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Home My WebLink AboutCO 552 ) ) Image Project Order File Cover Page XHVZE This page identifies those items that were not scanned during the initial production scanning phase. They are available in the original file, may be scanned during a special rescan activity or are viewable ~ direct ins~ection of the file. (~O 55 ~ Order File Identifier Organizing (done) 0 Two-sided 1111111111111111111 0 Rescan Needed 1111111111111111111 RESCAN DIGITAL DATA OVERSIZED (Scannable) D Maps: D Color Items: D Greyscale Items: D Diskettes, No. D Other, Norrype: 0 Other Items Scannable by a Large Scanner D Poor Quality Originals: OVERSIZED (Non-Scannable) D Other: 0 Logs of various kinds: Scanning Preparation x 30 = + D Other:: . Date: a-. a.3 65" 151 VVlP 1111111111111111111 Date~ d-..~ 'r'X5 151 m fJ It¡ = TOTAL,PAGES I O~ (Count doell3 not inc ude cover sheet) II\J) P. Date: ~ ~ tl~/sl f V J I 1111111111111111111 NOTES: BY: Helen ~ Project Proofing BY: Helen~ BY: Helen ~ \ Production Scanning Stage 1 Page Count from Scanned File: 1 () 3 (Count does include 00.7 sheet) Page Count Matches Number in Scanning Preparation: V Y~S NO Helen ~ Date:d.. d-3 OS Isl If NO in stage 1, page(s) discrepancies were found: YES NO BY: mp Stage 1 BY: Helen Maria Date: Isl Scanning is complete at this point unless rescanning is required. 1111111111111111111 ReScanned 1111111111111111111 BY: Helen Maria Date: Isl Comments about this file: Quality Checked 1111111111111111111 12/1/2004 Orders File Cover Page.doc ) ) INDEX CONSERVATION ORDER NO. 552 Colville River Field 1) December 2, 2004 Notice of Hearing, affidavit of mailing, e-mail list, buIk mailing list 2) December 23, 2004 Inter-office e-mail 3) January 6, 2005 Inter-office e-mail 4) ------------------------- Guidelines for Qualification of Multi phase Metering Systems for Well Testing 5) January 11, 2005 Sign in Sheet Hearing 6) January 11, 2005 Transcript CONSERVATION ORDER NO. 552 ) ') STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West 7th Avenue, Suite 100 Anchorage Alaska 99501 Re: Rules regulating use of multi phase ) Conservation Order No. 552 meters for well testing and ) Colville River Field, Alpine Oil Pool allocation of production within the) Colville River Field ) February 11,2005 IT APPEARING THAT: 1. On its own motion, the Alaska Oil and Gas Conservation Commission ("Commission") proposed to adopt rules regulating the use of multiphase meters ("MPMs") for well testing and allocation of production within all pools within t1)e Colville River Field. 2. The proposed rules are set out in the document "Guidelines for Qualification of Multiphase Metering Systems for Well Testing" ("Guidelines"), dated November 30, 2004, and have been made available at the Commission's offices and on its website at www.aogcc.alaska.gov/MeterGuide.htm. 3. Notice of opportunity for a public hearing on the proposal was published in the Anchorage Daily News on December 2, 2004. 4. The Commission received letters of non-objection to the Commission's proposal on January 7, 2005 from ExxonMobil Corporation ("Exxon") and January 11, 2005 from ConocoPhillips Alaska, Inc ("CPA"). 5. A hearing was held in conformance with 20 AAC 25.540 at the Commission's offices, 333 West 7th Avenue, Suite 100, Anchorage, Alaska 99501 on January 11,2005. FINDINGS: 1. Production Allocation Using Well Tests Well tests are conducted routinely to monitor the flow rates from wells for purposes of reservoir management, production diagnostics and field allocation. Conventional well testing requires that gas be separated from the fluids before measurement. Production from many of the Alaska reservoir pools is commjngled on the surface and processed using common facilities serving several pools within a field. Total field sales volumes of oil and gas are continuously monitored using custody transfer metering systems, generally referred to as LACT meters. LACT meters are required by regulation to provide accurate measurement to +/-0.25%. Because the pools do not have dedicated processing facilities and pool sales volumes ) Conservation Order 552 February 11, 2005 Page 2 are not separately measured through LACT meters, production volumes must be allocated back to wells and pools on the basis of well tests. Inaccuracies in well tests will cause errors within the final reported production of a pool, potentially affecting revenue of parties. 2. Multiphase Meter Technology Multiphase metering techniques were developed to improve upon certain measurement limitations of conventional two and three-phase metering systems requiring gravity based test separators. MPMs usually require less stabilization and test time, which may allow the operators to increase the number and frequency of well tests thereby improving the quality of well test data. Advances in multiphase metering may allow for individual wells to be continuously monitored. Changes in production characteristics and production upsets can then be detected immediately and intervention can be undertaken earlier. MPMs can be made into compact and lightweight systems because they can operate without the need for phase separation or with partial separation. With the elimination of the test separator and other ancillary equipment, significant cost savings may be achieved. The smaller footprint of the MPMs may also result in reduced disturbance to the tundra. On-site visits to remote locations to monitor and maintain well test measurement systems may be reduced with the elimination of separators and other equipment required in conventional use. 3. Purpose of Guidelines The use of MPMs for well testing is gaining increased support within petroleum production operations and some Alaska operators are investigating their use for well testing and field production allocation. In particular, in March 2004, BP Exploration (Alaska) Inc. ("BPXA") and ConocoPhillips Alaska, Inc. ("CP A") informed the Commission that tests of MPMs were ongoing in the Prudhoe Bay, Kuparuk Riv~r, and Milne Point Fields,. and requested input on the Commission's requirements for their use. Multiphase metering is a relatively new technology. Industry recommended practices are in place for 2-phase or 3-phase test separator based systems. However, no standards and few guidelines have previously been published for MPMs. To help fill this gap, the Commission developed the "Guidelines for Qualification of Multiphase Metering Systems for Well Testing" ("Guidelines"). The guidelines are intended to direct the operator and Commission personnel on the methodology to qualify these new measurement techniques and to provide a consistent process for the evaluation of the proposed metering systems. Custody transfer applications are regulated separately and are outside the scope of the guidelines. 4. Progress of Guidelines Development The Commission prepared an initial draft of the Guidelines on May 13,2004. Alaska operators, vendors of MPMs, other state and federal agencies, and industry experts involved in multiphase metering and well testing, were invited to participate in a ) ') Conservation Order 552 February 11, 2005 Page 3 meeting on June 3, 2004 to provide comment upon the draft. The guidelines were revised to incorporate comments received. A revised draft was distributed on August 27, 2004. A meeting was held to gather comments on the second draft on October 13, 2004. Final guidelines responding to industry comments were prepared on November 30, 2004. 5. Content of the AOGCC Guidelines The Guidelines provide a workable and reasonable interim set of criteria and procedures for evaluating proposals for the use of MPMs in well production measurement and allocation. The Guidelines describe: . the administrative process that will be followed for certification of a multiphase metering system, . meter performance requirements and documentation to accompany the application for certification of the proposed multiphase metering system, . requirements for verification of performance ofMPMs. A second document, "Principles of Multiphase Measurements," was prepared by the Commission to provide basic information concerning MPM technology, a list of references for further education, and a list of terms and defmitions commonly used in the industry. 6. Future Application As yet, no formal application has been made for use of MPMs for production allocation in Alaska fields. However, BPXA and CPA have tested several meters in the Prudhoe Bay, Kuparuk River, and Milne Point Fields. It is anticipated that three or more applications to use MPMs in Alaskan North Slope fields will be submitted to the Commission in the next few years. The Commission plans to test the workability of the guidelines over the coming two to three years. As experience is gained using these guidelines, the document may be further revised to reflect practical experience gained by the field applications. CONCLUSIONS: 1. Alaska Statute 31.05.030(d)(6) gives the Commission authority to regulate the measurement of oil and gas. 2. The Commission's multiphase metering Guidelines are an appropriate initial mechanism for regulating the use of MPMs for well production measurement and for allocation of production within the Colville River Field. 3. A three-year trial period to evaluate the effectiveness and workability of the Guidelines is appropriate. ) ') Conservation Order 552 February 11,2005 Page 4 NOW, THEREFORE, IT IS ORDERED: 1. Conservation Order No. 443A is amended to add the following rule: For purposes of satisfying well test measurement requirements of 20 AAC 25.230, the use of multiphase meters will be approved only in accordance with the provisions of the Commission's document, "Guidelines for Qualification of Multiphase Meters for Well Testing" dated November 30, 2004. The Commission may administratively waive a requirement of these Guidelines or administratively amend the Guidelines as long as the change does not promote waste or jeopardize correlative rights, and is based on sound engineering and geoscience principles. 2. This order expires on January 1, 2008. ---- 1 ation Commission Danie T. Seamount, Jr., 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 rehearing. A request for rehearing must be received by 4:30 PM on the 23rd day fullowing 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 lO-day period. An affected person has 30 days ftom 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 ftom the date on which the request is deemed denied (i.e., 10th day after the application for rehearing was filed). Citgo Petroleum Corporation PO Box 3758 Tulsa, OK 74136 Mona Dickens 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 Jill Schneider US Geological Survey 4200 University Dr. Anchorage, AK 99508 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 ) ) Mary Jones XTO Energy, Inc. Cartography 810 Houston Street, Ste 2000 Ft. Worth, TX 76102-6298 David McCaleb IHS Energy Group GEPS 5333 Westheimer, Ste 100 Houston, TX 77056 Robert Gravely 7681 South Kit Carson Drive littleton, CO 80122 George Vaught, Jr. PO Box 13557 Denver, CO 80201-3557 Richard Neahring NRG Associates President PO Box 1655 Colorado Springs, CO 80901 John Levorsen 200 North 3rd Street, #1202 Boise,lD 83702 Samuel Van Vactor Economic Insight Inc. 3004 SW First Ave. Portland, OR 97201 Michael Parks Marple's Business Newsletter 117 West Mercer St, Ste 200 Seattle, WA 98119-3960 Schlumberger Drilling and Measurements 2525 Gambell Street #400 Anchorage, AK 99503 David Cusato 200 West 34th PMB 411 Anchorage, AK 99503 Baker Oil Tools 4730 Business Park Blvd., #44 Anchorage, AK 99503 Ivan Gillian 9649 Musket Bell Cr.#5 Anchorage, AK 99507 Gordon Severson 3201 Westmar Cr. Anchorage, AK 99508-4336 Jack Hakkila PO Box 190083 Anchorage, AK 99519 James Gibbs PO Box 1597 Soldotna, AK 99669 Kenai National Wildlife Refuge Refuge Manager PO Box 2139 Soldotna, AK 99669-2139 Richard Wagner PO Box 60868 Fairbanks, AK 99706 Cliff Burglin PO Box 70131 Fairbanks, AK 99707 Williams Thomas Arctic Slope Regional Corporation Land Department PO Box 129 Barrow, AK 99723 North Slope Borough PO Box 69 Barrow, AK 99723 /1f 1;/1-jð 5 '""v~~..,......~ y ",,,tV!! '-1'1 \.1.'-'1,;:) ) ) Subject: Conservation Orders From: Jody Colombie <jody - colombie@admin.state.ak.us> Date: Tue, 15 Feb 2005 10:11:26 -0900 To: undisclosed-recipients:; BCC: Robert E Mintz <robert_mintz@law.state.ak.us>, Christine Hansen <c.hansen@iogcc.state.okus>" Terrie Hubble <hubbletl@bp.com>, Sondra Stewman <StewmaSD@BP.com>, Scott & Cammy Taylor <staylor@alaska.net>, stanekj <stanekj@unocal.com>, ecolaw <ecolaw@trustees.org>, roseragsdale <roseragsdale@gci.net>, trmjrl <trmjr 1 @aol.com>, jbriddle <jbriddle@marathonoil.com>, shaneg <shaneg@evergreengas.com>, jdarlington <jdarlington@forestoil.com>, nelson <knelson@petroleumnews.com>, cboddy <cboddy@usibelli.com>, Mark Dalton <markdalton@hdrinc.com>, Shannon Donnelly <shannon.donnelly@conocophillips. com>, "Mark P . Worcester" <mark. p. worcester@conocophillips.com>, Bob <bob@inletkeeper.org>, wdv <wdv@dnr.state.ak.us>, tjr <tjr@dnr.state.akus>, bbritch <bbritch@alaska.net>, mjnelson <mjnelson@purvingertz.com>, Charles O'Do~el1 <charles.o'donnel1@veco.com>, "Randy L. Skillern" <SkilleRL@BP.com>, "Deborah J. Jones" <JonesD6@BP.com>, "Paul G. Hyatt" <hyattpg@BP.com>, "Steven R. Rossberg" <RossbeRS@BP.com>, Lois <lois@inletkeeper.org>, Dan Bross <kuacnews@kuac.org>, Gordon Pospisil <PospisG@BP.com>, "Francis S. Sommer" <SommerFS@BP.com>, Mikel Schultz <Mikel.Schultz@BP.com>, "Nick W. Glover" <GloverNW@BP.com>, "Daryl J. Kleppin" <K1eppiDE@BP.com>, "Janet D. Platt" <PlattJD@BP.com>, "Rosanne M. Jacobsen" <JacobsRM@BP.com>, ddonkel <ddonkel@cfl.rr.com>, Collins Mount <collins - mount@revenue.state.akus>, mckay <mckay@gci.net>, Barbara F Fullmer <barbara.ffullmer@conocophillips.com>, bocastwf <bocastwf@bp.com>, Charles Barker <barker@usgs.gov>, doug_schultze <doug- schultze@xtoenergy.com>, Hank Alford <hank.alford@exxonmobil.com>, Mark Kovac <yesnol@gci.net>, gspfoff <gspfoff@aurorapower.com>, Gregg Nady <gregg.nady@shell.com>, Fred Steece <fred. steece@state.sd.us>, rcrotty <rcrotty@ch2m.com>, jejones <jejones@aurorapower.com>, dapa <dapa@alaska.net>, jroderick <jroderick@gci.net>, eyancy <eyancy@seal-tite.net>, "James M. Ruud" <james.m.ruud@conocophillips.com>, Brit Lively <mapalaska@ak.net>, jah <jah@dnr.state.ak.us>, Kurt E Olson <kurt _olson@legis.state.ak.us>, buonoje <buonoje@bp.com>, Mark Hanley <mark _hanley@anadarko.com>, loren _lernan <loren _leman@gov.state.ak.us>, Julie Houle <julie_houle@dnr.state.ak.us>, John W Katz <jwkatz@sso.org>, Suzan J Hill <suzan_hill@dec.state.ak.us>, tablerk <tablerk@Unocal.com>, Brady <brady@aoga.org>, Brian Havelock <beh@dnr.state.ak.us>, bpopp <bpopp@borough.kenai.ak.us>, Jim White <jimwhite@satx.rr.com>, "John S. Haworth" <john.s.haworth@exxonmobil.com>, marty <marty@rkindustrial.com>, ghammons <ghammons@aol.com>, rmclean <rmclean@pobox.alaska.net>, mkm7200 <mkm7200@aol.com>, Brian Gillespie <ifbmg@uaa.alaska.edu>, David L Boelens <dboelens@aurorapower.com>, Todd Durkee <TDURKEE@KMG.com>, Gary Schultz <gary_schultz@dnr.state.ak.us>, Wayne Rancier <RANCIER@petro-canada.ca>, Bill Miller <Bill- Miller@xtoalaska.com>, Brandon Gagnon <bgagnon@brenalaw.com>, Paul Winslow <pmwinslow@forestoil.com>, Garry Catron <catrongr@bp.com>, Sharmaine Copeland <copelasv@bp.com>, Kristin Dirks <kristin_dirks@dnr.state.ak.us>, Kaynell Zeman <kjzeman@marathonoil.com>, John Tower <John.Tower@eia.doe.gov>, Bill Fowler <Bill_Fowler@anadarko.COM>, Vaughn ~wartz <vaughn.swartz@rbccm.com>, Scott Cranswick <scott.cranswick@mms.gov>, Brad McKim <mckimbs@BP.com>, Steve Lambe <lambes@unocal.com>, jack newell <jack.newell@acsalaska.net>, James Scherr <James.Scherr@mms.gov>, david roby 10f2 2/15/2005 10:12 AM conservatIon urders ) <David.Roby@mms.gov>, Tim Lawlor <Tim_Lawlor@ak.blm.gov>, Lynnda Kahn <Lynnda_Kahn@fws.gov>, Jerry Dethlefs <Jerry.C.Dethlefs@conocophillips.com>, Jerry Dethlefs <n1617@conocophillips.com>, crockett@aoga.org, , Cynthia B Mciver <bren _fficiver@admin.state.ak.us> C0552.pdf Content-Type: application/pdf Content- Encoding: base64 C0548.pdf Content-Type: application/pdf Content-Encoding: base64 Content- Type: application/pdf C0549.pdf Content-Encoding: base64 Content- Type: application/pdf C0550.pdf Content-Encoding: base64 Content-Type: application/pdf C0551.pdf Content-Encoding: base64 Content- Type: application/pdf C0547.pdf Content-Encoding: base64 20f2 2/15/2005 10: 12 AM ::t:t: 0\ ) ) 11 ALASKA OIL AND GAS CONSERVATION COMMISSION 2 PUBLIC HEARING 3 4 In Re: 5 ) ) Guidelines for Qualification of Multiphase) Metering Systems for Well Testing ) ) 6 7 8 TRANSCRIPT OF PROCEEDINGS 9 Anchorage, Alaska January 11, 2005 9:00 o'clock a.m. 10 11 12 COMMISSIONERS: 13 14 JOHN NORMAN, Chairperson DAN SEAMOUNT 15 16 17 18 * * * * 19 20 21 22 23 24 25 METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 -"^ --..- "^ -- " ORIGINAL ~if:~:- y --.,~ ') 1 TABLE OF CONTENTS 2 3 4 I OPENING REMARKS BY CHAIRPERSON NORMAN . . . . . . . . . Page 3 TESTIMONY OF JANE WILLIAMSON . . . . . . . Page 5 5 61 DISCUSSION. . . . . . . . . END OF PROCEEDINGS. . . . . . . . . . . . . . . Pages 7 - 20 . . . . . . Page 21 7 8 9, * * * * 10 11 12 13 14 15 16 17 I 18 19 20 21 22 23 24 25 METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 ) ) 3 1 2 3 4 order. PRO C E E DIN G S (On record) CHAIR NORMAN: I'll call this hearing to This is a hearing before the Alaska Oil and Gas 5 Conversation Commission being held on the morning of Tuesday, 6 January 11th, the hour is 9:05 a.m. Notice of this hearing 7! was duly published in the Anchorage Daily News. The date of 8 publication was December 2nd, and additionally notice of this 9 I hearing was sent out to all persons who have registered on the 10 AOGCC's distribution list for receipt of official 11 publications. 12 The purpose this hearing is to consider rules 13 governing the use of multiphase metering for well testing and 14 allocation of production within all pools within the Colville 15 River, Endicott, Kuparuk River, Milne Point, North Star, and 16 Prudhoe Bay fields. The Commission has initiated this hearing 17 I on its own motion; the purpose being as indicated to regulate 18 the use of multiphase metering for well testing in the 19 designated fields. 20 Any persons that have not previously received a copy 21 of the Commission guidelines that have been developed may do 22 so now or at any point in the hearing. Any persons present 23 who may require special accommodations, either for hearing or 24 other matters, likewise, please see the Commission Special 25 Assistant, Jodi Colombie, and we will do our very best to METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 ') 4 1 accommodate you so that you can participate meaningfully in 2 the hearing. 3 I have before me an affidavit of the publication 4 showing that the publication occurred on the 6th of December, 5 2004, and the hearing today will be conducted in accordance 6 with the normal rules of the Alaska Oil and Gas Conservation 7 Commission. A transcript of the hearing will be prepared and 8 I available for review by any persons desiring same. With us 9 today is Sharon Wilcox of Metro Court Reporting who will act 10 as the court reporter. Unless there is a reason to do so we 11 will not plan to swear witnesses today, but we will accept 12 oral testimony from any persons, as well as any additional 13 written comments that may be offered into the record. 14 I'll begin the hearing by calling upon -- well, first 15 of all I will also introduce Commissioner Dan Seamount, seated 16 to my left, and my name is John Norman, Chairman of the 17 Commission. A quorum is present so we do have a legally 18 constituted meeting. Commissioner Seamount, before we proceed 19 do you have any comments? 20 I 21 I Chairman. COMMISSIONER SEAMOUNT: No , I don't, Mr. 22 CHAIR NORMAN: Then I will call upon 23 Commission engineer Jane Williamson to offer a statement in I 24 I the record concerning the purpose of these multi-phase I 25 I: metering guidelines and what the Commission proposes to i i III ,I II II II METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 ) ) 5 1 I accomplish by adopting them. Ms. Williamson. 2 TESTIMONY BY JANE WILLIAMSON 3 MS. WILLIAMSON: The staff here recommends the 4 adoption of the guidelines for qualification of multi-phased 5 metering for well testing and this is dated November 30th, 6 2004, for use of multiphase meters in well testing on the 7 North Slope. And we're looking at this for a trial period of, 8 I would say, two to three years use. I want to go over what 9 our authority is, what the purposes are of well testing, what 10 are multiphase meters, why are we considering these -- this 11 technology, the purpose of the guidelines, and also the -- how 12 these guidelines were created and what our final proposal and 13 implementation would be. By statute and regulations we have 14 authority over well testing in Alaska. Also, we require as a 15 minimum one well test per month and in some pools we require 16 two well tests per month. 17 I Well tests are used for production management and 18 allocation of production. On the North Slope all the major 19 flelds have several oil pools producing into common I' . 20 facilities. Now, these pools aren't separately measured 21 i through LACT meters. Rather the full field is measured 22 I through LACT meters so well production and pool production is I 23 II allocated back through well tests. Because you have separate 24 II pools with potentially separate ownership and separate tax 25 ¡I treatment, it is quite important that we have -- insure II ill :1 !I iUETRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 ) 6 1 accuracy on the well test metering. 2 Now, currently no well test can guarantee accuracy 3 within a LACT meter quality. So, again, it has to be 4 allocated back and it's roughly you can get plus or minus five 5 percent on the accuracy with normal well testing. Now, 6 I multiphase metering technology is a little bit different from 7 conventional technology in well testing. Conventional 8 technology separates out gas from the fluids and separately 9 meters the gas from the total fluids, and sometimes water and 10 oil are also separated. This is because the typical metering 11 I that you have out there is not accurate when you have gas, any 12 significant gas within the fluids and vice versa, fluids in 13 the gas. 14 Well, there's new technology that would allow metering 15 without full separation of that gas and that's what we're 16 looking into now. There are no standards out there for 17 multiphase meters so what we decided is that we needed to look 18 at this on how we would implement allowing multiphase meters 19 to be used in Alaska. 20 21 I some of the owners at Prudhoe Bay Unit came to us saying that i 22 I they had done some tests, multiphase metering, and that they 23 I might be coming to us with applications for their use and they 24 Ii wanted to know what we were going to require. We. .... I' 2511 Ii 'I II ;1 II II I, Now, this -- we started this process early in 2004, CHAIR NORMAN: I'm sorry, what year was that? ~[ETRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 ) ) 7 1 MS. WILLIAMSON: That was 2004, that was I 2 believe that was February or March time frame. We hired a -- 3 an expert consultant, his name is Parve Medesaday (ph), to 4 help us with setting up some protocol for this and also to I 5 I provide some -- a tutorial on what multiphase meters are and 6 what needs to be considered. We put together initial 7 guidelines in May, initial drafts in May, submitted it to all 8 the operators in Alaska, as well as vendors, other federal and 9 state agencies, and others even outside of Alaska that are ex- 10 -- have expertise in multiphase meters. We've had several -- 11 I a couple meetings revising these and we've incorporated I 12 believe everybodys comments into these guidelines. 13 I I have with -- that I wish to put into the record, two 14 I letters, one from ConocoPhillips and one from Exxon that takes 15 no exception to the use of the guidelines and also comments on 16 I that it is a thorough process that we went through and it's -- 17 I lays out our requirements well. 18 As far as our future, we want -- it's early to try to 19 put these into regulations, we need to test these out and make 20 sure it works, and so I'm recommending two to three years of a 21 trial period. In that period of time we may find that they 22 are ready to go into regulations, and I believe that's it. Do 23 you have any questions? 24 CHAIR NORMAN: Let's take the letters first if 25 you don't mind. METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 ) ) 8 1 MS. WILLIAMSON: Okay. 2 CHAIR NORMAN: Can you briefly identify each 3 letter and then weill ask the court reporter to mark them so 4 that they can be attached..... 51 I 6 MS. WILLIAMSON: Sure. CHAIR NORMAN: I believe you mentioned one 7 I letter from ConocoPhillips and a second from Exxon. 8 MS. WILLIAMSON: Yeahl I -- the first is an e- 9 mail letterl it is from Mike Hanus dated January 7th and he -- 10 he/s with Exxon I so he was representing Exxon on these 11 I guidelines. The second..... 12 I CHAIR NORMAN: And the letter -- the letterl 13 I of coursel will speak for itselfl but..... 14 MS. WILLIAMSON: Yeah. 15 CHAIR NORMAN: .... .for claritYI the letter is 16 supportive or does the letter make any suggestions..... 17 MS. WILLIAMSON: It takes no exception to them 18 being implemented and it says that they/re thorough in regards 19 to application requirements. They did say the ability to meet 20 accuracy expectations would be a challenge but that/s 21 I something weill work through within this trial period. I Againl 22 they felt it was good we were looking at it on a trial period 23 before going into regulations. They/re asking to be kept 24 informed. 25 CHAIR NORMAN: Okay. Then if you don/t mind METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 ) 9 1, if you'll have me that to keep our records straight we will 2 I ask that that be identified as our first attachment to the 3 transcript. 4 MS. WILLIAMSON: The second one is from 5 ConocoPhillips, Mike Wheatall, dated January 11th. 6 CHAIR NORMAN: Neatall? 7 MS. WILLIAMSON: Wheatall. 8 CHAIR NORMAN: Wheatall. 9 MS. WILLIAMSON: W-h-e-a-t-a-l-l. They have 10 no objections to the issuance; they indicate that they're 11 appreciative of the technical participation that we stimulated 12 and that we allowed input from the -- the fact that we allowed 13 input from all these different agencies and companies. And 14 they feel that it will provide a productive basis for a 15 discussion for multiphase meters in the future. 16 CHAIR NORMAN: Very good, and if you don't 17 mind again, if you'll have me that we'll keep the record 18 straight. 19 MS. WILLIAMSON: And otherwise, we've had no 20 objections that have been submitted to the Commission. 21 I CHAIR NORMAN: Commissioner Seamount, any 22 questions? 23 2 4 ¡II' ment l' oned that conventional meters are -- have plus or minus I: 25 II five percent accuracy. II II II II i COMMISSIONER SEAMOUNT: I have a few. You METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 ) ) 10 1 MS. WILLIAMSON: In total. Each individual 2 piece of the metering can be within plus or minus I believe 3 it's one to two percent, but when you add up the total system, 4 it can -- you can have an uncertainty, I shouldn't say 5 inaccuracy, an uncertainty of in the three to five percent 6 range. 7 COMMISSIONER SEAMOUNT: Okay. You might have 8 missed this or I might have missed this and you might have 9 said it, but how -- what does it look like the multiphase 10 meters compare to the conventional? 11 MS. WILLIAMSON: It -- what we're requiring is 12 it to be within five percent of -- in comparison to the 13' reference equipment that's being used so it would be compared 14 to test separators for instance. However, we have a broad 15 range of criteria where we can loosen that a bit and in the 16 event that -- for instance if this is the only way that you're 17 going to get a development going, which is the case in some 18 places in the Gulf of Mexico, you may be willing to decrease 19 that accuracy expectation. There's several things that could 20 come into play there. 211 22 COMMISSIONER SEAMOUNT: Increase the expectation of accuracy..... 23 MS. WILLIAMSON: To say plus or minus 10 24 percent uncertainty. 25 COMMISSIONER SEAMOUNT: And this will apply to ftr[ETRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 ) ) 11 1 all the pools or do different pools have different ranges of 2 accuracy or sensitivity? 3 MS. WILLIAMSON: That would be all the pools. 4 COMMISSIONER SEAMOUNT: So like North Star 5 would have the same accuracy with multiphase metering as the 6 I Prudhoe Bay oil pool? i 7 MS. WILLIAMSON: And it -- yes, and again 8 though, when a company applies for that multiphase metering, 9 I they would provide the justification for the use of the 10 meters, they would provide information on the accuracy that's 11 expected and if they're asking for an exception to that 12 accuracy, then we would evaluate that. 13 COMMISSIONER SEAMOUNT: Okay. During this two 14 to three year trial period, will these meters be used as 15 official meters? 16 MS. WILLIAMSON: It will be in the same manner 17 as well testing, it would be allowed for -- this would be, 18 these applications would be for allowance of the use of them 19 in an allocation system so, yes, they are official for 20 I allocation of production. 21 COMMISSIONER SEAMOUNT: And what criteria will 22 I be used to approve the use of these after -- I mean, what's i 23 II the criteria for multiphase metering passing the test within I' II h h ' d .. . . 24 Ii t e two to tree year perlo? Is It Just accuracy or lS It -- I: 2 5 il I gue s s . . . . . II II II ,I I II II METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 ") ) 12 1 MS. WILLIAMSON: And reliability..... 2 COMMISSIONER SEAMOUNT: And reliability. 3 MS. WILLIAMSON: And there would be -- have to 4 be maintenance and within our pool rules weld likely have some 5 requirements for coming back to us with information as to how 6 I they performed. 7 COMMISSIONER SEAMOUNT: And finally, while 8 you're going through this pre-hearing period looking at the -- 9 or what, this preliminary evaluation, the multiphase metering, 10 what were the references you used, I mean, who was involved in 11 determining the accuracy or testifying the accuracy? It 12 I sounds ll'ke the Commission worked on it, the operators had 13 some input, Mr. Medis -- Medesaday (ph)? ! 14 MS. WILLIAMSON: Medesaday. 15 COMMISSIONER SEAMOUNT: Medesaday and how much 16 did you rely on the manufacturers? 17 MS. WILLIAMSON: Okay. We did involve several 18 manufacturers in this and I must say that what we're 19 requesting on the accuracy is at the tighter range of that. 20 What we were told is yes, they can -- it's a challenge but 21 I they should be able to meet it. There are some, I have -- I I 22 Ii just heard yesterday that there is some concern from one of 23 I! the companies as to whether or not that might be a little bit II 24 II too tight. Again, I guess we erred on not making it too lose 25 ¡I but rather allowing for a process by which you can expand that Ii Ii Ii Ii II II METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 ) ) 13 1 so -- does that make sense? 2 COMMISSIONER SEAMOUNT: Uh-huh (affirmative) I 3 okay. Thank youl Ms. Williamsonl I have no further questions. 4 CHAIR NORMAN: I have just a few. In the 5 course of developing these guidelines and working them overl 6 has opposition to their use been expressed by any parties? 7 MS. WILLIAMSON: No, I haven/t..... 8 CHAIR NORMAN: Either formally or informally? 9 MS. WILLIAMSON: On an informal basis I should 10 I say that yesterday I -- it/s not oppositionl a concern on 11 whether or not the accuracy requirements are too tight. It/s 12 not -- and this was not officiall it was one person from a 13 company. Otherwise, lIve had no opposition and I should say 14 'I this was like just yesterday when I heard this so..... 15 CHAIR NORMAN: SOl that particular concern is 16, not addressed to that fact that it/s inaccurate I it's that the 17 I Commission is expecting too much out of multiphase metering? 18 MS. WILLIAMSON: Yes. 19 i CHAIR NORMAN: Or may be expecting..... 20 MS. WILLIAMSON: Maybe. 21, I 22 I! of I believe you said two to three years, will multiphase 23 II metering be operated in some cases parallel with conventional II , 'h' 1. h '1 . 24 ¡i meterlng or lS t lS rep aClng t e conventlona meterlng I' ,1 . 1 25 ii entlre y? II II II II il ¡i II II CHAIR NORMAN: During the -- this test period METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 ') ) 14 1 MS. WILLIAMSON: There's no plans to go out 2 and replace all test separators, for instance, but I would 3 anticipate that there will be places where instead of test 4 separators, they will put multiphase meters in. I would also 5 expect that there will be more tests of meters in parallel 6 with a test separator to check their validity for use and 7 allocation purposes. 8 CHAIR NORMAN: Until -- I'm going to state my 9 understanding and then would appreciate it if you would 10 correct me if I'm wrong but, as long as these are adopted as I 11 guidelines, that's what they will be as guidelines. How would 12 you suggest the Commission proceed if someone is not foll- -- 13 if an operator is not following the guidelines, what will be 14 the plan of the Commission? 15 . MS. WILLIAMSON: Well, first of all, as it 16 I would be set out, the operators would be required before using 17 these in an alloca- -- these multiphase meters in allocation 18 purposes, they have to come to us, otherwise they would not be 19 in compliance. I mean, this is on the North Slope, so they 20 would not be compliance if they didn't come to us. Secondly, 21 I they would have to be -- follow the requirements as far as I 22 ¡ documentation of what they're going to do and then get our i 23 I approval for their use. As far as what we would do if they I II 24 II weren't in compliance, I guess I'm not certain we would bring 25 II it in front of the Commission, the staff would bring it to the II Ii 'I II I! II il METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 ') 15 1 Commission for their determination. 2 CHAIR NORMAN: Sure, I understand that, I 3 I appreciate that and I understand that we're somewhat plowing 4 new ground here. I would note for the record that in order to 5 be able to have tight enforceability, we're going to need to 6 I progress to the regulation standpoint and that there are 7 constraints on agencies enforcing guidelines that haven't gone 8 through the full regulatory adoption process. But that's a 9 bridge we can cross as this unfolds. 10 A second question, where else -- in what other 11' jurisdictions right now is multiphase metering being utilized? 12 MS. WILLIAMSON: The major area where this was 13 started was the North Sea and a second area is the Gulf of 14 I Mexico, Venezuela has a lot of them. They are just kind of 15 starting in the California area, in the heavy oil arena. In 16 some of these -- the technology started in areas where -- 17 offshore where in order to allow for testing of wells, they 18 wouldn't actually develop a pool because it's too small if you 19 required full testing, with a normal meter. So they tried to 20 determine and come up with the technology where they could 21 II separately test this and then come up with, for instance, sub- 22 II sea multiphase meters. So, that was kind of the start of the 2311 whole process. In the meantime, the technology has improved 24 as far as accuracy and now it's being considered in 25 II replacement of more conventional -- in a more conventional I! i II METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 ) ) 16 1 manner. 2 CHAIR NORMAN: Insofar as standards are 3 concerned, you mentioned that currently there are none in 4 existence. What about the government of Norway, do they have 5 a standard? 6 MS. WILLIAMSON: They do have a handbook of 7 I multiphase metering that goes over the technology and some of 8 the expectations on that technology, as does Great Britain. 9 It is a little different from ours and these guidelines 10 provide a procedural mechanism on going through the -- getting 11 multiphase meters approved so the guidelines are more 12 procedural than theirs are. Theirs is more of a technical 13 evaluation. Again, though, they're not standards and nobodies 14 I gone to the point of setting up standards for multiphase 15 metering. 16 CHAIR NORMAN: And MMS in the gulf how do they 17 I -- what guidance does MMS offer to operators for use of I 18 multiphase meters, if you know? 19 MS. WILLIAMSON: Well, I -- anything I say 20 would be hearsay so I'd rather -- I don't know that they've -- 21 I've gotten the impression from Parve that we are farther 22 along on this than they are so I -- and again, that's just 23 [, kind of hearsay. But MMS was involved here or did come to 24 some of our meetings as did BLM, and they showed no objection 25 ¡I to what we were doing. fttfETRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 ) 17 1 CHAIR NORMAN: In I believe all of the pools 2 fields where this will be -- these guidelines will be approved 3 for use, I'm guessing that the state of Alaska is the owner 4 there. Someone else may want to speak to this but my question 5 for you is have we had any communication from the state 6 about -- the states about calculation of the state's royalty 7 interest or measurement for revenue purposes, Department of 8 Revenue taxation? 9 10 I is here today, verbally has stated to me that they don't have MS. WILLIAMSON: The DNR, whose representative 11 any problem with it. DOR has not chosen to comment so -- so I 12 don't know. 13 CHAIR NORMAN: And I believe DOR has received 14 i notice of these proceedings..... 15 MS. WILLIAMSON: They certainly have. 16 CHAIR NORMAN: Okay. They're aware of it. 17 I Are there any parties that may be affected by this that have 18 I not received notice to your knowledge? 1911 20 II 21 II multiphase metering, during this trial period, what would you 22! see as a next step, when would you see taking a look at the 23 I! experience level, what period of time, six months, 12 months? !I 24 I: 'I 11 25 II couple at least, two to three applications to go through and II I' Ii II ,I II II II MS. WILLIAMSON: Not to my knowledge. CHAIR NORMAN: As the Commission monitors MS. WILLIAMSON: Well, first of all, we need a METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 ') 18 1, see whether or not the application process is going to work. 2 Then beyond that performance is going to be a key area and 3 we'll want to look at that so I would say you'd want to have 4 some of these installed and working for about six months. 5 Again, I think a -- certainly a three year period, we should 6 see whether or not it's going to be workable and if it -- if 7 we need to extend it, we can do so. 8 CHAIR NORMAN: And if you can in basic terms, 9 tell me how you would approach gauging reliability against 10 what measure would you gauge it? You're going to get a II! reading on the -- out of multiphase metering, but how are you 12 going to know within what..... 13 MS. WILLIAMSON: Whether or not it's 14 reliable..... 15 CHAIR NORMAN: .... . tolerances -- yes. 16 MS. WILLIAMSON: .... . long term? There are -- 17 will be requirements on and going through and testing the 18 meters, not necessarily against the test separator, but to -- 19 there are tests that can be done on this -- on separate pieces 20 of the meters to ensure that it's still reading at the same I 21 II levels that it was before, so we'll be looking at that. We i 22 will also be looking at - - and I don't know if this will make 23 much difference but see whether or not there's anything 24 strange going on with tests over time. Are you seeing a lot 25 of variation in tests that you wouldn't expect? So, we'll be ~IETRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 ) 19 1 taking a look at that. Those are the major ways and then if 2 I we see some real problems, we would go back to the operator 3 and ask them to give us some more information as far as what's 4 going on. 5! CHAIR NORMAN: In that monitoring process will 6 the AOGCC be relying upon operator reports or will AOGCC 7 inspectors have the capability to independently test this? 8 MS. WILLIAMSON: I think we would try to do 9 this through the reporting mechanism. Normally AOGCC 10 inspectors do not go to inspect test separation equipment. II! That's not to say they can't, you know, but they -- normally 12 we haven't done that at the Commission. 13 CHAIR NORMAN: We have a variety of reservoirs 14 that may begin to use this and my question's a general one but 15 to what extent can we rely upon differences in ownership to 16 cause working interest owners themselves to take an interest 17 in accuracy, if you follow what I'm saying. In other words, 18 for purposes of allocating production within a unit for 19! example, that certainly is in the interests, that's something I 20 working interest owners pay attention to to make sure they're 21 getting their fair share. Within these test areas, will we I 22: have that incentive for monitoring by parties with potentially 23 Ii differing interests to try to ensure accuracy? II 24 'I ¡ 25 Slope particularly at Prudhoe Bay and Kuparuk, we have a MS. WILLIAMSON: I think so. On the North METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 ) 20 1 process where at least once a year we get together to review 2 allocation and production. Within that process I would see 3 I that we might take a look at multiphase meters in a separate 4 manner here, but in these allocation meetings, we have 5 representatives of DOR, DNR, AOGCC and the owners, so that's 6 everybody that would be affected by inaccuracies and 7 allocation. So, I see that we have that mechanism now and 8 this would be just incorporating that into the current 9 mechanism. 10 CHAIR NORMAN: Thank you. Commissioner 11 Seamount, do you have anything further of Ms. Williamson? 12 COMMISSIONER SEAMOUNT: No, I don't. 13 CHAIR NORMAN: Okay. Well, Ms. Williamson we 14 thank you very much for your testimony. You've stated things 15 very clearly and you've answered all our questions. I would 16 I ask if you wouldn't mind that you remain here, you may stay 17 seated, and I'll see if there are any other parties present at 18 I this hearing that wish to offer any testimony. Are there any I 19 other persons present in the room who would like to testify? 20 Okay, the Chair does not see anyone asking for recognition so I 21 ¡ the Chair interprets that as no other persons wishing to offer 22 testimony. 23 I would like to thank you for all of your effort in I 24 i bringing this forward and I think it's a challenging project 25 and it's interesting to see Alaska pioneering in this endeavor METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 ") ) 21 1 and 11m sure that weill be revisiting this subject 2 periodically as we all gain experience in it. 1/11 call once 3 more for the purposes of the record to see if there are any 4 other comments or any other persons wishing to say anything. 5 Againl the Chair notes that no other persons have requested to 6 testify. Commissioner Seamount I any final comments? 7 COMMISSIONER SEAMOUNT: None other than I 8 agree with your thanks of Ms. Williamson and the task force in 9 working on this project. 10 CHAIR NORMAN: Okay. Thenl without objectionl 11 we will adjourn and these proceedings are closed. 12 (Off record) 13 14 I * * * END OF PROCEEDINGS * * * 15 16 17 18 19 20 21 , I 22 23 i ¡ 24 I ! 25 i i ! METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 ') ') 1 C E R T I FIe ATE 2 SUPERIOR COURT ) )ss. ) 3 STATE OF ALASKA 41 5 I, Jerri Young, Notary Public in and for the State of Alaska, do hereby certify: 6 THAT the annexed and foregoing pages numbered 2 7 1 through 21 contain a full, true and correct transcript of the Public Hearing before the Alaska Oil and Gas Conservation 8 I Commission, taken by Sharon Wilcox and transcribed by Jerri Young: 9 THAT the Transcript has been prepared at the request of 10 i the Alaska Oil and Gas Conservation Commission, 333 West Seventh Avenue, Anchorage, Alaska, 11 DATED at Anchorage, Alaska this 24th day of January, 12 2005. 13 SIGNED AND CERTIFIED TO BY: 14 15 ~\\\\\\UUIIIII/ ~'OûNG I~ ~ ~ ....,....... ~ ;::: ~ ...... ....0 Z S :"'Çl -°. ~ ::::0:1 ~R y ~ ~ :: wi "" \ II( e - -,: 0 if $¿ :: «I- S \2/:V ¡.,= ~ ..0 f'~<b l ::::: ~ .00 .-~~ ~ --.. ..." Co "..s ~ .........00 0"" '§: ~ .State ~ r¡111/1I1 n\ \\\\'\ CY ~ U;t~~ Jerri Young , Nota~ in and f Alaska My Commission Expires: 11 03/07 16 17 18 19 ! 20 21 22 I 23 r 24 25 METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 ~. ...Ì' '\y.. ..... .... ConocoPhillips Alaska ') RE: Guidelines for Qualification of Multiphase Metering Systems for Well Testing January 11, 2005 John Norman Dan Seamount Commissioners Alaska Oil and Gas Conservation Commission (AOGCC) 333 W 7th Ave # 100 Anchorage, Alaska 99501-3539 ConocoPhillips Alaska, Inc. ("ConocoPhillips") has no objection to the issuance of the "Guidelines for Qualification of Multiphase Metering Systems for Well Testing" contained in the November 30, 2004 draft posted on the AOGCC website to be considered at the January 11, 2005 hearing. ConocoPhillips appreciates the technical participation stimulated by the AOGCC among Operators, Service Companies, and Consultants, allowing input throughout the compilation of these draft Guidelines. These Guidelines will provide a productive basis for discussion as multiphase meters are introduced to North Slope operations. We look forward to further opportunities in assisting with revisions of these Guidelines, as experience is gained in multiphase"metering technology. Regards, M1. }tV, W~ Mike Wheatall GKA Operations Manager cc: Paul Dubuisson Steve Kruse (r) Scott Fahrney Mark Ireland (r) Chirs Alonzo James Rodgers (r) Kenneth Martin Elizabeth Goudreau ConocoPhillips Alaska. Inc. is a Subsidiary of Co no coP hill ips Petroleum Company -.- ----- -- -.-- -.- 0---------- --- - .--_u ---J:'- ... ') Subject: Re: Hearing Ian 11 - Adoption ofMPM guidelines för North Slope Reservoirs From: mike.hanus@exxonmobil.com Date: Fri, 07 Ian 2005 14:09:50 -0900 To: Mary Williamson <jane - williamson@admin.state.ak.us> CC: sonny.rix@exxonmobi1.com, rob.g.dragnich@exxonmobil.com, charles.s;luna@exxonmobil.com, BradyJL@;BP .com, Scott.Fahrney@conocophillips.com, roy.ck.meyer@exxonmobil.com, mike.j.mullaIly@exxonrnobil.com ) Mary, I have read the latest draft of the guidelines, and within ExxonMobil we do not take exception to them being implemented on a trial basis. Recognizing that the AOGCC has authorization over well test metering, the guidelines are thorough with regards to application requirements for getting a multi-phase metering system approved. The ability to meet the accuracy expectations in Section 3.2 will be a challenge. However, we recognize that the use of multi-phase meters is dependent on giving well test and production allocation results that are comparable or better than that which can be achieved with test separators. Before the AOGCC moves forward on adopting these guidelines into state-wide regulations, EM would like to have the opportunity to review and provide comments. I will not be attending the January 11 hearing, but please include me on correspondence on the hearing results. Sincerely, Mike Hanus ExxonMobil Mary Williamson <jane williamson@admin.s .:::Jam~~. 'I'. Rodgers@conocophillips ..£om>, tate.ak.us> Scott.Fahrney@conocophillips.com, mike.hanus@exxonmobil.com cc: To: "Rodgers, James T" E?S?~b::!:..!.l:.~.~~S?_9_~.:..~~~3. ' BradyJL@BP.com Subject: Hearing Jan 11 - Adoption of MPM guidelines for North Slope 01/04/05 06:04 PM Reservoirs All, We will be holding a hearing on Jan. 11 at 9 am concerning adoption of our MPM meter guidelines for North Slope pools. It would be good to have on record whether the major owners of the North Slope fields support the use of the guidelines or if there are any concerns. Jerry Brady indicated that BP is pla~~ing to send a short letter in support. I was wondering if Exxon and Conoco-Phillips would consider doing the same? We anticipate that we'll adopt these guidelines for a trial period¡ and ultimately we'll propose adoption within the State-wide regulations, with revisions which result from this trial period. As we haven't received comments on this latest (Nov. 30) draft, I expect that 10f2 1/10/2005 5:31 PM .........-. """'--"""'''''''''0 """"",,,.L ..... ..I. "'-'VY"'.L'V'.L.L '-'..... ""'.J...J.. J..""'" ó""'.I,.u."'.l1..I,..lV~ J.V.I,. .l"V.1. '-.1.1. Ul.Vp\.l' ... . ) . h h 'd 1, h h ") there are no maJor concerl1S Wlt t e gUl e lnes. T oug wt..haven't received comments, Chairman Norman wants to hold the hearing anyway as these may ultimately be adopted within regulations. The guidleines are available on line at ~!.~!._~,§:g9s:_c:;-~---~_~_~_~l~,~SlS?_y.l!:'!~_t::_~Eg_\~~~-.:_,h,!:~ Please call if you have questions. Jane 20f2 1/10/20055:31 PM ') ) Recommendation to Adopt Multiphase Meter Guidelines in North Slope Pool Rules Recommendation AOGCC staff recommends adoption of the "Guidelines for Qualification of Multiphase Metering Systems for Well Testing" dated November 30, 2004, for use of multiphase meters for well testing for all North Slope pools. Commission Authority By Statute (Title 31, Sec. 31.05.030(d)(6» and regulation (20AAC25.230), oil, gas, and water production from Alaska wells must be measured using techniques and equipment acceptable to the Commission as accurate and reliable (20AAC25.230). By regulation, the Commission requires well tests to be conducted a minimum of once per month. By conservation ordesr, two well tests per month are required in many North Slope pools to provide quality assurance in production allocation. Purpose of Well Tests Well tests are an important component in reservoir management and allocation of production to pools. Production from many of the Alaska reservoir pools is commingled on the surface and processed using common facilities serving several pools within a field. Total field sales volumes of oil and gas are continuously monitored using custody transfer metering systems, generally referred to as LACT meters. LACT meters are required by regulation to provide accurate measurement to +/-0.25%. Because the pools do not have dedicated processing facilities and pool sales volumes are not separately measured through LACT meters, production volumes must be allocated back to wells on the basis of well tests, and then to the pools on the basis of comparison of the total sales volume to the summation of all well production estimated through well tests. Figure 1 is a simplified flow diagram illustrating the typical flow and allocation metering in a North Slope field where production from multiple pools is commingled. No well test equipment can guarantee accuracy to the requirements of the LACT meters, and wells are not continuously monitored, further causing uncertainty in production allocation. Often pools within the same field will have differing working interest, royalty interest, or severance tax treatment. Inaccuracies in well tests will cause errors within the final reported production of a pool, potentially affecting revenue of parties. It is therefore essential that the equipment and methodology for production allocation provide for accurate measurement. Multiphase Meterin2 Technolo2Y Multiphase meters (MPMs) appear to be a promising substitution for conventional test separator based well test systems. With multiphase metering, full separation of fluids is not required. Alaska faces very high capital costs for new developments, and MPMs may playa part in decreasing these costs, decreasing facility footprint and perhaps improve allocation of production. BP Exploration (Alaska), Inc. (BPXA) and ConocoPhillips Alaska, Inc. have conducted field trials of a number of commercially available MPMs in Prudhoe Bay Unit and Kuparuk River Unit pools to assess their effectiveness in current operations as well as for future asset developments. January 11, 2005 Page 1 of3 Recommendation to Adopt Multiphase Mt: )Uidelines in North Slope Pool Rules ) Multiphase metering is a relatively new technology. Industry standards and recommended practices are in place for 2-phase or 3-phase test separator based systems. However, no standards and few guidelines have been published for multiphase meters. Purpose of Guidelines Considering that the multiphase metering technology is relatively new and that accurate well test metering has both financial and reservoir management importance, AOGCC initiated a project to understand multiphase metering technology and prepare for its application to well testing. With industry input, "Guidelines for Qualification of Multiphase metering Systems for Well Testing", were prepared to direct the operator and AOGCC personnel on how to qualify these new measurement techniques and to provide a consistent process for the evaluation of the proposed metering systems. We believe that with consistent processes, the overall effort and time to prepare and process applications will be reduced, while assuring sufficient accuracy is maintained. Custody transfer applications are regulated separately and are outside the scope of the guidelines. Content of Guidelines Two documents were prepared to provide a consistant process for preparation and review of applications for use of MPMs, and to provide basic education to the layman on the principles of muItiphase measunnent. The first document, "Guidelines for Qualification of Multiphase metering Systems for Well Testing" (November 30, 2004) is the governing regulatory document and "Principles of Multiphase Measurements" (November 30, 2004) provides basic information concerning the technology, a list of references for further education, and a list of terms and definitions. . The guidelines describe the AOGCC administrative process for review and ruling upon application for MPM installation, requirements for meter performance and documentation to be submitted within the application, and recommendation for the conduct for field tests, if required. Process of Guidelines Development In the development of these guidelines emphasis was placed upon ensuring adequate review be afforded to industry. The effort towards development of the guidelines began in early 2004, with an initial draft submitted in May 2004 to all Alaska operators, vendors of MPMs, other state and federal agencies, and industry experts involved in multiphase metering and well testing. The guidelines were revised to incorporate subsequent comments received. A second draft was then distributed and final guidelines incorporating industry comments were published in November 2004. The Alaskan petroleum industry has shown support and substantial involvement in the development of the guidelines. Proposal for Application of Guidelines In the near future, the AOGCC anticipates applications for use of MPMs in North Slope fields. We wish to test the workability of these guidelines in the coming year or two. We may then recommend adoption of the guidelines within the statewide regulations, with revisions as needed based on the initial applications in the North Slope Fields. January 11,2005 Page 2 of3 . . ~ U) ) ) STATE OF ALASKA OIL AND GAS CONSERVATION COMMISSION Guidelines for Multi-phase Metering January 11, 2005 9:00 AM NAME - AFFILIATION ADDRESS/PHONE NUMBER TESTIFY (Yes or No) (PLEASE PRINT) , /f>~ ~ 6~/ ç~ Ap?/ 0/ c),,;;I(~>~'S>/"ÇÛ;/ ¿C 7(J8 20 /V 6 ~~ç ~a5EfZA ~l1c>(on¡JIIPJ 7ó1-tS7f-7Zzt, .Alo 0~Þ- ~1-~ k~vL-- 1f?--l~)1- ¡JÓ TÓA<-Jtd~. MfkYC 7/f3-/ó2-:J4 y~ ::t:t:: ~ ) ) GUIDELINES For QUALIFICATION OF MUL TIPHASE METERING SYSTEMS FOR WELL TESTING November 30, 2004 Alaska Oil & Gas Conservation Commission www.aogcc.alaska.Qov Prepared by: Parviz Mehdizadeh, Ph.D. Production Technology Inc. Jane Williamson, P.E. Alaska Oil and Gas Conservation Commission AOGCC Guidelínes for ..\ Qualification of l\t1ultiphase., __..:teri.ng Systems 11-30-04 Parvíz IVlehü-,___,-i'f,roducrìon Technology lne / Jane \Vilhamson. AOGCC Guidelines for Qualification of Multiphase Metering Systems for Well Testing Table of Contents 1.0 Purpose................................................................................... 3 1.1 Organization of the AOGCC Guidelines...........................4 1.2 "Principles of Multiphase Measurements" ........................4 2.0 AOGCC Administrative Process ............................................5 2.1 Application Contents-General.......................................... 5 2.2 Review Process............................................................... 5 2.3 AOGCC Decision.... ..................................................... .... 6 3.0 Qualifying Multiphase Metering Systems for Well Testing..6 3.1 Application Contents........................................................ 6 3.2 Accuracy Expectations............. ...................... ......... ........8 4.0 Validation of Meter Performance in Field............................ 1 0 4.1 Field Verification ............................................................10 4.2 Field Test Plan...............................................................11 4.3 Reporting the Field Results............................................ 13 2 of 15 AOGCC Guidelines for \ Qualification oLVlultiphase _Jering Systems 11-30-04 ParVlZ J\'Iehc___d ..."... )roductìon Technology Ine hane \Vìlli.amsOtL AOGCC Guidelines for Qualification of Multiphase Metering Systems for Well Testing 1.0 Purpose 1.0.1 The use of multiphase meters for well testing is gaining increased support within petroleum production operations. It is anticipated that Alaskan operators will be pursuing their use in well testing and field production allocation. 1.0.2 Multiphase meters are devices that measure oil, gas, and water flow rates of a well stream with or without partial separation of these components into individual phases. Multiphase metering techniques were developed as an alternative to measurement methods using two and three phase gravity based test separators. 1.0.3 The Alaska Oil and Gas Conservation Commission (AOGCC) is authorized to evaluate and approve methodology and equipment utilized for well testing and allocation of production in Alaska per regulation (20 MC 25.230) and Alaska Statute (Sec 31.05.030(d)(6)). 1.0.4 Industry standards and recommended practices are in place for test separator based single-phase gas or liquid metering. However, there are no standards and few guidelines available for multiphase meters. 1.0.5 Considering that the multiphase metering technology is relatively new and that accurate well test metering has both financial and reservoir management importance, the AOGCC will require approval prior to use of mutiphase meters to satisfy requirements of 20 MC 25.230. These guidelines are provided to train and direct the operator and AOGCC on how to qualify these new measurement techniques. 1.0.6 These guidelines address both wet gas and multiphase metering systems for use in well testing. Custody transfer applications are regulated under 20 MC 25.228 and are outside the scope of these guidelines. 1.0.7 The materials described in the "Guidelines for Qualification of Multiphase Metering Systems for Well Testing" were developed to serve the following objectives: 3 ()f 15 AOGCC Guidelines for ) Qualifîca rion of iviultiphase l. J.ering S ystem.s 11-30-04 Parviz ìVlehc___...df' -"~roducrìon Technology lnc !Jane \Vì1liamsoIL AOGCC As a guide for the operator in submitting a request to apply new multi phase metering techniques for well testing and allocation of production, As a guide and process tool for reviewing operators' requests for qualifying a multi phase metering system for well testing, and As a training tool for AOGCC personnel who will be involved in the assessment of the multi phase technology for well testing. 1.1 Organization of the AOGCC Guidelines 1.0.7.1 1.0.7.2 1.0.7.3 Section 4 The remaining sections of this document are organized as follows: Section 2 AOGCC Administrative Process: This section outlines the overall administrative process that will be followed for certification of a multiphase metering system. Qualifying Multiphase Metering Systems for Well Testing: AOGCC expectations of documentation to accompany the application for pre-certification or certification of the proposed multiphase metering system are described. Validation of Meter Performance in Field: In some instances, the AOGCC may require field verification of meter performance prior to approving use. This section provides recommendations and requirements for conducting these field tests to gather information required by the AOGCC for qualification of the multiphase metering systems and outlines requirements for documentation of the field test results. Section 3 1.2 "Principles of Multiphase Measurements" A separate document, "Principles of Multiphase Measurements", is concurrently issued with these guidelines. This document provides basic information on multiphase meters, a list of references for further education on multiphase meters, a list of terms and definitions, and installation suggestions for multiphase meters. It is recommended that the novice review the "Principles of Multiphase Measurements" document in conjunction with these guidelines. 4 of 15 AOGCC Guidelines for \ Qualification of?vlultiphase - "~ering Systems 11-30-04 Parviz J.\¡lell(,___.(ì~roductìon Technology lne JJallè Wì11iamson. AOGCC 2.1 2.0 AOGCC Administrative Process 2.0.1 This section describes the AOGCC review and decision process that will be used in processing requests and summarizes required application contents. Section 3 provides further detail on required application content. 2.0.2 AOGCC approval will be required prior to use of multiphase meters in well rate determination to satisfy requirements of 20 MC 25.230. 2.0.3 AOGCC approval will not be required for minor changes (such as meter size or minor technical upgrades that will not deteriorate performance) of previously approved meter systems. However, if production characteristics change significantly (such as large changes in GVF and water cut) from the initial approved application, a new application must be submitted. Approval will not be required for use of multiphase meters if the well test results are not used to satisfy monthly production reporting and well test allocation requirements of 20 MC 25.230. 2.0.4 The AOGCC will only approve use of a multiphase meter system by Commission order adopting or amending pool rules under 20 MC 25.520 or, in the Commission's discretion, by administrative approval where provided under an existing order. However, in the case of a pool for which pool rules have not been adopted and for which the applicant demonstrates that pool rules are not yet needed, the Commission will consider an ad hoc application for an order under 20 MC 25.540 approving use of a multiphase meter system. Application Contents-General The application must include a cover-letter request with a summary description of the proposed meter system, discussion of how the proposed meter will be used for the determination of well production within the allocation system, reference to the conservation orders which prescribe the rules for development and operation of the pool, requested changes to the conservation order, and other documentation described in Section 3. 2.2 Review Process 2.2.1 It is recommended that the applicant contact the AOGCC early in the evaluation process to decrease the, ultimate time to process applications and to reduce the risk of later costly revisions to plans. 5 of 15 _t~O~(::C ?uide~ines f?r ),- Quahhcanon of .Multlphase ">_iÇtenng Systems 11-30-04 Parviz MelwÅ_,'}:roducrion Technology Ine i Jane \Vìlliamson. AOGCC 2.2.2 If the application is deemed complete, AOGCC will notice the application for public comment and potential hearing, unless handled by administrative approval. By regulation, a minimum of 30 days is required for public comment from the date notice is issued. In some cases an oral hearing may also be held. Applicants should expect the full approval process, from submittal of a complete application to AOGCC decision, to take 30 to 60 days. 2.3 AOGCC Decision 2.3.1 If sufficient information is provided, the AOGCC may approve the system either unconditionally, or conditionally upon field testing and subsequent reporting of meter performance. Any approval is conditioned upon maintenance of the multiphase meter to provide accurate and reliable measurement, and will require periodic calibration of the multiphase meter and records to be kept to verify the calibration of the meter. 2.3.2 An applicant that is dissatisfied with the AOGCC's decision has the option to request reconsideration ("rehearing"). 3.0 Qualifving Multiphase Metering Systems for Well Testing The operator shall submit a proposal to the AOGCC for deploying the multiphase meter or meters in a designated application as a well testing system. 3.1 Application Contents A complete application must address the following: 3.1.1 Discuss the intended application, proposed location and projected timing of installation of the meter. 3.1.2 List fields, pools, and wells affected by the proposal. Are multiple pools commingled? If so, provide details. 3.1.3 Outline any differences in working interest, royalty interest, and tax treatment for leases or for commingled pools. 3.1.4 Ensure that all working interest owners, royalty owners (e.g. Alaska Department of Natural Resources), and state revenue department (Alaska Department of Revenue) are notified. 3.1.5 Describe the meter make, model, type and measurement 6 of 15 AOGCC Guidelines for, Qualification ofl\riultíphase" -~ríng Systems 11-30-04 Parviz Ìvlehü,- je1~roductìon Technology Ine Jane Wìlliamson, AOGCC methodology for the intended applications. 3.1.6 Describe plans for field-testing the meter (see Section 4). If no field-testing is planned, provide justification. 3.1.7 Provide data on the performance of metering systems obtained from laboratory or field tests. Discuss the expected effect of the proposed meter system upon the quality of the well test data measurement accuracy and overall production allocation in the planned application. 3.1.8 Provide information on expected precision, repeatability, and bias over the range of conditions for which the meter is planned for use. Accuracy must be evaluated across the full range of expected production flow rates, water cut 0NC), gas volume fraction (GVF) and process conditions for which the system will be used (see also Section 4.3). 3.1.8.1 Review accuracy for each phase. 3.1.8.2 The method of accuracy description must be clearly defined. It is preferred that the accuracy be expressed as the percentage (+/-) uncertainty in the flow rates for each phase - i.e. oil, water, and gas flow rates. Other methods may be accepted by the AOGCC on a case-by-case basis if sufficient justification is provided. 3.1.8.3 A numerical degree of confidence in the accuracy estimate must be provided and method of determining the confidence level must be discussed. In general, accuracy must be evaluated at a 90% or higher level of confidence. Other confidence levels or statistical analysis of confidence may be accepted by the AOGCC on a case- by-case basis if the methodology for determining confidence level is explained and sufficient justification is provided. 3.1.9 Summarize the production allocation methodology currently being used and explain how the meter will be incorporated into the existing methods of well production allocation. 3.1.10 Describe the contingency plan in the event the meter system does not meet the expected performance. Can the meter be changed out if the system does not meet expected performance, or if the well conditions change such that the production is outside the 7 of 15 AOGCC Guidelines for \ Qualiricarion ofl\1ultiphaseL.. .1ering System.s 11-30-04 Parviz r./Iehüt._._J¡;>' ''1\. lroductìon Technology lnc Jane \Vì1liamson. AOGCC original designed operating envelope of the meter system? How will this be accomplished? 3.1.11 Submit plans for quality assurance of long-term accuracy. 3.1.12 Describe the proposed systematic maintenance of the measurement system, including methods and frequency of periodic calibration. Describe the proposed record keeping and reporting format. 3.2 Accuracv Expectations 3.2.1 Generally, the AOGCC will expect accuracy for the pay fluid (oil or gas) from the multiphase meter to be within :t 5°10 over the full range of rates, GVF and WC that the meter will measure when in service. It should be noted that this 5% is relative to the reference equipment. 3.2.2 When a multiphase meter is tested against a reference test separator in the field, the accuracy of fluid measurement by both the test separator and multiphase meter will affect the accuracy of the data obtained by the process. Using a root mean square (RMS) approach, the total probable error (accuracy) of the process is determined by: TPE = (E2TS + E2MP) ~ Where: TPE = total probable error in the measurement E TS = error due to the Test Separator measurement E MP = error due to the Multiphase Meter measurements As an example, if the test separator accuracy is 5% and the multiphase meter accuracy is SOlo, the total probable error will be 70/0. To obtain a meaningful multiphase meter accuracy, it is critical that the error of the reference equipment be less than 50/0. (See also 4.2.2) 3.2.3 Some circumstances may warrant the use of multiphase metering for production allocation even if the meter accuracy is outside the ranges noted above. The AOGCC will consider applications on a case-by-case basis if thorough justification is provided with the application to the AOGCC. 8 of 15 AOGCC Guidelines for ' Qualification ofJ\iultìphase ~~ring Systems 11-30-04 ParvÎ.z IVIehü.,__Jé,.L.)-¡rOdUCtion Techn.01Ogy luc ane \Villiamson. AOCiCC 3.2.4 The applicant shall provide justification for use of a meter system that will operate outside the above stated accuracy criteria. The following are examples where the AOGCC may determine it to be appropriate to relax these criteria. 3.2.4.1 If the meter is used solely for reservoir management and there are no significant financial impacts resulting from well test allocation with multiphase meter systems, less accuracy may be acceptable. 3.2.4.2 Relaxation of accuracy criteria may be appropriate if agreed to by all parties that are financially impacted by inaccuracies of the meter system. 3.2.4.3 It may be very difficult to obtain valid, accurate well tests with conventional separator based systems. As an example, some produced fluids may be extremely difficult to separate and lack of adequate separation will cause large errors in readings. In such instances, use of multiphase meters operating outside of the stated accuracy targets may provide better accuracy and may be preferable to use of separator based systems. 3.2.4.4 Multiphase meters often reduce the measurement system footprint and visits by on-site personnel compared to gravity based separation systems. Multiphase meters may therefore provide an environmental advantage in new, remote drillsite developments and may improve chances of development approval from other regulatory agencies with authority over land use and environmental conservation. 3.2.4.5 Multiphase meter systems may facilitate more frequent well tests as compared to a gravity separator based system. The stability of production during the non-test times will greatly affect the overall allocation accuracy. With more frequent testing and the resulting greater certainty in well test production, overall production allocation may be improved even if the absolute accuracy of the multiphase meter is less than that of the gravity based test separator. 90f1S AOGCC Guidelines for Qualification of?vlultíphase 11-30-04 lríng Systems Parviz IvIeh<.I., ..jé'J.{ro(:uc~~OI.: Te~hno~og~, 1:1C Jane \\ llham::;on, AObCC 4.0 Validation of Meter Performance in Field 4.0.1 The AOGCC will generally require field validation of meter performance prior to final approval. This section provides a guide to the operator in planning a field test to verify the performance of the measurement system and required documentation of these tests. It is strongly encouraged that the field test plan be reviewed with the AOGCC prior to actual field-testing to ensure required data is obtained and to help speed the approval process. 4.0.2 In determining whether to waive the requirement of field testing in a particular situation, the AOGCC will consider such factors as other performance validation options, including prior successful field tests for similar types of fluids and flow conditions, the purpose to which the multiphase metering system will be put, and the practicability of field testing. 4.0.3 Situations where the AOGCC may choose to waive requirements of a field test include but are not limited to the following. 4.0.3.1 Field validation may be unnecessary if the meter system has been successfully tested in a field with similar fluids, flow regimes, operating conditions, rates, GVF and WC. Results of the prior testing must be provided. 4.0.3.2 If the meter is used solely for reservoir management purposes and other lab or field tests are available at similar conditions, a field test may be unnecessary. 4.0.3.3 Field validation of multiphase meters may be difficult, logistically impossible or highly impractical in some instances, particularly for new, remote drill sites. In lieu of a field test, the AOGCC may accept other lab or field tests conducted at similar operating conditions 4.0.4 If the AOGCC determines that a field verification of the proposed multiphase metering system is required, the processes described in the remainder of this section must be followed. 4. 1 Field Verification 4.1.1 The field tests must be conducted under normal field operating conditions. 4.1.2 Field tests require comparison to reference field measurements. Options used to determine the reference flow are: ¡ 0 of 15 AOGCC Guidelines for ') Qualification of ?v1ultiphase l\,,~œríng Systems 11-30-04 Parviz :LvIehü<- Ate"'rocluctìon Technologylnc ,Jane vVì1liamson. AOGCC 4.1.2.1 Capturing fluids that flow through the system during the test and measuring them with secondary equipment. This option requires extra equipment that must be calibrated per appropriate standards. Indexing the performance of the new system against an established well test measurement system such as a conventional gravity based test separator. A combination of the above. 4.1.2.2 4.1.2.3 4.1.3 There may be a large uncertainty in the reference measurements. Pre-calibration and maintenance of the reference measurement system must be performed prior to conducting the field trial. 4.2 Field Test Plan The following is a guide for planning of field tests and may be revised to suit specific conditions. 4.2.1 Establish performance expectations that are within the design and tested constraints of the system. 4.2.1.1 Multiphase metering accuracy degradation typically occurs for wells that have operating liquid rates, gas rates, water cut, or gas volume fractions outside the system's designed accuracy range. 4.2.1.2 The multiphase metering system must be sized and designed to handle the flow range, pressure, and temperature (ambient and production) conditions existing in the field. 4.2.1.3 Multiphase meter performance is also related to the fluid composition such as salt content of the liquids, impurities in the gases etc, which can change over the field life. 4.2.2 In a majority of qualification tests, 2-phase or 3-phase gravity based test separators are used to verify the performance of other multiphase measurement systems. Since these systems are used as the reference, the test plan must document the procedures used to calibrate and establish the accuracy of the liquid and gas measurement devices, the water cut analysis and monitoring, and the data acquisition and recording. 4.2.3 Full separation is rarely achieved and the procedures must make 11 of 15 AOGCC Guidelines for \ Qualification. ofNlultìphase,,- -1ering Systems 11-30-04 Parviz rvreh(l. ,Je1.<\Ç.. roducrion Technology lue lane Vvì1hamson, AOGCC an allowance for reduced instrumentation accuracy of the reference under field conditions. 4.2.4 Multiphase meters must be calibrated initially to accommodate the properties of the field fluids. The calibration procedures to be used prior to the field tests must be described. The calibration procedures must cover both the multiphase metering system as well as the reference systems. 4.2.5 Quite often the multiphase meter, the reference test separator, and the tanks used for fluid measurements are operating at different pressures and temperatures. Measurements made by these systems must be converted to rates at standard conditions (14.65 psia and 60 OF). Actual test measurements, prior to conversion to standard conditions, must be retained. Procedures used to determine shrinkage and conversion of volumes to standard conditions must be addressed. 4.2.6 Once the initial calibration is done, the field test results must be obtained without further intervention in the settings of the multiphase meter. If repair, resetting, or recalibration is required during the field tests, the nature and frequency of these interventions must be recorded and reported. 4.2.7 One of the major objectives of the field test is to evaluate the performance of the multiphase metering system over the full range of gas volume fraction and water cut since these are the two principal factors in determining the accuracy of the multiphase metering systems. To accomplish this, an outline of the test matrix to be used in the field tests is needed, noting the range of flow rates, GVF, and we to be covered in the field tests. It is recognized that this matrix may be limited by the flow rates of the wells available, however the test matrix must cover a wide enough range to allow for practical evaluation of the performance. 4.2.8 The testing program must cover enough data points to allow a statistical evaluation of the accuracy performance such as the number of points in the tests that can meet the acceptance criteria of Section 3.2. 4.2.9 The proposed method for reporting the field test results must be described (see Section 4.3). í:2 of 15 AOGCC Guidelines for ) Quali1leaÜon ofYlultiphase .eríng Systems 11-30-04 Parviz lvIelKc, ,j¡""'f..'. roduction Technology lne hane \Vìlliamson. AOGCC 4.3 Reporting the Field Results 4.3.1 Thorough documentation will be required if field verification is required by the AOGCC prior to final approval of the multi-phase meter system. A report must be submitted to the AOGCC describing the results of such field trials, including accuracy results. The guidelines described in this section are recommended for formatting the report of the field test results. Alternate formats may be used. Regardless, it is required that evaluation of performance be provided as a function of factors (rates, fluid properties, operating conditions, GVF, WC, etc.) found to significantly affect accuracy. 4.3.2 All flow performance data for the metering system must be described in conventional oilfield units at standard conditions. 4.3.3 Individual well test results as measured by the multi phase meter and the reference measurement system must be provided and include the following: 4.3.3.1 Flowing pressure - measured at the meter in pounds per square inch absolute (psia). 4.3.3.2 Flowing temperature - measured at the meter in degrees Fahrenheit (F) 4.3.3.3 Oil rate - Stock Tank Barrels of Oil per Day (STBD) corrected to standard conditions, at 14.65 psia and 60°F. 4.3.3.4 Water rate - barrel per day (BPD). 4.3.3.5 Gas rate - thousand standard cubic feet per day (MSCFD), at 14.65 psia and 60°F. 4.3.3.6 Gas-ail-ratio (GaR) - (SCF/STB) the gas volume flow rate, relative to the oil volume flow rate, both converted to volumes at standard pressure and temperature. 4.3.3.7 Gas Volume Factor (GVF) - gas volume flow rate, relative to the multi phase volume flow rate (oil, gas, water), at the pressure and temperature prevailing at the meter. The GVF is normally expressed as a percentage 4.3.3.8 Water cut (WC) - the water volume flow rate, relative to the total liquid volume flow rate (oil and water), both converted to volumes at standard pressure and temperature. The WC is normally expressed as a percentage. 13 of 15 AOGCC Guidelines 1'0, ') Qualification ofJ\!lu1tiphase L\>,~(eríng Systerns 11-30-04 Parvíz Mehe j{" 'Ttro(~uct}.o::~<.Te.~hno~og~,I~l~ Jan~ \À¡ llnamson. A.O<JCC 4.3.3.9 Water-in-liquid ratio (WLR) (optional) - the water volume flow rate, relative to the total liquid volume flow rate (oil and water) at the pressure and temperature prevailing at the meter. The WLR is normally expressed as a percentage. 4.3.3.10 Fluid properties including: . Oil volume factor (Barrels at meter conditions/STB) . Gas volume factor (Cubic feet at meter conditions/SCF) . Water salinity . Oil gravity (° API) . Gas specific gravity 4.3.4 Figure 1 shows an illustrative graphical method that may be used to display accuracy results as a function of oil, water, and gas flow rates, WC, GVF or other important factors. In this figure the y coordinate represents flow rate error relative to the reference measurements. 4.3.5 Repeatability of the measured data and confidence level (see 3.1. 8.3) must be stated. The repeatability is expressed by the following relationship: . . (max error)- (min error) repeatabllzty = ~ number of tests i 4 of 15 AOGCC Guidelines 1'01)\ Quahfîcarion oL\-1ultiphase l\_~~,érí:ng Systems 11-30-04 Parviz f./lehl.___..lc1é',r....V.. oduction Technology Ine Jane \Villiamson. AOGCC Fig. 1 - An illustrative graphical method of reporting the accuracy performance of multiphase metering systems. These plots should be provided for each phase compared to GVF, water cut, and other important parameters. Liquid Flowrate Error vs. GVF 50 ~ 40 0- t:: ~ 30 W 55 20 ~ CD Q) 1; Õ) 10 ~c:: ~ .9 0 0 Q) -10 - > LL ~ -20 "C Q) .- c:: -30 ~ 0 .2"' ~-40 ...J -so, 20 ... , J>. ~t ~ . A (::-~ ~J:.. j. a. Â ~. ~. Á t ~ t I Â¿ .i TeStD~ F:' ..¡ ¡a.' A ~mÎI.A -:I . À.t. :. At. Â A ..A A" Á I Â A Á 4t~, ¡ Blue Lines, Range of relative flow rate error I I I I ! 30 40 50 60 70 80 90 100 Reference GVF (%) i) ()l' 1) ) ) PRINCIPLES OF MUL TIPHASE MEASUREMENTS November 30,2004 State of Alaska Alaska Oil & Gas Conservation Commission Prepared by: Parviz Mehdizadeh, Ph.D. Production Technology Inc. Jane Williamson, P.E. Alaska Oil and Gas Conservation Commission Information Document to accompany "Guidelines For Qualification of Multiphase Metering Systems for Well Testing", November 30, 2004 Principles of Multiphase Measurements Table of Contents 1.0 (:)"Etr\fiEt\nl..................................................................................~ 2.0 TEtrms, DEtfinitions, and NomEtnclaturEt..................................4 ~.o Standards and Publications................................................... 5 4.0 PEtrformancEt of MultiphasEt MEttEtrs .......................................5 5.0 PrinciplEts of MultiphasEt MEtasurEtmEtnts...............................6 5.1 Phase Velocity and Phase Fraction Measurements ....................... 6 6.0 Classification of MultiphasEt MEttEtrs ....................................10 6.1 Measurement Techniques............................................................ 11 6.2 Multiphase Metering Installations..................................................12 7.0 WEtt Gas MEttEtring TEtchniquEts.............................................1 ~ 7.1 Classification of Wet Gas.............................................................. 13 7.2 Type 1 Wet Gas Meters ................................................................ 15 7.3 Type 2 Wet Gas Meters ................................................................ 16 7.4 Type 3 Wet Gas Meters ................................................................ 17 8.0 MultiphasEt MEttEtr PEtrformancEt ............................................17 8.1 Specifying Accuracy and Uncertainty........................................... 17 8.2 Preferred Method to Describe Accuracy....................................... 17 8.3 Performance Data and Field Tests............................................... 18 8.4 Impact of GVF and WC on Performance ......................................18 8.5 Graphical Presentation of Multiphase Performance...................... 20 AppEtndix 1 - REtfEtrEtncEts ....................................... .......... .............22 AppEtndix 2 - TEtrms and NomEtnclaturEts .....................................25 AppEtndix ~ - Installation SuggEtstions ........................................29 2 -30 Principles of Multiphase Measurements 1.0 Overview 1.0.1 Multiphase metering techniques were developed to improve upon certain measurement limitations of conventional two and three- phase metering systems requiring gravity based test separators. Well tests are conducted routinely to monitor the flow rates from wells and forecast production. The well test data are used for reservoir management, production diagnostics and field allocation. To obtain accurate and consistent test results from conventional well testing systems, the equipment requires high maintenance, field personnel intervention, and time to perform tests. 1.0.2 Operators have looked at the multiphase metering technology as a method for reducing the cost of well tests and improving the quality of the well tests. Since multiphase metering systems can operate without the need for phase separation or with partial separation, they can be made into compact and lightweight systems. The small footprints and lightweight advantages can produce significant savings, especially in operational areas such as the North Slope and offshore where size and weight may result in additional installation costs. 1.0.3 A number of operators on the North Slope are looking at multiphase meter technology as an alternative to conventional gravity based test separators. BP Exploration (Alaska), Inc. (BPXA) and ConocoPhillips Alaska, Inc. have conducted field trials of a number of commercially available multiphase meters in Prudhoe Bay Unit and Kuparuk River Unit pools to assess their effectiveness in current operations as well as future asset developments. 1.0.4 The AOGCC, Department of Natural Resources (DNR) and Department of Revenue (DOR) sponsored a multiphase metering workshop, conducted in Anchorage on May 23, 2002, to assess the application of this technology to well testing and field allocation operations in Alaska. This seminar and follow up reviews by AOGCC have indicated that the multiphase metering techniques may be acceptable as a means of obtaining improved well testing 3 -30 data. Furthermore the field wide deployment of this technology (1)* has the potential for improved reservoir management and reduction in facility costs required for well testing as noted by the recent Society of Petroleum Engineers papers listed in references 2-4. 1.0.5 Currently, there are few guidelines or standards available to train and direct the operator and AOGCC on how to qualify these new measurement techniques. To bridge this gap for Alaska operations, the AOGCC published "Guidelines for Qualification of Multiphase Metering Systems for Well Testing." Industry and vendors who have potential application of multiphase meter systems were given opportunity to comment on the guidelines, planned for adoption as the process by which the AOGCC will process applications for multiphase meter use. This document, "Principles of Multiphase Measurements" compliments the guidelines by providing a general overview and training document for the applicant and AOGCC personnel 2.0 Terms, Definitions, and Nomenclature 2.0.1 The term "multiphase metering" in its broadest interpretation can be used to refer to both wet gas metering, as well as, the measurement of oil, water, and gas portions of commingled streams, which is commonly referred to as "multiphase metering". Whether one is conducting a "wet gas" or "multiphase" measurement can depend on which product - i.e. oil or gas - is the focus of the measurement, as well as, the type of equipment used.(2) This document addresses both wet gas and multiphase metering systems. 2.0.2 A number of terms and definitions are used in describing the multiphase flow and multiphase measurements within the industry. The terms and definitions listed in Appendix 2 are adopted from the "Handbook of Multiphase Metering", developed by the Norwegian Society of Oil and Gas Measurement. (3) * References are listed in Appendix 1 4 -30 3.0 Standards and Publications No U.S. standard is currently available for the users and regulators in the application and qualification of the multiphase meters. (4) However, the following publications address aspects of the multiphase and wet gas metering, and should be reviewed for those pursuing multiphase meter use. 3.0.1 American Petroleum Institute - "Use of Sub-sea Wet-Gas Flowmeters in Allocation Measurement Systems", API Recommended Practice RP 85, August 28, 2002 (www.apLorg/cat) 3.0.2 International Standards Organization - "Allocation of Gas and Condensate in the Upstream Area", Draft version of Technical Report - ISOTC193-SC3-WG1, May 18, 2002. (a. m.scheers@siep.shell.com) 3.0.3 The Norwegian Society for Oil and Gas Measurement - "Handbook of Multiphase Metering", published by NFOGM, September 1995 (www.oilnet.no/nfogm) 3.0.4 Department of Trade and Industry, UK - "Guideline Notes For Petroleum Measurements Under The Petroleum (Production) Regulations", Oil and Gas Division, UK, Issue 7 - December 2003. (www.og.dti.gov.ukJregulation.) 3.0.5 American Society of Mechanical Engineers- "Wet Gas Metering Guidelines", ASME/MFC publication 19M, (in preparation). RichardS@mccrometer.com 4.0 Performance of Multiphase Meters The use of multiphase meters in field applications is in its relative infancy. There are few generally accepted standards for performance. Three different approaches have been used by industry to verify the performance of multiphase and wet gas meters. These approaches consist of: 4.0.1 Manufacturer sponsored testing either in a third party test loop or at the manufacturer's facility. A number of joint industry studies have been conducted to establish that these meters can perform to the specifications and capabilities claimed by the manufacturers. (7) The National Engineering Laboratory (NEL) in the UK, the K-Lab Wet Gas loop in Norway and the Colorado Engineering Experiment Station (CEESI) in the US have conducted a number of joint 5 -30 industry projects to characterize the performance of multiphase flow meters. The results are not published but released to Joint Industry Project (JIP) participants and the multiphase meter manufacturers, who can share the data with their clients. 4.0.2 Third party testing where vendors and end users are not involved. These tests are generally conducted in a test loop under controlled conditions. 4.0.3 End-user field-testing where the multiphase meter is tested against conventional test separators. Many of these tests compare and index the performance of the multiphase meters to gravity based two or three phase test separators. The owner companies conducting the tests generally release the results to the JIP participants and the multiphase meter manufacturer. Some results have been published. (8-20) 5.0 Principles of Multiphase Measurements The primary information required in the measurement of oil or gas multiphase flow streams includes flow rates of oil, water, and gas. The ideal method to obtain this data is to have a multiphase flow meter that would make direct and independent flow rate measurements of these components. Unfortunately, such a device does not exist as yet. Consequently, much of the extensive development in multiphase metering has been directed toward inferential techniques that use the instantaneous velocity and cross sectional fraction of each component to make these measurements. The following section will examine the application of these techniques as applied to multiphase meters used for oil, water and gas measurements. 5.1 Phase Ve/ocitv and Phase Fraction Measurements 5.1.1 For single-phase liquid or gas travelling through a pipe of cross sectional area A at an average velocity V, the volumetric flow rate Q can be calculated by: Q=AV (1 ) 5.1.2 When an oil, water and gas mixture is flowing through the same pipe, the calculations of the volumetric flow rates are complicated. 6 -30 As gas and liquid flow simultaneously in a pipe, the two phases can distribute themselves in a variety of flow regimes. The configuration of the flow regime is affected by gas and liquid flow rates, pipe diameter, and fluid properties. These effects result in a variety of flow patterns as shown in Figure 1. ~~jtr.;;rf;"i«:E::j~t~~" ./ Plug _/~./ . -é / / :.". :,~E~~~~iírir~.~-I$ / /.- Slug -:Æ< .~~. ;;." /~. ."...' ...-....., /~- . ",;;.-.:". ~... .""...'" ..""1$ ,'~~~;i/~~..-.....~~~",~~~~ø~~~._O"",.,.,-,,~~~~~~ Mist Figure 1 - This schematic shows general flow patterns of gas-liquid stream in horizontal and near horizontal pipe (Reference 3). GAS OIL f\ ...... v s WATER v Figure 2 - An approximate model of the multi phase flow. Each phase is occupying a fraction of the total cross sectional area of the pipe. The superficial phase velocity is defined as the flow velocity of one phase, assuming the phase (gas or liquid) occupies the whole conduit. 7 -30 5.1.3 A simple approach to estimate the volumetric flow rates for each phase is to establish the distribution of each phase (as illustrated in Figure 2) by assuming that each phase is occupying a fraction of the total cross-sectional area at any instant, which is determined by the following relationships: fo = AJA, fw=AwfA, fg =Ag fA (2) fo+fw+fg = 1 (3) Where fo, fw, and fg are the volume fractions (fraction of cross sectional area A) of the oil, water, and gas phases in the mixture. 5.1.4 The volumetric flow rate Q of each phase and the total (mixture) flow rate are then determined by: Qo = A fo Vo , Qw =A fwVw , Qg = A fg Vg Qt = Qo+Qw+Qg (4) (5) Where Vo, Vw, and Vg are the superficial velocities of the oil, water, and gas phases in the mixture. The task of any multiphase meter is to estimate the volume fractions and the individual phase velocity in the above equations. 5.1.5 A model shown schematically in Figure 3 is used by multiphase metering systems to conduct these processes. The developers of the multiphase meters have employed different technologies and modelling of the multiphase flow (2,6,7) to simplify the process shown in Figure 3. 5.1.6 Multiphase measurement systems that are commercially available today (6) utilize a diverse range of equipment from full three-phase conventional separators to in-line multiphase meters that consist of a spool piece with no separation. From the perspective of users, these systems have one common purpose - i.e. to provide accurate flow rates for oil, water and gas. 8 -30 ... '. .;;:..::?2iifF~~t~tfijij~~~F.~.. .'~i:: ),,'i'~,"Y':~~~:lti;;Æ + + ~ ~ IDle t: M ultiphase Flow + Output - oil, water, gas flow rates Figure 3 - Processes shown schematically in this figure are used in a multiphase metering system to obtain single-phase flow rates from a multiphase stream. 5.1.7 Processes that are shown in Figure 3 consist of some type of fluid conditioning, mixture density determination, mixture rate determination, mixture composition determination, and application of a flow model. These functions can be supplied by an instrument or by an assumption in a model. 5.1.8 A multiphase metering system scans the flow stream at very high frequency, processes the instantaneous flow rates for each phase, and sums up the data for each phase to produce the flow rates for each phase within the multiphase stream. Figure 4 shows the distribution of the oil, water, and gas, at a wellhead, as a function of time, as recorded by a multiphase meter. 9 -30 A 1\, ~ l . II. ~~I \1 , . \ i I . ¡ Ilf " I ¡ I t!j',i j',rl¡,./', i'l,i\~1 [ I!~," ;1~lr\ll. I~ ;':JJlI/ ,;'1, r ,! i.I ,t ¡'J,1:II' !t f¡ I~ I !I, ;~;1': '~I!' t ~. !~ U ¡ WI,! 11, II: i,' i\I, ~ III ~!'J 11'~~I: III Ililill I! ¡ j j!""':illlll~ '¡I,l ,III~H I, 'i II' II'~ 1!~'~I,~~~'W~"/I/'~ 1\ ~~'n!~Y IJ: I f~ -QO BPD 100- -QWBPD -OG MACFD °O~OO 1 :12 2:24 3:36 4:48 6:00 7:12 8:24 9:36 1000 900 800- 700- 600- B p 500 D 400- 300- 200- Time, hours - 92 - 90 - 88 - 86M A - 84C F - 82 D - 80 Figure 4 - Distribution of oil (green), water (blue), and gas (red) flow rates in real time at a wellhead as recorded by a multiphase flow meter. 6.0 Classification of Multiphase Meters 6.0.1 There is currently no "commonly-accepted" method of classifying multiphase meters. The following classification is proposed for this document until a "standard" classification system becomes available. In this classification, the metering systems are grouped in terms of methods by which the gas and liquid components are handled. In Group I systems, one or more phases are completely separated then measured. The separated streams mayor may not be recombined to form the original stream. This category includes gravity or centrifugal based separation systems. In Group II systems, the main flow stream is divided into "gas rich" and "liquid rich" streams, generally using separation based on a centrifugal process. Each stream is 6.0.1.1 6.0.1.2 10 -30 subjected to multiphase measurements then recombined to form the original stream. 6.0.1.3 In Group III systems, all three phases go through a single conduit and are measured at the same time. This category includes all the so-called inline meters. These meters may use some form of flow conditioning - i.e. use of elbow, mixers, etc. 6.1 Measurement TechniQues In each group, different measurement techniques, combination of techniques, and strategies can be used to obtain phase velocity and phase fraction information. Some typical examples of these techniques are shown in Table 1. For a more comprehensive discussion of these techniques, and how they are utilized in commercially available multiphase metering systems, the reader should consult references 2 and 6. Table 1 Measurement Techniques and Devices Used to Obtain Phase Velocity and Phase Composition in Multiphase and Wet Gas Metering Systems Velocity Methods Venturi Device Composition Methods Capacitance Positive Displacement Device Cond uctivity/l nd uctance Coriolis Device Microwave/l nfrared Cross Correlation Techniques Acoustic Atten uation Dual Venturi Gamma Ray Absorption 11 -30 6.2 Multi"hase Metering Installations 6.2.1 The AOGCC "Guidelines for Qualification of Multiphase Metering Systems for Well Testing" focuses on Groups II and III multiphase metering systems. However, it should be noted that Group I systems, which include 3-phase and 2-phase gravity-based test separators, are used in a majority of operations. The number of Group II and III installations (4) is about 1000, while the number of Group I installations is well over 10,000. Also, gravity-based test separators are the current "standard" of field measurement within the industry. All Group II and III installations are performance indexed against these systems in the field. Figure 5 shows four different multiphase metering systems in a field test loop. ~ , f j' Figure 5 - A field test loop that includes four different multiphase metering systems. From left to right- Agar MPFM 400, Roxar 1900VI, FMC FlowSys, and Schlumberger Venturi X. (21) 12 -30 7.0 Wet Gas Meterina TechniQues Wet gas metering covers a wide range of measurements, which is necessitated by the specific applications and the definition of "wet gas". The definition of wet gas can vary depending on whether one is looking at the fluids from the perspectives of reservoir engineering, measurement systems, or commercial sales of the products. (7) Wet gas can be simply defined as gas, which contains some liquid. The amount of liquid can vary from a small amount of water to substantial amount of water and hydrocarbon. The amount and nature of the liquid, as well as the flow rate, temperature, and pressure of the flow stream can impact the selection and accuracy of the measurement system. It is therefore important that "wet gas" be characterized properly before one can discuss the wet gas measurement systems. 7.1 Classification of Wet Gas 7.1.1 A classification for different types of wet gas is proposed in reference 8. The proposed classifications, shown in Table 2, will be used in this document. This classification is based on superficial velocity (volumetric rate divided by the pipe cross sectional area) for gas and liquid and the Lockhart-Martinelli parameter, which is defined as: x = (Vsl/ Vsg) (~pl/ ~pg) (1 ) Where X is the Lockhart-Martinelli number, Vsl and Vsg are the superficial velocity, and pi and pg are the density of liquid and gas respectively. The gas volume fraction (GVF) of the stream can be obtained from the following equation: GVF= 1/ [1 + X* (~pg/~pl)] (2) The liquid to gas ratio (LGR) can also be calculated from Equation 1. LGR=X*(~pg/~pl) (3) 13 -30 7.1.2 Equations 1-3 can be used to identify three different regions of wet gas and calculate the associated gas volume fraction and liquid load in each region. A summary of different types of wet gas conditions and typical areas of application is shown in Table 2. It should be noted that the boundary for these three types of wet gas conditions is dependent on the composition of the liquid fraction and the pressure and temperature of flow stream, which affects the density of the gas and liquid. TABLE 2 - TYPES OF WET GAS AND TYPICAL APPLICATIONS IN PRODUCTION OPERATIONS Type of Lockhart- Wet Gas Martinelli Number Type 1 Equal or less than 0.025 Type 2 0.025 to 0.30 Type 3 Above 0.30 Typical Applications Type 1 wet gas measurement represents measurement systems at production wellheads, unprocessed gas pipelines, separators, allocation points, and well test facilities. Liquid measurement is necessary to make correction for improved gas measurements. Type 2 wet gas-metering systems cover higher liquid flow ranges so that the users often require more accurate gas and liquid flow rates. Applications include the flow stream at the production wellhead, commingled flow line, or well test applications. Type 3 meter must make an oil, gas and water rate determination at relatively high GVF > 800/0 or X~0.3. Typical application is gas condensate wells and gas lift wells. 14 -30 7.2 Tvpe 1 Wet Gas Meters 7.2.1 Table 3 lists devices that are used for metering Type 1 wet gas conditions. Type 1 metering systems are typically used in fiscal metering. These are single-phase commercial gas meters that require liquid flow rate input to measure gas flow rate calculations. These methods assume a constant liquid flow rate estimate over a time period or until a new liquid flow rate is updated. 7.2.2 Common methods of determining liquid flow rate are periodical well tests, tracer injection, pressure-volume-temperature (PVT) prediction, and allocation techniques. 7.2.3 The liquid presence in the gas for Type 1 metering systems cause a systematic bias error in gas flow measurement if liquid content is not corrected in the gas flow equation. When utilizing Type 1 system, selection of flow-metering devices for liquid measurement and their correspondent uncertainty must be considered in order to deliver an optimum system. Table 3- Type 1 Wet Gas meters, gas rate over-reading data (reference 7) Metering Devices Volumetric Over-reading range (%) for Lockhart- Martinelli number SO.02 Coriolis 0 to 6 Inverted Venturi (V-cone) 0 to 1.5 Orifice -1 .7 to 2 Turbine 0 to 0.75 Ultrasonic 0 to 1 0 Venturi 0 to 5 Vortex 0 to 6 15 -30 7.3 Tvpe 2 Wet Gas Meters 7.3.1 Type 2 wet gas metering systems typically measure the flow stream at the production wellhead, commingled flow line, or for well test applications. In some applications direct measurement of produced water in the gas stream can improve process control and reservoir management. (23) 7.3.2 Several commercial metering systems have been developed for Type 2 wet gas. (7) Most Type 2 wet gas meters use a differential pressure device plus another technique to measure gas and liquid flow rates. Sampling and tracer techniques are used in some systems to determine liquid flow rate periodically when liquid flow rates remain constant between sampling intervals. Other systems such as extended Venturi, dual differential, and dual Venturi with vortex offer continuous measurement of gas and liquid flow rates. Other systems offer direct measurement in the gas stream. 7.3.3 Examples of the various techniques and combination of devices (7) used in Type 2 wet gas metering systems are listed in Table 4. Table 4- Various Techniques and Combination of Devices Used in Type 2 Wet Gas Metering Systems . Venturi and Wedge . Dual Venturi with Vortex . Extended Venturi . Orifice with Sampling . Venturi with Tracer Sampling . V -cone with Microwave based Water Cut device 7.3.4 The field proven accuracy of these devices has not yet been fully corroborated by the users. Operational conditions and fluid properties significantly impact the volumetric uncertainty. Type 2 wet gas metering is applicable for higher liquid flow ranges, where the commercial value of the liquid may be significant. 16 -30 7.4 TYIJe 3 Wet Gas Meters 7.4.1 Metering systems used for Type 3 wet gas are multiphase metering systems that were developed to measure flow streams composed of oil, water, and gas mixtures as was discussed in Section 6. 7.4.2 In field tests where the performance of the Type 3 wet gas and Group III multiphase meters have been compared to conventional test separators, uncertainty of 5-100/0 has been claimed. (21) Even uncertainty values as low as 20/0 have been claimed in some field tests. (7) It should be noted that these accuracy performances are obtained by comparing the gas flow measurements against conventional separators that generally use gas-metering devices described for Type 1 wet gas metering conditions. In many of the field tests these "reference" devices have questionable accuracy. 8.0 Multiphase Meter Performance 8.1 8.2 SIJecifvina Accuracy and Uncertainty 8.1.1 Manufacturers and users have utilized different methods of specifying and reporting the uncertainty (accuracy) for multiphase meters. Reference 2 provides a discussion of the various methods of describing the accuracy of a multiphase metering system, their advantages and limitations. 8.1.2 Users generally prefer to specify the accuracy in terms of percentage uncertainty relative to the flow rates of each phase - i.e. oil, water, and gas flow rates. This method is preferred by the AOGCC. 8.1.3 The uncertainty of the metering system can also be specified as a percentage relative to the total multiphase flow rate, which is called the "relative" uncertainty method. In certain measurement applications - e.g. trending or monitoring process changes at low flow rates, this may be an appropriate method for describing the accuracy (performance) of a multiphase metering system. Preferred Method to Describe Accuracy 8.2.1 In the document "Guidelines for Qualification of Multiphase Metering Systems for Well Testing", the AOGCC requires that the percentage uncertainty of each phase be used to describe the 17 -30 accuracy of the multiphase measurements. 8.2.2 As an example, if the meter specification calls for relative uncertainty of each phase to be within :1:100/0, the anticipated production accuracy for this meter testing a well that is producing 500 BBL/O of liquid at a 200/0 water cut and GOR of 1000 SCF/B is shown in Table 5. Table 5 - DETERMINTATION OF UNCERTAINTY FOR A WELL PRODUCING 500 SBUD OF LIQUID, WC=20%, GOR = 1000 SCFISTB Well Fluids Flow Rates Absolute Uncertainty Relative :f: 10°10 of phase flow Uncertainty I Production rate Accuracy Oil 400 BBLIO :1:40 BBL :1:100/0 Water 100 BBL/O :1:10 BBL :1:100/0 Gas 400 MSCF/O :1:40 MSCF :1:10% 8.3 Performance Data and Field Tests As described in Section 4, three different approaches have been used by industry to verify the performance of multiphase and wet gas meters. The approaches include manufacturer sponsored testing, third party testing and end user testing. In the AOGCC "Guidelines for Qualification of Multiphase Metering Systems for Well Testing" the focus is on field testing. However, when applicable, data from the other types of testing may be used to support the application with expected performance later verified in actual field conditions. 8.4 ImlJact of GVF and we on Performance 8.4.1 The performance data available from all the sources described above show that the level of accuracy for all types of the multiphase meters is affected by two major factors as discussed below. 8.4.1.1 As the GVF of the flow stream increases, the level of accuracy for the liquid (oil and water) rate determination is adversely affected. 18 -30 8.4.1.2 As the we in the flow stream increases, it becomes more difficult for a multiphase metering system to achieve high levels of accuracy for the oil phase, which frequently is the major focus of the measurements. 8.4.2 The effects described in item 8.4.1 are to be expected since the gas phase can expand much more than the liquid phase and therefore occupy a larger fraction of the volume. Similarly as the water cut increases, the volumetric fraction occupied by the oil phase decreases. These relationships are shown graphically in Figure 6. 8.4.3 Both GVF and we impact the performance of the devices and modeling assumptions that are used in multiphase metering systems to identify the volume fraction (fo = Ao/A) and calculate phase velocity. The resulting loss of accuracy in volumetric fraction and phase velocity determinations impacts the calculation of the oil, water, and gas flow rates in a multiphase stream. OIL 4% GAS 600/0 OIL 10/0 WATER 60/0 GAS 93% Figure 6 - Graphical representations of the impact of GVF and we on the phase distribution for the oil flow rates as would be seen by a multiphase metering system. The actual flow rates for the oil and water is the same for both diagrams, but GVF has increased from 60% in the left diagram to 93% on the right side. 19 -30 8.5 GraJJhical Presentation of MultiJJhase Performance 8.5.1 A variety of methods have been used to graphically show the performance of the multiphase meters. Reference 22 describes these graphical methods, their advantages and limitations. The two most commonly used graphical presentations are shown in Figures 7 and 8. 8.5.2 Figure 7 shows the accuracy of liquid flow rate for four different multiphase meters. The dotted lines, in Figure 7, show the :1:5%> error band. The liquid (water and oil) flow rate measurements from the multiphase meters are compared with reference flow rate data, in this case obtained from a gravity based test separator. This type of plot is useful in showing if the liquid rate measurements for a certain multiphase meter can satisfy the :1:50/0 accuracy level within the flow range shown in Figure 7. 8.5.3 Figure 8 shows the accuracy of the liquid flow rate for the same four multiphase meters, shown in Figure 7, in the so-called "two phase map". In this type of graphical presentation one can see the impact of another parameter - Le. GVF, on the accuracy of the four meters. The error bands show the capability of each meter to satisfy the :1:5 accuracy requirement for liquid flow rates. This type of presentation is helpful to show not only the compliance of a meter with the accuracy requirement but also the effect upon accuracy as the GVF is increased. This "two phase map" type of graphical presentation can also be prepared to show the impact of other important factors such we. This approach is especially helpful where the multiphase metering application is being considered for a large number of wells with wide range of GVF and we values. 20 -30 ;Ya rVIZ 3500 MFM Liquid Rate ~ 3000 - .Q ... en -2500 - () ... C'CI ~ ;: 2000 - 0 ¡:¡: -C 1500 - .3 C" = 1 000 - ~ () ... () :i I I I 1000 1500 2000 2500 Reference liquid flowrate Figure 7 - (Reference 21) Graphical presentation of liquid rate accuracy of four different meters as a function of flow rate 50 Q;' g 40- ! .e ! 30- B ~ 20- ¡ ! 10- ~ ~ 0 ... ... CD -10 - CD - ~ -20 - 3= 0 ;¡:: -30 - "C .:; -40 - 9 -50 40 . I 500 I 3000 3500 MPM Liquid Errors - +/- 5% error . Meter A <> Meter B BI Meter C ~ Meter D ~ <> IE! I!iI - ElI œ~" .. 0 ..r. <> 0 0 Ii!! ..... ,.. . <J f"Þ.o , 51 . I!!I. ~\ ~. <> f!I ~ . -~ <> *0 <>.4 . ~UI'''' ,.. ~ ¡ ~. I!!I 0 .- sf . œ<> $ Q .. . - I!I <> 60 I 80 100 Reference GVF Figure 8 - (Reference 21) Graphical presentation of the liquid rate accuracy of four different meters shown in Figure 7, as a function of the GVF in the flow stream. 21 -30 Principles of Multiphase Measurements Appendix 1 - References 1. Mehdizadeh P., "Multiphase Measuring Advances Continue," Oil&Gas Journal, July 9, 2001. 2. State of the Art Multiphase Flow Meterinq, American Petroleum Institute Publication 2566, 1 st Edition, Committee on Petroleum Measurements, May 2004. 3. Dykesteen, Eivind, et aI, Handbook of Multiphase Meterinq, Norwegian Society for Oil and Gas Measurement, published by NFOGM, September 1995. 4. Mehdizadeh P., "Status of MP and WG Metering," presented at TAMU Multiphase Measurement Users Roundtable, Houston, May 7, 2003. 5. Theuvey, B. C. and Mehdizadeh, P., "Multiphase Flowmeters for Well and Fiscal Applications", SPE 76766, presented at SPE Western Regional/AAPG Pacific Section Joint Meeting, Anchorage, May 20-22, 2002. 6. Falcone, G., et aI, "Multiphase Flow Metering- Current Trends and Future Applications," SPE 71474, presented at 2001 SPE-ATCE, New Orleans, September 30 - October, 2001. 7. Mehdizadeh P., Marrelli J., and Ting V.C., "Wet Gas Metering: Trends in Application and Technical Development," SPE paper 77351, presented at SPE Annual Technical Conference and Exhibition, San Antonio, September 29-0ctober 2, 2002. 8. Mehdizadeh P., Marrelli J., and Ting V.C., "Meter Designs Provide Wet-Gas Measurement Alternatives," Oil&Gas Journal, March 24, 2003. 9. Stokes, Edward G., et aI, "Application of The First Multiphase Flowmeter in The Gulf of Mexico," SPE 49118, presented at Annual Technology Conference and Exhibition, New Orleans, September 27-30,1998. 22 -30 10. Kalsaas, Odd-Pedder, et ai, "Operational Experience with Multiphase Meters at Vigdis," presented at Multiphase Metering Workshop 2001 ASME -ETCE Conference, Houston, February 27,2001. 11. Santamaria, G. and Noel, M.I., "Multiphase Flow Metering: the Mexican Experience," presented at TAMU Multiphase Measurement User Roundtable, Houston, May 3, 2000. 12. Shen, Joseph, "Field Operation of a Compact Separation Multiphase Metering System," presented at Multiphase Measurement & Production Testing User Roundtable, Houston, May 3, 2000. 13. Means S. R. and Mehdizadeh P., "New Technology Improves Well Testing Units," Oil&Gas Journal, October 30, 2000. 14. Bortolin, Luigi, "Petrozuata's Multiphase Metering Application," presented at T AMU Multiphase Measurement User Roundtable, Houston, May 3, 2000. 15. Humphrey, A. I., et ai, "Application of Multiphase Metering in Machar and Monan Fields," OTC 12018, presented at 2000 Offshore Technology Conference, May 1-4, 2000, Houston. 16. Shen, Joseph, et ai, "Field Evaluation of a Multiphase Meter in Well Testing Operation," SPE 37436, presented at 1997 SPE Production Operations Symposium, Oklahoma City, March 9-11,1997. 17. Ngai, Charles C., et aI, "Performance Test of a High Gas Volume Fraction Multiphase Meter in 'a Producing Field," SPE 38784, presented at 1997 SPE Annual Technical Conference and Exhibition, San Antonio, October 5-8, 1997. 18. Okland, 0., et ai, "Applications of Multiphase Meters at the Fullfaks Field in the North Sea", OTC 8551, presented at 1997 Offshore Technology Conference, Houston, May 5-8, 1997. 19. Tuss, Bernie, et ai, "Field Tests of the High Gas Volume Fraction Multiphase Meter," SPE 36594, presented at 1996 SPE Annual Technical Conference and Exhibition, Denver, October 6-9, 1996. 20. Mohamad, P. G., et ai, "Field Evaluation of Different Multiphase Flow Measurement Systems," SPE 56585, presented at 1999 SPE-ATCE, 23 -30 Houston, October 3-6, 1999. 21. Hasebe, B., Hall, A., Smith, B., Brady, J., and Mehdizadeh, P., "Field Qualification of Four Multiphase Flowmeters on North Slope, Alaska," SPE 90037, presented at 2004 SPE-ATCE, Houston, September 27-29,2004. 22. Scheers, Lex, "Multiphase and Wet Gas Flow Measurement", presented at T AMU Multiphase Measurement Users Roundtable, May 8, 2004, Houston. 23. Haddelland, R., et aI, "Online Measurement of Water in Wet Gas Flow," presented at S.E. Asia Flow Measurement Workshop 2003. 24. "Sampling," Manual of Petroleum Measurements Standards, Chapter 8, Section 8.2, American Petroleum Institute. 25. Guideline Notes For Petroleum Measurements Under The Petroleum (Production) Regulations, Issue 7 ed, Department of Trade and Industry, Oil and Gas Division, UK, December 2003. 24 -30 Principles of Multiphase Measurements Appendix 2 - Terms and Nomenclatures The fol!cHfI/ing t,erms definitions are ,adopted frotn "Handbook .of Mu!t#.H'1ase Meterinç/', ,de\/(;;doped by Nonvegian Society Oil Emulsion: Colloidal mixture of two immiscible fluids, one being dispersed in the other in the form of fine droplets. Flow regime: The physical geometry exhibited by a multiphase flow in a conduit; for example, liquid occupying the bottom of the conduit with the gas phase flowing above, or a liquid phase with bubbles of gas. Fluid: A substance readily assuming the shape of the container in which it is placed; e.g. oil, gas, water or mixtures of these. Gas: Hydrocarbons in the gaseous state at the prevailing temperature and pressure. Gas-liquid-ratio (GLR): The gas volume flow rate, relative to the total liquid volume flow rate (oil and water), all volumes converted to volumes at standard pressure and temperature. Gas-oil-ratio (GOR): The gas volume flow rate, relative to the oil volume flow rate, both converted to volumes at standard pressure and temperature. Gas volume fraction (GVF): The gas volume flow rate, relative to the multiphase volume flow rate, at the pressure and temperature prevailing in that section. The GVF is normally expressed as a percentage. Hold-up: The cross-sectional area locally occupied by one of the liquid phases of a multiphase flow relative to the cross-sectional area of the conduit at the same local position. Homogeneous multiphase flow: A multiphase flow in which all phases are evenly distributed over the cross-section of a closed conduit; Le. the composition is the same at all points. 25 -30 liquid-gas-ratio (lGR): The liquid volume flow rate (oil and water) relative to the total liquid volume flow rate (oil and water) at the pressure and temperature prevailing in that section. Mass flow rate: The mass of fluid flowing through the cross-section of a conduit in unit time. Multiphase flow: Two or more phases flowing simultaneously in a conduit. This document deals in particular with multiphase flows of oil, gas and water. Multiphase flow rate: The total amount of the two or three phases of a multiphase flow flowing through the cross-section of a conduit in unit time. The multiphase flow rate should be specified as multiphase volume flow rate or multiphase mass flow rate. Multiphase flow velocity: The flow velocity of a multiphase flow. It may also be defined by the relationship (Multiphase volume flow rate / Pipe cross-section ). Multiphase flow rate meter: A device for measuring the flow rate of a multiphase flow through a cross-section of a conduit. It is necessary to specify whether the multiphase flow rate meter measures the multiphase volume or mass flow rate. Multiphase fraction meter: A device for measuring the phase area fractions of oil, gas and water of a multiphase flow through a cross-section of a conduit. Multiphase meter: A device for measuring the -phase area fractions and flow rates of oil, gas and water of amultiphase flow through a cross- section of a conduit. It is necessary to specify whether the multiphase meter measures volume or mass flow rates. Oil: Hydrocarbons in the liquid state at the prevailing temperature and pressure conditions. Oil-continuous multiphase flow: Multiphase flow of oil/gas/water characterized by the water phase distributed as water droplets surrounded by oil. Phase: In reference to multiphase measurement - one constituent in a mixture of several. In particular, the term refers to oil, gas or water in a 26 -30 mixture of any number of the three. Phase area fraction: The cross-sectional area locally occupied by one of the phases of a multiphase flow, relative to the cross-sectional area of the conduit at the same local position. Phase flow rate: The amount of one phase of a multiphase flow flowing through the cross-section of a conduit in unit time. The phase flow rate may be specified as phase volume flow rate or as phase mass flow rate. Phase mass fraction: The phase mass flow rate of one of the phases of a multiphase flow, relative to the multiphase mass flow rate. Phase velocity: The mean velocity of one phase of a multiphase flow at a cross-section of a conduit. It may also be defined by the relationship (Superficial phase velocity * Phase area fraction). Phase volume fraction: The phase volume flow rate of one of the phases of a multiphase flow relative to the multiphase volume flow rate. Slip: Term used to describe the flow conditions that exist when the phases have different velocities at a cross-section of a conduit. The slip may be quantitatively expressed by the phase velocity difference between the phases. Slip ratio: The ratio between two-phase velocities. Slip velocity: The phase velocity difference between two phases. Supeñicial phase velocity: The flow velocity of one phase of a multiphase flow, assuming that the phase occupies the whole conduit by itself. It may also be defined by the relationship (Phase volume flow rate I Pipe cross-section). Velocity profile: The mean velocity distribution of a fluid at a cross- section of a conduit. The velocity profile may be visualized by means of a two- or three-dimensional graph. Void fraction: The cross-sectional area locally occupied by the gas phase of a multiphase flow relative to the cross-sectional area of the conduit at the same local position. Volume flow rate: The volume of fluid flowing through the cross-section 27 -30 of a conduit in unit time at the pressure and temperature prevailing in that section. Water-continuous multiphase flow: A multiphase flow of oil/gas/water characterized by the oil phase being distributed as oil droplets surrounded by water. Electrically, the mixture acts as a conductor. Water cut (WC): The water volume flow rate, relative to the total liquid volume flow rate (oil and water), both converted to volumes at standard pressure and temperature. The we is normally expressed as a percentage. Water-in..liquid ratio (WLR): The water volume flow rate, relative to the total liquid volume flow rate (oil and water) at the pressure and temperature prevailing in that section. Water Volume Fraction (WVF): The water flow rate relative to the total volume flow rate at the local temperature and pressure. WVF is normally expressed as a percentage. 28 -30 Principles of Multiphase Measurements Appendix 3 - Installation Suaaestions Installation of multiphase measurement systems (multiphase and wet gas meters) should consider steps that would not only maximize the performance but also ease the verification and periodic testing (calibration) that may be necessary. These systems may require specific piping and fitting arrangements mechanical supports, and electrical equipment installation. Vendors generally provide this type of information to the users. Operators should require documentation from vendors on piping, installation description, electrical and instrument hook-ups, and accurate cabling requirements. For the rest of this section the discussion will focus on Type 2 wet gas and Group II or III multiphase measurement systems. In a majority of field installations Group I multiphase meters - Le. 2-phase and 3- phase gravity based test separators, are used to verify the performance of other multiphase measurement systems. While Group I multiphase meter installations are outside the scope of this document, when appropriate, issues related to their installations and performances are addressed. The following issues should be addressed in field installations for multiphase metering systems: (a) (b) (c) For consistent performance, the metering system should be sized to cover the range (maximum and minimum instantaneous) of fluid rates expected. Complete system documentation including a detailed P&ID showing all instruments and set points and process conditions should be provided. The P&ID is helpful in identifying the location of critical system elements such as pipefitting, pressure and density measurement devices, control valves, and the operating set point. Gas breakout when flowing through single-phase liquid meters, used in Type I multiphase meters, causes inaccuracy. If the Group I system utilizes gravity separation equipment, the liquid discharge piping from this equipment to the liquid meters should be designed to eliminate gas breakout in liquid meters. 29 -30 (e) (f) (g) (h) (i) U) (d) Another cause for gas breakout in liquid meters is the pressure drop that occurs between the vessel and the meter. This gas breakout occurs if the liquid line pressure is below the last separation pressure If automatic samplers are used as a part of the multiphase metering system, reference 24 can be used to establish the requirements of velocity and flow conditioning that must be included in the sampler design and installation. Instrument wiring should be installed to minimize electrical noise including proper use of shielding, grounds, and electrical and radiation isolation. There are some special requirements if the multiphase meter utilizes a radiation-based source. These requirements include tracking of the radiation source and general worker safety. Tracking the radiation source can be done by the operator or through an approved third party contractor. These sources must be tracked on and off the property, as well as, to and from the property by a trained entity. While on the property, swab tests are performed for radiation leakage with the swab sent off for evaluation. Safety requirements and regulations related to item (g) may dictate the need for an individual on location who is trained in radiation awareness and safety. Workers in the area may require radiation awareness training. If a gamma densitometer is used in the multiphase metering system, field calibration may be necessary using the well water and gas at temperature and pressure. It is imperative that when calibrating the gas phase the meter be absolutely dry internally. The installation must consider ways of providing this capability. Wet gas meter accuracies are affected by the degree of insulation of the meter run and pressure taps from the meter body to the process instruments. (25) Pressure taps are especially affected by cooling which causes liquids to condense in the tapping line. 30 -30 ::t:t:: w Re: [Fwd: Re: [Fwd: Scheduled Hearing. ""undry Exemptions]] ) ') Subject: Re: [Fwd: Re: [Fwd: Scheduled Hearing on Sundry Exemptions]] From: Thomas Maunder <tom_maunder@admin.state.ak.us> Date: Thu, 06 Jan 2005 14:37:31 -0900 To: John Norman <john_nonnan@admin.state.ak.us> CC: John D Hartz <jack_hartz@~admin.state.ak.us>, Dan T Seamount <dan_seamount@admin.state.ak.us>, Jody J Colombie I have been working on them to be ready and will send them to Rob. Tom John Norman wrote: Jack and Tom-as you know we left the record open until January 19. Can you begin preparation of the amended orders so we will be ready to issue them as soon as the record has closed? Rob should of course review all final drafts. Thanks John -------- Original Message -------- Subject:Re: [Fwd: Scheduled Hearing on Sundry Exemptions] Date:Wed, 29 Dec 2004 15:31:16 -0900 From:John Hartz ~iack hartz(ã¿admin.state.ak.us> Organization:State of Alaska To:Rob Mintz <robert mintz@law.state.ak.us> CC:tom maunder@admin.state.ak.us, dan sean10unt(ã¿admin.state.ak.us, john norman(ã¿admin.state.alcus, steve davies(ã¿admin.state.ak.us References:<s 1 d2b4d8.054(ã¿smtpa.1aw.state.ak.us> See my comments below. jack Rob Mintz wrote: Two issues. As to AOGA "involvement in final wording" of the order coming out of the current proceeding, my view is that AOGA's further input should be in the form of written comments or oral comments at the hearing, and not through additional informal contact. Therefore, AOGA should probably be told that if they have anything further to contribute it should be at the hearing, and the hearing should therefore be held unless AOGA says it declines. I I i : I As to inclusion of service wells in the matrix, my understanding is that the matrix that came out of the series of workgroup meetings was intended to reflect (1) desired changes in Commission policy regarding development wells and (2) current Commission policy regarding injection wells. Once the Commission issues its order regarding development wells, the matrix will reflect current policy regarding both development wells and service wells. As such, a combined matrix would not need to be adopted by an order if the purpose is simply to serve as a convenient guide to Commission requirements. In fact, anyone couId read the appIicabIe Commdssion reguIations and orders and come up with his or her own ma trix for tha t purpose. ! I ¡ I 10f3 1/6/2005 4:30 PM Re: [Fwd: Re: [Fwd: Scheduled Hearing ( "'undry Exemptions]] ) Rob - the last sentence is not correct - 20AAC25.280 lists generic type workovers, however, there are 10's to 100's of operations that can be done that may fit within some of the generic categories. The matrix is a convenient way to aid the operator to understand which "workovers" are important or have meaning to AOGCC. The objective is to ensure compliance with the spirit of the regulation. -- jdh If I recall correctly, the reason a development well matrix was proposed to be added to the order currently under consideration was to eliminate any uncertainty as to whether the specifics in the matrix correctly interpret the general rules otherwise stated in the conservation orders. So under the new order, the matrix wil be not just a convenient guide but also a set of rules with independent and direct legal effect with regard to develoment wells. If ruLes in the form of a matrix with independent and direct 1.egal. effect are aLso desired for injection weLLs, a new proposal will have to be published and opportunity for hearing provided, because that is well beyond the scope of what was previously noticed. The notice specified 20AAC25.280 which is applicable to injectors also. Doesn't it follow that if something comes out of the hearing or documents submitted in response to the notice can be taken into consideration when drafting the rules or inclusion of a second matrix? I believe sometimes we should broaden our view to make our efforts more efficient - i.e., resist the bureaucratic impulse. -- jdh Thomas Maunder <tom maunder@admin.state.ak.us> 12/29/2004 12:27:23 PM »> I guess to ask you Tom it would be nice if I copied you on the message if I am going a question. -------- Original Message -------- Subject: Scheduled Hearing on Sundry Exemptions Date: Wed, 29 Dee 2004 11:57:34 -0900 From: Thomas Maunder <tom maunder@admin.state.ak.us> Organization: State of Alaska To: John Norman <john norman@admin.state.ak.us>, Daniel JR <dan seamount@admin.state.ak.us>, Steve Davies <steve davies@admin.state.ak.us>, John D Hartz <jack hartz@admin.state.ak.us> T Seamount All, The hearing for the sundry exemption orders is scheduled for Tuesday. Linda has asked me if there would be a hearing. The purpose of this message is to offer a review of the matter so that the need for a hearing can be determined. 20f3 1/6/2005 4:30 PM Re: [Fwd: Re: [Fwd: Scheduled Hearing r -"uldry Exemptions]] ') ) There has not been any request for a hearing. The operators through AOGA did submit a comment letter supporting the effort, requesting they be involved in the final wording and requesting that an injection well matrix be included. Rob and I spoke regarding their request to be involved in the final wording and his opinion was that their involvement is limited to what has happened in the prior meetings of the workgroup and their comments. Final wording of the orders will be at the Commission's discretion. We also briefly discussed including an injection well matrix. With regard to including the injection well matrix, originally there was a combined matrix and prior to the notice Rob had me split it in two with one for development (production) wells and one for service (injection) wells. The notice only addressed development wells. Expanding to include service wells too should not entail much work, however I do not know how the process is effected. Does the notice limit the scope of the action or does the comment from AOGA afford the Commission hearing were to be the coverage?? the opportunity to include service wells too? If the held, do we consider AOGA's letter as a request to expand If the scope of the notice trumps everything, then there is no need for a hearing. If it is possible to consider AOGA's request to include an injection well matrix, then the hearing should be held so that matter can be considered and a determination be made to broaden the coverage to injection wells. Rob, for the benefit of all what is your opinion. Tom 30f3 1/6/2005 4:30 PM ::t:t:: N ) \ { 11/6 "J C-j a W\ Re: [Fwd: Multi-phase Metering] Subject: Re: [Fwd: Multi-phase Metering] From: John Norman <jo~norman@admin.state.ak.us> Date: Thu, 23 Dec 2004 13:37 :22 -0900 To: lVlary Williamson <jane - \villiamson(@admin.state.ak.us> CC: Dan T Seamount <dan_seamount(~,admin.state.ak.us>, Jody J Colombie <jody_colombie@admin.state.ak.us>, John D Hartz <jack_hartz(gjadmin.state.ak.us> Jane-Jody-because these guidelines will have application to many operators, we should hold the hearing at the appointed time, just as we did with the BOPE regulation change. Jane, you should be prepared to make a statement for the record concerning the background leading up to the final guidelines, the intent of these guidelines, and the fact that at some point in the future the Commission may contemplate adopting these as regulations. Jody- we will want to make a record of this hearing. Thanks, John Mary Williamson wrote: Yes, that's the hearing. However, we've had no request for hearing and no comments back on the last draft, so I expect I'll recommend vacating. John Norman wrote: Jane, do I need to plan to attend this? -------- Original Message -------- Subject:Multi-phase Metering Date:Tue, 30 Nov 2004 15:29:05 -0900 From:jody colombie~admin.state.ak. us Reply- To:jody colombie~admin.state.ak.us To:winton aubel1~admin.state.ak.us, bob crandall@}admin.state.ak.us, jolm norman~admin.state.ak.us, dan seamount@}admin.state.ak.us, .lane willian1son@}admin.state.ak.us The following meeting has been added to your Agenda. , i i I Proposed by:Jody Colombie i I Access level: Normal Importance level: Normal Subject: Multi-phase Metering Tuesday, January 11, 2005 Time: 9:00 am to 12:00 pm (NAST9NADT) Location: Hearing Room I John K. Norman <John Norman~admin.state.us>! 10f2 1/3/2005 3 :44 PM Re: [Fwd: Multi-phase Metering] ) ! Commissioner i Alaska Oil & Gas Conservation Commission I 2of2 1/312005 3 :44 PM =+t:: ~ STATE OF ALASKA ) NOTICE TO PUBLISHEI ) ADVERTISING ORDER NO. ADVERTISING ORDER SEE BOTTOM FOR INVOICE ADDRESS INVOICE MUST BE IN TRIPLICATE SHOWING ADVERTISING ORDER NO" CERTIFIED AFFIDAVIT OF PUBLICATION (PART 2 OF THIS FORM) WITH ATIACHED COPY OF ADVERTISEMENT MUST BE SUBMITTED WITH INVOICE AO-02514026 F AOGCC R 333 W 7th Ave, Ste 100 0 Anchorage, AK 99501 AGENCY CONTACT DATE OF A.O. Jody Colombie PHONE December 1, 2004 PCN M (907) 793 -1 ??1 DATES ADVERTISEMENT REQUIRED: ¿ Anchorage Daily News P0 Box 149001 Anchorage, AK 99514 December 2, 2004 THE MATERIAL BETWEEN THE DOUBLE LINES MUST BE PRINTED IN ITS ENTIRETY ON THE DATES SHOWN. SPECIAL INSTRUCTIONS: Type of Advertisement X Legal D Display Advertisement to be published was e-mailed D Classified DOther (Specify) SEE ATTACHED SEND INVOICE IN TRIPLICATE TO REF TYPE NUMBER VEN 2 ARD 02910 3 4 FIN AMOUNT SY CC PGM LC ACCT FY NMR DIST LlQ 05 02140100 73451 AOGCC, 333 Vv'. 7th Ave., Suite 100 ,~chorage.AJ( 99501 AMOUNT DATE TOTAL OF PAGE 1 OF ALL PAGES$ 2 PAGES COMMENTS 2 3 R:Q~~~~-;Y~-(~J 0'- )J DIVISION APPROVAL: ) Notice of Public Hearing STATE OF ALASKA Alaska Oil and Gas Conservation Commission Re: Rules governing use of multiphase meters for well testing and allocation of production within all pools within the Colville River, Endicott, Kuparuk River, Milne Point, Northstar, and Prudhoe Bay Fields The Alaska Oil and Gas Conservation Commission ("Commission"), on its own motion, proposes to regulate the use of multi-phase meters for well testing and allocation of production within all pools within the Colville River, Endicott, Kuparuk River, Milne Point, Northstar, and Prudhoe Bay Fields. The proposed rules are set out in the document "Guidelines for Qualification of Multiphase Metering Systems for Well Testing", dated November 30, 2004, which may be inspected at the Commission's offices or on its web site at www.aogcc.alaska.gov/MeterGuide.htm The Commission has tentatively set a consolidated public hearing on these proposed actions for January 11,2005 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 December 17, 2004. If a request for a hearing is not timely filed, the Commission will consider the issuance of orders 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 these proposed actions to 'the Alaska Oil and Gas Conservation Commission at 333 West ih Avenue, Suite 100, Anchorage, Alaska 99501. Written comments must be received no later than 4:30 pm on January 3, 2005, except that if the Commission decides to hold a public hearing, written comments must be received no later than 9:00 am on January 11, 2005. If you are a person with a disability who may need special accommodations in order to comment or to attend the public hearing, :~e cont~mbie at 793-1221. Daniel T. Seamount, Jr. Commissioner Published Date: December 2, 2004 ADN AO# 02514026 ') Anchorage Daily News Affidavit of Publication ") 1001 Northway Drive, Anchorage, AK 99508 PRICE OTHER OTHER OTHER OTHER OTHER GRAND AD# DATE PO ACCOUNT PER DAY CHARGES CHARGES #2 CHARGES #3 CHARGES #4 CHARGES #5 TOTAL 360257 12/02/2004 02514026 STOF0330 $175.20 $175.20 $0.00 $0.00 $0.00 $0.00 $0.00 $175.20 Î' J L, ,1,,_/\ J~ r iyL i~ - /7r¡ /¡ (Ii -:;ZL/ C , Notice of Public Hearing STATE OF AL.ASKA' ~~,AlaskaOì.I.(JndGas c~nservation Commission :R'~::~'Rule;, governing use ûf multi phase mét~rs for . .' 'JV~II te-sting ond ollocation of p~oduCllon witnin all pool;, within rn~ C~I'Jllle River, Enaicoll KlJPoruk Ri'J~r, MII"':- po.n!. ,Northstar, and Prudhoe Bav F l.elds ',.,.+t1~Älaskåoif.and'Gas éonsérvat.iO"n commi;:' sion'("Commission"), oT) it5 Qwn motIOn propos.S \0 re9ulotethe iJse ofl11ulri'Phose m~ters for ""ell tesr¡ng and allocation of p~oductlon Nllhln 011 ~oolS wlrhln the COlv;lI¿o River,Endicott K~paruk RI,'e~ I'/dlne point. NorThst()r, ana Pru~ho", B,)'I F,eld\ T he proposed ru les are set outlnt.he documen "Guidelines for aualification,jr ,,'ijltiDh('lc,~ M.~t~~- ing s,,:.te-m:. for 'Nell Testing" üùl~'? ~I~':,~,m~,:r. ,.11,1, 2P04,Whichmavbeinspectecj ,:,1 Ir,,,: \, ."T"Y" """r. > offices oron its website at: . .. www.aogct.olaska.gov!MeterGulde.htm TheComrnission has tentativelY seta ~onsoli. dated,publichearing on these proposed actlo~s for 'Januarv1l20050t 9:00 om atthe Alaska 011 and GasCon~e/vation Commission at 333 W~st7th Av- enu" 5ulte 100 Ançhorage. Alaska 99501,Aper: ;,on '~a~ r~quesT thai Ih", tent9tivelysch~duled h¿oaring ae held b't tiling ° written request with the Camrnis;,ion no laler tnon J:30pmonDe!=ember 17, 2ÜO,l. , . '. If a request fora heating is n.ottirnely filed, the Commission wi II ~ansider t~e Issuance .of .0rde~l~ without a hearing.' To learn If the Commission WI hold'the public tlearing, please. call 793.-1221. I nadditiOn: a person mavsubmit w~itten com- men's regarding these proposed actlon.s ~o the ~la;,l<,a Oil and Gas Conservation Commission at I 333 We;,r 7Th ':'",enue, suite 100, 'An~ho~age,. Alaska 99501 Written commènts must be received no later than 4: 30 pm on J anY.9r,y 3, 2005, e.xcept ~hat if the Commission decides.to hold a public h~.arrng, written comments must.be received no later' than 9:00 am on Januarv 11, ~005. ,. If YOU are a person with .a dis.åbilÌfvwhO may need special accommodatIOns I~ order to com- ment or.to atTend tne public hearrng, please con-. tact JodvColomaie aT 79).1221 . . STATE OF ALASKA THIRD JUDICIAL DISTRICT Teresita Peralta, 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 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 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. Signed ;/¡¡1/19/JcU Subscribed and sworn to me before this date: Notary Public in and for the State of Alaska. Third Division. Anchorage, Alaska i ' i', I~{ j '{ì J or] ,', '7 MY COMMISSION EXPIRES: t; ''.-j / I /Á 1..-1: lL',' } l , J' ,...,) j i /',.,i / . ,/ - / f'/., /1 J / ¡//" ! I, i />rv'1,y;",'¡ ;il l' /7 ,Jl ¡ I u .,.i(,il,l ,/7\ !.. A , J I F-_'; '!.-/"j~ v " . ,'1.'," XY II /'-""',' .//\ 1/ '/ _/ Daniel T. Seamount, Jr. Commissioner ADN AO# 02514026 Publish: December 2, 2004 ., I "'.' RE: Public Notice ') Subject: RE: Public Notice From: legalads <legalads@adn.com> Date: Wed, 01 Dec 2004 12:30:10 -0900 To: Jody Colombie <jody_colombie@admin.state.ak.us> Hi Jody: Following is the confirmation information on your legal notice. Please let me know if you have any questions or need additional information. Account Number: STOF 0330 Legal Ad Number: 360257 Publication Date(s): December 2, 2004 Your Reference or PO#: 02514026 Cost of Legal Notice: $175.20 Additional Charges Web Link: E-Mail Link: Bolding: Total Cost to Place Legal Notice: $175.20 Your Legal Notice Win Appear On The Web: www.adn.com: XXXX Your Legal Notice Win Not Appear On The Web: www.adn.com:. Thank You, Kim Kirby Anchorage Daily News Legal Classified Representative E-Mail: legalads@adn.com Phone: (907) 257-4296 Fax: (907) 279-8170 ---------- From: Jody Colombie Sent: Wednesday, December 1, 2004 11 :33 AM To: legalads Subject: Public Notice «File: Ad Order form.doc»«File: multiphase notice. doc» 1 of 1 12/1/2004 1 :31 PM 02-902 (Rev. 3/94) Publi~.- _./p~1inal Copies: Department Fiscal, Depar J*')eceiVing AO,FRM 'STATE OF ALASKA NOTICE TO PUBLISHER ADVERTISING..<>RDERNO. ADVERTISING INVOICE MUST BE IN TRIPLICATE SHOWING ADVERTISING ORDER NO.. CERTIFIED AO-02514026 ORDER AFFIDAVIT OF PUBLICATION (PART 2 OF THIS FORM) WITH ATTACHED COpy OF ADVERTISEMENT MUST BE SUBMITTED WITH INVOICE SEE BOTTOM FOR INVOICE ADDRESS F AOGCC R 333 West ih Avenue, Suite 100 0 Anchorage, AK 99501 M 907-793-1221 AGENCY CONTACT Jody Colombie PHONE (907) 793 -1 ??1 DATES ADVERTISEMENT REQUIRED: DATE OF A.O. December 1, 7004 PCN T 0 Anchorage Daily News PO Box 149001 Anchorage, AK 99514 December 2, 2004 THE MATERIAL BETWEEN THE DOUBLE LINES MUST BE PRINTED IN ITS ENTIRETY ON THE DATES SHOWN. SPECIAL INSTRUCTIONS: United states of America AFFIDAVIT OF PUBLICATION REMINDER State of ss INVOICE MUST BE IN TRIPLICATE AND MUST REFERENCE THE ADVERTISING ORDER NUMBER. A CERTIFIED COPY OF THIS AFFIDAVIT OF PUBLICATION MUST BE SUBMITTED WITH THE INVOICE. ATTACH PROOF OF PUBLICATION HERE. division. Before me, the undersigned, a notary public this day personally appeared 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 2004, and thereafter for - consecutive days, the last publication appearing on the - day of ,2004, 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 2004, Notary public for state of My commission expires 02-901 (Rev. 3/94) AO.FRM Public Notice ) ) Subject: Public Notice From: Jody Colombie <jody_colombie@admin.state.ak.us> Date: Wed, 01 Dec 2004 11 :33:54 -0900 To: Legal Ads Anchorage Daily Ne\vs <legalads@adn.com> Order Content-Type: applicationlmsword Content-Encoding: base64 , . .... .. '.m' m' , .. .' ...................................,,,.,.............................................._,_,.m,..n,! . , '. .i Content-Type: applicationlmswordi ¡multIphase notIce.doc: E d. b 64 . ; .: Content- nco lng: ase ,-,,-,,-,,"~---"'-"-----"~--'-""-"'--""._~......".'-.-..-..-.. --:...--.~....:-.;~;~------.-.----.~----..-.-.-----,,--.._._...l 1 of 1 12/112004 11:35 AM Public Notice ) From: lody Colombie <jody_colombie@admin.state.ak.us> Date: Wed, 01 Dee 2004 11 :34:22 -0900 To: Cynthia B Mciver <bren_mciver@admin.state.ak.us> i . Content-Type: applicationlmsword! i multiphase notice. doc . , . Content-Encoding: base64 : ,....,. 1 of 1 12/1/2004 11 :35 AM Public Notice ) Subject: Public Notice From: Jody Colombie <jody_colombie@admin.state.ak.us> Date: Wed, 01 Dec 2004 11 :34:54 -0900 To: undisclosed-recipients:; BeC: Robert E Mintz <robert_mintz@law.state.ak.us>, Christine Hansen <c.hansen@iogcc.state.ok.us>, Terrie Hubble <hubbletl@bp.com>, Sondra Stewman <StewmaSD@BP.com>, Scott & Cammy Taylor <staylor@~alaska.net>, stanekj <stanekj@unocal.com>, ecolaw <ecolaw@.trustees.org>, roseragsdale <roseragsdale@gci.net>, tnnjrl <trmjr l@aol.com>, jbriddle <jbriddle@marathonoil.com>, rockhill <rockhill@aoga.org>, shaneg <shaneg@evergreengas.com>, jdarlington <jdarlington@forestoil.com>, nelson <knelson@petroleumne\vs.com>, cboddy <cboddy@.usibelli.com>, Mark Dalton <mark.dalton@hdrinc.com>, Shannon Donnelly <shannon.donnelly@conocophillips.com>, "Mark P. Worcester" <mark.p. worcester@conocophillips.com>, Bob <bob@inletkeeper.org>, wdv <wdv@dnr.state.ak.us>, tjr <tjr@dnr.state.ak.us>, bbritch <bbritch@alaska.net>, mjnelson <mjnelson@purvingertz.com>, Charles O'Donnell <charles.o'donnell@veco.com>, "Randy L. Skillern" <SkilleRL@BP.com>, "Deborah J. Jones" <JonesD6@BP.com>, "Paul G. Hyatt" <hyattpg@BP.com>, "Steven R. Rossberg" <RossbeRS@.BP.com>, Lois <lois@inletkeeper.org>, Dan Bross <kuacnews@kuac.org>, Gordon Pospisil <PospisG@BP.com>, "Francis S. Sommer" <SommerFS@BP.com>, Mikel Schultz <Mikel.Schultz@BP.com>, "Nick W. Glover" <GloverNvV@BP.com>, "Daryl J. Kleppin" <KleppiDE@BP.com>, "Janet D. Platt" <PlattJD@BP.com>, "Rosanne M. Jacobsen" <JacobsRM@BP.com>, ddonkel <ddonkel@cfl.rr.com>, Collins Mount <collins - mount@.revenue.state.ak.us>, mckay <mckay@.gci.net>, Barbara F Fullmer <barbara.f.fullmer@conocophillips.com>, bocastwf <bocastwf@bp.com>, Charles Barker <barker@usgs.gov> , doug_schultze <doug_schultze@xtoenergy.com>, Hank Alford <hank.alford@exxonmobil.com>, Mark Kovac <yesnol@gci.net>, gspfoff <gspfoff@aurorapower.com>, Gregg Nady <gregg.nady@sheILcom>, Fred Steece <fred.steece@state.sd.us>, rcrotty <rcrotty@ch2m.com>,jejones <jejones@aurorapower.com>, dapa <dapa@alaska.net>,jroderick <jroderick@gci.net>, eyancy <eyancy@seal-tite.net>, "James M. Ruud" <james.m.ruud@conocophillips.com>, Brit Lively <mapalaska@ak.net>, jah <jah@dnr.state.ak.us>, Kurt EDIson <kurt_olson@legis.state.ak.us>, buonoje <buonoje@bp.com>, Mark Hanley <mark_hanley@anadarko.com>, 10ren_Ieman <loren_leman@gov.state.ak.us>, Julie Houle <julie_houle@,dnr.state.ak.us>, John W Katz <jwkatz@sso.org>, Suzan J Hill <suzan_hill@dec.state.ak.us>, tablerk <tablerk@unocal.com>, Brady <brady@aoga.org>, Brian Havelock <beh@dnr.state.ak.us>, bpopp <bpopp@borough.kenai.ak.us>, Jim White <jimwhite@satx.rr.com>, "John S. Haworth" <john.s.haworth@exxonmobil.com>, marty <marty@rkindustrial.com>, ghaminons <ghammons@aol.com>, nnc1ean <rmc1ean@pobox.alaska.net>, rnkm7200 <rnkm7200@aol.com>, Brian Gillespie <ifbmg@uaa.alaska.edu>, David L Boelens <dboelens@aurorapower.com>, Todd Durkee <TDURKEE@KMG.com>, Gary Schultz <gary_schultz@dnr.state.ak.us>, Wayne Rancier <RAN CIER@petro-canada.ca>, Bill Miller <Bill- Miller@xtoalaska.com>, Brandon Gagnon <bgagnon@brenalaw.com>, Paul Winslow <pmwinslow@forestoil.com>, Garry Catron <catrongr@bp.com>, Sharmaine Copeland <copelasv@bp.com>, Kristin Dirks <kristin_dirks@dnr.state.ak:.us>, Kaynell Zeman <kjzeman@marathonoil.com>, John Tower <John.Tower@eia.doe.gov>, Bill Fowler <Bill_Fowler@anadarko.COM>, Vaughn Swartz <vaughn.swartz@.rbccm.com>, Scott Cranswick <scott.cranswick@mms.gov>, Brad McKim <mckimbs@BP . com>, Steve Lambe <lambes@unocal.com>, jack newell <jack.newell@acsalaska.net>, James Scherr <James.Scherr@mms.gov>, david roby lof2 12/1/2004 11 :35 AM Public Notice ) ) <David.Roby@mms.gov>, Tim La\vlor <Tim - Lawlor@ak.blm.gov>, Lynnda Kahn <Lynnda_Kahn@fws.gov>, Jerry Dethlefs <Jerry.C.Dethlefs@conocophillips.com>, Jerry Dethlefs <n 1617@conocophillips.com> \_. "'-.---."--,.,. - -..-, --~ -.- -.---- _.._---~..- --------- ._-- ~-'-"'~'.- -- -~_._._.. _.,-~ , Content-Type: applicationlmsword I ¡ multiphase notice. doc ¡ Content-Encoding: base64 I --~.,--_.- "--'-----.- -- -.--.--",---~,---.--.-.,--~-----~-----1 20f2 12/1/200411:35 AM Citgo Petroleum Corporation PO Box 3758 Tulsa, OK 74136 ) . Mary Jones XTO Energy, Inc. Cartography 810 Houston Street, Ste 2000 Ft. Worth, TX 76102-6298 Kelly Valadez Tesoro Refining and Marketing Co. Supply & Distribution 300 Concord Plaza Drive San Antonio, TX 78216 Robert Gravely 7681 South Kit Carson Drive Littleton, CO 80122 Jerry Hodgden Hodgden Oil Company 408 18th Street Golden, CO 80401-2433 Richard Neahring NRG Associates President PO Box 1655 Colorado Springs, CO 80901 Kay Munger Munger Oil Information Service, Inc PO Box 45738 Los Angeles, CA 90045-0738 Samuel Van Vactor Economic Insight Inc. 3004 SW First Ave. Portland, OR 97201 Mark Wedman Halliburton 6900 Arctic Blvd. Anchorage, AK 99502 Schlumberger Drilling and Measurements 2525 Gambell Street #400 Anchorage, AK 99503 Baker Oil Tools 4730 Business Park Blvd., #44 Anchorage, AK 99503 Ciri Land Department PO Box 93330 Anchorage, AK 99503 Gordon Severson 3201 Westmar Cr. Anchorage, AK 99508-4336 Jack Hakkila PO Box 190083 Anchorage, AK 99519 James Gibbs PO Box 1597 Soldotna, AK 99669 Kenai National Wildlife Refuge Refuge Manager PO Box 2139 Soldotna, AK 99669-2139 Richard Wagner PO Box 60868 Fairbanks, AK 99706 Cliff Burglin PO Box 70131 Fairbanks, AK 99707 Williams Thomas Arctic Slope Regional Corporation Land Department PO Box 129 Barrow, AK 99723 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 David Cusato 200 West 34th PMB 411 Anchorage, AK 99503 Jill Schneider US Geological Survey 4200 University Dr. Anchorage, AK 99508 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 Il/I//Iek! aIi)¥