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5/21/03 ConservOrdCvrPg.v,/pd
INDEX CONSERVATION ORDER NO. 458A
NORTHSTAR OIL POOL
1. September 30, 2002 BP's Northstar SSSV Setting Depth
2. October 5, 2002 Notice of Hearing, Publication, affidavit from newspaper,
copy of bulk mailing list and certificates of service
3. October 20, 2002 Request for a hearing
4. November 7, 2002 e -mail
5. November 7, 2002 Transcript
6. October 2003 Public Records Request
Conservation Order 458A
STATE OF ALASKA
ALASKA OIL AND GAS CONSERVATION COMMISSION
333 West 7th Avenue, Suite 100
Anchorage, Alaska 99501
Re: THE APPLICATION OF BP )
EXPLORATION (ALASKA) INC. )
for a variance from the subsurface )
safety valve (SSSV) setting depth )
requirements of 20 AAC 25.265(a)(2) )
in the Northstar Oil Pool, Northstar )
Field, Beaufort Sea, Alaska
Conservation Order No. 458A
Northstar Field
Northstar Oil Pool
November 20, 2002
IT APPEARING THAT:
By letter dated September 30, 2002, BP Exploration (Alaska) Inc. ("BPXA")
requested a variance from the setting depth requirements of 20 AAC 25.265(a)(2) for
subsurface safety valves ("SSSV"), in order to allow a SSSV setting depth to 500' in
Northstar wells.
2. Notice of opportunity for public hearing was published in the Anchorage Daily News
on October 5, 2002.
3. The Commission received a request for hearing on October 20, 2002.
.
A hearing concerning BPXA's request was convened in conformance with 20 AAC
25.540 at the Commission's offices, 333 West 7th Avenue, Suite 100, Anchorage,
Alaska 99501 on November 7, 2002.
FINDINGS:
1. BPXA is the designated operator of the Northstar Unit.
2. The Commission issued Conservation Order 458, dated October 9, 2001, to govern
development of the Northstar Oil Pool on the North Slope of Alaska.
o
20 AAC 25.265(a)(2) requires wells with offshore locations that are capable of
unassisted flow of hydrocarbons, be equipped with Commission approved fail-safe
automatic surface-controlled subsurface safety valves (SSSV) placed in the tubing
string and located below the permafrost.
4. Continuous permafrost exists below the Northstar development from approximately
1100 feet (') to 1600' below surface.
5. Wireline conveyed SSSVs require packing to provide a seal in their landing nipples.
Packing leaks necessitate SSSV retrieval, repair and replacement.
Conservation Order No?
November 20, 2002
oA Page 2
o
,
.
.
10.
11.
12.
Tubing conveyed SSSVs have the same inside diameter as tubing so valve retrieval is
unnecessary during well interventions such as perforating and production logging,
thus reducing the number of valve retrievals and replacement operations.
An SSSV setting depth shallower than the base of permafrost is necessary to ensure
operation of tubing conveyed SSSVs over the full range of expected conditions.
Northstar production casing is designed and pressure tested to withstand full shut in
tubing pressure. Annular fluid in inner annulus and outer annulus is diesel to below
the base of permafrost. Diesel will not freeze, expand and detrimentally affect
adjacent casing or tubing.
If a tubing conveyed SSSV fails, a wireline conveyed insert valve can be set inside
the tubing conveyed SSSV after the SSSV is locked open.
Installation of tubing conveyed SSSVs in nine Northstar wells is expected to decrease
by one per year the number of necessary well interventions.
The minimum SSSV opening pressure in the worst case late field life exceeds the
surface hydraulic system operating pressure of 6000 psi.
Current North Slope practice, including in the Northstar Field, is to use cement
formulated for permafrost conditions, appropriate casing grades and annular fluids to
alleviate concerns regarding casing failures in permafrost. (See Conservation Order
173,348).
CONCLUSIONS
1. Experience, proper well design and cementing have reduced any danger to casing
integrity from freeze-back or thaw subsidence effects within permafrost.
2. A 500' setting depth for tubing conveyed SSSVs at Northstar reduces the number of
well interventions and hence, reduces the risk of releases associated with work-over
operations.
3. A minimum 500' setting depth for SSSVs is adequate to prevent an uncontrolled
flOW.
NOW THEREFORE IT IS ORDERED that
1. Conservation Order 458 is amended to provide for a variance from the SSSV setting
depth requirements of 20 AAC 25.265(a)(2).
2. Conservation 458A supersedes Conservation Order 458 dated October 9, 2001.
3. The findings, conclusions and administrative record for Conservation Orders 458 are
adopted by reference and incorporated in this decision.
4. The following rules, in addition to statewide requirements under 20 AAC 25 (to the
extent not superseded by these rules), apply to the affected area encompassing all of
Conservation Order No.}
November 20, 2002
.,A Page 3
State Oil and Gas Leases ADL 312798, ADL 312799 and ADL 312808, portions of
State Oil and Gas Leases ADL 312809 and ADL 355001, and all of Federal Oil and
Gas Leases OCS-Y-1645, OCS-Y-0179 and OCS-Y-0181 to the extent such leases
are located within the lands described below:
Umiat Meridian
STATE LEASES
Township Range Sections
T14N R13E 30 through 35: All State lands
T13N R13E 2 through 18, 20 through 24: All State lands
T13N R14E 17 through 20, 29 and 30: AllStatelands
The affected area is more particularly described as follows:
ADL 312798
Consists of Tract C30-46 (BF-46), a portion of Blocks 470 and 514 as shown on the
"Leasing and Nomination Map" for the Federal/State Beaufort Sea Oil and Gas Lease
Sale, dated 1/30/79, more particularly described as follows:
Those lands located easterly of the west boundary of T. 13N, R. 13E, and T.14N, R. 13E,
Umiat Meridian, Alaska, being the north-south line intersecting the north and south
boundary of Block 470, within the offshore three-mile arc lines listed as State area of
Block 470 "Supplemental Official O.C.S. Block Diagram" approved 10/4/79, and those
lands in Block 514 easterly of the west boundary of T. 13N., R. 13E., Umiat Meridian,
Alaska (being identical with line 1-2 of Block 514) and lying northerly of the south
boundary of Sections 7 and 8, T.13N., R. 13.E, Umiat Meridian, Alaska (being identical
with line 2-3 of Block 514) and that portion of Section 16, T. 13N., R. 13E., Umiat
Meridian, Alaska, within the N1/2 S1/2 (being easterly of line 3-4 of Block 514), being a
portion of the listed State area of Block 514 on the "Supplemental Official O.C.S. Block
Diagram" approved 12/9/79.
ADL 312799
Consists of Tract C30-47 (BF-47), a portion of Blocks 471 and 515 as shown on the
"Leasing and Nomination map" for the Federal/State Beaufort Sea Oil and Gas Lease
Sale, dated 1/30/79, more particularly described as follows:
Those lands located in Block 471 within the offshore three-mile arc lines, listed as State
area on the "Supplemental Official O.C.S. Block Diagram", approved 10/4/79, and those
lands in N1/2, N1/2 S1/2 of Block 515 within the offshore three-mile arc lines being a
portion of the listed State area on the "Supplemental Official O.C.S. Block Diagram"
approved 10/4/79.
,,'
Conservation Order Noli
November 20, 2002
oA Page 4
ADL 312808
Consists of Tract C30-56 (BF-56), a portion of Blocks 514, 515, 558, and 559 as shown
on the "Leasing and Nomination Map" for the federal/state Beaufort Sea Oil and Gas
Lease Sale, dated 1/30/79, more particularly described as follows:
Those lands located in the S1/2 S1/2 of Block 514, within Section 16 and 21 of T. 13N.,
R. 13E.; Umiat Meridian, Alaska, (being those lands lying easterly of line 3-4 on Block
514), a portion of the state area on the "Supplemental Official O.C.S. Block Diagram"
approved 12/9/79, and those lands in S 1/2 S1/2 of Block 515, being a portion of the State
area on the "Supplemental Official O.C.S. Block Diagram" approved 10/4/79, and those
lands within Block 558 located in Section 21, T. 13N., R. 13E.; Umiat Meridian, Alaska,
(being the portion easterly of line 1-2 and northerly of line 2-3 block 558), listed as State
area on the "Supplemental Official O.C.S. Block Diagram" approved 12/9/79, and those
lands in Block 559 lying northerly of the south boundary of Sections 21, 22, 23, and 24,
T.13N., R. 13E.; Umiat Meridian, Alaska, (being the northerly portion of Block 559),
listed as State area on the "Supplemental Official O.C.S. Block Diagram" approved
10/4/79.
ADL 312809
Consists of Tract C30-57 (BF-57), a portion of Block 516 and 560 as shown on the
"Leasing and Nomination Map" for the Federal/State Beaufort Sea Oil and Gas Lease
Sale, dated 1/30/79, more particularly described as follows:
Those lands located in Block 516 within the offshore three-mile arc lines, listed as State
area on the "Supplemental Official O.C.S. Block Diagram" approved 10/4/79, containing
227.02 hectares, and those lands in Block 560 located within Section 24, T. 13N., R. 13E.,
Umiat Meridian, Alaska, and those lands in Block 560 located within Sections 19, 20, 29
and 30 of T13N, R14E, Umiat Meridian, Alaska, within the offshore three-mile arc lines,
listed as State area on the "Supplemental Official O.C.S. Block Diagram" approved
12/9/79.
ADL 355001
That portion of Blocks 514 and 558 as shown on the "Leasing and Nomination Map" for
the federal/state Beaufort Sea Oil and Gas Lease Sale, dated 1/30/79, more particularly
described as follows:
Those lands in Block 514 lying located within Sections 17, 18, and 20 ofT. 13N., R. 13E.,
Umiat Meridian, Alaska, and those lands located in Block 558 within Section 20, T. 13N.,
R. 13E., Umiat Meridian, Alaska.
FEDERAL LEASES
Lease Number Description
OCS-Y-1645 All Federal lands
OCS-Y-0179 All Federal lands
OCS-Y-0181 All Federal lands
Conservation Order No?._ oA
November 20, 2002
Page 5
The affected area is more particularly described as follows:
OCS-Y-1645
That portion of Block 6510, OCS Official Protraction Diagram NR06-03, Beechey Point,
approved February 01, 1996, shown as Federal 8(g) Area C on OCS Composite Block
Diagram dated April 24, 1996.
OCS-Y-0179
That portion of Block 470 lying east of the line marking the western boundary of parcel
"1" and between two lines bisecting Block 470, identified as parcel "1", containing
approximately 94.30 hectares, and parcel "2", containing approximately 15.27 hectares,
as shown on the Supplemental Official OCS Block Diagram, dated 10/4/79, based on
Official Protraction Diagram NR 6-3, Beechey Point, approved April 29, 1975; and that
area lying between the two lines bisecting Block 471, containing approximately 611.95
hectares, as shown on the Supplemental Official OCS Block Diagram, dated 10/4/79,
based on Official Protraction Diagram NR 6-3, Beechey Point, approved April 29, 1975;
and that area lying northeasterly of the line bisecting Block 515, containing
approximately 189.83 hectares, as shown on the Supplemental Official OCS Block
Diagram, dated 10/4/79, based on Official Protraction Diagram NR 6-3, Beechey Point,
approved April 29, 1975.
OCS-Y-0181
That area lying northeasterly of the line bisecting Block 516, containing approximately
2076.98 hectares, as shown on the Supplemental Official OCS Block Diagram, dated
10/4/79, based on Official Protraction Diagram NR 6-3, Beechey Point, approved April
29, 1975; and that area lying northeasterly of the line bisecting Block 560, located in the
northeast comer of Block 560, containing approximately 44.65 hectares, as shown on the
Supplemental Official OCS Block Diagram, revised and dated 12/9/79 based on Official
Protraction Diagram NR 6-3, Beechey Point, approved April 29, 1975.
Pool Name~ Definition~ and Classification
The Northstar Oil Pool is defined as the accumulation of hydrocarbons common to and
correlating with the interval between measured depths of 12,418 feet and 13,044 feet the
Seal A-01 well. The Northstar Oil Pool is classified as an oil pool.
Rule 1: Field Name
The field overlying the Northstar Oil Pool is the Northstar Oil Field.
Rule 2: Well Spacing
Minimum spacing within the pool is 40 acres. The pool shall not be opened in any well
closer than 500 feet to an external unit boundary where ownership changes.
Conservation Order No.{
November 20, 2002
oA Page 6
Rule 3: Drilling and Completion Practices
Alternative completions will be authorized on a case by case basis so long as the
requirements of 20 AAC 25.030(a) are met.
Rule 4: Safety Valve System Equipment and Performance Testing Requirements
1. With the exception of the Class I disposal well, each well must be equipped with a
Commission approved fail-safe automatic SSV system capable of preventing an
uncontrolled flow and fail-safe automatic surface controlled SSSV system capable of
preventing an uncontrolled flow, unless another type of subsurface valve with that
capability is approved by the Commission.
2. The SSV and SSSV systems and the individual components of the SSV and SSSV
systems must be maintained in proper working condition at all times unless the well is
shut in and secured.
3. Operation and performance tests must be conducted at intervals and times as
prescribed by the Commission to confirm that the SSV system, SSSV system, and
associated equipment are in proper working condition. At least 24 hours notice must
be given prior to the performance of a test to allow a representative of the
Commission to witness the test.
4. The minimum setting depth for tubing conveyed SSSVs is 500 feet.
Rule 5: ReservOir Pressure Management and Monitoring
1. Prior to placing each well on regular production or injection, an initial pressure
survey must be obtained.
2. Bottom-hole pressure surveys must be acquired in at least one-half the active wells
each year. Bottom-hole surveys in paragraph (a) may fulfill the minimum
requirement.
3. The reservoir pressure datum will be 11,100 feet TVDss.
4. Pressure surveys may be stabilized static pressure measurements at bottom-hole or
extrapolated from surface (single phase fluid conditions), pressure fall-off, pressure
buildup, multi-rate tests, drill stem tests, and open-hole formation tests.
5. Data and results from all relevant reservoir pressure surveys must be reported
quarterly on Form 10-412, Reservoir Pressure Report. All data necessary for analysis
of each survey need not be submitted with the Form 10-412, but must be available to
the Commission upon request.
6. Results and data from special reservoir pressure monitoring tests or surveys must also
be submitted in accordance with paragraph (e) of this rule.
Rule 6: Gas-Oil Ratio Exemption
Wells producing from the Northstar Oil Pool are exempt from the gas-oil-ratio limits of
Conservation Order
November 20, 2002
oA Page 7
20 AAC 25.240(a) so long as requirements of 20 AAC 25.240(b) are met.
Rule 7: Annual Reservoir Performance Report
The first operations and reservoir performance report will be due April 1, 2002 and
annually thereafter. The report shall include, but is not limited to, the following:
a. Progress of enhanced recovery project implementation and reservoir management
summary including results of reservoir simulation techniques.
b. Voidage balance by month of produced fluids and injected fluids and cumulative
status for each producing interval.
c. Summary and analysis of reservoir pressure surveys within the pool.
d. Results and, where appropriate, analysis of production and injection log surveys,
tracer surveys, observation well surveys, and any other special monitoring.
e. Review of pool production allocation factors and issues over the prior year.
f. Future development plans.
g. Review of Annual Plan of Operations and Development.
Rule 8: Administrative Action
Unless notice and public hearing is otherwise required, the Commission may
administratively waive the requirements of any rule stated above or administratively
amend any rule as long as the change does not promote waste or jeopardize correlative
rights, is based on sound engineering and geoscience principles and will not result in an
increased risk of fluid movement into freshwater.
DONE at Anchorage, Alaska and dated November 20, 2002.
Daniel T. Seamount, Jr., Commissioner
Alaska Oil and Gas Conservation Commission
Michael L. Bill, Commissioner
Alaska Oil and Gas Conservation Commission
AS 31.05.080 provides that within 20 days after receipt of written notice of the entry of an order, a person affected by it may file
with the Commission an application for reheating. A request for rehearing must be received by 4:30 PM on the 23rd day following
the date of the order, or next working day if a holiday or weekend, to be timely filed. The Commission shall grant or refuse the
application in whole or in part within 10 days. The Commission can refuse an application by not acting on it within the 10-day
period. An affected person has 30 days from the date the Commission refuses the application or mails (or otherwise distributes) an
order upon rehearing, both being the final order of the Commission, to appeal the decision to Superior Court. Where a request for
rehearing is denied by nonaction of the Commission, the 30-day period for appeal to Superior Court runs from the date on which
the request is deemed denied (i.e., l0th day after the application for rehearing was filed).
John Katz
State of Alaska
Alaska Governor's Office
444 North Capitol St., NW, Ste 336
Washington, DC 20001
Daniel Donkel
2121 North Bayshore Drive, Ste 1219
Miami, FL 33137
SD Dept of Env & Natural Resources
Oil and Gas Program
2050 West Main, Ste 1
Rapid City, SD 57702
Alfred James
107 North Market Street, Ste 1000
Wichita, KS 67202-1822
Christine Hansen
Interstate Oil & Gas Compact Comm
Excutive Director
PO Box 53127
Oklahoma City, OK 73152
Citgo Petroleum Corporation
PO Box 3758
Tulsa, OK 74136
Conoco Inc.
PO Box 1267
Ponca City, OK
74602-1267
Mir Yousufuddin
US Department of Energy
Energy Information Administration
1999 Bryan Street, Ste 1110
Dallas, TX 75201-6801
Mary Jones
XTO Energy, Inc.
Cartography
810 Houston Street, Ste 2000
Ft. Worth, TX 76102-6298
Gregg Nady
Shell E&P Company
Onshore Exploration & Development
PO Box 576
Houston, TX 77001-0576
Michael Nelson
Purvin Gertz, Inc.
Library
600 Travis, Ste 2150
Houston, TX 77002
Paul Walker
Chevron
1301 McKinney, Rm 1750
Houston, TX 77010
G. Scott Pfoff
Aurora Gas, LLC
10333 Richmond Ave, Ste 710
Houston, TX 77042
G. Havran
Gaffney, Cline & Associations
Library
1360 Post Oak Blvd., Ste 2500
Houston, TX 77056
David McCaleb
IHS Energy Group
GEPS
5333 Westheimer, Ste 100
Houston, TX 77056
William Holton, Jr.
Marathon Oil Company
Law Department
5555 San Fecipe St.
Houston, TX 77056-2799
T.E. Alford
ExxonMobil Exploration Company
PO Box 4778
Houston, TX 77210-4778
Texico Exploration & Production
PO Box 36366
Houston, TX 77236
Corry Woolington
ChevronTexaco
Land-Alaska
PO Box 36366
Houston, TX 77236
W. Allen Huckabay
Phillips Petroleum Company
Exploration Department
PO Box 1967
Houston, TX 77251
Chevron USA
Alaska Division
PO Box 1635
Houston, TX 77251
Donna Williams
World Oil
Statistics Editor
PO Box 2608
Houston, TX 77252
Chevron Chemical Company
Library
PO Box 2100
Houston, TX 77252-9987
Shelia McNulty
Financial Times
PO Box 25089
Houston, TX 77265-5089
Shawn Sutherland
Unocal
Revenue Accounting
14141 Southwest Freeway
Sugar Land, TX 77478
Kelly Valadez
Tesoro Refining and Marketing Co.
Supply & Distribution
300 Concord Plaza Drive
San Antonio, TX 78216
James White
Intrepid Prod. Co./Alaskan Crude
4614 Bohill
SanAntonio, TX 78217
Doug Schultze
XTO Energy Inc.
3000 North Garfield, Ste 175
Midland, TX 79705
Robert Gravely
7681 South Kit Carson Drive
Littleton, CO 80122
George Vaught, Jr.
PO Box 13557
Denver, CO 80201-3557
Jerry Hodgden
Hodgden Oil Company
408 18th Street
Golden, CO 80401-2433
Richard Neahdng
NRG Associates
President
PO Box 1655
Colorado Springs, CO
80901
John F. Bergquist
Babson and Sheppard
PO Box 8279
Long Beach, CA 90808-0279
John Levorsen
200 North 3~ Street, #1202
Boise, ID 83702
Samuel Van Vac~r
Economiclnsightlnc.
3004 SWFirst Ave.
Portland, OR 97201
Kay Munger
Munger Oilln~rmation Se~ice, lnc
PO Box 45738
Los Angeles, CA 90045-0738
Thor Cutler OW-137
US EPA egion 10
1200 Sixth Ave.
Seattle, WA 98101
Michael Parks
Marple's Business Newsletter
117 West Mercer St, Ste 200
Seattle, WA 98119-3960
Jim Arlington
Forest Oil
310 K Street, Ste 700
Anchorage, AK 99501
Julie Houle
State of Alaskan DNR
Div of Oil & Gas, Resource Eval.
550 West 7th Ave., Ste 800
Anchorage, AK 99501
Susan Hill
State of Alaska, ADEC
EH
555 Cordova Street
Anchorage, AK 99501
Mark Wedman
Halliburton
6900 Arctic Blvd.
Anchorage, AK 99502
Rob Crotty
C/O CH2M HILL
301 West Nothern Lights Blvd
Anchorage, AK 99503
Tim Ryherd
State of Alaska
Department of Natural Resources
550 West 7th Ave., Ste 800
Anchorage, AK 99501
Duane Vaagen
Fairweather
715 L Street, Ste 7
Anchorage, AK 99501
Cammy Taylor
1333 West 11th Ave.
Anchorage, AK 99501
Ed Jones
Aurora Gas, LLC
Vice President
1029 West 3rd Ave., Ste 220
Anchorage, AK 99501
John Harris
NI Energy Development
Tubular
3301 C Street, Ste 208
Anchorage, AK 99503
Schlumberger
Drilling and Measurements
3940 Arctic Blvd., Ste 300
Anchorage, AK 99503
Richard Mount
State of Alaska
Department of Revenue
500 West 7th Ave., Ste 500
Anchorage, AK 99501
Williams VanDyke
State of Alaska
Department of Natural Resources
550 West 7th Ave., Ste 800
Anchorage, AK 99501
Robert Mintz
State of Alaska
Department of Law
1031 West 4th Ave., Ste 200
Anchorage, AK 99501
Trustees for Alaska
1026 West 4th Ave., Ste 201
Anchorage, AK 99501-1980
Ciri
Land Department
PO Box 93330
Anchorage, AK
99503
Mark Dalton
HDR Alaska
2525 C Street, Ste 305
Anchorage, AK 99503
Jack Laasch
Natchiq
Vice President Government Affairs
3900 C Street, Ste 701
Anchorage, AK 99503
Baker Oil Tools
4730 Business Park Blvd., #44
Anchorage, AK 99503
Mark Hanley
Anadarko
3201C Street, Ste 603
Anchorage, AK 99503
Judy Brady
Alaska Oil & Gas Associates
121 West Fireweed Lane, Ste 207
Anchorage, AK 99503-2035
Aden Ehm
2420 Foxhall Dr.
Anchorage, AK 99504-3342
Greg Noble
Bureau of Land Management
Energy and Minerals
6881 Abbott Loop Rd
Anchorage, AK 99507
Rose Ragsdale
Rose Ragsdale & Associates
3320 E. 41st Ave
Anchorage, AK 99508
Thomas R. Marshall, Jr.
1569 Birchwood Street
Anchorage, AK 99508
Jeff Walker
US Minerals Management Service
Regional Supervisor
949 East 36th Ave., Ste 308
Anchorage, AK 99508
Paul L. Craig
Trading Bay Energy Corp
5432 East Northern Lights, Ste 610
Anchorage, AK 99508
Jill Schneider
US Geological Survey
4200 University Dr.
Anchorage, AK 99508
Jim Scherr
US Minerals Management Service
Resource Evaluation
949 East 36th Ave., Ste 308
Anchorage, AK 99508
Richard Prentki
US Minerals Management Service
949 East 36th Ave., 3rd Floor
Anchorage, AK 99508
Chuck O'Donnell
Veco Alaska,Inc.
949 East 36th Ave., Ste 500
Anchorage, AK 99508
Gordon Severson
3201 Westmar Cr.
Anchorage, AK 99508-4336
Jim Ruud
Phillips Alaska, Inc.
Land Department
PO Box 100360
Anchorage, AK 99510
Kristen Nelson
IHS Energy
PO Box 102278
Anchorage, AK 99510-2278
Perry Markley
Alyeska Pipeline Service Company
Oil Movements Department
1835 So. Bragaw- MS 575
Anchorage, AK 99515
Jordan Jacobsen
Alyeska Pipeline Service Company
Law Department
1835 So. Bragaw
Anchorage, AK 99515
Robert Britch, PE
Northern Consulting Group
2454 Telequana Dr.
Anchorage, AK 99517
David Cusato
600 West 76th Ave., #508
Anchorage, AK 99518
Jeanne Dickey
BP Exploration (Alaska), Inc.
Legal Department
PO Box 196612
Anchorage, AK 99518
Tesoro Alaska Company
PO Box 196272
Anchorage, AK 99519
J. Brock Riddle
Marathon Oil Company
Land Department
PO Box 196168
Anchorage, AK 99519-6168
Kevin Tabler
Unocal
PO Box 196247
Anchorage, AK 99519-6247
Sue Miller
BP Exploration (Alaska), Inc.
PO Box 196612
Anchorage, AK 99519-6612
BP Exploration (Alaska), Inc.
Land Manager
PO Box 196612
Anchorage, AK 99519-6612
Dudley Platt
D.A. Platt & Associates
9852 Little Diomede Cr.
Eagle River, AK 99577
Bob Shavelson
Cook Inlet Keeper
PO Box 3269
Homer, AK 99603
Shannon Donnelly
Phillips Alaska, Inc.
HEST-Enviromental
PO Box 66
Kenai, AK 99611
Peter McKay
55441 Chinook Rd
Kenai, AK 99611
Kenai Peninsula Borough
Economic Development Distr
14896 Kenai Spur Hwy #103A
Kenai, AK 99611-7000
Penny Vadla
Box 467
Ninilchik, AK
99639
James Gibbs
PO Box 1597
Soldotna, AK
99669
Claire Caldes
US Fish & Wildlife Service
Kenai Refuge
PO Box 2139
Soldotna, AK 99669
Kenai National Wildlife Refuge
Refuge Manager
PO Box 2139
Soldotna, AK 99669-2139
John Tanigawa
Evergreen Well Service Company
PO Box 871845
Wasilla, AK 99687
Charles Boddy
Usibelli Coal Mine, Inc.
100 Cushman Street, Suite 210
Fairbanks, AK 99701-4659
Richard Wagner
PO Box 60868
Fairbanks, AK
99706
Cliff Burglin
PO Box 131
Fairbanks, AK 99707
Harry Bader
State of Alaska
Department of Natural Resources
3700 Airport Way
Fairbanks, AK 99709
Bernie Karl
K&K Recycling lnc.
PO Box 58055
Fairbanks, AK 99711
North Slope Borough
PO Box 69
Barrow, AK 99723
Williams Thomas
Arctic Slope Regional Corporation
Land Department
PO Box 129
Barrow, AK 99723
Senator Loren Leman
State Capitol Rm 113
Juneau, AK 99801-1182
• •
STATE OF ALASKA
ALASKA OIL AND GAS CONSERVATION COMMISSION
333 West 7 Avenue, Suite 100
Anchorage, Alaska 99501
Re: AN ORDER rescinding those rules within ) Docket Number: CO -10 -21
existing Conservation Orders relating to ) Other Order No. 66
well safety valve systems. )
) Statewide, Alaska
) January 11, 2011
IT APPEARING THAT:
1. On October 13, 2010 the Alaska Oil and Gas Conservation Commission ( AOGCC
or Commission) formally adopted new regulations relating to well safety valve
systems, at 20 AAC 25.265.
2. The newly adopted well safety valve system regulations underwent final review
by the Regulations Section of the Alaska Attorney General's Office and were
forwarded to the Alaska Lieutenant Governor's Office on October 28, 2010.
3. The new regulations were signed by the Lieutenant Governor and took legal effect
on December 3, 2010.
4. To ensure consistency with the new regulations, the AOGCC, on its own motion,
proposed to rescind part or all of the outdated rules within existing Commission
Orders relating to well safety valve systems.
5. On November 4, 2010, pursuant to 20 AAC 25.540, the Commission published in
the Alaska Daily News notice of opportunity for public hearing on December 6,
2010.
6. The Commission received written comments in response to its public notice, and
held a public hearing on December 7, 2010.
7. Oral testimony and written comments were provided at the December 7, 2010
hearing.
FINDINGS:
1. Well safety valve systems are regulated under newly- adopted 20 AAC 25.265,
which consolidates the requirements previously established in legacy documents,
policies, and statewide guidelines relating to safety valve systems.
2. Thirty -four existing Commission Orders contain rules governing well safety valve
systems. Twenty of those Orders contain broad regulatory requirements for safety
valve systems that are now covered by the newly- adopted regulations. The
remaining fourteen Orders include field- or pool- specific safety valve system
requirements.
Other Order 66 • 0 Page 2
Statewide, AK
January 11, 2011
existing Commission rules unrelated to well safety valve
3. Within e sti n Co Orders are u es e y
g
systems; these rules will continue in effect, unmodified.
Y >
4. Existing Commission Orders containing individual rules relating to well safety
valve systems are enumerated in the attached Table.
CONCLUSIONS:
1. Eliminating redundant requirements and standardizing wording for those field -
and pool- specific safety valve system requirements deemed appropriate to retain
will improve regulatory clarity.
2. Twenty existing Commission Orders that include rules relating to well safety
valve systems are rendered unnecessary, and can be replaced by newly- adopted
20 AAC 25.265. As more fully set forth in the attached Table, those Orders are
Conservation Orders 98A, 207A, 300, 311B, 317B, 329A, 341E, 345, 402B,
432D, 452, 457B, 471, 477, 484A, 505B, 553, 559, 570, and a Commission
unnumbered Order signed March 30, 1994 (policy dictating SVS performance
testing requirements).
3. Fourteen existing Commission Orders include field- or pool - specific safety valve
system requirements that the Commission considers appropriate for retention.
Wording for the same safety valve system requirements existing in different
Commission Orders has been standardized. As more fully set forth in the attached
Table, those Orders are Conservation Orders 406B, 423, 430A, 435A, 443B, 449,
456A, 458A, 562, 563, 569, 596, 597, and 605.
NOW, THEREFORE, IT IS ORDERED THAT individual rules in thirty-four existing
Commission Orders that relate to well safety valve systems are hereby rescinded or
revised as enumerated in the Table. Remaining rules unrelated to safety valve systems
within affected Commission Orders remain in effect, unmodified.
DONE at Anchorage, Alaska, and dated ail .- ary 11, 2011
1 ■110111 111111111
Aye ,.
Daniel T. Se. .- o , r., Commissioner, Chair
. • it . • :. s Conservation Commission
111110k " /
s i� rman, Co er
7 0
- .� a Oi , • • . a Conserva ion Commission
.?. 4 1' : `.. � �` ' Cat y P.: oerst r, Comm
Alaska • it and Gas Conservation Commission
•
Other Order 66 • • Page 3
Statewide, AK
January 11, 2011
RECONSIDERATION AND APPEAL NOTICE
As provided in AS 31.05.080(a), within 20 days after written notice of the entry of this order or decision, or such further time as the
Commission grants for good cause shown, a person affected by it may file with the Commission an application for reconsideration of
the matter determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration
must set out the respect in which the order or decision is believed to be erroneous.
The Commission shall grant or refuse the application for reconsideration in whole or in part within 10 days after it is filed. Failure to
act on it within 10 -days is a denial of reconsideration. If the Commission denies reconsideration, upon denial, this order or decision
and the denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after
the date on which the Commission mails, OR 30 days if the Commission otherwise distributes, the order or decision denying
reconsideration, UNLESS the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which
the application for reconsideration was filed.
If the Commission grants an application for reconsideration, this order or decision does not become final. Rather, the order or
decision on reconsideration will be the FINAL order or decision of the Commission, and it may be appealed to superior court. That
appeal MUST be filed within 33 days after the date on which the Commission mails, OR 30 days if the Commission otherwise
distributes, the order or decision on reconsideration. As provided in AS 31.05.080(b), "[t]he questions reviewed on appeal are limited
to the questions presented to the Commission by the application for reconsideration."
In computing a period of time above, the date of the event or default after which the designated period begins to run is not included in
the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00
p.m. on the next day that does not fall on a weekend or state holiday.
Fisher, Samantha J (DOA)
From: Fisher, Samantha J (DOA)
Sent: Tuesday, January 11, 2011 4:08 PM
To: Ballantine, Tab A (LAW); '(foms2 @mtaonline.net)'; '( michael .j.nelson @conocophillips.com)';
'(Von.L .Hutchins @conocophillips.com)'; 'AKDCWelllntegrityCoordinator; 'Alan Dennis';
'alaska @petrocalc.com'; 'Anna Raff; 'Barbara F Fullmer; 'bbritch'; 'Becky Bohrer; 'Bill
Penrose'; 'Bill Walker; 'Bowen Roberts'; 'Brad McKim'; 'Brady, Jerry L'; 'Brandon Gagnon';
'Brandow, Cande (ASRC Energy Services)'; 'Brian Havelock'; 'Bruce Webb'; 'carol smyth';
'caunderwood'; 'Chris Gay; 'Cliff Posey; 'Crandall, Krissell'; 'D Lawrence'; 'dapa'; 'Daryl J.
Kleppin'; 'Dave Matthews'; 'David Boelens'; 'David House'; 'David Steingreaber;
'ddonkel @cfl.rr.com'; 'Deborah J. Jones'; Delbridge, Rena E (LAA); 'Dennis Steffy'; 'Elowe,
Kristin'; 'Erika Denman'; 'eyancy'; 'Francis S. Sommer; 'Fred Steece'; 'Gary Laughlin'; 'Gary
Rogers'; 'Gary Schultz'; 'ghammons'; 'Gordon Pospisil'; 'Gorney, David L.'; 'Greg Duggin';
'Gregg Nady'; 'gspfoff; 'Harry Engel'; 'Jdarlington (jarlington @gmail.com)'; 'Jeanne
McPherren'; 'Jeff Jones'; 'Jerry McCutcheon'; 'Jill Womack'; 'Jim White'; 'Jim Winegarner;
'Joe Nicks'; 'John Garing'; 'John Katz'; 'John S. Haworth'; 'John Spain'; 'John Tower'; 'Jon
Goltz'; 'Judy Stanek'; 'Julie Houle'; 'Kari Moriarty'; 'Kaynell Zeman'; 'Keith Wiles'; 'Kelly
Sperback'; 'Kim Cunningham'; 'Larry Ostrovsky'; 'Laura Silliphant'; 'Marilyn Crockett; 'Mark
Dalton'; 'Mark Hanley (mark.hanley @anadarko.com)'; 'Mark Kovac'; 'Mark P. Worcester;
'Marguerite kremer'; 'Michael Dammeyer'; 'Michael Jacobs'; 'Mike Bill'; 'Mike Mason'; 'Mikel
Schultz'; 'Mindy Lewis'; 'MJ Loveland'; 'mjnelson'; 'mkm7200'; 'nelson'; 'Nick W. Glover'; 'NSK
Problem Well Supv'; 'Patty Alfaro'; 'Paul Decker (paul.decker @alaska.gov)'; 'Paul Figel';
'PORHOLA, STAN T'; 'Randall Kanady'; 'Randy L. Skillern'; ' rob.g.dragnich @exxonmobil.com';
'Robert Brelsford'; 'Robert Campbell'; 'Ryan Tunseth'; 'Scott Cranswick'; 'Scott Griffith'; Scott,
David (LAA); 'Shannon Donnelly'; 'Sharmaine Copeland'; Shellenbaum, Diane P (DNR);
Slemons, Jonne D (DNR); 'Sondra Stewman'; 'Steve Lambet; 'Steve Moothat; 'Steven R.
Rossberg'; 'Suzanne Gibson'; 'tablerk'; 'Tamera Sheffield'; Taylor, Cammy 0 (DNR); 'Temple
Davidson'; 'Teresa Imm'; 'Terrie Hubble'; 'Thor Cutler; 'Tina Grovier; 'Todd Durkee'; 'Tony
Hopfinger; 'trmjrl'; 'Valenzuela, Mariam '; 'Vicki Irwin'; 'Walter Featherly'; 'Will Chinn';
Williamson, Mary J (DNR); 'Yereth Rosen'; 'Aaron Gluzman'; Bettis, Patricia K (DNR);
rwood marathonoil.com; 'Dale Hoffman'; 'David Lenig'; 'Gary Orr'; 'Jason Ber erson';
caunde @ g, ry 9 ,
'Joe Longo'; 'Lara Coates'; 'Marc Kuck'; 'Mary Aschoff; 'Matt Gill'; 'Maurizio Grandi';
Ostrovsky, Larry Z (DNR); 'Richard Garrard'; 'Sandra Lemke'; 'Talib Syed'; 'Tiffany Stebbins';
'Wayne Wooster; 'William Van Dyke'; Woolf, Wendy C (DNR); Aubert, Winton G (DOA)
(winton.aubert@alaska.gov); Brooks, Phoebe L (DOA) (phoebe.brooks @alaska.gov);
Colombie, Jody J (DOA) (jody.colombie @alaska.gov); Crisp, John H (DOA)
(john.crisp @alaska.gov); Davies, Stephen F (DOA) (steve.davies @alaska.gov); Foerster,
Catherine P (DOA) (cathy.foerster @ alaska.gov); Grimaldi, Louis R (DOA)
(lou.grimaldi @alaska.gov); Johnson, Elaine M (DOA) (elaine.johnson @alaska.gov); Jones,
Jeffery B (DOA) (jeff.jones @alaska.gov); Laasch, Linda K (DOA) (linda.laasch @alaska.gov);
Maunder, Thomas E (DOA) (tom.maunder @alaska.gov); McIver, Bren (DOA)
(bren.mciver @alaska.gov); McMains, Stephen E (DOA) (steve.mcmains @alaska.gov);
Mumm, Joseph (DOA sponsored); Noble, Robert C (DOA) (bob.noble @alaska.gov); Norman,
John K (DOA) (john.norman @alaska.gov); Okland, Howard D (DOA)
(howard.okiand @alaska.gov); Paladijczuk, Tracie L (DOA) (tracie.paladijczuk @alaska.gov);
Pasqual, Maria (DOA) (maria.pasqual @alaska.gov); Regg, James B (DOA)
(jim.regg @alaska.gov); Roby, David S (DOA) (dave.roby @alaska.gov); Saltmarsh, Arthur C
(DOA) (art.saltmarsh @alaska.gov); Scheve, Charles M (DOA) (chuck.scheve @alaska.gov);
Schwartz, Guy L (DOA) (guy.schwartz @alaska.gov); Seamount, Dan T (DOA)
(dan.seamount @alaska.gov); Shartzer, Christine R (DOA)
Subject: Other 66 Safety Valve Systems
Attachments: other66.pdf
Sa-►i,a41.,tha/ Fi4,,hex
Co -vis-e-s vc urvv C aviuvt,i4-s-iaw
(907)793 -1223
(907)276-7542 (roux)
•
•
Mary Jones David McCaleb
XTO Energy, Inc. IHS Energy Group George Vaught, Jr.
Cartography GEPS P.O. Box 13557
810 Houston Street, Ste 200 5333 Westheimer, Suite 100 Denver, CO 80201 -3557
Ft. Worth, TX 76102 -6298 Houston, TX 77056
Jerry Hodgden Richard Neahring Mark Wedman
NRG Associates
Hodgden Oil Company Halliburton
President
408 18 Street 6900 Arctic Blvd.
Golden, CO 80401 -2433 P.O. Box 1655 Anchorage, AK 99502
Colorado Springs, CO 80901
Bernie Karl CIRI
95 Oil
K &K Recycling Inc. Land Department E. h
7
P.O. Box 58055 P.O. Box 93330 795 E. 94 Ct.
Anchorage, AK 99515 -4295
Fairbanks, AK 99711 Anchorage, AK 99503
North Slope Borough Jill Schneider Gordon Severson
P.O. Box 69 US Geological Survey 3201 Westmar Circle
Barrow, AK 99723 4200 University Drive Anchorage, AK 99508 -4336
Anchorage, AK 99508
Jack Hakkila Darwin Waldsmith James Gibbs
P.O. Box 190083 P.O. Box 39309 P.O. Box 1597
Anchorage, AK 99519 Ninilchick, AK 99639 Soldotna, AK 99669
Kenai National Wildlife Refuge
Penny Vadla Cliff Burglin
Refuge Manager 399 West Riverview Avenue 319 Charles Street
P.O. Box 2139 Soldotna, AK 99669 -7714 Fairbanks, AK 99701
Soldotna, AK 99669 -2139
Richard Wagner
P.O. Box 60868
Fairbanks, AK 99706
�pO
Orders Establishing Requirements for Well Safety Valve Systems
1/7/2011
Conservation New Regulation Provisions
Unit/Field Pool Order (1) Rule Rescind Rule? Existing Order Requirement Addressing Reqts from Order Revised Rule - "Well safety valve systems" (2) Comment
fail -safe auto SSV and SCSSV; injection wells (except disposal) require "Injection wells (excluding disposal injectors) must be equipped with(i) a double check valve
25.265(a); 25.265(b); 25.265(d)(2)(H); Check valve requirements for injectors are not covered by
Colville River Unit Qannik 605 5 no (i) double check valve, or (ii) single check valve and SSV; injection 25.265(h)(5) arrangement or (ii) a single check valve and a SSV. A subsurface - controlled injection valve or readopted regulation
valve satisfies single check valve requirement; test every 6 months SCSSV satisfies the requirements of a single check valve."
fail -safe auto SSV and SCSSV; injection wells (except disposal) require
25.265(a); 25.2659(b); 25.265(d)(1); "Injection wells (excludin disposal injectors) must be equipped with(i) a double check valve
Check valve requirements for injectors are not covered by
Oooguruk Oooguruk - Nuiqsut 597 6 no (i) double check valve, or (ii) single check valve and SSV; injection 25.265(h)(5) arrangement or (ii) a single check valve and a SSV. A subsurface - controlled injection valve or readopted regulation
valve satisfies single check valve requirement; test every 6 months SCSSV satisfies the requirements of a single check valve."
fail -safe auto SSV and SCSSV; injection wells (except disposal) require
25.265(a); 25.265(b); 25.265(d)(1); "Injection wells (excludin disposal injectors) must be equipped with(i) a double check valve
Check valve requirements for injectors are not covered by
Oooguruk Oooguruk - Kuparuk 596 6 no (i) double check valve, or (ii) single check valve and SSV; injection . arrangement or (ii) a single check valve and a SSV. A subsurface - controlled injection valve or
25.265(h)(5) readopted regulation
valve satisfies single check valve requirement; test every 6 months ( )( 5 ) SCSSV satisfies the requirements of a single check valve."
fail -safe auto SSV and SCSSV; maintain list of wells w/ removed or 25.265(a); 25.265(b); 25.265(d)(2)(F); Requirement to maintain a wellhead sign and list of wells with
Prudhoe Bay Unit Raven 570 5 yes r N/A deactivated SVS was replaced with requirement to maintain a
deactivated SVS; sign on wellhead 25.265(m) tag on well when not manned
fail -safe auto SSV and SCSSV; injection wells (except disposal) require
25.265(a); "I njec ti on we ll s (exc disposal injectors) must be equipped with(i) a double check valve
(a); 25 25 Check valve requirements for injectors are not covered by
Colville River Unit Fiord 569 5 no (I) double check valve, or (ii) single check valve and SSV; injection 25.265(h)(5) arrangement or (ii) a single check valve and a SSV. A subsurface - controlled injection valve or readopted regulation
valve satisfies single check valve requirement; test every 6 months SCSSV satisfies the requirements of a single check valve."
fail -safe auto SSV and SCSSV; injection wells (except disposal) require wells (excluding disposal injectors) must be equipped with(i) a double check valve
25.265(a); 25.265(b); 25.265(d)( Check valve requirements for injectors are not covered by
Colville River Unit Nanuq - Kuparuk 563 6 no (1) double check valve, or (ii) single check valve and SSV; injection 25.265(h)(5) arrangement or (ii) a single check valve and a SSV. A subsurface - controlled injection valve or readopted regulation
valve satisfies single check valve requirement; test every 6 months SCSSV satisfies the requirements of a single check valve."
fail -safe auto SSV and SCSSV; injection wells (except disposal) require wells (excluding disposal injectors) must be equipped with(i) a double check valve
25.265(a); 25.265(b); 25.265(d)(2)(H); Check valve requirements for injectors are not covered by
Colville River Unit Nanuq 562 6 no (i) double check valve, or (ii) single check valve and SSV; injection 25.265(h)(5) arrangement or (ii) a single check valve and a SSV. A subsurface - controlled injection valve or readopted regulation
valve satisfies single check valve requirement; test every 6 months SCSSV satisfies the requirements of a single check valve"
Prudhoe Ba Unit Put River 559 3 yes fail -safe auto SSV; SSSV landing nipple below permafrost; test as 25.265(a); 25.265(b); 25.265(d); N/A Readopted 25.265(d) dictates which wells require SSSV;
Y prescribed by Commission 25.265(h)(5)
replaces SSSV nipple requirement for all wells
Deep Creek Unit Happy Valley 553 3 yes SSV or SSSV 25.265(a) N/A
Prudhoe Bay Unit Orion 505B 3 yes fail -safe auto SSV; SSSV landing nipple below permafrost; test as 25.265(a); 25.265(b); 25.265(d); N/A Readopted 25.265(d) dictates which wells require SSSV;
prescribed by Commission 25.265(h)(5) replaces SSSV nipple requirement for all wells
Prudhoe Ba Unit Polaris 484A 3 yes fail -safe auto SSV; SSSV landing nipple below permafrost; test as 25.265(a); 25.265(b); 25.265(d); N/A Readopted 25.265(d) dictates which wells require SSSV;
Y prescribed by Commission 25.265(h)(5) replaces SSSV nipple requirement for at wells
fail -safe auto SSV; SSSV landing nipple below permafrost; gas /MI 25.265(a); 25.265 b 25.265 d Readopted 25.265(d) dictates which wells require SSSV;
Milne Point Unit Milne Point ( )' ( )' 477 5 yes injection well require SSSV or injection valve below permafrost test N/A
Schrader Bluff y 25.265(h)(5) replaces SSSV nipple requirement for all wells
every 6 months
Prudhoe 68 Unit Borealis 471 3 yes fail -safe auto SSV; SSSV landing nipple below permafrost; gas/MI 25.265(8); 25.265(b); 25.265(d); N/A Readopted 25.265(d) dictates which wells require SSSV;
Y Y injection well require SSSV below permafrost; test every 6 months 25.265(h)(5) replaces SSSV nipple requirement for all wells
Northstar Northstar 458A 4 no fail -safe auto SSV and SCSSV; test as prescribed by Commission; 500• 25.265(a); 25.265(b); 25.265(d)(1) "The minimum setting depth for a tubing conveyed subsurface safety valve is 500 feet." Existing pool rule established a minimum setting depth for the
ft minimum setting depth for SSSV SSSV
Prudhoe Ba Unit Aurora 457B 3 yes fail -safe auto SSV; SSSV landing nipple below permafrost; test every 6 25.265(a); 25.265(b); 25.265(d); Readopted 25.265(d) dictates which wells require SSSV;
Y months 25.265(h)(5) N/A replaces SSSV nipple requirement for all wells
fail -safe auto SSV; gas /MI injectors require SSV and single check 25.265(a); 25.265(b); 25.265(d); "Injection wells (excluding disposal injectors) must be equipped with(i) a double check valve Check valve requirements for injectors are not covered by
Kuparuk River Unit Meltwater 456A 5 no valve and SSSV landing nipple; water injection wells require (1) double arrangement or (ii) a single check valve and a SSV. A subsurface-controlled injection valve or readopted regulation; readopted 25.265(d)(5) does not include
check valve, or (ii) single check valve and SSV; test every 6 months 25 SCSSV satisfies the requirements of a single check valve." SSSV requirement for MI injectors
Prudhoe Bay Unit Midnight Sun 452 6 yes fail -safe auto SSV (all injectors and producers capable of unassisted 25.265(a); 25.265(b); 25.265(d); N/A Readopted 25.265(d) dictates which wells require SSSV;
flow to surface); test every 6 months 25.265(h)(5) replaces SSSV nipple requirement for all wells
fail -safe auto SSV and SCSSV; SSSV may be installed above or below 25.265(a); 25.265(b); 25.265(d)(1); "The setting depth of a required subsurface safety valve must be located in the tubing either Existing pool rule established alternate SSSV setting depth;
Duck Island Unit Eider 449 7 no permafrost; injection wells require double check valve; LPS trip above or below permafrost. Injection wells must be equipped with a double check valve check valve requirements for injectors are not covered by
pressure; test every 6 months 25 arrangement." readopted regulation
fail -safe auto SSV and SCSSV (producers and gas injectors); water "Injection wells (excluding disposal injectors) must be equipped with(i) a double check valve Check valve requirements for injectors are not covered by
Colville River Unit Alpine 443B 5 no injection wells require (i) double check valve, or (ii) single check valve 25.265(a); 25.265(b); 25.265(d)(2)(H) arrangement or (ii) a single check valve and a SSV. A subsurface - controlled injection valve or readopted regulation
and SSV SCSSV satisfies the requirements of a single check valve."
fail -safe auto SSV; gas /MI injectors require SSV and single check 25.265(a); 25.265(b); 25.265(d); "Injection wells (excluding disposal injectors) must be equipped with(i) a double check valve Check valve requirements for injectors are not covered by
Kuparuk River Unit Tabasco 435A 6 no valve and SSSV landing nipple; water injection wells require (i) double arrangement or (ii) a single check valve and a SSV. A subsurface controlled injection valve or readopted regulation; readopted 25.265(d)(5) does not include
check valve, or (ii) single check valve and SSV; test every 6 months 25 SCSSV satisfies the requirements of a single check valve." SSSV requirement for MI injectors
fail -safe auto SSV (S /D well and artificial lift); sign on well if SVS Requirement to maintain a wellhead sign and list of wells with
deactivated; maintain list of wells w /deactivated SVS; test as 25.265(a); b 25.265(h)(5); deactivated SVS was replaced with requirement to maintain a
25.265
Ku aruk River Unit; 25 . 265 (b);
p Kuparuk 432D 5 yes prescribed by Commission; CO 432D.009 modifies Rule 5(b) - LPP 265 m N/A tag on well when not manned; administrative approval CO
25 .
Milne Point Unit may be defeated on W. Sak injectors w /surface pressure <500psi w/ ( ) 432D.009 remains effective [re:defeating the LPS when surface
notice when defeated and placed back in service injection pressure for West Sak water injector is <500psi]
Page 1 of 2
Orders Establishing Requirements for Well Safety Valve Systems
1/7/2011
Conservation New Regulation Provisions Revised Rule - "Well safety valves stems' (2) Comment
UnitlField Pool Order (1) Rule Rescind Rule? Existing Order Requirement Addressing Reqts from Order y systems" ( )
fail -safe auto SSV; gas /MI injectors require SSV and single check 25.265(x); 25.265(b); 25.265(d);
"Injection wells (excluding disposal injectors) must be equipped with(i) a double check valve Check valve requirements for injectors are not covered by
Kuparuk River Unit Tarn 430A 6 no valve and SSSV landing nipple; water injection wells require (t) double arrangement or (ii) a single check valve and a SSV. A subsurface - controlled injection valve or readopted regulation; readopted 25.265(d)(5) does not include
check valve, or (ii) single check valve and SSV; test every 6 months 25 SCSSV satisfies the requirements of a single check valve" SSSV requirement for MI injectors
Milne Point - Sag 423 7 no fail -safe auto SSV; injection wells require double check valve; test Pp arrangement." valve requirements for injectors are not covered by
Milne Point Unit every 6 months 25.265 ( a ) ; 25.265(b); b ) 25.265 ( h )( 5 )
"Injection wells must bee equipped ed with a double check valve arran ement" readopted regulation
River
fail -safe auto SSV; gas /MI injectors require SSV and single check Check valve requirements for injectors are not covered by
valve and SSSV landing nipple; water injection wells require (i) double "Injection wells (excluding disposal injectors) must be equipped with(i) a double check valve readopted regulation; readopted 25.265(d)(5) does not include
Kuparuk River Unit Kuparuk -West Sak 406B 6 n check valve, or (ii) single check valve and SSV; test every 6 months; 25.265(x); 25.265(b); 25.265(d); arrangement or (ii) a single check valve and a SSV. Asubsurface- controlled injection valve or SSSV requirement for MI injectors; administrative approval CO
p P CO 4068.001 modifies Rule 6(e) - LPP may be defeated on W. Sak 25.265(h)(5) SCSSV satisfies the requirements of a single check valve. The Low Pressure Pilot may be
injectors w /surface pressure <500psi w/ notice when defeated and defeated on West Sak water injectors with surface injection pressure less than 500psi." 4066.001 remains effective [re:defeating the LPS when surface
injection pressure for West Sak water injector is <500psi]
placed back in service
fail -safe auto SSV and SCSSV; LPS trip pressure; readily accessible
Badami Badami 402B 6 yes control unit; SSSV below permafrost; NTE 210days between tests; 25.265(a); 25.265(b); 25.265(h); N/A
submit test results electronically within 14days; SVS defeated /removed 25.265(m)
only if well SI or pad continuously manned
fail -safe auto SSV (S /D well and artificial lift); sign on well if SVS 25.265(a); 25.265(b); 25.265(h)(5); Requirement to maintain a wellhead sign and list of wells with
Prudhoe Bay Unit North Prudhoe 345 4 yes deactivated; maintain list of wells w /deactivated SVS; test as 25.265(m) N/A deactivated SVS was replaced with requirement to maintain a
prescribed by Commission tag on well when not manned
fail -safe auto SSV (S /D well and artificial lift); if SSSV installed it must
be maintained and tested as part of SVS; sign on well if SVS 25.265(a); 25.265(b); 25.265(d); N/A Readopted 25.265(d) dictates which wells require SSSV;
Prudhoe Bay Unit Prudhoe 341E 5 yes deactivated; maintain list of wells w /deactivated SVS; test as 25.265(h)(5) replaces SSSV nipple requirement for all wells
prescribed by Commission
fail -safe auto SSV and SCSSV; maintain list of wells w/ removed or 25.265(a); 25.265(b); 25.265(d); N/A Readopted 25.265(d) dictates which wells require SSSV;
Prudhoe Bay Unit Niakuk 329A 5 yes deactivated SVS; sign on wellhead 25.265(h)(5); 25.265(m) replaces SSSV nipple requirement for all wells
fail -safe auto SSV and SCSSV; SSSV may be rermoved as part of 25.265(a); 25.265(b); 25.265(d); N/A Readopted 25.265(d) dictates which wells require SSSV;
Prudhoe Bay Unit Pt. McIntyre 3178 8 yes routine well ops w/o notice 25.265(j); 25.265(m) replaces SSSV nipple requirement for all wets
fail -safe auto SSV; sign on well if SVS deactivated; maintain list of wells 25.265(a); 25.265(b); 25.265(d); N/A Readopted 25.265(d) dictates which wells require SSSV;
Prudhoe Bay Unit West Beach 311B 6 yes w /deactivated SVS; test as prescribed by Commission 25.265(h)(5); 25.265(m) replaces SSSV nipple requirement for all wells
West Fork West Fork (Sterling 300 5 yes fail -safe auto SVS on each production tubing 25.265(a); 25.265(b) N/A
A &B)
fail -safe auto SSV; sign on well if SVS deactivated; maintain list of wells 25.265(a); 25.265(b); 25.265(h)(5); Requirement to maintain a wellhead sign and list of wells with
N/A
Prudhoe Bay Unit Lisburne 207A 7 yes w /deactivated SVS; test as prescribed by Commission 25.265(m) deactivated SVS was replaced with requirement to maintain a tag on well when not manned
suitable automatic safety valve installed below base of permafrost to 25.265 d N/A Readopted 25.265(d) dictates which wells require SSSV;
Prudhoe Bay Unit Prudhoe - Kuparuk 98A 5 yes prevent uncontrolled flow () replaces SSSV nipple requirement for all wells
AOGCC Policy - SVS Failures; issued by order of the
Commission policy dictating SVS performance testing 25.265(h); 25.265(n); 25.265 ( o ) N/A Commission 3/30/1994 (signed by Commission Chairman
Statewide N/A N/A N/A yes requirements
Dave Johnson)
Footnotes
(1) No SVS rules found in Injection Orders
(2) New title for Revised Rule; "N /A" means entire pool rule to be rescinded
I
Page 2 of 2
• .
Public Hearing Record
And
Backup Information available in Other 66
if 6
Requested documents 41/ •
{
Subject: Requested documents
Date: Wed, 15 Oct 2003 13:52:50 -0800
From: Jody Colombie <jody colombie @admin.state.ak.us>
Organization: Alaska Oil and Gas Conservation Commission
To: kbird @usgs.gov
Mr. Bird:
I was given your request yesterday and have completed the copying. I
will mail the documents to you tomorrow. The Commission's standard
charge for copies is $.25 per page. The total cost of your request is
$20.75. I will enclose an invoice with the copies for payment.
Thank you for your patience. In the future if you need documents from
conservation orders, please e-mail me direct.
Jody Colombie
Special Staff Assistant
Jody Colombie <jody colombie @admin.state.ak.us>
1 of 1 10/15/2003 2:04 PM
lot Iow up
•
N - Subject: follow up
Date: Fri, 10 Oct 2003 12:18:10 -0700
From: Ken Bird <kbird @usgs.gov>
To: Howard_Okland@admin.state.ak.us
Howard,
In mid - August, I sent you an inquiry about figures submitted by BP
for the Eider pool as follows: "The Exhibits F, G, H, and 'I for the
Eider pool rules and injection order application dated April 17, 2000
were held confidential at BP's request until February 2001. We would
like to get copies of these documents." Could you tell me the status
of this request?
I also would like to get a copy of the August 13, 2001 BPXA document
entitled "Application to AOGCC for Approval of Pool Rules and Area
Injection Order (for Northstar Field), Public Information Copy
Regards,
Ken
Ken Bird
U.S. Geological Survey
345 Middlefield Road, MS 969
Menlo Park, CA 94025
email: kbird @usgs.gov
phone: 650 - 329 -4907
fax: 650 - 329 -4975
35
I
• 1 ALASKA OIL AND GAS CONSERVATION COMMISSION
2 PUBLIC HEARING
3 )
In Re: )
4 )
NORTHSTAR DEVELOPMENT WELLS, )
5 NORTHSTAR FIELD. )
6
TRANSCRIPT OF PROCEEDINGS
7
Anchorage, Alaska
8 November 7, 2002
9:02 o'clock a.m.
9
APPEARANCES:
10
Commissioners: MR. DAN SEAMOUNT, JR., CHAIRPERSON
11 MR. MIKE BILL
12
For Applicant
13 BP Exploration: MR. JEFF CONRAD
• MR. MIKE FRANCIS
14
15
16 * * * * *
17
18
19
20
21
22 RECEIVED
23
NOV la 2002
24
Alaska OH & Gas Cons. Commission
25 Anchorage
• METRO COURT REPORTING, INC.
745 West Fourth Avenue, Suite 425
Anchorage, Alaska 99501
(907) 276 -3876
•
• 1 TABLE OF CONTENTS
2
WITNESSES: PAGE:
3
For the Applicant:
4
Mike Francis 6
5
EXHIBITS: ADMITTED:
6
Wellbore schematic 8
7 E -mail questions /answers 9
8 * * * * *
9
10
11
12
13
• 14
15
16
17
18
19
20
21
22
23
24
25
• METRO COURT REPORTING, INC.
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ii
• •
• 1 P R O C E E D I N G S
2 (On record - 9:02 a.m.)
3 THE CHAIRPERSON: Call this hearing to order.
4 Thank you all for showing up, attending. The date is Thursday,
5 November 7, 2002. The time is 9:02. We're at the offices of
6 the AOGCC, Alaska Oil and Gas Conservation Commission. We're
7 located at 333 West Seventh Avenue, Anchorage, Alaska, and
8 those are our -- the AOGCC's office. I'd like to introduce us
9 at the front here. To my left is Commissioner Michael Bill.
10 My name is Dan Seamount. Cammy Taylor, the third commissioner,
11 has a scheduling conflict and she's attending to other
12 Commission business at this time. Laura Ferro is on my right.
13 She's with Metro Court Reporting. She's making a transcript of
• 14 the proceedings. You can get a copy from Metro Court
15 Reporting.
16 The purpose of this hearing is to consider a request
17 from BP Exploration Alaska to be granted a variance from a
18 portion of AOGCC Regulation 20 AAC 25.265(a)(2), and that
19 states a completed well with an offshore surface location and
20 is capable of unassisted flow of hydrocarbons to the surface
21 must be equipped with a Commission - approved fail -safe automatic
22 subsurface safety valve system, capable of preventing an
23 uncontrolled flow unless another type of subsurface valve with
24 that capability is approved by the Commission. This valve must
25 be in a tubing string and located below the mud line datum, or
• METRO COURT REPORTING, INC.
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3
1 if permafrost is present, below the permafrost. That portion
2 that BP requests to be waived is a requirement that subsurface
3 safety valve be placed below the permafrost. Specifically, BP
4 wants to set the subsurface safety valve at 500 feet.
5 Notice of the hearing was published on October 5, 2002.
6 We -- the Commission received a request for the hearing dated
7 October 20, 2002. This was received on October , 2002, from
8 a Ms. Nancy Wainwright. Proceedings will be held in accordance
9 with 20 -- with regulation 20 AAC 25.540. These are
10 regulations governing public hearings. The hearing will be
11 recorded.
12 Is -- could I see the sign -in sheet, please? Okay. I
13 see that we have a few people that will provide testimony if
• 14 needed. Do you -- does BP wish to provide oral testimony
15 today?
16 MR. CONRAD: We're here to answer questions if
17 the Commission has them, and we have some handouts that we'd
18 like to enter into the record.
19 THE CHAIRPERSON: Okay. Then I take it that
20 you probably should provide some testimony. Okay. We provide
21 that we consider sworn testimony or unsworn statements. We
22 give greater weight to sworn. Let's see, today, if you wish to
23 be considered an expert, you have to state your qualifications,
24 and the Commission will rule whether to consider you an expert.
25 Where did that sign -in sheet go? We're going to hear from BP
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4
+1
• 1 first. If anyone else wants to make an oral statement, they
2 will be allowed to do so at the end of the testimony. A person
3 may not ask questions of the witness directly, but to have a
4 question directed to the witness, you need to write the
5 question down, forward the question to the designated
6 Commission representative, which is Winton Aubert in the
7 audience there, then he will forward the designated -- he will
8 forward the question to the Commission. The Commission will
9 ask questions that -- ask the question if they deem that it's
10 relevant to the hearing.
11 Is there anyone else in the room that would like to
12 testify? I see from the sign -in sheet, no. It looks like the
13 Applicant will be the only one testifying today. Okay. We
410 14 invite the Applicant to introduce themselves.
15 MR. CONRAD: First of all, Mister
16 COURT REPORTER: Excuse me. Could you clip a
17 microphone on, please? Thank you.
18 THE CHAIRPERSON: Before making your
19 statements, could you give us your name?
20 MR. CONRAD: I'd like to introduce myself as
21 Jeff Conrad with BP.
22 THE CHAIRPERSON: Are you giving sworn
23 testimony?
24 MR. CONRAD: I am not giving sworn testimony
25 today. And with me is Mike Francis. He is a petroleum
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5
. 411 111
• 1 engineer at BP, and we will consider -- request the Commission
2 consider his testimony as expert testimony.
3 THE CHAIRPERSON: Okay. Are you giving sworn
4 testimony?
5 MR. FRANCIS: Right, okay. Are we ready?
6 THE CHAIRPERSON: Please raise your right hand.
7 (Oath administered)
8 MR. FRANCIS: Yes.
9 MIKE FRANCIS
10 called as a witness on behalf of the Applicant, testified as
11 follows:
12 THE CHAIRPERSON: State your name, please?
13 MR. FRANCIS: Okay. My name is Mike Francis.
• 14 I'm the petroleum engineer for the Northstar Field. I received
15 a Bachelor of Science degree in petroleum engineering from
16 Texas A &M University in 1981. I have 21 years of petroleum
17 engineering experience with Arco, Vastar, and BP. I've worked
18 on fields located in Texas, the Gulf of Mexico, Indonesia, and
19 Alaska. I've been a licensed professional engineer in the
20 State of Alaska since 1990. I've worked on Northstar since
21 June 2001.
22 THE CHAIRPERSON: And do you -- who do you
23 represent?
24 MR. FRANCIS: BP.
25 THE CHAIRPERSON: Okay. Commissioner Bill, do
• METRO COURT REPORTING, INC.
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(907) 276 -3876
6
• 1 you have any questions concerning the witness' qualifications?
2 COMMISSIONER BILL: None.
3 THE CHAIRPERSON: Okay, Mr. Francis, you are
4 being accepted as an expert witness.
5 MR. FRANCIS: BP would like to switch the --
6 switch to a tubing- conveyed subsurface controlled subsurface
7 safe -- or surface - controlled subsurface safety valve in our
8 future producing wells at Northstar. The tubing- conveyed
9 valves that we would like to use, they are the industry
10 standard. They require less well intervention activity than
11 the wireline- retrievable valves that are utilized in the
12 current Northstar wells. In order to use this type of tubing -
13 conveyed valve, which would be an improvement, the setting
• 14 depth needs to be higher than the base of the permafrost as
15 required in the rules. This is necessary because the shallower
16 setting depth is to -- necessary to ensure that the valve will
17 operate properly across the full range of anticipated operating
18 conditions.
19 THE CHAIRPERSON: Okay. Do you wish to submit
20 any evidence into the record at this point?
21 MR. FRANCIS: Just a -- to demonstrate what
22 we're speaking about, I've got just a simple wellbore
23 schematic.
24 THE CHAIRPERSON: And you wish to have this
25 admitted into evidence?
• METRO COURT REPORTING, INC.
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7
i •
• 1 MR. FRANCIS: Yes, sir.
2 THE CHAIRPERSON: Okay. We will admit a
3 wellbore schematic submitted November 7, 2002. It is two
4 pages.
5 (Exhibit of wellbore schematic admitted)
6 THE CHAIRPERSON: Could you describe it now?
7 MR. FRANCIS: What has been admitted into
8 evidence is a wellbore schematic for a typical producing well
9 at Northstar. This is one of the current wells. This shows a
10 safety valve landing nipple at 2,032 feet, measured depth.
11 This is below the base of the permafrost. The rule exception
12 that's being asked for would allow us to move that depth up to
13 as high as 500 feet to allow us to use a different type of
410 14 valve. This current wellbore that's shown has a wireline-
15 retrievable type valve whereas there's a setting -- there's a
16 landing nipple here that the valve is running on wireline. The
17 future wells, if the exception was granted, would have a tubing
18 retrievable type valve set at a shallower depth. This would
19 eliminate the need for the packing material that holds the
20 wireline- retrievable valve in place and reduce the amount of
21 intervention necessary to maintain proper operation of the
22 valve.
23 The second schematic is -- just shows what a tubing
24 retrievable subsurface safety valve looks like.
25 THE CHAIRPERSON: Okay. Before I ask
• METRO COURT REPORTING, INC.
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8
• •
• 1 Commissioner Bill if he has any questions, you also submitted I
2 believe via e -mail today, November 7th, answers to 13 questions
3 that had been asked you by the Commission.
4 MR. FRANCIS: Yes, sir.
5 THE CHAIRPERSON: We're going to admit that
6 into evidence also, the 13 questions with answers -- the
7 questions from the Commission with BP's response in red.
8 (Exhibit of e-mail questions /answers admitted)
9 THE CHAIRPERSON: Commissioner Bill, do you
10 have any questions of the Applicant?
11 COMMISSIONER BILL: Regarding your diagram
12 on -- of the tubing - retrievable valve, will that be controlled
13 using control and balance lines?
• 14 MR. FRANCIS: This type of valve is a single
15 control line valve.
16 COMMISSIONER BILL: All right. And those will
17 be strapped to the tubing?
18 MR. FRANCIS: Yes, sir.
19 COMMISSIONER BILL: Okay. It will be strapped
20 to the tubing, okay. Now I understand from the information
21 that you provided in answer to the questions that this setting
22 depth is used elsewhere on the North Slope?
23 MR. FRANCIS: It's my understanding it is used
24 at Milne Point.
25 COMMISSIONER BILL: Without operational
• METRO COURT REPORTING, INC.
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•
• 1 problem?
2 MR. FRANCIS: Correct.
3 COMMISSIONER BILL: I think you had mentioned
4 as you introduced the exhibit that you intend to set the valve
5 as high as 500 feet. There's indication that you might be
6 using a deeper depth on -- in some installations.
7 MR. FRANCIS: The request was for a shallowest
8 500 feet. Our plan is to actually set them at 1,000 feet.
9 COMMISSIONER BILL: And would that be for both
10 producers and injectors?
11 MR. FRANCIS: No, sir. That would just be for
12 the future producing wells. In the injection wells, we'll
13 continue to use the current valve we're using, which is a
410 14 wireline- retrievable valve set at 2,000 feet and dual control
15 line valve.
16 COMMISSIONER BILL: What is it about the design
17 of the valve that makes 2,000 feet impractical or the -- or
18 your system that makes 2,000 feet impracticable for the
19 producing wells?
20 MR. FRANCIS: The valves as you know are
21 operated by a surface hydraulic system. Ours is rated up to
22 6,000 pounds. With 6,000 pounds, we cannot attain an opening
23 pressure at the conditions anticipated late in the life of the
24 field.
25 COMMISSIONER BILL: So current installations
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10
•
• 1 would not have an operational problem?
2 MR. FRANCIS: It would not be a problem in the
3 near term future but we could have operational problems with
4 the valves late in the life of the field.
5 COMMISSIONER BILL: What would you do with
6 valves that are on completions that are already on existing
7 wells?
8 MR. FRANCIS: Well, the current wells that have
9 their valves at 2,000 feet, they'll utilize a different type of
10 valve that will be okay late in the life of the field, but with
11 the single control line tubing- retrievable valves, that's where
12 we run into the problem, or we could potentially run into the
13 problem late in the life of the field with the valves set at
• 14 2,000 feet.
15 COMMISSIONER BILL: And all of the valves that
16 you intend to use are standard industry rated valves?
17 MR. FRANCIS: Yes, sir. They're Schlumberger
18 TRM -4 valves widely used elsewhere in the world.
19 COMMISSIONER BILL: Okay, thank you.
20 THE CHAIRPERSON: As I said before, it doesn't
21 look like any -- there is anyone else wishing to testify. I
22 want to make one last time to question whether anybody else
23 wants to testify. Okay, looks like there will be no more
24 testimony. At this time I'd like to take just a very short
25 five minute recess and we'll be right back. Off the record.
• METRO COURT REPORTING, INC.
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11
s •
• 1 (Off record - 9:17 a.m.)
2 (On record - 9:23 a.m.)
3 THE CHAIRPERSON: On record. All of our
4 questions have been answered. It's now appropriate to close
5 the meeting. I'd like to thank you for your time, and a
6 decision will be forthcoming. Thank you. Off the record.
7 (Off record - 9:23 a.m.)
8 END OF PROCEEDINGS
9
10
11
12
13
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15
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17
18
19
20
21
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24
25
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12
• •
1 C E R T I F I C A T E
2 UNITED STATES OF AMERICA)
) ss.
3 STATE OF ALASKA
4 I, Laura C. Ferro, Notary Public in and for the State
5 of Alaska, and Reporter for Metro Court Reporting, do hereby
6 certify:
7 That the foregoing Alaska Oil & Gas Conservation
8 Commission Public Hearing was taken before myself on the 7th
9 day of November 2002, commencing at the hour of 9:02 o'clock
10 a.m., at the offices of the Alaska Oil & Gas Conservation
11 Commission, 333 West Seventh Avenue, Suite 100, Anchorage,
12 Alaska;
13 That the public hearing was transcribed by myself to
14 the best of my knowledge and ability.
15 IN WITNESS WHEREOF, I have hereto set my hand and
16 affixed my seal this llth day of November 2002.
17 %14.(■ut,C, \ \ \Illllllil / / / / / ?-e/t-t-0
18 � "' F F'9 q �� Laura C. Ferro
Notary Public in and for Alaska
19 • NOTAR Y = My P 06 03 commission ex ires: 05
_ / /
20 PUBLIC
#! /! 1! I I I I I I\ \\ \`\\
22
23
24
25
M E T R O COURT R E P O R T I N G , I N C .
745 West Fourth Avenue, Suite 425
Anchorage, Alaska 99501
(907) 276 -3876
13
STATE OF ALASKA
OIL AND GAS CONSERVATION COMMISSION
NORTHSTAR SSV HEARING
November 7, 2002 at 9:00 am
NAME - AFFILIATION ADDRESS/PHONE NUMBER TESTIFY (Yes or No)
(PLEASE PRINT) ,r
M tc1Nat,1 . a . r rartc, P 5Co4 -4Z4CC t nt,edle.44
d i CarereA 3 8P/ 5 -sew s-
via I1-Qt_ A 64 /Q'°Uc -c- / 1f5- 1151
(� - 6 7'73 - rZ3 /\/a
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A/Y 4)6A I t 345 - 5- q5 ,n c)
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/tdicrf 3,c.c ,4oGcc 71 3 -/ z
•
BPXA request for SSSV setting depth at 500' at North Star
Questions for BPXA
1. What is the lateral and vertical variability of the permafrost section(s)?
It has not been logged in all of the wells.
2. Is the permafrost continuous within the main permafrost interval (1130' to 1630'
in Seal #1 Well)?
Yes
3. A primary reason for setting SSSV's below the base of the permafrost is to place
the SSSV's below any potential detrimental effects within the permafrost section.
What well designs (cementing practices, casing grades, annular fluids, etc.) at
North Star mitigate that risk?
The production casing is designed and pressure tested to withstand the full shut in tubing
pressure. The annular fluid in both the IA and OA down below the base of permafrost is
diesel. This diesel precludes the possibility of annular fluid freezing/expansion and the
detrimental effects that may have adjacent casing or tubing.
4. Please describe the current safety valve system ( "SVS ") at North Star.
The system consists of SCSSSVs, surface safety valves (actuated master valves) and
actuated wing valves. These valves are designed to shut when the system is triggered and
the hydraulic pressure is released.
5. What are the roblems associated with setting tubing conveyed SSSV's at 2000'?
p g g co
Y
The minimum opening pressure in the worst -case late life field conditions exceeds the
surface hydraulic system operating pressure of 6000 psi.
6. What does the MMS require for sub - surface safety valve ( "SSSV ") setting depth
at North Star?
They have the same requirements as the AOGCC, but have indicated they will follow the
states lead and allow a shallower setting depth if the AOGCC approves this request.
7. What are the advantages of using tubing conveyed SSSV's?
• The elimination of the packing required to seal wireline conveyed SSSVs in their landing
nipples. Packing leaks that require that these wireline retrievable valves be pulled and
replaced are common.
• Tubing conveyed valves have the same ID as the tubing so they do not need to be pulled
during well intervention activities such as perforating and production logging.
8. Why was the proposed 500' setting depth chosen?
A setting depth shallower than the base of the permafrost is needed to ensure operation of
the tubing retrievable SCSSSVs over the full range of expected conditions. An allowable
setting depth request of 500' was based on the setting depth used at Milne Point.
9. Does BPXA plan any modifications to the SVS if the request is approved?
A relief valve setting will be changed to allow the hydraulic supply pressure to increase from
5000 to 6000 psi. This is within parameters of the existing equipment.
RECEIVED
Nov 0 7 2002
(--) ,
Alaska Oit•& Gas Cons. Commission
Anchorage
•
10. Does BPXA plan any modifications (e.g. pulling tubing) to existing well
completions?
There are no plans to pull tubing in the current producers. The Halliburton dual control line
BBE ball type SSSVs are being replaced with Schlumberger WRDP single control line flapper
valves.
11. If tubing conveyed SSSV's are utilized, what are BPXA's plans if an SSSV fails?
An insert valve like the wireline conveyed valves being used in the current producers can be
set inside the proposed tubing conveyed SSSVs after the tubing conveyed SSSV is locked in
the open position using wireline tools.
12. What would be the impact on the number of well interventions?
Based on SSSV performance to date, we would expect to reduce the number of interventions
in these new wells by one intervention per year in the nine wells that will use the tubing
conveyed SSSVs.
13. What other types of SSSV's might be used at North Star in the future?
The plan is as follows:
• Tubing conveyed, single control line SCSSSVs set at 1000' in the nine future producers
• Wireline retrievable, dual control line SCSSSVs set at 2000' in future injection wells (the
same as the current injection wells)
• If control line integrity is lost in a producing well, an insert subsurface controlled SSSV
(SSCSSSV) will be run (i.e. a storm choke type valve).
• If control line integrity is lost in an injectionwell, an insert SSCSSSV will be run (i.e. an
injection valve).
ALASKA OIL, GAS CONSERVATION IJMMISSION
FAX 907- 276 -7542
PHONE 907- 279 -1433
FACSIMILE TRANSMITTAL SHEET
TO: FROM: al
COMPANY: DATE:
FAX NUMBER: � �y L./ TOTAL NO OF PAGES INCLUDI COVER:
/ f
PHONE NUMBER: SENDER'S REFERENCE NUMBER:
RE: YOUR REFERENCE NUMBER:
❑ URGENT ❑ FOR REVIEW ❑ PLEASE COMMENT ❑ PLEASE REPLY ❑ PLEASE RECYCLE
NOTES /COMMENTS:
AOGCC
333 WEST 7TH AVENUE, SUITE 100
ANCHORAGE, AK 99501 -3935
��
Re: Nov 7th Hearing
•
Subject: Re: Nov 7th Hearing
Date: Tue, 05 Nov 2002 12:20:02 -0900
From: Cammy Oechsli Taylor <Cammy_Taylor@admin.state.ak.us>
Organization: DOA -AOGCC
To: Jody Colombie <jody colombie @admin.state.ak.us>
CC: Daniel T Seamount JR <dan_seamount @admin.state.ak.us >,
Michael L Bill <mike bill @admin.state.ak.us>
I didn't realize we had Northstar scheduled for the 7th - if she
formally requested the hearing (and her request was timely) we must
have a hearing.
Who is the lead on this? Have all the issues been identified and has
BP provided the commission with all the information to support a
decision?
Jody Colombie wrote:
> Nancy Wainwright called today and was inquiring if we will be a hearing
> on Northstar Setting SSV on November 7th. She has formally requested a
> hearing. After I receive your answer I will call her back at 345 -5595.
> Jody
Cammy Oechsli Taylor <cammy taylor(aiadmin.state.ak.us>
Commissioner
Alaska Oil and Gas Conservation Commisison
Department of Administration
1 of 1 11/5/2002 1:19 PM
Northstar -SSSV Setting Depth
• •
Subject: Northstar - SSSV Setting Depth
Date: Mon, 30 Sep 2002 11:32:01 -0500
From: "Francis, Michael J" <Michael.Francis @BP.com>
To: "Winton Aubert (E- mail)" < wnton aubert@admin.state.ak.us>
«SSSV setting depth - letter to AOGCC 09-30-2002.doc»
Winton,
Here is an unsigned copy for your reference. The signed letterhead copy is
on the way.
Regards,
Mike
Michael J. Francis, P.E.
SP Exploration Alaska, Inc. RECEIVED
Senior Petroleum Engineer
Phone: (907) 564 -4240
Cell: (907) 529 -8678
Fax: (907) 564 -5200 e -mail: Michael.Francis @bp.com NOV N 7 0 t 2002
P.O. Box 196612
Anchorage, AK 99519-6612 Alaska Clf•& Gas Gons. Commissior
Anchorage
.._. � _ ..... .
e: SSSV setting depth - letter to AOGCC
SSSV setting depth - letter to AOGCC 09- 30- 2002.doc 09- 30- 2002.doc
Type: WINWORD File (application/msword)
Encoding: base64
Permafrost and SSSV Setting Depth
• •
Subject: Permafrost and SSSV Setting Depth
Date: Thu, 19 Sep 2002 18:23:33 -0500
From: "Francis, Michael J" <Michael.Francis @BP.com>
To: "Tom Maunder (E- mail)" <tom_maunder @admin.state.ak.us>,
"Winton Aubert (E- mail)" <winton_aubert@admin.state.ak.us>
CC: "NSU, ADW WL & Completion Supervisor" < NSUADWWL &CompletionSupervisor @BP.com >,
"NSU, ADW Well Operations Supervisor" < NSUADWWellOperationsSupervisor @BP.com >,
"NSU, ADW Well Integrity Engineer" < NSUADWWe1lIntegrityEngineer @BP.com >,
"Hernandez, Floyd" <HernanF 1 @BP.com>, "Schultz, Mikel" <Mikel.Schultz @BP.com>
Tom /Winton,
BP is exploring the potential benefits of reducing the setting depth of the
SSSVs of future Northstar wells. A reduced setting depth would eliminate
the need to use a SSSV with a balance line. It would also allow the use of
a tubing conveyed valve. Additionally, it would ensure that valves are not
set in a deviated hole section.
As you are aware, AOGCC regulation 20 AAC 25.265 states that "fail -safe
automatic surface - controlled subsurface safety valve (SSSV) system capable
of preventing an uncontrolled flow, unless another type of subsurface valve
with that capability is approved by the commission; this valve must be in
the tubing string and located below the mudline datum or, if permafrost is
present, below the permafrost."
The Permafrost at Northstar, as logged in the Seal A -01 well, exists between
1130' and 1630' subsea. Additionally, there is a slush zone that exists
between 240' and 340' subsea.
Would and under what conditions would the AOGCC entertain an exception to
the "below the permafrost" clause? It is my understanding that there is a
precedent already set Milne Pointe where the valves are set at 500'.
Regards
Mike
Michael J. Francis, P.E.
BP Exploration Alaska, Inc.
Senior Petroleum Engineer
Phone: (907) 564 -4240
Cell: (907) 529 -8678 RECEIVED
Fax: (907) 564 -5200
e -mail: Michael.Francis@bp.com
P.O. Box 196612 NOV 0 7 2002
Anchorage, AK 99519 -6612
Alaska OM Gas Cons. Commission
Anchorage
-4
1 a
LAW OFFICES OF NANCY S. WAINWRIGHT
13030 Back Road, Suite 555
Anchorage , Alaska 99515 -3538
(907) 345 -5595 (telephone)
(907) 345 -3629 (facsimile)
nsw @Alaska.com (e -mail)
October 20, 2002
Alaska Oil and Gas Conservation Commission RECEIVED
333 W. 7th Ave #100
Anchorage, Alaska, 99501 -3539 OCT 2 2 2002 4v'2i,
Re: Request for Hearing A$S tI GdB0011S.
BPXA Exemption to Allow the Setting of Subsurface Safety Valves in MOWS
the Northstar Development
Dear Commissioners:
This request for hearing is submitted in response to the public notice which stated
that "a person may request that a tentatively scheduled hearing be held by filing a written
request with the Commission no later than 4:30 pm on October 22, 2002" for the
BPXA request for an exemption under 20 AAC 35.265(a)(2).
I request that the Commission hold the hearing tentatively set for November 7,
2002.
Thank you for your consideration of this request.
Sincerely,
A'i 11,0 „Ii/U ' 1, t
Nancy S Wainw ig it
NSW:ne
#2
STATE OF ALASKA
NOTICE TO PUBLISHER ~" ADVERTISING ORDER NO.
ADVERTISING INVOICE MUST BE IN TRIPLICATE SHOWING ADVERTISING ORDER NO., CERTIFIED
AFFIDAVIT OF PUBLICATION (PART2 OF THIS FORM)WITH Ag-rACHED COPY OF AO-0231401 8
ORDER ADVERTISEMENT MUST BE SUBMI'I-rED WITH INVOICE
SEE BOTTOM FOR INVOICE ADDRESS
F
' AOGCC AGENCY CONTACT DATE OF A.D.
R 333 W 7th Ave, Ste 100 Jody Colombie October 3, 2002,
o Anchorage, AK 99501 PHONE PCN
M
- (907~ 793-1221
T Anchorage Daily News October 5, 2002
o
P O Box 149001
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R;QUISITIONED BY: ,/~ ~ /r ',~ j / ,,// /,.. ..,,,.~.....,.,~
02-902 (Rev. 3/94) Publisher/Original Copies: Department Fiscal, Department, Receiving AO.FRM
Anchorage Daily News
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STATE OF ALASKA
THIRD JUDICIAL DISTRICT
Amy Heath, being first duly sworn on oath deposes and says that
she is an advertising representative of the Anchorage Daily News, a
daily newspaper.
That said newspaper has been approved by the Third Judicial
Court, Anchorage, Alaska, and it now and has been published in
the English language continually as a daily newspaper in
Anchorage, Alaska, and it is now and during all saidtime was
printed in an office maintained at the aforesaid place of
publication of said newspaper. That the annexed is a copy of an
advertisement as it was published in regular issues (and not in
supplemental form) of said newspaper on the above dates and
that such newspaper was regularly distributed to its subscribers
during all of said period. That the full amount of the fee charged
for the foregoing publication is not in excess of the rate charged
private individuals.
Subscribed and sworn to me before this date:
Notice of Public Hearing
STATE OF ALASKA
. AlasRa Oil and OaS Conservation Commission
Re: Northstar Development Wells, NOrthstar Field
BP Exploration (Alaska), Inc. by letter dated
September 30, 2002, has applied for an exemption
Under 20 AAC 25.265(a)(2) to allOW the setting'of
subsurface safety valves in Northstar develop-
ment wells at a depth of approximately 500 feet
TVD. ' '
The Commission has te~ntatlvely set a public
hearing on this application for November 7, 2002 at.
9:00 am at the Alaska O11 and GaS Cbnservation
Commission at 333 West 7th Avenue, Suite 100, An-
'chorage~ Alaska 99501. A person m.a¥.request that
the tentatively schedul'ed hearing be held by filing
a written request with the Commission no later
:than 4:.30 ~pm on. October 22, 2002.
,
If a request for a hearing is not timely filed,
;r'he Commission will Consider the issuance, of an
order without a hearing. To learn if the Commis-
sion will hold 'the Public hearing, please call
793-1221.. .
..
. In addition, a person may submit written
comments regarding this application to the Alaska
Oil and Gas Conservation Commission at 333 West
7th A~enue, Suite'100, 'Anchorage, Alaska 99501.
,Wi"itten comments must be received :no later than
4:30 pm on November 6, 2002 except that if the
Commission decides to hold a public hearing, writ-
.ten comments must be received no later than 9:00
am on November 7~ 2002.
,
If you are a Person With a disability who may
need a special modificatiOn in order to comment or
to attend the public hearing, please contact Jody
C01ombie at 793-1221. before November 1, 2002.
·
'D~'niel T, seamount, Jr.
Commissioner
Publish: October 5, 2002' '
Notary Public in and for the State of Alaska.
Third Division. Anchorage, Alaska
MY COMMISSION EXPIRES:
STATE OF ALASKA [. NOTICE TO PUBLISHER '~' ADVERTISING ORDER NO.
ADVERTISING INVOICE MUST BE IN TRIPLICATE SHOWING ADVERTISING ORDER NO., CERTIFIED
AFF,DAV,T OF PUBL,CAT,ON (P^RT 2 Or T.,S FO..) W,TH A~AOHED COP~ OF A O-0231 401 8
ORDER ADVERTISEMENT MUST BE SUBMIq-~ED WITH INVOICE
SEE BOTTOM FOR INVOICE ADDRESS
FAOGCC AGENCY CONTACT DATE OFA.O.
R 333 West 7th Avenue. Suite 100 Jodv Colombie October 3_ 2002
O Ar~c']nc~rac~. A~' QQ~(]I PHONE PCN
M - (9073 793-1221
DATES ADVERTISEMENT REQUIRED:
T Anchorage Daily News October 5, 2002
o
? O Box 149001
Anchorage, AK 99514 ~.N~v oN T,~ ~nT~S S~OW~.
SPECIAL INSTRUCTIONS:
Account #STOF0330
AFFIDAVIT OF PUBLICATION
United states of America REMINDER
State of ss INVOICE MUST BE IN TRIPLICATE AND MUST REFERENCE
THE ADVERTISING ORDER NUMBER.
division. A CERTIFIED COPY OF THIS AFFIDAVIT OF PUBLICATION
MUST BE SUBMITTED WITH THE INVOICE.
Before me, the undersigned, a notary public this day personally appeared ATTACH PROOF OF PUBLICATION HERE.
who, being first duly sworn, according to law,
says that he/she is the of
Published at in said division
and state of and that the advertisement, of which
the annexed is a true copy, was published in said publication on the
__ day of 2002, and thereafter fOr
consecutive days, the last publication appearing on the __ day of
,2002, and that the rate charged thereon is not in excess
of the rate charged private individuals.
Subscribed and sworn to before me
This ~ day of 2002,
Notary public for state of
My commission expires
02-901 (Rev. 3/94) AO.FRM
Page 2 PUBLISHER
Notice of Public Hearing
STATE OF ALASKA
Alaska Oil and Gas Conservation Commission
Re: Northstar Development Wells, Northstar Field
BP Exploration (Alaska), Inc. by letter dated September 30, 2002, has applied for
an exemption under 20 AAC 25.265(a)(2) to allow the setting of subsurface safety valves
in Northstar development wells at a depth of approximately 500 feet TVD.
The Commission has tentatively set a public hearing on this application for
November 7, 2002 at 9:00 am at the Alaska Oil and Gas Conservation Commission at
333 West 7th Avenue, Suite 100, Anchorage, Alaska 99501. A person may request that
the tentatively scheduled hearing be held by filing a written request with the Commission
no later than 4:30 pm on October 22, 2002.
If a request for a hearing is not timely filed, the Commission will consider the
issuance of an order without a hearing. To learn if the Commission will hold the public
hearing, please call 793-1221.
In addition, a person may submit written comments regarding this application to
the Alaska Oil and Gas Conservation Commission at 333 West 7th Avenue, Suite 100,
Anchorage, Alaska 99501. Written comments must be received no later than 4:30 pm on
November 6, 2002 except that if the Commission decides to hold a public hearing,
written comments must be received no later than 9:00 am on November 7, 2002.
If you are a person with a disability who may need a special modification in order
to comment or to attend the public hearing, please contact Jody Colombie at 793-1221
before November 1, 2002. ~I~~~~
Daniel T. S~amount, Jr.
Commissioner
Published Date: October 5, 2002
ADN AO# 02314018
John Katz
State of Alaska
Alaska Governor's Office
444 North Capitol St., NW, Ste 336
Washington, DC 20001
Daniel Donkel
2121 North Bayshore Drive, Ste 1219
Miami, FL 33137
SD Dept of Env & Natural Resources
Oil and Gas Program
2050 West Main, Ste 1
Rapid City, SD 57702
Alfred James
107 North Market Street, Ste 1000
Wichita, KS 67202-1822
Christine Hansen
Interstate Oil & Gas Compact Comm
Excutive Director
PO Box 53127
Oklahoma City, OK 73152
Citgo Petroleum Corporation
PO Box 3758
Tulsa, OK 74136
Conoco Inc.
PO Box 1267
Ponca City, OK
74602-1267
Mir Yousufuddin
US Department of Energy
Energy Information Administration
1999 Bryan Street, Ste 1110
Dallas, TX 75201-6801
Mary Jones
XTO Energy, Inc.
Cartography
810 Houston Street, Ste 2000
Ft. Worth, TX 76102-6298
Gregg Nady
Shell E&P Company
Onshore Exploration & Development
PO Box 576
Houston, TX 77001-0576
Michael Nelson
Purvin Gertz, Inc.
Library
600 Travis, Ste 2150
Houston, TX 77002
Paul Walker
Chevron
1301 McKinney, Rm 1750
Houston, TX 77010
G. Scott Pfoff
Aurora Gas, LLC
10333 Richmond Ave, Ste 710
Houston, TX 77042
David McCaleb
IHS Energy Group
GEPS
5333 Westheimer, Ste 100
Houston, TX 77056
G. Havran
Gaffney, Cline & Associations
Library
1360 Post Oak Blvd., Ste 2500
Houston, TX 77056
William Holton, Jr.
Marathon Oil Company
Law Department
5555 San Fecipe St.
Houston, TX 77056-2799
T.E. Alford
ExxonMobil Exploration Company
PO Box 4778
Houston, TX 77210-4778
Texico Exploration & Production
PO Box 36366
Houston, TX 77236
Corry Woolington
ChevronTexaco
Land-Alaska
PO Box 36366
Houston, TX 77236
Chevron USA
Alaska Division
PO Box 1635
Houston, TX 77251
W. Allen Huckabay
Phillips Petroleum Company
Exploration Department
PO Box 1967
Houston, TX 77251
Donna Williams
World Oil
Statistics Editor
PO Box 2608
Houston, TX 77252
Chevron Chemical Company
Library
PO Box 2100
Houston, TX 77252-9987
Shawn Sutherland
Unocal
Revenue Accounting
14141 Southwest Freeway
Sugar Land, TX 77478
Kelly Valadez
Tesoro Refining and Marketing Co.
Supply & Distribution
300 Concord Plaza Drive
San Antonio, TX 78216
James White
Intrepid Prod. Co./Alaskan Crude
4614 Bohill
SanAntonio, TX 78217
Doug Schultze
XTO Energy Inc.
3000 North Garfield, Ste 175
Midland, TX 79705
Robert Gravely
7681 South Kit Carson Drive
Littleton, CO 80122
George Vaught, Jr.
PO Box 13557
Denver, CO 80201-3557
Jerry Hodgden
Hodgden Oil Company
408 18th Street
Golden, CO 80401-2433
John Levorsen
200 North 3rd Street, #1202
Boise, ID 83702
Kay Munger
Munger Oil Information Service, Inc
PO Box 45738
Los Angeles, CA 90045-0738
John F. Bergquist
Babson and Sheppard
PO Box 8279
Long Beach, CA 90808-0279
Samuel Van Vactor
Economic Insight Inc.
3004 SW First Ave.
Portland, OR 97201
Thor Cutler OW-137
US EPA egion 10
1200 Sixth Ave.
Seattle, WA 98101
Michael Parks
Marple's Business Newsletter
117 West Mercer St, Ste 200
Seattle, WA 98119-3960
Richard Mount
State of Alaska
Department of Revenue
500 West 7th Ave., Ste 500
Anchorage, AK 99501
Tim Ryherd
State of Alaska
Department of Natural Resources
550 West 7th Ave., Ste 800
Anchorage, AK 99501
Williams VanDyke
State of Alaska
Department of Natural Resources
550 West 7th Ave., Ste 800
Anchorage, AK 99501
Cammy Taylor
1333 West 11th Ave.
Anchorage, AK 99501
Ed Jones
Aurora Gas, LLC
Vice President
1029 West 3rd Ave., Ste 220
Anchorage, AK 99501
Jim Arlington
Forest Oil
310 K Street, Ste 700
Anchorage, AK 99501
Duane Vaagen
Fairweather
715 L Street, Ste 7
Anchorage, AK 99501
Robert Mintz
State of Alaska
Department of Law
1031 West 4th Ave., Ste 200
Anchorage, AK 99501
Julie Houle
State of Alaskan DNR
Div of Oil & Gas, Resource Eval.
550 West 7th Ave., Ste 800
Anchorage, AK 99501
Susan Hill
State of Alaska, ADEC
EH
555 Cordova Street
Anchorage, AK 99501
Trustees for Alaska
1026 West 4th Ave., Ste 201
Anchorage, AK 99501-1980
Mark Wedman
Halliburton
6900 Arctic Blvd.
Anchorage, AK
99502
John Harris
NI Energy Development
Tubular
3301 C Street, Ste 208
Anchorage, AK 99503
Ciri
Land Department
PO Box 93330
Anchorage, AK
99503
Schlumberger
Drilling and Measurements
3940 Arctic Blvd., Ste 300
Anchorage, AK 99503
Baker Oil Tools
4730 Business Park Blvd., #44
Anchorage, AK 99503
Rob Crotty
C/O CH2M HILL
301 West Nothern Lights Blvd
Anchorage, AK 99503
Jack Laasch
Natchiq
Vice President Government Affairs
3900 C Street, Ste 701
Anchorage, AK 99503
Mark Hanley
Anadarko
3201 C Street, Ste 603
Anchorage, AK 99503
Mark Dalton
HDR Alaska
2525 C Street, Ste 305
Anchorage, AK 99503
Judy Brady
Alaska Oil & Gas Associates
121 West Fireweed Lane, Ste 207
Anchorage, AK 99503-2035
Arlen Ehm
2420 Foxhall Dr.
Anchorage, AK
99504-3342
Greg Noble
Bureau of Land Management
Energy and Minerals
6881 Abbott Loop Rd
Anchorage, AK 99507
Rose Ragsdale
Rose Ragsdale & Associates
3320 E. 41st Ave
Anchorage, AK 99508
Paul L. Craig
Trading Bay Energy Corp
5432 East Northern Lights, Ste 610
Anchorage, AK 99508
Richard Prentki
US Minerals Management Service
949 East 36th Ave., 3rd Floor
Anchorage, AK 99508
Thomas R. Marshall, Jr.
1569 Birchwood Street
Anchorage, AK 99508
Jill Schneider
US Geological Survey
4200 University Dr.
Anchorage, AK 99508
Jim Scherr
US Minerals Management Service
Resource Evaluation
949 East 36th Ave., Ste 308
Anchorage, AK 99508
Jeff Walker
US Minerals Management Service
Regional Supervisor
949 East 36th Ave., Ste 308
Anchorage, AK 99508
Chuck O'Donnell
Veco Alaska,Inc.
949 East 36th Ave., Ste 500
Anchorage, AK 99508
Gordon Severson
3201 Westmar Cr.
Anchorage, AK 99508-4336
Jim Ruud
Phillips Alaska, Inc.
Land Department
PO Box 100360
Anchorage, AK 99510
Kristen Nelson
IHS Energy
PO Box 102278
Anchorage, AK
99510-2278
Perry Markley
Alyeska Pipeline Service Company
Oil Movements Department
1835 So. Bragaw- MS 575
Anchorage, AK 99515
Jordan Jacobsen
Alyeska Pipeline Service Company
Law Department
1835 So. Bragaw
Anchorage, AK 99515
Robert Britch, PE
Northern Consulting Group
2454 Telequana Dr.
Anchorage, AK 99517
David Cusato
600 West 76th Ave., #508
Anchorage, AK 99518
Jeanne Dickey
BP Exploration (Alaska), Inc.
Legal Department
PO Box 196612
Anchorage, AK 99518
Peter McKay
BP Exploration (Alaska), Inc.
BP P7
PO Box 196193
Anchorage, AK 99519
Tesoro Alaska Company
PO Box 196272
Anchorage, AK 99519
J. Brock Riddle
Marathon Oil Company
Land Department
PO Box 196168
Anchorage, AK 99519-6168
Kevin Tabler
Unocal
PO Box 196247
Anchorage, AK
99519-6247
Sue Miller
BP Exploration (Alaska), Inc.
PO Box 196612
Anchorage, AK 99519-6612
BP Exploration(Alaska),lnc.
Land Manager
PO Box 196612
Anchorage, AK 99519-6612
Dudley Platt
D.A. Platt & Associates
9852 Little Diomede Cr.
Eagle River, AK 99577
Bob Shavelson
Cooklnlet Keeper
PO Box 3269
Homer, AK '99603
Shannon Donnelly
Phillips Alaska, Inc.
HEST-Enviromental
PO Box 66
Kenai, AK 99611
Kenai Peninsula Borough
Economic Development Distr
PO Box 3029
Kenai, AK 99611
Penny Vadla
Box 467
Ninilchik, AK
99639
Claire Caldes
US Fish &Wildli~ Service
Kenai Refuge
PO Box 2139
Soldotna, AK 99669
James Gibbs
PO Box 1597
Soldotna, AK
99669
Kenai National Wildlife Refuge
Refuge Manager
PO Box 2139
Soldotna, AK 99669-2139
John Tanigawa
Evergreen Well Service Company
PO Box 871845
Wasilla, AK 99687
Richard Wagner
PO Box 60868
Fairbanks, AK 99706
Cliff Burglin
PO Box 131
Fairbanks, AK 99707
Harry Bader
State of Alaska
Department of Natural Resources
3700 Airport Way
Fairbanks, AK 99709
Bernie Kad
K&K Recycling Inc.
PO Box 58055
Fairbanks, AK 99711
North Slope Borough
PO Box 69
Barrow, AK 99723
Williams Thomas
Arctic Slope Regional Corporation
Land Department
PO Box 129
Barrow, AK 99723
Senator Loren Leman
State Capitol Rm 113
Juneau, AK 99801-1182
Re: Amended Notice of Public Hearing
Subject: Re: Amended Notice of Public Hearing
Date: 03 Oct 2002 14:26:23 -0800
From: Amy Heath <aheath~adn.com>
To: <j ody_colombie@admin.state.ak.us>
__
Account Number: STOF0330
Legal Ad Number: 593675 (amended public notice)
Run Dates: October 5, 2002
Total Amount: $134.26
Thanks Jody! :)
Amy L. Heath
Legal Customer Service Representative
Phone: (907) 257-4296
Fax: (907) 279-8170
Office Hours 8:00am - 5:00pm
aheath@adn.com
On Thursday, October 3, 2002, jody_colombie@admin.state.ak.us wrote:
>Amy:
>
>Please toss the last public notice I sent you and replace it
>wi th this
>one. Jody
1 of 1 10/3/2002 2:57 PM
#1
bp
Michael J. Francis, P.E.
Senior Petroleum Engineer
Northstar
BP Exploration (Alaska) Inc.
900 East Benson Boulevard
P.O. Box 196612
Anchorage, Alaska 99519-6612
(907) 561-5111
September 30, 2002
Winton Aubert
Alaska Oil & Gas Conservation Commission
333 West 7th Avenue Suite 100
Anchorage, AK 99501
Phone: (907) 564-4240
Fax: (907) 564-5200
Email Michael. Francis@bp.corn
Web: www.bp.com
RE: Northstar SSSV Setting Depth
Dear Winton:
BP Exploration (Alaska)Inc. seeks an exemption to a portion of AOGCC
regulation 20 AAC 25.265 (a)(2). This regulation states that "A completed
well with an offshore surface location and that is capable of unassisted
flow of hydrocarbons to the surface, must be equipped with a commission
approved fail-safe automatic surface-controlled subsurface safety valve
(SSSV) system capable of preventing an uncontrolled flow, unless another
type of subsurface valve with that capability is approved by the
commission; this valve must be in the tubing string and located below the
mudline datum or, if permafrost is present, below the permafrost." BP
seeks permission to set SSSVs above the base of the permafrost.
The Permafrost at Northstar, as logged in the Seal A-01 well, exists
between 1130' and 1630' subsea. Additionally, there is a slush zone that
exists between 240' and 340' subsea. The current wells at Northstar have
the SSSVs set at 2000' TVD, below the permafrost.. The combination of
this setting depth and the available hydraulic system pressure limits the
types of SSSVs that can be used at Northstar and precludes the use of
tubing conveyed SSSVs. Tubing conveyed SSSVs are the industry
standard and are not prone to the packing leaks common to wireline
retrievable valves such as those in the current Northstar wells. Packing
leaks and other problems with the SSSVs at Northstar have necessitated
extensive well intervention activity.
RECEIVED
SEP 3o, 2002
Alaska Off,& Gas (:Ions. Commlssio[~
Anchorage
Winton Aubert
Northstar SSSV Setting Depth
September 30, 2002
BP proposes to raise the allowable SSSV setting depth to 500' TVD. This
depth will allow for the use of tubing retrievable SSSVs. This type of valve
should provide greater reliability and reduce well interventions in future
Northstar wells.
Sincerely,
Senior PCt, foleum Engineer
CC:
John Garing
Mikel Schultz
Floyd Hernandez
Steve Rossberg
John Smart/Gary McBride
Doug Cismoski/Jerry Middendorf
File
