 psi working pressure rating and 10,000 psi test pressure rating. (Source: C.O. !45, Rule 4d) Conservation Orde '[ ~41A Page 4 October 2, 1995 (e) The associated equipment shall include a drilling spool with minimum three-inch side outlets (if not on the blowout preventer body), a minimum three-inch choke manifold, or equivalent, and a fill-up line. The drilling string will contain full-opening valves above and immediately below the kelly during all circulating operations with the kelly. Two emergency valves with rotary subs for all connections in use will be conveniently located on the drilling floor. One valve will be an inside blowout preventer of the spring-loaded type. The second valve will be of the manually-operated ball type, or any other type which will perform the same function. (Source: C.O. 145, Rule 4e) (f) All ram-type blowout preventers, kelly valves, emergency valves and choke manifolds shall be tested to required working pressure when installed or changed and at least once each week thereafter. Annular preventers shall be tested to 50% recommended working pressure when installed and once each week thereafter. Test results shall be recorded on written daily records kept at the well. (Source: C.O. 145, Rule 40 Rule 5 Automatic Shut-in Equipment (ref. C.O. 145, 333,363) (a) Each well shall be equipped with a Commission approved tail-safe automatic surface safety valve system (SVS) capable of preventing uncontrolled flow by shutting off flow at the wellhead and shutting down any artificial lift system where an over pressure of equipment may occur. (b) The safety valve system (SVS) shall not be deactivated except during repairs, while engaged in active well work, or if the pad is manned. If the SVS cannot be returned to service within 24 hours, the well must be shut in at the well head and at the manifold building. 1. Wells with a deactivated SVS shall be identified by a sign on the wellhead stating that the SVS has been deactivated and the date it was deactivated. . A list of wells with the SVS deactivated, the dates and reasons for deactivating, and the estimated re-activation dates must be maintained current and available for Commission inspection on request. (c) A representative of the Commission will witness operation and performance tests at intervals and times as prescribed by the Commission to confirm that the SVS is in proper working condition. (d) The SVS must be maintained in working condition at all times unless the well is shut in and secured, or the well is being operated in conformance with other sections of this rule. (e) Upon proper application or its own motion, the Commission may administratively waive or amend the requirements of this rule as long as the change does not promote Conservation Order' 'o41A Page 5 October 2, 1995 waste, jeopardize correlative rights or compromise ultimate recovery, and is based on sound engineering principles. (f) Nothing in this rule precludes the installation of a SSSV in wells designated by the operator. If a SSSV is installed, it must be maintained in working order and is subject to performance testing as part of the SVS. Rule6 Pressure Surveys (ref. C.O. 145, 165, 192, 208, 213, 220, AA 220.1) (a) Prior to regular production, a static bottom hole or transient pressure survey shall be taken on each well. (Source: C.O. 220, Rule 1) (b) A minimum of 95 and 87 static bottomhole or transient pressure surveys shall be run annually in the Western Operating Area and Eastern Operating Area, respectively. These surveys are needed to effectively monitor reservoir pressure in the Prudhoe Oil Pool. The surveys required in (a) of this rule may be used to fulfill the minimum requirements. (Source: C.O. 220, Rule 6) (c) Data from the surveys required in (a) and (b) of this rule shall be filed with the Commission by'the last day of the month following the month in which each survey is taken. Form 10-412, Reservoir Pressure Report, shall be used to report the data from these surveys. Data submitted shall include rate, pressure, time, depths, temperature and any well condition necessary tbr the complete analysis of each survey. The datum for the pressure surveys is 8800 feet subsea. Transient pressure surveys obtained by a shut in buildup test, an injection well pressure fall-off test, a multi-rate test or an interference test are acceptable. Other quantitative methods may be administratively approved by the Commission. (Source: C.O. 220, Rule 7) (d) Results and data from any special reservoir pressure monitoring techniques, tests, or surveys shall also be submitted as prescribed in (c) of this rule, (Source: C.O. 220, Rule 8) (e) By administrative approval the Commission may grant time extensions and waive requirements of this rule, and by administrative order the Commission may require additional pressure surveys in (b) of this rule. (Source: C.O. 220, Rule 5) Rule 7 Gas-Oil Contact Monitoring (ref. C.O. '!45, 1165, 1.92, 208, 213, AA 213.39) (a) Prior to initial sustained production, a cased or open hole neutron log shall be run in each well. (Source: C.O. 165, Rule 9a) This requirement is waived for waterflood/EOR areas encompassed by the expanded Prudhoe Bay Miscible Gas Project outlined in C.O. 290, and for those areas not expected to have significant GOC movement or gas encroachment from the gravity drainage area defined by the Commission through Administrative Approval. (Source: AA 213.39, excerpts from paragraph 1) Conservation Order~' o41A Page 6 October 2, 1995 (b) A minimum of 40 repeat cased hole neutron log surveys shall be run annually. (Source: C.O. 208, Rule 4) (c) The neutron logs run on any well and those required in (a) and (b) of this rule shall be filed with the Commission by the last day of the month following the month in which the logs were run. (Source: C.O. 165, Rule 9d) (d) By administrative approval, the Commission may delay, modify or waive the logging requirements of this rule or may require additional wells to be logged. (Source: C.O. 213, Rule 3) Rule 8 Productivity Profiles (ref. C.O. 'i45, 165, 192, 208, 213, AA 213.40) (a) A spinner flow meter or tracer survey shall be run in each well during the first six months the well is on production. (Source: C.O. 165, Rule I la) This requirement is waived for wells completed with a single perforated interval, or with perforations in a single reservoir zone including highly deviated (greater than 65 degrees) and horizontal wells. (Source: AA 2'i3.40 paragraph 3) (b) Follow-up surveys shall be performed on a rotating basis so that a new production profile is obtained on each well periodically. Nonscheduled surveys shall be run in wells which experience an abrupt change in water cut, gas-oil ratio, or productivity. (Source: C.O. 1165, Rule llb) (c) The complete spinner flow meter or tracer data and results shall be recorded and filed with the Commission by the last day of the month following the month in which each survey is taken. (Source: C.O. 165, Rule 1 lc) (d) The Commission may administratively approve alternate methods and time periods in the enforcement of this rule provided that the data obtained is appropriate for monitoring the Prudhoe Oil Pool or may waive the requirements of (ia), (b) and (c). By administrative order the Commission may specify additional surveys other than the surveys submitted under (a), (b) and (c) of this rule. (Sources: C.O. 208, .Rule 8 and C.O. 213, Rule 2) Rule 9 Pool Off-Take Rates (ref. C.O. 145, 214) The maximum annual average oil offiake rate is 1.5 million barrels per day plus condensate production. The maximum annual average gas offiake rate is 2.7 billion standard cubic feet per day, which contemplates an annual average gas pipeline delivery sales rate of 2.0 billion standard cubic feet per day of pipeline quality gas when treating and transportation facilities are available. Daily offiake rates in excess of these amounts are permitted only as required to sustain these annual average rates. The annual average offiake rates as specified shall not be exceeded without the prior written approval of the Commission. Conservation Order' o41A Page 7 October 2, 1995 Annual average offiake rates mean the daily average rate calculated by dividing the total volume produced in a calendar year by the number of days in the year. However, in the first calendar year that large gas offiake rates are initiated, following the completion of a large gas sales pipeline, the annual average offiake rate for gas shall be determined by dividing the total volume of gas produced in the calendar year by the number of days remaining in the year following initial delivery to the large gas sales pipeline. Rule 10 Facility Gas Flaring (ref. C. O. 145, 145A, 197,219) (a) The venting or flaring of gas is prohibited except as may be authorized by the Commission in cases of emergency or operational necessity. However, upon application by the operators, the venting or flaring of gas may be authorized by the Commission to permit testing of wells in areas of the pool where access to pool gas gathering facilities is not prudent. (Source: C.O. 197) (b) The flaring of gas is approved to maintain safety flares and to permit purging of the gas handling equipment at the rates specified for the following facilities. The daily average rate shall be calculated on a monthly basis. Facility Approved Rate Gathering Center No. 1 Gathering Center No. 2 Gathering Center No. 3 Flow Station No. 1 Flow Station No. 2 Flow Station No. 3 Field Fuel Gas Unit & Central Compressor Plant Central Gas Facility (Source: C.O. 2 l 9, Rule 1 ) 1,100 MCF/D 1,100 iMCF/D 1,100 .MCF/D 1,000 'M CF/D 1,000 MCF/D 1,000 MCF/D '1,000 MCF/D 3,000 MCF/D (c) After the commencement of any flaring incident a.t any facility arising from an emergency or operational necessity, the Operator shall take the following action: . Initiate appropriate action and procedures so that flaring can be terminated as soon as reasonably possible arid the flaring can be minimized during the flaring period. 2. Production shall be curtailed to minimize flaring as soon as reasonably possible. (Source: C.O. 145A, Rule 2) (d) Flaring as a result of an emergency or operational necessity shall not be permitted longer than a total of twelve ('.12) hours after the commencement of each such incident without approval of the Commission or its designated representative. (Source: C.O. 145A, Rule 3) Conservation Order{'"'o41A Page 8 October 2, 1995 (e) Upon the request of the Operator to flare for more than a total of twelve (12) hours, a member of the Commission or its designated representative may verbally approve the request for a period not to exceed five (5) days beyond the twelve (12) hour period provided for in (d) above. The following information shall be given to the Commission or its designated representative upon request for such approval: (Source: C.O. 145A, Rule 4) 1. The facility at which the flaring is occurring. 2. Description of the flaring incident and cause. 3. Time of commencement. 4. Estimated time of termination. 5. Volume of gas flared. 6. Estimate of gas volume to be flared. 7. Action being taken to minimize and eliminate flaring. (f) A request in writing must be submitted by the Operator in order to obtain written administrative approval 'to flare beyond the period provided in (e) above. (Source: C.O. 145 A, Rule 5) (g) On a monthly basis the Operator shall sub,nit a written report to the Commission on all flaring incidents that result from an emergency or operational necessity. The report shall be due by the 20th day of the month following the reporting month. The report shall contain the fbllowing information for each flaring incident: 1. The facility at which the flaring occurred. 2. Time of commencelnent and termination of flaring. 3. Description of the flaring incident and cause 4. Volume of gas flared. 5. Action taken to eliminate the cause for the flaring incident. (Source: C.O. 145A, Rule 6) (h) Following a ten (10) day notice to the operator of any production facility the Commission may change the. volumes of gas allowed to be flared for safety. (Source: C.O. 145A, Rule 7) Conservation Order1 o41A Page 9 October 2, 1995 Rule 11 Annual Surveillance Reporting (ref. C.O. 165, 186, 195, 208, 223,224, 279, AA 279.1) (a) An annual Prudhoe Oil Pool surveillance report will be required by April 1 of each year. The report shall include but is not limited to the following: 1. Progress of enhanced recovery project(s) implementation and reservoir management summary including engineering and geotechnical parameters. . Voidage balance by month of produced fluids, oil, water and gas, and injected fluids, gas, water, low molecular weight hydrocarbons, and any other injected substances (which can be filed in lieu of monthly Forms 10-413 for each EOR project). (Source C.O. 279, Rule 7 and AA 279.1 excerpt from paragraph 3) 3. Analysis of reservoir pressure surveys within the field. 4. Results and where appropriate, analysis of production logging surveys, tracer surveys and observation well surveys. o Results of gas movement and gas-oil contact surveillance efforts, including a summary of wells surveyed and analysis of gas movement within the reservoir. The analysis shall include map(s) and/or tables showing the locations of various documented gas movement mechanisms as appropriate. (Source: C.O. 279, Rule 7) (b) Upon its.own motion or upon written request, the Commission may administratively amend this rule so long as the change does not promote waste nor jeopardize correlative rights and is based on sound engineering principles. (Source: C.O. 279, Rule 8) Rule 12 Prudhoe Bay Miscible Gas Project (PBMGP) (ref. C.O. 195, 290) (a) Expansion of the PBMGP and infill expansion of miscible gas injection in the 'NWFB is approved for the 59,740 acre portion of the Prudhoe Oil Pool defined in the record. (Source: C.O. 290, Rule 1, AA 290.1) (b) An annual report, must be submitted to the Commission detailing performance of the PBMGP and outlining compositional information for the current miscible injectant (MI) necessary to maintain miscibility under anticipated reservoir conditions. (Source: C.O. 290, Rule 2) (c) The operator will maintain a pressure differential of at least 250 psi between the minimum miscibility pressure (MMP) of the 'MI and the prevailing reservoir pressure at the time of injection. This differential is based on a projected prevailing reservoir Conservation Order" o41A Page 10 October 2, 1995 pressure decline of no more than 30 psi/year over the life of the project. (Source: C.O. 290, Rule 4) (d) The operators are directed to continue investigating options to mitigate pressure decline and to provide an annual progress report to the Commission. (Source: C.O. 290, Rule 5) (e) Upon its own motion or upon written request, the Commission may amend this rule by administrative action if the change does not promote waste, violate correlative rights, nor jeopardize ultimate recovery, and is based on sound engineering principles. (Source: C.O. 290, Rule 6) Rule 13 Waiver of GOR Limitation (ref. 8/22/86 letter) The Commission waives the requirements of 20 AAC 25.240(b) for all oil wells in the Prudhoe Oil Pool of the Prudhoe Bay Field so long as the gas from the wells is being returned to the pool, or so long as the additional recovery project is in operation. (Source: Letter 8/22/86, L. Smith to Heinze/Nelson, paragraph 3) Rule 14 Waiver of "Application lot"Sundry Approval" Requirement for Workover _O_perations (ref. C.O. 258) The requirements of 20 AAC 25.280(a) are waived fbr development wells in the 'Prudhoe Oil Pool of the Prudhoe iBay Field. (Source: C.O. 258) Rule 15 Waterflooding (ref. 3/20/81 letter Hamilton to Nelson/Norgaard) The co,nmission approves the December, 1980 additional recovery application for water- flooding in the Prudhoe Oil Pool subject to the requirements listed in Rule 11 above. Any proposed changes must be submitted to the Commission for approval. (Source: Letter 3/20/81, Hmnilton to Nelson/Norgaard) Rule 16 Orders Revoked The following Conservation Orders and associated Administrative Approvals and letter approvals are hereby revoked. Conservation orders 78, 83B, 85, 87, 88, 96, 97, 98B, 11.7, l17A, 1'18, 1.30, 137, 138, 139, 140, 141, 1143, 145, 145A, 148, 155, 160, 164, 165, 166, 167, 1169, 174, 178, 180, 181, 183, '184, 185, 186, 188, 189, 192, 194, 195, '195.1, '195.2, 195.4, 197, 199, 200, 204, 208, 213,214, 219, 220, 223,224, 238, 258, 259, 279, 290 and 333, and March 20, '1981 and August 22, 1986 letter approvals. The hearing records of these orders are made part of the record for this order. ,, Conservation Orde?o41A Page 11 October 2, 1995 DONE at Anchorage, Alaska and dated October 2, 1995. Dav,d"'""~' W. Johns-~on, .,C'l~rman Alaska Oi~ervation Commission Russell A. Douglass, Commissi?~er Alaska Oil and Gas Conservation Commission AS 31.05.080 provides that within 20 days oiler receipt of written notice of the entsy of an order, a person affected by it may tile with the Commission an application tbr rehearing. A request fbr rehearing nmst be received by 4:30 pm on the 23rd day fi~llowing the date of the order, or next working day ifa holiday or weekend, to be timely :filed. The Commission .shall ~an! or refuse the application in whole or in part within l0 days. The Commission can refuse an application by not acting on it within the 10-day period. An affected person has 30 days fi'om the date the c~,ommission relhses the application or mails (or otherwise distributes) an order upon rehearing, both being the final order of the Commission, to appeal the decismn to Superior Court. Where a request rehearing is denied by nonaction of the Commission, the 30 day period :[br appeal to Superior Court runs from lhe date on which the request is deemed denied (i.e., 10th day after the application fbr rehearing was filed). TONY KNOWLE$, GOVEFINOFt ALASI~& OIL AND GAS CONSERVATION COMMISSION 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 FAX: (907) 276-7542 June 5, 1997 Kenny Lang Manager, PBU Resource Management BP Exploration (Alaska) Inc. PO Box 196612 Anchorage, Alaska 99519-6612 Re' Automatic Surface Safety Valves on Prudhoe Bay WOA WAG Wells Dear Mr. Lang: The Commission has considered your February 28, 1997 letter requesting a waiver from Rule 5, Conservation Order 341A. We have analyzed the safety valve system curren, tly in use on the PBU WOA WAG wells and the testing of those wells while injecting miscible injectant (MI). The Commission finds that the system employed on these wells does not provide the same degree of assurance of automatically shutting-in an uncontrolled flow as would be obtained by full compliance with CO 341A, should a flow line break. Your request for a waiver from the requirements of Rule 5, Conservation Order 341A is hereby denied. The WAG wells on MI injection should be equipped with an automatic, pilot controlled surface safety valve within two weeks. Please prepare a schedule to bring the other WAG/MI wells into compliance. If you have questions, please call Blair Wondzell, senior petroleum engineer, at 279-1433. Chairff~,,~ Commissioner cc: Blair Wondzell l-bp-mi.svs BP EXPLORATION February 28, 1997 BP Exploration (Alaska) Inc. 900 East Benson Boulevard P.O. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 Mr. David Johnston State of Alaska Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501-3192 Subject: Automatic Surface Safety Valves on Prudhoe Bay WOA WAG Wells Dear Mr. Johnston: The AOGCC, in a letter dated December 11, 1996 from Mr. Blair Wondzell to Mr. Ross Warner of BPX, made clear that AOGCC regulations require automatic, pilot controlled surface safety valves in the Prudhoe Bay Western Operating Area's water-alternating-gas (WAG) wells. This ruling is appropriate for any well on miscible gas injection (MI) which has had its sub-surface safety valve (SSSV) removed. However, as BPX has no intention of permanently removing SSSVs from WAG wells, we would wish to pursue a waiver with respect to the amended CO 341, Rule 5. We ask that this waiver be granted on the basis that all wells on MI will continue to have a SSSV (check valve style) installed, and that the waiver allows BPX to continue operating with the surface safety valve system (SVS) currently installed on all WAG wells. Should BPX ever wish to remove the SSSV's'from the WAG wells, then we will consult with the AOGCC regarding any necessary changes to the surface safety valve system. If your technical staff have any questions regarding this request, then they should feel free to contact John Putnam or Tim Bradbury. Your consideration and approval of this request would be appreciated. Yours sincerely, Management c,t, Blair Wondzell - AOGCC John Putnam Tim Bradbury