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Home My WebLink AboutO 032 • INDEX OTHER NO. 32 PBU H -11 Enforcement Action 1. October 14, 2004 BPXA's initial assessment of field operations for PHU H- 11 2. October 25, 2004 Ltr from AOGCC to BPXA re: surface casing failure 3. November 10, 2004 BPXA response to the AOGCC ltr of 10/25/04 4. November 10, 2004 BPXA response to the AOGCC ltr of 10/25/04 5. November 12, 2004 BPXA Incident Investigation: Well H -11 OA over - Pressure Incident 6. November 19, 2004 Ltr from PACE to AOGCC 7. January 26, 2005 BP's H -11 Enforcement Action Submittal of Detailed Information 8. 2005 BPXA Status Update 9. Various Newspaper Articles 10. Background Information Other Order #32 4 111 STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Avenue, Suite 100 Anchorage Alaska 99501 -3539 Re: BP Exploration (Alaska), Inc., as Operator of the ) Prudhoe Bay Unit; Prudhoe Bay Field; ) Well PBU H -11 Enforcement Action ) AOGCC Order No. 32 December 16, 2004 DECISION AND ORDER On October 25, 2004, the Alaska Oil and Gas Conservation Commission ( "Commission ") issued a Notice of Proposed Enforcement Action under 20 AAC 25.535(b), stating that it considered that BP Exploration (Alaska) Inc. ( "BPXA ") may have violated provisions of Conservation Order No. 492 and regulation 20 AAC 25.526 in connection with operating well PBU H -11 ("H-11"). The Commission proposed civil penalties under AS 31.05.150(a) in the total amount of $117,500, as well as specified corrective actions. BPXA responded in writing on November 10, 2004, stating that it "does not contest the proposed enforcement action, although it asks the Commission to re- evaluate portions of the proposed action." Although BPXA specifically stated that it "does not request either a formal hearing or an informal conference in connection with this matter," there is no procedure by which the Commission can re- evaluate a proposed enforcement action and issue an enforcement order that differs from the proposal other than through an informal review or formal hearing under 20 AAC 25.535. Consequently, the Commission will treat BPXA's response as a request for informal review limited to a written statement, but subject to BPXA's representation that it will not contest the outcome (assuming that the order does not impose additional sanctions). lb 11 6 AOGCC Order #32 December 16, 2004 Page 2 of 6 A. Summary of Proposed Enforcement Action In its Notice of Proposed Enforcement Action, the Commission identified an apparent violation by BPXA of Rule 2 of Conservation Order No. 492 ( "CO 492 ") by failing to record and make available on request the results of monitoring the H -11 tubing and annulus pressures during the approximate time period of August 19, 2004, through September 8, 2004. The apparent violation of Rule 3 of CO 492 consisted in BPXA's failure to notify the Commission of OA pressure in H -11 exceeding 1,000 psig beginning on or about September 9, 2004 until September 21, 2004, on which date H -11's OA pressure was reported to the Commission by BPXA personnel in response to a Commission inquiry. The apparent violation of Rule 6 of CO 492 and 20 AAC 25.526 resulted from BPXA's failure to bleed off H -11 's OA pressure before it was restarted on September 9, 2004, after having been shut -in. The Commission proposed to order the following corrective actions by BPXA: (1) that within 30 days after the date of the enforcement order, BPXA provide the Commission with a detailed description of actions, planned and accomplished, to prevent recurrence of violations similar to those that the Commission believed to have occurred in connection with the start-up of H -11; and that BPXA provide the Commission with monthly progress reports until the planned actions are completed; and (2) that for a period of 180 days beginning 10 days after the date of the enforcement order, BPXA provide the Commission with (a) 24 hour advance notice of all Prudhoe Bay Unit ( "PBU ") well restarts so that the Commission has an opportunity to witness the restart operations; and (b) documentation of all PBU well pressure bleeds in connection with well restarts. AOGCC Order #32 December 16, 2004 I t ) Page 3 of 6 In addition, the Commission proposed the following civil penalties under AS 31.05.150 (a): (i) $2,500 per day for each of 21 days for violating Rule 2 from August 19, 2004, through September 8, 2004, inclusive; (ii) $5,000 per day for each of 12 days for violating CO 492, Rule 3 from September 9, 2004, through September 20, 2004, inclusive; and (iii) $5,000 for violating CO 492, Rule 6, and 20 AAC 25.526. The total of the proposed civil penalties was $117,500. B. Conservation Order 492, Rule 2 BPXA contends that Conservation Order 492, Rule 2, does not expressly require an operator to record OA pressure observations but acknowledges that an OA pressure recording requirement may be implied by Rule 2. BPXA further maintains that it would be helpful to clarify the rule and state the requirement expressly, if the Commission intends to require it. Although Rule 2 does not use the term "record," the Commission believes that recordation is clearly required by the provision of Rule 2 that "Monitoring results shall be made available for AOGCC inspection." It is not reasonable to interpret this provision as equating "monitoring results" with mere personal recollections. Accordingly, the Commission will impose the proposed civil penalties of $2,500 per day for each of 21 days from August 19, 2004 through September 8, 2004, inclusive To avoid the possibility of future uncertainty or misunderstanding, the Commission agrees that it may be desirable to revise Rule 2 to make the recording requirement express. The Commission may therefore initiate a separate proceeding to propose a rule amendment. C. Conservation Order 492, Rule 3 BPXA claims that sustained OA pressure in well H -11 could not have been verified instantaneously and that "in many instances, it may take a week or more to determine if a well is AOGCC Order #32 December 16, 2004 Page 4 of 6 exhibiting sustained outer annulus pressure." BPXA references a discussion recorded in a transcript of hearing dated May 27, 2003, in support of its position. CO 492, Rule 3 requires that an operator provide notice of sustained annulus pressures to the Commission within three working days. The Commission believes that a time period of three days is generally sufficient to assess the cause of anomalously high well annulus pressure observations and that it was sufficient in this instance. BPXA's Hearing Transcript citations address the relationship between relatively high annulus pressure observations and pressure bleed rates, in the context of BPXA's internal guidelines for bleeding down annulus pressures. However, during the relevant period BPXA performed no pressure bleeds on Well 11-11. Had BPXA performed timely H -11 annulus pressure bleeds in accordance with its guidelines, either to diagnose anomalously high OA pressure observations or for other reasons, BPXA would have been able to determine whether H -11 's outer annulus pressure met the definition of "sustained." BPXA also points out that Rule 3 does not require that an operator provide notice of sustained annulus pressure to the Commission earlier than three working days after identifying the situation. The Commission concurs, and the civil penalty calculation will be corrected accordingly. Finally, BPXA contends that the Commission had actual notice of 11-11 OA pressure, provided by a Commission Petroleum Inspector's observation. The inspector was conducting surface safety valve testing on H Pad when he noted H -11's OA pressure. Rule 3 requires an operator to provide the Commission notice of well annulus pressure observations above a specified threshold. The happenstance of a Commission Inspector's detecting pressure above that threshold simply does not excuse the operator from complying with its obligation under the rule. Among other problems with BPXA's argument, an Inspector doing AOGCC Order #32 December 16, 2004 Page 5 of 6 field work on the North Slope should not be expected to have to verify with the Commission whether the Commission has received notice from the operator or whether the operator is relying on the inspector to substitute for that notice. The Commission will impose civil penalties for violating Rule 3 of $5,000 per day for each of 9 days from September 12, 2004, through September 20, 2004, inclusive. D. Conservation Order No. 492, Rule 6 BPXA does not contest this portion of the proposed enforcement order. E. Corrective Actions BPXA accepts the Commission's proposed requirement that BPXA provide documentation of corrective actions but suggests that the requirement be clarified as providing for documentation in "Logbook," BPXA's well data recording system. The Commission concurs with this recommendation. BPXA objects to the Commission's proposed requirement of 24 hours advance notice of all PBU well restarts as being impractical. The Commission agrees that a blanket 24 hour notice requirement may not be practical in all cases and therefore withdraws this aspect of the required corrective actions. The Commission agrees to consider potential alternative procedures outside of this enforcement proceeding. it) AOGCC Order #32 l b December 16, 2004 Page 6 of 6 F. Findings and Conclusions For the reasons stated above, the Commission finds that BPXA violated Rules 2, 3, and 6 of Conservation Order No. 492 and regulation 20 AAC 25.526, and the Commission concludes that civil penalties in the total amount of $102,500 are appropriate and that the corrective actions set out below should be ordered. NOW THEREFORE IT IS ORDERED THAT: 1. BPXA shall pay to the Commission civil penalties of $102,500 within 30 days after the date this Decision and Order becomes final; 2. BPXA shall comply with the following corrective actions: a. Within 30 days from the date this Decision and Order becomes final, BPXA shall provide the Commission with a detailed description of actions, planned and accomplished, to prevent recurrence of violations similar to those found in connection with the start-up of H -11. BPXA shall provide the Commission with monthly progress reports until all planned actions are accomplished. b. For a period of 180 days beginning 10 days after the date this Order and Decision becomes final, BPXA shall document PBU well pressure bleeds performed in connection with well restarts in Logbook. 3. This Decision and Order shall become final o • ecem . er 27, 2004 Done at Anchorage, Alas ; is 16th of P - ce ► •'. , 2004. * N. OIL `` / A L 4 4 + 4, , , _ �; 10' .1 rman, hai . 111111 , �- ,., C t A a • • .. • • as Con erva . ommission �� & , ; �� 'r ` Daniel T. Seamount, Jr., Commissioner d ,,, ;, • Alaska Oil and Gas Conservation Commission 44 4 ., ... 414:, _ !'" �� (C� matt - i� �� 11 ("� ,. )c9,01 `',on° ) ) , E~CE/\I STATE OF ALASKA JAN 1 0 2005 ALASKA OIL AND GAS CONSERV A TION COMMI~IQ~(m f) ~ O[ uas Com; Cij .' . A /1'J(j'I\/k. . mm33SWII7J MSil\.fuurar8lge HE: BP EXPLORATION (ALASKA), INC., AS OPERA TOR OF THE ) PRUDHOE BAY UNIT; PRUDHOE BAY FIELD; ) WELL PBU H-ll ENFORCEMENT ACTION .",) ) BPXA'S SUBMISSION IN RESPONSE TO COMMISSION DECISION AND ORDER DA TED DECEMBER 16,2004 In its December 16, 2004 Decision and Order in this matter, the Alaska Oil and Gas Conservation Commission ordered BP Exploration (Alaska), Inc. ("BPXA"), as Operator of the Prudhoe Bay Unit, to pay the Commission a civil penalty of $102,500 (Ordering Paragraph No.1) and to provide the Commission with a detailed description of actions, planned and accomplished, to prevent recurrence of violations similar to those found in connection with the start-up of H-l1 (Ordering Paragraph No.2. a.). This filing is timely made to comply with Ordering Paragraph No. 1 of the Commission's Decision and Order. Concurrent with this pleading, BPXA submits a check in the amount of $102,500. BPXA is still preparing its detailed description of actions required under Ordering Paragraph No. 2.a. and will submit it under separate cover. If the Commission has any questions, please do not hesitate to call me at (907) 564-5289. "-fl·il Dated this lO day of January, 2005. Randal G. Buckendorf Attorney for BP Exploration (Alaska) Inc.,//--) __J«:c j~::ç)// .:' ,?,/ ~\ [r.,;r,,,A;::.J ' /i ~'<~ì,':"vr~}~c':-;/ / \'.... ._~../~-_.../~ l / I , c-·- .~>\ /0/·/,1" ..."/ V'" II Page 1 J~II - --.:...-..-- ~ ~'- .-- --- -. -.;. ..' - -~~_._-~--~~~~ ·:;;I~T,:::,,:yEF.ij.¡::Y¡T:HE'¡'/¡.l:Itf.lENfi;,ICliO'~;gR:Y¡HIS:MI:Jt:TI~'FONË·SECjjÃI:r-fiDqëifJM'EWr:""~~:1;~~';1(1I:;:ClÍfËej(:BÄçKGR'Ol!J~DI'ÄREÄ"CflÄNGES:'COl(jR'GRÄDUÄCLY.::~ROM'TO.P::TO!'BO:r:'EOI\if~;::¡¡ :·/r~j~·~;:~~~:;·.'.:'I:,'~.;1~::-':',~¡tl:;:~!."~~\/~~·~~~.~~~:~~.:~I~:';,~:;~;~~~~" I .:~'\~:" I .i""~'''''. ,....:..~.~.~.~. ~ .~.. :~':. \',- "..'t'··...~·..~~~· C;<'~,·¡~.~ '. (~:.....~':.. ~.4~~ ~",~,:",,;~:.: "f/"""':~, ,:~. 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P r.:"'~ ",,.. ..llb, ,....~ :,' ,fill; ,,1111.; ":1 'If. ~~¡' I ' ," ~ ~; . , ~. $ ~~; ~:. ~ ~~.~ ~.: t r~' ~ , .:-'" I. ;,..f /.::"r. r.. ;; ( .t 'fl'l. ....:':~.. ~ ~ : ~ ~ \: ," " ~., "~': "." .s' ! ' tI'.:A C '11111' ..:.". 1t,...' =il"";. 'Hr.,· '1"11,' I'U" ....... .. ',.', " ~ :~~~ ":":;:~:::st~::~:f~~1J:~~:::;;,!:!t~~~;f~~",':¡";~(~:~~~~:~.. .;.,,,,,;. . . ~.~·ER 333 WEST 7TH AVENU,E, 8UITE.1.00 . . ANCHORA(3E, AK 99501-3539 " ) < . .. , II· 0 5 b 0 3 2 II· I: 0 3 ¡. ¡. 0 0 2 0 c:¡ I: 3 a b a 8 .. ... 5"- 'i;%¡::)j1%!¡ì1iH"Ë::Õ:R¡Gj:f;fij[~DöplJM~Ñjf,:Íf.iÄS;7i¡iif.jliÊ:iEË~EømlME';iiÂ~Ë§fJlliiWij)1J¡fiE\)iiißi~~;~i.i¡j~~B,(jí£Ð\~~ïiiiÑ!:1A~,~ßE!i'itQj,:$~e'ë·)îiii~::.M~äK;wH~~i.içHeê~iijG:;mi;i~.\'ê:NPº:¡ijšeìij:ÊÑm$~'ì¡Wi;(iii~~¡:0:q';i)K~ #10 Alaska Wells Group 9 Day Rolling Schedule Last Revised: 10/11/2004 05:40:34 Unit #5 WSU 1.75" Unit #9 WSU 2.375" Klnd #1 E -Line Northstar /Badami Slickline Pumping ASRC Test Separator Mon, 10/11 09 -18 !PROF 12 -26 GLVs, 13 -04 Caliper 13 -18 SBG J -23 Q -05 Q -05 End1 -33 SCMT SIT's? E -102 SBHPS, 2 -19 do #4 vlv 02 -37 HOT MPU Well Tests Z -11 V -202 Fish Patch / P&A Extended Patch End1 -47 LDL END1 - 27 Set TTP, 11 - 06 Fish mill E -33 L &K (day 16 / 14) FCO with CTU Well Flowback (on well head) Tue, 10/12 E -23 PATCH 15 -41 GLVs, 13 -29 GLVs 18 -19 OA Down Sqz V -115 F -11 Q -05 11 -34 LDL SIT's? E -16 Drift, 4 -18 GLVs State Testing MPU Well Tests Z -11 V -202 PPROF Catch & Release liner 01 -14 SCMT P1 -03 Run SSSV Z -07 Thaw (day 17 / 14) FCO with CTU Well Flowback 1 -30 Pull TTP (on well head) Wed, 10/13 Z -24 ADPERF L5 -16 Caliper & SBHPS 12 -34 SBG 24 Hr Maintenance Z -11 Q -05 RD 01 -10 RST E -17 Drift, 12 -19 Drift K -11 CMIT Road to Z Pad V Pad Welltests Pipe Swap FCO w/ Test Sep 04 -14 LDL P2 -25 RSSSV 06 -04b L &K W Pad Welltests (V -119, V -115) L2 -06 Set DHSIT Z -12, Z -24, Z -39 Thu, 10/14 S -14 LDL NK -38 Drift, L -117 (PROF W -07 CMIT Z -100 V -114 Maint. 06 -02 RU Z -39 PPROF W -200 B &F, L5 -04 SBHPS W -12 CITOA W -201 Z Pad V Pad Welltests Adperf 24 hours 02 -16 GLVs, 7 -28 toggle plug L2 -26 L &K Welltest Welltests (V -119, V -115) Z -12, Z -24, Z -39 Fri, 10/15 Z -12 ADPERF 7 -36 CMIT, 15 -42 Drift W -20 Liquid Pack TBG Z -100 V -114 GNI -01 06 -02 J -23 CHEM CUT E -33 DGLVs, L1 -27 SSSV S -35 OA Dwn Sqz W -203 Z Pad V Pad Welltests Adperf FCO L5 -17 ADPERF L3 -31 Fish, NK -19 B &F END1 -27 CMIT Welltest Welltests (unit 8) Z -12, Z -24, Z -39 Sat, 10/16 S -213 Jet Cut W -203 B &F, W -205 B &F M -38 MIT Z -100 W -04 06 -02 06 -02 E -16 Perf 5' NK -12 B &F, L3 -31 Fish NK -19/61 BF W -04 V Pad Welltests Clay Acid Stim Extended patch END4 -38 PPROF L5 -17 Drift s -105 HOT Acid FB Welltests w/ Test Sep Z -12, Z -24, Z -39 Sun, 10/17 D -29 RST BORAX V -105 Set TTP &MIT 16 -23 HOT Z -100 Z -25 06 -02 06 -02 07 -35 PERF END2 -40 SBHPS D -11 OA Dwn Sqz W -04 V Pad Welltests FCO (pre -pert) Extended patch F -12 Pull TTP &Drift 2 -33 HOT Acid FB 15 -26 F -29 Pull TTP &Drift New Well FB Mon, 10/18 L -216 SBHPS (flowline not ready) PSI -8 02 -28 06 -02 RD L5 -04 SBHPS, PSI -08 SBHPS MEM (PROF P&A PSI -09 SBHPS 15 -26 S -117 B &F New Well FB Tue, 10/19 P5I -10 SBHPS PSI -9 15 -09 Sand Back 11 -27 V -01 SBHPS, W -201 B &F MEM (PROF Cement Cap W -211 B &F (no AFE) Z -25 SSSV 04 -01 Nordic 1 C -25B 659 -4433 Nabors 2ES on E -20A 659 -4103 Sand Plug w/ 11 -27 Moving to F-11B 10/12/2004 Moving to J -23A 10/15/2004 Cement Cap Tubing patch Nordic 2 Kuparuk 659 -4393 Nabors 7ES Z -210 659 -4835 Moving to 15 -42 10/22/2004 Moving to Z -13A 10/22/2004 Nabors 9ES on V -106A 659 -4831 Nabors 4ES 07 -22 659 -4608 L2 -11 Moving to L -02A 11/3/2004 Moving to 07 -09 10/15/2004 Mem CNL Doyon 16 S -119 659 -4168 (69) Moving to S -213A 10/19/2004 -F-6\e_ pa/A 4-/-1( 2 • Well Integrity History Well H - 11 10/5/2004 Type: P WI Status: Trouble Problem: Status: Planned Action: Surface Caing leak, broached to > 10/16/02: DSO bled OA from 1060 to 540 psi, Obj: Secure well, Eval for Surface surface during 9/26/04 arctic pack OA has arctic pack. Casing leak waiver flush. > 01/07/04: High IAP noted in DS reads 1. SL: Set TTP Caliper recorded tbg in good T =IA =2300 psi 2. VECO: Install cellar liner condition 2/1/04 > 01/09/04: TIFL Failed on overnight BUR, T =IA 3. FB: MITIA to 3000 psi CHROME tubing! > 01/10/04: Classified problem well (PWE) 4. DHD: MITOA w/ N2, locate TIW rep confirmed packer was tested > 01/16/04: SL DGLVs, ran OGLV in top station. surface casing leak point to 3500 psi w/ the rig. > 01/18/04: TIFL FAILED - Fluid to surface. 5. WIE: Eval for SC Waiver > 02/01/04: TTP set @ 8398', Caliper all jts <10% > 02/21/04: CMIT -TxIA passed to 3000 psi, LLR TxIA 4.8 bpm @ 650 psi > 02/24/04: LDL found leak in GLM #1 > 05/16/04: SL ran DGLV's, MIT -T Passed to 2500 psi, pulled TTP > 09/26/04: MITOA Failed, OA Broached to surface while doing Arctic Pac flush. Left phone message with Winton and talked with Jeff Jones. Date Comment 9/28/2004 T /I /0= 2350/1070/20. Temp =Sl. Monitor & Cellar. (Post arctic pack flush). TP increased 50 psi overnight. IAP increased 510 psi overnight. OAP increased 20 psi overnight. Cellar is dry, no fluids comming from flutes. 9/27/2004 T /I /O= 2300/560/10. Temp= SI. Monitor WHPs & Cellar (post Artic Pack Flush). IAP increased 280 psi. Liquid 6" below the top of Conductor flutes, no bubbles in fluid & no noise indicating of a leak. 9/26/2004 TIO= 360/1100/980 Circ 4.6 bbls 90 *f Diesel into OA for Arctic Pack Flush (Well Flowing on Arrival) OA Broached to Surface - - -DHD Crew Made Appropriate Calls -- -Final WHP's= 360/1100/0 9/26/2004 TIO= 360/1100/980, temp =150. TIFL PASSED / OA arctic pack flush (Fluid Broached / Conductor flutes); initial OA FL at surface (arctic pack). Bled OA from 980 psi to 0+ psi in 40 minutes (1.5 bbls of arctic pack). LRS pressured OA to 2000 psi (2.6 bbls); monitored for 15 minutes and OA lost 40 psi, bled to 0+ psi (diesel & small amount of arctic pack). Re- pressured to 2000 psi and fluid broached to surface through conductor flutes (approximately 5 gallons in cellar), bled to 0 psi, continued to bubble slightly from conductor flutes. SI well and the bubbling stopped. Monitored during TIFL and the fluid in the conductor dropped to 8" from top. OAP increased to 20 psi in 3 hours. Total returns of approximately 2 bbls of arctic pack from OA. TIFL PASSED; bled IA from 1100 psi to 280 psi in 2 hours. IA FL started at 6320' (between St. #3 & #4) and rose to 5850' at 1 hour, dropped to 6170' at 2 hours. SI bleed and monitored for 1 hour and the IAP increased 10 psi and the IA FL dropped to 6370'. Gas lift line is connected and has 20 psi on it. Final W H P's= 360/280/20. 9/23/2004 T /I /0= 400/1190/1020, temp =152. Monitor WHP's (post FO OA bleed). OA FL at surface (arctic pack). 9/22/2004 T /I /0= 400/1200/1020. Temp =155. Monitor WHP's, (post FO OAP bleed). • 5/17/2004 * ** JOB CONTINUED FROM 5 -16 -04 * ** (Pull TTP, sbhps) RAN 4 1/2" EQ. PRONG TO 8402' SLM. GOOD MARKS ON EQ. PRONG. RAN 4 1/2" GS. PULLED XXN PLUG @ 8397' SLM. RIH W/ TANDEM PETRADAT GUAGE. (LOCATE EOT @ 8,416' SLM, TD @ 9,257' SLM, CORR. TO KB +24'= 9, 281' ) PERFORMED STOP'S AS PER PROGRAM. ( SEE SBHPS DATA PAGE. ) ** *LEFT WELL SHUT -IN * ** 5/16/2004 * ** CONTINUED FROM 5 -15 -04 * ** (SET STA #3 /MIT -T) PULLED & SET STA #4 W/ 1.5" DGLV & RK LATCH. PULLED 1.5" DGLV W/ RK LATCH FROM STA #3. SET 1.5" DGLV W/ EXTENDED PACKING IN STA #3. MIT -T TO 2500 #. PASSED RIH W/ 4 1/2" EQ. PRONG TO XN PLUG @ 8405' SLM. INCONCLUSSIVE MARK'S EQ. PRONG. NO PRESSURE CHANGE. * ** JOB CONTINUED ON 5 -17 -04 * ** 5/15/2004 * ** WELL SHUT -IN ON ARRIVAL * ** (P /S STA #3, MIT) RIG UP ON H -11 10/5/2004 Page 1 of 3 • • Date Comment * ** JOB CONTINUED ON 5 -16 -04 * ** 5/12/2004 ** *CONT. FROM 5 -11 -04 WSR * ** (DUMMY STA. 1 & 5, MIT -T) SET 1.5" RK POCKET PACKER AT 8223' SLM STA. 1 RUN 4 1/2 BLB, DOUBLE KNUCKLE, 2.24 GAGE RING MIT -T TO 3000# - FAIL, T x IA HAS RAPID COMMUNICATION. CMIT T x IA TO 1000# - PASS PULLED/ RE -RUN 1.5" RK POCKET PACKER AT STA. 5 MIT -T -T TO 1000# - FAIL RUN 4 1/2 D &D HOLEFINDER TO 8125' SLM, 7875' SLM, 7240' SLM, (7177' SLM, HELD PRESSURE) ** *RIG DOWN FOR NIGHT, UNIT 137 WILL TAKE OVER TOMMORROW * ** 5/11/2004 * ** CONTINUE FROM 05/10/04 * ** ( DUMMY STA. 1& 5, MIT -T) RUN 1.75 LIB, NO PICTURE. RUN 1.70 LIB, NO PICTURE PULLED 1.5" RK DGLV FROM 8223' SLM STA. 1 3 ATTEMPTS TO PULL RK OGLV @ STA.5, RUN 2.7 LIB SHOWS EMPTY POCKET RUN MANDREL RATTLE THRU ALL STATIONS. ATTEMPT 1 1/2" POCKET PACKER (DGVL) WITH RK LATCH. (RUNNING FISHING NECK ON RK IS .935 ** *CONTINUE TO 05/12/04. * ** 5/10/2004 ** *FOUND WELL SHUT IN ON ARRIVAL ** *(DUMMY OFF STA. 1 & 5, MIT -T) SET 4 1/2 WHIDDON CATCHER SUB AT 8405' SLM. * ** CONTINUE TO 5/11/04 * ** 2/24/2004 PERFORMED LEAK DETECT LOG. LEAK DETECTED AT 8245', IN THE PUP JT. CONNECTION AT THE BOTTOM OF GLM #1. BASELINE PASS LOGGED FROM SURFACE TO TTP @ 120 FPM. TTP TAGGED AT 8421'. PUMP CRUDE OIL DOWN TUBING @ 1 BPM / 250 PSI WITH RETURN FROM IA TO FLOWLINE FOR FURTHER LOGGING. LOGGED ANOMALY PASS FROM TTP TO SURFACE © 120 FPM. SOME FLUID IS COMING BACK FROM IA INTO TUBING THROUGH ORIFICE IN GLM #5. FLOWLINE FREEZE PROTECTED WITH MEOH. WELL TURN OVER TO PAD OPERATOR. * * ** *WELL LEFT SHUT- IN * * * ** 2/24/2004 T /I /0= 250/400/250 Assist E- line, 115 bbls crude, 2 bbls meth down tubing. FWP= 250/300/100 2/20/2004 T /I /0= 400/375/100 Load and CMIT TBG X IA and LLRT TBG X IA. Loaded tbg and is w/477 bbls crude. LLRT from TBG to IA was © 650 PSI =4.8 bpm. CMIT PASSED on 1st test. TBG /IA Pressure losses were 15 min =60 psi /70 psi, 30 min.= 20 psi /20 psi. Pumped 5 bbls neat to freeze protect flowline. Final W HP= 200/250/100 2/3/2004 T /I /O= 450/420/130. (Post WHP's bleed, Secure). No increase in pressure overnight. 2/2/2004 T /I /O= 1450/1450/150. Temp= SI. (Well secure, post TTP). Flowline freeze protected. Thawed out frozen jewelery on IA. TBG FL @ 6700', IA FL @ 6400'. Rigged up to bleed IAP down H -32's flowline (LP). Swab appears to be frozen on H -32. Opened wing on H -11 to choke. Bled TBG pressure down from 1450 psi to 350 psi. IAP tracked TBG slowly during bleed down. IAP decreased from 1450 psi to 420 psi. Monitored WHP's for 1 hr. Final WHP's = 450/420/130. 2/1/2004 ** CONTINUED FROM 1 -31 -04 WSR ** CALIPERED TUBING FROM 8458' SLM, GOOD DATA, XN NIP LOOKED GOOD. SET 4 1/2" XXN PLUG @ 8398' SLM ( MAX TUBING PSI 2000 PSI) BLEED TBG TO 1500 PSI GOOD TEST ON PLUG. ** LEAVE WELL SHUT -IN ** 1/31/2004 ** *WELL FLOWING ON ARRIVAL * ** LOC TT @ 8406' SLM + 25' + 8431' CORRECTED. CALIPER TUBING FROM 8458' SLM UP. ** CONTINUED ONTO 2 -01 -04 WSR ** 1/19/2004 TIO= 340/580/440. 155° Monitor WHPs (Post TIFL). Over night IAP decreased 370 psi. Well is flowing with out A/L. 1/18/2004 T /I /0= 320/620/420. Temp =hot. TIFL FAILED, FTS (Post GLV C /O). Well flowing upon arrival, shut well in to stack out TBG. A/L casing valve SI with 600 psi on A/L line. Initial TBG FL could not get readable fluid level. Initial IA FL @ 6299' or 336 bbls (between sta 4 & 3). When stacking out TBG, IAP started tracking. In 30 min. TBG pressure went from 320 psi to 1130 psi and IAP went from 620 psi to 840 psi. In 2nd 30 min TBG went from 1130 psi to 1420 psi and IAP went from 840 psi to 980 psi. Let well stack out for 4 hours. TBG pressure stack out to 2060 psi and IAP is now @ 1440 psi. TBG FL @ 8412' and IA FL rose to 5833'. Start TIFL. Bled IAP from 1440 psi to 950 psi in 1.5 hrs. IA FL rose to surface during bleed. Final whp's = 1880/950/420. * * ** *DSO will bring well back on line * * * * ** 1/16/2004 ** *WELL SHUT IN UPON ARRIVAL * ** SET 4 -1/2" WHIDDON C -SUB @ 8410' SLM. PULLED OGLV FROM STA# 1© 8224' SLM, ,PULLED LGLV FROM STA# 3 @ 7206' SLM, PULLED LGLV FROM STA# 4 @ 5054' SLM, PULLED LGLV FROM STA# 5 @ 2974' SLM, SET OGLV /RK (DUAL CHECK 5/16 ") @ STA# 5 © 2974' SLM,SET DGLV /RK @ STA# 4 @5054' SLM. SET DGLV /RK © STA # 3 @ 7206' SLM, SET DGLV /RK @ STA # 1@ 8224' SLM, 10/5/2004 Page 2 of 3 • • Date Comment PULLED M/T WHIDDON C -SUB * ** WELL LEFT SHUT IN AS PER DSO * * ** 1/10/2004 TIO= 1480/1480/190. Monitor WHPs Post TIFL Failed. (Eval High IAP). Over night TBG pressure decreased 430 psi, IAP increased 720 psi. 1/9/2004 TIO= 2320/2300/100 (SI). TIFL Inconclusive (Eval High IAP). Initial IA FL @ bottom sta 8243' (445 bbls). A/L casing valve was open & A/L lateral valve is closed. Closed A/L casing valve and bled spool down to 0 psi, monitor during TIFL. Start bleeding IAP to H -32 flow line from 2300 psi to 680 psi in 3 hrs. IA FL remained unchanged. TBG pressure decreased 300 psi, monitor for 1 hr. In 1 hr TBG pressure decreased 90 psi and IAP increased 80 psi. Final WHPs= 1910/760/190. 12/17/2003 TIO= 300/1180/560. 145° OA FL (OA Survey). OA FL near surface. Bled small amount of arctic pac from jewelry. 11/13/2003 T /I /0= 280/1020/480. (Post OA Bleed) OAP increased 20 psi since previous day. 11/12/2003 T /I /0= 280/1010/460. (Post OA Bleed) 11/10/2003 T /I /0= 260/950/460. Temp =150 *. Monitor WHP's. Post OA teed. (Possible IA x OA). OAP increased 190 psi overnight. OA has Arctic Pac in jewelry. Well has A/L. 11/9/2003 T /I /0= 260/1080/900. Bleed OA (High OAP). Temp 140. OA FL near surface. Bled OA from 900 psi to 260 psi in 35 mins. OA FL rose to surface. Monitored OAP for 30 mins. OAP increased 10 psi. Final WHP's 260/1080/270. 8/12/2003 T /I /0= 300/1020/780. (Operator call in) Temp 150. IA FL @ 8285'. 6/6/2003 TIO= 320/850/740. Temp= 158. IA FL @ 8243' (Sta. # 1). No Gaslift Rate. (For GLR). 12/12/2002 T /I /O = 290/1140/560 Temp = 160 OA FL @ surface (arctic pack). (500+ psi OA FL list) 11/26/2002 TIO= 340/950/700 Temp= 140. IA FL @ 8236' (Sta. #1). (For GLE). Well is not on gas lift. 4/11/2002 TWO = 300/580/400, DSO called in high OA. Bled OA to 400psi from 1120psi. Took approx. 5 min., all arctic pack. 5/9/2001 T /I /O = 300/1200/1000; OA FL @ Surface (Artic Pac), (OA shoe competency survey) 2/27/2000 T /I /0= 360/ 1300/ 1300, Temp= 0. JEWELRY FREE 7/20/1998 T /I /0= 250/ 1470/ 500, Temp= 127. BLED DOWN O.A. FROM 1250 P.S.I. 6/17/1998 T /I /0= 320/ 1650/ 800, Temp= 132. BLED OA FROM 1400. 5/11/1998 T /I /0= 300/ 1675/ 1000, Temp= 136. F/L ON IA ( GLR =3.5MM ) 5/11/1998 T /I /0= 300/ 1675/ 1000, Temp= 136. G/L RATE @ 3.5 MM S/O @ 8,242' 4/21/1997 T /I /0= 300/ 1650/ 500, Temp= 0. GR @ 3.4 1/26/1997 T /I /0= 260/ 1550/ 380, Temp= 141. GLR @2.0 10/27/1996 T /I /0= 290/ 1600/ 220, Temp= 138. GLR @ 2.1 10/23/1996 T /I /0= 290/ 1610/ 240, Temp= 142. No data in original FMPro File 10/10/1996 T /I /0= 290/ 1575/ 20, Temp= 144. MONITOR 10/9/1996 T /I /0= 300/ 1600/ 0, Temp= 143. BLED OA DOWN FROM 1460 PSI. 7/23/1996 T /I /0= 1940/ 2110/ 150, Temp= 0. 1 /4LY F/L - G/L R. 2.0 4/26/1996 T /I /0= 360/ 1625/ 780, Temp= 144. G/L RATE= 1.6 1/26/1996 T /I /0= 410/ 1700/ 300, Temp= 110. GLR = 2.0 mmcf 1/14/1996 T /I /0= 360/ 1625/ 660, Temp= 148. No data in original FMPro File 1/13/1996 T /I /0= 1020/ 1800/ 250, Temp= 0. L/G @ 1.6, WELL WAS BACK FLOWED & W/H WAS COMING DOWN. 12/24/1995 T /I /0= 380/ 1600/ 640, Temp= 136. GLR = 2.0 mmcf 12/17/1995 T /I /0= 300/ 1750/ 440, Temp= 0. GL RATE 2.0 7/22/1995 T /I /0= 350/ 1640/ 460, Temp= 149. QUARTERLY 5/3/1995 T /I /0= 290/ 1650/ 140, Temp= 0. GL RATE 2.3 4/17/1995 T /I /0= 460/ 1510/ 1490, Temp= 138. BLEED 0/A TO 440PSI. 1/29/1995 T /I /0= 380/ 1540/ 1040, Temp= 141. No data in original FMPro File 10/5/2004 Page 3 of 3 • • Page 1 of 1 WELL SERVICE REPORT WELL JOB SCOPE UNIT H -11 ANN -COMM (AC -EVAL AND REPAIR) UNKNOWN DATE DAILY WORK DAY SUPV 9/26/2004 AC- BLEED; AC -MITOA ANDERS COST CODE PLUS KEY PERSON NIGHT SUPV PBHPDWL11 -M VEC- JOHNSON UNKNOWN MIN ID DEPTH TTL SIZE 0" OFT 0" DAILY SUMMARY TI0= 360/1100/980, temp =150. TIFL PASSED / OA arctic pack flush (Fluid Broached / Conductor flutes); initial OA FL at surface (arctic pack). Bled OA from 980 psi to 0+ psi in 40 minutes (1.5 bbls of arctic pack). LRS pressured OA to 2000 psi (2.6 bbls); monitored for 15 minutes and OA lost 40 psi, bled to 0+ psi (diesel & small amount of arctic pack). Re- pressured to 2000 psi and fluid broached to surface through conductor flutes (approximately 5 gallons in cellar), bled to 0 psi, continued to bubble slightly from conductor flutes. SI well and the bubbling stopped. Monitored during TIFL and the fluid in the conductor dropped to 8" from top. OAP increased to 20 psi in 3 hours. Total returns of approximately 2 bbls of arctic pack from OA. TIFL PASSED; bled IA from 1100 psi to 280 psi in 2 hours. IA FL started at 6320' (between St. #3 & #4) and rose to 5850' at 1 hour, dropped to 6170' at 2 hours. SI bleed and monitored for 1 hour and the IAP increased 10 psi and the IA FL dropped to 6370'. Gas lift line is connected and has 20 psi on it. Final WHP's= 360/280/20. JOB COSTS SERVICE COMPANY - SERVICE DAILY COST CUMUL TOTAL VECO $1,020 $1,920 SCHLUMBERGER $0 $960 BP $0 $5 WAREHOUSE $0 $25 CONAM $0 $380 LITTLE RED $0 $5,598 TOTAL FIELD ESTIMATE: $1,020 $8,888 file: / /C:\ Program %20Files\AWGRS\Reports\Report.htm 10/5/2004 • • Page 1 of 1 WELL SERVICE REPORT WELL JOB SCOPE UNIT H -11 ANN -COMM (AC -EVAL AND REPAIR) LRS 62 DATE DAILY WORK DAY SUPV 9/26/2004 FLUID SWAP ANDERS COST CODE PLUS KEY PERSON NIGHT SUPV PBHPDWL11 -M LRS -WIGHT UNKNOWN MIN ID DEPTH TTL SIZE 0" OFT 0" DAILY SUMMARY TI0= 360/1100/980 Circ 4.6 bbls 90*f Diesel into OA for Arctic Pack Flush (Well Flowing on Arrival) OA Broached to Surface- - -DHD Crew Made Appropriate Calls -- -Final WHP's= 360/1100/0 LOG ENTRIES Init -> 360 1100 980 TIME BPM BBLs FLUID TEMP TBG IA OA COMMENTS 06:30 Head for COTU to Load Diesel 07:20 Diesel Loaded/ Head for SPOC 07:50 Open Permit @ SPOC 08:20 Arr Loc/ MIRU/ PJSM/ Pre -Burn Coil PT/ PT Surface Lines 09:01 Bleed all Pressure Off OA to Tank -- Approx 1.5 bbls Arctic Pack Returns 09:36 0 Start Diesel 90*f 360 1100 0 Open to ON Start Diesel 09:42 Bump 2.6 2000 Shut Down/ Let Soak 10:07 2.9 0 Bled Off -- Diesel Returns - -- Flush Line to Tank 10:16 Bump 4.6 2000 Shut Down/ Let Soak 10:38 0 Fluid Broached to Surface through Conductor-- - DHD Making Calls - -OA is Bled Down -- Stand -by 11:07 5 Flush Line to Tank/ RDMO 11:25 Leave Loc 12:00 End Ticket Final -> JOB COSTS SERVICE COMPANY - SERVICE DAILY COST CUMUL TOTAL LITTLE RED $1,348 .. $5,598 WAREHOUSE $25 $25 SCHLUMBERGER $0 $960 BP $0 $5 CONAM $0 $380 VECO $0 $1,920 TOTAL FIELD ESTIMATE: $1,373 $8,888 FLUID SUMMARY 5 bbls Diesel file: / /C:\ Program %20Files\AWGRS\Reports\Report.htm 10/5/2004 1 Notes Well History of Handover 9/29/2004 H -11 We F /P • 9/26/2004 H -11 DHD out wit LRS to pu m p, flush and bleed OA. OA breached to conduc Well S / I, DHD bled IA to LP pressure, ACS out to clean up Diesel in Cellar, flowline to be freeze p rotected, PE group to evaluate the next step. 9/23/200 H -11 H -11, 0/A has arctic pack it. Bled down from 980 to 0 psi. 9/19/2004 H -11 H -11 S/I to test H -32 @ 09:00 (Lindmple) 9/17/2004 H -11 Bled OA to 400 psig from 1750 psig, mostly gas and to in a took sa d turned Arctic pack in the end. - -- ''.-,:,.:..c r .`�c�' 17 � t � ' .a ^ `` -- a� a� . � � . ' r -- q ^b 1--;.' - -^ ' �` M { - , ..ss, '$- a�s ,... -, .. .„.. . '. ' n - � ' �-` - =.a `,` � '" - ms - - - s # Thursday, October 07, 2004 Page 1 o 1 . WOA Operator's Handover Report Date Order RUN: 4 Day: Wortham, Bob Night: 10[7/2004 Pad: H Bleeds PAD D H -P Did HSE Walk throughs. PAD D H -!! S/I working on well to set TTP. PAD D H -29, Y -14 passed State test today. PAD D H -29,02 Hyd panels leaks repaired. 10/6/2004 Pad: H Bleeds PAD D Skid 54, F &G completed halon N2 hose upgrades. PAD D Skid 54, filled SOT transfer pump oil lubricator drip system with H -68. Pad: H Bleeds PAD N H -P Did HSE Walk throughs and reads. 10/5/2004 Pad: H Bleeds 13 D POP, won't flow, needs a GLT. jumper. 29 D OE wanted the well POP. Also needs a GLT. jumper. PAD D PCC can't move H -13/27 piggy back valve. W/R # 29619. PAD D UWP, F &G doing upgrade work to the N2 portion of the Halon system. PAD D Pump down SOT. Pad: H Bleeds PAD N H -P Did HSE Walk throughs and reads. PAD N H -29 POP with GLT, and in HP. PAD N H -Pad UWP to add Meho to tank 10,000 gals. 10/4/2004 Pad: H Bleeds 02 D S /I, put on the F/P board. 21 D S/O GLT. slot, PO /BP, Rousties pulled blind, installed check valve. GLT. slot has been P/T'd. 34 D Down hole truck tried to F/P tubing, they locked up, either froze, or has a plug down hole. PAD D LDF, Insulation crew insulating pipe. PAD D HWP, Canspec, U/T pipe in well houses. Pad: H Bleeds PAD N H -P Did HSE Walk throughs and reads. PAD N H -23 S/I H /GOR will put on F/P board. 10/3/2004 Pad: H Bleeds 23 D Checked the 0/A psi @ 800 psi. 29 D Spill team cleaned up hydraulic spill. 34 D Put on the F/P board. Thursday, October 07, 2004 Page 1 of 15 • s WOA Operator's Handover Report Date Order RUN: 4 Day: Mills, Ted Night: 37 D S/O GLT. slot, John Hall replaced outlet block valve. C -spool has been P/T'd. PAD D Chemical delivery. Pad: H Bleeds PAD N H -P Did Hse Walk throughs and reads. PAD N H -14 SI HGOR, put on F/P board. 10/2/2004 Pad: H Bleeds PAD D ESD test has been cancelled till 10/11/04. PAD D HWP, Canspec, U/T W/H chokes. Pad: H Bleeds PAD N H -P Did HSE Wailk throughs and reads. PAD N H -29,02 WRW 29504 to repair HYD solenoid Leaking. H -29 Has a Spill form the HYD leaking out of well house only about a quart, I called 5700. Heater in well house. PAD N H -14,23 POP per PCC needed GAS, H -23 is waivered need to check it today, till it gets normal. PAD N H -23 Bled OA from 2000psi to 300psi at 04:00. Check it today. 10/1/2004 Pad: H Bleeds 16 D Switched P -pilot to HP. PAD D H -37, valve was delivered for the GLT. slot. PAD D To GC -2, UWP, Canspec, U/T pipe. Pad: H Bleeds PAD N H -P Did HSE and walk throughs and reads. 9/30/2004 Pad: H Bleeds PAD D UN's BIS. PAD D H -20, 27, S /I. Pad: H Bleeds 20 N S/I ' 0130 hrs, chem S /I. 27 N S/I @ 0130 hrs, chem S /I. PAD N Possible ESD testing tomorrow. PAD N H -P Did HSE Walk throughs H -PAD reads. PAD N H- 25,20,26,16,27,07 POP. 9/29/2004 Pad: H Bleeds PAD D H- 07,16,20,25,26 &27 S/I for GC -1 ESD, chemical S /I. PAD D UWP, Canspec out to X -Ray GL transit line to GC -2. PAD D Reset T /S. Pad: H Bleeds Thursday, October 07, 2004 Page 2 of 15 WOA Operator's Handover Report Date Order RUN: 4 Day: Night: Mills, Ted 11 N Well F /P. 13 N Well F /P. 20 N POP. 27 N POP. PAD N Reads / walk throughs. PAD N UN's B /P. 9/28/2004 Pad: H Bleeds 13 D UWP, Schlumberger S/L out to pull plug. Ric Williams ran new tubing to SSV. 37 D Attempted to PT GL line, Trunion seal started leaking again. John Hall came out and checked the valve out and needs to find the right rebuild kit, if no kit can be found he would like to replace the valve. PAD D Walked through freeze protection and the Methanol pump with Joe Paolino. Pad: H Bleeds 13 N S/L completed pulling TTP. PAD N Reads / walk throughs. 9/27/2004 Pad: H Bleeds 35 D S/I @ 0915 hrs for stand alone test on H -33. Chemical is S/I and W/H choke is at minimum. 37 D Safed out GL line for the RSTB's to reconnect. GL block valve in skid 59 started leaking externally when pressure tested. Valve serviced and seems to be holding. PAD D Caspec out to UT Piping between the Pad and GC -2. Pad: H Bleeds 35 N POP. PAD N Reads / walk throughs. 9/26/2004 Pad: H Bleeds 11 D DHD out with LRS to pump, flush and bleed OA. OA breached to conductor, Well S /I, DHD bled IA to LP pressure, ACS out to clean up Diesel in Cellar, flowline to be freeze protected, PE group to evaluate the next step. 13 D Grease crew back out to install Tree platform. Hydraulic line still needs to be installed. 18 D OE requests well to be brought on, time permitting. IA fluid packed. 36 D S/I @ 1245 hrs for stand alone test on H -05. Chemical is off and W/H choke is at minimum. 37 D PCC requested Well to be brought on, OE notified WSG that the GL line needs to be hooked back up. New gas lift design. Pad: H Bleeds 36 N POP. PAD N Reads / walk throughs. 9/25/2004 Pad: H Bleeds Thursday, October 07, 2004 Page 3 of 15 WOA Operator's Handover Report Date Order RUN: 4 Day: Paulsberg, Steve Night: PAD D H -13, POBP, Grease crew out to replace SSV. Work completed and the pump truck will be out to PT the Tree and the Wing valve flange. All bleeds are closed and the Tags have not been PAD D Pump truck freeze protected the flowline. Pad: H Bleeds 13 N Pull tags, tree platform needs to be installed, SSV actuator needs the hyd. Hooked up. PAD N Reads / walk throughs. 9/24/2004 Pad: H Bleeds PAD D H -11, WSG staged a snorkel tank and R/U OA Integral flange and hardline. PAD D Veco crew out to re- insulate lines at the road crossing. PAD D H -13, Job postponed until tomorrow morning due to Y &P -Pad S /D's. Pad: H Bleeds PAD N Skid 52, Swap N2, need to have one ordered. PAD N Reads / walk thoughs. 9/23/2004 Pad: H Bleeds PAD D H-11, DHD out to monitor Well. DHD put the OA on the list to flush and bleed. PAD D H -13, Grease crew serviced choke ISO. Bled flowline down. Well will need safed out tonight, the G rease crew will replace the SSV in the morning, Tags and M/C on Dash of truck. PAD D UV's BIS. Pad: H Bleeds 11 N H -11, 0/A has arctic pack in it. Bled down from 980 to 0 psi. 13 N H -13, S/0 for SSV repairs. PAD N Reads / walk throughs. 9/22/2004 Pad: H Bleeds 13 D H -13: Bled down F/L in preparation for Safe out. PAD D H & Y pads. Chemical crew filling chemical tanks. SK54 D HWP H -54 skid: Rick repairing equipment. Pad: H Bleeds PAD N UWP, Canspec out to X -Ray Piping. 9/21/2004 Pad: H Bleeds 13 D H -13: Schlumberger completed setting plug. Switched to LP. P -pilot in LP. Pad: H Bleeds PAD N UV's B/P for X -Ray. UWP, Canspec out to X -Ray Piping. PAD N Chem Operator out to fill the corrosion inhibitor Tank. 9/20/2004 Pad: H Bleeds Thursday, October 07, 2004 Page 4 of 15 WOA Operator's Handover Report Date Order RUN: 4 Day: West, Lee Night: 13 D H -13: UWP - Scaffolding crew modifying scaffold for Wire Liners. PAD D H -pad U.V.'s B. I. S. Pad: H Bleeds PAD N UV's B/P for X -Ray. PAD N UWP, Canspec out to X -Ray Piping. PAD N H -13, UWP, Schlumberger S/L out to set a Plug in the SSSV nipple. 9/19/2004 Pad: H Bleeds 11 D H -11 S/I to test H -32 @ 09:00 (Linda took sample) 18 D H -18: Process Opening & Blndg. Roustabouts connecting Poor boy from H24 to H -18 21 D H -21: DHD doing TIFL 21 D H -21: DHD doing Now flow test. Found Bkr tripped on Hyd panel. Re -set & opened for DHD 32 D Linda (Chem. Crew) getting sample. Pad: H Bleeds PAD N H -07 to 47 HDR Divert is showing travel when it's open, WRW to have limit switch repaired. PAD N H -11 POP @ 1750 hrs and had to manually open choke. PAD N UV's B/P for X -Ray. PAD N UWP, Canspec out to X -Ray Flowlines. 9/18/2004 Pad: H Bleeds 13 D H -13: Scaffolding crew erecting scaffold for SSV repairs. 16 D H -16: HWP Rick Williams completing reconnect for the new Well Choke. Pad: H Bleeds PAD N H -05, UWP, Schlumberger S/I Well and will Drift and Tag for an upcoming Add Perf job. 9/17/2004 Pad: H Bleeds SK59 D Skid H -59: Eric (Chemical crew) cleaned up the Corrosion Inhibiter on and around the flow control boxes. Pad: H Bleeds 11 N Bled OA to 400 psig from 1750 psig, mostly gas and turned to Arctic pack in the end. 9/16/2004 Pad: H Bleeds 02 D H -02 P.O.P. Waivered well. Troy monitoring. 13 D H -13: Grease crew tested Master and Wing valve. Both O.K. 13 D H -13: Little Red rigged up to kill well. 21 D H -21 Process open. & Blndg. Rousts. Install blind on GLT at well. Safeout tagout. Pad: H Bleeds PAD N H -16, Pilot and Well dropped to LP to try and unload again. Thursday, October 07, 2004 Page 5 of 15 • WOA Operator's Handover Report Date Order RUN: 4 Day: Night: Paulsberg, Steve PAD N H -13, LRS pumped 350 bbls of D/C down Tubing. Valve shop came out and attempted to set BPV, no luck. 9/15/2004 Pad: H Bleeds PAD D H -P Did HSE Walk trhroughs. Pad: H Bleeds 13 N H -13: PCC reading 80 deg. Strapped TT to Flowline in Skid 54. O.K. now. 16 N H -16 still only 70 Deg. SI GLT. Well died. Put to LP With GLT to see if it will come around. 9/14/2004 Pad: H Bleeds PAD D H -P Did HSE Walk throughs. PAD D H -34 DHC F/L F /P, also had him put some neat down the tubing may help it thaw. PAD D H -13 WRW 28669 to repair Top wire line doors need hinge welded. PAD D H -22 WRW 28670 Repair air filter pot leaking air GLT Valve skid 62. 9/13/2004 Pad: H Bleeds PAD D H -P Did HSE Walk throughs. PAD D H -13 WRW 28607 to repair SSV failed State Test. 9/12/2004 Pad: H Bleeds PAD D H -P Did HSE Walk throughs. PAD D H -16 well was dead, some one S/I the GLT, I open it up to warm up for State test. 9/11/2004 Pad: H Bleeds PAD D H -P Did HSE Walk throughs. PAD D H -09 POP on PW, keep eye on annulus PAD D H -34 Open up The GLT to well. PAD D H -Y PAD DHC F/P wells. 9/10/2004 Pad: H Bleeds PAD D H -P Did HSE Walk throughs. PAD D H -04,18 closed the B/P valves, also closed H -27 why it was open ?. PAD D H -16 Open the GLT at tree. PAD D H -29 S/J completed pulling TTP, off pad. PAD D H -pad I replaced the remainder of bad local Tls. Pad: H Bleeds 16 N H -16 Choke was still cut back. Advised PCC. (GLT Still on well was only about 80 deg. 17 N H -17 Heater on well to open SSV. (Check downhole press for freeze prot. Thursday, October 07, 2004 Page 6 of 15 WOA Operator's Handover Report Date Order RUN: 4 Day: Night: West, Lee PAD N H -54 skid. Check out SDV 9406b for PCC. Was showing travel. Valve was closed. Lined up 41 header to GC #1. PAD N H59 Opened TS for PCC 9/9/2004 Pad: H Bleeds 24 D H -24: Bled OA from 3100 to 400# 27 D H -27 UWP Schlumberger slick line pull TTP PAD D H- 27,20,26,24, 22,06,33,5136,16,13,18,11 /32,04 and 30 all POP today. Still S/I are the waviered wells H- 07,25,17,35,34 PAD D H -18,04 PCC are Back flowing B/P open, I back Flowed these well three times no good, I winged in H -04. PAD D H -Y PADS Ppilot heaters are on. PAD D Down Hole crew F/P some wells, till GC -1 wnt down. 9/8/2004 Pad: H Bleeds 18 D Pump truck F/P tubing. PAD D Skid 59, notified roustabouts that we need meoh for our GLT. drip system. PAD D Roads, and pads replaced the bad culvert. Pad: H Bleeds PAD N H -P Did HSE Walk throughs and reads on P -PAD. PAD N H -19 i S/I THE SWEEP Gas , looks like the GC -2 we will be coming up ?. 9/7/2004 Pad: H Bleeds 13 D To the 42 header, John T reconnected the electrical to the actuator. 13 D Divert to the 43 header, has to have the limit switch repaired. PCC sees the valve closed when it's open. W/R # 27184 PAD D LDF, Canspec U/T work. PAD D Skid 59, open up the OPPV's to GC-2. Open H -18, 19, ISDV's, we now have these flowing to Pad: H Bleeds PAD N H -18 Died Grease crew checking out looks like it's frozen at SSV ?. PAD N H -30 POP to replace H -18 going to GC -2. PAD N H -11/32 flowing to GC -1. 9/6/2004 Pad: H Bleeds 05 D Coupon crew removed service valve. PAD D Skid 54, P/T with H -11, H -4 was dead. P/T'd up to 1000 psi, H -13 to the 42, H -27 to the 47 header diverts was producing stem seal leaks, depressured H -54, replaced the diverts. PAD D UN's BIS. Pad: H Bleeds Thursday, October 07, 2004 Page 7 of 15 WOA Operator's Handover Report Date Order RUN: 4 Day: Night: Wortham, Bob PAD N H -PAD I pulled all the tags on the wells, we Opened all the masters, some seem to have ice in them will need to check them when they warm up, H- 25,18,13. PAD N H -PAD WRW 28268 to repair air leak on filter pot for HV0021 6" off of the 47 header. PAD N H -PAD All the 6" double plugs are open on the manual side. PAD N H -PAD All the valves have been put back to remote. PAD N H -PAD all pressuer test to 1000psi and inlets are closed except H- 11/32,18,19 which are flowing to GC -1. PAD N H -32 Have GLT going to this well only till it gets warm up, Have a lot of Meoh going to H -11 and into GLT line. PAD N H -29 S/L going to pull TTP some time today. PAD N H -PAD LDF to GC -1 Locked open. 9/5/2004 Pad: H Bleeds PAD D LDF Insulation crew cribing up pipe, Canspec, U/T work. PAD D UN's still B /P. PAD D Skid 52, Phill bled the air from the Hyd. Pumps. Pad: H Bleeds PAD N H -PAD UV still in B /P. 9/4/2004 Pad: H Bleeds PAD D UN's B /P. PAD D LDF, insulators cribbed up pipe. Pad: H Bleeds PAD N H -PAD UV Still B /P. PAD N H -PAD Walked all the wells checked for leaks none. 9/3/2004 Pad: H Bleeds 23 D DHD did a no flow on the I/A. PAD D UN's B/P for X -ray. PAD D LDF inspections out to look @ locations. PAD D LDF insulators stripping pipe. Pad: H Bleeds PAD N H -P Did HSE Walk throughs and P -PAD reads. PAD N H -Pad UV still B /P. 9/2/2004 Pad: H Bleeds 23 D DHD conducting a no flow on the 1/A. PAD D LDF at the road crossing, Insulation crew installing insulation. PAD D UWP, Insulation crew stripping the LDF. Line lift being conducted. Thursday, October 07, 2004 Page 8 of 15 WOA Operator's Handover Report Date Order RUN: 4 Day: Mills, Ted Night: PAD D LDF, Canspec U/T pipe. Pad: H Bleeds PAD N H -P Did HSE Wask Throughs and P -PAD reads. 9/1/2004 Pad: H Bleeds PAD N Walk throughs. 8/31/2004 Pad: H Bleeds 21 N S/L complete. PAD N Walk throughs. 8/30/2004 Pad: H Bleeds 21 D W/L Install dummy gas lift valves 29 D Connected up hyd. Lines SSV is closed PAD D GC 2 Rover removed lock and tag on warm valve going into the LDF PAD D Closed bypass around GLT SDV and closed the warm up loop valves Pad: H Bleeds 21 N S/L still on well. PAD N Walk throughs. 8/29/2004 Pad: H Bleeds 04 D Ric Williams reset pilot to 3000 psi PAD D Call for roustabouts to change out N2 bottle PAD D Closed bleeds and removed tags in 54 and 56 Modules GC also removed cross tags Pad: H Bleeds PAD N Walk throughs. 8/28/2004 Pad: H Bleeds 29 D Changed out W.H. still needs to be pressure tested and need to hang SD tags on WH PAD D Closed tree cap bleeds, removed tags and matched up tags Pad: H Bleeds 29 N Safed back in, tree still needs to be P/T'd. PAD N Walk throughs. 8/27/2004 Pad: H Bleeds 29 D Reschduled for tommorrow due to high wind gusts today PAD D GC 2 start up possiable tomorrow Pad: H Bleeds Thursday, October 07, 2004 Page 9 of 15 WOA Operator's Handover Report Date Order RUN: 4 Day: Night: Mills, Ted PAD N Reads / walk throughs. 8/26/2004 Pad: H Bleeds 04 D Finished up pulling blinds on FL 29 D Grease crew is going to replace tree in the AM need to verify safe out 29 D S /O, double tagged, used lock box, master card (in well house), for tree replacement. 37 D S/L complete, double block & bleed established at the tree. Pad: H Bleeds 29 N S/O tree, double tagged, used its own lock box, master card, which are in the well house. 37 N S/L complete. 8/25/2004 Pad: H Bleeds PAD D (Matonis) Supervising Process opening & blndg. H pad. PAD D H -pad PW block valve. Hung tags for GC#2 PW safeout. Backside of pit at Y & P PW line. Pad: H Bleeds PAD N UV's B/P for X -Ray. Work completed, UV's BIS. PAD N H -37, S/L work continues. PAD N UWP, Century Inspection out to X -Ray on the new flanges that were welded on H -04 flowline today. 8/24/2004 Pad: H Bleeds PAD D H -04: Open Process & Blinding. Veco remove blind behind sk54 and spread flange behind H -30 for line repairs. Pad: H Bleeds PAD N H -37, UWP, Schlumberger S/L back out to resume Gas Lift work. 8/23/2004 Pad: H Bleeds PAD D WR# 27629 to provide flowline support for H -pad flowlines. Pad: H Bleeds PAD N UWP, Canspec out to UT Y -804 line between H &Y -Pads. PAD N Grease crew out to work on TI & TT thermowells inside Sk -54. 8/22/2004 Pad: H Bleeds PAD D HWP H54 skid. Rick W calibrate chokes. PAD D Methanol delivered. PAD D H -32: UWP Schlumberger rigged up to do Static survey. PAD D H -37: Schlumberger rigged off. Pad: H Bleeds PAD N H -37, S/L completed work. Thursday, October 07, 2004 Page 10 of 15 WOA Operator's Handover Report Date Order RUN: 4 Day: Night: Paulsberg, Steve PAD N H -34, S/L moved on to Well to conduct a Static, Well added to Permit. PAD N Grease crew was out to work on Temp Probe removal. PAD N UWP, Canspec out to UT on Y -804 line between H &Y -Pads. 8/21/2004 Pad: H Bleeds PAD D HWP VECO Welding sleeves GLT line on the pipeline access. (Brian chalk) 07:00 (8094 -24) PAD D HWP VECO Welding sleeves GLT line on the pipeline access. (Brian Chalk) 08:00 (9 +83) PAD D HWP VECO Power tools, Poltable generator, Crane. (Brian Chalk) 11 :00 (106 +19) PAD D HWP VECO Welding sleeves GLT line on the pipeline access (Brian Chalk) 07:00 (H intesctn) PAD D H -59 skid: Rick W. calibrate the 3 new chokes. Pad: H Bleeds PAD N H -37, S/L work continues. 8/20/2004 Pad: H Bleeds PAD D HWP 24" GLT line Pipeline rd. PAD D HWP VECO: 24" GLT line pipeline rd. (66/14) Brian Chalk PAD D HWP VECO: 24" GLT line pipeline rd. (65/14) Brad Neel PAD D HWP H -54 skid. Rick & Lance working on Choke re- connect and versa valves PAD D HWP VECO: 24" GLT line. "pipeline rd. (VSM 122 +87) Brian Chalk PAD D HWP VECO: 24" GLT line. Pipeline rd. (At intersection to H) Brian Chalk PAD D H -15: DHD (Gary) Shoot fluid levels IA & OA. Pad: H Bleeds PAD N H -37, S/L work continues, LRS was out and pressure tested the tubing to 2500 psig (PASS). 8/19/2004 Pad: H Bleeds 29 N UWP, Valve shop and Grease crew out to set a BPV. PAD N H -37 Slick line doing GLT work PAD N HWP VECO Welding side seams on 24" GLT line on Pipeline access road. GC #2 end PAD N HWP Rick Williams working on electrical equipt. In H -54 skid PAD N HWP VECO Welding side seams on 24" GLT line on Pipeline access road 65 +16 station PAD N Training sign off for Troy Snow on Test Separator operation and PW operation H, Y, & P pads. PAD N UWP, Canspec out to X -Ray Piping. UV's were B/P but are now BIS after X -Ray. PAD N H -37, S/L work continues. 8/18/2004 Pad: H Bleeds PAD D H -37 S/L still on well. PAD D H -PAD I got some more new local TI and installed on wells that had insulations. PAD D H -PAD Thursday, October 07, 2004 Page 11 of 15 WOA Operator's Handover Report Date Order RUN: 4 Day: Wortham, Bob Night: PAD D H -PAD Subsidence working on wells. Pad: H Bleeds PAD N H -37 S/i still doing GLT valve work. PAD N H -09,31 GC -2 taged closed for 301 work. PAD N H -PAD I showed the grease crew what we need on the Tis. 8/17/2004 Pad: H Bleeds PAD D Checked wells for leaks. PAD D H -PAD I put 20 -1" plugs in SK. PAD D H -37 S/L still on well, pulled TTP, and will do GLT valve work. PAD D H -37 WSC pulled GLT line and blinded M/C in skid 55. Pad: H Bleeds PAD N Basic Energy took methanol from H -pad. PAD N WSG rigging intergal on IA H -37. Rig off 0-? 8/16/2004 Pad: H Bleeds PAD D H -07 WRW 27350 to repair TT. 8/15/2004 Pad: H Bleeds PAD D H -P Did HSE Walk throughs. PAD D H -PAD Looks like all the S/D work is completed but the welding on H -04. PAD D H -PAD need to have grease crew Band T/I onto S /Risers, need to remove Themowell form T /I. Same For 0-PAD. PUT SO BANDING METERIAL IN THERE OFFICE ALONG WITH PLUG FOR Q -04 PAD D H -PAD WRW 27303 to repair HYD pumps in the 52 skid keep running build little Pressure. PAD D H -PAD WRW 27307 to repair Versa on HV -H7055 ISO valve between H -08 and H -25. PAD D H -PAD Got some 1 "1/2 and 2" flanges for T/I that are flanged you have list, also in skid 11 more 1" plugs in sample bottle. I have more flanges and plugs coming. Pad: H Bleeds PAD N H54 skid. Grease crew plugging Thermowelds. 8/14/2004 Pad: H Bleeds PAD D Roust a bouts, and Marc changed out the 45 header valve HV7592. Note all 6" bleeds are open to slop tank. PAD D Marc repaired the GLT cross country valve, all valves open and tags pulled at H -PAD and at GC -2. The H -PAD glt can pressure up evenly with other when it comes up. PAD D H -PAD I walked all the wells checked for tree leaks. None PAD D H -Q Have grease crew start pulling T/I out and pluging in H -54, at wells. See list Pad: H Bleeds PAD N Basic Energy taking Methanol from H -pad. Thursday, October 07, 2004 Page 12 of 15 WOA Operator's Handover Report Date Order RUN: 4 Day: Night: West, Lee PAD N H -54 skid emergency vent fans. Air press regulator blown diaphram. Shut off air. VF- 5001 -H. WR# 27288 PAD N Grease crew replaced all the thermo -welds with plugs except Q -04. 8/13/2004 Pad: H Bleeds PAD N H -P Did HSE Walk throughs. PAD N Kept working on S/D items. PAD N H -18 WRW 27189 to repair versa going to the $1 and 42 headers PAD N H pad: Went with rover to cross tag outlet sdv's, LDF's and Warm up to LDF on H pad PAD N Jerry wrote WR for DBLE plug valve H7592 replace. PAD N Basic Energy Unloaded 82 BBLS MEOH from "H" pad. PAD N WR # 27234 for H7684. SDV outlet for H42 line to GC. 8/12/2004 Pad: H Bleeds PAD D Helped Wortham with S /D. Pad: H Bleeds PAD N H -pad all drains still open to slop tank. Hose to bleed trailer shut. PAD N Grease crew greased and serviced the HP Dble Plug valves. All holding but H -7592 8/11/2004 Pad: H Bleeds 22 D 32, 27, winged. 1 8/10/2004 Pad: H Bleeds PAD D Chemical delivery. Pad: H Bleeds PAD N H -P Did HSE Walk throughs and reads. PAD N H -PAD reset T /S. 8/9/2004 Pad: H Bleeds 29 D Oil sheen in a water puddle in front of well house, called 5700, Environmental came out and cleaned up. PAD D Rousties installed wind socks. Pad: H Bleeds PAD N H -P Did HSE Walk throughs and reads 8/8/2004 Pad: H Bleeds 03 D Dewatering demobe, tubing is F /P. 29 D DHD bled down tubing for tree replacement. 35 D SI to test H -33. Thursday, October 07, 2004 Page 13 of 15 WOA Operator's Handover Report Date Order RUN: 4 Day: Night: Wortham, Bob Pad: H Bleeds PAD N H -P Did HSE Walk throughs and reads. PAD N H -35 POP after H -33 test. PAD N H -36 S/I to test H -05. PAD N H -25 bled OA down from 90psi to 20psi. PAD N H -35 POP after H -05 test. 8/7/2004 Pad: H Bleeds 03 D Dewatering S /D, and demobing. Pad: H Bleeds PAD N H -P Did HSE Walk throughs and reads. 8/6/2004 Pad: H Bleeds 03 D Dewatering continues. PAD D Chemical delivery. Pad: H Bleeds PAD N H -P Did Hse walk throughs and reads. PAD N H -31 TBG was F/P with MEOH, OA was at 175psi. PAD N H -11 PCC drop into 41 header sent to GC -1, did not need to S /I. PAD N H -24 S/I for GC -2 D -Bank clean out. 8/5/2004 Pad: H Bleeds PAD D Skid 59, Phill R. replaced communication card to the NOC. Pad: H Bleeds PAD N H -P Did HSE Walk throughs and reads. PAD N H -03 still dewatering. PAD N H -31 needs the tubing F/P hope its not frozen. 8/4/2004 Pad: H Bleeds PAD D H -02, Dewatering Ops continue. PAD D Mechanic John Hall out to conduct HVAC PM's. PAD D CIC layout crew working. Pad: H Bleeds 03 N Dewatering continues. PAD N Fire extinguisher checks. PAD N Reads / walk throughs. 8/3/2004 Pad: H Bleeds Thursday, October 07, 2004 Page 14 of 15 WOA Operator's Handover Report Date Order RUN: 4 Day: Paulsberg, Steve Night: PAD D H -02, Dewatering Ops continue. Pad: H Bleeds 03 N Dewatering continues. PAD N Reads / walk throughs. 8/2/2004 Pad: H Bleeds PAD D H -02, Schlumberger S/L completed work and has moved off location. Pad: H Bleeds 03 N Dewatering continues. PAD N Reads / walk throughs. 8/1/2004 Pad: H Bleeds PAD D H -02, S/L still on Well. PAD D H -03, Dewatering Ops continue. PAD D H -04, WSG out to completed R/D and demobe, post CTU Ops. Pad: H Bleeds 02 N S/L still on well. 03 N Dewatering continues. 04 N WSG, R/D coil job. PAD N Reads / walk throughs. PAD N Skid 54, pump down SOT. 1 Thursday, October 07, 2004 Page 15 of 15 Ann, Comm Query (1.2.1) Page 1 of 4 Ann Comm Query - Well Report Well IH -11 Greater Prudhoe Bay - -> Prudhoe - West - -> H Pad - -> H -11 Problem Status Planned Action Surface Caing leak, broached to Obj: Secure well, Eval for Surface surface during 9/26/04 arctic pack > 10/16/02: DSO bled OA from 1060 to 540 Casing leak waiver flush. psi, OA has arctic pack. 1. SL: Set TTP Caliper recorded tbg in good > 01/07/04: High IAP noted in DS reads 2. VECO: Install cellar liner condition 2/1/04 T =IA =2300 psi 3. FB: MITIA to 3000 psi CHROME tubing! > 01/09/04: TIFL Failed on overnight BUR, 4. DHD: MITOA w/ N2, locate TIW rep confirmed packer was T =IA surface casing leak point tested to 3500 psi w/ the rig. > 01/10/04: Classified problem well (PWE) 5. WIE: Eval for SC Waiver > 01/16/04: SL DGLVs, ran OGLV in top station. > 01/18/04: TIFL FAILED - Fluid to surface. > 02/01/04: TTP set @ 8398', Caliper all jts 's <10% > 02/21/04: CMIT -TxIA passed to 3000 psi, LLR TxIA 4.8 bpm @ 650 psi > 02/24/04: LDL found leak in GLM #1 > 05/16/04: SL ran DGLV's, MIT -T Passed to 2500 psi, pulled TTP > 09/26/04: MITOA Failed, OA Broached to surface while doing Arctic Pac flush. Left phone message with Winton and talked with Jeff Jones. Date Comment 9/28/2004 T /I /0= 2350/1070/20. Temp =SI. Monitor & Cellar. (Post arctic pack flush). TP increased 50 psi overnight. IAP increased 510 psi overnight. OAP increased 20 psi overnight. Cellar is dry, no fluids comming from flutes. 9/27/2004 T /I /0= 2300/560/10. Temp= SI. Monitor WHPs & Cellar (post Artic Pack Flush). IAP increased 280 psi. Liquid 6" below the top of Conductor flutes, no bubbles in fluid & no noise indicating of a leak. 9/26/2004 TIO= 360/1100/980 Circ 4.6 bbls 90 *f Diesel into OA for Arctic Pack Flush (Well Flowing on Arrival) OA Broached to Surface - - -DHD Crew Made Appropriate Calls -- -Final WHP's= 360/1100/0 9/26/2004 TIO= 360/1100/980, temp =150. TIFL PASSED / OA arctic pack flush (Fluid Broached / Conductor flutes); initial OA FL at surface (arctic pack). Bled OA from 980 psi to 0+ psi in 40 minutes (1.5 bbls of arctic pack). LRS pressured OA to 2000 psi (2.6 bbls); monitored for 15 minutes and OA lost 40 psi, bled to 0+ psi (diesel & small amount of arctic pack). Re- pressured to 2000 psi and fluid broached to surface through conductor flutes (approximately 5 gallons in cellar), bled to 0 psi, continued to bubble slightly from conductor flutes. SI well and the bubbling stopped. Monitored during TIFL and the fluid in the conductor dropped to 8" from top. OAP increased to 20 psi in 3 hours. Total returns of approximately 2 bbls of arctic pack from OA. TIFL PASSED; bled IA from 1100 psi to 280 psi in 2 hours. IA FL started at 6320' (between St. #3 & #4) and rose to 5850' at 1 hour, dropped to 6170' at 2 hours. SI bleed and monitored for 1 hour and the IAP increased 10 psi and the IA FL dropped to 6370'. Gas lift line is connected and has 20 psi on it. Final WHP's= 360/280/20. 9/23/2004 T /I /0= 400/1190/1020, temp =152. Monitor WHP's (post FO OA bleed). OA FL at surface (arctic pack). 9/22/2004 T /I /0= 400/1200/1020. Temp =155. Monitor WHP's, (post FO OAP bleed). 5/17/2004 * ** JOB CONTINUED FROM 5 -16 -04 * ** (Pull TTP, sbhps) RAN 4 1/2" EQ. PRONG TO 8402' SLM. GOOD MARKS ON EQ. PRONG. RAN 4 1/2" GS. PULLED XXN PLUG @ 8397' SLM. RIH W/ TANDEM PETRADAT GUAGE. (LOCATE EOT @ 8,416' SLM, TD @ 9,257' SLM, CORR. TO KB +24'= 9, 281' ) PERFORMED STOP'S AS PER PROGRAM. ( SEE SBHPS DATA PAGE. ) ** *LEFT WELL SHUT -IN * ** 5/16/2004 * ** CONTINUED FROM 5 -15 -04 * ** (SET STA #3 /MIT -T) PULLED & SET STA #4 W/ 1.5" DGLV & RK http: // apps- alaska. bpweb. bp. com /sst_drilling_we11s /ann_comm_ query/ann_comm_query.asp ?level... 10/6/2004 Ann Comm Query (1.2.1) Page 2 of 4 LATCH. PULLED 1.5" DGLV W/ RK LATCH FROM STA #3. SET 1.5" DGLV W/ EXTENDED PACKING IN STA #3. MIT -T TO 2500 #. PASSED RIH W/ 4 1/2" EQ. PRONG TO XN PLUG @ 8405' SLM. INCONCLUSSIVE MARK'S EQ. PRONG. NO PRESSURE CHANGE. * ** JOB CONTINUED ON 5 -17 -04 * ** 5/16/2004 * ** JOB CONTINUED FROM 5 -15 -04 * ** ( P/S STA #3/ MIT) PULLED & SET STA'S #3 & #4 W/ 1.5" DGLV & RK LATCH'S. PULLED WHIDDON CATCHER SUB ©8,396' SLM. (HAD 5/16" DUAL CHECK ORIFICE AND RUNNING TOOL IN IT) PERFORMED A MIT -T TO 2500 #. MIT -T PASSED. T =2410, IA= 420, OA= 90. LOST 90# IN 30 MINUTES. (NOTE: STA #3 HAS EXTENDED PACKING!) ** *LEFT WELL SHUT -IN * ** (NOTIFIED DSO OF WELL STATUS) 5/15/2004 * ** WELL SHUT IN ON ARRIVAL * ** (AC -EVAL & REPAIR) RIGGING UP ON H -11. STANDING BY FOR BLEED TANK. * ** JOB CONTINUED ON 5 -16 -04 * ** 5/15/2004 * ** WELL SHUT -IN ON ARRIVAL * ** (P /S STA #3, MIT) RIG UP ON H -11 * ** JOB CONTINUED ON 5- 16-04 * ** 5/15/2004 5/13/2004 »Cont. from 5- 11 -04» (Dmy off GLM's, Run D &D hole finder) Set 1.5" pocket pkr in #1 glm @ 8243' md. MIT -T to 2500 psi. Started to test then something gave up just as reaching test pressure. Pull & Rerun pocket pkr & re- MIT -T, failed. RIH with D &D hole finder, PT above & below GLM's starting at #1 GLM. Achieved successful 1000 psi MIT -T above #3 GLM at 7224' md, POOH. Note: Catcher sub set in XN nipple. GLV running tool lost in hole, should be in catcher. - -Rig down, well left SI- 5/12/2004 ** *CONT. FROM 5 -11 -04 WSR * ** (DUMMY STA. 1 & 5, MIT -T) SET 1.5" RK POCKET PACKER AT 8223' SLM STA. 1 RUN 4 1/2 BLB, DOUBLE KNUCKLE, 2.24 GAGE RING MIT -T TO 3000# - FAIL, T x IA HAS RAPID COMMUNICATION. CMIT T x IA TO 1000# - PASS PULLED/ RE -RUN 1.5" RK POCKET PACKER AT STA. 5 MIT -T -T TO 1000# - FAIL RUN 4 1/2 D &D HOLEFINDER TO 8125' SLM, 7875' SLM, 7240' SLM, (7177' SLM, HELD PRESSURE) ** *RIG DOWN FOR NIGHT, UNIT 137 WILL TAKE OVER TOMMORROW * ** 5/12/2004 CONTINUE FROM 5/12/2004. 5/11/2004 * ** CONTINUE FROM 05/10/04 * ** ( DUMMY STA. 1& 5, MIT -T) RUN 1.75 LIB, NO PICTURE. RUN 1.70 LIB, NO PICTURE PULLED 1.5" RK DGLV FROM 8223' SLM STA. 1 3 ATTEMPTS TO PULL RK OGLV @ STA.5, RUN 2.7 LIB SHOWS EMPTY POCKET RUN MANDREL RATTLE THRU ALL STATIONS. ATTEMPT 1 1/2" POCKET PACKER (DGVL) WITH RK LATCH. (RUNNING FISHING NECK ON RK IS .935 ** *CONTINUE TO 05/12/04. * ** 5/10/2004 ** *FOUND WELL SHUT IN ON ARRIVAL ** *(DUMMY OFF STA. 1 & 5, MIT -T) SET 4 1/2 WHIDDON CATCHER SUB AT 8405' SLM. * ** CONTINUE TO 5/11/04 * ** 2/24/2004 Leak Detection Log found leak in bottom GLM #1. Up /Down Anomally passes completed. Stop counts above and below GLM #1 recorded. Full Report to follow AM. * *Well Left Shut In ** 2/24/2004 PERFORMED LEAK DETECT LOG. LEAK DETECTED AT 8245', IN THE PUP JT. CONNECTION AT THE BOTTOM OF GLM #1. BASELINE PASS LOGGED FROM SURFACE TO TTP @ 120 FPM. TTP TAGGED AT 8421'. PUMP CRUDE OIL DOWN TUBING @ 1 BPM / 250 PSI WITH RETURN FROM IA TO FLOWLINE FOR FURTHER LOGGING. LOGGED ANOMALY PASS FROM TTP TO SURFACE @ 120 FPM. SOME FLUID IS COMING BACK FROM IA INTO TUBING THROUGH ORIFICE IN GLM #5. FLOWLINE FREEZE PROTECTED WITH MEOH. WELL TURN OVER TO PAD OPERATOR. * * ** *WELL LEFT SHUT- IN * * * ** 2/24/2004 T /I /0= 250/400/250 Assist E- line, 115 bbls crude, 2 bbls meth down tubing. FWP= 250/300/100 2/20/2004 T /I /0= 400/375/100 Load and CMIT TBG X IA and LLRT TBG X IA. Loaded tbg and is w/477 bbls crude. LLRT from TBG to IA was @ 650 PSI =4.8 bpm. CMIT PASSED on 1st test. TBG /IA Pressure losses were 15 min =60 psi /70 psi, 30 min.= 20 psi /20 psi. Pumped 5 bbls neat to freeze protect flowline. Final WHP= 200/250/100 2/3/2004 T /I /0= 450/420/130. (Post WHP's bleed, Secure). No increase in pressure overnight. 2/2/2004 T /I /0= 1450/1450/150. Temp= SI. (Well secure, post TTP). Flowline freeze protected. Thawed out frozen jewelery on IA. TBG FL @ 6700', IA FL @ 6400'. Rigged up to bleed IAP down H -32's flowline (LP). Swab appears to be frozen on H -32. Opened wing on H -11 to choke. Bled TBG pressure down from 1450 psi to 350 psi. IAP tracked TBG slowly during bleed down. IAP decreased from 1450 psi to 420 psi. Monitored WHP's for 1 hr. Final WHP's = 450/420/130. 2/1/2004 ** CONTINUED FROM 1 -31 -04 WSR ** CALIPERED TUBING FROM 8458' SLM, GOOD DATA, XN NIP LOOKED GOOD. SET 4 1/2" XXN PLUG @ 8398' SLM ( MAX TUBING PSI 2000 PSI) BLEED TBG TO 1500 PSI GOOD TEST ON PLUG. ** LEAVE WELL SHUT -IN ** 1/31/2004 ** *WELL FLOWING ON ARRIVAL * ** LOC TT @ 8406' SLM + 25' + 8431' CORRECTED. CALIPER TUBING FROM 8458' SLM UP. ** CONTINUED ONTO 2 -01 -04 WSR ** http: // apps- alaska. bpweb. bp. com /sst_drilling_wells /ann_comm_ query/ann_comm_query.asp ?level... 10/6/2004 Ann Comm Query (1.2.1) Page 3 of 4 • 1/31/2004 1/19/2004 TIO= 340/580/440. 155° Monitor WHPs (Post TIFL). Over night IAP decreased 370 psi. Well is flowing with out A/L. 1/18/2004 T /I /0= 320/620/420. Temp =hot. TIFL FAILED, FTS (Post GLV C /O). Well flowing upon arrival, shut well in to stack out TBG. A/L casing valve SI with 600 psi on A/L line. Initial TBG FL could not get readable fluid level. Initial IA FL @ 6299' or 336 bbls (between sta 4 & 3). When stacking out TBG, IAP started tracking. In 30 min. TBG pressure went from 320 psi to 1130 psi and IAP went from 620 psi to 840 psi. In 2nd 30 min TBG went from 1130 psi to 1420 psi and IAP went from 840 psi to 980 psi. Let well stack out for 4 hours. TBG pressure stack out to 2060 psi and IAP is now © 1440 psi. TBG FL © 8412' and IA FL rose to 5833'. Start TIFL. Bled IAP from 1440 psi to 950 psi in 1.5 hrs. IA FL rose to surface during bleed. Final whp's= 1880/950/420. * * ** *DSO will bring well back on line * * * * ** 1/16/2004 ** *WELL SHUT IN UPON ARRIVAL * ** SET 4 -1/2" WHIDDON C -SUB @ 8410' SLM. PULLED OGLV FROM STA# 1© 8224' SLM, ,PULLED LGLV FROM STA# 3 © 7206' SLM, PULLED LGLV FROM STA# 4 @ 5054' SLM, PULLED LGLV FROM STA# 5 © 2974' SLM, SET OGLV /RK (DUAL CHECK 5/16 ") @ STA# 5 © 2974' SLM,SET DGLV /RK @ STA# 4 ©5054' SLM. SET DGLV /RK @ STA # 3 @ 7206' SLM, SET DGLV /RK @ STA # 1© 8224' SLM, PULLED M/T WHIDDON C -SUB * ** WELL LEFT SHUT IN AS PER DSO * * ** 1/10/2004 TIO= 1480/1480/190. Monitor WHPs Post TIFL Failed. (Eval High IAP). Over night TBG pressure decreased 430 psi, IAP increased 720 psi. 1/9/2004 TIO= 2320/2300/100 (SI). TIFL Inconclusive (Eval High IAP). Initial IA FL @ bottom sta 8243' (445 bbls). A/L casing valve was open & A/L lateral valve is closed. Closed A/L casing valve and bled spool down to 0 psi, monitor during TIFL. Start bleeding IAP to H -32 flow line from 2300 psi to 680 psi in 3 hrs. IA FL remained unchanged. TBG pressure decreased 300 psi, monitor for 1 hr. In 1 hr TBG pressure decreased 90 psi and IAP increased 80 psi. Final WHPs= 1910/760/190. 12/17/2003 TIO= 300/1180/560. 145° OA FL (OA Survey). OA FL near surface. Bled small amount of arctic pac from jewelry. 11/13/2003 T /I /0= 280/1020/480. (Post OA Bleed) OAP increased 20 psi since previous day. 11/12/2003 T /I /0= 280/1010/460. (Post OA Bleed) 11/10/2003 T /I /0= 260/950/460. Temp =150 *. Monitor WHP's. Post OA teed. (Possible IA x OA). OAP increased 190 psi overnight. OA has Arctic Pac in jewelry. Well has A /L. 11/9/2003 T /I /0= 260/1080/900. Bleed OA (High OAP). Temp 140. OA FL near surface. Bled OA from 900 psi to 260 psi in 35 mins. OA FL rose to surface. Monitored OAP for 30 mins. OAP increased 10 psi. Final WHP's 260/ 1080/270. 8/12/2003 T /I /0= 300/1020/780. (Operator call in) Temp 150. IA FL @ 8285'. 6/6/2003 TIO= 320/850/740. Temp= 158. IA FL @ 8243' (Sta. # 1). No Gaslift Rate. (For GLR). 12/12/2002 T /I /0 = 290/1140/560 Temp = 160 OA FL @ surface (arctic pack). (500+ psi OA FL list) 11/26/2002 110= 340/950/700 Temp= 140. IA FL @ 8236' (Sta. #1). (For GLE). Well is not on gas lift. 4/11/2002 T /I /O = 300/580/400, DSO called in high OA. Bled OA to 400psi from 1120psi. Took approx. 5 min., all arctic pack. 5/9/2001 T /I /0 = 300/1200/1000; OA FL @ Surface (Artic Pac), (OA shoe competency survey) 2/27/2000 T /I /0= 360/ 1300/ 1300, Temp= 0. JEWELRY FREE 7/20/1998 T /I /0= 250/ 1470/ 500, Temp= 127. BLED DOWN O.A. FROM 1250 P.S.I. 6/17/1998 T /I /0= 320/ 1650/ 800, Temp= 132. BLED OA FROM 1400. 5/11/1998 T /I /0= 300/ 1675/ 1000, Temp= 136. F/L ON IA ( GLR =3.5MM ) 5/11/1998 T /I /0= 300/ 1675/ 1000, Temp= 136. G/L RATE @ 3.5 MM S/O @ 8,242' 4/21/1997 T /I /0= 300/ 1650/ 500, Temp= 0. GR @ 3.4 1/26/1997 T /I /0= 260/ 1550/ 380, Temp= 141. GLR©2.0 10/27/1996 T /I /0= 290/ 1600/ 220, Temp= 138. GLR @ 2.1 , 10/23/1996 T /I /0= 290/ 1610/ 240, Temp= 142. No data in original FMPro File 10/10/1996 T /I /0= 290/ 1575/ 20, Temp= 144. MONITOR 10/9/1996 T /I /0= 300/ 1600/ 0, Temp= 143. BLED OA DOWN FROM 1460 PSI. 7/23/1996 T /I /0= 1940/ 2110/ 150, Temp= 0. 1 /4LY F/L - G/L R. 2.0 4/26/1996 T /I /0= 360/ 1625/ 780, Temp= 144. G/L RATE= 1.6 http: // apps- alaska.bpweb.bp. com/sst_drilling_wells /ann_comm_ query/ann_comm_query.asp ?level... 10/6/2004 Ann Conant Query (1.2.1) Page 4 of 4 1/26/1996 T /I /0= 410/ 1700/ 300, Temp= 110. GLR = 2.0 mmcf 1/14/1996 T /I /O= 360/ 1625/ 660, Temp= 148. No data in original FMPro File 1/13/1996 T /I /0= 1020/ 1800/ 250, Temp= 0. L/G @ 1.6, WELL WAS BACK FLOWED & W/H WAS COMING DOWN. 12/24/1995 T /I /0= 380/ 1600/ 640, Temp= 136. GLR = 2.0 mmcf 12/17/1995 T /I /0= 300/ 1750/ 440, Temp= 0. GL RATE 2.0 7/22/1995 T /I /0= 350/ 1640/ 460, Temp= 149. QUARTERLY 5/3/1995 T /I /0= 290/ 1650/ 140, Temp= 0. GL RATE 2.3 4/17/1995 T /I /0= 460/ 1510/ 1490, Temp= 138. BLEED O/A TO 440PSI. 1/29/1995 T /I /0= 380/ 1540/ 1040, Temp= 141. No data in original FMPro File Annulus Pressure Report Notes: • This query works for GPB, GPMA and Endicott wells • Input Well Names using the surface well house name format, i.e. 09 -32, not 09 -32C • Endicott well names can be entered in the following format: "ENDX -XX ", i.e. END1 -01 • When called from the Package Generator, the report is limited to the 20 most recent entries • This report pulls Problem /Status /Planned action from Oracle based AnnComm tables • Well events listed are a combination of historical AnnComm events and AWGRS events for this well Questions? Contact Joe Anders, 659 -5102 Revised: 06/09/2003 http: // apps- alaska. bpweb. bp. com /sst_drilling_wells /ann_comm_ query /ann_comm_query.asp ?level... 10/6/2004 Well Readings For: H -11 Page 1 of 1 -- Well Pad Readings -- H Readings Flow Line Flow Status Wavered Temperatu Line IA OA OOA 000 10/6/2004 SI 275 2000 0 10/5/2004 SI 275 2000 0 10/4/2004 SI 275 2000 0 10/3/2004 SI 275 2000 0 10/2/2004 SI 200 1700 0 10/1/2004 SI 200 1700 0 9/30/2004 SI 200 1700 0 9/29/2004 SI 1400 0 9/28/2004 SI 700 0 9/27/2004 SI 400 0 9/26/2004 SI 400 0 9/25/2004 FL 150 360 1200 980 9/24/2004 FL 150 360 1200 980 9/23/2004 FL 150 360 1200 980 9/22/2004 FL 150 600 1200 600 9/21/2004 FL 150 600 1200 600 9/20/2004 FL 130 1000 1300 0 9/19/2004 FL 130 1000 1300 0 9/18/2004 FL 150 320 1300 400 -- i p week 9/17/2004 FL 150 320 1300 1680 9/17/2004 FL 150 320 1300 1680 9/15/2004 FL 150 320 1300 1680 9/14/2004 148 320 1320 1700 9/13/2004 150 360 1480 1680 9/12/2004 146 330 1400 1650 9/11/2004 145 340 1450 1620 9/10/2004 148 320 1500 1600 _ 9/9/2004 145 360 1540 1600 H t Pi F'o P €� y) 8/18/2004 C " " \ 157 350 0 500 G c s - r - "+t) v j r- 8/16/2004 157 350 0 500 8/13/2004 4 157 350 0 500 - } CSC a 5 e.$ :_y 3. e1_., 8/10/2004 157 350 0 500 9i 8/9/2004 ( a (VCt -- cl (g VA- 158 350 0 500 -/ i,rf • 8/8/2004 160 350 0 525 V 1 8/7/2004 160 350 0 500 8/6/2004 158 300 0 500 - T 8/5/2004 155 300 0 500 �^ t ��, i 8/3/2004 FL 155 300 0 450 3f'�� 8/2/2004 FL 155 300 0 450 8/1/2004 FL 155 300 0 450 ��S P on SIw (o4 • • H -11 TIO Plot 4,000 -sr- Tbg 3,000 • IA U E m 0 2,000 A- OA C7 C * 5 ( 1/ ,' Ill *1 / lio i' I' • 11•111 OOA 1,000- 4444:: 0 Ill 1 I _ : I 1 �. �� I • -1.- 000A t III 0 10/8/2003 12/8/2003 2/8/2004 4/8/2004 6/8/2004 8/8/2004 10/8/2004 JPEG image 915x281 pixels • • Subject: [Fwd: RE: PBU H-11 (PTD 1800680)] Date: Mon, 04 Oct 2004 15:06:59 -0800 From: James Regg <jim_regg @admin.state.ak.us> Organization: State of Alaska To: Louis R Grimaldi <lou_grimaldi @admin. state. ak.us> Original Message Subject: RE: PBU H -11 (PTD 1800680) Date: Tue. 21 Sep 2004 11:09:44 -0800 From: NSU, ADW Well Integrity Engineer ° NSU AD1't`N `ellIntegrityEngineer'�i BP.com> To: James Regg <iim regg_c?admin.state.akus> CC: Mielke, Robert L. <robert.mielke:: BP.com >, GPB, Fld TL <GPBFIdTL[aBP.com >, GPB, Fld Ops Lead <GPBF1dOpsLead( e.BP.com: , GPB, GC2 TL <GPBGC2TL( >, GPB, Well Pads HYQ <GPBWeHPadsHPYQ(BP.com >, NSU, ADW Well Operations Supervisor <NSUADW ellOperationsSupervisor 'com >, Winton G Aubert <\ vinron aubert<<ivadmin.state.ak.us >, Engel, Harry R ‹En Te1HR rBP.com:-, Reeves, Donald F <ReevesDf;i %:BP.com >, Rossber„ R Steven <RossbeRS!a!BP_con> , NSU, ADW Well Integrity Engineer <<_NSUADW elllnte�v.rih Engineerric'BP.com> , Dube, Aiuia T <Anna.Dube cc•BP.com -> Hi Jim. The H Pad Operator bled H -11's GA to 400 psi, it did not re- pressure. The well was The TxIA Comm was fi_ -=ed by changing out a DGLV. Attached is a TIO plot, let me know if you have any other questions. Joe Anders, F.E. Well Integrity Coordinator, BP Exploration, Alaska) Inc. Work: 1 -907- 659 -5102 Mobile: 943 -1154 Pager: 659- 5100, __1154 Email: :•]SC= .D.:We11ir,tegrit, ngineer9b .cone Original Message From: James Pegg [maiit= -im regq@admin.s`ate.a us] Sent: Monday, September 20, 2004 3:06 PM To: NSU, ADW Well Integrity Engineer Cc: Winton G Aubert Subject: PEU H -11 (PTD 1600600) Inspector did SVS tests at H -pad on 9/12/04; reports that H -11 has following pressures: Tbg -- 350 psi IA -- 1450 psi OA -- 1650 psi There was no mention of a waiver posted for the well and I cannot find any record of notice for pressure ' >1000psi in OA. Also, there was a report of T_=IA communication on 1/10/04; I assume OGLV was changed out to remedy that situation as proposed in 1/10/04 email.. What does your recent TIO data show regarding possible I.L'OA communication? Thanks. l of 2 10/04/04 5:38 PM • • Jim Regg H =91 ftt Plot -►-A 3,000 . -I 5. _ a — S. t1 201.a tr22rz -_ -- Th s 22r2OI4 9/2 _, J Regg < re #tzoi adm us> Petroleum Engineer A{ )GCC 2 of 2 10/04/04 5:38 PM [Fwd: PBU well H -11 casing failure] • • Subject: [Fwd: PBU weld H -11 casing failure] Date: Mon, 04 Oct 2004 15 :07 :27 -0800 From: James Regg <jim_regg @admin.state.ak.us> Organization: State of Alaska To: Louis R Grimaldi <lou_grimaldi @admin.state.ak.us> Original Message Subject: PBU well H -11 casing failure Date: Mon, 27 Sep 2004 08:49:18 -0800 From: Jeff B. Jones cjefjonesri %�adtnin.state.ak.us> To: James B Rego jim_re <ugr&admin.state.al;.us> CC: - Field Inspectors AOGCC (E -mail) <aogcc prudlioe_bay uadmin_state.ak.us> Hello Jim, Joe Anders notified me yesterday that during an arctic pak flushing operation on the outer annulus of well PBU H -li, the surface casing failed (at appro:_. 2000 psi) and fluid was released up the conductor pipe into the cellar. He indicated the well is shut in awaiting diagnostics. I was planning to stop by there today to have a look. Thanks, Jeff Jim Regg <jim_regg<<�admin.state.ak.us> Petroleum Engineer L OUCC 1 of 1 10/04/04 5:38 PM JPEG image 799x1065 pixels • • Subject: [Fwd: PBU H -111 Date: Mon, 04 Oct 2004 15 :07:57 -0800 From: James Regg <jim_regg @admin.state.ak.us> Organization: State of Alaska To: Louis R Grimaldi < 1ou_grimaldi @admin.state.ak.us> Original Message Subject: PBU H -11 Date: Mon, 27 Sep 2004 21:15:56 -0800 From: Jeff B. Jones < jeff_jones vadmin.state a E._�is' :: To: James B Regg =_jim_re_Tg(ii aclmin_state_a1: his Hello Jim, Here is some further information I recieved from BP on the surface casing integrity failure on PBU production well H -11: the casing failure occurred 9/26/04. The well is not artificially lifted. Immediately preceding the failure the well pressures were Tubing- 360 psi; IA- 1100 psi; OA- 980 psi (the 'A pressure value is suspect in my view as it is the reason for flushing). H -11 normal production is: 589 BELS oil; 4429 H20; :.899 mm gas. According to Joe Anders ::DHD Supervisor) the arctic pak flush procedure is initiated by the pad operator who contacts the DHD department when he observes during his normal duties that an OA pressure guage is plugged with arctic pak & is no longer indicating pressure correctly. The DHD field crew typically performs the flushing procedure on 1 or two wells per month. There is no comprehensive program to flush all the arctic pak'd welts unless a problem has been noted by an operator or another craft person working on the well. The flushing procedure is performed by the DHD field personnel and uses a hot oil truck to pressure up the OA with appro_ 90 degree diesel to 2000 psi and wait 15 -20 minutes for it to hopefully- dissolve the dessicated arctic pak. Then a hard line from the OA is quickly opened to allow the fluid in the OA to surge out to a 40 EBL snorkel tank, washing out the arctic pak. This process is repeated as many times as necessary :usually 2 or 3 times)) until the desired result is achieved. In the case of H -11, the casing integrity failed during the second pressure up cycle. Roland Johnson was the DHD representative performing the procedure, and I have not yet spoken with him. I contacted EP's environmental group representative Alison Ericson 659 -4789) and asked for a copy of the incident report and any pictures they night have. She said they estimated that approx. 5 gals. of diesel was released to the cellar, and that quantity allowed them 30 days to file a report and she would forward it to us as soon as it was finished. She also said that the spill was cleaned up immediately and approx. 1 cubic yard of contaminated gravel was removed from the cellar. I also put a call in to Gilbert Wong (BP Wells Group Supervisor- 6_59-5224) but he was not available, so I left a message asking for information on the incident. I went to the well and looked it over, noted that the cellar had been cleaned up, the well was shut in and there was no pressure on the OA. I took a few pictures and they are attached. I checked our list of BP's category A/B :;ells and the SCP list I have, but H -11 was not listed. Joe Anders indicated that no previous problems were documented on this well and it's TIO plot looked normal. I asked Joe Anders why they pressured up to 2000 psi and he told me that's what they have always done in the past, but they are revising the flushing procedure to a maximum 1000 psi pressure in the future. I told him I thought that was probably a good 1 of 5 10/04/04 5:38 PM • • idea under the circumstances. I can investigate further if yo have any other questions or need more informati Jim, in my opinion, this event at ous and others in ten of rth Sl�uag t past beg the questions: Since Be is aware that arctic pak in the OA PBU wells is causing a problem monitoring the OA casing pressure of Noope wells, why are they waiting until someone reports a plugged OA e, instead of instituting a program proactive removing the arctic pak from all the wells? What about arctic pak in other wells in other fields? Is arctic pak affecting pressure readings during MITOA's performed to verify barriers for variances or waivers? It seems to me that not being able to effective monitor the QA pressures may, least in part, defeat the purpose of the well desgn and poses a seri risk to people, the environment and the resource. Thanks, Jeff Yf W "w - , „ , -,- -:.-='W,-,,:- .. '- ._=:_-ig-'-',. ±.77: --4-„-.-.!, '----'-'-- _ ==-,g4kIS; - -_ ' ,7--- - 7 ''''.---- --4------.. ioi-- --4...:.---- :-. '1,..-sw.s4t - -.... - -* -$ - --_,,;-'-'71.kt-Mk-f--',*;:4-.):F.-.1-1-.:N_Y —_---_—_ „,--1----1.- _-1-------- _ - _ -7 _ : , ---. : .,,. r y a< �:' - _ 2 of 5 10/04/04 5:38 PM JPE ima 799x1065 pi • { I x iv ° _.. _ - - _ gam. - - R - z 7 5 - air._ - lA pis � '� � \ \, _ �. �' - ,2U y . �, �.. « mac --� E . C i A F i> M 3 of 5 10/04/04 5:38 PM JPEG image 799x1065 pixels • • I ! .6 7 9 6,1, 5 of 5 10/04/04 5:38 PM [Fwd: Re: PBU H -1 • • Subject: [Fwd: Re: PBU H -111 Date: Mon, 04 Oct 2004 15:08 :37 -0800 From: James Regg <jim_regg @admin.state.ak.us> Organization: State of Alaska To: Louis R Grimaldi < lou_grimaldi @admin.state.ak.us> Original Message Subject: Re: PBU H -11 Date: Tue. 28 Sep 2004 12:08:49 -0800 Front: Jeff B. Jones ° jettJonesWadmin.state.ak.us> To: James Regy iimeg:,r(admin.state.ak.us> References: <4158F38C.2080800 (iiadmin.state.ak.us=- <4159B: X26 .6000906adnun.state.ak.us> James Pegg wrote: > Jeff - > Thank you for the information and photos. Any idea where the casing > failed? > What follows is internally confidential - there are at least 3 > inconsistencies that we are exploring: 1) BP provided no notice when • OA pressures exceeded 1000 psi per CO 492 rule 3, this must be done • within 3 working days of identifying pressure); 2) it is unclear if > the operator that started the well (whenever that was) actually bled > the OA pressure before startup (per Co 492 rule 6, pressure must be • bled to a point that the OA pressure does not exceed 1000 psi at > operating temperatures - rule 6 is funde mental to our effort to > prevent annular pressure related accidents; 3) why did the surface > casing fail at such a low pressure? (this has a huge impact on BP's • justifying barriers based on a test to 1.2x the h'LCP, and calls into • question BP's assertion that they do not operate unsafe wells). ▪ Your concerns are valid regarding validity of monitored OA pressures; > my understanding for tests is the DHD is installing a calibrated test • gauge so plugging should not be a real concern there (or should be > more evident • Please be cautious with your info gathering and discussions with BP. > We have not ruled out enforcement actions - spoke with Commissioners > and Assistant Attorney General about this. > It would be nice if we could find out when the well was brought on > line (I assume this was tied to the GC-2 restart after the 5 v}: > shutdown) ; curious if you know who the operator was for well • restarts. We might want to speak with him about the restart procedure. • Jim > Jeff B. Jones wrote; Hello Jim, >0 Here is some further information I recieved from BP on the surface >> casing integrity failure on PBU production well H -11: the casing >0 failure occurred 9/26/04. The well is not artificially lifted. >0 Immediately preceding the failure the well pressures were Tubing- 360 1 of 3 10/04/04 5:38 PM • » psi; IA- 1100 psi; OA- 980 psi (the OA pressure value is suspect in » my view as it is the reason for flushing). H -11 normal production is: » 589 BBLS oil; 4429 H20; 9.899 mm gas. » According to Joe Anders (DHD Supervisor) the arctic pak flush » procedure is initiated by the pad operator who contacts the DHD » department when he observes during his normal duties that an OA » pressure guage is plugged with arctic pak & is no longer indicating » pressure correctly. The DHD field crew typically performs the » flushing procedure on 1 or two wells per month. There is no » comprehensive program to flush all the arctic pak'd wells unless a » problem has been noted by an operator or another craft person working » on the well. The flushing procedure is performed by the DHD field » personnel and uses a hot oil truck to pressure up the OA with approx. » 90 degree diesel to 2000 psi and wait 15 -20 minutes for it to » hopefully dissolve the dessicated arctic pak. Then a 2" hard line » from the OA is quickly opened to allow the fluid in the OA to surge » out to a 40 BBL snorkel tank, washing out the arctic pak. This » process is repeated as many times as necessary (usually 2 or 3 time Y Y ( Y times) » until the desired result is achieved. In the case of H -11, the casing » integrity failed during the second pressure up cycle. Roland Johnson » was the DHD representative performing the procedure, and I have not » yet spoken with him. » I contacted BP's environmental group representative Alison Ericson » (659 -4789) and asked for a copy of the incident report and any » pictures they might have. She said they estimated that approx. 5 » gals. of diesel was released to the cellar, and that quantity allowed » them 30 days to file a report and she would forward it to us as soon » as it was finished. She also said that the spill was cleaned up » immediately and approx. 1 cubic yard of contaminated gravel was » removed from the cellar. » I also put a call in to Gilbert Wong (BP Wells Group Supervisor- » 659 -5224) but he was not available, so I left a message asking for » information on the incident. » I went to the well and looked it over, noted that the cellar had been » cleaned up, the well was shut in and there was no pressure on the OA. » I took a few pictures and they are attached. I checked our list of » BP's category A/B wells and the SCP list I have, but H -11 was not » listed. Joe Anders indicated that no previous problems were » documented on this well and it's TIO plot looked normal. I asked Joe » Anders why they pressured up to 2000 psi and he told me that's what » they have always done in the past, but they are revising the flushing » procedure to a maximum 1000 psi OA pressure in the future. I told him » I thought that was probably a good idea under the circumstances. I » can investigate further if you have any other questions or need more » information. » » Jim, in my opinion, this event and others in the recent past beg the » questions: Since BP is aware that arctic pak in the OA of PBU wells » is causing a problem monitoring the OA casing pressure of North Slope » wells, why are they waiting until someone reports a plugged OA guage, » instead of instituting a program proactively removing the arctic pak » from all the wells? What about arctic pak in other wells in other » fields? Is arctic pak affecting pressure readings during MITOA's » performed to verify barriers for variances or waivers? It seems to me » that not being able to effectively monitor the OA pressures may, at » least in part, defeat the purpose of the well design and poses a » serious risk to people, the environment and the resource. » Thanks, » Jeff Hi Jim, I spoke with Lori at BP WOA Production Control who said H -11 was last POP'd on 8/26/04. The BP Field Spoc said that was crew change out day 2 of 3 10/04/04 5.38 PM [Fwd: Re: PBU H -11 ] • • and according to his records the day pad operator was Clark Lawler and the night pad operator was Ted Mills. DHD doesn't know yet where the casing failed until they do some diagnostics. Thanks, Jeff Jim Rego admin. st ate _ak. s> Petroleum Engineer • AOCCC 3 of 3 10/04/04 5:38 PM [Fwd: Telephone conversation w/ Bill Bocast (BPXA - Pace)] S • Subject: [Fwd: Telephone conversation w/ Bill Bocast (BPXA- Pace)] Date: Mon, 04 Oct 2004 15:09:12 -0800 From: James Regg <jim_regg@admin.state.ak.us> Organization: State of Alaska To: Louis R Grimaldi <lou_grimaldi @admin.state.ak.us> Original Message Subject: Telephone conversation w! Bill Bocast (BPXA -Pace) Date: Fri, 01 Oct 2004 15:04:33 -0800 From: Jeff B. Jones ; jet}jones @admin.state.ak.us> To: James B Reg;* � Jim_reggra admin.state.ak_us Hello Jim, this note is to confirm our phone conversation of today re: a call to me at the Anchorage office from BPKA GC-2 employee Bill Bocast (Pace Union Health & Safety Rep... I returned Bill Bocast's telephone call to find out what he wanted. He indicated to me that he had a concern about hydrocarbons bubbling up between the surface pipe & conductor on some PEU wells. He did not give specific well numbers but identified A & S pads in Prudhoe WOA as e_:arnples. He said the situation had been reported to BPKA supervision, but wanted to know if BPXA had reported the situation to us (AOGCC). I told him that any uncontrolled release of hydrocarbon should be reported to the AOGCC. I told him I was unaware of any recent reports, but that it would be checked out. He said he had a copy of an A pad operator hand -over log that he wanted to send me & I gave him my home address. When it arrives I will bring it to the Anchorage office. Bill said we could easily get any of these pad operator logs from the SPOC if we wanted, electronic or printout. He mentioned the fact that Roman Gray A_hOsH? was investigating some safety issues involving leaking valves in the manifold buildings & he mentioned that several of the SD`:` vales leaked. He also asked about our requirements (or rather lack of for SSSV 's s in Prudhoe. He was of the opinion that high GOR wells in Prudhoe should have a working SSSV installed. I told him that he should stop in the Anchorage office and talk to you about these issues because you would be interested to speak with him about any North Slope Field well integrity or production related issues. Thanks, Jeff Jim Regg jim re�ru.a.dnun.state.ak.us> Petroleum Engineer AOGCC 1 of 2 10/04/04 5:38 PM Re: PBU H -11 • • Subject: Re: PBU 1141 From: "Jeff B. Janes" <j eff j anes@a adxnin.state.ak us> Date: Tue, 28 Sep 2004 12:03:49 -0800 To: m R I'm = _ .t tate.ak us> : :: E r: # ; , ... J� �s a ��, � .p� _..- ..: �f'; ix° . ._ • James Regg wrote: Jeff - Thank you for the information and photos. Any idea where the casing failed? What follows is internally confidential - there are at least 3 inconsistencies that we are exploring: 1) BP provided no notice when OA pressures exceeded 1000 psi (per CO 492 rule 3, this must be done within 3 working days of identifying pressure); 2) it is unclear if the operator that started the well (whenever that was) actually bled the OA pressure before startup (per CO 492 rule 6, pressure must be bled to a point that the OA pressure does not exceed 1000 psi at operating temperature) - rule 6 is fundemental to our effort to prevent annular pressure related accidents; 3) why did the surface casing fail at such a low pressure? (this has a huge impact on BP's justifying barriers based on a test to 1.2x the MAOP, and calls into question BP's assertion that they do not operate unsafe wells). Your concerns are valid regarding validity of monitored OA pressures; my understanding for tests is the DHD is installing a calibrated test gauge so plugging should not be a real concern there (or should be more evident). Please be cautious with your info gathering and discussions with BP. We have not ruled out enforcement actions - spoke with Commissioners and Assistant Attorney General about this. It would be nice if we could find out when the well was brought on line (I assume this was tied to the GC -2 restart after the 5 wk shutdown); curious if you know who the operator was for well restarts. We might want to speak with him about the restart procedure. Jim Jeff B. Jones wrote: Hello Jim, Here is some further information I recieved from BP on the surface casing integrity failure on PBU production well H -il: the casing failure occurred 9/26/04. The well is not artificially lifted. Immediately preceding the failure the well pressures were Tubing- 360 psi; IA- 1100 psi; OA- 980 psi (the OA pressure value is suspect in my view as it is the reason for flushing). H -11 normal production is: 589 BBLS oil; 4429 H2O; 9.899 mm gas. According to Joe Anders (DHD Supervisor) the arctic pak flush procedure is initiated by the pad operator who contacts the DHD department when he observes during his normal duties that an OA pressure guage is plugged with arctic pak & is no longer indicating pressure correctly. The DHD field crew typically performs the flushing procedure on 1 or two wells per month. There is no comprehensive program to flush all the arctic pak'd wells unless a problem has been noted by an operator or another craft person working on the well. The flushing procedure is performed by the DHD field personnel and uses a hot oil truck to pressure up the OA with approx. 90 degree diesel to 2000 psi and wait 15 -20 minutes for it to hopefully dissolve the dessicated arctic pak. Then a 2" hard line from the OA is quickly opened to allow the fluid in the OA to surge out to a 40 BBL snorkel tank, washing out the arctic pak. This process is repeated as many times as necessary (usually 2 or 3 times) until the desired result is achieved. In the case of H -11, the casing integrity failed during the second pressure up cycle. Roland Johnson was the DHD representative performing the procedure, and I have not yet spoken with him. I contacted BP's environmental group representative Alison Ericson (659 -4789) and asked for a copy of the incident report and any pictures they might have. 1 of 2 9/29/2004 9:57 AM Re: PBU H -1 1 She said they estimated that approx. 5 gals. of diesel was released to the cellar, and that quantity allowed them 30 days to file a report and she would forward it to us as soon as it was finished. She also said that the spill was cleaned up immediately and approx. 1 cubic yard of contaminated gravel was removed from the cellar. I also put a call in to Gilbert Wong (BP Wells Group Supervisor- 659 -5224) but he was not available, so I left a message asking for information on the incident. I went to the well and looked it over, noted that the cellar had been cleaned up, the well was shut in and there was no pressure on the OA. I took a few pictures and they are attached. I checked our list of BP's category A/B wells and the SCP list I have, but H -11 was not listed. Joe Anders indicated that no previous problems were documented on this well and it's TIO plot looked normal. I asked Joe Anders why they pressured up to 2000 psi and he told me that's what they have always done in the past, but they are revising the flushing procedure to a maximum 1000 psi OA pressure in the future. I told him I thought that was probably a good idea under the circumstances. I can investigate further if you have any other questions or need more information. Jim, in my opinion, this event and others in the recent past beg the questions: Since BP is aware that arctic pak in the OA of PBU wells is causing a problem monitoring the OA casing pressure of North Slope wells, why are they waiting until someone reports a plugged OA guage, instead of instituting a program proactively removing the arctic pak from all the wells? What about arctic pak in other wells in other fields? Is arctic pak affecting pressure readings during MITOA's performed to verify barriers for variances or waivers? It seems to me that not being able to effectively monitor the OA pressures may, at least in part, defeat the purpose of the well design and poses a serious risk to people, the environment and the resource. Thanks, Jeff Hi Jim, I spoke with Lori at BP WOA Production Control who said H -11 was last POP'd on 8/26/04. The BP Field Spoc said that was crew change out day and according to his records the day pad operator was Clark Lawler and the night pad operator was Ted Mills. DHD doesn't know yet where the casing failed until they do some diagnostics. Thanks, Jeff 2 of 2 9/29/2004 9:57 AM #9 ') News from every state Alabama: Huntsville - Patrick Richardson, the driving force behind the establishment of the University of Ala- bama in Huntsville in the 1940s, has died. He was 79, He successfully lobbied for a satellite campus in the textile mill town of Huntsville while still in law school in Tuscaloosa in 1946. Alaska: Anchotage - State oil regula- tors reduced by half a proposed fine against BP Exeloration (Alaska) for a Prudhoe Bay 011 well explosion in 2002 that severely injured a worker. The Oil and Gas Conservation Commission slashed the fine 'from $2.53 million to $1.26 million after the company contest- ed it. The commission also ruled that BP can count toward the fine $549,000 it has spent on a program on remote well-pres- sure mOnitoring. State investigators found the explosion was caused byex- cessive presSure that had built up inside the idle well. The company has 30 days to payor it can continue to appeal. Arizona: Tucson - The Pima County supeIVisors approved a plan to create a trust fund to help low-income and mod- erate-income home buyers. The decision makes Pima County the only local gov- ernment in the state to create such a fund. The fund will be financed largely by local home builders. Contributions will be mandatory, said Edward Taczanow- sky, president of the Southern Arizona Home Builders Association, the first per- son named to a housing commission to direct the fund. Arkansas: Harrison - Searcy Coun- t:;¡ police are searching for a marl acéiJsed of avoiding a debt by faldng his own death. Terry Presnell, 43, former publish- er of a small newspaper, allegedly sent a phony death certificate to a printing busi- ness to which he owed $1,857. The docu- ment said Presnell died in a traffic acci- dent in Mexico. Authorities say he's alive. California: Napa - A group that op- poses the construction of a Wal-Mart Su- percenter in Napa Valley wine country filed a lawsuit claiming that officials ig- nored state and local laws in approving the more than 190,OOO-square-foot store. City officials say the project com- plies with laws and zoning codes. Colorado: Denver - The state and two contractors agreed to pay $1.5 núl- lion to the relatives of three people killed when a 40-ton bridge girder sagged into the path of a sport utility vehicle and sliced it in two. William and Anita Post and their daughter Koby Ann, 2, died May 15 when the 100-foot girder drooped over eastbound lanes of Interstate 70. Fed~ral i!1v~~tiga~~rs determined that Holton, 16, in September 2003. Prosecü- tors said Holton was strangled in a local motel before her body was dumped from a plane into the Atlantic Ocean. Keyser faces death or life in prison. A penalty hearing begins today. ' D.C.: District of Columbia Mayor Antho- ny Williams will attend the annual con- ference of the New Jersey State League of Municipalities in Atlantic City. NJ., today. Later in the day, he will head to Little Rock for the opening of the presidential library of Bill Clinton. Florida: Orlando - Tourism officials said the four hurricanes that hit the state caused tourism to dip slightly in the third quarter. Preliminary figures released by Visit Florida showed that an estimated 19.1 million people visited the state in Ju- ly, August and September, a 4% decrease from the same period last year. Georgia: Atlanta - The state will need more than 14,000 new teachers by the end of the decade to prevent a serious teacher shortage, according to a presen- tation to the state Board of Regents. Asso- ciate vice chancellor Jan l<ettlewell told the regents that more state colleges should help produce teachers and that state colleges need to produce more mi- nority teachers. Hawaii: Honolulu - The Justice De- partment approved $1.47 million to sup- port anti-drug programs on l<auai, U.S. Sen. Daniel Inouye said. The money will be used in a number of ways, including funding a task force to target crystal meth users and dealers at all levels. The money will also support drug-prevention activ- ities across the island. Idaho: Jerome - Students at Jerome High School are launching what's be- lieved to be the state's first bilingual stu- dent newspaper. The BridgejEI Puente will have articles in English and Spanish. Jour- nalism teacher David Quinley said the project is designed to create a better con- nection between the community's two cultures. About a third of Jerome's stu- dents are Hispanic. Dlinois: Kankakee - The City Council decided that it no longer needs the $370,000 generated by the city's $35 an- nual vehicle tax and voted unanimously to repeal it. The tax was in the form of stickers required for vehicles. The mayor sought the repeal after comparing cur- rent expenses and revenue with past au- dits and budgets and finding that city sales tax. revenue had been growing. Indiana: Indianapolis - Republicans formally took control of the Indiana House for the first time since 1996 and elected Rep. Brian Bosma of Indianapolis as the House speaker. Bosma said the state's economic and budQ'pt;mr trnll¡'I",.. J nated ågãiiištJmëñ¡;g¡t~~¿~~ig~ ~;;~ universit:;¡ officials announced. The po will apply to students living in dorm des, smaller scholarship þalls or an api ment complex run by the university. ({entucky: frankfort - Gov. Flet er and Economic Development Cabi! Secretary Gene Strong announced pl. for a $1.2 billion advanced coal-fir power plant. Fletcher, Strong and offic of LG&E Energy announced the com} ny's plans to build the facilit:;¡ at the gt erating station in Trimble County. It v have a power output of750 megawatt Louisiana: Oakdale - Former G Edwin Edwards, 77, was transferrt from a prison in Fort Worth to the fede prison at Oakdale, making it easier t family and friends to visit. Edwards serving a 10-year federal sentence f racketeering, extortion and fçaud ster ming from the licensing of riverboat ca: nos during and after his term. Maine: Levant - The Maine Wardt Service said Adam Nason was hunting legally when he fatally shot a friend tn month in the woods in Levant. Officia said Nason, 20, fired the shot that kille James Griffin about 15 minutes aft~r leg hunting ended that day. It was the fir: hunting-related shooting death in Mair since 2001. Authorities are discussin whether charges will be brought. Maryland: Annapolis - Furnitur makers from St. Michaels are schedule to deliver a desk Thursday made fror remnants of the state's most famous tret the 460-year-old Wye Oak. The desk wi be displayed at the State House rotund until Nov. 29, then moved to the gover nor's office for his personal use. The trel toppled during a thunderstorm in 2002. Massachusetts: Boston - Tht state's highest court rejected Attorne~ General Thomas Reilly's challenge to ¿ 2.5% increase in 2004 auto insurance pre, miums. Reilly had challenged a new for· mula being used to calculate underwrit- in!¡1; profits. The Supreme Judicial Court said the state's commissioner of insur- ance had "considerable latitude" in devis- ing a formula. Michigan: Auburn Hills - A Ger- man automotive supplier plans to spend $15.3 million to expand in this Detroit suburb. the state announced. The expan- sion by Pgam Advanced Technologies should add 240 jobs. The company sup- plies tools and parts to Ford, General Mo- tors and Volkswagen AG's Audi unit. Minnesota: St. Paul- Secretary of State Mary Kift"meyer said that more vot- ers used absentee ballots in this year's election than any other year in Minneso- ta's history. More than 231,000 people, .::1hn"r sz "')Of n.f",."t'cu"'1t'" ,........... .........-__...__ 1-_1 )('cd on /he /ecl'l' \rticu! fìsh on the ,\'creett ,'Jer on 'd he a long, long day. lVl ANCHORAGE DAILY NEWS · www.adn.com ;g q~~~ [~~~~~~§~ ~ ª~~g~~~~~~~~~g~rn~~ WW ~ ~ ~~ ~ 0 ~~. 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C" ' -......oooot ::s ° .-+- .... ~ § I-' ~ ~ __ .-+- ('þ ()'Q 0 ~ o::1~~ 8~¡::¡..~ 0& ~-~::6~ \\.J a ° ~ õ' S E § æ.. * ('þ ('þ s. ~ æ.. -- ~ I ::s ""'::S I' " I _ t/j ¡::¡.. ('þ p". ('þ _ 0 R~vv\ 0 ve. 11/:;- "* SATURDAY, OCTOBER 30, ..M__........_.~""'~,.,.__'.,_____ BP again accused of safety violations . CIVIL FINE: State regulators propose $11 7,500 penalty for alleged breach of pressure monitoring rules. By WESLEY LOY Anchorage Dally News State oil industry regulators have proposed a $117,500 civil fine against BP Exploration (Alaska) Inc. for possibly violating rules on monitoring and preventing dangerous pressure buildup in Prud- hoe Bay wells. The action marks the second time the Alas- ka Oil & Gas Conservation Commission has pro- posed fining BP in connection with oil well pres- sure problems. The company, which operates the huge Prud- hoe Bay oil and gas field, is still contesting a pro- posed $2.53 million fine stemming from an August 2002 well explosion and fire that badly injured for- mer BP field operator Don Shugak of Anchorage. Mter the explosion, the commission developed new rules to prevent pressure buildup in wells. Those rules, contained in Conservation Order No. 492, were issued in June 2003. A letter this week to BP from commission chairman John Norman accused the company of violating the order in three ways: · BP failed to record and make available daily well monitoring information on Prudhoe Bay well H-11 for the period of Aug. 19 through Sept. 8. · BP failed to notify the commission of pres- sure in the well exceeding 1,000 pounds per square inch during the period of Sept. 9 until Sept. 21. · BP failed to bleed off pressure before the well was restarted on Sept. 9 following a shutdown. For the second two alleged violations, the commission is proposing the maximum penal- ty "in light of the fact that compliance with Con- servation Order No. 492 is mandated specifically to avoid the serious consequences of catastroph- ic well failure that in fact previously occurred" at the well that injured Shugak, Norman's letter to BP said. For the first violation" a lesser penalty is being wWW.t"etrOleuml~ews.C ) . PRUDHOE BAY )}EEK OF NOVEMBER 7. 2004 AOGCC hits BP with fine for annulus pressure violation at Prudhoe unit Alaska Oil and Gas Conservation "Commission proposes $11 7,500fine, corrective action, increased monitoring by agency; BP preparing a response By KRISTEN NELSON Petroleum News Editor-in-Chief The Alaska Oil and Gas Conservation Commission is proposing to fine BP Exploration (Alaska) for failure to record annular pressure problems, notify the commission of those prob- lems and to bleed down pressure at Prudhoe aay well H-ll at the BP-operated Prudhoe Bay field on Alaska's North Slope. The commission notified BP Oct. 25 that it was proposing to fine the company $117,500 and order corrective action~ The commission sàid in a letter to BP that it appears the company violated Conservation Order No. 492, "by failing to record and make available on request the results of monitoring the H-ll tubing and annulus pressures" between Aug. 19 and Sept. 8. The commission said the violations are indicated by gaps in the record of H-ll tubing pressure, inner annulus pressure and outer annulus pressure. A second violation was failure to notify the com- mission of outer annulus pressure exceeding 1,000 psig at H-ll from Sept. 9 through Sept. 21. The com- mission said it received a report. on the outer annulus pressure from BP only after it inquired. In a third violation, of both the conservation ~rder and of the commission's regulations, BP failed to bleed offH-ll's outer annulus pressure before it was restarted S~t. 9, after the well had been shut-in. Corrective action ordered In addition to the fine, the commission said it is proposing to order corrective actions by BP. Within 30 days BP is to provide' the commission ''with· a detailed description of actions, planned and accomplished, to prevent recurrence of violations similar to those that appear to have occurred in con- nection with the start-up of H-ll" and montlùy progress reports until the planned actions are com- pleted. ' For 180 days BP will provide the commission with 24-hour advance notice of all Prudhoe Bay well restarts so that the commission will ~ve the opportu- nity to witness the restart operations, and documenta- tion of well pressure bleeds in connection with well restarts. The commission is proposing a lighter 'fine ($2,500 " a day vs. the maximum of $5,000 a day) for the first group of violations because, the commission said, it understands ''that the pressures in qu~stion were in fact monitored and that the failure to record the obser- vations may have been due at least in part to confu- sion about the workings of BPXA's well data record- ing system." BP has 15 days from Oct. 25 date to notify the commission that it "concurs' in whole or in part with the proposed action ..., requests. infonnal review,. or requests a"hearing .. .," othetwise the commission will consider BP has accepted by default arid will issue an enforcement order. " BP reviewing BP said in an Oct. 29 statement that it "is review- ing the matter t() develop a response' to the proposed enforcement action. Options available to us include request for infonnal or fonnal hearings to the pro- posed enforcement action." BP said it is investigating ''why B-ll operated above policy guidelines of 1,000 psi (pounds per square inch) on the outer annulus for several days." The company said according to its policies and proce- dures "the well should have been monitored closely during start-up to ensure pressure remained below 1,000 psig during start-up operations." To keep pres- " sure 'below 1,000 psig; BP said, pressure can be bleed from the outer annulus either prior to the well being brought online, or while the well is being brought on line. "Bleeding pressure out of an annulus is a routine, relatively simple procedure that well site operators and contractors are traiÍ1ed to safely perfonn," BP said. On the issue of recording data - the violation for which the commission has proposed a lesser penalty - BP said its preliminary investigation found that the workers were uncertain "about whether data that had not changed over the identified period of time (Aug. 19-5ept. 8) needed to be entered into the computer database. Operators felt that if the data did not change see BP-page 15 ) Î¡ ) continued from page 14 BP trom day to day no entry was required because the computer would. automatically use the previous reading. We have since reinforced the need to input this data." . Rulesestabhshed last year The èommission issued rules r~gulating sustained annulus pressures in Prudhoe Bay . development wells in June 2003, following an explosion and fIre at Prudhoe,. Bay well A-22 in August 2002 which seriously injured a BP employee. The commission fmed BP for the inci- dent and said when it finished its investiga- tion in late 2003 that BP "may have violat- ed" the commission's regulations "by failing to cany on operations and maintain the property in a safe and skillful manner in accordance with good oil field engineering practices. " BP revised its Prudhoe Bay annular pres- sure management policies, and ~e commis- sion said in mid-2003 when it issued its new rules that while BP's policies "provide a rea- sonable starting point for establishing rules regulating annular pressure," those policies needed to be supplemented by a rule requir- ing 'BP to notify the commission when "wells exhibit annular pressures that exceed specific thresholds," by a rule requiring sub- mission by the operator of proposed COlT~- - tive actions for affected wells, by specific annular pressure limits necessi.tating COlTec- tive action and "operator accounting for annular pressure increases due to well heat~ ing dwing start-up." The connnission has established annular pressure rules for wells at. Kuparuk, Alpine and Milne Point similar' to those for Prudhoe. . #8 ') '& ) bp -~ BP Exploration (Alaska) Inc, P.O, Box 196612 900 East Benson Boulevard Anchorage, AK 99519-6612 (907) 564-5111 December 22, 2005 Hand-deli vered John K. Norman, Chair ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Ave., Suite 100 Anchorage, AK 99501 ,RECEIVED¡ DEC 2 2 2005 Alaska Oil & Gas Cons. Commission Anchorage Re: Well PBU H-ll Enforcement Action - Status Update Dear Commissioner Norman: On January 21, 2005, BPXA submitted a detailed description of actions planned and accomplished to prevent recurrence of violations similar to those found in connection with the startup of Well H-11 in September 2004. Pursuant to paragraph 2a of AOGCC Order #32, BPXA provides herewith the eleventh monthly progress report on the status of the outstanding activities in this matter: Training 1. Complete a BU-wide refresher training to clarify expectations of Well Integrity System Policy, with emphasis on recording every well's annulus pressures during normal, shut-in and shut-down operations. Due Date: 12/31/05 Completed Status: This action is now considered complete. Training for the SVS procedures has now been conducted at all Greater Prudhoe facilities and is complete for all staff with very few exceptions where individuals are away for extended vacation or out due to illnesses. Training has been tracked via B.P's automated training system (VT A) and the remaining individuals will receive iraining as they retun" to work. This is BPXA's final progress report on these activities. Please do not hesitate to contact me at 564-4632 with any questions or concerns. ~~ Bruce J. Williams Operations Integrity Manager Greater Prudhoe Bay BJW/jr bp ) ) ) .\ BP Exploration (Alaska) Inc. P.O. Box 196612 900 East Benson Boulevard Anchorage, AK 99519-6612 (907) 564-5111 November 30, 2005 Hand-deli vered RECEIVED NOV 3 0 Z005 John K. Norman, Chair ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Ave., Suite 100 Anchorage, AK 99501 Alaska Oil & Gas Cons. Commission Anchorage Re: Well PBU B-1! Enforcement Action- Status Update Dear Commissioner Norman: On January 21,2005, BPXA submitted a detailed description of actions planned and accomplished to prevent recurrence of violations similar to those found in connection with the startup of Well H-11 in September 2004. Pursuant to paragraph 2a of AOGCC Order #32, BPXA provides herewith the tenth monthly progress report on the status of the outstanding activities in this matter: Training 1. Complete a BU-wide refresher training to clarify expectations of Well Integrity System Policy, with emphasis on recording every well's annulus pressures during normal, shut-in and shut-down operations. Original Due Date: 11/30/05 Revised Due Date: 12/31/05 Status: Training for the SVS procedures are underway currently and have been completed with about half of the operations staff. The training for the remaininR staff will be completed by the end of December. BPXA's next progress report on these activities will be provided to the CUIIunission by DeCelllber 31, 2005. Please do not hesitate to contact me at 564-4632 with any questions or concerns. Sincerely, /aziJ m(~1- -Por Bruce J. Williams Operations Integrity Manager Greater Prudhoe Bay BJW /j r bp ) ¡I ') o BP Exploration (Alaska) Inc, P,O. Box 196612 900 East Benson Boulevard Anchorage, AK 99519-6612 (907) 564-5111 October 31,2005 Hand-deli vered John K. Norman, Chair ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Ave., Suite 100 1\nchorage, AK 99501 RECE OCT :3 1 Z005 Alaska Oil & G~~! Re: Well PBU H-l1 Enforcement Action - Status Update Dear Commissioner Norman: On January 21,2005, BPXA submitted a detailed description of actions planned and accomplished to prevent recurrence of violations similar to those found in connection with the startup of Well H-11 in September 2004. Pursuant to paragraph 2a of AOGCC Order #32, BPXA provides herewith the ninth monthly progress report on the status of the outstanding activities in this matter: Training 1. Complete a BD-wide refresher training to clarify expectations of Well Integrity System Policy, with emphasis on recording every well's annulus pressures during normal, shut-in and shut-down operations, Due: 11/30105 Status: Training commenced in October and is expected to require a roximatel 2 months to com lete. BPXA's next progress report on these activities will be provided to the Commission by November 30, 2005. Please do not hesitate to contact me at 564-4632 with any questions or concerns. Sincerely, ? J¿}~ ~..~ 1 Bruce J. Williams Operations Integrity Manager Greater Prudhoe Bay BJW/jr bp ) RECEIVED SEP 3 0 2005 " September 30, 2005 Hand-delivered Alaska Oil & Gas Cons. Commission Anchorage BP Exploration (Alaska) Inc. 900 East Benson Boulevard P.O. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 John K. Norman, Chair ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Ave., Suite 100 Anchorage, AK 99501 Re: Well PBU H-11 Enforcement Action - Status Update Dear Commissioner Norman: On January 21,2005, BPXA submitted a detailed description of actions planned and accomplished to prevent recurrence of violations similar to those found in connection with the startup of Well H-11 in September 2004. Pursuant to paragraph 2a of AOGCC Order #32, BPXA provides herewith the seventh monthly progress report on the status of the outstanding activities in this matter: Policies and Procedures 1. Modify the Well Integrity System Policy, procedures and training materials to clarify requirements to read and record data associated with Shut In, Shut Down and stabilized well operations. Present revised policy to Well Pad and Drill Site Operators in each area to incorporate feedback. Due: 9/30/05 Completed Status: All Prudhoe Bay operating procedures that include well integrity tasks have been reviewed and modified to clarify requirements to read and record annular pressure data on all wells. A separate annular well integrity procedure combining all well integrity guidance has been developed and is referenced within the other operating procedures. Approval to implement the new procedure has been completed and the Management of Change process is currently underway to enable the training of these changes. Training 2. Complete a BU-wide refresher training to clarify expectations of Well Integrity System Policy, with emphasis on recording every well's annulus pressures during normal, shut-in and shut-down operations. Due: 9/30/05 Revised due date 11/30/05 Status: Training will commence in October and is expected to require a roximately 2 months to com lete. John Nonnan, AOGCC ~ September 30, 2005 Page 2 ,) ) ~ . BPXA's next progress report on these activities will be provided to the Commission by October 31, 2005. Please do not hesitate to contact me at 564-4632 with any questions or concerns. Sincerely, ~~ Bruce J. Williams Operations Integrity Manager Greater Prudhoe Bay BJW /jr :" bp ) ) August 30, 2005 Hand -deli vered BP Exploration (Alaska) Inc, 900 East Benson Boulevard PO, Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 John K. Norman, Chair ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Ave., Suite 100 Anchorage, AK 99501 RECE~\/E, AUG 3 1 2005 A~aska 08' & B~s Re: Well PBU H-11 Enforcement Action - Status Update Dear COlnn1issioner Norman: On January 21,2005, BPXA submitted a detailed description of actions planned and accomplished to prevent recurrence of violations similar to those found in connection with the startup of Well H-11 in September 2004. Pursuant to paragraph 2a of AOGCC Order #32, BPXA provides herewith the seventh monthly progress report on the status of the outstanding activities in this matter: Policies and Procedures ), Modify the Well Integrity System Policy, procedures and training materials to clarify requirements to read and record data associated with Shut In, Shut Down and stabilized well operations. Present revised policy to Well Pad and Drill Site Operators in each area to incorporate feedback. Due: 8/31/05 Status: All Prudhoe Bay operating procedures that include well integrity tasks have been reviewed and modified to clarify requirements to read and record annular pressure data on all wells. A separate procedure combining all well integrity guidance has been developed and is referenced within the other operating procedures. A Management of Change process is currently underway to enable the authorization and training of these changes and is expected to be completed in September. Training 2. Complete a BU-wide refresher training to clarify expectations of Well Integrity System Policy, with emphasis on recording every well's annulus pressures during normal, shut-in and shut-down operations. Due: 9/31/05 Status: To be completed following the well integrity approval of the procedure revisions outlined in the action item above. John Norman, AOGCC August 30, 2005 Page 2 ') ., "1 'II" ~ BPXA's next progress report on these activities will be provided to the Commission by September 30,2005. Please do not hesitate to contact me at 564-4632 with any questions or concerns. Sincerely, , ~~ Bruce J. Williams Operations Integrity Manager Greater Prudhoe Bay BJW /jr bp ) ) July 29, 2005 CERTIFIED MAIL BP Exploration (Alaska) Inc. 900 East Benson Boulevard P.O, Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 John K. Norman, Chair ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Ave., Suite 100 Anchorage, AK 99501 RECEIVED JUL 2 9 Z005 Alaska Oil & Gas Cons. Commission Anchorage Re: Well PBD H-ll Enforcement Action - Status Update Dear Commissioner Norman: On January 21, 2005, BPXA submitted a detailed description of actions planned and accomplished to prevent recurrence of violations similar to those found in connection with the startup of Well H-ll in September 2004. Pursuant to paragraph 2a of AOGCC Order #32, BPXA provides herewith the sixth monthly progress report on the status of the outstanding activities in this matter: Policies and Procedures I. Modify the Well Integrity System Policy, procedures and training materials to clarify requirements to read and record data associated with Shut In, Shut Down and stabilized well operations, Present revised policy to Well Pad and Drill Site Operators in each area to incorporate feedback. Due: 8/31/05 Status: Activities are underway and continue to progress. Several modifications regarding data monitoring and recording have been implemented in the policies and procedures. As previously reported, a series of on-going meetings are being held with operators to review changes in the . well integrity policy and to provide clarification of the requirements within the operating procedures. Actions are presently Oil target for a timely completion at the end of August. Training 2. Complete a BU-wide refresher training to clarify expectations of Well Integrity System Policy, with emphasis on recording every well's annulus pressures during normal, shut-in and shut-down operations. Due: 9/31/05 Status: To be completed following the well integrity policy and procedure revisions outlined in the action item above. l .~ 'r .. John Norman, AOGCC July 29, 2005 Page 2 ) ) BPXA's next progress report on these activities will be provided to the Commission by August 30, 2005. Please do not hesitate to contact me at 564-4632 with any questions or concerns. Sincerely, 84~ Bruce J. Williams Operations Integrity Manager Greater Prudhoe Bay BJW /pj bp ) ') June 30, 2005 Hand-delivered BP Exploration (Alaska) Inc. 900 East Benson Boulevard PO, Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 John K. Norman, Chair ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Ave., Suite 100 Anchorage, AK 99501 RECEfVE JUN 2 9 Z005 l\laslŒ Oil & Re: Well PBU H-ll Enforcement Action - Status Update Dear Commissioner Norman: On January 21,2005, BPXA submitted a detailed description of actions planned and accomplished to prevent recurrence of violations similar to those found in connection with the startup of Well H-ll in September 2004. Pursuant to paragraph 2a of AOGCC Order #32, BPXA provides herewith the fifth monthly progress report ori the status of the outstanding activities in this matter: Policies and Procedures 1. Modify the Well Integrity System Policy, procedures and training materials to clarify requirements to read and record data associated with Shut In, Shut Down and stabilized well operations. Present revised policy to Well Pad and Drill Site Operators in each area to incorporate feedback. Due: ~ 8/31/05 Status: Activities are underway and continue to progress. Several modifications regarding data monitoring and recording have been implemented in the policies and procedures. As previously reported, a series of on-going meetings are being held with operators to review changes in the , well integrity policy and to provide clarification of the requirements within the operating procedures. Actions are presently on target for a timely completion at the end of August. Training 2. Complete a BU-wide refresher training to clarify expectations of Well Integrity System Policy, with emphasis on recording every well's annulus pressures during normal, shut-in and shut-down operations. Due: ~ 9/31/05 Status: To be completed following the well integrity policy and procedure revisions outlined in the action item above. ) ) John Norman, AOGCC June 30,2005 Page 2 BPXA's next progress report on these activities will be provided to the Commission by July 29, 2005. Please do not hesitate to contact me at 564-4632 with any questions or concerns. Sincerely, ~ ~!/~ Bruce J. Williams Operations Integrity Manager Greater Prudhoe Bay BJW/pj · . ) ) bp May 31,2005 Hand-deli vered BP Exploration (Alaska) Inc. 900 East Benson Boulevard P,Q. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 John K. Nonnan, Chair ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Ave., Suite 100 Anchorage, AK 99501 Re: Well PBU H-11 Enforcement Action - Status Update Dear Commissioner Norman: " . Ii:: (!' "'\\ E-··· [~\I E,,,:: ~ ~"'''''' .",;I~'P ."''''~! ',",""'" MAY 3 1 Z005 (m Ærl On January 21,2005, BPXA submitted a detailed description of actions planned and accomplished to prevent recurrence of violations similar to those found in connection with the startup of Well H-11 in September 2004. Pursuant to paragraph 2a of AOGCC Order #32, BPXA provides herewith the fourth monthly progress report on the status of the outstanding activities in this matter: Policies and Procedures 1. Modify the Well Integrity System Policy, procedures and training materials to clarify requirements to read and record data associated with Shut In, Shut Down and stabilized well operations. Present revised policy to Well Pad and Drill Site Operators in each area to incorporate feedback. Status: Activities are underway. The modifications regarding data monitoring and recording have been made. However, additional modifications to the policy are under review and are expected to take until August to finalize. A series of meetings have been held with operators to initiate reviews of changes in the well integrity policy and clarification of requirements within the operating procedures. Due: 5/31/05 Target extended to 8/31/05 Training 2. Complete a BU-wide refresher training to clarify expectations of Well Integrity System Policy, with emphasis on recording every well's annulus pressures during normal, shut-in and shut-down operations. Status: To be completed following the well integrity policy and procedure revisions outlined in the action item above. Due: 6/30/05 Target extended to 9/31/05 John Norman, AOGCC May 31,2005 Page 2 ) BPXA's next progress report on these activities will be provided to the Commission by June 30,2005. Please do not hesitate to contact me at 564-4632 with any questions or concerns. Sincerely, c;- ~¡))J~ .---:.'7' /,'/''') r-;;)L'~-"·'! Bruce J. Williams Operations Integrity Manager Greater Prudhoe Bay BJW /pj bp ) ) May 31,2005 Hand-deli vered BP Exploration (Alaska) Inc. 900 East Benson Boulevard PO, Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 John K. Norman, Chair ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Ave., Suite 100 Anchorage, AK 99501 Re: Well PBU H-ll Enforcement Action - Status Update Dear Commissioner Norman: On January 21,2005, BPXA submitted a detailed description of actions planned and accomplished to prevent recurrence of violations similar to those found in connection with the startup of Well H-l1 in September 2004. Pursuant to paragraph 2a of AOGCC Order #32, BPXA provides herewith the fourth monthly progress report on the status of the outstanding activities in this matter: Policies and Procedures 1. Modify the Well Integrity System Policy, procedures and training materials to clarify requirements to read and record data associated with Shut In, Shut Down and stabilized well operations. Present revised policy to Well Pad and Drill Site Operators in each area to incorporate feedback. Status: Activities are underway. The modifications regarding data monitoring and recording have been made. However, additional modifications to the policy are under review and are expected to take until August to finalize. A series of meetings have been held with operators to initiate reviews of changes in the well integrity policy and clarification of requirements within the operating procedures. Due: 5/31/05 Target extended to 8/31/05 Training 2. Complete a BU-wide refresher training to clarify expectations of Well Integrity System Policy, with emphasis on recording every well's annulus pressures during normal, shut-in and shut-down operations. Status: To be completed following the well integrity policy and procedure revisions outlined in the action item above. Due: 6/30105 Target extended to 9/31/05 John Norman, AOGCC May 31, 2005 Page 2 ) BPXA's next progress report on these activities will be provided to the Commission by June 30, 2005. Please do not hesitate to contact me at 564-4632 with any questions or concerns. Sincerely, ? ¡',7 ¡, "<.,(__A /'j I ¡ ,[LL/v(ßj -F:.":~"""",, -.,~__,.~ ¡,ii./ / r"·.: )L-'~' I Bruce J. Williams Operations Integrity Manager Greater Prudhoe Bay BJW /pj " :-':'1 ... bp ) -'.\ ~ ) April 29, 2005 Hand-deli vered BP Exploration (Alaska) Inc. 900 East Benson Boulevard P.O, Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 John K. Norman, Chair ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Ave., Suite 100 Anchorage, AK 99501 RECEIVED APR 2 t 2005 Alaska Oil & Gas Cons. Commission Anchorage Re: Well PBU H-11 Enforcement Action - Status Update Dear Commissioner Norman: On January 21, 2005, BPXA submitted a detailed description of actions planned and accomplished to prevent recurrence of violations similar to those found in connection with the startup of Well H-11 in September 2004. Pursuant to paragraph 2a of AOGCC Order #32, BPXA provides herewith the third monthly progress report on the status of the outstanding activities in this matter: Policies and Procedures 1. Modify the Well Integrity System Policy, procedures and training materials to clarify requirements to read and record data associated with Shut In, Shut Down and stabilized well operations. Present revised policy to Well Pad and Drill Site Operators in each area to incorporate feedback. Due: 5/31/05 Status: Activitiesare underway. A series of meetings with operators have been set up to review changes in the well integrity policy and clarify requirements within the operating procedures. Training 2. Complete a BU-wide refresher training to clarify expectations of Well Integrity System Policy, with emphasis on recording every well's annulus pressures during normal, shut-in and shut-down operations. Due: 6/30/05 Status: To be completedfollowing the well integrity policy and procedure revisions outlined in the action item above. John Norman, AOGCC ,<\pri129, 2005 Page 2 ') \) r^'" 1- 1'h .f BPXA's next progress report on these activities will be provided to the Commission by May 31,2005. Please do not hesitate to contact me at 564-4632 with any questions or concerns. Sincerely, ~~ Bruce J. Williams Operations Integrity Manager Greater Prudhoe Bay BJW /pj Bcc: Darren Jones, ConocoPhillips Richard Owen, ExxonMobil Kemp Copeland, GPB Field Mgr Jack Fritts/Roger Reddin, GPB Ops Mgrs Gary Christman, Alaska Drilling & Wells Harry Engel, Drilling Engineer Sandra Halliwill, Integrity & Assurance Bradley S. McKim, Legal Rosanne M. Jacobsen, Legal Bruce J. Williams, GPB Ops Integrity Steve Rossberg, Drilling Mgr J oe Anders/Anna Dube, Well Integrity Coordinators bp ) ') RECEIVED March 31, 2005 MAR 31 Z005 Hand-deli vered A"lkl au a GI$ Cans. Co_,ieI A,nchOfage BP Exploration (Alaska) Inc. 900 East Benson Boulevard P.O. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 John K. Nonnan, Chair ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Ave., Suite 100 Anchorage, AK 99501 Re: Well PBU H-ll Enforcement Action :- Status Uµdate Dear Commissioner Norman: On January 21, 2005, BPXA submitted a detailed description of actions planned and accomplished to prevent recurrence of violations similar to those found in connection with the startup of Well H-11 in September 2004. Pursuant to paragraph 2a of AOGCC Order #32, BPXA provides herewith the second monthly progress report on the status of the outstanding activities in this matter: Expectations and Accountability Due: 3/31/05 1. Administer appropriate levels of disciplinary action and coaching to individuals involved in failure to record H-ll annular pressures during the shut-in period; the failure to correctly bleed annular pressure prior to start up; and for failure to report the well as having sustained casing pressure and/or bleeding the annulus to reduce the annular pressure. Status: Disciplinary action has been administered. Continued focus on COMPLETE well start-up and proper monitoring and operation is being reinforced through morning tool box meetings and regular discussion. This action is considered complete. Database Enhancements Due: 3/30/05 2. Modify the data management programs to: a) highlight annular pressures entries that exceed the maximum allowable casing pressures immediately upon data entry, and b) require the operator to acknowledge when a newly entered pressure exceeds the maximum allowable casing pressure prior to proceeding with additional data entry. Status: Database enhancements have been made that immediately COMPLETE illuminate in red any pressure entry that exceeds the maximum allowable John Norman, AOGCC March 31, 2005 Page 2 \) ) operating pressure. Another enhancement includes a check box that must be checked prior to existing to indicate acknowledgement that the information entered is accurate. Continued database improvements are planned and will be implemented over the coming months as the overall data management program matures. This action is considered complete. Policies and Procedures 3. Modify the Well Integrity System Policy, procedures and training materials to clarify requirements to read and record data associated with Shut In, Shut Down and stabilized well operations. Present revised policy to Well Pad and Drill Site Operators in each area to incorporate feedback. Due: 5/31/05 Status: Activities are underway and are currently on target to achieve the targeted completion date. Training 4. Complete a BU-wide refresher training to clarify expectations of Well Integrity System Policy, with emphasis on recording every well's annulus pressures during normal, shut-in and shut-down operations. Due: 6/30/05 Status: To be completed following the well integrity policy and procedure revisions outlined in the action item above. BPXA's expectations regarding well monitoring continue to be reinforced on an on-going basis through daily morning safety meetings. Assurance is being provided through daily reviews of the well integrity management reports by Area Managers or lead operators as well as spot checks on the quality of data in the reports. BPXA's next progress report on these activities will be provided to the Commission by April 29, 2005. Please do not hesitate to contact me at 564-5671, or GPB's Operations Integrity Manager, Bruce Williams at 564-4632, with any questions or concerns. Sincerel .-7 ~ .'/';' _/ # /,./ Mauree . 0 son Vice President, Greater Prudhoe Bay BJW /pj bp ) ) February 28,2005 Hand-deli vered BP Exploration (Alaska) Inc. 900 East Benson Boulevard PO, Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 John K. Norman, Chair ALASKA OIL AND GAS CONSER V ATION COMMISSION 333 West Seventh Ave., Suite 100 Anchorage, AK 99501 FEB 2 2005 Re: Well PBU H-ll Enforcement Action - Status Update Dear Commissioner Norman: On January 21,2005, BPXA submitted a detailed description of actions planned and accomplished to prevent recurrence of violations similar to those found in connection with the startup of Well H-l1 in September 2004. Pursuant to paragraph 2a of AOGCC Order #32, BPXA provides herewith it's first monthly progress report on the status of the outstanding activities in this matter: Expectations and Accountability Due: 3/31/05 1. Administer appropriate levels of disciplinary action and coaching to individuals involved in failure to record H-ll annular pressures during the shut-in period; the failure to correctly bleed annular pressure prior to start up; and for failure to report the well as having sustained casing pressure and/or bleeding the annulus to reduce the annular pressure. Status: Actions are completedfor three of the 4 individuals and the actions for the remaining individual should be completed by the targeted due date. Database Enhancements Due: 3/30/05 2. Modify the data management programs to: a) highlight annular pressures entries that exceed the maximum allowable casing pressures immediately upon data entry, and b) require the operator to acknowledge when a newly entered pressure exceeds the maximum allowable casing pressure prior to proceeding with additional data entry. Status: Modifications are currently being evaluated and should be completed by the targeted due date. John Norman, AOGCC February 28, 2005 Page 2 ) ') Policies and Procedures 3. Modify the Well Integrity System Policy, procedures and training materials to clarify requirements to read and record data associated with Shut In, Shut Down and stabilized well operations, Present revised policy to Well Pad and Drill Site Operators in each area to incorporate feedback. Due: 5/31/05 Status: Revisions to the policy and procedures are underway and feedback is being incorporated from well pad and drill site operators. Training 4, Complete a BU-wide refresher training to clarify expectations of Well Integrity System Policy, with emphasis on recording every well's annulus pressures during normal, shut-in and shut-down operations, Due: 6/30/05 Status: To be completed following the well integrity policy and procedure revisions outlined in the action item above. BPXA's expectations regarding well monitoring continue to be reinforced on an on-going basis through daily morning safety meetings. Assurance is being provided through daily reviews of the well integrity management reports by Area Managers or lead operators as well as spot checks on the quality of data in the reports BPXA's next progress report on these activities will be provided to the Commission by March 31, 2005. Please do not hesitate to contact me at 564-5671, or OPB' s Operations Integrity Manager, Bruce Williams at 564-4632, with any questions or concerns. Sincerely, BJW /pj #7 bp ) ) BP Exploration (Alaska) Inc, 900 East Benson Boulevard PO. Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 January 26, 2005 Hand-delivered RECEI\/ED JAN 2 7 Z005 John K. Norman, Chair ALASKA OIL AND GAS CONSER V A TION COMMISSION 333 West Seventh Ave., Suite 100 Anchorage, AK 99501 Alask~ Oil & Ga~ Cons. Commission Anchorage Re: AOGCC Order #32, Well H-11 Enforcement Action Submittal of Detailed Information Dear Commissioner Norman: On January 10, 2005, BPXA paid the Commission a civil penalty of $102,500 in compliance with paragraph No.1 of the Commission's December 16, 2004 Decision and Order in this matter. BPXA advised the Commission that a detailed description of the actions, planned and accomplished, to prevent recurrence of violations similar to those found in connection with the start-up of H-l1 required under paragraph No. 2.a would be forthcoming. BPXA hereby timely submits those details. Background BPXA conducted a thorough investigation of this event to determine both immediate and root causes of the incident and to identify recommendations that would prevent similar events and improve the effectiveness of BPXA's well integrity processes. The investigation team consisted of both managers and union representation and was lead by a BPXA Area Manager external to the Prudhoe Bay Field organization. Members included a well operations coordinator, a drill site operator, a PACE HSE (Health Safety Environment) representative, and a Safety Team Leader. Additional support was provided by the Prudhoe Bay Field Team Leader, Operations Integrity Manager, two Area Managers, an Area Maintenance Coordinator, a Wells Staff Engineer, and a Well Integrity Coordinator. ) ) John Norman, AOGLL January 26, 2005 Page 2 Investigation Findings Evaluation of the root causes of this incident were two-fold: (1) failure to record annular pressures while the well was shut-in (prior to start-up); and (2) failure to bleed the well and maintain an annular pressure below 1000 psi upon start-up and while producing for the first nine days. The root cause for failing to document the well annulus pressures during the shut in period was "inadequate knowledge transfer." The field operators did not fully understand the Well Integrity System Policy directive and the well operating procedure requirements for entering and recording well annulus readings. The operators understood that readings were required when a well pad was in operation, but were not clear that readings were also required when a well pad was shut-in, depressured, safed-out and stabilized. Corrective actions for this failure include: · Coaching of individuals involved in the incident with specific feedback on the requirements. Improving expectations and accountability of all operators and well integrity engineers through BPXA-wide communication and training. Revision of well integrity policy and operation procedures to clarify data recording requirements during well shut-in periods. Enhancing the current database and reporting systems to notify key indi viduals of missing well annular pressure data. · · · The root cause failure for allowing well H-11's outer annulus pressure to exceed 1000 psig for 9 days was determined to be poor judgment. The operator who recorded the high pressures had received training on the well integrity policy and operating procedures yet failed to take appropriate action. BPXA's policies and procedures reinforce the maximum allowable annulus pressure limits provided in Conservation Order 492. Likewise, BPXA policies clearly require operators to prevent annulus pressures from exceeding set pressures limits during startup as well as manage (bleed and/or report) the pressures on a daily basis if the pressure limits are reached. BPXA believes that the failure that occurred in this case is behavioral and is not a result of inadequate training or unclear policies and procedures. In addition, the secondary or backup process to identify failures in well integrity management was not effective in this case. Individuals who received and reviewed daily well integrity information failed to identify and respond to reported annulus pressures that exceeded the maximum allowable pressures. The factors contributing to this failure include inadequate database and reporting processes coupled with unclear expectations. Reinforcing ac~ountability through the administration of disciplinary action and coaching to the individuals involved. Strengthening the data recording process to automatically identify data entries that exceed the pressure limits so that the operator can take immediate corrective actions. Enhancing daily reports to highlight wells that have reported pressures exceeding the maximum allowable pressures for each area. Area Managers, in turn, are responsible for reviewing the reports to ensure daily compliance. ) ) John Norman, AOGL~ January 26, 2005 Page 3 Corrective actions for these failures consist of: · · · The following detailed action plan has been implemented. As you can see, many of these actions have been addressed. Expectations and Accountability 1. Require all Area Managers to communicate with all Well Pad and Drill Site operators: a) To clearly reinforce company expectations that pressure limits are not to be exceeded by any amount without taking corrective action, and b) Refresh them on the Well Integrity Policy and clarify expectations for recording operations readings when wells and pads are shut down. Expectations and Accountability 2. Administer appropriate levels of disciplinary action and coaching to individuals involved in failure to record H-ll annular pressures during the shut-in period; the failure to correctly bleed annular pressure prior to start up; and for failure to report the well as having sustained casing pressure and/or bleeding the annulus to reduce the annular pressure. Expectations and Accountability 3. Re-emphasize to well integrity team members that pressure limits are not to be exceeded by any amount without taking corrective action. Expectations and Accountability 4. Reinforce to the H Pad Operators the expectation that policy and safe practices are top priority - if work activity is too high to manage it all safely, then the operator is expected to shut work down to allow for safe operations. Database Enhancement 5. Develop a Well Management Report that provides daily well operation information to Area Managers and Lead Operators to ensure compliance with regulations and local policy. The Well Management Report is provided to each Area Manager and Lead Operator daily highlighting any wells with sustained casing pressure or wells missing annular pressure readings for that specific area. Completed 10/13/04 Due: 3/31/05 Completed 10/31/04 Completed 12/28/04 Completed 10/13/04 ') ) John Norman, AOGL~' January 26, 2005 Page 4 Database Enhancement Due: 3/30/05 6. Modify the data management programs to: a) highlight annular pressures entries that exceed the maximum allowable casing pressures immediately upon data entry, and b) require the operator to acknowledge when a newly entered pressure exceeds the maximum allowable casing pressure prior to proceeding with additional data entry. Policies and Procedures Due: 5/31/05 7. Modify the Well Integrity System Policy, procedures and training materials to clarify requirements to read and record data associated with Shut In, Shut Down and stabilized well operations. Present revised policy to Well Pad and Drill Site Operators in each area to incorporate feedback. Training Due: 6/30/05 8. Complete a BU-wide refresher training to clarify expectations of Well Integrity System Policy, with emphasis on recording every well's annulus pressures during normal, shut-in and shut-down operations. Pursuant to paragraph #2a of the Commission's order in this matter, BPXA will provide monthly progress reports on the status of the final three actions listed above (database enhancements, policy and procedure modifications, and training) until all are complete. BPXA has taken this incident very seriously and I remain committed to ensure that we conduct our field operations in a safe manner, and in compliance with all applicable regulations and orders. Please do not hesitate to contact me at 564-5671, or GPB' s Operations Integrity Manager, Bruce William 564-4632, with any questions or concerns. ....,,'~' /G Mauree 0 son Vice President, Greater Prudhoe Bay #6 11/19/2004 08:23 1 907':" ~\491 7 ) GATHERING CEI"· -1 2 ) PAGE 01/02 '" r...C.E. .... P~A.C.E.. LOCAL 8..369 Bac P-8 Ançhorag8!1 Alaska '15'5..6612 (107)":51.2320 FAX (901~"5.-232D Paper ~ Allledoolnductrlal, ChemÎcal and Energy Workers Intematlon.' Unlon~ AFL..cIO . , November 19~ 2004 John Not't11aß., Commissioner. Alaska Oil and Gas Conservation Conunission 333 W. 7th Ave #100 Anchorage, Alaska, 99501-3539 William F. Bocast P ACE Health and Safety Representative BP Bargaining Unit PACE Loca18~369 C/O BPX, North Slope, Mailstop P-8 PO Box 196612 Anchorage, Alaska 99519 Dèat COmnJissîoner Norman: The Paperworkers, Allied Industrial, Chemical and Energy Workers Union (PACE) represents over 200 North Slope workers employed by BPX, Alaska. The BP employee injured in the well A-22 explosion was one of our Union members. OUT members work on the other oil wells on BP's lease. We like to express our support oftbe Alaska. on and Gas Conservation Commission ~ s enforce.ment action against BP for deficiencies noted with the operation of the well known as "H-l1". We believe any reduction in fmes and penalties would be unwarranted. We believe engineering controls and timely repair of wells with annular pressure problems are much more appropriate than the over~reliance on administrative controls which failed in ilie H-l1 incident. A universal safety maxim is that when you rely on the hum~Ul factor for safety, you a.re relying on the weakest link of your safety system. We have made recommendations to BP in the past, and BP's own Alaska $afcty Ha.ndbook. lists engineering controls as the first priority in reducing hazards. BP internal investigation also revealed tbe additional workload put on the Field Operators i11 charge of their wellpads by the fi'equent shutdoWDS and startups of Gathering Center 1 and its associated wellpads. We contend that BP~s use of replacement Process 11/19/2004 08:23 ,., 1 907Ç '""\491 7 ) GATHERING CEI"--, 2 ) PAGE 02/02 Automation Control technicians greatly contributed to the unstable operation of Ga.thering Center 1. BP, jn ourview~ has accepted deficiencies in its operation in order to reduce costs and prevail in its ongoing labor dispute which has resulted in our PACE PAC technicians being on strike again,st BP. While BP has hired additional Field Operàtors~ they are still in training, and the experien.ced Field Operators have multjple wellpa.ds for which they are responsible. We understand the Commission's view that jt is inappropriate for AOGCC to intervene in a 1abor dispute, but we believe the Conunission needs to understand the context in which GCl was experienci.ng operational difficulties and subsequent loss of oil production and revenue to the State of Ala.ska. Gathering Center 2 was also starting up at the same time as the H~11 oversight occU1Ted~ and Field Operators were severely taxed to respond to all these multiple demands on their services. We urge th~ Commission to require BP to commit a.dditional workover resources to fIX these wells with annular communication problems. 'fhank You ~lfm~ PACE Health and Safety Representative #5 11/22/2004 09:28 1907FJ::84917 ) GATHERING CEN~~R 2 ') PAGE 01/19 -'- 0"· b .. P bp Exploration Memorandum ... ,;' To: Distribution Date: November 12. 2004 From: Roger Reddin/Jack Fritts Subject: Incident Investiaation: Well H.11 OA Qver·l!ressure Il'lclde-"t Attached is an investigation report covering the incident where outer annulus pressure readings were not recorded in Logbook for GPB weU H~11 during the time frame of August 19 to September at 2004. Quta'" annulus pressure for well H..,11 was allowed to exceed 1000 psig during the time frame of September 9-18,2004. Please distribute further for review and discussions in toolbox and safety meetings. Concur: DI.tribution~ GPB Field Manger ACT! Field Møn~ger GPB Operations Manager MB 5-2 MPUL·1 PRB-10 GPB Ops Support Manager Don Enslow ACTI Operations M$nager PACE"HSE Commfttee E-1 MB 11-6 MPUL·1 P-8 BU Saféty Team Leader H-6 Signed Orlglnsl GÞ13 Safety NS E:ngineer H-6 Electronic Version GPB Safety NS Engineer E-MeU Internal Distribution: Performance Unit Leaders: Maureen Johnson Don Nicolson MB 5-1 MB 11-5 Add~ional: Daren Beaudo Fritz Gunkel Len Seymour Robert Batch MB 13-4 MB 5--1 MB 8-2 MB 11-6 1 ",~ ("", '\, ~, \þ'-; ''1,:'''' .,: \~.., ,~~ ug ~ " C'" ~' I :/ (:,~. ..' ." "J .......) / ' !~;-~ {~I :;,", ~'i'Ì 1~~tA:C'i' ",. ~ .'¡ , '.ìt. !·,(;~'4'i·· )ì" /:X~ :,"1~ '" U". I ;) PAGE 02/19 Well H-l1 OA Over-Pressure Incident fR NO.1 089480 10-14-2004 Investigation Initiated: IR No. 1089480 Well H~11 OA Over-Pressure Incident Investigation Report GA THER I NG CEI'........,R 2 ') 1907("' "',Q491 7 ) 11/22/2004 09:28 , 11/22/2004 09:28 1907r ~q)l 7 GATHERING CEt"~-"""R 2 ) Table of Contents INTRODUCTION Incident Description Methodology Terms of Reference Causal Factors INCIDENT DESCRIPTION AND RESPON~SE Sequence of Events I ncident Description Incident Response FINDINGS, CAUSES & RECOMMENDATIONS Action Item Recommendation Table REFERENCES and APPENDICES IR No. 1089480 Well H-l1 OA Over-Pres.sure Incident IR No_ 1089480 PAGE 03/19 "A .' Page 1 of 18 11/22/2004 09:28 1907~¡::;g4917 ) INTRODUCTION Incident Description: GATHERING CENT~~ 2 ) PAGE 04/19 .. J' Outer annulus pressure readings were not recorded in Logbook for GPB well H-11 during the time frame of August 19 to September 8, 2004. Outer annulus pressure for well H-11 was allowed to exceed 1000 psig (limit for normal wells) during the time frame of September 9 to September 16, 2004. Methodolo9'i The purpose of this report is to document the findings, causes, reoommendations and action items identified during the investigation. The team utilized Root Cause Analysis investigative techniques and the Comprehensive List of Causes methodology to identify immediate and system cause(s) of the incident prior to developing recommendations. Terms of Reference An inquiry was conduoted on the H-11 unrecorded pressure reading and the OA Overpressure Incident which occurred on 9-9-2004, at approximately 22:00 hrs. The investigation team consisted of the following members: T earn Leader: MPU, Ops Manager Members: MPU Well Ops Coord. EOA Drillsite Op. PACE HSE Representative Safety Representative The team was assisted by: GPB Ops Integ Manager Field TL Field AMC GC-3 Area Manager GC-3 Area Manager Wells Staff Engineer Well Integrity Coord. Well B-1 L OA Over-Pressure Incident lA-No. 1089480 Jeff Michels Mark O'Malley Konrad Schruf Mike Suttles Darrell Shanholtzer Bruce Williams Bruce Weiler Jerry Meek Tom Simpson Henry Herrington Harry Engel Joe Anders Page 2 of 18 11/22/2004 09:28 1907'""'Q4917 ) GATHERING CE~'--'R" 2 ,) PAGE 05/19 The investigation team convened On October 14,2004, and completed on October 17, 2004. ;9 The following issues were to be investigated; o What were the root causes of failing to record pressures on well H-11 while the pad was shutnin and safed out? o What were the root cases of allowing the outer annulus pressure on well H-11 to remain in excess of 1000 psig after the well was started back up. o What are the system causes (using CLC) of these breakdowns? o What are the recommended actions to prevent reoccurrence? Well H-11 OA Over-Pressure Inddent IR No. 1089480 Page 3 of 18 11/22/2004 09:28 1907f,i=94917 ) GATHERING CENT~~ 2 ) PAGE 05/19 _C.AUSAL FACTORS Immediate Causes: .þ For not entering weekly H..11 well annulus pressures into Logbook, the immediate causes were: There was decision error or confusion by Operators about the need to reenter into Logbook the well annulus readings due to the Well Pad being totally shutdown, depressured, safed out and stabilized (4-1). For allowing H..11 well outer annulus pressure to exceed 1000 pSÎg for 9 days, the immediate causes were: The H-Pad operators failed to bleed the outer annulus pressure on well H-11 to keep it below the 1000 psig limit. The Wells Team did not follow their common practice to communicate to Operations that excessive OA pressure existed on H-11 (5.5). Contributing Factors: During the time period that pressure readings were not recorded for H-11, there was a misunderstanding by all the Operators on this pad run about the need to reenter Logbook readings since H-Pad was shutdown, de-pressured, sated-out and stabilized. There was no question that HSE walkthroughs had to be performed (as evidenced by Logbook entries during this time period); however; since production and injection operations had been stopped at H-Pad and annulus pressures had stabilized, the Operators thought that the previous readings would carryover in the system and thus did not believe ìt was necessary to reenter annulus pressure readings into the Logbook system. Also, in the cOurse of the investigation the investigation team noted that the current Logbook and Well Integrity Diagnostic system initiates a notification to the Well Integrity Coordinator on a 14 day interval instead of a 7 day interval tor pressure recordings missing from the database. Duríng the time period that well H-11 outer annulus pressure was allowed to exceed 1000 psig, GC-2 was starting back up after a significant planned outage and GC-1 was having operational problems. This created several high priority actions for the H/Y/P/Q pad operators to manage and caused those priorities to change fairly often (driven by several unplanned shutdowns and restarts at GC1). Well Ii-I J OA Over-Pressure Incident IR No, 1089480 Page 4 of 18 11/22/2004 09:28 1 907r ~g)91 7 GA THER I NG CEI""'-9- 2 ) PAGE 07/19 For context, the investigation team noted that the HYPQ Operators reported that during the time that well H-11 OA pressure exceeded 1000 psig they were responding, to maintenance activities, H-Pad start-up, and the operational problems at the well pads associated with GC-1 (which changed work load priorities for both day and night shifts). They further explained that this pad run (assigned to one operator position) has 4 well pads with over 107 wells that flow to 2 Gathering Centers (Y, P, and H-Pad LP production flow to GC-1; Q~Pad flows to the GC-1 Annex, and; H..Pad HP&LP production flows to GC"2). During the investigation interviews, operators expressed there were distractions at this time due to the activity levels. As an example, one operator expressed that although he had completed the Well Integrity System Policy training, he forgot after the first day that H-11 was a Normal We[ and not a Waivered Well where the higher annulus pressure would have been acceptable. :.J System Causes: For not entering well annulus pressures into Logbook, the system causes were: . Inadequate knowledge transfer - the Operators did not fully comprehend that the Well Integrity System POlicy directive and well operating procedure requirements for entering and recording well annulus readings is also required when a well pad was shut-in, depressuredt safed out and stabilized (7-1). The Operators knew that readings were required when a well pad is in operation, and that HSE checks were always required (as documented in the Logbook) (7 -1 ). In reviewÎng the Conservation Order 492, the Well Integrity System Policy, the Well Operating procedures and the E-Book training modules, the Investigation Team noted that it is not absolutely clear in these documents that pressure readîngs are specifically required for shut-in and stabilized wells. For allowing H-11 well outer annulus pressure to exceed 1000 psig for 9 days, the system causes were: Poor judgment - the operator had training on the Well Integrity System Policy and well operating procedures, but did not choose an appropriate course of action to either shut-ìn the well or ask for help to bleed the outer annulus (3- 1). The investigation team noted that the operator had options to allowing the pressure to exceed 1000 psíg which included shutting-in the well, communicating the need to bleed the pressure to the day pad operator, or communicating the need to his Lead Operator or Field Team Leader. Well H-ll OA Over-Pressure Incident IR No. 1089480 Page 5 of 18 11/22/2004 09:28 1 907" ~ "14)17 GATHERING CEN~-9,2 ) PAGE 08/19 Preoccupation with problems - the Operators had to deal with 4 well pads with 107 wells flowing to both GC-1 and GC-2. GC-2 was just starting up and GC-1 was having operational problems that resulted in it shutting down and starting up multiple times (4-1) Inadequate communication between different organizations- the Well Integrity Engineer could have i'nfolTlled the Pad Operator that H-11 OA pressure was excessive as shown on the Well Integrity Diagnostic Report (15-3). Although this communication is not required by written policy standards or , procedures (since well operations and readings are the operators' responsibility), it is a common praotioe. In working to investigate the incident, it was determined that the Well Integrity Engineer had noticed the exoessive OA pressure on H-11, but knew the well had recently started up and since the operator had recorded the pressure assumed the operator would be bleeding the annulus pressure according to policy. ¿ Noncontributory Findings: The investigation team identified potential deficiencies in electronic data transfer between Logbook and the Digital Wellfile databases. While these potential defioiencies did not in the team's view.contribute to the H-11 missing data incident, the team suggests that further evaluation of the accuracy of data transfer and between these systems is warranted. The risk rank for this incident is 1 (High) as determined using the Severity Index. Well H-l1 OA Over~Pressure. Incident IR No. 1089480 Page 6 of 18 11/22/2004 09:28 1907Fr'14917 ) GATHERING CENT~~ 2 ~) PAGE 09/19 INCIDENT DESCRIPTION AND RESPONSE ;; Sequence of Events (Tirneline leading up to, during and after incident) Date 8-12- Event H- Pad was shut in for Tum around at GC-2. OA record recorded at 500 psi. H Pad HSE Walk-through was completed by Pad Operator Operator checked wells for Tree Leaks- None found H Pad HSE Walk-through was completed by Pad Operator Operator checked wells for Leaks H Pad HSE Walk..through was completed by Pad Operator Operator completed reads/walk-throughs Operator completed walk-throughs Operator completed walk..throughs Operator completed walk-throughs Operator completed walk-thrOughs Operator completed walk-throughs Operator completed walk-throughs Operator completed walk"'throughs Pressure test Skid 54 with H-11. H-11 flowing tiJ GC~1 GC-1 sId at 12:02 pm, H-11/32 shut in.. H-11 brought back on that evening to GC-1. H Pad HSE Walk-through was completed by Pad Operator H-11 was diverted to GC-2- OA reoorded on H-11 @ 1600 psi H Pad HSE Walk-through was completed by Pad Operator. OA recorded on H-11 @ 1600 psi H Pad HSE Walk-through was completed by Pad Operator- OA pressure recorded on H-11 @ 1620 psi H Pad HSE Walk-through was completed by Pad Operator- OA pressure recorded on H.,11 @ 1650 psi- H Pad was State Tested- H-11 was noted @ 1650 psi by AOGCC Inspector. H Pad HSE Walk-through was completed by Pad Operator- OA pressure recorded on H-11 @ 1680 psi H Pad HSE Walk-through was completed by Pad Operator- OA pressure recorded on H-11 @ 1700 psi H Pad HSE Walk-through was completed by Pad Operator- OA pressure recorded on H-11 @ 1680 psi 8-13 8-14 8-15 8-16 8-17 8-18 8..27 8-28 8-29 8-30 8-31 9~1 9-2 9-3 9-6 9-7 9-8 9-9 9-10 9..11 9-12 9~13 9-14 9-15 9-17 Pad HSE Walk-through was completed by Pad Operator- OA pressure recorded on H-11 @ 1740 psi. Bled OA from 1750 psi to 400 psi, mostly gas and turned to Arctic Pak in the end. (Note: Two Well B-l1 OA Over-Pressure Incidenl 1Ft No. 1089480 Page 7 of 18 11/22/2004 09:28 1907í"·g4.917 ) GATHERING CE~'-""'~, 2 ) PAGE 10/19 9-18 entries were logged on this datef one of which could have' been data for the 16tH.) H Pad HSE Walk-through was completed by Pad Operator- OA pressure recorded on H..11 @ 400 psi H Pad HSE Walk-through was completed by Pad Operator- OA pressure recorded on H-11 @ 0 psi- Well shut at 09:00 to test Well H-32. H-11 POP @ 17:50. H Pad HSE Walk-through was completed by Pad Operator- OA pressure recorded on H-11 @ 0 psi. AOGCC email to Well Integrity Coord. reporting inspectors discovery of H-11 OA~ 1650 psi on 9- 12 and requested additional information. H Pad HSE Walk-through was completed by Pad Operator- OA pressure recorded on H-11 @ 600 psi. Well Integrity Coord. responded to AOGCC. H Pad HSE Walk-through was completed by Pad Operator- OA pressure recorded on H-11 @ 600 psi H Pad HSE Walk-through was completed by Pad Operator- OA pressure recorded on H-11 @ 980 psi. DHD out to monitor Well- H- 11- DHD put the OA on list to flush and bleed- OA bled down from 980 psi to 0 psi.. Has Arctic P þ1k in it. H Pad HSE Walk-through was completed by Pad Operator- OA pressure recorded on H-11 @ 980 psi per Operator Log. H Pad HSE Walk..through was completed by Pad Operator- OA pressure recorded on H-11 @ 980 psi per Operator Log H Pad HSE Walk-through was completed by Pad Operator- OA pressure recorded on H-11 @ 0 psi per Operator Log (Nights), DHD reports 980 pSi.(Days) DHD pump/flush and bleed OA. OA breached to conductor, well shut-in! DHD bled IA to LP pressuret ACS out to clean up Diesel in cellar, Flow line to be freeze protected, PE group to evaluate next step. AOGCC contacted GC-3 Area Manager requesting additional historical operations information and copies of Standard Operating procedures. GC-3 Area Manager provided this information to AOGCC. An Incident Investigation Team started to be formed. The Incident Investigation Team started work. 9-19 9-20 9-21 9-22 9-23 9-24 9-25 9-26 10-8 1 O~ 12 10-14 Well H-II OA Over~Prcssure Incident IR No.1 089480 Page 8 of 18 ;;- 11/22/2004 09:28 190751:"~A917 ) GATHERING CENTr~ 2 ') PAGE 11/19 INCIDENT DESCRIPTION AND RESPONSE Incident Description ~ On September 6, 2004, H-11 was brought on to pressure test the H-Pad manifold. Flow directed to GC-1. On September 7, 2004, the day shift Pad Operator put on production (POP'd) well H- 11. On September 9, 2004, the night shift Pad Operator recorded in the Logbook that well H-11 OA pressure was 1600 psi. On September 17, 2004, the new night shift Pad Operator bled H-11 OA from 1750 psig to 400 psig. On, September 20,2004, at approximately 15:06 hrs, the BP Well Integrity Coordinator (WIC) received an amaH from the State of Alaska, Alaska Oil & Gas Conservation Commission that a State Inspector performing a SVS test at H-Pad noted a well with a outer annulus (OA) pressure of 1650 psig on a well that did not appear to be waivered for pressures in excess of 1000 psig. The State of Alaska requested information concerning tubingl inner annulus/ outer annulus pressure communication. On September 21, 2004, at approximately 11:10 hrs, the BP Well Integrity Coordinator responded to the State of Alaska stating that the Operator had bled the OA pressure to 400 psig and that it did not re-pressure. The WIC also stated that the well had been shut-in On 9/19 to test its twin, H-321 and that the OA was currently on a vacuum. The WIC submitted to the AOGCC information, including graphs of tubing, lA, and OA pressure for the period in question On October 7, 2004, the AOGCC contacted the GC-3 Area Manager noting that the information submitted by the BP WIC showed that the annulus pressures had not been updated for what appeared to be -3 weeks before the OA overpressure incident. Incident ResQonse On October 8, 2004, BP GPB Operations management started tò investigate why no pressure readings had been taken for an extended period of time and what caused the OA to remain over-pressured for 9 days. Interviews of Well Pad Operators and data gathering began by the FieJd TL, the GC-1 and GC-2 Area Managers. On October 14, 2004, the Incident Investigation Team that authored this report was formed and reviewed the information gathered by others and performed some additional interviews before generating this Incident Report. Well H-ll OA Over-Pressure Incident IR No. 1089480 Page 9 of 18 FrNDfNGSt CAUSES AND RECOMMENDATIONS Fjnding Causes Recommendatron Action Items Responsible Party Target Date Well annulus 1) Oecisjon error 1 a) Immedrate'y 1 a) Same as GPB, Operations 1 0-31-2004 readings were not or confusion req uire all Area recommendation Manager documented from about need to Managers to 8/19/04 to 9/8/04 reenter rnto communrcate with Logbook the all Wen Pad and operations Drill Site operators readjngs due to to refresh them on Wen Pad bejng the Well Integrity totally shutdown, Policy and clarify depressured, expectations for safed out and recording stabílized. (4-1) operations readings wh en wells and pads are shutdown. . 1 b) Present the 1b) Same as Well Integrity 1 0-31-2004 WeU Integrity recommendation Coordinator DiagnosUcs Report 10 the Area Manager in each Operating Area across the Business Unit with communicat10n emphasis on sustained casing pressure and ... missing pressure Wen H-l1 OA Over-Pressure Incident IR No.1 089480 Page 10 of 18 \'\0. , I--" I--" ........ .t...) tV ........ t...) (S) (S) - .p.. (S) lD tV co I--" lD (S) -.,J T'} ,1 .j) . ! .p.. -lD I--" -.,J G) J> -I I £TI :;0 H Z G) -0 £TI 7' 1 1 );0 '~I\J -.. . -u J> G) £TI I--" I\J ........ I--" lD reports. 1c) Develop a 1 c} Same as Production 3-1-2005 Wen Management Recommendation OptimizatÎon TL Report that provides daHy well integrity information to Area Managers and Lead Operators to ensure compliance with regulations and local poJicy 2) Conservation 2} Modify the 2) Same as ADW WeJl Ops 12-31-2004 Order 492, Well Well Integrity recommendations Sup v Integrity System System Policy, PolicYl Operating Procedures and Procedures and Training Materials Training Materials to clarify are not absoluteJy requirements to crear on specific read and record data recording data associated requirements for with Shut In, Shut Shut In, Shut Down and Down and stabiUzed wall stab ilized weJl operations operations .. Well H-ll OA Over-Pressure Incident I A No. 1089480 Page 11 of 18 ~ .f-' f-' "- . . /'\) t-.J "- t-.J CS) CS) - .p.. CS) LD t-.J ro f-' LD CS) -...j I) -, ,;) P. ~LD f-' -...j G) D --I I fT1 AJ H Z G) () fT1 '7 ï i AJ --- t-.J -u --.... D G) fT1 f-' W "- f-' LD ·3) Operators 3) Comprete a BU 3) Ensure aU Wen GC3 Area 3-31-2005 thought the wide refresher Pad and DriJl Site Manager pressure readings trai n ing to clarify operators onty had to be expectations of complete training reentered during Weill ntegrity in the revised shut down System Policy. trainfng modufes. operations if the (5.8.1) with GAP had changed emphas;s on fro m the previous recordrng every reading; they well's annulus thought the pressures during previous reading normal, shut-in would carry over and shut down (Contributing operations. Facto r) .. 4) Current Log 4) Change the 4) Sarna as Well Integrity 12-31-2004 Book and Well Well Integrity recommendation Coord. Integrity Diagnostics Diagnostic Report Report to a]ann in iti ates a Missing Pressure notifìcation on a data from 14 to 7 14 day interval day interval instead of a 7 day interva' which is required by policy, (5-5) .. Well H-l1 OA Over-Pressure Incident Iff No, 1089480 Page 12 0118 ·'10 . I-" I-" "'- t-J 1'0 "'- '\,) (S) (S) ..¡::.. (S) lD '\,) co I-" lD (S) --..J TI J .0 ~~ I-" --..J G) D -; :r: fT1 :;0 H Z G) () fT1 "Z ~ 1 ¿(J .~'\,) lJ D G) fT1 I-" ..¡::.. "'- I-" lD Finding Causes Recommendation Action ttems Responsible Party Target Date OA pressures 5) Pad Operators 5a) Immedjate~y 5a) Sarna as GPB Operations 1 0-31..2004 exceeded 1 000 logged excessive require all Area recommendation Manager psi from 9/9/04 to pressure but Managers to 9/17/04 fa ii ed to take communicate with immediate action all Well Pad and (4.1/4.2). DrÏII Site operators to dearly reinforce company expectations that pressu ra limits are not to be exceeded by any amount without ta king co rrec1ive action. . 5b) Re-emphasize 5b) Present Wefllntegrity 1-31-2005 to Operators that revised Well Coord. pressure limits are Integrity System not to be Policy to Well Pad exceeded by any and Drill Site amount without Operators in each taking corrective area. action. 5c) In logbook, 5c) Same as GC-2 Area 3..1-2005 make a recommendation Manager mandatory dialogue box 1he .. Operator must 'V ell H-ll OA Over-Pressure Incident IR No. 1 089480 Page 13 of 18 '\'.. .1-> I-> ...... . I'\J I'\J ...... I'-.) (S (S . .p.. (S LD I'-.) ()j I-> LD (S -..j TI 1 ~ ,-P>. ___LD I-> -..j (j) D --I I TJ ;u t-f Z (j) (') TJ "Z 1 I _.ù ~-I'-.) -u D (j) TJ I-> Ul ...... I-> LD acknowledge in the event the new entry exceeds the maximum allowable casing pressure before the Operator can procee d with fu rth er data ent IY. 5d) Modify 5d) Same as GC-2 Area 3-1-2005 Logbook to recommendation Manager highJight input annulus pressures that exceed maximum aHowabfe casing pressure 6) Preoccupation 6) Reinforce to H- 6) Same as GC-3 Area 11-30-2004 with high activity Pad operators the recommendation Manager levels during the expectation that time that the H-11 policy and safe OA was allowed practices are top to exceed 1 000 priority - if work psrg nmit activity is too high to manage it all safely þ then the operator is expected to shut work down to ... allow for safe Well H-Il OA Over-Pressure Incident I R No. 10694BO Page 14 of 18 \> '1-" I-" ........ t-.) I'.) ........ I'.) ($) ($) .p. ($) LD I'.) co I-" LD ($) -..J T1 ;l ..::D ~.p. LD I-" -..J (j) 1> -; I fTI :;0 H Z (j) (") fTI '7 j 1 ~ c~'N -0 1> (j) fTI I-" C1l ........ I-" LD operations. 7) Inadequate 7) Re-emphasize 7) Same as ADW Well 1 0-31-2004 communication - to Wen Integrity recommendation Operat'ons Wells Integrity team members Supervisor. Team did not that pressure follow their limits are not to be common practice exceeded by any to communicate to amount without Operations that taking corrective excessive OA action. If pressure existed. excessive pressures are found, they are to contact the Area Manager to notify th at co rrectJve action ;8 required WeB H-ll OA Over-Pressure Incìdent IR No. 1089480 Page 15 of 18 \). , I-' I-' "- tv tv "- N CS) CS) ,- .p.. CS) LD N co I-' LD CS) -J TI 1 ,~ ,.b. ·~LD I-' -J (j) D -; :r: fTI ::;0 H Z (j) o fTI "Z I i ~..¡J ,,--'. f\J 'lJ D (j) fTI I-' -J "- I-' LD Noncontributory Cause Recommendation Action Items Responsible Party Target Date Finding Potential 8) Logbook 8) Investigate how 8) Same as 3-1-2005 deficiencies in system data Logbook works Recommendation Harry Engel efectronîc data transfers to other and determine if transfer between we n integrity there are Logbook and databases appear problems other well ìntegrjty to have committrng data databases deficiencies that transfers may result in data not being recorded, \VelJ A-II OA Over-Pressure Incident r R No. 1089480 Page 16 of18 \,. , t-> t-> ......... to I\) ......... I\) (S) ,(S) -..p.. (S) ill I\) co t-> ill (S) -..j TI 11 B ---./~ t-> -..j G) D -t :r: fTI AJ H Z G) o fTI -z: :-f 1 ;{J -I\) -u D G) fTI t-> co ......... t-> ill 11/22/2004 09:28 19071="'"'14917 ~) GATHERING CE~~-~ 2 ) REFERENCES H-Pad Wen Operator Logbook reports from 8/1/04 to 9/??/04 Well Annulus Pressure Report for Well H-11 Graph of H~11 tubing/ IAlOA pressures for period in question. Well Integrity Diagnostic Report dated 9/13/04 as an example E-Book Procedures Traccess Training Modules WelJ B-1 J. OA Over-Pressure Incident JR No. 1089480 PAGE 19/19 .~ Page 17 of 18 #4 bp ') ) BP Exploration (Alaska) Inc, 900 East Benson Boulevard PO, Box 196612 Anchorage. Alaska 99519-6612 (907) 561-5111 November 10t\ 2004 Hand-Delivered Commissioner John K. Norman Chair, Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, Alaska 99501 r"'",~,:',' ~' ,~ NOjl 1 LV r~,I~~k~k g~ G,~ Q.1;)~" (~;'mm~'ì~¡'¡)(i' RE: PBU H-11 Surface Casing Dear Commissioner Norman: Thank you for the opportunity to respond to your October 25, 2005 request for additional information regarding the subject well. H-ll is an Ivishak producer with a rate of approximately 350 BOPD, 85% water cut, 20,000 Gas to Oil Ratio and estimated remaining reserves of approximately 330,000 barrels of oil. The well was secured with a tubing tail plug after the surface casing failed during an arctic pack flush procedure on September 26,2004. We believe external corrosion of the surface casing to be the likely failure mechanism. This can occur at the cement top of the surface casing where water and oxygen can create a corrosive environment. Positive confirmation of the failure mechanism would require a rig workover to recover the surface casing. This type of rig workover is not a routine or standard procedure and has the potential to create a situation where the well could be rendered inoperable. H-ll's estimated remaining reserves do not economically support the $3,500,000 to $4,000,000 required to complete this procedure, Under these circumstances, our current plan is to conduct diagnostic tests to evaluate the integrity of the well. The evaluation will include a mechanical integrity test of the outer annulus with nitrogen to locate the surface casing leak point. Additional integrity tests will provide information to evaluate the condition of the tubing and production casing, The results will be evaluated to conclude if the well is safe to operate, and, if so, to restore production. Additionally, periodic testing would be conducted to confirm well integrity. We will keep the AOGCC informed of the progress of these diagnostics and, if we determine it is appropriate to restart this well, will notify the AOGCC before restarting it pursuant to your request. In closing, I'd like to note that the H-ll surface casing did not fail during production, it failed under controlled conditions as the diagnostics crew was attempting to flush the arctic pack as part of their well diagnostics procedures. Thus, although we acknowledge the delay in addressing the high outer annulus pressure in B-11, our diagnostics policies and procedures were successful in locating the problem with the surface casing in a safe manner. #3 bp ) ) BP Exploration (Alaska) Inc, 900 East Benson Boulevard p. 0, Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 November 10th, 2004 Commissioner John K. Norman Chair, Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, Alaska 99501 Hand-Delivered Re: Proposed Enforcement Action - PBU H-11 Well Annulus Pressure Dear Commissioner Norman: Thank you for the opportunity to respond to your letter dated October 25, 2004, advising of the Commission's proposed enforcement action for violations of Conservation Order 492 and 20 AAC 25.526 in connection with annulus pressure monitoring of Prudhoe Bay Unit Operating Well H-11. As discussed below, BPXA does not contest the proposed enforcement action, although it asks the Commission to re-evaluate portions of the proposed action, While BPXA will respond to any request from the Commission for additional materials, BPXA is prepared to have the Commission make its decision on the current record, as supplemented by this letter. I. BACKGROUND FACTS On September 26, 2004, the surface casing of PBU Well H-ll failed during an outer annulus flush procedure which was being performed by the well diagnostics crew. As reported in my letter to you dated October 14, 2004, prior to the September incident, H-ll was classified as a normal well. H-ll was shut in beginning August 18, 2004, during the period that Gathering Center 2 ("GC-2") was down for maintenance, and was returned to uninterrupted production on September 8, 2004. Prior to August 18, the outer annulus pressure ("OAP") was monitored and recorded at approximately 500 psi. During the period that H-11 was shut in, the OAP was observed daily by H pad operators. The operators report that the OAP remained constant during the GC-2 shutdown, but the daily OAP readings were not recorded on the Logbook computer system. Apparently, some operators misunderstood the need to reenter data when the wells and well pad were shut in and safed out, as well as how the Logbook computer system functioned. With the well shut in, the operators believed that the system would automatically carryover recordings of the daily observations of a constant OAP of 500 psi until new data were entered. The operators' understanding of this aspect of the Logbook system was incorrect. Although some data management programs in use at the PBU carryover data automatically, data must be entered into the Logbook system or they do not appear. BPXA appreciates that your letter of October 25 reflects that the Commission understands this aspect of the case. Con=umssioner John K. Nor!. ) Page 2 November 10th, 2004 ) Following the shut in period, H-ll was returned to service as a flowing well. As the well returned to production, it generated heat, as do all wells, and the OAP rose. On the evening of September 9, our operator noted that the pressure was 1600 psi, the first indication that the well was experiencing higher than normal OAP. Three days later, on September 12, 2004, the state inspector witnessed the Surface Safety Valve tests on H Pad and noted that the H-11 OAP was 1650. On September 17, 2004, the H pad operator bled the OAP on H -11 from 1750 to 450 psi. On September 20,2004, AOGCC staff member Jim Regg contacted BPXA well integrity coordinator Joe Anders about the OAP that had been observed by the state inspector on September 12. Mr. Anders sent Mr. Regg the TIO (tubing, inner annulus, and outer annulus pressure) plot for H-11 and further explained that the well had since been bled down and shut in to test its twin. On September 23, 2004, a diagnostic crew bled the H-11 well from 980 psi to 0 psi. Three days later, on September 26, 2004, the diagnostic crew performed an Arctic Pack flush of H-11, during which the OAP surface casing failed at 2000 psi, causing five gallons of Arctic Pack to bubble into the well cellar. The well then was secured with a tubing tail plug and BPXA notified the AOGCC of this action. The well remains shut in and secured. An investigation conducted by BPXA following the incident indicated that BPXA's well pad operating procedures were not adhered to in connection with the start-up of well H-ll: · Annular pressure data were not recorded into the Logbook computer system at the prescribed frequency; and · The outer annulus pressure of H-11 was not managed to keep it below 1000 psi during and following the re-start operations. The Commission proposes to impose penalties for violations of Rules 2, 3, and 6 of Conservation Order 492 and 20 AAC 25.526. As indicated above, BPXA does not contest the proposed enforcement action, although it asks the Commission to re-evaluate portions of the proposed action. The bases for BPXA's request for re-evaluation are set forth below. II. CONSERVATION ORDER 492, RULE 2 The Commission proposes to impose a penalty for violation of Conservation Order 492, Rule 2, for failing to record and make available on request the results of monitoring the H-ll tubing and annulus pressures during the time period from August 19,2004 to September 8, 2004. By its terms, Rule 2 requires daily monitoring for sustained annulus pressures, but does not impose any express requirement of recording. The rule states: The operator shall monitor each development well daily to check for sustained pressure, except if prevented by extreme weather conditions, emergency situations, or similar unavoidable consequences. Monitoring results shall be made available for AOGCC inspection. BPXA's well pad operators complied with the rule's requirement of daily monitoring for sustained annulus pressures during the time that H-11 was shut-in between August 19 and September 8, 2004. As noted above, operators observed that the OAP was constant at 500 psi during that time period. BPXA also understands that, while the Rule may not expressly require recording of OAP observations, the second sentence of Rule 2 could be read to imply that requirement. If that is the practice the Commission intends to require, BPXA believes that it would be helpful to clarify the rule and state the requirement expressly. CO~SSioner John K. Nor...J Page 3 November 10th, 2004 ) BPXA appreciates that the Commission's proposed enforcement action letter recognizes that the events here involved only a failure on the part of the operators to record OAP readings, not a failure to monitor for sustained OAP, and that the recording failure was a product of a misunderstanding on the part of the operators with respect to how the Logbook computer system functioned. As discussed below, BPXA is taking steps to clarify with operators how the system functions and has reinforced the importance of both monitoring and recording OAP. While BPXA does not contest this portion of the Commission's proposed penalty, we ask that you consider this additional information as you make your final determination. III. CONSERVATION ORDER 492, RULE 3 The Commission proposes to impose a penalty for BPXA's alleged violation of Conservation Order 492, Rule 3, by failing to notify the Commission within three working days of sustained outer annulus pressure in H-ll exceeding 1000 psi. The Commission proposes to impose a penalty for the period from September 9, 2004, through September 21,2004, which was the date the information on H-ll's OAP was provided to the Commission by BPXA in response to a Commission inquiry. BPXA does not agree with this portion of the Commission's proposed enforcement action for the reasons discussed below. First, Rule 3 requires that "the operator.. . notify the AOGCC within three working days after the operator identifies a well as having. ..(b) sustained outer annulus pressure that exceeds 1000 psig." By its terms the rule is triggered only when a well is identified as having sustained pressure. The Commission's proposed enforcement action is predicated on the assumption that such a determination could or should have been made with respect to H- lion September 9, 2004, That conclusion is incorrect, however. "Sustained" outer annulus pressure is not something that is susceptible to being determined instantaneously. As Conservation Order 492 reflects, operating wells can and regularly do exhibit higher than normal pressures for short periods of time during entirely normal operations. Most notably, higher than normal pressures are frequently observed as a consequence of thermal expansion associated with bringing on line wells that have been shut in, but pressures then drop back to normal levels, For a well to have "sustained" outer annulus pressure requires that higher than normal pressures be observed for a period of time and under conditions that are indicative of a cause other than normal operations. As a result, in many instances, it may take a week or more to determine if a well is exhibiting sustained outer annulus pressure. This issue was discussed with the Commission at the hearing on May 27, 2003, in connection with the adoption of Conservation Order 492. [See Hearing Transcript 9:15-25, 10:1-4, and 20:15-22]. BPXA respectfully submits that a diagnosis of sustained outer annulus pressure for H-ll could not have been made on September 9, 2004. The well was started up on the previous day and, although higher than normal pressure was observed on September 9, there was no immediate way of determining whether the high pressure was a product of thermal expansion on start up, or was, instead, indicative of a problem that would generate sustained outer annulus pressure. Rule 3 contemplates that the operator will have sufficient time to conduct diagnostic procedures to determine if an annular pressure condition qualifies as "sustained pressure." Therefore, BPXA submits that the Commission should reconsider and vacate the proposed penalty for violation of Rule 3, and should find that the reporting requirement was not triggered on September 9, because a diagnosis of sustained OAP could not have been made on that date. · Co~ssioner John K. Nor. ) Page 4 November 10th, 2004 ) Second, Rule 3 does not require an immediate notification after sustained OAP is identified; it provides that sustained OAP is to be reported within three working days after it is identified. Consequently, even if it reasonably could be concluded that BPXA should have identified H-ll as having sustained high pressure on September 9 (the first day that higher than normal pressure was observed), under the terms of Rule 3, notice to the AOGCC would have been timely if provided within three days, or by September 12, 2004. At a minimum, any penalty should be calculated starting after that date, not September 9. Thus, BPXA respectfully disagrees with, and requests that the Commission reconsider the proposed penalty amount for the violation of Rule 3, so that any penalty is imposed starting three days after the sustained OAP should have been identified. Finally, if notification of sustained pressure at H-11 was required by September 12, the AOGCC had actual notice of the pressure reading at H-11 on that date. As described above, an inspector for the AOGCC witnessed the Surface Safety Valve testing on H Pad on September 12 and noted OAP at H-ll of 1650 psi. BPXA provided formal notice of H-ll's pressure on September 20, 2004, in response to inquiry by AOGCC staff, and BPXA provided the TIO plot for H-1!. It is undisputed, however, that the Commission was aware of the OAP reading of 1650 psi as of September 12. As discussed above, September 12 was the first possible date by which BPXA conceivably could have been required to inform the Commission of H-11's pressure. BPXA respectfully requests reconsideration by the Commission of its proposed penalty for violation of Rule 3 on the basis that the Commission in fact possessed the pressure reading at H-11 on or before the date by which notification was due under the rule. For the reasons discussed above, BPXA requests that the penalty proposed for violation of Rule 3 be reconsidered and vacated or, at a minimum, reduced. IV. CONSERVATION ORDER 492, RULE 6 The Commission proposes to impose a penalty for BPXA' s alleged violation of Conservation Order 492, Rule 6 and 20 AAC 25.526 for failing to bleed off H-11's OA pressure before it was placed in service on September 9, 2004. The circumstances involving H-11 are quite different from A-22. At the time of the A-22, Conservation Order 492 had not been written and clear regulations for managing well annular pressures did not exist. BPXA will not contest this portion of the Commission's proposed enforcement action because it acknowledges that the well was not bled off before the well reached operating temperatures and pressures.l V. BPXA's RESPONSE TO PROPOSED CONDITIONS In addition to the monetary penalties, the Commission proposes to impose several conditions and operational requirements on BPXA, BPXA will not contest the imposition of these conditions, but has comments on, and requests reconsideration of, several of the conditions, as noted below. The proposed enforcement order appears to require that wells that will exceed 1000 psi at operating temperature be bled before start-up. However, Rule 6 states that such wells need only be bled before being placed in service. When pressures start out low, as in H-ll, it is often not practical or necessary to bleed them down before start up operations are commenced. Such bleeding can result in loss of freeze protect fluids and would be difficult to achieve in swing wells which come on and off at night. However, wells must be monitored during the start-up process to ensure pressures do not exceed those specified for that particular well before the well is placed in service upon reaching operating temperatures and pressures. BPXA believes it would be helpful to clarify this with the Commission. (BPXA does not question that wells that have OAPs closer to 1000 psi should be bled before start up.) Co1Ìunissioner John K. NOl. :~ , Page 5 November 10th, 2004 } 1. The Commission proposes to order that, within 30 days, BPXA provide the Commission with a detailed description of actions, planned and accomplished, to prevent recurrence of violations similar to those that are alleged in connection with the start up of H -11. BPXA will provide the requested information by the date proposed by the Commission. As a preliminary response, BPXA can report that the following steps and actions have been taken: · BPXA has investigated the event. The investigative team consisted of both managers and union representatives, including the Milne Point Operations Manager, the Milne Point Wells Operations Coordinator, the EOA Drillsite Operator, a PACE representative, a safety team leader, and the WOA Production Coordinator. The investigative team was assisted by the GPB Operations Integrity Manager, the Field Team Leader, the Field Area Maintenance Coordinator, the GC-3 Area Managers, and a Wells Staff Engineer. BPXA believes that external corrosion of the surface casing may have caused H-ll's surface casing to fail. Such corrosion can occur at the cement top of the surface casing where water and oxygen can create a corrosive environment. · BPXA has developed plans for diagnostic testing of H-ll and for restoring H-ll to production, if tests indicate it is safe to do so, and after notification to the Commission as requested in the Commission's October 25, 2004 letter.2 BPXA will provide the details for proposed testing in a separate submission. · BPXA has identified shortcomings in executing policies and procedures as a root cause of this incident and has reinforced expectations that operators enter data and record pressures into Logbook, including shut-in wells. · BPXA initiated fieldwide notification on October 13, 2004, alerting the organization of the H-ll incident. The notification outlined the preliminary findings of BPXA' s investigation and directed all area managers to immediately meet with wellpad and drillsite operators to review well operating procedures and well integrity policies and ensure annulus pressures are managed in strict compliance with BPXA policy. · BPXA is evaluating additional methods of documenting and confirming that pressures have been monitored daily. 2. The Commission proposes to order that BPXA provide the Commission with monthly progress reports until all planned actions are completed. BPXA accepts this proposed requirement. 3. The Commission proposes to order that, for a period of 180 days, BPXA provide the Commission with 24 hour advance notice of all PBU well restarts. BPXA perceives a problem with the way this requirement is framed. There are occasions when BPXA does not have 24 hours advance knowledge of a well restart. Numerous operating activities such as maintenance, plant upsets, well work, and the like, and conditions such as ambient temperatures and system pressures can affect the decision of whether and when to restart a well, and changes in those conditions often require actions on less than 24 hours notice. BPXA is able to provide the Commission with its best estimate, 24 hours in advance, of well restarts. It also may be able to provide the Commission with notice as soon as is practicable, when wells need to be restarted on less than 24 hours notice. But BPXA believes it would not always be a sound practice to require that a well remain shut in, and production limited, in order to comply with the proposed 24 hour notice requirement. BPXA believes that a discussion with the Commission about this condition, and the available alternatives, likely would produce a procedure that accommodates the Commission's desire to monitor these activities and, at the same time, would not unnecessarily limit production. 2 The evaluation will include a mechanical integrity test of the outer annulus with nitrogen to locate the surface casing leak point. Additional integrity tests will provide information to evaluate the condition of the tubing and production casing. BPXA will keep the Commission informed of the progress of these evaluations and tests. COImnissioner John K. No!. } , Page 6 November 10th, 2004 ) 4. The Commission proposes that BPXA provide the Commission with documentation of all PBU well pressure bleeds in connection with well re-starts. BPXA does not contest this proposed requirement, but requests clarification of the specific documentation that is requested. BPXA recommends that bleeds be documented in Logbook. VI. CONCLUSION As reflected by the comments above, BPXA acknowledges the concerns of the Commission and does not contest many of the Commission's proposed actions, but requests re-evaluation, and in some instances adjustment, of portions of the findings and penalties proposed by the Commission.3 BPXA does not request either a formal hearing or an informal conference in connection with this matter. It requests only that the information set out in this letter be considered by the Commission and that the Commission modify the proposed enforcement action as it believes appropriate. If the Commission has questions about any of the matters discussed above, or is in need of any additional information, please let me know and we will respond promptly, Thank you for your consideration of these issues. /''''"'''--' Sincerely, "'\. .,/ ----"~,..~.~..... / " ; __......."" .,1'" f,.... -./j~"/""/ " ¿;:;:;:'" i Maureen ns Vice President, Greater Prudhoe Bay Cc: Bradley S. McKim Rosanne M. Jacobsen Jeffrey M. Feldman 3 While BPXA does not contest the Commission's findings and proposed actions with respect to the application of Rules 2, 3 and 6 in these circumstances, in light of the lack of clarity about the intent and reach of the rules, BPXA reserves the right to contest the interpretation or application of the rules in the future. #2 \ ') '~ ) ~1f~1fŒ ffiJ~ iÆ~iÆ~[\iÆ ALASIiA OIL AND GAS CONSERVATION COMMISSION FRANK H. MURKOWSKI, GOVERNOR 333 W. 7fH AVENUE, SUITE 100 ANCHORAGE, ALASKA 99501-3539 PHONE (907) 279-1433 FAX (907) 276-7542 October 25, 2004 Hand Delivered Ms. Maureen Johnson Vice President, Greater Prudhoe Bay BP Exploration (Alaska) Inc. 900 East Benson Blvd. P.O. Box 196612 ~chorage,AJ( 99519-6612 HAND DELIVERED Re: PBU H-l1 surface casing failure. Dear Ms. Johnson: As you know, on September 26, 2004, the surface casing of Prudhoe Bay Unit well H-l1 ("H -11") failed during an outer annulus flush procedure. This surface casing failure re- portedly occurred at about 2000 psig internal pressure. Surface casing failure at such a relatively low internal pressure obviously raises questions about the safe operation of PBU wells and about future PBU well production. We assume that BPXA has been actively investigating and analyzing this event, but if not, the Commission requests that BPXA conduct a thorough analysis of the H-l1 surface casing failure to determine the cause. In either case, we request that BPXA report the re- sults of this analysis to the Commission as soon as it is available. Please provide to the Commission no later than November 10, 2004, BPXA's detailed plans on how it will (1) detennine the H -11 surface casing failure cause, and (2) restore H -11 production. In the Commission's view, H-ll should remain shut in until this matter is resolved to the Commission's satisfaction. If BPXA has a different view, you are requested to notify the Commission before restarting the well, be ause in that event the Commission would an- ticipate issuing an emergency order re rin 11 to remain shut in. onn~ ~1f~1fŒ (ID~ ~~~~~~ ALASKA. OIL AND GAS CONSERVATION COMMISSION / FRANK H. MURKOWSKI. GOVERNOR 333 W. "JTH AVENUE, SUITE 100 ANCHORAGE, ALASKA 99501-3539 PHONE (907) 279-1433 FAX (907) 276-7542 October 25, 2004 Hand Delivered Ms. Maureen Johnson Vice President, Greater Prudhoe Bay BP Exploration (Alaska) Inc. P.O. Box 196612 Anchorage, AK 99519-6612 Re: Notice of proposed enforcement action concerning PBU H-11 well annulus pressure. Dear Ms. Johnson: Pursuant to 20 AAC 25.535, the Alaska Oil and Gas Conservation Commission hereby notifies BP Exploration (Alaska) Inc. ("BPXA") of a proposed enforcement action. The Commission considers that BPXA may have violated provisions of Conservation Order No. 492 and regulation 20 AAC 25.526 in connection with operating well PBU H-11 ("H -11 "). Specifically, it appears that BPXA violated Rule 2 of Conservation Order No. 492, by failing to record and make available on request the results of monitoring the H-11 tubing and annulus pressures during the time period of August 19, 2004, through September 8, 2004. These violations are indicated by gaps in the record ("TIO plot") provided to the Commission by BPXA ofH-l1 tubing pressure, inner annulus ("IA") pressure, and outer annulus ("OA") pressure, covering a time period of approximately one year prior to September 21,2004. Second, it appears that BPXA violated Rule 3 of Conservation Order No. 492, by failing to notify the Commission of OA pressure in H-l1 exceeding 1,000 psig beginning on or about September 9, 2004 and continuing until September 21,2004, on which date H-l1's OA pressure was reported to the Commission by BPXA personnel in response to a Com- mission inquiry. These violations are indicated by pressure data on the TIO plot. .~ Ms. Mauleell JOIlUSUI1 October 25,2004 Page 2 of3 Third, it appears that BPXA violated Rule 6 of Conservation Order No. 492 and 20 AAC 25.526, by failing to bleed off H-l1's OA pressure before it was restarted on September 9, 2004, after having been shut-in. This is indicated by the well's pressure history as shown on the TIO plot and by oral and written reports by BPXA personnel. The Commission proposes to order the following corrective actions by BPXA: (1) that within 30 days after the date of the enforcement order, BPXA provide the Commission with a detailed description of actions, planned and accomplished, to prevent recurrence of violations similar to those that appear to have occurred in connection with the start-up of H-ll; and that BPXA provide the Commis- sion with monthly progress reports until the planned actions are completed; and (2) that for a period of 180 days beginning 10 days after the date of the enforcement order, BPXA provide the Commission with (a) 24 hour advance notice of all Prudhoe Bay Unit ("PBU") well restarts so that the Commission will have an opportunity to witness the restart opera- tions; and (b) documentation of all PBU well pressure bleeds in connection with well re- starts. In addition, the Commission proposes to impose the following civil penalties on BPXA under AS 31.05.150 (a): (1) $2500 per day for each of21 days for violating Conservation Order No. 492, Rule 2 from August 19, 2004 through September 8, 2004, inclusive; (2) $5000 per day for each of 12 days for violating Conservation Order No. 492, Rule 3 from September 9, 2004' through September 20, 2004, inclusive; and (3) $5000 for violating Conservation Order No. 492, Rule 6. The total of the proposed civil penalties is $117,500. Except for the first group of violations, the maximum daily penalty is pro- posed in light of the fact that compliance with Conservation Order No. 492 is mandated specifically to avoid the serious consequences of catastrophic well failure that in fact pre- viously occurred at another PBU well. A lesser daily penalty is proposed for the first group of violations in light of the Commission's understanding that the pressures in ques- tion were in fact monitored and that the failure to record the observations may have been due at least in part to confusion about the workings of BPXA' s well data recording sys- tem. As provided by 20 AAC 25.535 (c), within 15 days after receipt of this notification BPXA may file with the Commission a written response that concurs in whole or in part with the proposed action described here, requests infonnal review, or requests a hearing under 20 AAC 25.540. If infonnal review is requested and BPXA disagrees with the Commission's proposed decision or order after that review, BPXA may then request a hearing within 10 days after the proposed decision or order is issued. ,. ~ Ms. Maureen Johnson October 25, 2004 Page 3 of3 '\ .,~ ') ) If BPXA does not file a timely written response to this notification, the Commission will consider BPXA to have accepted by default the proposed penalty described above and will proceed to issue an enforcement order. If BPXA requires more than 15 days to re- spond, you may for good cause shown request an extension of the 15-day response pe- riod. C) ) ) Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, AK 99501-3539 Phone: (907) 279-1433 Fax: (907) 276-7542 Fax Transmission The information contained in this fax is confidential and/or privileged. This fax is intended to be reviewed initially by only the individual named below. If the reader of this transmittal page is not the intended recipient or a representative of the intended recipient, you are hereby notified that any review, dissemination or copying of this fax or the information contained herein is prohibited. If you have received this fax in error, please immediately notify the sender by telephone and return this fax to the sender at the above address. Thank you. /í5 d To: (~~: . ¿IC /~ ' ' ¿:; 117 i / From:, Jod"j(lólom/iL ¿ - / Phone #: ß jJ ¡¿d· . Date: 7J:J /ftL9·ó51 7 //-/0(/ . ( 5 Fax #: Subject: Pages (including cover sheet): Message: ~/-k/~ ô;::- /¢~'-I If you do not receive all the pages or have any problems with this fax, please call for assistance at 907 793-1223. #1 bp \ ) ') ') BP Exploration (Alaska) Inc. 900 East Benson Boulevard PO, Box 196612 Anchorage, Alaska 99519-6612 (907) 561-5111 October 14th, 2004 Commissioner John K. Norman Chair, Alaska Oil and Gas Conservation Commission 333 West ih Avenue, Suite 100 Anchorage, Alaska 99501 RECEf\/ED OCT 1 4 2004 Alaska Oil & Gas Com;, ..~¡Anmi5sion Anchorage Re: H-11 Information Dear Mr. Norman: The purpose of this letter is to provide you with our initial asseSSlnent of field operations related to an early September 2004 start up of Prudhoe Bay Well H-11. A summary of this information was communicated verbally to Winton Aubert on October 8, 2004 by Harry Engel. H-11 was classified a normal well at the time of the early September 2004 start-up. The well was shut in from August 18th to September 8t\ 2004 during the period GC-2 was down. During this period the outer annulus pressure (OAP) was observed by Operators but not recorded in the Logbook computer system. Prior to August 18,2004 the OAP was approximately 500 psi. The H- Pad Operators have said the OAP remained constant during the GC-2 shut down. Some Pad Operators misunderstood the functionality of Logbook. They believed the system automatically carried over data if new data was not entered. In fact, data must be entered into the system or it appears absent. Operators have been informed regarding the system for entering data into Logbook. Operators are expected to record pressures into Logbook at least weekly for normal wells. When H-11 was brought back on line in early September 2004 we believe the OAP was approximately 500 psi. On the same evening the OAP in H-11 was recorded at 1,600 psi. At this time we have not determined the root cause as to why the OAP was not managed below 1,000 psi while the well was started up. We have taken immediate actions to ensure this will not occur again. This incident has been communicated to the workforce through meetings with Area Managers to ensure Operators fully understand BP policy and procedures. An investigation team has been assembled and has begun the investigation to identify the root cause of this incident and develop actions to ensure pressure data is recorded and OA pressures will be managed below 1,000 psi. ) ) , ) ) Commisioner Norman Page 2 October 14th, 2004 On September 26, 2004, diagnostic work was initiated to determine if H-11 experienced any anomalies that could result in sustained casing pressure. An arctic pack flush was performed on the outer annulus to ensure that arctic pack fluid did not inhibit pressure gauge reading accuracy. During the second flush operation, the surface casing failed at 2,000 psi and 5 gallons of diesel spilled into the well cellar. The well is currently secured with a tubing tail plug. Further diagnostic work is planned to evaluate the failure. I am taking this situation very seriously and I am committed to ensure we conduct our field operations in a safe manner, in compliance with all applicable regulations and orders. If you have any questions, please call me at 564-5671. Mauree . J hnson Vice President, Greater Prudhoe Bay