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Home My WebLink AboutCO 091 E ) ) 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 by direct inspection of the file. (~O 0 C I E Order File Identifier , Organizing (done) D Two-sided 1111111111111111111 o Rescan Needed 1111111111111111111 RES CAN DIGITAL DATA OVERSIZED (Scannable) D Maps: D Other Items Scannable by a Large Scanner D Color Items: D Greyscale Items: D Diskettes, No. D Other, NolType: o Poor Quality Originals: OVERSIZED (Non-Scannable) D Other: D Logs of various kinds: Scanning Preparation x 30 = o Other:: Dale: (¡; 3 os- Is! ~ 1111111111111111111 Dale:to Ò os Isl mP + = TOTAL PAGES ~ð (Coun~do ~s no'-'inclu~ cover sheet) V)IJ .p Date:(/? a 05 151 r r V .' ¡ 1111111111111111111 NOTES: BY: Helen~ Project Proofing BY: Helene Maria) BY: Helen /Maria ~ b!. ~ Production Scanning Stage 1 Page Count from Scanned File: ~ 4 (Count does include cover sheet) Page Count Matches Number in Scanning Preparation: V YES , Helen~ Date: (P ,(.3, 0 S" NO BY: 151 vvtP Stage 1 If NO in stage 1, page(s) discrepancies were found: YES NO BY: Helen Maria Date: 151 11111111111I1111111 Scanning is complete at this point unless rescanning is required. ReScanned 1111111111111111111 BY: Helen Maria Date: 151 Comments about this file: Quality Checked 1IIIIII111111111111 12/1/2004 Orders File Cover Page.doc ') ) Conservation Order 91E 1. 2. 3. August 20, 1976 August 28, 1976 September 28, 1976 4. October 1, 1976 Atlantic Richfield Company application re: CO 91E Notice of Hearing and affidavit of publication Atlantic Richfield Company request for an administrative Approval Emergency Order Conservation Order 91E "\' '), /'\ ~) State of Alaska Department of Natural Resources Division of Oil and Gas 3001 Porcupine Drive Anchorage, Alaska 99501 Conservation Order No. 91-E Re: The appl ication of the Atlantic ) Richfield Company for an order ) pursuant to Title 11, Alaska ) Administrative Code, Section ) 22.540 modifying Conservation ) Order No. 91-D Rule 2a to remove ) the throughput restriction of the) Prudhoe Bay Topping Plant. ) Prudhoe Bay Field Prudhoe Oil Pool Prudhoe Bay Topping Plant September 22, 1976 IT APPEARING THAT: 1. The Atlantic Richfield Company submitted the referenced application on August 20, 1976. 2. The notice of the Atlantic Richfield Company request was published in the Anchorage Daily News on August 28, 1976 pursuant to Title 11, Alaska Administrative Code, Section 22.540 and no protests were received. FINDING: 1. The October 1, 1976 completion of the Field Fuel Gas System in the Prudhoe Bay Oil Field makes it possible to beneficially utilize all the casinghead gas produced in excess of the amount prescribed for the safety flare at the Prudhoe Bay Crude Oil Topping Plant. CONCLUSION: 1. There is no regulation restricting throughput of a facility providing the casinghead gas produced is beneficially used. NOW, THEREFORE, IT IS ORDERED THAT: 1. Rule 2a of Conservation Order 91-D is am~ended to read as follows: The volume of crude oil produced for topping plant use shall not be restricted. ',,- ) , ',> ) Conservation Order No. 91-E Page 2 September 22, 1976 DONE at Anchorage, Alaska and dated September 22, 1976. dL. r¿ If!( ~ l. Thomas R. Marshall, Jr., Executive Secretary Alaska Oil and Gas Conservation Committee Concurring: Hamilt~h~ ìl and Gas Conservation Committee Har~? M:~rd¡~ Alaska Oil and Gas Conservation Committee #4 STATE OF ALASKA DEPARTMENT OF NATURAL RESOURCES D I V I S ION 0 F 0 I LAND GAS Alaska Oil and Gas Conservation Committee 3001 Porcupine Drive Anchorage, Alaska 99501 No. E2-91 D EMERGENCY o R D E R ...-,..---... October 1,. 1976 Re: Conservation File No. 91~D Atlantic Richfield Company Prudhoe Bay Field The Atlantic Richfield Company has petitioned the Alaska Oil and Gas Conservation Commi ttee for an emergency allowing exception to Rule 2 b of Conservation Order 91-D to permit the flaring of the excess casing- head gas necessary to maintain the current production rate for the Crude Oi 1 Topping Plant. Unforeseen transportation delays prevented completion of the projects which were intended to compress and dehy- drate the excess casinghead gas. An emergency order is hereby granted pursuant' to Ti tIe II, AlasJ.-.a Ad- ministrative Code, Section 22.555 permitting the flaring of excess gas at the Crude Oil Topping Plant until 7:00 AM, October 15, 1976. I ó! æ, /j¡¡~¡¿f!f ¡. Thomas R. Marshall, Jr. Executive Secretary #3 AtlanticR ichfield Company North Amerir \Producing Division Alaska Explo bn & Producing Operations Post Office Box 360 Anchorage, Alaska 99510 Telephone 907277 5637 ~~ ~". Af pi" "-tn>1 k y _ ,.,," () , ~\ .f'\o" j ,',., , !" I t, '1,'I·'l .' "").,' l ;"~ 11:, "') ~, '. , , ,':, (,;" " , ,~,/ ." J ' \.:1;' 7 ,;: ( .. , ,.,,"{ E '2..- 91 0 ItA <18,ß!> ' / Alaska Oil & Gas Conservation Committee State of Alaska, Dept. of Natural Resources Division of Oil & Gas 3001 Porcupine Drive Anchorage, AK 99501 ') Robert A. Crosky North Alaska Operations Manager September 28, 1976 Subject: Application for Administrative Approvals pursuant to Conservation Order 98-B. Gentlemen: Your earliest possible attention to the requests con- tained in this letter are needed and will be appreciated. We have verbally kept you advised of the progress of our ongoing efforts to reduce flaring from the çrude oil t~pping plant to the level of a 400 MCF/D s¡fe~y pilot by beneticially using all produced gas in excess of that volume. This requires the completion of the Prudhoe Bay Field Fuel Gas Pipeline System and a com- pressor and related faciliite"§'''''at the plant. The pipeline system has already been purged and is being pressured up with gas. Deliveries to BP Alaska Inc. are imminent. Every feasible action is being taken to complete the compressor and related facilities at the earliest possible date. For example, personnel have been "borrowed" from other projects and a 24-hour construction schedule is in force. It is hoped that the compressor and additional dehydration capacity will be available by October 15, perhaps as early as October 10. (You will recall that certain key items needed for these facilities required long delivery periods and some of those were recently delayed even further by causes beyond the control of our Company.) Accordingly, you are respectfully requested to issue administrative approvals and an emergency order pursuant to Rule 8 of Conservation Order 98-B as follows: 1. In order to commission and gain operating experience with the aforesaid facilities, prudent operations will likely require some intermittent flaring during a 'II shakedown" period for such things as tes ting, improving, repairing and/or modifying the facilities. A period r~ ~ n 1 ¡ ·'·',i 1. r\:~~ I.E {~ Œi r ~1',,7 ~§$P 2..9 ~.. ..... ) \ , Alaska Oil & Gas Conservation Committee September 28, 1976 Page 2 ending sixty days following the startup of the compressor should be sufficient for this purpose. (Note that this does not contemplate sixty days of continuous flaring, but a sixty day period during which intermittent flaring may be necessary.) The exact volumes, if any, to be flared are not predictable. 2. Following the sixty day "shakedown" period, we request your approval to flare such volumes as may from time to time result from such events as operational upsets that could create risks of explosions and fires; provided, however, that if any such flaring continues for a period of five days and could be safely stopped by a cessation of the source operations, the Committee's approval will be requested if the operator desires to continue such flaring. 3. An emergency order is requested to permit the continuation of flaring from the COT plant up to and including October 15 to the extent the gas therefrom can not be used pending the availability of the com- pression and additional dehydration capacities pre- viously mentioned. (In fact, flaring has already been reduced by the aforesaid deliveries being made to pressure up the pipeline system.) This emergency order is justified because, among other reasons, the subject operation is the source of some 5,000 MCF/D of gas that is being beneficially used in ways that are essential to the continuation of vital operations in the field -- including, for example, the heating of quarters occupied by approximately 2,000 workers. As stated earlier, your earliest possible attention will be appreciated and we will remain available to provide you with any additional information you may desire. Very truly yours, ß ¡t?4~ 1¡::P~)R. A. Crosky RAC:job \'::.~; " W~ ; , ~ \ ' t~ . 1,.~ "1 :' :":? /\ ,.~ i~jrl,~ .~ ...' , , . i' #2 ') ¡"; ) NOTICE OF PUBLIC HEARING STATE OF ALASKA DEPARTMENT OF NATURAL RESOURCES Alaska Oil and Gas Conservation Committee Conservation File No. 91-E Re: Prudhoe Oil Pool Prudhoe Bay Field Prudhoe Bay Topping Plant Notice is hereby given that an application was received from the Atlantic Richfield Company on August 20, 1976, applying for an order pursuant to Title II, Alaska Administrative Code, Section 22.540 ammending Conservation Order No. 91-0, Rule 2a to remove the throughput restrictions of the topping plant because completion of the Field Fuel Gas System will make it possible to beneficially utilize all the casinghead gas in excess of the amount pre- scribed for the safety flare. Parties who may be aggrieved if the requested order is issued are allowed 10 days from the date of this publication in which to file a protest and request for hearing. Place of filing is 3001 Porcupine Drive, Anchorage, Alaska 99501. If such a protest is timely filed, a hearing on the matter will be held at the above address at 9:00 AM, September 8, 1976, at which protestants and others may be heard. If no such protest is timely filed, the Committee will consider the issuance of the order without a hearing. ûl,I<I/f~( Thomas R. Marshall, Jr. Executive Secretary Alaska Oil and Gas Conservation Committee 3001 Porcupine Drive Anchorage, Alaska 99501 Publish August 28, 1976 #1 "'ÀtlanticRichfie!dCompany NorUî1 Amer~' )pmdUdng Dhviskm Alaska Reg, ¡¿' Post omce Eh))( 360 Anchorage, Alaska 99510 Telephone 907 211 5637 August 20, 1976 ì i Alaska Oil & Gas Conservation Committee State of Alaska Department of Natural Resources Division of Oil & Gas 3001 Porcupine Drive Anchorage, Alaska 99501 Subject: APPLICATION Re: Prudhoe Bay Field Fuel Gas System, Field Fuel Gas Unit and Crude Oil Topping Plant /' Gentlemen: We expect to make the Field Fuel Gas System suf- ficiently operational by the end of next month to accept gas from the Crude Oil Topping Plant. As noted in your Conservation Order 9l-D, this will enable us to reduce the Crude Oil Topping Plant flare. Meanwhile, work on the Field Fuel Gas Unit will continue and we expect to complete it before the end of this year. Accordingly, we need an order setting the maximum volumes needed for safety flaring at such unit and authorizing sufficient flaring to purge and test the unit and related system during a "shakedown" period. We also need permission to increase the throughput rate of the Crude Oil Topping Plant. Finally, we request an administrative approval provision in case the need arises to make changes that might otherwise require undue delays in the commissioning of these vitally important facilities. Specifically, we request an order along the lines of the draft attached hereto. Also enclosed for your consideration and possible use are a draft public notice and a supporting statement. ~:lQ~l RODert A. Crosky Y Operations Manager ~ RAC:kab Enclosures ~~ ~". , (C) ì ' DRAFT PROPOSED ORDE R 1. Atlantic Richfield Company is hereby granted permission to flare gas from the Prudhoe Bay Field Gas Unit and related Field Fuel Gas System subject to the following limitations: a. an average of 600 mcf per day on a monthly basis for the purpose of maintaining a safety flare or flares; b. such volumes as may from time to time result from such events as operational upsets that could create risks of explosions and fires from hydrocarbon accumulations; provided, however, that if any such flaring in excess of the volumes allowed for safety purposes continues for a period of five days and can be safely stopped by a cessation of the source operations, the Committee's permission must be obtained to continue such flaring; and c. during an initial "shakedown" period ending 90 d~ys following the startup of the operation of the Field Fuel Gas Unit, such volumes as may be required by the operator for purging, testing, repairing, adjusting and/or modifying the unit and related system. Page 1 of 3 J ,1 2. Atlantic Richfield Company is hereby granted permission to flare casinghead gas from the Prudhoe Bay Crude Oil Topping Plant subject to the following limitations: a. an average of 400 mcf per day on a monthly basis for the purpose of maintaining a safety flare or flares; b. such volumes as may from time to tim~ result from such events as operational upsets that could create risks of explosions and fires from hydrocarbon accumulations; provided, however, that if any such flaring in excess of the volumes allowed for safety purposes continues for a period of five days and can be safely stopped by a cessation of the source operations, the Committee's permission must be obtained to continue such flaring; and c. during an initial "shakedown" period ending 60 days following the startup of the compressor and related facilities installed at such plant to utilize low pressure gas, such volumes as may be required by the operator for purging, testing, repairing, adjusting and/or modifying such compressor and related facilities. Page 2 of 3 ) ¡ 3. Atlantic Richfield Company is hereby granted permission to inject unused fractions of crude oil produced for Prudhoe Bay Crude Oil Topping Plant use into the Prudhoe Oil Pool subject to the limitation that the volume of crude oil produced for topping plant use shall not exceed an average of 16,000 barrels per day on a monthly basis. 4. The Committee may, from time to time, by administrative orders without further public notices or hearings grant the type of permission provided for in l.b. and 2.b. of this order, and require or permit decreases or increases in any limitations set in this order and/or extend or shorten any time periods herein established. 5. Conservation Order 9l-D is superseded by this order and is hereby revoked. Page 3 of 3 J ) D R AFT PROPOSED PUBLIC NOTICE Re: Prudhoe Oil Pool Prudhoe Bay Field Prudhoe Bay Topping Plant Prudhoe Bay Field Fuel Gas System Notice is hereby given that an application was received on August 20, 1976 from Atlantic Richfield Company, as operator of the subject crude oil topping plant and fuel gas system, applying for an order pursuant to Title 11, Alaska Administrative Code, Section 22.540 requesting permission to maintain a safety flare or flares at the Prudhoe Bay Field Fuel Gas Unit amd related system of sufficient volumes to avoid risks of explosions and fires resulting from accumulations such as might result from operational upsets, and to flare such volumes from such unit and system and from the subject crude oil topping plant as may be needed for purging, testing and operating such system and related facilities for initial "shakedown" periods following the commencement of the operations. The operator further requests permission to operate the subject plant at an average throughput rate up to 16,000 barrels of crude oil per day on a monthly basis. The Operator does not request any increases in the specific flare limits already set for the crude oil topping plant, and states that when the Field Fuel Gas System and related facilities become operational, flaring at- the topping plant can be reduced to a safety flare without decreasing the throughput rate because gas from the plant will be taken into the system and beneficially used. The Committee may include in its order an administrative approval provision to increase or decrease any limitations and to shorten or extend any time periods provided for therein. [Usual closing paragraph.] ok 'k ';'( ';'( 'k ) ) Statement in Support of Atlantic Richfield Company's Application of August 20, 1976 Regarding the Prudhoe Bay Field Fuel Gas Unit and System and the Prudhoe Bay Crude Oil Topping Plant. With respect to matters preceding the issuance of Conservation Order 9l-D, reference is hereby made to the files and records of the Division of Oil & Gas pertaining to Conservation Orders 91, 9l-A, 9l-B, 9l-C and 9l-D. This is done to make the record of this application complete without repeating earlier findings and other details already within the Committee's knowledge. Since the issuance of Conservation Order 9l-D, work has progressed to make the Prudhoe Bay Field Fuel Gas System sufficiently operational to accept gas from the topping plant by October 1, 1976. This will enable the operator to put high pressure gas from the topping plant into the system. Concurrent work is being done to install compression facilities at the plant in order to utilize low pressure gas. These installations will enable the operator to reduce the volume of gas currently being flared at the topping plant from the current maximum level of 6',000 MCFPD to the level of a safety flare -- a maximum of 400 MCFPD. When the Field Fuel Gas Unit becomes operational (probably before the end of this year) a safety flare will be needed there, also. It is anticipated that the maximum volumes needed for such purpose will never exceed 600 MCFPD. J ) The specific reasons for the exact provisions in the proposed order follow. Flares Conservation Order 98-B (part of the so-called "Prudhoe Bay Field Rules") provides, in pertinent part: "Rule 8. Gas Venting or Flaring. The venting or flaring of gas is prohibited except as may be authorized by the Committee in cases of emergency or operational necessity." Safety flares are operational necessities. It might be more appropriate to call them "pilot lights". Their purpose is to avoid the risk of explosions and fires from hydrocarbon accumu- lations that can result from such things as operational upsets. This has already been specifically recognized in Conservation Orders 91 and 114. In the latter (sometimes referred to as the "Cook Inlet No-Flare Order"), the Connnittee concluded: "Safety of personnel and property is the paramount con- sideration; therefore safety flares...should be of an adequate size to handle both routine and unexpected gas and liquid volumes." Accordingly, the volumes being requested for safety flares are maximums."k *Perhaps it should be noted here that prior to major oil production such volumes will also include a small amount of condensed vapors to be removed from the field fuel gas system. ) ) Those portions of the proposed order ('s l.b. and 2.b.) referring to flaring resulting from such things as operational upsets are merely intended to make explicit that which is implicit from the purpose of such flares. On the other hand, a proviso has been added to require the Committee's permission to continue any such flaring for more than five days in instances where it could be safely stopped by shutting down the source operations. This proviso should obviate any concerns about instances where the Committee's opinion might differ from the operator's with respect to the necessity for such flaring. Please note that the proposed five day period is not exclusive of weekends or holidays. Those portions of the proposed order ('s l.c. and 2.c.) pertaining to possible flaring during a "shakedown" period are to accomodate a definite need to purge the system initially. Such flexibility may also be needed to allow the operator to test for, detect and correct malfunctions where such would be difficult or impossible while the facilities are shut down. It should be noted that the periods requested for such purposes are to expire irrespective of whether or to what extent any such flaring actually occurs. In other words, no request is made for permission to flare for the stated number of days. In fact, except for approximately 15 days required for purging operations, it is not certain that any such flaring will take place at all. Nevertheless, it would seem prudent to provide for such flexibility in order to enable the operator to achieve an optimum operational ) ) I level within a reasonable time after startup. The 15 ,OnnBarrel Daily' ThroUghput Limit In Conservation Order 91-D, both the permission to flare and the permission to inject unused fractions seem to be conditioned upon limiting the volume of crude oil produced for topping plant use to an average of 13,000 barrles per day on a monthly basis. The proposed order (~r3) would change this in two respects by (1) removing this as a condition to flaring, and (2) increasing the limit from 13,000 to 16,000 barrels. The first change is appropriate because flaring volumes are and will be limited directly, and there is no longer any need for a "back door" limitation. The reason for the second change, the increase to 16,000 barrels, is mainly a matter of administrative convenience. Such limit should be high enough to allow for occasional increases in the plant's capacity up to 16,000 barrels without repeated administrative proceedings. The history of the plant seems to indicate this would be wise. When the plant commenced operations in October of 1969 its "design" capacity was 5,000 BOPD. By "design" capacity, was meant the plant manufacturer's guaranteed inlet rate. In June of 1973 a test indicated the plant's actual capacity to be about 5,800 BOPD. Thereafter, minor modifications and fine-tuning increased its capacity to approximately 7,000 BOPD. On October 11, ) ) 1975 its capacity was essentially doubled. At the time of the December 1975 hearing (regarding Conservation Order 9l-D) the plant was averaging about 12,000 BOPD and it was then expected that the plant could handle approximately 13,000 BOPD. More current experience indicates the plant's actual capacity exceeds 13,000 BOPD and there are indicia there will be a definite need to produce up to 15,000 BOPD within the foreseeable future. Technological advances, modifications, fine-tuning and/or old-fashioned "necessity" may well combine to improve the plant's throughput capacity even more eventually. No such future increases will require the flaring of additional gas. Administrative Approvals The purpose of paragraph 5 of the proposed order is to enable the Committee to modify the order in its discretion without undue delays. It has been suggested that the Committee might be reluctant to use an open-ended provision for this purpose. For example, in the hearing of January 25, 1974 regarding Conservation Order 9l-A Mr. Burrell stated: fl. ..but you wouldn't object if we put some parameters on the administrative discretion; for instance, instead of going to December 31, 1976 we might not want to go, say, more than another year administratively, without another ) ) hearing. We might not want to let you go more than 10% on the throughput without another hearing. I just mention these numbers arbitrarily but we might take that approach, I don't know. Would you have objection to some limitation on our administrative discretion imposed on ourselves, by ourselves. II (Hearing Transcript, page 37) If the Committee desires to add such parameters, a proviso along the following lines might be added to paragraph 4 of the proposed order: "...; provided, however, another application and public notice will be required for any such extension or increase that would result in an extension of more than one year and/or an increase in excess of 50%." The foregoing is merely intended as a helpful suggestion in case the Committee desires such parameters. We are neither requesting nor recommending any such parameters, nor presuming to address any policy considerations involved. Revocation of Conservation Order 9l-D The proposed order (,r 5) would revoke Conservation Order 9l-D because it would be entirely superseded by the new order. Perhaps, however, all Conservation Orders in the 91- series should be ) ~' ) reviewed to determine if any of the supporting findings stated therein should be expressly carried forward and repeated in the Committee's new order. * * * * *