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Home My WebLink AboutCO 333Conservation Order Cover Page XHVZE This page is required for administrative purposes in managing the scanning process. It marks the extent of scanning and identifies certain actions that have been taken. Please insure that it retains it's current location in this file. ~.._~_.~_ Conservation Order Category Identifier Organizing I~o~) RESCAN [] Color items: [] Grayscale items: [] Poor Quality Originals: [] Other: NOTES: DIGITAL DATA [] Diskettes, No. [] Other, No/Type OVERSIZED (Scannable with large plotter/scanner) [] Maps: [] Other items OVERSIZED (Not suitable for plotter/scanner, may work with 'log' scanner) [] Logs of various kinds [] Other BY: ~ MARIA Scanning Preparation DATE: L~ F¢&,--~ /S/'~ ~"~ TOTALPAGES ~L/ Production Scanning Stage I PAGE COUNT FROM SCANNED DOCUMENT: PAGE COUNT MATCHES NUMBER IN SCANNING PREPARATION: YES ~ NO Stage 2 IF NO IN STAGE 1, PAGE(S) DISCREPANCIES WERE FOUND: ~ YES __ NO General Notes or Comments about this Document: 5/21/03 ConservOrdCvrPg.wpd s • INDEX CONSERVATION ORDER NO. 333 1.) August 19, 1993 Letter from ARCO Requesting to Modify Rule No.S CO 145 2.) December 3, 1993 Note to File 3.) December 17, 1993 Notice of Public Hearing, Affidavit of Publication 4.) February 18, 1994 Conservation Order from AOGCC to Operators 5.) March 8, 1994 BP Comments of Draft Conservation Order No.331 6.) June 3, 1994 ARCO Meeting Memorandum Conservation Order No. 333 STATE OF ALASKA OIL AND GAS CONSERVATION COMMISSION 3001 Porcupine Drive Anchorage, Alaska 99501-3192 Re~ The Application of Arco Alaska Inc. and ) BP Exploration (Alaska) Inc. requesting a ) modification to Rule 5, Conservation Order ) 145, dealing with safety valve requirements. ) Conservation Order No. 333 Prudhoe Bay Field Prudhoe Oil Pool April 15, 1994 (Rev. April 28, 1994) IT APPEARING THAT 1. By letter dated August 19, 1993, Arco Alaska, Inc. and BP Exploration (Alaska) Inc. requested modifications to Rule 5, Conservation Order 145. 2. By letter dated September 22, 1993, the Commission requested the operators to consider delaying action on the request until pool rules for the Prudhoe Pool had been consolidated. 3. Upon the applicants' request, the Commission agreed to pursue changes to Rule 5, Conservation Order 145, before consolidating pool rules for the Prudhoe Pool. 4. A notice of opportunity for public hearing was published in the Anchorage Daily News on December 17, 1993. 5. No protests were filed with the Commission. FINDINGS: . The Commission may require surface safety valves (SSV's) or subsurface .safety valves (SSSV's), or both, on wells in all areas after notice and an opportunity for hearing. 20 AAC 25.265. . Rule 5, Conservation Order No. 145, requires Prudhoe Bay wells to be equipped with a suitable safety valve installed below the base of the permafrost which will automatically shut in the well if an uncontrolled flow occurs. 3. Prudhoe Bay operators historically have installed both SSV's and SSSV's in Prudhoe Bay oil pool wells. . Rules regarding safety valve systems are in place for the Kuparuk River, Lisburne, Schrader Bluff, Pt. Mclntyre/Stump Island, Niakuk and West Beach oil pools and by regulation for Endicott oil pool. The regulations (20 AAC 25.265) or rules for these pools require both SSV's and SSSV's in wells capable of unassisted flow. Conservation Order 333 Prudhoe Oil Pool Page 2 April 15, 1994 (Rev. April 28, 1994) 5. The primary purpose of the safety valve system is to prevent uncontrolled flow of hydrocarbons. 6. The SSSV must occassionally be removed to allow passage of certain equipment and performance of well maintenance. 7. Conservation Order No. 258 waived the requirements of 20 AAC 25.280(a) for Prudhoe oil pool wells. CONCLUSIONS Amending Rule 5, Conservation Order No. 145, to require both SSV's and SSSV's is appropriate and will make this rule consistent with similar rules for other pools on the North Slope. . Since Prudhoe Bay operators have previously installed both SSV's and SSSV's in Prudhoe Bay oil pool wells, no hardship will be imposed on the operators by amending Rule 5 to require surface safety valves. o Temporary removal of SSSV's to allow passage of certain equipment and performance of well maintenance is a reasonable operational requirement and is in keeping with sound engineering practices. 4. Temporary removal periods need to be defined and a tracking system established to prevent indefinite removal of SSSV's and ensure accountability for their status. . Prior approval from the Commission to temporarily remove SSSV's is not necessary if appropriate posting and tracking requirements are adopted and temporary removal periods are defined. 6. With appropriate posting and tracking requirements, temporary removal of SSSV's may occur without causing waste, jeopardizing correlative rights or harming ultimate recovery. 7. Wells that are demonstrated to be incapable of unassisted flow of hydrocarbons do not require a SSSV. 8. Wells used for continuous water injection are incapable of unassisted flow of hydrocarbons. 9. Permanent removal of SSSV's from wells incapable of unassisted flow of hydrocarbons will not cause waste nor jeopardize correlative rights. Conservation Order 333 Prudhoe Oil Pool Page 3 April 15, 1994 (Rev. April 28, 1994) NOW, THEREFORE, IT IS ORDERED THAT Rule 5, Conservation Order No. 145, is amended to read: Rule 5 Automatic Shut In Equipment a. Upon completion, each well shall be equipped with: i. a fail-safe automatic surface safety valve (SSV) capable of preventing uncontrolled flow. ii. a fail-safe automatic subsurface safety valve (SSSV), unless other types of subsurface valve are approved by the Commission, installed in the tubing string below the base of permafrost and capable of preventing uncontrolled flow. bo A well that is not capable of unassisted flow of hydrocarbons, as determined by a "no flow" performance test witnessed by a Commission representative, is not required to have a fail- safe automatic SSSV. Co Subsurface safety valves may be temporarily removed for not more than 30 days as part of routine well operations or repair without specific notice to, or authorization by the Commission. i. Written notification will be required for those wells that will have SSSV's removed longer than the 30 day period. ii. Wells with SSSV's removed shall be identified by a clearly visible sign or tag on the wellhead stating that the valve has been removed, reason for removal and the date of removal. iii. A list of wells with SSSV's removed, removal dates, reasons for removal, and estimated reinstallation dates must be maintained current and available for Commission inspection on request. do The Low Pressure Sensor (LPS) systems shall not be deactivated except during repairs to the LPS, while engaged in active well work or well operations. During times when the LPS is deactivated, the pad must be manned at all times or the well shut-in at the wellhead and manifold building. Repairs to the LPS must be completed within 24 hours or the well must be shut-in at the well head and at the manifold building. i. Wells with a deactivated LPS shall be identified by a clearly visible sign or tag on the safety valve control panel stating the date the LPS was deactivated. ii. A list of wells with the LPS deactivated, the dates and reasons for deactivating, and the estimated re-activation dates must be maintained current and available for Commission inspection on request. Conservation Order 333 Prudhoe Oil Pool Page 4 April 15, 1994 (Rev. April 28, 1994) e. The safety valve systems must be maintained in working condition at all times unless the well is shut in and secured, or the well is being operated in conformance with other sections of this rule. Upon proper application or its own motion, the Commission may administratively waive or amend the requirements of this rule as long as the change does not promote waste, jeopardize correlative rights or compromise ultimate recovery, and is based on sound engineering principles. g. A representative of the Commission will witness performance tests as prescribed by the Commission to confirm that the SSV, SSSV and all associated equipment are in proper working condition. DONE at Anchorage, A1 ,1994). David W~hn~ton, ~-'~i-rma~' Russell A. Douglass, Commissioner --Tuckerman Babcock, '~ommissioner AS 31.05.080 provides that within 20 days after receipt of written notice of the entry of an order, a person affected by it may file with the Commission an application for rehearing. A request for rehearing must be received by 4:30 PM on the 23rd day following the date of the order, or next working day ifa 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., 10th day after the application for rehearing was filed). STATE OF ALASKA OIL AND GAS CONSERVATION COMMISSION 3001 Porcupine Drive Anchorage, Alaska 99501-3192 The Application of Arco Alaska Inc. and ) BP Exploration (Alaska) Inc. requesting a ) modification to Rule 5, Conservation Order ) 145, dealing with safety valve requirements. ) Conservation Order No. 333 Prudhoe Bay Field Prudhoe Oil Pool April 15, 1994 IT APPEARING THAT 1. By letter dated August 19, 1993, Arco Alaska, Inc. and BP Exploration (Alaska) Inc. requested modifications to Rule 5, Conservation Order 145. 2. By letter dated September 22, 1993, the Commission requested the operators to consider delaying action on the request until pool rules for the Prudhoe Pool had been consolidated. 3. Upon the applicants' request, the Commission agreed to pursue changes to Rule 5, Conservation Order 145, before consolidating pool rules for the Prudhoe Pool. 4. A notice of opportunity for public hearing was published in the Anchorage Daily News on December 17, 1993. 5. No protests were filed with the Commission. FINDINGS: o The Commission may require surface safety valves (SSV's) or subsurface safety valves (SSSV's), or both, on wells in all areas after notice and an opportunity for hearing. 20 AAC 25.265. . Rule 5, Conservation Order No. 145, requires Prudhoe Bay wells to be equipped with a suitable safety valve installed below the base of the permafrost which will automatically shut in the well if an uncontrolled flow occurs. 3. Prudhoe Bay operators historically have installed both SSV's and SSSV's in Prudhoe Bay oil pool wells. . Rules regarding safety valve systems are in place for the Kuparuk River, Lisburne, Schrader Bluff, Pt. Mclntyre/Stump Island, Niakuk and West Beach oil pools and by regulation for Endicott oil pool. The regulations (20 AAC 25.265) or rules for these pools require both SSV's and SSSV's in wells capable of unassisted flow. Conservation Order 333 Prudhoe Oil Pool Page 2 April 15, 1994 5. The primary purpose of the safety valve system is to prevent uncontrolled flow of hydrocarbons. 6. The SSSV must occassionally be removed to allow passage of certain equipment and performance of well maintenance. 7. Conservation Order No. 258 waived the requirements of 20 AAC 25.280(a) for Prudhoe oil pool wells. CONCLUSIONS Amending Rule 5, Conservation Order No. 145, to require both SSV's and SSSV's is appropriate and will make this rule consistent with similar rules for other pools on the North Slope. . Since Prudhoe Bay operators have previously installed both SSV's and SSSV's in Prudhoe Bay oil pool wells, no hardship will be imposed on the operators by amending Rule 5 to require surface safety valves. o Temporary removal of SSSV's to allow passage of certain equipment and performance of well maintenance is a reasonable operational requirement and is in keeping with sound engineering practices. 4. Temporary removal periods need to be defined and a tracking system established to prevent indefinite removal of SSSV's and ensure accountability for their status. Prior approval from the Commission to temporarily remove SSSV's is not necessary if appropriate posting and tracking requirements are adopted and temporary removal periods are defined. 6. With appropriate posting and tracking requirements, temporary removal of SSSV's may occur without causing waste, jeopardizing correlative rights or harming ultimate recovery. 7. Wells that are demonstrated to be incapable of unassisted flow of hydrocarbons do not require a SSSV. 8. Wells used for continuous water injection are incapable of unassisted flow of hydrocarbons. 9. Permanent removal of SSSV's from wells incapable of unassisted flow of hydrocarbons will not cause waste nor jeopardize correlative rights. Conservation Order 333 Page 3 Prudhoe Oil Pool April 15, 1994 NOW, THEREFORE, IT IS ORDERED TItAT Rule 5, Conservation Order No. 145, is amended to read: Rule 5 Automatic Shut In Equipment a. Upon completion, each well shall be equipped with: i. a fail-safe automatic surface safety valve (SSV) capable of preventing uncontrolled flow. ii. a fail-safe automatic subsurface safety valve (SSSV), unless other types of subsurface valve are approved by the Commission, installed in the tubing string below the base of permafrost and capable of preventing uncontrolled flow. bo A well that is not capable of unassisted flow of hydrocarbons, as determined by a "no flow" performance test witnessed by a Commission representative, is not required to have a fail- safe automatic SSSV. c. Safety valves may be temporarily removed for not more than 30 days as part of routine well operations or repair without specific notice to, or authorization by the Commission. i. Written notification will be required for those wells that will have SSV's removed longer than the 30 day period. ii. Wells with SSV's or SSSV's removed shall be identified by a clearly visible sign or tag on the wellhead stating that the valve has been removed, reason for removal and the date of removal. iii. A list of wells with SSV's or SSSV'S removed, removal dates, reasons for removal, and estimated reinstallation dates must be maintained current and available for Commission inspection on request. do The Low Pressure Sensor (LPS) systems shall not be deactivated except during repairs to the LPS, while engaged in active well work or well operations. During times when the LPS is deactivated, the pad must be manned at all times or the well shut-in at the wellhead and manifold building. Repairs to the LPS must be completed within 24 hours or the well must be shut-in at the well head and at the manifold building. i. Wells with a deactivated LPS shall be identified by a clearly visible sign or tag on the safety valve control panel stating the date the LPS was deactivated. ii. A list of wells with the LPS deactivated, the dates and reasons for deactivating, and the estimated re-activation dates must be maintained current and available for Commission inspection on request. Conservation Order 3 3 3 Prudhoe Oil Pool Page 4 April 15, 1994 e. The safety valve systems must be maintained in working condition at all times unless the well is shut in and secured, or the well is being operated in conformance with other sections of this rule. Upon proper application or its own motion, the Commission may administratively waive or amend the requirements of this rule as long as the change does not promote waste, jeopardize correlative fights or compromise ultimate recovery, and is based on sound engineering principles. g, A representative of the Commission will witness performance tests as prescribed by the Commission to confirm that the SSV, SSSV and all associated equipment are in proper working condition. DONE at Anchorage, David W.-~Y6h~-~rman Russell A. Douglass, Iruckerman Babcock, Commissioner AS 31.05.080 provides that within 20 days after receipt of written notice of the entry of an order, a person affected by it may file with the Commission an application for rehearing. A request for rehearing must be received by 4:30 PM on the 23rd day following the date of the order, or next working day ifa 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., 10th day after the application for rehearing was filed). ARCO Alaska, Inc. Date: Subject: From/Location: Telephone: To/Location: Attendees: AOGCC: ARCO: BPX: June 3, 1994 SVS Requirements for Prudhoe 5/19/94 Meeting with AOGCC M. L. Bill- ATO 1528 263-4254 A. J. Whitehead - ATO 1676 Internal Correspondenc~~~_ File Code: B. Wondzell, J. Hartz, J. Spalding, B. Fisher, D. Amos J. Whitehead, M. Shoemake, M. Bill F. Hoffer, E. Walker, S. Farris, R. Frazier The PBU operators requested a meeting with AOGCC staff and field inspectors to discuss the Safety Valve System requirements in light of the recently issued Conservation Order 333, Automatic Shut-In Equipment and the AOGCC Policy on SVS Failures, amended 3/30/94. The meeting was held at the AOGCC office on May 19, 1994. It was very cordial with John Whitehead introducing each question and Blair Wondzell giving the AOGCC's viewpoint with input from other AOGCC personnel. John Whitehead began the meeting by stating that the purpose was to gain a mutual understanding of the recent changes, to clear up confusion in several areas, to discuss ways to increase communication and to share the status of ARCO's and BP's efforts to comply with the new rules. To provide background, Blair Wondzell indicated the PB operators originally presented the use of SSSV"s in field rules hearings as a way to improve well safety and the Commission accepted that recommendation. The intent of the Policy is to fulfill the AOGCC's oversight responsibility and to help the operators get their money's worth from the equipment. The AOGCC sought extensive industry input in preparing the original AOGCC Policy on SVS Failures, and the amended version has not changed very much. The AOGCC supports and encourages industry comment and input to get to the best workable polices. Listed below are the specific questions discussed and the AOGCC responses. Attached are copies of Conservation Order 333 and the amended Policy for reference. A. J. Whitehead June 3, 1994 Page 2 I. C.O. 333, Automatic Shut-In Equipment Are there any specific guidelines for notification if a SSSV will be removed for longer than 30 days? (Rule 5, c i) The AOGCC endorsed the following proposal to satisfy the notification requirement: Each operator will prepare and submit a snapshot status report every two weeks. The report will list those wells which have had valves removed for longer than the 30 days. It will also include the reason for removal, the date of removal, and the estimated date the valve will be reinstalled. The report should be faxed to David Johnston, in care of Blair Wondzell. The list also needs to be up to date and available onsite. Both operators indicated that the current systems can accommodate this requirement. BP has already submitted a list containing about 23 wells. Must the sign or tag indicating that the SSSV has been removed be placed on the wellhead, or may it be placed on the safety panel? {Rule 5, c ii) The AOGCC will allow the term "wellhead" to include the panel, because the panel is normally the focus of attention when entering the well house and is the usual location to find safety related tags. Following well work, we sometimes have difficulty getting wells to flow and must have the LPS disabled until they kickoff. Could a waiver be granted to the requirement that the pad be manned in these situations? {Rule 5, d) At this point, the AOGCC does not intend to define the term "manned". Operator personnel must exercise due care, be aware of the situation with the well and keep a close watch on it. The purpose of the requirement is to have a workable system that is not an undue burden on either the operator or the AOGCC. Note: In a follow-up call to John Whitehead, Blair Wondzell requested that the operators develop a working definition of "manned" for compliance with this rule. This was after reviewing the ARCO Prudhoe Bay EOA Drill Site Operating Procedures (March, 1994) and noting that under Wellhead Safety System Operations, "the Drill Site must be continuously manned or the well must be shut in at the wellhead ( - - ) and IGV." Does the requirement that LPS repairs be completed within 24 hours only refer to LPS repair/maintenance activities? (Rule 5 d) If the LPS is broken, the 24 hours applies. If the LPS is out of service due to well operations in progress or other well problems, then the well can flow longer than 24 hours subject to the requirements of the rule. A. J. Whitehead June 3, 1994 Page 3 Is any notification required to remove SSSV's in continuous water injectors? (Conclusions 7&8) Operators should provide a list of water injectors which are not subject to WAG and which, if capable of flowing at all, will only flow water. The list should be sent to David Johnston, to the attention of Blair Wondzell, With a copy forwarded to the inspectors. The inspectors will then know that those wells do not need to be on the inspection list. A Form 10-403 Sundry may be also be required, but not at this time. II. AOGCC Policy on SVS Failures Could the "single point of contact" for SVS monitoring, testing and data gathering be a single contact for each Flow Station area? (Policy # 1) Ongoing efforts to streamline operations to gain efficiency may involve a redistribution of responsibilities within the operating groups. The intent of the single point of contact Is to provide a representative that the inspector can contact ff questions arise regarding a test and to handle other concerns. ARCO is seriously considering turning over the responsibility for the testing of the SVS systems 'to the Drill Site Supervisors, who would then become the single point contacts for each Flow Station Area. If there is a problem, the next level is the FS Superintendent. The inspectors agreed that the DS Supervisors in the EOA are a better choice for the point contact because they have operational responsibility and control over the wells. A list of responsible parties should be sent to the AOGCC when the transition takes place. NO changes to the two WOA point contacts are planned at this time. The AOGCC does not intend to witness 100% of the tests, but is currently exceeding their policy of 25%. The inspectors voiced a concern about DS. operators having responsibility for the test verification. Abuse of the system could put everyone in a bad situation. ARCO suggested the Lead Operators for verification, which was acceptable to the AOGCC. The operators offered their data bases (when complete) to the inspectors to help streamline record keeping. ARCO is developing a 4D data base and BPX is using Ftc Maker Pro. Clarify the intent of the requirement to test SSSV's in wells which were SI for the previous six months, within 48 hours after being brought on production. (Policy #2) Why was the requirement changed from one month? The AOGCC is concern that a well could be shut-in on such a schedule that it is always unavailable during the normal six month cycle of testing. They do not want to bring wells on Just to test, but do want a test soon after the well is available. The AOGCC agreed that until a well warms up and stabilizes, it A. d. Whitehead June 3. 1994 Page 4 should not be tested. The test should be performed within 48 hours after stabilization. The inspectors asked if there are plans to place a flag in the EOA automation system so that the Eastern Operations Center (EOC) is aware of the need for a test. The current plan is to forward all test dates to the EOC to insure compliance. In the WOA, the tracking is currently done manually by those responsible for testing. Clarify the intent of the failure criteria on LPS pilot trip pressures in Policy #5. A new item was added, "25% of the flowing tubing pressure". The AOGCC's goal is to develop a simple set of requirements to insure that the LP pilot will trip at a sufficiently high pressure so the well will shut in if there is a flowline break. The "25% of FTP" requirement was added because a well with a very high FTP could be flowing into a LP system. In that case, under the other criteria, only a very low LPS trip pressure would be required. BP has standardized on two pilot settings, 125 and 550 psi, and asked ff intent was to require third, higher pilot setting for wells which flow above 2200 psi. BP will forward data on those wells and the AOGCC will evaluate their policy in light of this information. ARCO currently uses three pilot settings for producers and can comply with the policy with no changes. III. Potential streamlining opportunities beneficial to operators and AOGCC Reporting procedures The AOGCC is very interested in electronic data transfer for reports and to assist in maintaining databases for tracking purposes. Notification procedures/schedules for testing The inspectors have difficulty trying to cover high levels of testing simultaneously across the slope. They prefer a schedule which spreads out the testing, Testing Procedures No changes are needed in test procedures at this time. IV. Potential meeting between the AOGCC NS Inspectors and NS Operations The AOGCC endorsed a meeting on the slope with key operating personnel. It was proposed that topics for discussion be submitted in advance. The meeting will be scheduled at least one month after the EOA DS Supervisors take responsibility for the testing, probably in late summer. A. J. Whitehead June 3, 1994 Page 5 A copy of this documentation reviewed by the AOGCC to verify its accuracy. The AOGCC will consider these questions in future revisions to the Policy on SVS Failures. If you have any questions, please contact me or any of the attendees. M. L. Bill Sr. Staff Engineer MLB2/002 cc: Attendees from ARCO and BPX AOGCC: ~B~air Wondzell ARCO: ~ R. R. Bowden- ATO 1526 D. F. Scheve - ATO 1576 H. W. Johnson/L. C. Gurule - PRB 10 $. J. Glaser/W. W. Patterson - PRB 15 J. Fausett/S. Piggott- PRB 13 D. W. Cooper/R. M. Lance - PRB 24 J. H. Roam/G. W. From- PRB 19 R. M. Lemon/C. P. Foerster- PRB 16 J. Winters - PRB 20 BPX: C. J. Phillips RECEIVED JUN - 7 Alaska Oil & Gas Cons. Commission Anchorage BP EXPLORATION ARCO Alaska, Inc. March 8, 1994 RECEIVED Mr. David W. Johnston Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501-3192 rV P,R - 8 1994 ^iaska 0il & 6as Cons. Commission Anchorage Re: Comments on Draft Conservation Order No. 331 Modifying Conservation Order 145, Rule 5: Automatic Shut In Equipment Dear Mr. Johnston, Thank you for the opportunity to review and comment on draft Conservation Order No. 331. We also appreciate your consideration of our verbal comments concerning the recent Niakuk rule governing automatic shut-in equipment. We offer the following comments and suggestions. Suggested revisions are shown in italics. Page 1, Finding 1: C.Oo 145, Rule 5 does not currently address surface safety valves (SSV's). We suggest the Finding read: "Rule 5 of Conservation Order No. 145 requires subsurface safety valves be installed in Prudhoe Oil Pool wells." Page 2, Conclusion 1' We suggest the conclusion be reworded as follows: "Requiring specific notice and approval from the Commission prior to temporary removal of SSSV's for routine maintenance and well work would impose significant burden on the Commission without commensurate benefit." Page 2, Rule 5 a. ii. After further consideration, we request the required minimum SSSV setting depth be changed to be consistent with the required depth within the Kuparuk River Pool. This change would allow additional flexibility for future completions. We suggest this section be worded as follows: "a fail-safe automatic subsurface safety valve (SSSV), unless other types of subsurface valves are approved by the Commission, shall be installed in the tubing string at a depth of 500 feet or greater below ground level and be capable of preventing uncontrolled flow." Page 2, Rule 5 b. To clarify that a water injection well does not require a SSSV, we suggest the following: "A well that is incapable of unassisted flow of hydrocarbons, as determined by a "no flow" performance test witnessed by a Commission representative, is not required to have a fail-safe automatic SSSV. Wells used for continuous water injection are incapable of unassisted flow of hydrocarbons." Co-Operators, Prudhoe Bay Unit BP Exploration (Alaska) Inc. Post Office Box 196612 Anchorage, Alaska 99519-6612 Telephone (907) 561-5111 ARCO Alaska, Inc. Post Office Box 100360 Anchorage, Alaska 99510-0360 Telephone (907) 276-1215 · D. W. Johnston March 8, 1994 Page 2 Page 2, Rule 5 c. i. To account for unforeseen circumstances near the 30 day limit, we suggest the following wording: "Written or verbal notification will be required for those wells that will have SSSV's removed for longer than the 30 day period." Page 3, Rule 5 c. ii. To allow the use of our current tagging system, we suggest the following wording: "... shall be identified by a clearly visible sign or tag on the wellhead ..." Page 3, Rule 5 d. We suggest the following wording for clarification: "The Low Pressure Sensor (LPS) system shall not be deactivated except during repairs to the LPS or while engaged in active well work or well operations. During times when the LPS is deactivated, the pad must be manned at all times or the well shut-in at the wellhead and manifold building. Repairs to the LPS must be completed within 24 hours or the well shut-in at the wellhead and at the manifold building." Page 3, Rule 5 d. i To allow the use of our current tagging system, we suggest the following wording: "... shall be identified by a clearly visible sign or tag on the wellhead or safety panel..." Page 3, Rule 5 e. For clarity, we suggest the following: - Move this section to the Rule 5 b location renumber and reword as follows: "The safety valve systems must be maintained in working condition at all times unless the well is shut in and secured, or the well is being operated in conformance with other sections of this rule." If you have any questions concerning the above comments, we would be happy to meet with you at your convenience. Sincerely, C. J. Phillips Manager, PBU Operations Engineering BP Exploration, (Alaska), Inc. D. F. Scheve Manager, PB Operations Engineering ARCO Alaska, Inc. MAR - 8 i994 Alaska OiJ & Gas Cons. Commission Anchorage ALASKA OIL AND GAS CONSERVATION COMMISSION WALTER J. HICKEL, GOVERNOR 3001 PORCUPINE DRIVE ANCHORAGE, ALASKA 99501-3192 PHONE: (907) 279-1433 TELECOPY: (907) 276-7542 February 18, 1994 C. J. Phillips BP Exploration, Inc. P.O. Box 196612 Anchorage, Ak. 99519-6612 D. F. Scheve Arco Alaska, Inc P.O. Box 100360 Anchorage, Ak. 99510-0360 Dear Gentlemen: Enclosed, please find a draft conservation order addressing your request to modify Rule 5, CO 145. The new rule is patterned after a similar rule written for the Niakuk Pool last month. Because we have received informal comments to the Niakuk rule governing SSSV's at the staff level, we felt you should have an opportunity to review and comment on the proposed new rule. Our intent is to define a time limit for temporary removal of SSSV's and maintain accountability for the valves that are removed. Our goal is to derive an effective rule and reporting system that will allow operators latitude and yet keep the AOGCC informed. This can be accomplished without requiring burdensome paperwork. ~ We ask that you forward any comments and suggestions to the Commission within two weeks. We look forward to your response. David W.~ Johnston\ ~ai;man~ STATE OF ALASKA OIL AND GAS CONSERVATION COMMISSION 3001 Porcupine Drive Anchorage, Alaska 99501-3192 Re: The Application of Arco Alaska Inc., and BP Exploration (Alaska) Inc., requesting a modification to Rule 5, Conservation Order 145, dealing with surface and subsurface safety valve requirements. ) Conservation Order No. 331 ) DRAFT ) Prudhoe Bay Field ) Pmdhoe Oil Pool ) February 17, 1994 IT APPEARING THAT 1. By letter dated August 19, 1993, Arco Alaska, Inc. and BP Exploration (Alaska) Inc. requested modifications to Rule 5, Conservation Order 145. , By letter dated September 22, 1993, the Commission requested the operators to consider delaying action on the request until pool rules for the Prudhoe Pool had been consolidated. 3. Upon the applicants' request, the Commission agreed to pursue changes to Rule 5, Conservation Order 145 prior to consolidation of pool rules for Prudhoe Bay. 4. A notice of opportunity for public hearing was published in the Anchorage Daily News December 17, 1993. 5. No protests were filed with the Commission. FINDINGS: 1. Rule 5 of Conservation Order No. 145 requires subsurface and surface safety valves be installed in Prudhoe oil pool wells. . Rules regarding safety valve systems are in place for the Endicott oil pool, Kuparuk River oil pool, Lisburne oil pool, Schrader Bluff oil pool, Pt. Mclntyre/Stump Island oil pools, Niakuk oil pool and West Beach oil pool. 3. The primary purpose of the safety valve system is to prevent uncontrolled flow of hydrocarbons. 4. To allow passage of certain equipment and performance of well maintenance, the subsurface safety valve (SSSV) must be removed temporarily 5. Conservation Order No. 258 waived the requirements of 20 AAC 25.280(a) for Prudhoe oil pool wells. /)raft Conservation Order 33'~ Prudhoe Oil Pool Page 2 February 17, 1994 CONCLUSIONS o Temporary removal of SSSXPs for routine maintenance and well work without specific notice to or approval from the Commission will reduce administrative burden and allow operators latitude to determine their own work priorities. . Temporary removal periods need to be defined and a tracking system established in order to prevent indefinite removal of the SSSV from operating wells and ensure accountability for their status. 3. Wells that are demonstrated to be incapable of unassisted flow of hydrocarbons do not need a SSSV. 4. Removal of SSSV's from wells incapable of unassisted flow of hydrocarbons will not cause waste nor jeopardize correlative rights. , Temporary removal of SSSV's to allow passage of certain equipment and performance of well maintenance is a reasonable operational requirement and in keeping with sound engineering practices. NOW, THEREFORE, IT IS ORDERED THAT Rule 5, Conservation Order 145 is repealed and a new Rule 5 is reissued to read: Rule 5 Automatic Shut In Equipment a. Upon completion, each well shall be equipped with: a fail-safe automatic surface safety valve (SSV) capable of preventing uncontrolled flow. ii. a fail-safe automatic subsurface safety valve (SSSV), unless other types of subsurface valve are approved by the Commission, shall be installed in the tubing string below the base of the permafrost and be capable of preventing uncontrolled flow. bo A well that is not capable of unassisted flow of hydrocarbons, as determined by a "no flow" performance test witnessed by a Commission representative, is not required to have a fail-safe automatic SSSV. Co Subsurface safety valves may be temporarily removed for not more than 30 days as part of routine well operations or repair without specific notice to, or authorization by the Commission. i. Written notification will be required for those wells that will have SSSV's removed longer than the 30 day period. Dratt Conservation Order 33'(~ { Prudhoe Oil Pool Page 3 February 17, 1994 ii. Wells with SSSV's removed shall be identified by a sign on the wellhead stating that the valve has been removed, reason for removal and the date of removal. iii. A list of wells with SSSV's removed, removal dates, reasons for removal, and estimated reinstallation dates must be up-to-date and available for Commission inspection on request. d. The Low Pressure Sensor (LPS) systems shall not be deactivated except during repairs to the LPS, while engaged in active well work or if the pad is manned. If the LPS cannot be returned to service within 24 hours, the well must be shut-in at the well head and at the manifold building. i. Wells with a deactivated LPS shall be identified by a sign on the wellhead stating that the LPS has been deactivated and the date it was deactivated. ii. A list of wells with the LPS deactivated, the dates and reasons for deactivating, and the estimated re-activation dates must be up-to-date and available for Commission inspection on request. e. The safety valve systems must be maintained in working condition at all times. Upon proper application or its own motion, the Commission may administratively waive or amend the requirements of this rule as long as the change does not promote waste, jeopardize correlative rights or compromise ultimate recovery, and is based on sound engineering principles. DONE at Anchorage, Alaska and dated February 17, 1994. David W. Johnston, Chairman Russell A. Douglass, Commissioner Tuckerman Babcock, Commissioner AS 31.05.080 provides that within 20 days after receipt of written notice of the entry of an order, a person affected by it may file with the Commission an application for rehearing. A request for rehearing must be received by 4:30 PM on the 23rd day following the date of the order, or next working day ifa 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 l~om the date the Commission refuses the application or mails (or otherwise distributes) an order upon rehearing, both being the £mal 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 rum from the date on which the request is deemed denied (i.e., 10th day after the application for rehearing was filed). Notice of Public Hearing STATE OF ALASKA Oil and Gas Conservation Commission Re: The application of ARCO Alaska , Inc. and BP Exploration (Alaska), Inc. for modification to Rule 5 Conservation Order 145. ARCO Alaska, Inc. and BP Exploration by letter dated August 19, 1993, have requested modifications to Rule 5 of Conservation Order No. 145 affecting subsurface safety valves. The proposed modifications would allow the AOGCC to approve an operators request to remove the subsurface valve from a well which has been demonstrated incapable of unassisted hydrocarbon floTM, allow the operators to temporarily remove subsurface safety valves from wells for routine well work without specific authorization or notice to the AOGCC and allow the AOGCC to administratively amend or waive the requirements of this rule. A person who may be harmed if the requested order is issued may file a written protest prior to 4:00 pm January 3, 1994 with the Alaska Oil and Gas Conservation Commission, 3001 Porcupine Drive, Anchorage, Alaska 99501, and request a hearing on the matter. If the protest is timely filed and raises a substantial and material issue crucial to the Commission's determination, a hearing on the matter will be held at the above address at 9:00 a.m. on January 20, 1994 in conformance with 20 AAC 25,540. If a hearing is to be held, interested parties may confirm this by calling the commission's office, (907) 279-1433 after January 3, 1994. If no protest is filed, the Commission will consider the issuance of the order without a hearing. Commissioner Alaska Oil and Gas Conservation Commission Published December 17, 1993. #7565 STOF0330 AO-08-5759 AFFIDAVIT STATE OF ALASKA, ) THIRD JUDICIAL DISTPJCT. ) Eva M. Kaufmann being first duly sworn on oath deposes and says that he/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 said time 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 Dec. 17, 1993 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 b~re me this .~day of~~,.~ ..... Notary Public in and for the State of Alasl~. Third Division. Anchorage, Alaska MY CO/VWtlSSION EXPIRES OF PUBLICATION NotiCe-O! Public Hearing STATE OF ALASKA , Alaska Oil' and ' Gas Conservation CommissionI Re: The application of ARCOI' Alaska, Inc., and BP Explora-J t on (AlasKa), Inc. for medtfi-| cation to Rule 5 Conservation| Order 145. ' ARCO Alaska, Inc. and BP. Exploration by letter dated August 19, 1993, have re-. quested modifications to Rule .$ 'of Cons~k'vation Order No. 145 affectir~g subsurface safety valves. The proposed modifica-. tiGriS would allow the AOGCC to approve an operators re- quest to remove the'subsurface valve from a well which has been demonstrated incapable ,of unassisted hydrocarbon .~ flow, allow the operators to "temporarily remove subsur. I~face safety valves from. wells · for=., routine well work without sPecifiC ~authorization or" notice tel'the A"OGCC and allow the AOGCC 'to administratively amend or waive the .require- ments of this rule.. A person who may be harm- ed. if the requested order is iSSUed n~ay fil~ a written pro- . test prior'to 4:00 'pm :january 3~ 1994 with the Alaska Oil and 'Gas ConServat on Commission, ~.'?~, ~o,'~.u~.,,e Drzvel, ~,'nchor- a .",eh- '1; c,-' ;;~: .-'-,l'.er' If the I~rC'e~' ~. · -e ~ '..~d' and. .raises a.substantla~ ano mate~ .~,rial.' ssue.crucial to the Com.' i/mission,s determination, a | hearing on the matter Will be i"he d at the above address at ~'9':'00 am on JarluarY" 20, 1994 in [.c~nformance 'With 20. AAC J2~.'5~.. If 'a hearing is to be [..~'he d,.. nte~eSted ~partles .may =o-'f'r',~ ~,,.~ ~v call.leg"the' :..* .... Ss.~:.. '~. .-II L'~ ~-~.."'.:' .,',"...;.fy ;3, 1994~J ' -: c':',.? .~. · ,'.",". me.Com-I 3r:e .'.f ",~ c'."...~r Without a hearing. I/s/Russell A. Douglass, I' Commissioner'' ,', J Alaska:Oil and. GaS .' Conservation Commission / A0~08.-5759" . ' I P_u_blish Decembe_r. 17~ 19~..3~ JUL..Y...3~...~.994 .............. '~ 9 ...... of Co 317. ARCO Alaska, Inc. ~ Post Office Box 100360 Anchorage Alaska 99510-0360 Telephone 907 276 1215 August 19, 1993 Mr. D. W. Johnston, Chairman Alaska Oil & Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 Re: Request to Modif_v Rule 5, CO 145 Dear Mr. Johnston' The Prudhoe Bay Unit CPBU") operators request a modification to Rule 5, Conservation Order 145, which requires that "upon completion, each well shall be equipped with a suitable safety valve installed beloTM the base of the permafrost which will automatically shut in the well if an uncontrolled flow occurs." This valve is commonly called a Subsurface Safety Valve (SSSV). We propose Rule 5 be changed to be consistent with the corresponding rule in the pool rules for the Pt. McIntyre and Stump Island Oil Pools, Conservation Order 317, Rule 8, dated July 2, 1993. The proposed amended rule would remain more stringent than required under 20 AAC 25.265. The proposed revision would: 1) allow the AOGCC to approve removal of the SSSV after a successful demonstration that the well is not capable of unassisted hydrocarbon flow; 2) allow temporary removal of SSSV's from individual wells for routine wellwork operations without specific authorization or notice. As you know, this is a common practice and is an operational necessity for successfully completing a large number of routine wellwork operations requiring unrestricted internal wellbore dimensions. This modification will clarify the Rule and minimize administrative burden for both the Commission and the Operators; and 3) allow the AOGCC to administratively amend or waive thc requirements of this rule in certain special circumstances. As well productivity declines, the PBU operators will continue to rework as many low productivity wells as possible and to seek innovative technology to enhance the economics of these wells. This change will allow the Commission to administratively consider changes to the requirements RE£ E IV ED of this rule consistent with the application of new technology and specific well conditions. AU G 2 3 199,$ ARCO Alaska, Inc. is a Subsidiary of Atlantic Richfield Company Alaska 0il & Gas Cons. comrn%s~ Anchorage Mr. D. W. Johnston August 19, 1993 Page 2 Thus, the PBU operators propose that Conservation Order 145, Rule 5 be amended to read as follows: Rule 5: Automatic Shut-In Equipment a) Upon completion, each well which is capable of unassisted flow of hydrocarbons to the surface shall be equipped with: 1) a fail-safe automatic surface safety valve (SSV) capable of preventing an uncontrolled flow; and 2) a fail-safe automatic subsurface safety valve (SSSV), unless other types of subsurface valves are approved by the Commission, shall be installed in the tubing string below the base of the permafrost and be capable of preventing uncontrolled flow. b) A well that is not capable of unassisted flow of hydrocarbons as determined by a "no flow" performance test witnessed by a Commission representative is not required to have fail-safe automatic SSSV valves. c) SSSV's may be temporarily removed for routine wellwork operations without specific notice to, or authorization by the Commission. d) Upon proper application, the Commission may administratively amend or waive the requirements of this rule. Thank you for your consideration of this proposal. Please contact us at the numbers below should you have any questions or require additional information from us. Sincerely, c. Manager PB Petroleum Engineering BP Exploration (Alaska), Inc. 564-4757 D. F. Scheve Manager PB Operations Engineering ARCO Alaska, Inc. 263 -4248 RECEIVED Alaska Oil & Gas Cons. C.,ommissioP Anchorage