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Home My WebLink AboutO 026 ~ ~ OTHER ORDER FILE COVER PAGE This page identifies oversize material and digital information available for this individual Order file and weather or not it is available in the LaserFiche file. Please insure that it remains as the first page in this file. f) & 2- r; Other Order File Date ~/o¥ Color Materials # Added to LaserFiche File 0 Yes 0 No 0 Added (date) Digital Data 0 CD's - # 0 DVD's - # 0 Diskettes - # Added to LaserFiche File 0 Yes 0 No 0 Yes 0 No 0 Yes 0 No Oversized Material Added to LaserFiche File 0 Maps # - 0 Mud Logs # - 0 Other # - 0 Yes 0 No 0 Yes 0 No 0 Yes 0 No General Notes or Comments about this file. If any of the information listed above is not available in the LaserFiche file, or if you have any questions or information requests regarding this file, you may contact the Alaska Oil & Gas Conservation Commission to request copies at 279-1433, or email us at: AOGCC_Librarian@admin.state.ak.us ----------- ----- - -------------- ~, r--.. INDEX OTHER ORDER NO. 26 ENFORCEMENT ORDER 1. December 22, 2003 AOGCC's Letter to Unocal Re: Potential Waste Determination Unocal response to letter dated 12/22/03 E-mail from Unocal to our letter proposing to classify flared gas as waste AOGCC's letter to Dale Haines, Unocal 2.January 19, 2004 3.January 20, 2004 4. February 17, 2004 5. April 28, 2004 Unocal's letter of acknowledgement and fine Other Order 26 ,/ !~ ~ STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West 7th Avenue, Suite 100 Anchorage, Alaska 99501 Re: Enforcement Action Against) Union Oil Co. of California) Other Order No. 26 ENFORCEMENT ORDER IT APPEARING THAT: 1. Pursuant to 20 AAC 25.535, on February 17, 2004, the Alaska Oil and Gas Conservation Commission ("Commission") issued written notice to Union Oil Company of California ("Unocal") informing it that the Commission proposed to take enforcement action, including requiring payment of a penalty as a result of gas flaring at Baker platform in Middle Ground Shoal Field, Cook Inlet, during July 2003. 2. The Commission's written notice informed Unocal that if it failed to file a timely written response, the Commission would consider it to have accepted the proposed Commission action by default, as provided in 20 AAC 25.535(c). 3. The Commission received no response from Unocal. FINDINGS: 1. Unocal is operator of the Baker Platform located within the Middle Ground Shoal field of Cook Inlet. 2. Unocal publicly announced its intent to shut down production at Baker Platform in October 2002. 3. The scope of Baker shut down plans was not fully disclosed to the Commission despite inquiries subsequent to Unocal's public announcement. 4. Final shut down of operations at the Baker Platform was completed by August 2003. 5. Unocal flared 612,000 cubic feet (612 Mct) of gas while suspending operations at Baker Platform in Middle Ground Shoal during July 1-2, 2003; flaring exceeded one hour. 6. The Commission received from Unocal a "Facility Report of Produced Gas Disposition", Form 10-422, for Baker Platform, dated August 14,2003. 7. The Commission sent Unocal a letter dated December 22, 2003, requesting additional information about the flaring associated with shut down operations. , ~ .~ 8. Unocal responded to the Commission's request in a letter dated January 1, 2004, explaining that the gas flared at Baker Platform during July 1-2, 2003, was associated with the process of suspending operations, and normal production process and compression equipment were no longer operable because of steps involved with those operations. 9. 20 AAC 25.235(d) establishes flaring and venting that can be authorized by the Commission and not subject to a determination of waste, generally grouped into safety, lease use, and conservation categories. Flaring and venting associated with the suspension or abandonment of activities at Baker Platform do not meet the criteria set forth in AOGCC regulations as authorized flaring. 10. The royalty value of gas produced at Baker Platform during July 2003, according to the Alaska Department of Natural Resources, Division of Oil and Gas, was $2.26 per Mcf. Based on this figure, the fair market value of the flared gas was $1,383.12. CONCLUSIONS: 1. Unocal's flaring of 612 Mcf of gas on July 1 and 2,2003, constituted waste. 2. For purposes of AS 31.05.150(e), the fair market value of the wasted gas was $1,383.12. 3. Under AS 31.05.150(e), Unocal is liable to pay to the Commission a penalty of $1,383.12. 4. Pursuant to 20 AAC 25.535(c), Unocal has accepted by default the Commission's proposed action ordering payment of a penalty. NOW THEREFORE IT IS ORDERED: ~ orman, Chair ,~~... /~<lf ~/ ~/ Daniel T. Seamount, Jr. 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 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., 10tb day after the application for rehearing was filed). UNITED STATES POSTAL SERVICE First-Class Mail Postage & Fees Paid USPS Permit No. G-10 . Sender: Please print your name, address, and ZIP+4 in this box. Alaska Oil and Gas Conservation Commission 333 West ih Avenue, Suite 100 Anchorage, AK 9950 I ~N H/C Ji,&~}W'&~~I~Æ=9JLiì¡¡¡! $EN DÊA.: 'CÔNlÞÛ~fE .tHlSSECTlbiV, ..,.,,¿, ". ',. '...., ".i".,,', '<';."',"",ii,;,;",,'¡,.",.' ",/"..,."',',bi.,'.!.';,/...""'."..i;,;,¿i. A.;;eip;~;;S;:;-C/earIY) V!6;lJi ~ ~n.atu/J~re ')( Agent ï.7 L.J . 0 Addressee D. Is delivery ad ress different from item 1? 0 Yes 1. Article Addressed to: . 0" 1Jy!e. Ala/!? ø ~E.CE. NE. 0' YES, '""" "'NO" "dre.. bo'ow No ¿¿!/7tJca¿ ~~ - , îtJ4 .' RES /Y/3 /?t.;;?L/7 ~ Gasc.ns.~l':~:p, It,.... "RIC.~r"l) Ii ne-Á., )V þ( ~~~~~tMt8"e gt~:;ii:~:~e~~iI g~ttJ¡E~..rt;~ise I ) l.f 7 ¿/ I I 0 Insured Mail 0 C.O.D. IT . 4. Restricted Delivery? (Extra Fee) _~es . Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 2. A'-+'~I~ .,..~....-- /,,--.. <--- .-.-.,.. ,.,.-" 7002 3150 0005 3521 1126 PS F'orm 3811, July 1999 Domestic Return Receipt 102595-00-M-O952 ,..::¡ ru Ul rr1 Ul CJ CJ CJ CJ Ul ,..::¡ rr1 UNITED STATES POSTAL SERVICE First-Class Mail Postage & Fees Paid USPS Permit No. G-10 . Sender: Please print your name, address, and ZIP+4 in this box. Alaska Oil and Gas Conservation Commission 333 West ih Avenue, Suite 100 Anchorage, AK 9950 I E7 ß /? d)h~H¡d))tW;JJ,I~dtil!lt! . SENDER: COMPLETÈ tHís SECTION '",.i.,.,,:.,' .', ...... ,.:,.,.,,'. .....",." ,."'.'.'- . Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the r~verse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: A.:ee..'. ~b¥ (Please Print C~earIY) '¡l/Da.te G'I DeJi1ery {(--h,~iLlC 7-~ -O~ ;y. n~re L/ r;¡q Agent 0 Addressee R l UJeeIi'~~Wifferent from item 1? . 0 y~ . .' If~ ente~hvery address below: 0 No gl//(! e-- /f; n Iì e '/ A'R - 8 2004 . . [) a / It M)L M'¿AlaskaOi & Gas Cons. f/Jft..1!.~n '/" / . :t\tmhor~e , D. 'I( Ie) £0 .1/)tJ ø 771,-- ~¿ fI5?)//if:3~~~ ~'tM'"h,""~ (l/7cL /1!? 79)¿ì / 0 Insured Mail ,0 C.O.D. pes 4. Restricted Delivery? (Extra Fee) n ^~,-,- .'..-'-_.1'->__" <.-- M_';~~ 10"0/1. 7002 3150 0005 3521 1133 PS Form 3811, July 1999 Domestic Return Receipt 102595.00-M.O952 Ul D D Return Reciept Fee D (Endorsement Required) D Restricted Delivery Fee Ul (Endorsement Required) r-=t fT1 .....m"'¡1"'~"'1""'4'¡¡{"""');":{' ,i,¡,1'!;1,1~¡';~'l'.lW1\- fT1 fT1 r-=t r-=t Postage $ Certified Fee Total P"stage & Fees ~- /--', ,---, STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West 7th Avenue, Suite 100 Anchorage, Alaska 99501 Re: Enforcement Action Against) Union Oil Co. of California) Other Order No. 26 CERTIFICATE OF SERVICE e'-¡V I certify a true and correct copy was mailed by certified restricted delivery April'L, 2004 to the following at their addresses of record: Mr. Dale Haines Operations Manager Unocal Alaska PO Box 196247 Anchorage,AJ( 99519 Certified Mail No 7002 3150 00053521 1126 Mr. Bruce Kinney Department of Revenue, Tax Division 550 W. 7th Avenue, Suite 500 Anchorage, AK 9950 I Certified Mail No 7002 3150 000535211133 j(~b::::t~ Assist~t Other Order 26 ~ ~ rmmmm m m [mmmmmm mmmmmmm- I Other 26.docil Content-Type: ~~;ii~~ti~~;~~~;drl 10f2 4/6/20043:43 PM Other 26 lof! ~ /~ Please publish. Other Content-Type: application/msword Content-Encoding: base64 J 4/6/20043:43 PM Citgo Petroleum Corporation PO Box 3758 Tulsa, OK 74136 Kelly Valadez Tesoro Refining and Marketing Co. Supply & Distribution 300 Concord Plaza Drive San Antonio, TX 78216 Jerry Hodgden Hodgden Oil Company 408 18th Street Golden, CO 80401-2433 Kay Munger Munger Oil Information Service, Inc PO Box 45738 Los Angeles, CA 90045-0738 Mark Wedman Halliburton 6900 Arctic Blvd. Anchorage, AK 99502 Ciri Land Department PO Box 93330 Anchorage, AK 99503 David Cusato 600 West 76th Ave., #508 Anchorage, AK 99518 James Gibbs PO Box 1597 Soldotna, AK 99669 Richard Wagner PO Box 60868 Fairbanks, AK 99706 Williams Thomas Arctic Slope Regional Corporation Land Department PO Box 129 Barrow, AK 99723 r--.. Mary Jones XTO Energy, Inc. Cartography 810 Houston Street, Ste 2000 Ft. Worth, TX 76102-6298 Robert Gravely 7681 South Kit Carson Drive Littleton, CO 80122 Richard Neahring NRG Associates President PO Box 1655 Colorado Springs, CO 80901 Samuel Van Vactor Economic Insight Inc. 3004 SW First Ave. Portland, OR 97201 Schlumberger Drilling and Measurements 3940 Arctic Blvd., Ste 300 Anchorage, AK 99503 Jill Schneider US Geological Survey 4200 University Dr. Anchorage, AK 99508 Jack Hakkila PO Box 190083 Anchorage, AK 99519 Kenai National Wildlife Refuge Refuge Manager PO Box 2139 Soldotna, AK 99669-2139 Cliff Burglin PO Box 131 Fairbanks, AK 99707 North Slope Borough PO Box 69 Barrow, AK 99723 /-, David McCaleb IHS Energy Group GEPS 5333 Westheimer, Ste 100 Houston, TX 77056 George Vaught, Jr. PO Box 13557 Denver, CO 80201-3557 John Levorsen 200 North 3rd Street, #1202 Boise, ID 83702 Michael Parks Marple's Business Newsletter 117 West Mercer St, Ste 200 Seattle, WA 98119-3960 Baker Oil Tools 4730 Business Park Blvd., #44 Anchorage, AK 99503 Gordon Severson 3201 Westmar Cr. Anchorage, AK 99508-4336 Darwin Waldsmith PO Box 39309 Ninilchick, AK 99639 Penny Vadla 399 West Riverview Avenue Soldotna, AK 99669-7714 Bernie Karl K&K Recycling Inc. PO Box 58055 Fairbanks, AK 99711 !1/;v/jd L/iP.r;? tj 7 ~ ~ '.,- UNOCAL8' Dale A. Haines Operations Manager Tel 907-263-7951 Fax 907-263-7854 daleah@unocal.com April 28, 2004 John Norman, Chair Alaska Oil and Gas Conservation Commission 333 W. ih Avenue, Suite 100 Anchorage, AK 99501-3539 RECEIVED MAY 032004 Alaska Oil & Gas Cons. Commission Anchorage RETURN RECEIPT REQUESTED CERTIFIED MAIL 70022410000334903491 RE: ENFORCEMENTORDERNO.~ BAKER PLATFORM GAS FLARING Dear Chairman Norman: We are in receipt of Alaska Oil and Gas conservation Commission (AOGCC) Enforcement Order No. 26 addressing gas flared from Unocal's Baker Platform on July 1 and 2, 2003. The order contains a penalty in the amount of $1 ,383.12, due no later than May 1, 2004. Payment is remitted via check #2007785, enclosed herein. The order results from the Commission's conclusion that the gas flared from the Baker Platform during the decommissioning process was waste gas, as defined in 20 MC 25.235(d). Unocal respectfully disagrees with the Commission's determination. Unocal strives to operate its facilities in a safe, clean, and environmentally responsible manner. As we explained in our January 19, 2004 letter to the Commission, flaring was unavoidably necessary to cease facility operations in a safe manner. It is reasonable to believe the Commission had avoidance of an emergency in mind when it adopted 20 MC 25.235(d)(1) when there are other than regular operations ("operational upset"). There would be little point in requiring an operator to wait for the likely emergency of over- pressurization, instead of flaring a modest amount of gas to safely cease production operations. If you have any questions or wish to further discuss the circumstances surrounding this event, please direct them to our Compliance Coordinator, Mr. David S. Bailey at 907-263- 7967, or via e-mail at dbailey@unocal.com. Unocal Alaska I Union Oil Company of California 909 W, 91h Ave, P,O. Box 196247 Anchorage. AK 99519-6247 SCANNED JUL 0 8 2004 .., <. r--. /""".. þ. Page 2 Enforcement Order No. 26, Baker Platform Gas Flaring 28 April 2004 I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. Sincerely, ðcJ2 c. 6) { A.- Dale A. Haines SCANNED JUt 0 8 2004 FOR INQUIRIES CONTACT LOCATION WHERE INVOICES Wrl8MIITED INVOICE/CREDIT MEMO NO. VOUCHER No. 04-28-04 BAKERFLARINGPENFEE 10171458 FORM 4-28181 (REV 11-95) PRINTED IN U.S.A. DETACH STUB BEFORE DEPOSITING CHECK I i i I T()TAL...I CITIBANK DELAWARE A Subsidiary of Citicorp ONE PENN'S WAY NEW CASTLE, DE 19720 62.20 311 UNOCALfj) - . , ~. VEt-. JO. ¡ 1031548 04-29-04 DISCOUNT 2007785 NET 1,383.12 1,383.12 Union Oil Company of California Accounts Payable Field Disbursing 2007785 Date Check Amount GROSS 1,383.12 RECEVEO M/Ú 0 3 2004 mmission 0'\ & Gas ~O(\s. l.O Maska' AnchÐr8ge 1,383.12 Pay One Thousand Three Hund,red Eighty-Three Dollars And 12 Cents********************************* To the order of STATE OF ALASKA ALASKA OIL & GAS CONSERVATION 333 WEST 7TH AVENUE SUITE 100 ANCHORAGE, AK 99501 United States COMMISSION II. 200 ??B 511. 1:0 ~ . .00 20 '11: 29-APR-04 :;Z:":J°d:Jœ~ . ~ '1 . . B . ~ ? II. SCANNED JUL 0 8 2004 ******1,383. 12'. #4 K t " (~;:;:'1 ¡ i ! I ¡ ¡ ì ¡ I ¡ ¡ ¡ \,,\:~ J FRANK H. MURKOWSKI, GOVERNOR AI,ASIiA OIL AND GAS CONSERVAnONCO~SSION 333 W. 7'" AVENUE, SUITE 100 ANCHORAGE, ALASKA 99501-3539 PHONE (907) 279-1433 FAX (907) 276-7542 CERTIFIED MAIL NO, 7002 315000053521 1140 RETURN RECEIPT REQUESTED February 17,2004 Mr. Dale Haines Operations Manager Unocal Alaska PO Box 196247 Anchorage, AK 99519 Re: Potential Waste Determination - Baker Platform Gas Flaring Dear Mr. Haines: The July 2003 gas disposition report for the Baker Platform (Middle Ground Shoal field) includes 612,000 cubic feet (612 Mct) gas flared. The Alaska Oil and Gas Conservation Commission ("Commission") sent a letter to Unocal dated December 22, 2003, proposing to determine as waste the gas flared during July 1-2, 2003, at Baker platform, and providing the opportunity to submit additional information that Unocal believes is relevant to this proposed action. It was further noted that a determination of waste could result in the imposition of penalties as provided in AS 31.05.150, You responded to the Commission by letter dated January 19, 2004, explaining that the gas flared at Baker Platform on July 1-2, 2003, was associated with the process of suspending operations. It was further noted that normal production process and compression equipment were no longer , operable because of the steps involved with suspending the facility, The information provided does not appear to provide a basis for the Commission to authorize the flaring at Baker Platform during July 1-2, 2003, Specifically, it appears that the gas flared was not necessary for the facility operation, repairs, upgrades or testing; was not used in testing procedures; was not the result of an emergency that would threaten life or property; and was not necessary to prevent the loss of ultimate recovery. Pursuant to 20 AAC 25.535, the Commission proposes to impose a penalty on Unocal under AS 31.05.150(e) for the flaring of 612 Mcf of gas in the during July 1-2, 2003, at the Baker Platform located in Middle Ground Shoal Field, Cook Inlet. The proposed penalty is $1,383.12.1 I Royalty Value for gas produced at Baker Platform during July 2003 was $2,26/Mcf (Source: Dept. of Natural Resources, Division of Oil and Gas) Mr. Dale Haines February 17,2004 Page 2 of2 As provided under 20 AAC 25.535(c), within 15 days after receipt of this notification Unocal may file with the Commission a written response that concurs in whole or in part with the proposed action described here, requests informal review, or requests a hearing under 20 AAC 25.540. If informal review is requested and Unocal disagrees with the Commission's proposed decision or order after that review, Unocal may then request a hearing within 10 days after the proposed decision or order is issued. 8r" ~ If Unocal does not file a timely written response to this notification, the Commission will consider Unocal to have accepted by default the proposed penalty described above. However, if Unocal needs more than 15 days to respond, it may for good cause shown request an extension of the IS-day response period. Very Truly Yours, q)~ Daniel T. Seamount, Jr. Commissioner cc: Mr. Bruce Kinney Department of Revenue, Tax Division 550 W. ih Avenue, Suite 500 Anchorage, AK 99501 ,~ ~ UNITED STATES POSTAL SERVICE First-Class Mail Postage & Fees Paid USPS Permit No. G-10 . Sender: Pleàse print your name, address, and ZIP+4 in this box. State of Alaska AI{ Oil & Gas Conservation Commission 333 West 7th Avenue Anchorage Alaska 99501 l-iJ/ø j) Ii / y )iw j;~1¿ zP) 7 ~3 ;Y~;;¡:Þ ¡ ~//Ø J/YJ ", .. ,~ ~ £~~Ð ,,' .."~ " I'EB2 fJnO4 ~j~~(4~¡f;a3~;1 4. Restricted Delivery? (Extra Fee) 0 Agent 0 Addressee 0 Yes 0 No SENDER: COMPLETE THIS SECTION . ' Complett'!items'1; 2, 'and3~ Also complete. item .4 if RestrictêdDeliverYis desired, . Print your name and address on thP- reverse so that we can return the card to-you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article,/\ddressed to: 0 Express Mail 0 Return Receipt for Merchandise 0 C.O.D. )(ýes 2. Articl," U..-L_- ""--,..ç--- M_'¡~ð,/o¡"..1I 7002 3150 0005 3521 1140 PS Form 3811, July 1999 Domestic Return Receipt 102595-00-M-O952 "/ ,r--, ~ Postage lJ1 0 0 0 Certified Fee Return Reciept Fee (Endorsement Required) ru 0 0 ["- "/ . #3 [fwd: Jüly 2003 Baker Flare Eve.-- ~ Sùbject: [Fwd: July 2003 Baker Flare Event] From: James Regg <jim regg@admin.state.akus> Date: Tue, 20 Jan 2004 11 :09:41 -0900 Unocal's response to our 12/22 letter proposing to classify flared gas as waste Jim -------- Original Message -------- July 2003 Baker Flare Event Tue, 20 Jan 2004 09:13:59 -0900 Bailey, David S <dbailey@unocal.com> jim regg@admin.state.ak.us Subject: Date: From: To: Mr. Regg, Thank you for your time on the phone last week. We have reviewed the flare event that the AOGCC discusses in a letter dated December 22, 2003. We have prepared additional documentation to support the need for flaring and will place it in the mail today. The text below was copied from said documentation and is being submitted via e-mail to meet our January 20th deadline. *Copied from Unocal letter dated January 19, 2004* Union Oil Company of California (dba Unocal) was in the process of suspending operations at the Baker Platform during this flaring event. Steps associated with suspending the facility included de-energizing oil lifting and other equipment, and purging oil from within well casings, tanks and vessels. Under normal operation, gas breakout associated with oil production is recovered and compressed for fuel or exported off the platform. During the suspension activities described above, the normal production process was shut down. The gas in question originated from wells, vessels and tanks which were being depressurized. At that point in the suspension process there was no operable equipment in place to compress the gas and insufficient equipment operating to consume the gas should it have been compressed. Additionally, gas dehydration equipment was not operable, so export off the platform was not possible. Given the relatively short duration needed to cease production, and .the finite volume of gas to be brought to surface, we elected to flare the gas.** * ""'" . * I of2 1/20/2004 11: 14 AM [Fwcl:> Jaly 2003 Baker Flare Eve_~ ~ ,. Please call should you have any questions or if I can be of further assistance. Sincerely, *David S. Bailey* Compliance Coordinator Union Oil Company of California 909 W. 9th Avenue Anchorage, AK 99519 (work) 907-263-7967 (cell) 907-301-9954 (fax) 907-263-7901 2 of2 1/20/2004 II: 14 AM #2 .. ,. . 8r .' UNOCAL8 Dale A. Haines Operations Manager Tel 907-263-7951 Fax 907-263-7854 daleah@unocal.com January 19, 2004 Ms. Sarah Palin. Alaska Oil and Gas Conservation Commission 333 W. ih Avenue, Suite 100 Anchorage, AK 99501-3539 RECEIVED JAN 2 1 2004 RETURN RECEIPT REQUESTED CERTIFIED MAIL 7001 0320 0005 5886 0988 Alaska Oil & Gas Cons. Commission Anchorage RE: POTENTAIL WASTE DETERMINATION BAKER PLATFORM GAS FLARING Dear Ms. Palin: We are in receipt of your letter dated December 22,2003 wherein you propose to determine as waste 612,000 cubic feet of gas flared on the Baker Platform between July 1 and 2, 2003. Your offer to consider additional relevant information is greatly appreciated. Union Oil Company of California (dba Unocal) was in the process of suspending operations at the Baker Platform during this flaring event. Steps associated with suspending the facility included de-energizing oil lifting and other equipment, and purging oil from within well casings, tanks and vessels. Under normal operation, gas breakout associated with oil production is recovered and compressed for fuel or exported off the platform. During the suspension activities described above, the normal production process was shut down. The gas in question originated from wells, vessels and tanks which were being depressurized. At that point in the suspension process there was no operable equipment in place to compress the gas and insufficient equipment operating to consume the gas should it have been compressed. Additionally, gas dehydration equipment was not operable, so export off the platform was not possible. Given the relatively short duration needed to cease production, and the finite volume of gas to be brought to surface, we elected to flare the gas. Unoeal Alaska I Union 011 Company of Callfomla 909 W. 9th Ave, P.O. Box 196247 Anchorage, AK 99519-6247 <... Page 2 .-\ Potential Waste Determination, Baker Platform Gas Flaring 19 January 2004 ~ # Unocal strives to operate its facility in a safe, clean, and environmentally responsible manner. We appreciate AOGCC's attention to such matters and desire to continue to work cooperatively to assure the conservation of our natural resources. If you have any question please direct them to our Compliance Coordinator, Mr. David S. Bailey at 907-263-7967, or via e-mail at dbailey@unocal.com. I certify under penalty of law that this document and all attachments were prepared under the direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. Sincerely, L)~ a. C)./~ Dale A. Haines #1 r ~ '. . . "' ,\ ',. ~ "" FRANK H. MURKOWSKI, GOVERNOR ^',ASKA OIL AND GAS CONSERVATION COMMISSION " December 22, 2003 333 W. ?T" AVENUE. SUITE 100 ANCHORAGE. ALASKA 99501-3539 PHONE (907) 279-1433 FAX (907) 276-7542 Mr. Bill Britt HES Manager Unocal 909 West 9th Avenue Anchorage, AK 99501 Re: Potential Waste Determination Baker Platform Gas Flaring Dear Mr. Britt: July 2003 gas disposition for the Baker Platform (Middle Ground Shoal field) includes 612,000 cubic feet gas flared. Attached is the Monthly Gas Disposition Report, Form 10-422. The supplemental information provided by Unocal with Form 10-422, notes that flaring was the result of planned activities associated with the long-term shutdown of Baker platform. The Alaska Oil and Gas Conservation Commission ("Commission") is proposing to determine as waste the gas flared during July 1-2, 2003, at Baker platform. A determination of waste could result in the imposition of penalties as provided in AS 31.05,150. Before the Commission makes a final determination of waste, Unocal is being provided an opportunity to introduce additional information believed to be relevant to the decision. Any information you would like to have AOGCC consider must be presented before 4:30 PM on January 20, 2004. SincerelY,' -; , /,:' /J, L/ ( ~ /l' ,//, ,-----....."p~ /L/1f¿.-;.--.--- c',^--- '-------- ) \ ./ Sarah Palin Chair Attachment q.~ - C,l°p y--- . -. ALASKA OIL AND GAS CONSERVATION COMMISSION F AC~ITY REPORT OF PRODUCED GAS DISPOSITI(}N Facility BAKER PLATFORM Disposition 1. Sold 2. Reinjected 3. Flared or vented less than 1 hour 4. Flared or vented greater than 1 hour (Supplemental report required - See 20 AAC 25.235) 5. Pilot and Purge 6. Used for lease operations 7. Other TOTAL items 1 - 7 8. NGL gas equivalent produced 9. Purchased gas 10. Transferred from: 11. Transferred to: Remarks: Operator UNOCAL ALASKA RESOURCES Volume MCF* 16.407 'Field(s) MIDDLE GROUND SHOAL 9.584 0 224 388 217 5.994 0 0 0 0 0 I hereby n'fy th~t !be fOregOln. g is1true and correct to the best of my knowledge. s;gn.tn¥'furc?b.....tH1.t1I'.!j¡~ TIde PRODUCTION ACCOUNTANT Date Form 10-422 :¡ U Rev, 4/95 08/14/2003 MonthlY ear of Disposition JULY 2003 *Indicate contribution of each pool to total. Pool Name Code Percent UNDEFINED (GAS) 524500 . 100.00 38B 2. Lease Use MCF 3. Conserv. Purposes MCg" [::jo~ Dat: 17/ 03 Note: All volumes must be corrected to preksute of 14.65 psia and to a temperature of 60 degrees F. Report due by the 20th of the month following the month of disposition. Authority 10 AAC 15.135 ... . - ~ , ~ p"'. r""."" i ....--- Excess Flare Log Report acility Name: BAKER PLATFORM Date & Time Event Gas Begin End MCF Planned? Description of Incident Category Reason 7/1/20030:01 7/1/200323:59 264 N SHUTTING IN PLATFORM. OPERATIONAL OTHER: SEE DESC OF EVENT 7/2/20030:01 SHUTTING IN PLA TFORM. OPERATIONAL OTHER: SEE DESC OF EVENT 7/2/200323:59 124 N Report Date: 8/1412003 Actions Taken PLATFORM BEING SHUTDOWN FOR LIGHTHOUSE MODE OPERATIONS. ALL WELLS SYSTEMATICALLY BEING SHUT-IN. CUT BACK ON TANK AND PRODUCTION UNIT MAKE UP GAS.' PLATFORM BEING SHUTDOWN FOR LIGHTHOUSE MODE OPERATIONS. ALL WELLS SYSTEMATICALLY BEING SHUT-IN. CUT BACK ON TANK AND PRODUCTION UNIT MAKE UP GAS. \ . ~ . ~ . - . . f MonthlYear: July 2003 Steps Taken to Minimize Recurrence PLANNED SHUT-IN OF ENTIRE PLATFORM TO CEASE PRODUCTlON.1 PLANNED SHUT-IN OF ENTIRE PLATFORM TO CEASE PRODUCTION.! Equipment Down MP.2 ID Number oo-oo.co oo.co.co ~ , Page: 1 or I