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Home My WebLink AboutO 039 ) ') Image Project Order File Cover Page XHVZE This page identifies those items that were not scanned during the initial production scanning phase. They are available in the original file, may be scanned during a special rescan activity or are viewable by direct inspection of the file. o 0 ~ 0 Order File Identifier Organizing (done) 1111111111111111111 o Two-sided R¡SCAN YJ Color Items: o Greyscale Items: DIGITAL DATA D Diskettes, No. D Other, No/Type: D Poor Quality Originals: o Other: NOTES: I Date: 4- I{)- O~ Date: Lf, '1:;"'/00 X 30 = + Date if: lJ.j 00 BY: c: Maria.) Project Proofing BY: ( Maria) Scanning Preparation BY: ~aria.~ Production Scanning o Rescan Needed 1111111111111111111 OVERSIZED (Scannable) o Maps: D Other Items Scannable by a Large Scanner OVERSIZED (Non-Scannable) o Logs of various kinds: o Other:: VV1P 1111111111111111 rnP = TOTAL PAGES J (p J (Count does not include cover sheet) II\AJO /5/ V , t r 1111111111111111111 /5/ /5/ Stage 1 Page Count from Scanned File: 1 (P:l. (Count does include cover sheet) Page Count Matches Number in Scanning Preparation: ~ YES BY: ~ Date: 4-/I:J./O b Stage 1 If NO in stage 1, page(s) discrepancies were found: YES BY: Maria Date: Scanning is complete at this point unless rescanning is required. ReScanned BY: Maria Date: Comments about this file: NO D /5/ vy\ NO /5/ 1111111111111111111 1111111111111111111 /5/ Quality Checked 1111111111111111111 10/6/2005 Orders File Cover Page. doc INDEX OTHER ORDER NO. 39 Trading Bay Unit Steelhead Platform 1. June 18, 2004 AOGCC letter to Unocal re: reporting SVS tests 2. August 9, 2005 Internal memo 3. August 25, 2005 AOGCC letter to Unocal re: TBU Steelhead platform automatic shut-in equipment 4. September 16, 2005 Unocal's response to request for Steelhead information 5. October 13, 2005 Internal email 6. November 1, 2005 Internal email 7. December 1, 2005 Chevron's presentation for meeting and sign -in sheet 8. December 12, 2005 AOGCC's Notice of Proposed Enforcement Action 9. December 15, 2005 AOGCC letter to Unocal 10. December 21, 2005 Unocal letter re: schedule informal review 11. December 22, 2005 Scheduling Notice 12. January 9, 2006 Rescheduling of Informal Review 13. January 13, 2006 Sign -in sheet 14. January 13, 2006 AOGCC's Internal Investigation Document (held confidential in secure storage) 15. January 13, 2006 Scheduling Notice 16. February 9, 2006 Chevron's submittal of additional information for informal review 17. February 15, 2006 Sign -in sheet 18. March 21, 2006 Proposed Decision and Other Order No. 39 19. March 30, 2006 Unocal's response to proposed D&O and civil penalty check copy 20. April 12, 2006 Chevron's 1 st progress report 21. May 5, 2006 Chevron's flow chart re: SVS failure response procedures 22. May 12, 2006 Chevron's 2nd progress report 23. May 18, 2006 AOGCC response to Chevron's May progress report 24. June 12, 2006 Chevron's 3rd progress report 25. July 14, 2006 Chevron 4th progress report 26. August 15, 2006 Chevron 5th progress report INDEX OTHER ORDER NO. 39 .. Cet4A.J ~. . 0 ¡;1T, Ail_ "t/<JOjOðtJ ~~ ~ rP R~ LCJ ~~ ~ rcrJG ~Añ~;:; ~tt&-/ 7t'~ ~. " ý~11 é{~ . . . STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Avenue, Suite 100 Anchorage Alaska 99501-3539 Re: Unocal Oil Company of California, as Operator of Trading Bay Unit; Steelhead Platform; Automatic Shut-in Equipment Enforcement Action ) ) ) AOGCC Order No. 39 April 6, 2006 DECISION AND ORDER The Alaska Oil and Gas Conservation Commission ("Commission") issued a Notice of Proposed Enforcement Action under 20 AAC 25.535(b) on December 12,2005 stating that it considered that Union Oil Company of California ("Unocal") may have violated provisions of 20 AAC 25 .265( d) in connection with operating the wells on the Trading Bay Unit Steelhead platform. The Commission proposed specific corrective actions and, a $400,000 civil penalty under AS 31.05.150(a). A Proposed Decision and Order was sent to Unocal on March 21, 2006 following informal review and extensive consideration of factors that might impact the enforcement decision. The Proposed Decision and Order was substantially the same as in the notice of proposed enforcement. Unocal did not file a written request for hearing within the time allowed by 20 AAC 25.535(d) and therefore the Commission now issues this Final Decision and Order. A. Summary of Proposed Enforcement Action In its Notice of Proposed Enforcement Action, the Commission identified an apparent violation by Unocal of 20 AAC 25.265 by failing to test the safety valve systems ("SVS") for all Steelhead wells between December 17, 2003 and March 22, 2005, and after testing in March 2005 by continuing to Decision and Order Page 2 of 11 . . April 6, 2006 operate Well M-19RD1 with a failed subsurface safety valve ("SSSV") beyond the time allowed by the Commission to make repairs. The Commission proposed to order the following corrective actions by Unocal: (1) that the testing frequency of SVS' s on the Steelhead platform shall remain every 6 months; (2) that SVS test results, regardless of Commission witness, shall be required to be submitted to the Commission within 1 week of completion; (3) that within 3 ° days after the effective date of the enforcement order, Unocal shall be required to provide the Commission with documentation of the company's SVS failure response procedures that are consistent with Commission requirements; (4) that Unocal shall adopt the corrective actions identified by its root cause analysis investigation, which are consistent with Commission expectations for compliance with SVS requirements; and (5) that written progress reviews shall be required detailing corrective actions completed, and updating the status and timing for the completion of unfinished corrective actions. The report would be due on or before the 15th of each month following the effective date of the enforcement order, and until all corrective actions have been completed. B. Safety Valve System Testing Requirements Under 20 AAC 25.265, a completed well with an offshore surface location and that is capable of unassisted flow of hydrocarbons to the surface must be equipped with a commission-approved fail-safe automatic SSV and fail-safe automatic surface-controlled SSSV (unless another type of SSSV is approved by the Commission). Performance testing of SVS witnessed by a Commission representative must be carried out "at intervals and times as prescribed by the Commission." The Commission has prescribed the following requirements addressing test interval and response to test failures in the document "AOGCC Policy - SVS Failures" dated March 30, 1994: I TBU M-19RD: PTD 1931170; API # 50-733-20421-01 Decision and Order Page 3 of 11 . e April 6, 2006 1. Wells must be tested by plaiform, pad or drill site every 6 months unless a shorter period is designated by the Commission. 2. Wells that have neither produced nor injected during the preceding 6 months need not be tested, but must be tested within 48 hours after being returned to production or injection. 3. If a SSV or a SSSV fails, production/injection may continue, but the valve must be repaired and ready for a witnessed re-test within 2 weeks. If the valve fails the re-test, the well must be shut in until the valve has been repaired or replaced and passes a test. 4. If both the SSV and the SSSV fail, the well must be shut in until at least one of the valves is repaired or replaced and passes a test. The other valve must be repaired and ready for re-test within two weeks as in #3 above. The maintenance of test records by an operator is required by 20 AAC 25.310. The Commission maintains detailed records of any SVS tests it witnesses; there were no SVS tests witnessed on the Steelhead platform during 2004. Unocal was orally notified on April 27, 2005 about missing SVS test reports for 2004. Further investigation and information gathering by the Commission confirmed that Unocal could not produce 2004 SVS testing records for Steelhead platform. Unocal provided updated information about their internal root cause investigation in response to the Commission's August 25,2005 notice of investigation and request for information. Evidence gathered during independent investigations by the Commission and Unocal confirmed that SVS testing had not been performed between December 7, 2003 and March 22, 2005. Commission-required tests should have been performed in June and December of 2004. C. Informal Review Unocal requested an informal reVIew as provided in 20 AAC 25.535(c) in response to the Commission's Notice of Proposed Enforcement Action. An informal review conference was commenced January 13, 2006 with a recess granted until February 15, 2006 to provide UnocaI time to compile additional information and considerations that might impact the Commission's enforcement decision. During that time, UnocaI was specifically offered an opportunity to identify possible projects that might Decision and Order Page 4 of 11 . . April 6, 2006 offset civil penalties, with the burden of demonstrating the benefits to the State of Alaska clearly residing with Unocal. The Notice of Proposed Enforcement Action specified several factors which had been applied to mitigate the proposed civil penalty amount, including Unocal's good faith effort to determine the root cause for Steelhead platform's lack of SVS testing, Unocal's voluntary extension of its comprehensive internal compliance review to all Unocal-operated facilities in Cook Inlet, the lack of injury, the infrequent historical SVS failures, and the robust SVS design. In a February 9, 2006 letter (and during the February 15 conclusion of the informal review), Unocal identified the following mitigating factors for the Commission to consider "when assessing the appropriate level of penalties for this event": (1) No bad faith was involved in the violation; (2) No injuries were involved in the noncompliance event; (3) Failure occurred as a result of personnel not understanding regulatory obligations; (4) No need to deter similar behavior; Unocal moved immediately to determine and correct the causes; (5) Long history of regulatory compliance; (6) Event was an anomaly; a single failure in judgment at a single location; (7) Robust SVS exists for Steelhead wells; and (8) Noncompliance is similar to the situation addressed in Commission Order 33 dated May 20, 2005 and should be used as comparison for similar enforcement? Unocal did not follow up on the opportunity offered to identify beneficial offset projects. In the course of the informal review process, Unocal provided no new information to warrant a change to the proposed enforcement actions. The Commission's efforts to gather relevant information and to review the investigative record thoroughly, while time consuming, were able to account for 2 Commission Order 33 involved an enforcement action against ConocoPhillips Alaska Inc. for violations surrounding a waste injection well integrity failure. Decision and Order Page 5 of 11 . e April 6, 2006 reasonable mitigation, and propose enforcement actions that are appropriate to the violations. Some of the mitigating factors identified by Unocal were merely restatements of what the Commission had already considered in the proposed penalty. The following mitigating factors identified by Unocal require additional comment from the Commission: (1) reliance on the robust design of the SVS as mitigation for the seriousness of the event (and offset of the penalty amount), (2) personnel not understanding regulatory obligations, (3) Unocal's assertion that the Steelhead violations are analogous to those summarized in Commission Order 33, and (4) the need to deter similar behavior. Robust Design: The Commission's statements in the Notice of Proposed Enforcement Action referencing a robust SVS system on the Steelhead platform were a reflection of Unocal's own assertions about the system validated by past performance testing witnessed by the Commission and the levels of redundancy in the systems. Those comments have no relevance to requirements to test as outlined in Commission regulations. In fact, Unocal is referred to the February 2006 SVS test results from the Monopod platform as an example of why it is important to test. Despite having a robust SVS, Monopod testing showed a significant deterioration in SVS reliability with multiple component failures (22% failure rate) compared to previous tests.3 Good oilfield engineering practices dictate that the reliability of safety systems must be periodically assessed through testing, regardless of how robust the system design appears. Lack of Understanding by Personnel: Unocal's assertion that Steelhead personnel did not understand the regulatory obligations is not supported by the following facts: (1) A Commission inspector witnessed SVS testing in March 2005 and advised Unocal personnel of their obligations to test the SVS and maintain testing records. 3 Historic failure rate is 7%; Monopod platform was placed on a 90-day test cycle effective February 17, 2006 until an acceptable level of performance is achieved. Decision and Order Page 6 of 11 . e April 6, 2006 (2) The Commission sent Unocal a letter dated June 18, 2004 reiterating SVS testing requirements (although it is not the Commission's responsibility to remind an operator of its obligation to comply with clearly stated regulatory requirements). (3) Unocal personnel failed to follow Unocal's own internal SVS testing guidelines, which require more frequent testing4 than does the Commission. (4) Unocal's Steelhead platform "Safety/Obligations Inspection Report" for the months of July 2004 through February 2005 clearly show platform personnel were aware of and chose to neglect SVS testing obligations. Comparison to Commission Order No. 33: Unocal's comparison to Commission Order 33 is not valid. Unocal incorrectly asserts that the primary difference between the noncompliance outlined in Commission Order 33 and the Steelhead noncompliance is that Unocal did not self-report. Rather, there are several other, more serious differences between the two incidents, as follow: (1) Unocal states that they "were simply not aware of the violation" and when informed of the problem "addressed it swiftly and completely." The previous paragraph clearly shows that Unocal was aware of the requirements and simply chose to ignore them. (2) Unocal has been unable to demonstrate through alternative documentation provided to the Commission that the system maintained an acceptable level of integrity during the time in violation. (3) Although no actual harm or waste occurred, in the Unocal violation there was significant potential for catastrophic harm to people, property, and the environment, as well as potential waste of the hydrocarbon resource. The Need to Deter Similar Behavior: Unocal's assertion that there is no need to deter similar behavior assumes that Unocal is the only operator whose behavior needs to be influenced. In the 4 Unocal policy is to test the SVS every 3 months; Commission requirements are to test every 6 months Decision and Order Page 7 of 11 . . April 6, 2006 Commission's judgment, there is a need not only to deter Unocal from repeating this violation but also to demonstrate to other Operators in Cook Inlet and throughout the State of Alaska the seriousness with which the Commission views such a violation. Therefore, the Commission sees a strong need to deter similar behavior. D. Penalty Amount Failure to comply with SVS regulatory requirements is a serious category of violation that has the potential to result in significant public harm. A loss of well control in Cook Inlet could result in human injury or death, environmental damage, physical waste of valuable hydrocarbon resources, destruction of property, and significant loss of confidence by the public in the industry's ability to operate in a prudent and responsible manner. In past enforcement matters the Commission has identified five factors as among those that should be considered in determining the appropriate amount of a civil penalty. These are: (1) the good or bad faith of the operator in violating the law; (2) the injury to the public resulting from the violation; (3) the benefits derived by the operator from its violation; (4) the operator's ability to pay the penalty; and (5) the need to deter similar behavior by the operator and others in the future. The civil penalty totaling $400,000 was calculated by multiplying a daily penalty amount as provided under AS 31.05.150 by the number of days each violation occurred as follows: (1) $123,000 for violating 20 AAC 25.265 by continuing to produce TBU M-19RD following the identified failure ofthe SSSV ($1,000 per day for 123 days5); (2) $277,000 for violating 20 AAC 25.265 by failing to test automatic shut-in equipment on the Steelhead Platform wells during 2004 ($1,000 per day for 277 days6). The Commission has accounted for all appropriate mitigating factors in establishing the proposed enforcement action by not calculating penalties based on each possible violation (There were in excess of 5 123 days trom Apri16, 2005 through August 9, 2005; April 6 is the 15th day following the SSSV failure witnessed by a Commission inspector - there were no subsequent tests; August 9 represents the date the Commission was requested to witness are-test ofthe failed SSSV in TBD M-19RD. 6277 days trom June 18,2004 through March 21,2004; June 18 is the day following the 6-month anniversary of SVS testing completed December 17,2003; March 21 is the day prior to first SVS testing on Steelhead platform following the December 17, 2003 test. Decision and Order Page 8 of 11 . . April 6, 2006 40 possible violations each day.)? and by reducing the daily penalty amount from the maximum of $5,000 per day down to $1,000 per day as provided for in AS 31.05.150. A substantially larger financial penalty would have been included in the notice of proposed enforcement had the Commission not already accounted for mitigating circumstances. Unocal has argued that the proposed penalty amount is excessive because a single failure in judgment at a single location should not be treated as multiple days in violation. The Commission disagrees with Unocal's argument. Except as provided by regulation or specific Commission approval, each day beyond the required test date that the SVS is not tested represents a violation. E. Findings and Conclusions Unocal acknowledged that it failed to perform SVS tests at the required frequency during 2004, and failed to repair safety valves within the required timeframe during 2005 in Well TBU M-19RD. Where appropriate, the Commission has taken into account mitigating circumstances in establishing the enforcement action to be taken in response. Unocal was provided opportunities during the enforcement phase of this investigation to identify additional factors but no additional mitigating factors were identified. The Commission does note Unocal management's acceptance of responsibility for the violations and the Commission acknowledges the excellent work subsequently done at all Unocal Cook Inlet facilities to address the issues exposed by the SVS violations at the Steelhead Platform. The Commission has seen immediate and positive results from Unocal's post-violation efforts to comply with testing obligations as well as improved communications. The Commission also notes Unocal's high level of cooperation and outstanding proactive efforts to investigate the root causes of testing noncompliance. Detailed presentations ofUnocal's findings have helped the Commission fully understand the background ? UnocaI pointed out in its February 9, 2006 Ietter an apparent discrepancies in the number of wells (13 versus 17) requiring dedicated SVS on SteeIhead in an attempt to show the violation was a single failure in judgment; ifUnocal is correct, then the failure rate for SVS testing during March 2005 would have resulted in a failure rate triggering 90 day SVS testing; since Unocal did not test the Steelhead SVS again until August 26, 2005 there would have been additional testing violations; the Commission chose not to include this in the penalty calculation. Decision and Order Page 9 of 11 . . April 6, 2006 information about the Steelhead Platform operations and the factors that led to the testing violations. The root cause investigation and the company's post-violation response do not, however, alter the basic facts related to this violation as discovered by the Commission; i.e.: that no SVS testing was performed on Steelhead Platform wells between December 17,2003 and March 22,2005 and that TBU M-19RD was produced with a failed subsurface safety valve from April 6, 2005 through August 9, 2005, both clear violations of Commission requirements. The company's post-violations actions have, however, clearly demonstrated the seriousness with which Unocal management views such violations. For the reasons stated above, the Commission finds that Unocal violated 20 AAC 25.265 III connection with operating the wells on the Trading Bay Unit Steelhead Platform during 2004 and 2005, and concludes that significant sanctions including a civil penalty are appropriate. NOW THEREFORE IT IS ORDERED THAT: I. Within 30 days after this Decision and Order becomes final, Unocal shall pay the Commission a civil penalty of $400,000.8 2. Unocal shall comply with the following corrective actions: (a) Testing frequency of SVS's on the Steelhead Platform shall remain every 6 months unless a more frequent testing is ordered by the Commission based on SVS performance; (b) SVS test results, regardless of Commission witness, shall be submitted to the Commission within 1 week of completion; (c) Within 30 days after the date of this final Decision and Order, Unocal shall provide the Commission with documentation of the company's SVS failure response procedures that are consistent with Commission requirements; (d) Within 30 days after the date of this final Decision and Order, Unocal shall adopt the corrective actions identified by its root cause analysis investigation regarding: (1) 8 On March 30, 2006 Unocal paid the penalty of $400,000, receipt of which is hereby acknowledged, fully satisfYing the civil penalty imposed in this Decision and Order. Decision and Order Page 10 of 11 . . April 6, 2006 Training; (2) Single Point of Contact; (3) DataStream Assessment; (4) Management Discussion; (5) Orientation; (6) Reassessment of No Flow Wells; (7) SVS Status Displays; (8) Policies and Procedures; (9) Steelhead Survey; (10) Alternative System; and (11) Compliance Survey; and (e) Unocal shall provide written progress reviews detailing actions completed, and updating the status and timing for the completion of unfinished corrective actions. Such reports shall be due on or before the 15th day of each month following the date of this final Decision and Order, and shall continue to be submitted until all required corrective actions have been I hereby certify that a true and correct Copy of the attached decision was mailed To the following on April 6, 2006: Daniel T. Seamount, Commissioner c~e~~ Union Oil Company of California Attn: Dale A. Haines P.O. Box 196247 Anchorage, AK 99519-6247 Delaney, Wiles, Hayes, Gerety, Ellis & Young, Inc. Attn: Stephen M. Ellis 1007 W. 3rd Ave., Suite 400 Anchorage, AK 99501 State of Alaska, Department of Law Office of the Attorney General 1031 W. 4th Ave, Suite 200 ch 99501-1994 ~ resa Tolley 0-"" SUbsc~ed and sw0(i, t~re me this 6th of April, 2006 '~~ ~ () Notary Public . My Commission Expires / 1// )tJ 6 #26 08/15/2006 14:00 9072*07 6TH FLOOR I* PAGE 01 Chevron Date A. Haines Union Oil Company of California Operations Manager P.O. Box 196247 Anchorage, AK 99519-6247 7 Tel 907 263 951 Fax 263 7607 Email i{ d aleaieah@chevron.corn V AugUst 15, 2006 a Mr. John K. Norman, Chairman Alaska Oil and Gas Conservation Commission 333 W. 7" Avenue, Suite 100 Anchorage, AK 99501-3539 Reference: AOGCC Order No. 39, effective April 6, 2006 Dear Chairman Norman: On April 6, 2006, the Alaska Oil and Gas Conservation Commission (AOGCC) directed Union Oil Company of California (UOCC) to provide monthly written progress reports concerning corrective actions included in the referenced order. This is the fifth and final progress report. At this time, the following corrective actions pre closed: - payment of the civil penalty; - documentation of UOCC SVS failure response procedures; Training; Single Point of Contact; DataStream Assessment; Management Discussion; Orientation; SVS Status Displays; - Policies and Procedures; and Alternative System. We have reviewed the no -flow status of all Of our active Cook Inlet producing wells. As of July 31, 2006 all wells with no -flow designation have been identified and tested consistent with AOGCC regulations. This corrective action) is closed. Our Compliance Coordinator has consulted with AOGCC Inspector Lou Grimaldi, regarding AOGCC audits and requirements, and assessed UOCC work occurring under the other corrective actions related to this order, and ongoing internal audit and compliance work. He will witness SVS tests at the Steelhead later this month. Upon the completion of those tests, we will close the Steelhead survey corrective action. Our Compliance Coordinator completed a review of our Compliance Matrix to verify the adequacy of the compliance systems associated with AOGCC health, environmental, and safety items. One new item was added to the matrix, areas for improvement were identified, and Union Oil Company of Callfomia f A Chevron Company http;//www.cnevron,com 08/15/2006 14.00 9072007 6TH FLOOR PAGE 02 Mr. John Norman AOGCC August 15, 2006 Page 2 recommendations were provided. We will n w begin implementing the recommendations to strengthen the compliance systems. The compliance survey corrective action item is closed. Should you have any questions regarding a6y of the information provided, please contact Mr. William Britt at the above address. Sincerely, Da 00 oAr�" Dale Haines Cc: [Ian Seamount, Commissioner Cathy Foerster, Commissioner John Zager, UOCC Marc Bond, UOCC Kevin Tabler, UOCC William Britt, UOCC Union Oil Company of California I A Chevron Company http;//www.chevron.com *~~ . . Chevron === Dale A. Haines Operations Manager Union Oil Company of California P.O. Box 196247 Anchorage, AK 99519-6247 Tel 907 263 7951 Fax 907 263 7607 Email daleah@chevron.com August 15,2006 REceIVED AUG 1 5 2006 Alaska Oil & Gas Cons Comm· . . 18810B Anchorage Mr. John K. Norman, Chairman Alaska Oil and Gas Conservation Commission 333 W. ih Avenue, Suite 100 Anchorage, AK 99501-3539 Reference: AOGCC Order No. 39, effective April 6, 2006 Dear Chairman Norman: On April 6, 2006, the Alaska Oil and Gas Conservation Commission (AOGCC) directed Union Oil Company of California (UOCC) to provide monthly written progress reports concerning corrective actions included in the referenced order. This is the fifth and final progress report. At this time, the following corrective actions are closed: payment of the civil penalty; documentation of UOCC SVS failure response procedures; Training; Single Point of Contact; DataStream Assessment; Management Discussion; Orientation; SVS Status Displays; Policies and Procedures; and Alternative System. We have reviewed the no-flow status of all of our active Cook Inlet producing wells. As of July 31,2006 all wells with no-flow designation have been identified and tested consistent with AOGCC regulations. This corrective action is closed. Our Compliance Coordinator has consulted with AOGCC Inspector Lou Grimaldi, regarding AOGCC audits and requirements, and assessed UOCC work occurring under the other corrective actions related to this order, and ongoing internal audit and compliance work. He will witness SVS tests at the Steelhead later this month. Upon the completion of those tests, we will close the Steel head survey corrective action. Our Compliance Coordinator completed a review of our Compliance Matrix to verify the adequacy of the compliance systems associated with AOGCC health, environmental, and safety items. One new item was added to the matrix, areas for improvement were identified, and n'0lhl 1\' r-'{ ! !, ",' f ! \¡ IJ.. L Union Oil Company of California / A Chevron Company http://www.chevron.com .. . . Mr. John Norman AOGCC August 15, 2006 Page 2 recommendations were provided. We will now begin implementing the recommendations to strengthen the compliance systems. The compliance survey corrective action item is closed. Should you have any questions regarding any of the information provided, please contact Mr. William Britt at the above address. Sincerely, f)cß- ú)J t»JA Dale Haines Cc: Dan Seamount, Commissioner Cathy Foerster, Commissioner John Zager, UOCC Marc Bond, UOCC Kevin Tabler, UOCC William Britt, UOCC Union Oil Company of California / A Chevron Company http://www.chevron.com . . Chevron === Dale A. Haines Operations Manager Union Oil Company of California P.O. Box 196247 Anchorage, AK 99519-6247 Tel 907 263 7951 Fax 907 263 7607 Email daleah@chevron.com July 14, 2006 RECE\VED JUL 1 3 IUI.;;) C Commiss'lon Maska Oil & Gas OOS. Anchorage Mr. John K. Norman, Chairman Alaska Oil and Gas Conservation Commission 333 W. ih Avenue, Suite 100 Anchorage, AK 99501-3539 Reference: AOGCC Order No. 39, effective April 6, 2006 Dear Chairman Norman: On April 6, 2006, the Alaska Oil and Gas Conservation Commission (AOGCC) directed Union Oil Company of California (UOCC) to provide monthly written progress reports concerning corrective actions included in the referenced order. This is the fourth such progress report. At this time, the following corrective actions are closed: payment of the civil penalty; documentation of UOCC SVS failure response procedures; Training; Single Point of Contact; DataStream Assessment; Management Discussion; Orientation; SVS Status Displays; Policies and Procedures; and Alternative System. In our last monthly report we indicated that we were continuing to review our no flow documentation and would contact AOGCC Inspectors to schedule any tests necessary to validate no-flow status. Testing on K-25 well on the King Salmon has been completed as of July 10, the G-17 well on the Grayling is currently being tested, and tests of wells on the Dolly Varden are tentatively scheduled for July 27. This corrective action item will be closed when we complete these efforts. As previously indicated, our Compliance Coordinator is planning to conduct an audit of the Steel head and complete an assessment of the compliance systems documented in our compliance matrix by the end August. These corrective action items will be closed when the audit and assessment are complete. Union Oil Company of California / A Chevron Company http://www.chevron.com , :jt . . Mr. John Norman AOGCC July 14, 2006 Page 2 Should you have any questions regarding any of the information provided, please contact Mr. William Britt at the above address. Sincerely, 2~C. Dale Haines Cc: Dan Seamount, Commissioner Cathy Foerster, Commissioner John Zager, UOCC Marc Bond, UOCC Kevin Tabler, UOCC William Britt, UOCC Union Oil Company of California / A Chevron Company http://www.chevron.com 4t c14- e e Chevron === Dale A. Haines Operations Manager Union Oil Company of California P.O. Box 196247 Anchorage, AK 99519-6247 Tel 907 263 7951 Fax 907 263 7607 Email daleah@chevron.com June 12, 2006 RECEIVED JUN 1 9 2006 Alaska Oil & Gas Cons. Commission Anchorage Mr. John K. Norman, Chairman Alaska Oil and Gas Conservation Commission 333 W. ih Avenue, Suite 100 Anchorage, AK 99501-3539 Reference: AOGCC Order No. 39, effective April 6, 2006 Dear Chairman Norman: On April 6, 2006, the Alaska Oil and Gas Conservation Commission (AOGCC) directed Union Oil Company of California (UOCC) to provide monthly written progress reports concerning corrective actions included in the referenced order. This is the third such progress report. At this time, the following corrective actions are closed: payment of the civil penalty; documentation of UOCC SVS failure response procedures; Training; Single Point of Contact; DataStream Assessment; Management Discussion; Orientation; SVS Status Displays; Policies and Procedures; and Alternative System. In a letter to UOCC dated May 18, 20Ô6 you provided comments on a portion of our failure response procedures and requested additional information regarding our training and orientation, our DataStream 7i process, and our no-flow assessment. Your comments have been communicated to our Production Superintendent and included in the procedures and in our training and orientations. Additional information regarding our training and orientation, our DataStream 7i process, and our no-flow assessment is provided below: . Training and Orientation: All UOCC Facility Supervisors have been trained regarding SVS compliance obligations. Each supervisor has been asked to sign a statement confirming completion of the training. UOCC is also enhancing a supervisor orientation process which will facilitate the training of all new supervisors. · DataStream 7i Process (Summary): DataStream 7i (D7i) is a software package with task management and tracking capabilities. For SVS testing, we have entered tasks for Union Oil Company of California / A Chevron Company http://www.chevron.com e e Mr. John Norman AOGCC June 12, 2006 Page 2 testing requirements into D7i based on a three-month recurring basis. To simplify the process we have placed all wells at a given facility on the same testing cycle such that all testing for a facility comes due at the same time. The system is queried weekly for testing coming due within the next two weeks. Work orders are generated for each triggering facility, AOGCC notification is completed, testing is completed, and the work orders are closed out. Should a well be down when testing is due the well is tagged to identify the need for testing should the well be brought back into production. In this event the tag triggers the need for notification and testing and the now operating well is reintegrated into the recurring testing cycle. A power point presentation titled "DataStream 7i - Scheduling and Tracking - AOGCC Order 39" is attached which provides further information regarding the system, checklists, forms, etc. . No-Flow Assessment: We are continuing to review our no flow documentation. If we identify wells which may warrant validation of no-flow status, our Production Foremen will contact AOGCC Inspectors to schedule those tests. We expect to complete our review and complete any data collection necessary to confirm no-flow status by our next monthly report. This corrective action item will be closed when we complete this effort. Our Compliance Coordinator observed SVS testing at our Happy Valley facility on May 12th in preparation for coordinating an audit of the Steel head with AOGCC inspectors. Mr. Grimaldi of your office witnessed the tests. We expect the Steelhead audit to occur in August 2006. This corrective action item will be closed when the audit is complete. Our Compliance Coordinator will also complete an assessment of the compliance systems documented in our compliance matrix by the end August 2006. This corrective action item will be closed when the assessment is complete. Should you have any questions regarding any of the information provided, please contact Mr. William Britt at the above address. Sincerely, Ð¿'9JaiM. Dale Haines Cc: Dan Seamount, Commissioner Cathy Foerster, Commissioner John Zager, UOCC Marc Bond, UOCC Kevin Tabler, UOCC William Britt, UOCC Union Oil Company of California / A Chevron Company http://www.chevron.com Chevron .. e East Forelands Delivery Facility (EFDF) e Nikiski, Alaska May 2006 © Chevron 2005 DOC ID Task Scheduling - SVS Testing Chevron III Deseri tion QUARTERLY WELLHEAD SAFETY REGULATE A-QTRLY-WELLHEAD INSPECTION ANNA 90 3 Months FRANZMANN NO QUARTERLY WELLHEAD SAFETY REGULATE B-QTRLY-WELLHEAD INSPECTION BAKER 90 3 Months FRANZMANN NO QUARTERLY WELLHEAD SAFETY REGULATE G-QTRLY-WELLHEAD INSPECTION GRAYLING 90 3 Months FRANZMANN NO QUARTERLY WELLHEAD SAFETY REGULATE H-QTRLY-WELLHEAD INSPECTION STEELHEAD 90 3 Months FRANZMANN NO QUARTERLY WELLHEAD SAFETY REGULATE L-QTRLY-WELLHEAD INSPECTION KING 90 3 Months FRANZMANN NO QUARTERLY WELLHEAD SAFETY REGULATE M-QTRLY-WELLHEAD INSPECTION MONOPOD Du lieate 90 3 Months FRANZMANN NO QUARTERLY WELLHEAD SAFETY REGULATE P-QTRLY-WELLHEAD INSPECTION GPPF Du lieate 90 3 Months FRANZMANN NO QUARTERLY WELLHEAD SAFETY REGULATE U-QTRLY-WELLHEAD INSPECTION BRUCE Du lieate 90 3 Months FRANZMANN NO QUARTERLY WELLHEAD SAFETY REGULATE V-QTRLY-WELLHEAD INSPECTION DOLLY Du lieate 90 3 Months FRANZMANN NO © Chevron 2005 MidContinent 2 © Chevron 2005 Field Work Order - Example Chevron III . Work orders are generated from the 07i. They are printed and distributed to the facilities from our EFOF location. Chtl'fOO . Print Date: 5/30106 STEELHfAD wO#: 57880 QUARTERL Y WELLHEAD SAFETY INSPECTION PM Code: location : Scheduled Start D.Ie: 0410112006 Scheduled Finish Date: 0612912006 WELLHEAD PRESSURE SAFETY INSPEcnON WO Type: Priority: Assigned By: Assigned To: Completion D.te: Sen.l#: MFG: Model: SAFE 3 FRANZMANN H-QTRlY-WEllHEAD E~¡Ø: H-WELlHEAO~RESSURES I Equipment Notes: AcIi1IiIy .1 Activity Comments: Assigned Trade: OPER Addition.1 Job HCIteIMaIerUIs Used: I Hrs Empfo,.. H.... Empfoyeo H.... Task Instructions: 1 Schedule. slate rep,.....ntative, alleast 24 hours prior 10 a test, 10 wì1ness tests at le.st twice .nnually. AOGCC Contact: Jim Reg¡¡, Inspection Supervisor. jim_regg@admin.state.a!t.us 793-1236 Website for additional info http://www.state..k.usladminlogc.hcmeogc.htm 2. Periorm íhe SSV .nd lor SSSV testing in aooord.nce w~h AOGCC Policy 20AAC25.265. 3. Note results of test on the .ttached. "Safety Valve and Wd Pressures Tes! Report". NOTE, tt is Chew<>n's responsibiilly !o document and maintain a record of ~s SVS test results. 4 Send . copy of the test!o: AJaska Oil & Gas Conserv.tion Commission 333 W 71h Ave., SIe. 100 Anchorage. AJask. 99501 Voice (007) 279-1433 F.. (007) 2711-7542 5. tf no test fails. send work order tc EFDF Maintenance Group will1 closing ~!s. 6 tf. lest fais. make noIific-atíons 10 AOGCC in aooordance _ SVS Failures 2OAAC25.265. . Note: VaJvo must be ropai"'" or replaœd .nd ready for retest_in 2 _so II repairs cannct be made within 2 """,,s. notify AOGCC of the ""ed for well shu1-in, 7 24 hour notification for wi1nessmg. retest must be made 10 AOGCC wilen: .¡ rep.irs are completed after. failed test or b)_II restart after a sh~¡n. S Send the completed work order 10 EFDF Mainten.nce Group for closure W.O. CommentS: MidContinent 3 e © Chevron 2005 Field Inspection Sheet - Example Chevron III This is attached to the work order Safety Valve & Well Pressures Test Report Pad: Steel head Platform Date: State Rep. Interval: 90 day Insp #: Inspected by: Related Insp: Field Name: Operator: UNOCAL MGS Operator Rep: Reason: Source: }_ii :~'>iI(>I$\/X\ ~e "ø$" "¡ver Well Permit Separ Set UP Test Test Test Date Oil, Gas, Wlnj, Inner Outer Tbg Yes/No Yes/No Name Number PSI PSI Trip Code Code Code Shut-In SI, Gas Storage PSI PSI PSI M-1 SCSSV 0124/SSVPILOT (PSHL) M-2 SCSSV 0117/SSVPILOT (PSHL) M-3 SCSSV 0116/SSVPILOT (PSHL) M-4 SCSSV 01211SSVPILOT (PSHL) M-5 SCSSV 0115/SSVPILOT (PSHL) M-l SCSSV 0122/SSVPILOT (PSHL) M-9 SCSSV 0119/SSVPILOT (PSHL) M-12 SCSSV 0110/SSVPILOT (PSHL) M-13 SCSSV 0106/SSVPILOT (PSHL) M-14 SCSSV 0109/SSVPILOT (PSHL) M-15 SCSSV 0103/SSVPILOT (PSHL) M-16 SCSSV 0107/SSVPILOT (PSHL) M-19 SCSSV 0101lSSVPILOT (PSHL) M-25 SCSSV 0132/SSVPILOT (PSHL) M-28 SCSSV 0130/SSVPILOT (PSHL) M-29 SCSSV 0131/SSVPILOT (PSHL) M-31 SCSSV 0129/SSVPILOT (PSHL) M-32 SCSSV 0133/SSVPILOT (PSHL) M-2l M-30 Overall Comments: Performance Wells :::omponent! Faitures Failure Rate % MidContinent 4 Data . Personnel directly 7 facilities can their copy DataStream 7i program use the Wellhead Safety Inspection copy. facility BRUCE ((kg): QUARTERLY WELLHEAD V-QTRLY- WELLHEAD PRESSURE SAFETY INSPECTION WELLHEAD INSPECTION QUARTERLY WELLHEAD P-QTRLY" P-WELLHEAD WELLHEAD PRESSURE 04/01/2006 06/29/2006 SAFETY INSPECTION WELLHEAD INSPECTION GRAYLING 57864 QUARTERLY WELLHEAD G-QTRLY- G-WELLHEAD WELLHEAD PRESSURE 04/01/2006 06/29/2006 SAFETY INSPECTION WELLHEAD SAFETY INSPECTION KING 57363 QUARTERLY WELLH.EAD L-QTRLY- L-WELLHEAD WELLHEAD PRESSURE 04/01/2006 06/2912006 SAfETY INSPECTION WELLHEAD SAFETY INSPECTION MONOPOD 57371 QUARTERLY WELLHEAD M·QTRLY- ~~-WELLHEAD WELLHEAD PRESSURE 04/01/2006 06/29/2006 SAfETY INSPECTION WELLHEAD SAFETY INSPECTION STEELHEAD 57380 QUARTERLY WELLHEAD H-QTRL Y- WELLHEAD PRESSURE 04/01/2006 06/29/2006 FETY INSPECTION WELLHEAD SAfETY INSPECTION © Chevron 2005 5 Completion status can be watche.cI using our Intranet Web Site Availabilit!o-'/Reliability Emissions: Runtime Emissions Runtime Summary Crane Op Status , Clane Drawing/Load Charts , Service Reports Turþine Engine Hrs ~M.M_·"""U"""_""""_"_. MP2Work Orders MP21nventory , rnyUl100al POB Search MC Porta! PefSOl1f¡el Of¡ Board (POS) Oraole Fin,¡mOfa!s and MIS Ouefjf 6 · I Alaska's Integrated Information Web Site Easy access (everyone has access) Discussed each week at the "Grocery Meeting" © Chevron 2005 MidContinent 7 Follow Up I New Work Order - Example A new work order is written to provide tracking on necessary repairs identified during the SVS testing process. The work order below is what is generated by the facility for tracking purposes. Inside the DataStream 7i program there are areas to note more details such as who performed the repair and any other comments that may be applicable. Chevron DOLL y Print Date: 5/31106 ~ WOfII: 58204 . © Chevron 2005 MidContinent DWO:WfU 1).25 SSV REPAIR LEAKING VAL VElMAINTENANOE This shows who is dir responsible for this assignment and when the Job was completed. PM Code: Loca1ion: WELLHEAD ROOM A·1 WO Type: Priority: Assigned By: Assigned To: Completion Date: Serial#: MFG: Model: BARTOlOWlTS LEEJR 0411312006 BRKD ScheOOled Start Date: 0411112006 Scheduled Finish Date: 0412512006 WELUOIL PRODUOER Chevron III Equip#: V-WEO-DO025 This shows the Trade that is responsible to complete the repair. Equipment Notes: I. COMPlETE UNOCAl AlASI<A SPS-8.8 (PREWORK SAFETY REVIEW). 2. COORDINATE MAINTENANCE ACTIVITY WITH PRODUCTION PERSONNEL 3. IF APPLICABLE, lOTO. 4. INFORM PRODUCTION WHEN ACTIVITY IS COMPlETED. Activity 1t1 Activity Comments: Assigned Trade: OPER Date Worked rs W.O. Comments: THIS MUST BE COMPLETED WITHIN THE 14 D.....y TIMEFRAME. I. _ RepairiNiting valve. This area Provides the facility with Instructions on what needs to be completed. 2. _ When repaß are complete<!, reles.1 all<! ooCOO1E!nt. send 1es.1 data m AOGCC andcc Chris Myers (Anch} JoI1my San1iago (EFDf) all<! Paul BMolowi1s. (Dei'')' V_po 3. _ Send complete<! work Qfdier to EFDF Manlenanœ Group for closure. 8 .iF ~3 e e FRANK H. MURKOWSKI, GOVERNOR ALASKA OIL AND GAS CONSERVATION COMMISSION 333 W. 7TH AVENUE. SUITE 100 ANCHORAGE. ALASKA 99501-3539 PHONE (907) 279-1433 FAX (907) 276-7542 May 18, 2006 Mr. William Britt HES Manager Union Oil Company of California PO Box 196247 Anchorage, AK 99519 Re: Commission Order No. 39 Dear Mr. Britt: Union Oil Company of California ("UOCC") provided the second monthly written progress report concerning corrective actions required by Alaska Oil and Gas Conservation Commission ("Commission") Order No. 39, received on May 12,2006. The Commission appreciates the expeditious manner in which UOCC is pursuing the specific corrective actions in its safety valve system testing. Several actions are listed as closed by UOCC. Please note the following and include appropriate documentation supporting close-out of actions in your next monthly written progress report: Evidence of completed training and orientation associated with Commission requirements, specifically regarding the safety valve system; Example printed schedule and tracking document from DataStream 7i showing required actions specific to safety valve systems on the Steelhead Platform, if possible; Summary of the completed no-flow assessment listing well, date of no- f10w designation approved by the Commission, and information verified to reach a conclusion about the continued validity of the no-f1ow decision. The Commission received by electronic mail dated May 5, 2006 a flow diagram outlining UOCC's safety valve system failure response procedures. The following comments are offered: 1. Test reports are due to the Commission within 7 days of completing the test, regardless of Commission witness; 2. Component tàilure rates exceeding 10 percent (on a pad or platform basis) require testing at an increased frequency, typically every 90 days as opposed to the 180-day test interval under normal conditions; 3. An integral assumption of the f10w diagram appears to be that the well includes both a surface and subsurface safety valve. Numerous wells have been designated no-flow allowing the subsurface safety valve to be removed. Note that with the removal of a .. Mr. William Britt May 18, 2006 Page 2 of2 e e subsurtàce valve, a failure of the surface safety valve or low-pressure pilot requires the well to be shut in immediately (treated the same as if there were 2 failed components). The Commission is willing to discuss testing requirements in more detail as you progress toward implementing wellhead safety valve testing guidelines at UOCC-operated facilities. Feel free to contact Jim Regg at 793-1236 should you have any questions or require clarification. Please copy him on any electronic mail correspondence directed to the Commission addressing technical obligations in Commission Order 39. cc: James Regg, Sr. Petroleum Engineer #22 e e Chevron === Dale A. Haines Operations Manager Union Oil Company of California P.O. Box 196247 Anchorage, AK 99519-6247 Tel 907 263 7951 Fax 907 263 7607 Email daleah@chevron.com May 12, 2006 Mr. John K. Norman Chairman Alaska Oil and Gas Conservation Commission 333 W. 7th Avenue, Suite 100 Anchorage, Alaska 99501-3539 Re: AOGCC Order No. 39, effective April 6, 2006 Dear Chairman Norman: On April 6, 2006, in the reference order, the Alaska Oil and Gas Conservation Commission (AOGCC) directed Union Oil Company of California (UOCC) to provide monthly written progress reports on or before the fifteenth day of each month concerning corrective actions included in the order. This is the second such report, due on or before May 15, 2006. In the last report, we identified the following corrective actions as being closed: · payment of the civil penalty; · Training; · Single Point of Contact; · DataStream Assessment; · Management Discussion; · SVS Status Displays; and · Alternative System. Mr. William Britt provided you with a copy of our SVS failure response procedures by email on May 5, 2006. This corrective action is closed. As noted in my last report, the next tests of the SVSs on the Steel head Platform will occur on or before August 18, 2006. Our policies and procedures associated with SVS testing include the designation of a single point of contact for interactions with AOGCC on this subject, our use of DataStream 7i to schedule and track required actions, the failure response procedures provided to you last week, and the orientation process described below. The Policies and Procedures corrective action item is closed. Union Oil Company of California I A Chevron Company http://www.chevron.com Mr. John Norman AOGCC May 12, 2006 Page 2 e e As noted in my last report, at the end of 2005 we began providing more regulatory obligation information to new field supervisors and others that are temporarily "stepped-up." The checklist and supporting reference materials that were produced to formalize this increased effort are attached. This corrective action is closed. Our facility foremen have reviewed our no flow documentation and confirmed the adequacy and accuracy of the information. Our reservoir engineers are now confirming that no perforations have occurred since the no flow documentation was developed. This corrective action item will be closed when we complete this effort. As noted in my last report, our Compliance Coordinator will observe SVS testing at our Happy Valley facility this month, then coordinate an audit of the Steelhead with AOGCC inspectors. We expect the audit to occur in August 2006. This corrective action item will be closed when the audit is complete. Our Compliance Coordinator will also complete an assessment of the compliance systems documented in our compliance matrix by July 2006. This corrective action item will be closed when the assessment is complete. Should you have any questions regarding any of the information provided, please contact Mr. William Britt at the above address. Sincerely, 0dl- ~ oJÁh Dale Haines Enclosure CC: Dan Seamount, Commissioner Cathy Foerster, Commissioner John Zager, Union Oil Company of California Marc Bond, Union Oil Company of California Bill Britt, Union Oil Company of California Kevin Tabler, Union Oil Company of California Union Oil Company of California I A Chevron Company http://www.chevron.com MCBU Alaska Area Orientation for Field Supervisors Italicized items are optional Name: Category Trained by the Foreman Initials I Trained by HES Initials I Arranged by Initials I or Superintendent Date Date Training Coordinator Date 1. Regulations AOGCC - overview of policies, Spill Reporting - reporting procedures and regulations requirements in case of a spill, including report to Coast Guard AOGCC - SSV and SSSV flowchart NPDES - overview of policies, CFR 49 Hazardous Shipping & procedures and regulations Manifesting. -- DOT - overview of policies, Air emissions - overview of procedures and regulations policies, procedures and regulations DOT - regulated valves on your facility DOT - operator qualification requirements for employees and contractors Inspections - responsibilities for piping deficiencies and PSV work; tracking by Inspections Group Safety - specific responsibilities outlined in the Safety Procedures & Practices Manual 2. Manaaement of Chanae -= FCR - initiating an FCR and the Hazard analysis approval process Hazard analysis - responsibilities 3. Contractor Manaaement Approved vendors (use of vendor list) Reporting exceptions to contract managers (such as failure to follow safety regulations or discrepancies in billing) Page 1 of 3 MCBU Alaska Area Orientation for Field Supervisors Italicized items are optional Name: Category Trained by the Foreman Initials I Trained by HES Initials I Arranged by Initials I or Superintendent Date Date Training Coordinator Date 3. Personnel Performance appraisal review and process (PMP) HR- employee discipline procedures (use of Chevron forms; correct data collection) Orientation - performing new employee a and visitor orientations Recognition of alcohol and drug use Drug and alcohol policy (offsite training foreman receive every two years) 4. Leadership Safety Meeting & Drills STOP for supervisors Leadership 2000 courses Managing people - managing Other management training employee personality clashes Stress management 5. Project Manaaement Project cost tracking Logistics - cost of operations 6. Emeraency Response -e- Incident Command System - IC ICS training responsibilities 7. Incident Investigation Preparing an incident report for spills, Root Cause Analysis training accidents and near misses a.policy OE responsibilities Operational Excellence leadership training 9. Process Down hole completion and gas lift operation / trouble shooting Page 2 of 3 MCBU Alaska Area Orientation for Field Supervisors Name: Italicized items are optional Category Trained by the Foreman Initials I Trained by HES Initials I Arranged by Initials I or Superintendent Date Date Training Coordinator Date Wireline operations 10. Budoetino Budget training 11. Coding and Bill Paying Invoice coding SAP ..... 12. Computer FDCxtra morning report Computer training Expense reports e Page 3 of 3 e e svsdir03 AOGCC POLICY SVS FAILURES ( Amended 3/94) This document sets forth the C0ft1'.!1issiOt!·~J~.olicv regarding the testing of productionlil1jcction well safety valve systems (SVS), this inclu<:ICSlow pressure sensor (LPS) with pilot valve, surface safety valve (SSV), and subsurface safety valve (SSSV). Wells must be tested by platfonn, Pad. or drill site every 6 months unless a shorter period is designated by the Commission. The Conunission intends to witness at least 250/0, by facility, of all SVS tests; the Inspector must be given 24 hours notice prior to testing. Atl test results must be signed by an authorized representative of the operator and submitted to the Commission. Each ficld operator must maintain a "single-point-of-<:ontact" for SVS monitoring, testing, and data handling. 2. Wells that have neither produced nor injected during the preceding 6 months need not be tested, but must be tested within 48 hours after being returned to production or injection. The inspector is to be givct1 -24 hour notice prior to the test. 3. If a SSV or a SSSV fail, productionlinjcction may continue, but the valve must be repaired and ready for a witnessed ro-test within 2 weeks. If the valve fails the re-tcst, the well must be shut-in until the valve has been rcpairod or replaced and passes a test. 4. If both the SSV and the SSSV fail, the well must be shut-in until at least one of the valves is repaired or replaced and passes a test. The other valve must be repaired and ready for re-test within two weeks as in #3 above. s. LPSs will be tested as part of the SVS. If the pressure at which the pilot trips during the test is less then 50% of the primary separator pressure, or 25% of the flowing tubing pressure, or the designated minimum LPS pressure. whichever is greater, the LPS fails. 6. If the LPS trips at a pressure not less than 200A» below the required trip pressure. at the Inspecton discretion, the welt may be shut-in until repaired a.nd rc-tcstcd or must be æpaired and re-tested within 24 hours. If the LPS fails to trip, or trips at less than 20% of the required trip pressure. the 'Well must be shut-in until it has been repaired and re-tcstcd demonstrating the LPS and at least one of the safety valvcs are working properly. 7. Velocity type (differential pressure) valves, locally called "K valvcs", are to be flow tested like any other valve except that only I 00/0, by primary separation facility, need be tested each 6 months. Different wells must be tested each 6 months so that all "Ktt valves are tested at least every 5 ycan. Departures, if any. to thc above requirements arc to be rcconuncnded by a petrolcum inspector and must be approved by their supervisor or a commissioner. e e 20 AAC 25.265. Automatic Shut-in Equipment (a) A completed well with an offshore surface location and that is capable of unassisted flow of hydrocarbons to the surface, must be equipped with a commission-approved (1) fail-safe automatic surface safety valve (SSV) system capable of preventing an uncontrolle( flow; and (2) fail-safe automatic surface-controlled subsurface safety valve (SSSV) system capable of preventing an uncontrolled flow, unless another type of subsurface valve with that capability is approved by the commission; this valve must be in the tubing string and located below the muc datum or, if permafrost is present, below the permafrost. (b) An operator may demonstrate by a no-flow test that a well is incapable of unassisted flow 0 hydrocarbons to the surface. At least 24 hours notice must be given so that a representative of commission can witness the test. (c) The commission will, in its discretion, require an SSV system, an SSSV system, or both on well with an onshore surface location, after notice and an opportunity for hearing in accordancE with 20 AAC 25.540. (d) A representative of the commission shall witness operation and performance tests at interv and times as prescribed by the commission to confirm that the SSV system, SSSV system, an< associated equipment are in proper working condition. If an SSV system, SSSV system, or associated equipment fails the performance test, the system or associated equipment must be repaired within the time frame specified by the commission or the well must be shut in. Authority: AS 31.05.030 AS 31.05.095 '- ,.. r-=-' .=-:::; ;'";"' ----... '-: ..J : ~ .~ ".-... -- ~ 0.~ ; :/. ~..' I ...-- ...- - ': ¡, .~. -. . '- -. .~ .-=: :.; "-- !,::;,/ .~ .....;. ~_. -..;. TONY KNOWLES, GOVERNOR AT.ASIiA OIL AlVD GAS CONSERVATION COMMISSION 3001 PORCUPINE DRIVE ANCHORAGE. AlASKA 99501-3192 PHONE: (907) 279-1433 FAX: (907) 276-7542 November 14,1995 Eric WalkerlMonte Townsend P E Supervisors BPX Prudhoe Bay POBox 196612 Anchorage; AK 99519-6612 Dear Messrs. Walker and Townsend: A safety valve system (SVS) is required by regulation in all offshore wells and by Conservation Order in wells in onshore fields. The Commission considers the SVS criticaJ for safe and prudent production operations; therefore, it is the Commission's view that SVS should be tested at 6-month intervals. It is the Commission's goal to . witness at least 25% of these tests. The Commission anticipates some failures will occur, even when an SVS is properly maintained. The Commission considers thai a reason.1ble failure rate on a platformlpadldrillsite basis for all SVS components including the LPS, SSVand SSSV is 10% or less_ The Commission notes that for platfonnslpadsldriU sites: A 10010 or less SVS component failure rate is acceptable and no further action beyond normal testing and repair procedures will be e:\-pected. An SVS component failure rate greater than 10% may be considered negligent and a penalty may be assessed and a retest should be scheduled within 3 months. Should the retest failure rate be greater than 10010 another retest in 3 months will again be required and a penalty may be assessed. In addition, the Commission expects the SVS repair and maintenance records for all wells on the site over the past 12 months to be e 'cw and poSSlòle invesûgation. L-1f(}. Ill~i~~ Russell A ~ /Tudcemmn Babcock Commissioner Commissioner e e GREATER PRUDHOE BAY SAFETY VALVE MANAGEMENT SYSTEM 1.0 PURPOSE/SCOPE · Ensure the Safety Valve System (SVS) is functioning properly. The SVS consists of the Low Pressure Sensor (LPS) or P-pilot, the Surface Safety Valve (SSV), the SVS control panel, and, in certain cases, the Subsurface Safety Valve (SSSV). · Ensure the SVS provides the intended level of protection and well isolation. · Ensure the requirements set out by the Alaska Oil And Gas Conservation Commission (AOGCC) for Automatic Shut-In Equipment are met. 2.0 OBJECTIVES · Provide assurance that the SVS provides well isolation. · Remain in compliance with AOGCC Pool Rules: Prudhoe Conservation Order (CO) 341CA Rule 5(b) and CO 363, Lisburne CO 207A Rule 7(b), West Beach CO Rule 6(b), North Prudhoe CO 345 Rule 4, Point McIntyre CO 317 Rule 8, Niakuk CO 329 Rule 5, Midnight Sun CO 452 Rule 6, Aurora CO 457 Rule 3 and any other Greater Prudhoe Bay (GPB) Satellite Pool Rules that reference Automatic Shut-In Equipment. Also, remain in compliance with AOGCC Policy SVS Failures (Amended 3/94) and AOGCC letter dated November 14, 1995. · Follow American Petroleum Institute Recommended Practices standards for testing the SSV, which is API RP 14H. Also, follow AOGCC recommended practices for testing. · Execute a consistent SVS testing program throughout GPB. · Execute an optimized preventative maintenance program for the SVS. · Achieve a success rate of better than 90% for all SVS testing, and look for practical ways to improve performance. · Ensure timely reporting of results to the AOGCC and management. 3.0 GENERAL REQUIREMENTS SVS Testing Key System Tasks 1. Lead Operator or designee will identify wells that require State testing to remain in compliance. This includes a daily check to determine wells that require a test for coming on-line or WAG wells that begin gas injection. 2. Lead Operator or designee will schedule the manpower and equipment to perform the test in the required timeframe. 3. Lead Operator or designee will execute the SVS test. Repair SVS equipment as necessary. 4. Lead Operator or designee will input results into database. 5. SPOC will send results to AOGCC and management. Page 1 of7 e e SVS Preventative Maintenance Tasks 1. Lead Operator or designee will identify wells that require preventative maintenance. 2. Lead Operator or designee will coordinate valve maintenance with valve servicing crew. 3. Lead Operator or designee will exercise LPS, SSV, and/or SSSV, as required. Repair or servicing of the SVS equipment will be done as necessary. 4.0 KEY RESPONSIBILITIES First-Line Supervisor (Field OTL, FS1 OTL, FS2 OTL, FS3 OTL, and GPMA OTL) · Accountable for program implementation in their area. · Accountable for program regulatory compliance in their area. · Accountable for providing management assurance that the SVS is operable and compliant with regulations. · Ensure preventative maintenance program is properly executed. · Ensure SVS repairs and servicing are given the proper emphasis. · Ensure personnel responsible for executing the test program are qualified to perform the duties. Lead Operator or designee · Responsible for program implementation in their area. · Ensure procedures are current. · Oversee operator or qualified contractor that execute the procedures. · Ensure test data and test frequency is properly entered in database for State submittal. · Ensure repairs and servicing have timely completion. Operator and/or qualified contractor · Qualified skill set to execute test procedure. · Comprehends and complies with current testing procedures. · Executes test procedure. SPOC (Operations Staff Supt) · GPB "single point of contact" to/from the AOGCC on SVS issues. · Final reviewer and approver of SVS test data submitted to the State. · Ensure GPB SVS test program is implemented consistently. · Ensure overall test program complies with AOGCC and internal requirements. · Ensure SVS test program information is properly disseminated to GPB Operations. · Ensure management receives compliance and performance summaries. · Custodian of SVS management system and system improvements. Regulatory Compliance Engineer · Communicates and works with SPOC to ensure agency compliance. Page 2 of7 e e 5.0 PROCEDURES · The Safety Valves field report on the Internet is designed to highlight wells that are overdue for their regular safety valve inspection or are within one week of their inspection date, apps-alaska.bpweb.bp.com/sst drilling wells/operations/. In the Eastern area, RP42 Well Safety System Report on the PBAS system also identifies wells that are overdue for their safety valve inspection. In the GPMA, a SSV Access database is also used. · All areas of the field have a set annual schedule for 6-month testing of pads. The annual routine valve maintenance schedule will not be planned within 30 days of the schedule tests. Depending on the maintenance cycle, the valve maintenance could occasionally be within the 30 days. The valve maintenance procedure can be found in BP Greater Prudhoe Bay Christmas Tree Lube Service Procedure. · SVS testing and exercising procedures for Eastern PBU wells can be found on the Internet in the E-Book web site at nslope.bpweb.bp.comlgpb eoa drill sites/ in the folder DS Operating Procedures/ Wells/NORMAL OPERATIONS. These procedures are controlled and updated through the normal E-Book process. The procedures are: o DSO State Mandated Test -Preparation for Wellhead Safety System Tests o DSO State Mandated Test -Production Well LPP and SSV Testing o DSO State Mandated Test -Production Well LPP, SSV and SSSV Testing o DSO State Mandated Test -NGI, WGI, AGI Injection Well LPP, SSV, and SSSV Testing o DSO State Mandated Test -WAG MI Injection Well LPP, SSV, and SSSV Testing o DSO LPP and SSV 90-Day Cycling · SVS testing procedures for Western PBU wells can be found on the Internet in the E- Book web site at nslope.bpweb.bp.com/ebook/ in the folder WOA Production Operations/Field Production/Field Support Groups/ State Testing. These procedures are controlled and updated through the normal E-Book process. The procedures are: o State Test Production Wells o State Test MI Wells · SVS testing and exercising procedures for GPMA wells can be found on the Internet in the E-Book web site at nslope.bpweb.bp.comlgpma/ in the folder Drillsites/ Standard Operating Procedure/Wells/SSSVSSVLPP/Normal Operations. These procedures are controlled and updated through the normal E-Book process. The procedures are: o AOGCC Well Head Safety Valve System (SVS) State Testing Procedure Producing Wells Page 3 of7 e e o AOGCC Well Head Safety Valve System (SVS) State Testing Procedure WAG Wells and Gas Injection Wells · All the GPB SVS test procedures in E-Book were based on consensus field-wide generic procedures found in Attachment 1, Generic Test Procedure: Producing Wells, and Attachment 2, Generic Test Procedure: WAG Wells and Gas Injection Wells. · SVS test events by pad are entered in a database through the Wells Group Internet web site, apps-alaska.bpweb.bp.comlsst drilling wells/operations/. Once SVS test events are in the system, the system flags wells that failed the test and require a retest. The data can be reviewed and authorized before a SVS test report is generated and sent to the AOGCC. A monthly Operations manager report is generated from the information that was sent to the AOGCC. 6.0 VERIFICA TON · Outstanding Safety Valve Test Report, RP42 Well Safety System Report, and Setcim will identify all overdue wells. · Safety Valve Test Results database will maintain identification of failed wells that need retesting. Database also identifies test data that has not been sent to the AOGCC. · SPOC works with AOGCC to compare State Inspector test reports versus GPB Operations' submitted test reports. · SPOC will maintain relations with the AOGCC State Inspectors and technical and administrative staff. 7.0 MEASUREMENT Result indicators follow AOGCC guidelines for pad testing per AOGCC letter dated November 14, 1995. · " . . ., it is the Commission's view that SVS should be tested at 6-month intervals." (AOGCC Policy SVS Failures: 1. Wells must be tested by platform, pad, or drill site every 6 months unless a shorter period is designated by the Commission.) The interpretation of "6-month intervals" means a well must be tested anytime within the month that the well comes due. For example, if a well was tested on Jan 5, then the well must be tested anytime during the month of July to remain compliant. · "A 10% or less SVS component failure rate is acceptable and no further action beyond normal testing and repair procedures will be expected." · "An SVS component failure rate greater than 10% may be considered negligent and a penalty may be assessed and a retest should be scheduled within 3 months." Monthly summary reports will be generated · Tests by pads will be summarized by total wells, components, and failures. Page 4 of7 e e · Pads with more than 10% failure rate will be highlighted until pad returns to a 6- month cycle. · Overdue well SVS tests will be identified. · A rolling l2-month graph will show total components tested, sum of SSV failures, sum of LPS failures, sum of SSSV failures, and failure rate. · The Operations Manager will receive a field-wide performance summary. Accountable OTLs will receive an area performance summary. Performance can also be summarized by pad. · Monthly performance expectations will be gauged by the rolling l2-month performance. · The goal is to continuously improve SVS performance by reducing component failure rates and by keeping failure rates on all pads below the 10% state threshold. 8.0 FOLLOW-UP/IMPROVEMENT · SPOC will communicate all changes to everyone involved in the Safety Valve Management System. · Suggestions for test procedure improvements will be given to the SPOC who will communicate to everyone involved. Procedural changes will be made with consensus of the Lead Operators. · Performance improvements will mainly come from optimizing the preventative maintenance program and/or improvements to equipment repair or servicing. Changes to a pad program will be made with approval of the accountable OTL. Page 5 of? e e ATTACHMENT 1 GPB Generic SVS Test Procedure: Producine: Wells 1. Notify AOGCC Inspector at least 24 hours before scheduled test. 2. Notify appropriate personnel of impending test. 3. Install test gauge & bleed valve on pilot. Record P-Pilot Set Point Pressure. 4. Install test gauge on tree, if necessary. Note flowing tubing pressure. Record Separator Pressure and Common Line/Flow Line Pressure. 5. Shut in well using Wing Valve or suitable flowline valve and allow wellhead pressure to build up to +/- 300 psi above flowline pressure (or less with AOGCC inspector approval depending on well conditions). 6. Isolate P-Pilot from flow line. 7. Bleed off pressure to trip pilot, allowing SSV to close (also closes Surface Controlled SSSV if installed). 8. Record P-Pilot Trip Pressure. 9. Observe SSV closure. 10. Open Wing Valve to flowline to bleed tree pressure; establish pressure differential across SSV. 11. Note wellhead pressure. 12. Close Wing Valve. 13. Observe pressure between Safety Valve and Wing Valve or suitable flowline valve to determine if SSV is leaking. 14. Note stabilized pressure. 15. Block in SCSSSV control line, if surface controlled valve is installed. 16. Open SSV. (if the test passes, and there is no SSSV installed, return well to production. ) 17. Note stabilized pressure. 18. Open Wing Valve to flowline to bleed pressure; establish pressure differential across SSSV. 19. Close Wing Valve. 20. Note stabilized pressure. 21. Observe pressure between Safety Valve and Wing Valve to determine if SSSV is leaking. 22. Note stabilized pressure. 23. Open SSSV. 24. If the test passes, return well to production. Page 6 of7 e e ATTACHMENT 2 GPB Generic SVS Test Procedure: WAG Wells and Gas Iniection Wells 1. Notify AOGCC Inspector at least 24 hours before scheduled test 2. Notify appropriate personnel of impending test. 3. Install test gauge and bleed valve on pilot. Record P-Pilot Set Point Pressure. 4. Install test gauge and MI bleed equipment to tree, if required. Note Gas Injection Pressure. 5. Shut in well using Wing. Companion Valve or suitable flowline valve. 6. Isolate P-Pilot from flow line. 7. Bleed offpressure to trip pilot, allowing SSV to close (also closes Surface Controlled SSSV if installed). 8. Record P-Pilot Trip Pressure. 9. Observe SSV closure. 10. Bleed off at least 300 - 500 psi pressure from tree to establish pressure differential across SSV. 11. Note wellhead pressure. 12. Observe pressure between Safety Valve and closed wing, companion or flowline valve to determine if SSV is leaking. 13. Note stabilized pressure. 14. Block in SCSSSV control line, if surface controlled valve is installed. 15. Open SSV. 16. Bleed off 300 to 500 psi pressure from tubing & tree. 17. Note stabilized pressure. 18. Observe pressure between SSSV and Wing Valve to determine ifSSSV is leaking. 19. Note stabilized pressure. 20. Rig down test gauge and bleed equipment, if installed. 21. Ifthe test passes, open SSSV and return well to production. Page 7 of7 #21 [Fwd: AOGCC Order No. 39] e e Kar1 rectð- 5/u::(oþ Subject: [Fwd: AOGCC Order No. 39] From: John Norman <john _ norman@admin.state.akus> Date: Tue, 16 May 2006 15:25:12 -0800 To: Jody] Colomþie <jqdy_cÔlÔnibie@admin.state.ak.us> -------- Original Message -------- Subject:AOGCC Order No. 39 Date:Fri, 05 May 2006 15:17:21 -0800 From:Britt, Bill <BrittB~chevron.com> To:iohn norman~admin.state.akus CC:cathy foerster~admin.state.akus, dan seamount~admin.state.akus, "Haines, Dale A" <daleah~chevron.com>, "Bond, Marc D" <mbond(c4chevron.com> In the referenced order dated April 6, 2006, Chevron was ordered to "provide the Commission with documentation of the company's SVS failure response procedures that are consistent with Commission requirements" by today. The attached flow chart and associated guidance have been provided to our foremen and operators, and are in use at our facilities. «SVS Flow Chart. doc» We intend to work with your inspectors and engineers to improve these procedures and their implementation, as appropriate. Please feel free to call me if you have any questions. William .G. Britt, Jr. Health, Environment and Safety Team Leader Union Oil Company of California 909 West 9th Avenue, Anchorage AK 99501 Tel 907 263 7830 Fax 907 263 7901 brittb@chevron.com John K. Norman <John Norman~admin.state.us> Chairman Alaska Oil & Gas Conservation Commission Content-Type: application/msword SVS Flow Chart.doc Content-Encoding: base64 1 of 1 // 5/16/20063:25 PM State Witness Close out work order - Return to Jan Mabrey ... RETEST Testing Complete AOGCC form; ~ in 180 SVS Testing ... ... r' Completed ... Place copy in facility file; Send copy to Juanita & AOGCC ¡ (1) FAIL COMPONENT Operator needs to notify Jan Mabrey and work order must be generated Well may stay on if one of the components passes (2) FAIL COMPONENT Operator needs to notify Jan Mabrey and work order must be generated If both SSV & SSSV failed well must be SHUT IN. Put plan in place to repair or replace components I YES ~ Repairs must be completed within 14 days. RETEST State must be notified when repairs are ... ... ASAP complete. Schedule a retest. ,.. e RETEST FAILS Well must be SHUT IN LPS test RETEST 90 days 1 e Well must be shut in until repaired & retested. The LPS and at least one of the SV's must be working to return well to production 1. State requires a 24 hour notice prior to the 180 day witness test. 2. Prior to bringing a well on production or injection if well has been Shut - In for a period of (6) months or longer. Well must have a witness test within forty-eight (48) hours of return to production or injection. 3. Anytime a SSSV is pulled for whatever reason the well must be tagged e showing: (Call Jan Mabrey and fill out a work order) (1.) Date of removal. (2.) Reason for removal. We have (14) fourteen days from removal date to replace SSSV. If the SSSV can not be replaced within the 14 day period, well must be shut in. Submitting a variance, the State may grant a written approval to operate well in this mode. Assuming the SSV tests good. e 4. Chris Myers will be the single point of contact for SVS and no-flow monitoring in Cook Inlet Offshore and Onshore. Please send to Chris a hard copy or em ail of ªº correspondence with State. #20 .. e e Chevron === Dale A. Haines Operations Manager Union Oil Company of California P.O. Box 196247 Anchorage, AK 99519-6247 Tel 907 263 7951 Fax 907 263 7607 Email daleah@chevron.com RECEIV'E APR 1 4 April 12, 2006 Alaska Oil (~ Gas Cons. Co:mmÎss¡on Mr. John K. Norman, Chairman Alaska Oil and Gas Conservation Commission 333 W. ih Avenue, Suite 100 Anchorage, Alaska 99501-3539 Dear Chairman Norman: Reference: AOGCC Order No. 39. effective Aprjl1. 2006 On March 21, 2006, in the reference order, the Alaska Oil and Gas Conservation Commission (AOGCC) directed Union Oil Company of California (UOCC) to provide monthly written progress reports on the fifteenth day of each month concerning corrective actions included in the order. This is the first such report, due on or before April 15, 2006. A check in the amount of $400,000 was hand delivered to the AOGCC on March 31,2006. This corrective action item is closed. The SVSs on the Steel head Platform were tested on February 18, 2006. The tests were witnessed by AOGCC Inspector Lou Grimaldi. The test results were submitted to the AOGCC on February 21, 2006 by email. There was one component failure during the test. That failure was corrected on February 18. The next tests will occur on or before August 18, 2006. A copy of our SVS failure response procedures will be provided to you prior to April 30, 2006. This corrective action item will be closed at that time. Our Health, Environment, and Safety Manager provided training in AOGCC SVS requirements to our foremen on December 8, 2005. The foremen subsequently provided training to their crews at our facilities where SVS testing is required. This corrective action item is closed. Chris Myers, our Operations Superintendent, is our Single Point of Contact for SVS testing at our facilities. Mr. Myers communicated this to Jim Regg in December 2005, and sent Mr. Regg an email on April 10, 2006 reconfirming this assignment. This corrective action item is closed. Union Oil Company of California I A Chevron Company http://www.chevron.com ",' e e Mr. John Norman AOGCC April 12, 2006 Page 2 DataStream 7i is now being used to schedule and track required actions associated with SVS testing at our facilities. In addition to D7i, the Alaska Integrated Information Web Site provides weekly reports on all open work orders, including SVS testing work orders. Since D7i was determined to be fit for purpose, no evaluation of alternative systems occurred. These corrective action items are closed. Desk procedures associated with the D7i process exist. Additional policies and procedures have been designed and are being finalized. This corrective action item will be closed when those policies and procedures are finalized. John Zager, our Alaska General Manager, addressed this noncompliance with managers at a Managers Meeting on December 19, 2005. This corrective action item is closed. We began providing more regulatory obligation information to more new field supervisors and to others in the field that are temporarily "stepped-up" at the end of 2005. Lois Born, our Operations Excellence Coordinator is working with Johnny Santiago, our Kenai Operations Coordinator, to produce a checklist and supporting reference materials that will formalize this increased effort. This corrective action will be closed when the checklist and supporting material are finalized. Our facility foremen are currently reviewing our no flow documentation to confirm the adequacy and accuracy of the information. This corrective action item will be closed when we complete this effort. After D7i was selected as the tool to provide notice of the need for SVS testing at individual facilities, the usefulness of status displays was reevaluated. The displays were determined to be redundant and less useful than the periodic maintenance tracking tools in use. Absent specific direction from AOGCC, we do not intend to install the displays and consider this corrective action item closed. David Bailey, our Compliance Coordinator, will observe SVS testing at our Happy Valley facility in May prior to coordinating an audit of the Steel head with AOGCC inspectors. We expect the audit to occur in August 2006. This corrective action item will be closed when the audit is complete. Mr. Bailey is also working with selected UOCC subject matter experts to assess safety and environmental compliance systems documented in our compliance matrix. His effort should be completed by July 2006. This corrective action item will be closed when the assessment is complete. Union Oil Company of California I A Chevron Company http://www.chevron.com ~ ,þ 4.1 e . Mr. John Norman AOGCC April 12, 2006 Page 3 Should you have any questions regarding any of the information provided, please contact Mr. William Britt at the above address. 0~~~ Dale Haines Union Oil Company of California, Alaska Operations Manager Cc: Dan Seamount, Commissioner Cathy Foerster, Commissioner John Zager, Union Oil Company of California Marc Bond, Union Oil Company of California Bill Britt, Union Oil Company of California Kevin Tabler, Union Oil Company of California Union Oil Company of California I A Chevron Company http://www.chevron.com #19 . . Chevron === Dale A. Haines Operations Manager Union Oil Company of California P.O. Box 196247 Anchorage, AK 99519-6247 Tel 907 263 7951 Fax 907 263 7607 Email daleah@chevron.com RECEIVED March 30, 2006 MAR 3 0 2U06 Mr. John K. Norman, Chairman Alaska Oil and Gas Conservation Commission 333 W. 7th Avenue, Suite 100 Anchorage, Alaska 99501-3539 Alaska Oil & Gas Cons. Commission Anchorage Re: AOGCC Proposed Decision and Order No. 30 Dear Chairman Norman: I am writing in regard to the referenced proposed decision and order issued on March 21, 2006 by the Alaska Oil and Gas Conservation Commission. Enclosed with this letter you will find a check for $400,000 to satisfy the civil penalty associated with this order. If you have any questions please contact me at (907) 263-7951, or at the above address. Sincerely, Ð& ~JaW-, Dale Haines Enclosure Union Oil Company of California / A Chevron Company http://www.chevron.com e . ~ " 'he Northern Trust Company Chicago, IL Payable Through Oakbrook Terrace, IL 70-2382 ~ Union Oil Company of California Field Account No. 30482570 7901 Pay Four Hundreq ThoùsaÍ1d Dollars And 00 Cents***************************************************** To the Order of Date Check Amount STATE OF ALASKA ALASKA OIL & GAS CONSERVATION COMMISSION . 333 WEST 7TH AVENUE SUITE 100 ANCHORAGE;AK?~ 9:9501 Unites States 24-MAR-06 ; "-OOf~O ~,,- 1:07 ~ '1 238 281: 0 30 ~8 2570"- #18 . . STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Avenue, Suite 100 Anchorage Alaska 99501-3539 Re: Unocal Oil Company of California, as Operator of ) Trading Bay Unit; Steelhead Platform; Automatic ) Shut-in Equipment Enforcement Action ) AOGCC Order No. 39 March 21, 2006 PROPOSED DECISION AND ORDER The Alaska Oil and Gas Conservation Commission ("Commission") issued a Notice of Proposed Enforcement Action under 20 AAC 25.535(b) on December 12, 2005 stating that it considered that Union Oil Company of California ("Unocal") may have violated provisions of 20 AAC 25.265(d) in connection with operating the wells on the Trading Bay Unit Steelhead platform. The Commission proposed specific corrective actions and a $400,000 civil penalty under AS 31.05.150(a). After reviewing additional information from Unocal as part of the informal reVIew process, the Commission is issuing a proposed Decision and Order that is substantially the same as the notice of proposed enforcement - Unocal is ordered to pay a $400,000 civil penalty and take corrective actions to ensure compliance with safety valve systems requirements. A. Summary of Proposed Enforcement Action In its Notice of Proposed Enforcement Action, the Commission identified an apparent violation by Unocal of 20 AAC 25.265 by failing to test the safety valve systems ("SVS") for all Proposed Decision and Order Page 2 of 13 . . March 21, 2006 Steelhead wells between December 17, 2003 and March 22, 2005, and after testing in March 2005 by continuing to operate Well M-19RD1 with a failed subsurface safety valve ("SSSV") beyond the time allowed by the Commission to make repairs. The Commission proposed to order the following corrective actions by Unocal: (1) that the testing frequency of SVS' s on the Steelhead platform shall remain every 6 months; (2) that SVS test results, regardless of Commission witness, shall be required to be submitted to the Commission within 1 week of completion; (3) that within 30 days after the effective date of the enforcement order, Unocal shall be required to provide the Commission with documentation of the company's SVS failure response procedures that are consistent with Commission requirements; (4) that Unocal shall adopt the corrective actions identified by its root cause analysis investigation, which are consistent with Commission expectations for compliance with SVS requirements; and (5) that written progress reviews shall be required detailing corrective actions completed, and updating the status and timing for the completion of unfinished corrective actions. The report would be due on or before the 15th of each month following the effective date of the enforcement order, and until all corrective actions have been completed. I TBD M-19RD: PTD 1931170; API # 50-733-20421-01 Proposed Decision and Order Page 3 of 13 . . March 21, 2006 B. Safety Valve System Testing Requirements Under 20 AAC 25.265, a completed well with an offshore surface location and that is capable of unassisted flow of hydrocarbons to the surface must be equipped with a commission- approved fail-safe automatic SSV and fail-safe automatic surface-controlled SSSV (unless another type of SSSV is approved by the Commission). Performance testing of SVS witnessed by a Commission representative must be carried out "at intervals and times as prescribed by the Commission." The Commission has prescribed the following requirements addressing test interval and response to test failures in the document "AOGCC Policy - SVS Failures" dated March 30, 1994: 1. Wells must be tested by platform, pad or drill site every 6 months unless a shorter period is designated by the Commission. 2. Wells that have neither produced nor injected during the preceding 6 months need not be tested, but must be tested within 48 hours after being returned to production or injection. 3. If a SSV or a SSSV fails, production/injection may continue, but the valve must be repaired and ready for a witnessed re-test within 2 weeks. If the valve fails the re-test, the well must be shut in until the valve has been repaired or replaced and passes a test. 4. If both the SSV and the SSSV fail, the well must be shut in until at least one of the valves is repaired or replaced and passes a test. The other valve must be repaired and ready for re-test within two weeks as in #3 above. The maintenance of test records by an operator is required by 20 AAC 25.310. The Commission maintains detailed records of any SVS tests it witnesses; there were no SVS tests Proposed Decision and Order Page 4 of 13 . . March 21, 2006 witnessed on the Steelhead platform during 2004. Unocal was orally notified on April 27, 2005 about missing SVS test reports for 2004. Further investigation and information gathering by the Commission confirmed that Unocal could not produce 2004 SVS testing records for Steelhead platform. Unocal provided updated information about their internal root cause investigation in response to the Commission's August 25, 2005 notice of investigation and request for information. Evidence gathered during independent investigations by the Commission and Unocal confirmed that SVS testing had not been performed between December 7, 2003 and March 22, 2005. Commission-required tests should have been performed in June and December of2004. C. Informal Review Unocal requested an informal review as provided in 20 AAC 25.535(c) in response to the Commission's Notice of Proposed Enforcement Action. An informal review conference was commenced January 13, 2006 with a recess granted until February 15, 2006 to provide Unocal time to compile additional information and considerations that might impact the Commission's enforcement decision. During that time, Unocal was specifically offered an opportunity to identify possible projects that might offset civil penalties, with the burden of demonstrating the benefits to the State of Alaska clearly residing with Unocal. The Notice of Proposed Enforcement Action specified several factors which had been applied to mitigate the proposed civil penalty amount, including Unocal's good faith effort to determine the root cause for Steelhead platform's lack of SVS testing, Unocal's voluntary Proposed Decision and Order Page 5 of 13 . . March 21, 2006 extension of its comprehensive internal compliance review to all Unocal-operated facilities in Cook Inlet, the lack of injury, the infrequent historical SVS failures, and the robust SVS design. In a February 9, 2006 letter (and during the February 15 conclusion of the informal review), Unocal identified the following mitigating factors for the Commission to consider "when assessing the appropriate level of penalties for this event": (1) No bad faith was involved in the violation; (2) No injuries were involved in the noncompliance event; (3) Failure occurred as a result of personnel not understanding regulatory obligations; (4) No need to deter similar behavior; Unocal moved immediately to determine and correct the causes; (5) Long history of regulatory compliance; (6) Event was an anomaly; a single failure in judgment at a single location; (7) Robust SVS exists for Steelhead wells; and (8) Noncompliance is similar to the situation addressed in Commission Order 33 dated May 20,2005 and should be used as comparison for similar enforcement.2 Unocal did not follow up on the opportunity offered to identify beneficial offset projects. In the course of the informal review process, Unocal provided no new information to warrant a change to the proposed enforcement actions. The Commission's efforts to gather 2 Commission Order 33 involved an enforcement action against ConocoPhillips Alaska Inc. for violations surrounding a waste injection well integrity failure. Proposed Decision and Order Page 6 of 13 . . March 21, 2006 relevant information and to review the investigative record thoroughly, while time consuming, were able to account for reasonable mitigation, and propose enforcement actions that are appropriate to the violations. Some of the mitigating factors identified by Unocal were merely restatements of what the Commission had already considered in the proposed penalty. The following mitigating factors identified by Unocal require additional comment from the Commission: (1) reliance on the robust design of the SVS as mitigation for the seriousness of the event (and offset of the penalty amount), (2) personnel not understanding regulatory obligations, (3) Unocal's assertion that the Steelhead violations are analogous to those summarized in Commission Order 33, and (4) the need to deter similar behavior. Robust Design: The Commission's statements in the Notice of Proposed Enforcement Action referencing a robust SVS system on the Steelhead platform were a reflection of Unocal' s own assertions about the system validated by past performance testing witnessed by the Commission and the levels of redundancy in the systems. Those comments have no relevance to requirements to test as outlined in Commission regulations. In fact, Unocal is referred to the February 2006 SVS test results from the Monopodplatform as an example of why it is important to test. Despite having a robust SVS, Monopod testing showed a significant deterioration in SVS reliability with multiple component failures (22% failure rate) compared to previous tests.3 Good oilfield engineering practices dictate that the reliability of safety systems must be periodically assessed through testing, regardless of how robust the system design appears. 3 Historic failure rate is 7%; Monopod platfonn was placed on a 90-day test cycle effective February 17,2006 until an acceptable level of perfonnance is achieved. Proposed Decision and Order Page 7 of 13 . . March 21, 2006 Lack of Understanding by Personnel: Unocal's assertion that Steelhead personnel did not understand the regulatory obligations is not supported by the following facts: (1) A Commission inspector witnessed SVS testing in March 2005 and advised Unocal personnel of their obligations to test the SVS and maintain testing records. (2) The Commission sent Unocal a letter dated June 18, 2004 reiterating SVS testing requirements (although it is not the Commission's responsibility to remind an operator of its obligation to comply with clearly stated regulatory requirements). (3) Unocal personnel failed to follow Unocal's own internal SVS testing guidelines, which require more frequent testing 4 than does the Commission. (4) Unocal' s Steelhead platform "Safety/Obligations Inspection Report" for the months of July 2004 through February 2005 clearly show platform personnel were aware of and chose to neglect SVS testing obligations. Comparison to Commission Order No. 33: Unocal's comparison to Commission Order 33 is not valid. Unocal incorrectly asserts that the primary difference between the noncompliance outlined in Commission Order 33 and the Steelhead noncompliance is that Unocal did not self- report. Rather, there are several other, more serious differences between the two incidents, as follow: 4 Unocal policy is to test the SVS every 3 months; Commission requirements are to test every 6 months Proposed Decision and Order Page 8 of 13 . . March 21,2006 (1) Unocal states that they "were simply not aware of the violation" and when informed of the problem "addressed it swiftly and completely." The previous paragraph clearly shows that Unocal was aware of the requirements and simply chose to ignore them. (2) Unocal has been unable to demonstrate through alternative documentation provided to the Commission that the system maintained an acceptable level of integrity during the time in violation. (3) Although no actual harm or waste occurred, in the Unocal violation there was significant potential for catastrophic harm to people, property, and the environment, as well as potential waste of the hydrocarbon resource. The Need to Deter Similar Behavior: Unocal's assertion that there is no need to deter similar behavior assumes that Unocal is the only operator whose behavior needs to be influenced. In the Commission's judgment, there is a need not only to deter Unocal from repeating this violation but also to demonstrate to other Operators in Cook Inlet and throughout the State of Alaska the seriousness with which the Commission views such a violation. Therefore, the Commission sees a strong need to deter similar behavior. D. Penalty Amount Failure to comply with SVS regulatory requirements is a serious category of violation that has the potential to result in significant public harm. A loss of well-control in Cook Inlet could result in human injury or death, environmental damage, physical waste of valuable hydrocarbon resources, destruction of property, and significant loss of confidence by the public Proposed Decision and Order Page 9 of 13 . . March 21, 2006 in the industry's ability to operate in a prudent and responsible manner. In past enforcement matters the Commission has identified five factors as among those that should be considered in determining the appropriate amount of a civil penalty. These are: (1) the good or bad faith of the operator in violating the law; (2) the injury to the public resulting from the violation; (3) the benefits derived by the operator from its violation; (4) the operator's ability to pay the penalty; and (5) the need to deter similar behavior by the operator and others in the future. The civil penalty totaling $400,000 was calculated by multiplying a daily penalty amount as provided under AS 31.05.150 by the number of days each violation occurred as follows: (1) $123,000 for violating 20 AAC 25.265 by continuing to produce TBU M- 19RD following the identified failure of the SSSV ($1,000 per day for 123 days5); (2) $277,000 for violating 20 AAC 25.265 by failing to test automatic shut-in equipment on the Steelhead Platform wells during 2004 ($1,000 per day for 277 days6). 5 123 days from April6, 2005 through August 9, 2005; April 6 is the 15th day following the SSSV failure witnessed by a Commission inspector - there were no subsequent tests; August 9 represents the date the Commission was requested to witness are-test of the failed SSSV in TBU M-19RD. 6 277 days from June 18, 2004 through March 21, 2004; June 18 is the day following the 6-month anniversary of SVS testing completed December 17, 2003; March 21 is the day prior to first SVS testing on Steelhead platform following the December 17, 2003 test. Proposed Decision and Order . Page 10 of 13 . March 21, 2006 The Commission has accounted for all appropriate mitigating factors in establishing the proposed enforcement action by not calculating penalties based on each possible violation (There were in excess of 40 possible violations each day.)? and by reducing the daily penalty amount from the maximum of $5,000 per day down to $1,000 per day as provided for in AS 31.05.150. A substantially larger financial penalty would have been included in the notice of proposed enforcement had the Commission not already accounted for mitigating circumstances. Unocal has argued that the proposed penalty amount is excessive because a single failure in judgment at a single location should not be treated as multiple days in violation. The Commission disagrees with Unocal's argument. Except as provided by regulation or specific Commission approval, each day beyond the required test date that the SVS is not tested represents a violation. E. Findings and Conclusions Unocal acknowledged that it failed to perform SVS tests at the required frequency during 2004, and failed to repair safety valves within the required timeframe during 2005 in Well TBU M-19RD. Where appropriate, the Commission has taken into account mitigating circumstances in establishing the enforcement action to be taken in response. Unocal was provided 7 Unocal pointed out in its February 9, 2006 letter an apparent discrepancies in the number of wells (13 versus 17) requiring dedicated SVS on Steelhead in an attempt to show the violation was a single failure in judgment; ifUnocal is correct, then the failure rate for SVS testing during March 2005 would have resulted in a failure rate triggering 90 day SVS testing; since Unocal did not test the Steelhead SVS again until August 26,2005 there would have been additional testing violations; the Commission chose not to include this in the penalty calculation. Proposed Decision and Order Page 11 of 13 . . March 21, 2006 opportunities during the enforcement phase of this investigation to identify additional factors but no additional mitigating factors were identified. The Commission does note Unocal management's acceptance of responsibility for the violations and the Commission acknowledges the excellent work subsequently done at all Unocal Cook Inlet facilities to address the issues exposed by the SVS violations at the Steelhead Platform. The Commission has seen immediate and positive results from Unocal's post- violation efforts to comply with testing obligations as well as improved communications. The Commission also notes Unocal's high level of cooperation and outstanding proactive efforts to investigate the root causes of testing noncompliance. Detailed presentations of Unocal's findings have helped the Commission fully understand the background information about the Steelhead Platform operations and the factors that led to the testing violations. The root cause investigation and the company's post-violation response do not, however, alter the basic facts related to this violation as discovered by the Commission; i.e.: that no SVS testing was performed on Steelhead Platform wells between December 17, 2003 and March 22, 2005 and that TBU M-19RD was produced with a failed subsurface safety valve from April 6, 2005 through August 9, 2005, both clear violations of Commission requirements. The company's post-violations actions have, however, clearly demonstrated the seriousness with which Unocal management views such violations. For the reasons stated above, the Commission finds that Unocal violated 20 AAC 25.265 in connection with operating the wells on the Trading Bay Unit Steelhead Platform during 2004 Proposed Decision and Order Page 12 of 13 . . March 21, 2006 and 2005, and concludes that significant sanctions including the civil penalty assessed below are appropriate. NOW THEREFORE IT IS ORDERED THAT: 1. Within 30 days after this Decision and Order becomes final, Unocal shall pay the Commission a civil penalty of $400,000. 2. Unocal shall comply with the following corrective actions: (a) Testing frequency of SVS's on the Steelhead Platform shall remain every 6 months unless more frequent testing is ordered by the Commission based on SVS performance; (b) SVS test results, regardless of Commission witness, shall be submitted to the Commission within 1 week of completion; (c) Within 30 days after this Decision and Order becomes final, Unocal shall provide the Commission with documentation of the company's SVS failure response procedures that are consistent with Commission requirements; (d) Within 30 days after this Decision and Order becomes final, Unocal shall adopt the corrective actions identified by its root cause analysis investigation regarding: (1) Training; (2) Single Point of Contact; (3) DataStream Assessment; (4) Management Discussion; (5) Orientation; (6) Reassessment of No Flow Wells; (7) SVS Status Displays; (8) Policies and Procedures; (9) Steelhead Survey; (10) Alternative System; and (11) Compliance Survey; and (e) Unocal shall provide written progress reviews detailing actions completed, and updating the status and timing for the completion of unfinished corrective actions. Proposed Decision and Order Page 13 of 13 . . March 21, 2006 Reports shall be due on or before the 15th of each month following the effective date of this Enforcement Order, and until all corrective actions have been completed. 3. This Decision and Order shall become final on the 11 th day after the date of its issuance shown below, unless within 10 days after the date of issuance Unocal files a written request for a hearing under 20 AAC 25.535(d). If Unocal timely files a written request for a hearing this Decision and Order shall be of no effect. ~~±ier CZ7~~ Daniel T. Seamount, Commissioner Proposed Decision and Order Page 14 of 14 ) ) March 21, 2006 Affidavit of Mailin2 I HEREBY CERTIFY THAT A TRUE AND CORRECT I: ...D :.-=¡ t:Q rit .-=¡ rli.J... t::",,~,~:~: "',i,'*:::·] ·,I.,!::m,t~;'~IIl.] ..'J f..- k..l",i,~,,¡,.,1 ""'I~] 01:,'1, k {~¡ ~'!''''''''''I (,,'1 ~l-"1\o{.] 11~,r-,:~,~ ru .r¿... 6. fA'\- ¡¡'~~A ~l<cm .....D AmA1URHtJt.,d ~ ~ . 9 Œ. hmm IT1 u.s. Postal ServiceTM CERTIFIED MAILTM RECEIPT , . " '" Jï. "/ . , ',., .,. . . ..' p. '... COpy OF THE A TT ACHED DECISION WAS MAILED TO THE FOLLOWING ON MARCH 21, 2006: Postage $ .. tJrf( UNIT ID: 0535 8 Certified Fee 1~('/t--P-OÓ$'t-mŠaT1~?~1 CJ Return Reclept Fee 2. 40 v ~~ CJ (Endorsement Required) ~6!( Here 0 , O~ ?J~ CJ Restricted Delivery Fee Aol r' UA Dr4'1UB'06 ¡ n I .....D (Endorsement Required) ;cir fWi"UQ",rlQ) ~ ) ,...::¡ ¡() \ b .-=¡ Total Postage & Fees $ 3.27 Ö'itk11..06 /" ,Ø¡' .::r- \ ::-......--....,... 'l CJ SeftTo Dt (1. C '·""J¿'ê?~CE ~ ..L_N.._~~_____!::______-':\.~~~.~__ºE___._~~~fQ?:~L~_il~~~E¿. Street, Apt. NO';i) t) '~' ' . .~!..~~_l!.!_~~_ _~_:___:____~~__Jg~_Q4:J_________ ________.__________________. ~~:~~:+~~'G~ --ÄK.. qq5\q-~41 ~f:!llIJII~"¡'III') -.."t'r:II~{~,¿:...'1...~!iIIi1!r_J Union Oil Company of Calif ami a Attn: Dale A. Haines P.O. Box 196247 Anchorage, AK 99519-6247 Delaney, Wiles, Hayes, Gerety, Ellis & Young, Inc. Attn: Stephen M. Ellis 1007 W. yd Ave., Suite 400 Anchorage, AK 99501 ~ UNITED SmTES IIir POSTlJL SERClICi. ***** WELCOME TO ***** 5TH AVENUE POSTAL STORE ANCHORAGE, AK 99501-2351 03/21/06 03:38PM store USPS Trans 68 Wkstn sys5002 Cashier KGS3HH Cashier's Name DENISE Stock Unit Id WINDENISE PO Phone Number 800-275-8777 USPS # 0203150535 State of Alaska, Department of Law Office of the Attorney General 1031 W. 4th Ave, Suite 200 1. First Class Destination: Weight: Postage Type: Affix. Post.: Total Cost: Base Rate: SERVICES Ce rt i f i ed Ma il 70041160000136211816 Subtotal Total 0,00 Anchorage, AK 99501-1994 99519 2.90 02. Affixed -3.27 3.27 0.87 (};"\ 'ì ~tQ IJtf)Ç )iL' \ Ceresa L. Tolley If) 2.40 Subscribe nd sworn to before me this 21 st of March, 2006 "yP~~~~ ~ J ~jt~~ubliC My Commission Expires // /~ / lOb O.CIO 0.00 Number of Items Sold: 1 We here at the Postal Store appreciate You as our customer and wish you a II........" II_'~..I_" __..I _ r\_.t:_ LI_:, \/_-- Ll# ~ > t"" > ~ ;:J\ a= > ~ 0 ~ - ~ t"" oooo( > z z ~ 0 I ~ Þ-Ì- C1 = -. ¡" > cr a - ~ _. tÐ tÐ tÐ .. ~ ~ "" 0 I rJ Z '. \ ~ C" ~ ~ ~,"\ ìl ~ ~ ) ¿, > ..:." Þ-Ì \\ \ t"" Õ ~ Z " 8 .. ~ ~ - ~ ~ oooo( o z z > ~ ~ I > ~ ~ ÞOOO4 ~ oooo( > ~ - o z ~4I')ltu~~" ~ ~~ ~ ~\- ) G ~~ » ~h1 J) c: .. ~.\ t~ ~ S ;;:lJV ~ ~ 1- ~ __\ Þ-Ì ,.. f '" I'..... -- r ~ '" tN ~¥~~ - d ~ ~ ~ ~ ~, ' ~ ~ ~ I :t ~ ~~ ~~~ ,. _/ Þ-Ì ~ ~ ~ ÞO'tf == o 2 ~ rJ ~ '-0 \ ~ ~ """"'- ).,) N ~ .JÕ'~ -+l\}J./\J I I I t\ ~...J ~ Ô' " :) - V\ ~ 'tl #16 ) ) Chevron III Dale A. Haines Operations Manager Union Oil Company of California P.O. Box 196247 Anchorage, AK 99519-6247 Tel 907 263 7951 Fax 907 263 7607 Email daleah@chevron.com February 9, 2006 RECEIVED FEB 0 9 2006 Alaska Oil & Gas Cons. Commission Anchorage Mr. John K. Norman, Chairman Alaska Oil and Gas Conservation Commission 333 w. ih Avenue, Suite 100 Anchorage, Alaska 99501-3539 Steel head Platform Non compliance Event Dear Chairman Norman: I am writing to request consideration by the Alaska Oil and Gas Conservation Commission (AOGCC) of mitigating factors related to the Steel head Platform SVS noncompliance event. Union Oil Company of California (Union Oil) staff and AOGCC staff and Commissioners have been in frequent communications regarding the facts of the event. In summary: · Union Oil failed to perform SVS tests at the required frequency during 2004 and 2005 at gas wells on the Steelhead Platform · The failure was limited to one facility and one time period · Union Oil failed to repair two safety valves within the required time frame during 2005 · Union Oil failed to communicate the status of those safety valve repairs to the AOGCC or to shut the wells in as required · Under rule 20 MC 25.265 the penalties for these failures could be up to a maximum of $5,000 per day per event We respectfully request that the AOGCC Commissioners consider the following factors when assessing the appropriate level of penalties for this event: · No bad faith was involved in the violation. Union Oil has a long history of adherence to regulatory policies, and this event was an anomaly. Union Oil was forthcoming regarding the facts and root causes of the event, and committed to a suite of corrective actions to address those root causes. · No injuries were involved in the non compliance event. Although the systems were not tested, they functioned properly at various times during the non compliance period. A robust SVS design and multiple levels of shut in reduced potential for an event, as did low work activity levels on facility. · Although gas was produced from the wells during the period of non compliance, the failure to test the systems and communicate repair status occurred as a result of specific Union Oil Company of California I A Chevron Company http://www.chevron.com ) ) Mr. John Norman AOGCC February 9, 2006 Page 2 personnel not understanding our regulatory obligations. The failure to adhere to the rules was not a deliberate intent to derive benefits through substandard maintenance practices or reduced operating expenses. · No need exists to deter similar behavior or protect regulatory integrity. As noted above, we moved immediately to determine the causes of the event and to correct those causes. This event has strengthened our internal controls and oversight of this and other compliance and regulatory issues. · We have a long history of regulatory compliance. We take pride in that record. We have a history of proactively engaging the AOGCC when potential issues arise. Again, this event was an anomaly. · A single failure in judgment at a single location placed multiple wells in a non compliant status for an extended time. There are 13 gas wells on the Steelhead, not 17. Four of the wells have dual flow lines but single safety systems. Finally, we suggest that this instance of non compliance is similar to the ConocoPhillips (CPAI) situation addressed in Commission Order No. 33. In Commission Order No. 33, the proposed fine was: · $5,000 for violating reporting requirements, · $5,000 for violating corrective action plan requirements, and · $43,250 for 171 days of failing to obtaining approval to continue injecting Even though the Commission found that "the clear regulatory requirements for well integrity were violated", the Commission reduced the fine to $25,000. The Commission reduced the penalty in light of three factors: · self-reporting and self disclosure, · cooperation throughout the investigation, and · an absence of substantial risk associated with the violations. The instances of Steel head SVS testing and repair non compliance appear to be analogous to the CPAI violation from a safety and environmental perspective. Two of the three factors upon which the Commission relied in the CPAI order are plainly present here. First, we believe we have cooperated throughout the investigation. Indeed, we performed the investigation and provided the results to the Commission. Second, there was no substantial risk to public health or the environment as a result of the failure to test. In the AOGCC December 12, 2005 letter, you noted "the robust SVS design (including multiple levels of automatic shut in on each well), and demonstrated functionality of the SVS's during multiple platform shut-in events during 2004." Thus the primary difference between this non compliance event and the CPAI violation is that CPAI brought the matter to the Commission's attention while we did not. It is clear that we did not hide the failure to test. We were simply unaware of the violation. Once we were informed of Union Oil Company of California I A Chevron Company http://www.chevron.com ) ') Mr. John Norman AOGCC February 9, 2006 Page 3 the problem, we addressed it swiftly and completely. We initiated an investigation, completed a root cause analysis of the problem, and began corrective actions that included all of our facilities in Cook Inlet. It would thus appear that the fine associated with this non compliance should be comparable to the CPAI fine. After the reduction noted above, CPAl's fine appears to be: · $5,000 for violating reporting requirements, · $5,000 for violating corrective action plan requirements, and · $15,000 for 171 days of non compliance. A comparable Union Oil fine would consist of: · $5,000 for violating reporting requirements, · $25,000 for 277 days of failing to test SVSs, and · $11,000 for 123 days of failing to repair 2 SVSs or shut in 2 wells. We appreciate your consideration of these factors and look forward to discussing them with you on February 15. If you have questions or need more information regarding this matter please contact me at (907) 263-7951, or at the above address. Si7re~. . .ó ~._~ / ~ ·BršA...-...JÞèµrs(;..,j~Cs- r¿;>.R.. Dale Haines Union Oil Company of California, Alaska Operations Manager Cc: Dan Seamount, Commissioner Cathy Foerster, Commissioner Union Oil Company of California I A Chevron Company http://www.chevron.com #15 ) ,f'ñ"\ t E' i ¡¡¡In I!' ii, i! II i? :it! r !U' ~J :' Ï"\\' 'c, '[- ~~"'\ ,.-. (::I,f'1·'., \ : ',: ,j:'i.Þ.,):( ,:f.'.;_"J,Ì' 'i' 1 ,I I fl~ ',1 ", i; \ \ f; I !~ \ -"', '\ ;f i¡n'-, \ '¡Il ¡1.n/,,;, j\ nJ) ,1.Jj I!...i.I I!.....::::JU ¡,,~,..;' .î ' 1 !~ Ii !IJ \ , \ u~~ AIfASKA OILAlWD GAS CONSERVATION COMMISSION / / / f j j January 13,2006 Dale Haines Oil and Gas Operations Manager U nocal PO Box 196247 Anchorage, AK 99519 Re: Continued Informal Review TBU Steelhead Platform Automatic Shut-in Equipment Enforcement Action Dear Mr. Haines: ) FRANK H. MURKOWSKI, GOVERNOR 333 W. pH AVENUE, SUITE 100 ANCHORAGE, ALASKA 99501-3539 PHONE (907) 279-1433 FAX (907) 276-7542 This is to notify Unocal that the Commission recessed the informal review that was commenced today and that we will reconvene on February 15, 2006 at 1 :30 pm. It is the expectation of the Commission to conclude the informal review at that time. Should you have additional evidence or information you wish to provide to the Commission, please submit it at least one week prior to the reconvening of the informal review conference. If you have any questions you may contact Jim Regg at 793-1236. cc: Steven Ellis, Esq. Dave Cole, Unocal AOGCC Commissioners Jim Regg, AOGCC / #14 . . CONFIDENTIAL INTERNAL INVESTIGATION DOCUMENT #13 . . STATE OF ALASKA OIL AND GAS CONSERVATION COMMISSION Trading Bay Unit Steelhead Platform Enforcement Action - Informal Review January 13,2006 at 1:30 pm NAME - AFFILIATION (PLEASE PRINT) o (tl 'L \-tc.. \~l' .1 GUX ~ ~t>~BtA1Ct'-- c.u)t! /~'-" ß""l..'V - r_V/ Kéù I~ 4-.. "T.o.ß~ <:'\J~ ;1 ç/¡.-~ ADDRESS/PHONE NUMBER TESTIFY (Yes or No) ~ , 3- 1-<\ r I z. ~ 3 - ":-b'5 7- }1-~~- 7B~-. ,.:)/1'1- '7~OO ê..f'7-o7/3 #12 ~ ~1ÆJ\, ? Œ' ¡ ¡ il I ¡ ¡ ., . II . Ii! U U! . (ill rfw II IT' U IF I!J\ i :l!d\ L..i U U ~u u . ~. 7 fil ¡ ^, I '....\. ,Í ¡J \, 'U~, In \ uu U FRANK H. MURKOWSKI, GOVERNOR AI',ASIiA. OIL AND GAS CONSERVATION COMMISSION 333 W. 7'" AVENUE. SUITE 100 ANCHORAGE. ALASKA 99501-3539 PHONE (907) 279-1433 FAX (907) 276-7542 January 9,2006 Dale Haines Oil and Gas Operations Manager U nocal PO Box 196247 Anchorage, AK 99519 Re: Rescheduling of Informal Review TBU Steelhead Platform Automatic Shut-in Equipment Enforcement Action Dear Mr. Haines: The Informal Review meeting that was previously scheduled for January 10, 2006 at 1:30 pm at the Commission's Offices has been rescheduled at your request for January 13, 2006 at 1 :30 pm at 333 West 7th Avenue, Suite 100, Anchorage, Alaska. n Chairman cc: AOGCC Commissioners Dave Cole, Unocal #11 ,.",. r· ~ lA~ I. i ! ¡ FRANK H. MURKOWSKI, GOVERNOR i f ~liA~1iA OIL AND GAS CONSERVATION COMMISSION ./ } 1 ! / , 333 W. 7'" AVENUE. SUITE 100 ANCHORAGE. ALASKA 99501-3539 PHONE (907) 279-1433 FAX (907) 276-7542 December 22, 2005 Dale Haines Oil and Gas Operations Manager U nocal PO Box 196247 Anchorage, AK 99519 Re: TBU Steelhead Platform Automatic Shut-in Equipment Enforcement Action Dear Mr. Haines: The Alaska Oil and Gas Conservation Commission ("Commission") acknowledges receipt of your request for Informal Review of the Commission's proposed enforcement action regarding the TBU Steelhead Platform Automatic Shut-in Equipment Enforcement Action. An Informal Review meeting has been scheduled for January 10, 2006 at 1 :30 pm at the Commission's Offices at 333 West 7th Avenue, Suite 100, Anchorage, Alaska. Should you have any additional documentary evidence you wish to provide to the Commission, please submit it at least one week prior to the informal review meeting. If you have any questions you may contact the Commission's Special Assistant Ms. Jody Colombie at 793-1221. cc: AOGCC Commissioners Dave Cole, Unocal #10 . . Chevron === Dale A. Haines Manager Oil & Gas Operations Union Oil Company of California P.O. Box 196247 Anchorage, AK 99519-6247 Tel 907 263 7951 Fax 907 263 7607 Mobile 907 227 0761 Email daleah@chevron.com VIA CERTIFIED MAIL #7005 039 0004 7283 3636 AND EMAIL PDF Email: john_norman@admin.state.ak.us dan_seamount@admin.state.ak.us cathy _foerster@admin.state.ak.us RECEIVED DEC 22 2005 Alaska Oil & Gas Cons. Commíssiorr Anchorage December 21,2005 John K. Norman, Chairman Dan Seamount, Commissioner Cathy Foerster, Commissioner Alaska Oil and Gas Conservation Commission 333 W. 7th Avenue, Suite 100 Anchorage, Alaska 99501-3539 Re: Notice of Proposed Enforcement Action dated December 12, 2005 TBU Steel head Platform Automatic Shut-in Equipment Union Oil Request for Informal Hearing Dear Chairman Norman and Commissioners Seamount and Foerster: We are in receipt of the Commission's Notice of Proposed Enforcement Action dated December 12, 2005, concerning the TBU Steelhead Platform automatic shut-in equipment. Pursuant to the Commission's Notice and 20 AAC 25. 535(c), Union Oil hereby requests an informal review of the matter. In order to accommodate the absence of several of our staff members during the Christmas holidays, we ask that the Commission work with us to schedule the informal review for mid- January. Union Oil will submit documentary material and make an oral presentation at the in- formal review. We look forward to meeting with the Commission. It is our sincere hope that we will be able to resolve this matter during the informal review. Be~~ ¡;; À/e-JJ./ÌuS If2fr Dale A. Haines cc: Jim Regg Uim_regg@admin.state.ak.us) John Zager Marc Bond Union Oil Company of California I A Chevron Company http://www.chevron.com #9 . . ~~1' f£'â" lIi} ,HU '" '" ,,',J " " ' ~\, it!! [! '~ ~ ¡ g' , "¡ ¡. 'Ù Uu-uU ~ rïì'~ !~ ;,',' j,' !, 'I" L :I' " J ¡ IU¡ ¡' \.::V ! J'ï.'I F"\ '~lfj,A, " .: i L '\ ," ¡ ! ,. . ;, nJ~ ,rñ'\ I~' , fR' , '1, lu! ~' \ . ,\, i' " , , \ " ' ' , j Qi; J \.l Ln.\ FRANK H. MURKOWSKI, GOVERNOR AI,ASIiA OIL AlQ) GAS CONSERVATION COMMISSION 333 W. 7fH AVENUE, SUITE 100 ANCHORAGE. ALASKA 99501-3539 PHONE (907) 279-1433 FAX (907) 276-7542 December 15, 2005 Mr. Dale Haines Operations Manager Unocal P.O. Box 196247 Anchorage, Alaska 99519-6247 Re: Notice of proposed Enforcement Action TBU Steelhead Platform Automatic Shut-in Equipment Dear Mr. Haines: This is in response to your inquiry concerning the proposed enforcement action in regard to TBU Steelhead Platform Automatic Shut-in Equipment. You raised the possibility of Unocal's performing one or more projects or initiatives in lieu of paying part or all of the proposed civil penalty. That would be an appropriate issue to raise at an informal review of the proposed enforcement action. In that event, please be prepared to address how such a substitution would be beneficial to the State of Alaska. If you are interested in pursuing this option, please schedule an informal review as outlined in the notice of proposed enforcement. Sincerely, c~~~ Commissioner #8 . . .~ Ii ¡,~ !1 ~ FRANK H. MURKOWSKI, GOVERNOR Al'fASKA OIL AND GAS CONSERVATION COMMISSION 333 W. 7'" AVENUE. SUITE 100 ANCHORAGE. ALASKA 99501-3539 PHONE (907) 279-1433 FAX (907) 276-7542 December 12, 2005 MAILED CERTIFIED MAIL 7005 1160 0001 5753 7161 Mr. Dale Haines Operations Manager Unocal P.O. Box 196247 Anchorage, Alaska 99519-6247 Re: Notice of proposed Enforcement Action TBU Steelhead Platform Automatic Shut-in Equipment Dear Mr. Haines: Pursuant to 20 AAC 25.535, the Alaska Oil and Gas Conservation Commission ("AOGCC" or "Commission") hereby notifies Union Oil Company of California ("Unocal") of a proposed enforcement action of several corrective actions and a $400,000 fine. Unocal was advised by letter dated August 25, 2005 that the Commission was investigating Trading Bay Unit (" TBU") Steelhead platform operations to determine if the installation, operation and testing of the automatic shut in equipment were in compliance with Commission requirements. Based on this investigation, the Commission considers that Unocal has violated provisions of 20 AAC 25.265 in connection with operating the wells on the Steelhead platform. Specifically, it appears that Unocal violated 20 AAC 25.265(d) by failing to test the safety valve systems ("SVS") for all Steelhead wells between December 17, 2003 and March 22, 2005, and after testing in March 2005, by continuing to operate Well M- 19RD1 with a failed subsurface safety valve ("SSSV") beyond the timeframe allowed by the Commission to make repairs. Under 20 AAC 25.265, a completed well with an offshore surface location and that is capable of unassisted flow of hydrocarbons to the surface must be equipped with a commission-approved fail-safe automatic SSV and fail-safe automatic surface-controlled SSSV (unless another type of SSSV is approved by the Commission). Performance I TBU M-19RD: PTD 1931170; API # 50-733-20421-01 . . Mr. Dale Haines December 12,2005 Page 2 of5 testing of safety valve systems witnessed by a Commission representative must be carried out "at intervals and times as prescribed by the Commission." The Commission has prescribed the following requirements addressing test interval and response to test failures in the document "AOGCC Policy - SVS Failures" dated March 30, 1994 (only relevant paragraphs are referenced here): 1. Wells must be tested by platform, pad or drill site every 6 months unless a shorter period is designated by the Commission. 2. If a SSVor a SSSV fails, production/injection may continue, but (he valve must be repaired and ready for a witnessed re-test within 2 weeks. If the valve fails the re-test, the well must be shut in until the valve has been repaired or replaced and passes a test. 3. If both the SSVand the SSSVfail, the well must be shut in until at least one of the valves is repaired or replaced and passes a test. The other valve must be repaired and ready for re-test within two weeks as in #3 above. These specific requirements were addressed during a 2002-03 joint industry work group chaired by the Commission and the Alaska Oil and Gas Association, and reaffirmed as industry-recognized practice in Alaska by workgroup consensus. Unocal was represented on the work group and copied with its findings.2 Background A review of the Commission's SVS test records for Steelhead in March 2005 indicated no test results had been filed with the Commission during the past year. With further investigation, it appeared thåt none of the well SVS' s on the Steelhead platform had been tested since December 17, 2003. A Commission inspector traveled to the Steelhead platform on March 22, 2005 to witness SVS tests, identifying a total of four failures on four separate wells. In conjunction with the inspection, Unocal platform personnel were reminded of record keeping obligations, testing responsibilities (test intervals not to exceed 6 months), and that the failed SVS components must be repaired or replaced and available for retest within 14 days. . As part of its investigation the Commission contacted Unocal personnel on April 27, 2005 to determine the availability of test records. Unocal was unable to produce any well SVS test records for the Steelhead platform between the dates mentioned above. Steelhead Platform persoruiel contacted the Commission on August 9, 2005 to advise that TBU M-05 and TBU M-l~RD were ready for retests of the failed SSSV's. Unocal previously advised the Commission on May 17, 2005 of repairs to TBU M-05 (installation of new SSSV) and its availability for a test. The Commission waived witness of the TBU M-05 test at that time. Repairs on TBU M-19RD had recently been completed enabling the SSSV to be retested. According to monthly production reports filed by Unocal, both wells have remained in continuous gas production since the failures occurred on March 22, 2005 during a Commission-witnessed inspection. There is no 2 A final report for the "Safety Valve System Taskforce" was issued June 13,2003; Appendix 5.4 includes the Commission's SVS Failure Policy. Mr. Dale Haines December 12, 2005 Page30f5 documentation that Unocal obtained Commission approval to continue operating Well M- 19RD with a failed SSSV beyond the 14-day time frame provided for repair or replacement and re-test. Responding to the Commission's August 25, 2005 letter, Unocal provided all requested infonnation and initiated an internal investigation using a root cause analysis approach to determine the status of compliance with Commission SVS requirements, including the extent, severity and root causes of noncompliance. Unocal also investigated how to prevent recurrence of any noncompliance identified. Unocal's internal compliance investigation extended beyond the Steelhead platform to all Unocal-operated Cook Inlet facilities. Unocal presented to the Commission on December 1, 2005 the findings, root causes, and proposed corrective actions (with target completion dates) resulting from its internal investigation. Proposed Enforcement The Commission proposes to order Unocal to correct deficiencies 10 its SVS testing procedures and record keeping practices as follows: I. The testing frequency of SVS's on the Steelhead platfonn shall remam every 6 months; 2. SVS test results, regardless of Commission witness, shall be required to be submitted to the Commission within 1 week of completion; 3. Within 30 days after the effective date of the enforcement order, Unocal shall be required to provide the Commission with documentation of the company's SVS failure response procedures that are consistent with Commission requirements; 4. Unocal shall adopt the corrective actions identified by its root cause analysis investigation, which are consistent with Commission expectations for compliance with SVS requirements3; 5. Written progress reviews shall be required detailing corrective actions completed, and updating the status and timing for the completion of unfinished corrective actions. The report would be due on or before the 15th of each month following the effective date of the enforcement order, and until all corrective actions have been completed. In addition, the Commission proposes to impose civil penalties on Unocal under AS 31.05.150(a). In determining the amount of a civil penalty, the Commission has generally considered: (I) the good or bad faith of an operator in violating the law; (2) injury to the public resulting from the violation; (3) the benefits derived by the operator from its violation; (4) the operator's ability to pay a penalty; (5) the need to deter similar ~___ ,) ~'¡J() ~~ ~1!:f &~~. J From Unocal's presentation of root cause analysis results to the Commission on December 1,2005 corrective actions addressing the following areas would be completed by Unocal: 1) Training; 2) Single Point of Contact; 3) DataStream Assessment; 4) Management Discussion; 5) Orientation; 6) Reassessment of No Flow Wells; 7) SVS Status Displays; 8) Policies and Procedures; 9) Steelhead Survey; 10) Alternative System; and 11) Compliance Survey. . . Mr. Dale Haines December 12,2005 Page4of5 A mitigating factor regarding the civil penalty amount proposed in this case is Unocal's good faith effort to determine the root cause for Steelhead platform's lack of SVS testing during 2004, and Unocal's voluntary extension of its comprehensive internal compliance review to include all Unocal-operated facilities in Cook Inlet in response to presumed SVS violations found by the Commission. Additional mitigating factors are the lack of injury to the public as demonstrated by past Steelhead SVS performance (infrequent failures), the robust SVS design (including multiple levels of automatic shut in on each well), and demonstrated functionality of the SVS's during multiple platform shut-in events during 2004. However, other factors argue for a significant civil penalty amount including benefits derived by the operator (continued production of gas) and the need to deter similar behavior and protect regulatory integrity. In particular, regarding the need to deter, failure to comply with SVS regulatory requirements is a serious category of violation that has the potential to result in significant public harm. A well-control incident in the Cook Inlet could result in destruction of property, environmental damage, physical waste of valuable hydrocarbon resources, and human injury or death. Therefore, the Commission proposes the following civil penalties: 1) $123,000 for violating 20 AAC 25.265 by continuing to produce TBU M-19RD following the identified failure of the SSSV ($1,000 per day for 123 days4); 2) $277,000 for violating 20 AAC 25.265 by failing to test automatic shut-in equipment on the 17 Steelhead platform wells during 2004 ($1,000 per day for 277 days5) In calculating these civil penalties, the Commission has chosen not to propose amounts based on each possible violation (e.g., the 17 wells on the Steelhead platform that were not tested during the timeframe December 17, 2003 to March 22, 2005 account for 47 separate components - 47 possible violations). As provided by 20 AAC 25.535 (c), within 15 days after receipt of this notification Unocal may file with the Commission a written response that concurs in whole or in part with the proposed action described here, requests informal review, or requests a hearing · 123 days rrom April 6, 2005 through August 9, 2005; April 6 is the 15th day following the SSSV failure witnessed by a Commission inspector - there were no subsequent tests; August 9 represents the date the Commission was requested to witness are-test of the failed SSSV in TBU M-19RD. 5 277 days rrom June 18, 2004 through March 21, 2004; June 18 is the day following the 6-month anniversary ofSVS testing completed December 17,2003; March 21 is the day prior to first SVS testing on Steelhead platform following the December 17,2003 test. Mr. Dale Haines December 12, 2005 Page 5 of 5 . . under 20 AAC 25.540. If informal review is requested and Unocal disagrees with the Commission's proposed decision or order after that review, Unocal may then request a hearing within 10 days after the proposed decision or order is issued. If Unocal does not file a timely written response to this notification, the Commission will consider Unocal to have accepted by default the proposed action described above. If Unocal requires more than 15 days to respond, you may for good cause shown request an extension of the ~- -day response period. _', Si,nc~,:~,~, , 0\ //í/./ r 'ß;~fF l' ./ h i,I' ,./ v . " Daniel T. Seamount Commissioner ~.~~ Commissioner UNITED STATES POSTAL SERVICE First-Class Mail Postage & Fees Paid USPS Permil No. G-10 co: a , ¡~ <'I ·L.)Jsender;~lease print your name, address, and ZIP+4 in this box · U. C) c.J ~ (·~1 . fl.' .,.",.. ¿::~I ~ o:;...~ "'J~ 8 j ,..') 0 Cc C--- ~ ~.~ ~ g /-'v ï #/¿J ¿J III ~ ~ß3 ¡J.l?-;JyC- / (( f/l/)c¿ //1 CJ9¿tJ/ / . III /- 7l}t¿ ji;~/Y7.Jc/.///) /h~r /fT-- rl JI rl....... ; ~ " I~; 1"';1' _ ; rf";HlImlb'm¡¡;r~Iò1IF.f'''''l'-El I'- U1 Postage $ rl o o Return Receipt Fee o (Endorsement Required) Certified Fee i, r Poslmetk Here o Restricted Delivery Fee JI (Endorsement Required) rl rl Total Postage & Fees $ ~ .~~:_~~._~{)L___j]r)1¿m_ilClL¿.2(!2__, }!:~~~€f:~~~~~_.m_l7L?c.~CqLm__________u__m____u_____ City, State, ZIP+4 t1ìii1..JIIIII-,ml!1 :.:t'..:J...1:=--hl.flJ....Uq¡;'I.]IJ.: SENDER: COMPLETE THIS SECtION · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Pr~nt your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: /?7r J)a/¿ I/ainé'~ ¿/í?a~o/ //Ôð /9~atJ7 /)/v¿ /JZ \ìéJ'j/9 2. Article Number (Transfer from service lab! A. Signat. ure AJr.!.. / A , 11' _ _ ('\ '- ,)''!.£L{gent XL{)¡1~)À> (_7'-tUJfX') 0 Addressee ~. Re~,eived ~y (Ä1nted,~,me)~ I C\ ~t:l0!.?~i~e~~ An,14ncJI'\\.J C¡((Â! (': rl. .:;-- . , J D. Is delivery addre~s different from item 1? 0 Yes If YES, enter delivery address below: 0 No 3. ,~ice Type pCertified Mail o Registered o Insured Mail o Express Mail :;-&kfreturn Receipt for Merchandise o C.O.D. 4. Restricted Delivery? (Extra Fee) DYes 7005 1160 0001 5753 7161 102595-02-M-0835 PS Form 3811, August 2001 Domestic Return Receipt #7 . . ALASKA OIL AND GAS CONSERVATION COMMISSION """ Date: 12-1-0"",, Time ~;vOf,i/\. MEETING - Subject <8 ~Ih~~ ÇV s NAME - AFFILIATION TELEPHONE (pLEASE PRINT) --JiM. K<if'1 - MGcc.. 114. r (/ ~ "" ~ - eh()4" r'fJ lit .....-:;-" -:2.. ,Z4A '"~~~~:'\Í~<.:...r- c..fh~Vn:(.) ¡..J o e¡ \ t.... ..£ ~ \)....:d 13/.... I? (Z. , 'Ifr L'tt'fttl/{ fÐe~h- é h..~vv,,\... CJ,J&vJ~A1 ;kx"~.. KA.. bQ ~ IJ (iJ¡ c,L., e..,./ro (\ . c::.o I(... , , . ~1...J t>f\:tllct<:'JI'!t-,¡..U":)t. '::vr.t11f'¡}I'V;.JT\ c....:.M ~ It!.l!tl.D (' l....~vv£¿.... . C" ",-- b1f(,7Th C!!. t"'-Nêw~ø.]. c.c", C¡ 07 - 713-1 Z3¿, GtQ-¡. ~:J. 7~f.3. 40 1- -z'-.>-fG.s-::;- reo 1- - ~ -=i-"<i7J~{ 907'-¿~$-78~o q¡;7-7<13-, lrZf3 The Investigation Team Chevron === William G. Britt, Jr. Tim Brandenburg J.C. Waski HES Manager Drilling Manager Foreman © Chevron 200S DOC ID 2 CHRONOLOGY Chevron III August 25 '. . v-é".> \'ti¡Ock-c.¡ . /'c'C II\. -~ ~l:>l ..:7' John Norman letter to Dale Haines September 7 Investigation team formed September 16 Dale Haines response to John Norman November 30 Investigation Report finalized December 1 Investigation results presented to AOGCC v © Chevron 2005 DOC 10 3 Investigation Goals Chevron === Determine the status of compliance with AOGCC requirements and policies associated with installation, operation, and testing of the SVSs on the Steel head. If instances of noncompliance are found: · determine the exJent of noncompliance; · determine the sever!ty of the noncompliance; · determine the roo! Cª_~~lS.§S of the noncompliance; and · make recommendations to prevent recurrence of the .,..~-'-_.._~-_._--.- noncompliance. © Chevron 2005 DOC ID 5 fK9(I, © Chevron 2005 DOC 10 - cuJ\v\j-øL Findings Chevron - Issue 1 - Frequency of SVS Testing Steelhead Compliance v. The Steel head was not in compliance with 20 AAC 25.265 and AOGCC policy from March 2004 to March 2005. ,/. Other Union Oil facilities were in compliance with the regulations and policies during this time. /. Union Oil is currently in compliance with sVs testing regulations and policies. Procedures J. Union Oil procedures to address internal and external testing frequency requirements were inadequate. ~t' D~ «5/; I µ" ,ç o1t1.n- loss (), i _ . hh>CJ 5tKfe,. '-(.~~ /U ( ;/4ud vJl cí,,¡)d;1. ,) Other issues ¡/. steelhead operators were concerned that testing could lead to platform J shutdown. -? ~I1/'1& c~~ 1/.;V\il~~r¡¿'.W{í ~itei . steelhead operators were focused on maintaining gas production. Safety {{ClS -'? 51f4~ c'l/ls:k~ > ¿ s~ rkSlrtjl'(3:?J ..k, ,j J-¿ /. ¡¡e,... .(;.> r ~.).Jl,d >, 'ð,'I-/ plt4f ~k~ . Multiple shut-in events occurred during the period of noncompliance, demonstratlngJbe functionality of the associated safety valves ,__ _______.~e_.~....._~·__,,·_···~·_·_____m__..._¥_'""___. ~~.._..__...____,_~_,,___,_.____._..._~,.,_.-~'~_. .- ED-~s~ ~~;. Çï'S.~' <AlGI t:~ ~ oIléJ 1..( S-k() ðJ r æ 6/~,s 6 Findings Chevron === Issue 2 - Timeliness of SVS Repairs · Two SSSVs needed repairs after AOGCC witnessed testing on March 23, 2005. · Replacement of one valve was completed on May 15, 2005. A successful retest of that valve was witnessed by AOGCC on June 21. · Repairs were completed on the second valve on July 30, 2005. A successful retest of that valve was witnessed by AOGCC on August 26. ./ . Neither the repairs nor the retesting were within AOGCC mandated timeframes. e- 1\0 vtÁ/ìC'-1.(è ~ AðG(CC © Chevron 2005 DOC ID 7 Findings Chevron III Issue 3 - Communications with AOGCC ,/. No Union Oil p~~_~~cols existed for communications ðose cèð'l between Union Oil and AOGCC. Communications r:JJ~~h'r>? occurred at all levels and were generally informal. cçt.~ : Communications were not well documented. -;> ~5{(lC~'-5 fX¿s!- pCGnDiv"L <e.~e / ~~~~ 0/. AOGCC inspectors noted that scheduling a witnessed Cc-<pI(t~(?) SVS inspection was more difficult at the Steelhead than at other Union Oil facilities. r lévje(~ ,I r: ~ Ò( 1ft£s ~ ... , .... ÍÞ L/~/·· p/./t ur c I¡" .- CO¡J r¿y.-rr~· J 'J _ t>x òF- SiD pl"'JÇ~ -:') ¡\II) ,{. O~ cyooÔ ~'C~-Þ~ 1}S- vJ~ ~~ SVS:~. +,'Q}) (eA..'f:( _.:~ I¿'[clc cJt- ffttfoco/ s ~r ~C~. © Chevron 2005 DOC ID 8 © Chevron 2005 Root Cause Analysis: Immediate Causes Chevron === ,M~¡o9~f t ((Got- C~ Ä.4¡5J'S / S2:S'~1 , [2 '¿ll/Jr., 1G: I V¡OkJit ~S~ Vi()~t/" V~ )u,u...,-f1 v'o ;&(c) 1-2 1-3 3-1 4-1 Violation by group Violation by supervisor Lack of knowledge of hazar.ds present - k:JtL ~(.& ~~ f le9Gcc ~~. i-<t~t"-'d Improper decision making or lack of judgment 4-2 Distracted by other concerns 4-6 Failure to warn 5-6 Defective warning systems __ ~tvtw"ð -lv -k~~s.VS: J0i ¡w-i.)J-(}vf ~ ~t~ C¡S C-éhtC~)Y<. I'~ .-4: l.q? ~(q ~ [>,j N!f... ~~~. ¿-~1~1~0-P -Iv I~~ÁQ ¥tK<t I Qt",J- f\-{) --ks~ c~e.- .--" cC3' (ee, (~.Y-,) DOC ID k~ ,-+~~ b~ V\Jf ~)~ 9 - ~cft- 6f-C{PPJLClC~ .J- e;-3t- Root Cause Analysis: System Causes ~~ 3-1 Poor judgment 1 Preoccupation with .- problems- p-t'Sdn':eJ l·ss~t; ~,) .. A~~ Ittw sz.-J- ( 4-4 Conflicting direction and . demands 4-7 Extreme judgment! decision demands 5-2 Improper supervisory example 5-4 Inadequate reinforcement of critical behaviors 7-4 No training provided 8-3 Inadequate correction of worksite hazard 8-4 Inadequate identification of worksite haza rd Inadequate management of change system © Chevron 2005 DOC ID ^ ~ kt~ 'll~~/ V\,êøF \Þ~ '~~(0~~1 ./ . ..;51 , . .... .. "1 / 8-9// Other, management! -~/ supervision! employee leadership 11-6 Inadequate audit!inspection! monitoring 13-5 Inadequate adjustment or repairs! maintena nce 13-8 No equipment record history 14-2 Inadequate work rules! policies! standards! procedures (PSP) 14-4 Inadequate enforcement of PSP Chevron III 15-2 Inadequate vertical communication 15-3 Inadequate communication between different organizations 15-10 Inadequate communication of regulations or guidelines 10 ,~'c;~ cS,gC" yJ-V \ ~~^ \w 10~"'YÝ';'Proposed Corrective Actions Chevron - (J¿x ( ô wt ...M Je~iJvve ~'-£t"p . ~ :þ{~.~ Training December 8 - December 23, 2005~ Single Point of Contact December 9, 2005 ~> CJv;s v~¥e» Datastream Assessment~ December 23, 2005 --!;Ji;~_9l+,"'-HO Management Discussion December 30, 2005 Orientation December 30, 2005 --'> þOÇ,CC¡U,"<JL"ck rel/lj'refv4~tJ Reassess No Flow Wells Status Displays Policies and Procedures Steelhead Survey Discipline Alternative System Compliance Survey December 30, 2005 - June 30, 2Q06. -~ Qhr~ ¡A1<{vs w,t( cf.¿v'iLr) t pltk December 30, 2005_,> ~?/-ee(he<zi cl(l,vJI ~ S J s. & k:Jl-<J>. January 13 - March 10, 2006 t5D:'<>cf January 30, 2006 ,-> -4+~~;: ~ ~1&*':Y January 30, 2006 -> February 17, 2006 -'~N(A >I~ ixttt~ ~~,ve-,j ~~ c\hb .+V March 31, 200 6 cu~~"" c&Q cü.rds- C~û'vl/(~~~ cT © Chevron 2005 DOC ID 11 © The Investigation Team Chevron III William G. Britt, Jr. Tim Brandenburg J.C. Waski HES Manager Drilling Manager Foreman © Chevron 2005 DOC ID 2 CHRONOLOGY Chevron === August 25 John Norman letter to Dale Haines September 7 Investigation team formed September 16 Dale Haines response to John Norman November 30 Investigation Report finalized December 1 Investigation results presented to AOGCC © Chevron 2005 DOC ID 3 Investigation Goals Chevron =- ~ Determine the status of compliance with AOGCC requirements and policies associated with installation, operation, and testing of the SVSs on the Steelhead. If instances of noncompliance are found: . determine the extent of noncompliance; II determine the severity of the noncompliance; II determine the root causes of the noncompliance; and . make recommendations to prevent recurrence of the noncompliance. '.~ © Chevron 2005 DOC 1D 5 Findings Issue 1 - Frequency of SVS Testing Chevron III -"- Steelhead Compliance · The Steelhead was not in compliance with 20 AAC 25.265 and AOGCC policy from March 2004 to March 2005. · Other Union Oil facilities were in compliance with the regulations and policies during this time. · Union Oil is currently in compliance with SVS testing regulations and policies. Procedures · Union Oil procedures to address internal and external testing frequency requirements were inadequate. Other issues · Steelhead operators were concerned that testing could lead to platform shutdown. · Steelhead operators were focused on maintaining gas production. Safety · Multiple shut-in events occurred during the period of noncompliance, demonstrating the functionality of the associated safety valves ---, © Chevron 2005 DOC 1D 6 Findings Chevron . ""- Issue 2 - Timeliness of SVS Repairs II Two SSSVs needed repairs after AOGCC witnessed testing on March 23, 2005. II Replacement of one valve was completed on May 15, 2005. A successful retest of that valve was witnessed by AOGCC on June 21. II Repairs were completed on the second valve on July 30, 2005. A successful retest of that valve was witnessed by AOGCC on August 26. II Neither the repairs nor the retesting were within AOGCC mandated timeframes. -,- © Chevron 2005 DOC ID 7 Findings Chevron . Issue 3 - Communications with AOGCC ~~--' II No Union Oil protocols existed for communications between Union Oil and AOGCC. Communications occurred at all levels and were generally informal. Communications were not well documented. II AOGCC inspectors noted that scheduling a witnessed sVs inspection was more difficult at the Steel head than at other Union Oil facilities. e_ © Chevron 2005 DOC ID 8 Root Cause Analysis: Immediate Causes Chevron . 1-2 Violation by group 1-3 Violation by supervisor -~ 3-1 Lack of knowledge of hazards present 4-1 Improper decision making or lack of judgment 4-2 Distracted by other concerns 4-6 Failure to warn c,__ 5-6 Defective warning systems © Chevron 2005 DOC ID 9 Root Cause Analysis: Chevron ., System Causes 3-1 Poor judgment 8-9 Other, management/ 4-1 Preoccupation with supervision/ employee leadership problems 11-6 Inadequate audit/inspection/ -c_ 4-4 Conflicting direction and monitoring demands 13-5 Inadequate adjustment or 4-7 Extreme judgment/ repairs/maintenance decision demands 13-8 No equipment record history 5-2 Improper supervisory 14-2 Inadequate work example rules/ policies/ standards/ 5-4 Inadequate reinforcement procedures (PSP) of critical behaviors 14-4 Inadequate enforcement of 7-4 No training provided PSP ~~/ 8-3 Inadequate correction of 15-2 Inadequate vertical worksite hazard communication 8-4 Inadequate identification 15-3 Inadequate communication of worksite hazard between different 8-5 Inadequate management organizations of change system 15-10 Inadequate communication of regulations or guidelines © Chevron 2005 DOC ID 10 Proposed Corrective Actions Chevron === .,-- Training Single Point of Contact Datastream Assessment Management Discussion Orientation Reassess No Flow Wells Status Displays Policies and Procedures Steelhead Survey Discipline Alternative System Compliance Survey December S - December 23, 2005 December 9, 2005 December 23, 2005 December 30, 2005 December 30, 2005 December 30, 2005 - June 30, 2006 December 30, 2005 January 13 - March 10, 2006 January 30, 2006 January 30, 2006 February 17, 2006 March 31, 2006 © Chevron 2005 DOCID 11 #6 Re: Inspector Work Schedules ) ) . ...... ",. . . ... ..,. .. . . .. .. . . .. .. S~~ject:~~:~speAtór'Y?r~Scheclules ."<" '.' ..... . ... . ;Ft~:II1;..·.J~mes:·~~~g·$,it11~_l~~g@(t<lrnill.stat.~;akÆS?' Dåjte:,:ru¢,..Ol.N,8~:~2.8~.,l.6:35,:3~ .;0900 m~i~"i;· ::.g~i:~~~:I~~~:àfî Responses attached. Jim Regg AOGCC Brandenburg, Tim C wrote: Jim, Sorry for not getting back to you sooner. In general, we would like to understand from the inpectors perspective how the process has worked at the Steelhead and at other Unocal facilities. Please see the list of questions below: How has the SVS Inspection process at Steelhead worked from your perspective? Do you have any insight into what happened at the Steelhead? How has the SVS Inspection process at other Unocal facilities worked from your perspective? Are other Unocal facilities late or incomplete with their SVS inspections? What would you consider optimal as far as implementation of the SVS Inspection process? How do you track compliance? Is there another operator that you would consider excellent in their implementation? Do you have any suggestions regarding actions that we can take to prevent recurrence? Are there other areas of our business that you have had similar problems or in which you have concern? If you have any questions, please do not hesitate to call me at 263-7657 or on my cell at 350-7920. Thank s , Tim -----Original Message----- From: J a me s Re gg [~f~~..~..~_t::_9.m:j_~.Er.:'_:r.:.~.gg,ç~.~.9.~~.~_~,:...?_~_0:,~.~._:,_9..~_.:,.~.~] Sent: Monday, October 24, 2005 2:47 PM To: Brandenburg, Tim C Subject: Re: Inspector Work Schedules When can I expect to see the questions you would like to ask the inspectors? 1 of3 11/1/2005 4:35 PM Re: Inspector Work Schedules ) Jim Regg AOGCC Brandenburg, Tim C wrote: Mr. Regg, We will send you a summary or list of questions prior to our meeting. As for timing we wanted to see if it would be possible for us to meet with Mr. Grimaldi the morning of Friday, October 28 at our EFDF facility in Nikiski and Mr. Crisp in the afternoon of the same day here at Unocal. Then if we could meet with Mr. Jeff Jones on Monday, November 7 at our EFDF facility in Nikiski. Thanks for your assistance with this matter. If you need to speak to me, please call me on my cell phone 350-7920. Thank s , Tim -----Original Message----- From: J ame s Re gg [~~.?:.~..L~:..S~...:j...~.~_~~.~.99.~~~.9.:5~~~.~.!.!....:....~.~:.9.:.:~:'..~....:...?:}~...:...~~.ê.] Sent: Thursday, October 13, 2005 3:34 PM To :~~.~:.9.:T~~:~.~!.!..!?~~:~.F9.:~::.~~.~?):~.~:Y..E.~?T~..:..S..~~!~ ; Cat he r i ne P Foe r s t e r Subject: Inspector Work Schedules Per our discussion earlier today, Lou Grimaldi, Jeff Jones, and John Crisp would be the inspectors you should probably speak to about Steelhead. Their work schedules for next month are as follows: Lou Grimaldi (Nikiski) Jury Duty 10/12-14? North Slope 10/17-24; 11/7-14 Jeff Jones (Kenai) Out of State 10/15-22 North Slope 10/26-11/2; 11/16-23 John Crisp (Anchorage) North Slope 10/19-26; 11/9-16 Please let me know when you have decided on target dates so I can contact them. I'd also like to have either a summary or list of questions you would like to ask them. Thanks. Jim Regg AOGCC Inspection Supervisor 20f3 11/1/20054:35 PM Re: Inspector Work Schedules ) ) Steelhead Q&A 10-31-05 .doc Content-Type: application/msword Content-Encoding: base64 30f3 11/1/2005 4:35 PM ) Steelhead Inspection Experience Responses from AOGCC (11/1/2005) Q: How has the SVS Inspection process at Steelhead worked from your perspective? A: Scheduling a witnessed SVS is more difficult on the Steelhead platform than other platforms. Steelhead operations personnel have expressed anxiety over testing in the past, tests have been postponed at the last minute or interrupted midstream, and inspectors have been left hanging (sometimes after arriving at the heliport for transport to the platform). Part of this may be motivated by concerns about potential compressor shutdowns (that could occur as a result of testing) and how such affects the customer (Agrium). Q: Do you have any insight into what happened at the Steelhead? A: No. Q: How has the SVS Inspection process at other Unocal facilities worked from your perspective? A: Some platforms are better than others at scheduling and testing. In general, the Commission has not experienced the same types of problems on other platforms. Personnel changes in the last couple of years seem to have negatively impacted the testing. There have been a few occasions on the other platforms when SVS tests have been rescheduled to accommodate either the Commission or platform schedules after coordinating with the Commission. Q: Are other Unocal facilities late or incomplete with their SVS inspections? A: We have not found any thus far. Q: What would you consider optimal as far as implementation of the SVS Inspection process? A: Follow state regulation; work with the inspectors on scheduling witnessed tests. Accomplish SVS tests every 6 months with <1 0% fa ilure rate &file documentation with the AOGCC. Q: How do you track compliance? A: Commission has an inspection database. Compliance with testing intervals will show up when Commission office staff audit the data. Inspectors are responsible for witnessing the field tests, documenting and providing the results to Commission staff. Q: Is there another operator that you would consider excellent in their implementation? A: No response. Q: Do you have any suggestions regarding actions that we can take to prevent recurrence? A: No. Q: Are there other areas of our business that you have had similar problems or in which you have concern? A: No. [Fwd: RE: Inspector Work Schedules] ) ) Subje~t:.[1?wd;.RE:. InsBFctor·.\Vork Sche~ules] Frqm: . James Regg<Çj im£regg@adrhin.state.ak.us> Da~e:.Fri,210ct 2Q0509:31:52 ~0800 IJ~ ¡:W~~· it.r~~li~~c As part of Chevron's internal investigation of SVS testing at Steelhead, their investigators would like to interview each of you about your experiences on the platform with testing. I narrowed the list of interviews to you based on recent inspection history. Chevron's proposed interview dates and locations are listed below. As noted, we will get to see the questions before the interviews. Chevron initiated this after we told them AOGCC is investigating; their prelim findings from internal investigation found that Steelhead did no SVS tests during 2004 (not even their own required tests). Commissioner Foerster is aware of Chevron's request to interview each of you and supports your participation. Please advise if you have any particular concerns. Please also coordinate arrangements through me. Jim -------- Original Message -------- Subject:RE: Inspector Work Schedules Date:Thu, 20 Oct 2005 15:58:28 -0800 From:Brandenburg, Tim C <brandenburgt(?i}unocal.com> To:James Regg <jim regg(ã}adnlin.state.äk.us> Mr. Regg, We will send you a summary or list of questions prior to our meeting. As for timing we wanted to see if it would be possible for us to meet with Mr. Grimaldi the morning of Friday, October 28 at our EFDF facility in Nikiski and Mr. Crisp in the afternoon of the same day here at Unocal. Then if we could meet with Mr. Jeff Jones on Monday, November 7 at our EFDF facility in Nikiski. Thanks for your assistance with this matter. If you need to speak to me, please call me on my cell phone 350-7920. Thanks, Tim -----Original Message----- From: James Regg [rnai 1 to: 1~t!1-2~~9.9:~;i)admin. st at~=-~~~_01S] Sent: Thursday, October 13, 2005 3:34 PM To: brandenburgt@chevron.com; Catherine P Foerster Sub j ë-ct-;-Ins-pec tor Wor k----S-ëhe d u 1 e s Per our discussion earlier today, Lou Grimaldi, Jeff Jones, and John Crisp would be the inspectors you should probably speak to about Steelhead. Their work schedules for next month are as follows: Lou Grimaldi (Nikiski) Jury Duty 10/12-14? North Slope 10/17-24; 11/7-14 lof2 10/21/2005 9:32 AM [Fwd: RE: Inspector Work Schedules] ) J ) Jeff Jones (Kenai) Out of State 10/15-22 North Slope 10/26-11/2; 11/16-23 John Crisp (Anchorage) North Slope 10/19-26; 11/9-16 Please let me know when you have decided on target dates so I can contact them. lid also like to have either a summary or list of questions you would like to ask them. Thanks. Jim Regg AOGCC Inspection Supervisor 20f2 10/21/20059:32 AM #5 10/1 3/2005 3 :33 PM 1 of 1 (f~<0(C¡ It IZ'~05 ~C(~~ fWk --I-v Fv¡k LJ r-)+~ (ê~OVl£e- ,-+0 CtIlOC~LQ.. ìS 6W2~~~ ~~ ~~ ~'-~ £-1/\ ~Ie<;;¡ fù ce~Ç. ~e Gt:JkLC~-e~. ~ìte. I .--_' Jim Regg AOGCC Inspection Supervisor Please let me know when you have decided on target dates so I can contact them. I'd also like to have either a summary or list of questions you would like to ask them. Thanks. John Crisp (Anchorage) North Slope 10/19-26; 11/9-16 Jeff Jones (Kenai) Out of State 10/15-22 North Slope 10/26-11/2; 11/16-23 Lou Grimaldi (Nikiski) Jury Duty 10/12-14? North Slope 10/17-24; 11/7-14 Per our discussion earlier today, Lou Grimaldi, Jeff Jones, and John Crisp would be the inspectors you should probably speak to about Steelhead. Their work schedules for next month are as follows: ) ) ~·~.þj.~,~~:.···ItlspeQto]··.YM·~tk·...S~~$~~l.~~............... ~~~~1~...·.·Æ.~~~s····~~.~~..~.~~?!y9~.~~~i~..·.~~gt~..ª~~.~S~,.. n.ate:IT'hu ..1300t 2005.15:,3.3:42~0800<. .... ". '" ...... ...... ...... .-,'.,. . ... ....... . . . .... ....... ....... ....... '. ... .... -' ..... ........... ..... ..: .... ". ...:...,.....,.;/.,,~ ·,·.·.::·>:,,'..::c:;;'·,·,·:(j)·)·.:···;· .... ·;...:....:;,:.;.:;:..'i'·. ..... .,....,.......... \.",....'\. ..'.',....,....,. """'. ".:..",.:;.' ":~tii~i Inspector Work Schedules j ) ) Steelhead Inspection Experience Responses from AOGCC (11/1/2005) Q: How has the SVS Inspection process at Steelhead worked from your perspective? A: Scheduling a witnessed SVS is more difficult on the Steelhead platform than other platforms. Steelhead operations personnel have expressed anxiety over testing in the past, tests have been postponed at the last minute or interrupted midstream, and inspectors have been left hanging (sometimes after arriving at the heliport for transport to the platform). Part of this may be motivated by concerns about potential compressor shutdowns (that could occur as a result of testing) and how such affects the customer (Agrium). Q: Do you have any insight into what happened at the Steelhead? A: No. Q: How has the SVS Inspection process at other Unocal facilities worked from your perspecti ve? A: Some platforms are better than others at scheduling and testing. In general, the Commission has not experienced the same types of problems on other platforms. Personnel changes in the last couple of years seem to have negatively impacted the testing. There have been a few occasions on the other platforms when SVS tests have been rescheduled to accommodate either the Commission or platform schedules after coordinating with the Commission. Q: Are other Unocal facilities late or incomplete with their SVS inspections? A: We have not found any thus far. Q: What would you consider optimal as far as implementation of the SVS Inspection process? A: Follow state regulation; work with the inspectors on scheduling witnessed tests. Accomplish SVS tests every 6 months with <10%failure rate &file documentation with the AOGCC. Q: How do you track compliance? A: Commission has an inspection database. Compliance with testing intervals will show up when Commission office staff audit the data. Inspectors are responsible for witnessing the field tests, documenting and providing the results to Commission staff. Q: Is there another operator that you would consider excellent in their implementation? A: No response. Q: Do you have any suggestions regarding actions that we can take to prevent recurrence? A: No. Q: Are there other areas of our business that you have had similar problems or in which you have concern? A: No. #4 ) ) Chevron III September 16, 2005 Dale A. Haines Operation Manager Tel 907.263.7951 Fax 907.263.7607 Cell 907.227-0761 e-mail daleah@chevron.com Union Oil Company of California A wholly owned subsidiary of Chevron Corporation Mr. John K. Norman Chairman Alaska Oil and Gas Conservation Commission 333 W. ih Avenue, Suite 100 Anchorage, Alaska 99501-3539 Re: Response to request for Steel head Platform information. Dear Mr. Chairman: I am writing in response to your letter dated August 25, 2005. You indicated in your letter that the Alaska Oil and Gas Conservation Commission (AOGCC) is seeking to determine whether the installation, operation, and testing of the safety valve system (SVS) on the Steelhead Platform are in accordance with the requirements of 20 AAC 25.265. We were asked to provide the following information: 1. Copies of all SVS test reports documenting the results of tests performed on Steel head Platform wells beginning December 2003; including 6-month SVS tests, miscellaneous tests, and retest after failures. After reviewing the data we have gathered so far, it appears that we failed to comply with SVS testing requirements between May 2004 and March 2005. The requirements for the testing stipulate a frequency of testing on a semi-annual basis. Tests in accordance to the regulation were conducted in late 2003 but the mid year testing requirement does not appear to have occurred. In addition to the requirements of 20AAC 25.265 we have a practice of testing the equipment on a quarterly basis. In both instances we appear to have failed to conduct both our internal tests and the required test required under 20AAC 25.265. At this time I have confirmed that all flowing Trading Bay Unit (TBU) wells comply with 20 AAC 25.265 as the appropriate tests were conducted in March of this year and more recently in early August for the Steelhead flowing wells. In order to understand why we failed to meet our regulatory and internal testing obligations I have formed an investigation team. This team has been directed to determine the extent of the non-compliance event, determine what systems or processes failed to allow such an event to occur, and to make process and compliance recommendations to ensure that such an event does not occur in the future. Union Oil Company of California I Chevron 909 West 9th Avenue, Anchorage, Alaska 99501 http://www.chevron.com ) :) All wells requiring tests in accordance with 20AAC 25.265 are currently being entered into our preventative maintenance program which will generate a work order stating when the well must be tested and who needs to be notified of the impending test requirement. If the work is not completed by a target date a reminder will be sent on a reoccurring basis until such time as the work is completed. This process will ensure that the appropriate Operators and Supervisors are informed of the upcoming test requirements and that the appropriate managers are informed if the tests are not conducted in a timely manner. 2. Documents confirming the completion of repairs to SVS components that failed a test; This should include a description of the failure, repair(s) and the date completed. We have attached documentation of the repairs for the failed SVS components on two wells on the Steelhead Platform. It appears we failed to keep the AOGCC inspectors informed on the progress and status of the repairs subsequent to the initial testing. It is my current understanding that our platform operators failed to return phone calls from the inspectors in a timely manner while work was in progress to repair the SVS components. We will rectify this situation to ensure that AOGCC inspectors' phone calls are returned promptly and that our operators and supervisors adhere to the appropriate communications process as directed by the regulations. 3. Chevron's policies and procedures regarding installation and removal of safety devices, 10ck-ouUtag-out provisions, maintenance practices and schedules, testing, and response to failures. Chevron's Safe Practice Standards are collected in our Safety Procedures and Practices Manual. Many of these procedures and practices apply to work on SVS components. Chevron has a certified Valve Technician on staff that repairs our Surface Safety Valves. We have a portable valve repair shop. I have attached examples of worksheets presently used on our facilities. We take instances of apparent noncompliance seriously and truly appreciate AOGCC informing us of the problem. Our investigation to date leads us to believe that this event is isolated to the Steel head facility at the times noted above, and that our other facilities are and continue to be in compliance. We are continuing our investigation with the goal of ensuring that an event of this type does not occur again in the future. If you would like to discuss the investigation, call Bill Britt, our HES Manager, at (907) 263-7830. If you have other questions or need more information regarding this matter please contact me. Best regards, Y)~ O)J ~ Dale Haines Operations Manager cc: Bill Britt Chris Myers Johnny Santiago ~ep ~b ~UU~ o:~~"n UnU~"L r:.rlJr ,¡JU I I lOOOO..;J I""-c;;. ¡ , ' . . .~.~.-:" . .·~···~·uLr-:\u~... .:1~~\;:, .:.. . ....,. .:." .' '. t... ..;" .'~¡{:~/'.' .', .:':\' 'WEL '.'::.~. -... - .'. :_J: ~ .__:...----:-A'~4 ..- .. .. . .;:~:~' . "...;/:.:, .:~ '.":' r ..:;~::!;..:~",:~.~~~ ....~.. - D~'t~'~~ ',' ~ ~ JI-~oi~~~~'::~..:.,. .. ....' :~/~<~..~.,O';':~~~: .~: Well NU~b. er P1 J4f .. . - . Work .being døn.:~"L+'''' rd'/': -~\".';~ .' Locatlçm:· Ú-..~~k~~':~'>"~::;7':, . . ~.up.r'iaor: .(+~~' " ."'1P",.v,· . . .AFE# J Chárge, C~de~ . . . ',' '.' -' ., Wlfelln~ Unit Nunb.r: .(-+~I ~tf /.l,,:+ Polla~d Wlr.nne..C~.~: µ~II/<~I.:~A:I H~J '.' .:,' .~ Tre9 Valve C.ondltion t:~^J . Total Wlrellne MUe.; , ,.,.. ~., . ':'.' .' .,.-.... ~ '" '. ,"" . Fluid Levtl1f I~ertlfl.d r, /'J/,4- Max Oipth (1<8): ". 4S-7? ,','" .'.,'" . . , . " . . . . 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I~/r ", ~ (l'H. . u/ ~. 7S- h;AiA..iJ I.;"-~ ("LI'A+4~,. i-ð ~ v~A+i~' !$SV" PA^'1' ~~ fJrD.J.~r+;o~ . .. ~ ~ø"" aJ", '..- ~ L, S.t!' .: I.<J~., ,.. .~ P J H'· .u J 'i'~~:" .,' Js;.....+ h.Awe" ,t"~JCot d ~"-. j)M~- hyJ'r4ltklc< ." ~'~" 4r7'-k.()¡ ~",-*,+c.~, S"r~,v,:..c.+;JI.µOl1\'J"'-:J. ,<'ø~e ,.... -- '~" '\ ~. f"b ~. . Y~ ': '.- ~ < . ; I " ~~_:,.._' :. <r1. ....J'C(A , r . (.; __ ~o ~e¡""'. ....... .( ~ r . ,.:.. I,' Q'.' ~.':.9 ,.~. J1Do. ._ f.l-rJ~.· ~a/-' .~~API'-P' " . J r.(J~ ... ,- ." ·t:-r ,- ~-^~--.;Þ' -'-:--:-. ". : , I i , i I . ¡ ; ! J ·i I .I : ! , . .~ .. ..: ':,"!' . i ,,~, . ~ . 1 : ! ~ . , , . ."'.' ;~- -·';""4 .~ ..~ .'-1$7. ~1i " ,.f!!$l- f5~.JJ' . . ~ ~ "- .....------. . , ". .... . \' 'I.. 7.r-."" ð~~J.~J.. I ;,.,p Sc.rA~,d",,,~ _ _', S'~~. . ,'" u.. . .,' :. . I . I .." .. ' ... ~I , . ,. . ¿ . - -- .. . - .. -.. ·wOrkSt'¡ng·6·¡tifl~¿tf ~ *~,..~4-~~ $;'- , .' .' .'"'' ... ;¿¡ ~(. '. .:.r .... . '~.,I. ,~ r,~' .. _. ,. _.__ J. _ ", Þ. r . ~ D..crtptlel'\ of any toor. 'or debt1' ¡tft . 10 ~~ ~b~~:.i I.... . '-' ~ .. erief.~m.ty Of' :. ..~:'" '~~.....c~ .. L·": :_(.'( (1.1, _ ,+.... 'I ·1-Þ.. ~ e i- " ":"+~ c..Jp~.' è·.· .' 'Total Work . . . .~º'-"øJ~ft(r' ~ - .. .... <_' r~~1 ~.ð~~~,~~~~ l:~"" ,. . ' T~i ToQl' ëøst . 55 ~ f '. . . ~ Ticket":.. ~;'. . '. . " r.· . 'Dåll~ Co.è~ ',.. ':'::' 2..:.tü·;'.. -..L - ... . . -- L ... . ..... \ - r, ..,.."" .-I~n Downtlmi. Hr.;. 8~~t In' ',"',_ ~~:i:: . <;~.",~~~'-;..- ':, H28 PPM d :'&.. . 4II:::t ~ ' ,.. ," . Approvè ,'~~::' .... ,~:>,:,.~_ _-",,:.. ,'.-~~~~~q:',<,. . . ~. "0 <I\, I : . . . . . :.~ ~7. '. *. ~"._~. ._.~_ .'~~'., ..,~: ..:', ·,::jX·,:·~ì_~~~~~~;·;.~:.:~:~/:~t~,;;:,.::~:·~' .-.......----- . .... - '. . Ii ' ; , .. , . . 4.. I' . ..... .,. .- ~Q.._ I..~·J;· .-. - , - . . I ~ . , , . '.0 . . .To~t.~~r~~1 ~,~...?-2 ~f-. ~ .. - . Day"':.' /". I '_ . __ Ç'-!".'~I~tlV..CO.t: . .;!~.:J~_~,e: .' ,,.1/.,4' '. '. WtreTest .?,. ", :.. ~' .: Code: ,. , ._'.. :},: . ~. .:'~. ~.~ -.' "': ~~~~':.: .- .,1 . .! ' 1 ,- -r..... ". .¡Ç . . --. . ". <:-~.:~1-:~:7{~:~~~~ L~~:' . .,,_.~.. ~.-'.: .' ':""~.:~::. .;~.~.~"!!"..,/~~., '.. ' .~-----: ~ep lÞ, CUU~ o¡~~nn --...., unUlIo.#nL. .::.rur ~ r' 4/1112005 Sales Rate Line Press Gas Well M . Olf WeN M - . ~2 : MMCF 1102; PSt ' 2 : 28; Todd stone out to do hfs chemical stuff. ....~.. .. ... ........,..,"'... UIIOCAL4I ..... Monday Pot Dri" Diesel DewPt (J810 Shipped fI6 011 pig, to ¡r -bay. <0.5 gal~s wax rcYd noon 1100 Pollard on board ~ sCratch M-19 SSSV. Added Boz. CRW - 0132 to we. Pumps cooUng h20 day tank. 1200 SID waterftood Fdr TOdd S. to check coupons 1300 waterflood back on Ii~e ¡' " . . ~ 811 M-19... pressure test lubr . I: . 1430 PWL RIH... s~~ on valve 1500 PWL bk in Lubr...' te$ted SSSV... no go 1530 Run beck In hoIe.l. . sb,atched with no pressure on SSSV... stin will not close . . 1600PWL bk In Lubr...; rig~ing down on M-19 1630 Opened M..19 to sales .- - - 80% 87% 40% -50 2315 M-28 intake _ to 8e6 - then she started coming back up 1280 @ midnight motor temp dropped 3 degrees , . flowline temp never~ropped neither did tubing pressure aI other pump readings same as 2300hrs ~ep l~ ~UU~ b:~~Mn ~OM : '-??llard Wi rel ine, [nc unu""nL c.rur "'"- .,¡;IV t t t QQUU.., J:: ~_~ FAX NO. : 907 283-7118 ~ Sep. 01 2005 03:03PM. P3 UNOCAL ALASKA RESOURCES WELL SERVICE REPORT 'Date: Work being ;done: Supet:visor: Wlrelin. Unit Nu.mber: Tree ValVe Condition Fluid Lftel if identified Zero Wireline at: Minimum Tubing ID: Start 1:bg. & C~II. PSI . Time .. Q7:0D 07:40 09:OQ 09:30 ,_ 10:00 10:30 10:45 12:15 1~OO 14:00 18:30 17:00 19:00 23:30 _~4:00 . 7/29t2D06 i Set IIIÇ' vatve Mí~e ~~ .Steslhead unn Good NJA I . Tubl.~ Hapger . . Well Number Location: AFE' I Charge Code: Pollard Wire line Crew:: Total Wirel,IM Mlles:~; Max Depth (KB): Well KB: M8x Tool OD: Ending Tbg & C-sI PSI , - . ~pèct Unit X 350 ODenltløn gmoa. . Atrive at shop - Get tools Mive at Heh~ - standby_ _ _ A~ve on ~tIcn - discuss job ~J foreman ~ety meetinQ Rjg up . P;T~ Lub. & BOP's· test good n. . ·R~H wI 6 1q Braided line bruah to ~7' KB ~ brush SSSV nIpple - POOH RJH wI 5 1f21' ~-line wi .~. ~e t9 467 KB. . set val"le - P()OH . ~~e prod~ to.teat valve - valVe pressu~ set wrona - ~ too ~rly Stend by for. pu1ling tool to be sent out I. . -.. ~H w/5112". GS to 46"r KB - pull "K" valve - POOH . ~ by for chopper fa '1<" _ valve In Sient -I(" valve to shop to get I'B8IIt , . ..~ val~.lirrtves back on platform ,Shut dawn for night . . , . ! I . ,- . rOOL COST ~5: 1tr Bral4ed Une brush . 5: 112." X~llne 5~ 1/Z' GS ~. . . . . ~ ,. -. Werk strtng Det1d1: .,. RS.. ~ ..", ~ stem. S stem. B ~ I D..crtption of any 'I~ONE toota or d....... 'eft , . . in the hole: i ; . ., ... . ' ~ -Brief Sumrna~ of ~et "I(" Valve - didn't test · pressure let IDo hIgh .. puB-"I(- valve - sind to town to Qat reset , Tot.I Work . - Completed . ~ '. I r-- HoURI ~\'6"':.d . .. 17 I y~.: , ... ...~ CoM: $ Wen DawmJme Hr. 'hut in Approved by: ~ Tarin... TotafTaoI COet $ P-8439 3\SJ38.OQ 10 H28PP11 nla II \, S 55.00 S.. 385.00 . 385·øo 828..00 Total Hour~ S Day.~ Cunsulative Coat: . Wire Test Code: M-19 Steefhead HoweIIISp.rhawklAllen 114 457" 74" 5 112" 350 lIlT ;. ~ . ( . -! ~ .' .~ 3,113.00 1 3,938.OQ 22 ·1 5ep 16 ~uu~ ~:~~Mn 'unu~nL ~rur ~...., ~ r ~ ""'""""".......... ". 1.-:- - _~. '=-- -/ .' 7J2912OO5 UNOCAL4I ...... FridSy SaIet Rate !68 MMCF Line Press' 10~ 1 PSI Gas Well M - 13: OR Well M - 25: ln~ u® .. ._,._~I Pot 70% Drill 76% DIesel 39% Dew Pt -42 0700. Shipped ~n 011 pig to TB.#1" ~. -- \ (tG<' 0730 Started ·C" Gen to shut doNn liB" 0845 Shut down "Ir' gen to fIX a diesel leak inside Ø1e enclosure. 0845 Chopper for Dave Hart to the Dillon. 0845 Pollard here to PUt K..:Valve in M-19 0930 Pre Job Safety ~ng of wire line. " 1000 M--19 shut down for WL " 1015 Russ Gjovig swapped inst Þdr dryers . . 1030 pressur test M-19 1045 PWL Headed sodth with a brush to clean the nippfe. 1} ^t') PWL 'back to su~. . . 1100 Shut in M-2 until we can spend some tlmeta unload it. 1100. Raised M·1 to 5mm to unload water as per Jeff Smetanka 1215 PWL headed soUth.to put in the "K" Valve. 1300 PWL out of hole and we 'are bringing on M-19 to flare to test shut" in pressur:e. . 1315 The "K" vafvé set ~ ended up being 288 #.....Way too high need to pull It send it to town to reset to a tower pressure. Polard did no( ~ a retrieval tool on board" need 8 Chopper from town. WiR flow well at a reduced rate untill then.(Chopper at 4 pm) 1620 M-19 down to puR "K" Valve , 1640 PWL headed south ÜJ pull "K" valve 1100 PWl back to the 8~ce with the W valve 1130 M-19 back on line lR1tin the Valve gets back from tøwn. - 1830 Chopper to bring pave Hart back and take "K" valve to get reset at pollard. 23:30 chopper brought thks valve b~ PWL to bed. 5ep 16 ~UU~ b:~~Mn unU~nL ~rur ...."" r .. .. """"...,""""~ FRcr1 : ):)ollaT'd LJireline Inc' :--- Date: Work being done: Supe~or: , Wlrellne Unit Nu'Mber: Tree Valve Condition fluid Level if Id..,øfied Zero Wtreline lit: Minimum TubiÎ1g ID: " _ Start Tbg. ~ Csg. PSI .. Time 06:00 ~:15 08:30 01:00 08:15 09:,00 10:00 11:00 11:40 15: 00 , Il I F,:¡x NO. : 9ß7 283-7118 .......... ' 5@p. 01 2em Ø3:~ P2, UNOCAL ALAsKA RESOURCES WELL SERVICE REPORT 713012OO5 Set "1(" v~~e Mike Chivers Steel head 'Unit Good N/A T~lng Han..... We" Number Location: ' AFE.' Charge Code:· Pollard Wireline Crew: T ota) Wlreline Miles: , Ma. Depth (KB): Wen KB: Max Tool OD: ' ,Endi-. Tbg & c., PSI, IJIDIMICt Unit X 3SO .QperIItIan DáJIS RiQ back, up _ ..~ meeting , Rltt W,/" 6 1f'Z' X-line wJ "k" vëllv~ to 4ST KB .. let valve - POOH ~ production telt valVe prMaIØ -.11I too htah - ClOSed at 1_ . '\ . - _. ~ . ...~1Ji wJ 5 1f2" GS to 45T KB -latch a pun valve.. ,POOH _ st~,valve,~ to town piOdUdlon tries SSSV, it 'starts warkinø 8A8In CaU off f'I~ valve . ~ ' RIa down & dean up ß~ hom~ \ TOOL COST ·5,1~ X..1tne ¡ i . 5:1rr GS s ~.OO $ 220.00 .. - 'Iro. . . , Work String o.tail: ei.. RS, 2' 8Iem. fJ ~em, ~ .mt 8 SJ -, - I ,. Descriptian of.y "ONE , tools or delJrislefl, í In the hole: : . I _, , .- i.. " 'BrIel Su~ of'~t(R valve - didn't teet, pull ~ vaN~ Total Work. ' dton tries SSSV, SSSV starts working COmø..... 'fÍ¡tiQ down ' , - , I r~ ttou... W~ ; . 12 1-1c:ket" :: ~Hy Cost:~ $ I .... Well Downt1me Hr. 8hut In Approved by: ~T.n!,-r " TOt.) Tool coet I p~o 2.728.00 5 .t4O.00 - Total Hour eo.t $ . Day.:'" Cumulative Coet:. S WiMTest Code: HZS PPM nIa M-19 Sœethead H~WS~AIeIt 1/4 457 74' 5 112- , ;i50 MfT " " ., , 2.288.oø 2 6.888!OO ~ 1 Sep 16 20U~ ~:~~Hn unU,"-ML c.rur ........., , .. ""''''.......,..... '- I - '"",-- 1130/2005 '-Nf.JCALtI ..-- I Saturday Salu Rata ea MMCF Une Prea8 1034 PSI Gas Well M.... . 19 _ OUWell M..., 25: Pot 69% Drill 76% Diesel 39% Dew Pt -42 0500 added jet 2 to "e" :generator. 0630 M-19 81 for wire line. 0645 PWL heading doWn hole with reset "K" valve. On M...19 0715 P'NL back to the ~urface ready tQ try the "K'I valve set point. 0730 First try bloWing doWn M...19 to -t(" Vafve set point. Looks like i is still set just 8 bit high. It shut at 289 psi. 0745 Second try on M-19 set poinl Second try closed at the sa,mé press 290 psi. Will need to send the uK" valve back to town to·get set lower. 0800 Putting gas on the top side of M...19 to get the 111(" valve back open and ready to putl. 0830 PWL going down to pull vltve. 6~ _J èhopper here to take "I(" vatve in. 1000 Decided to try the Hyd SSSV one more time on M-19 while we are waiting. The wire finers have been In and ðUt of the origi'lal profile three times now maybe they have broken it free? 1030·GI'88t newsl M-19 ~ works good now. Holds like 8.rock. The SSV needs help now though. 1300 Sendh19 Pollard horre. 1330 M...19 back on line.. ~u..Down time is 7 hrs....Gas rate·for today out of M-19 i$ 6063 mm We had M-191n test to get a rate test for the moming report. A 24 hr run shoUld be aromd 8450 mm 1630 Had a FIrå drtß an~ Safety meeting. ~ep l~ ~uu~ o.'~nn Ul1u",nL.. I;;;.r I.I~ ......,. . . ----- .. ... ..... ..------ - - I . -- c_ "/''i/Þt' -ßi1 &166:. ".0 tAlA! ·fAltlWii· 5 ~dtJ...~ "'b. ~ . Sales Rate· 66 MMCF Li1e Press . 1001 : PSI Gas Weft M;. M-19: Oil Wen M - M-31' 7IÐ/. A ------- PDt '76% Drill 60% Diesel 38% Dew Pt ~3 0700 Shipped pig to 1radihg bay 0700 Shut in M+19 ref'tK)\àng tree to change'out SSV as per Paul B 1000 M-19 LOTO Doug ¡Gary and Peak Hands removing tree 1. SSSV shut bled to 0 2.Master shut bled to 0 3. Wf~ Ih.It : 4. Header valves shut 5. Bleed on fIowIîries to flare ' . . . 1200 Tailgate safety meêting for tree removal on M-19 1400 Removed cross &$wâb M..19 -I. ., Removed M-19 sstI \. . . . 1600 Boat dl'oppe;d off Obc HolidaY and M-19 SEW 1630 TaQgate safety ~ng for tree reinstallation on M-19 ...... Phoenix dównloads dqr,e and on Anchorage server 2230 M-1-9BOL 2354 Com Falure Work ~ 1.2.& 3 (8111rozen) StatIon 12 monitor black. Mr Wizzard (I mean WëtzeI ) did his magic and fixed it. Sep IS 2005 6:45AM UNOGRL ~~u~ ~u f f fIOIOOO.:J I""'.'¡; . r (. ..¡:~. ~. '-'" J ¡~/ , U~OCAL A~ASKA RE$0URCES ~ELL.SERVICE RE~ORT -'-"-r--'--;' - ' . ---- ~ Datë:','- . 5) I S/ ~.."S"" ''\Iell N ~mber; Þ1 ...s \ : wórk bein~ done: 'J'tJl.. RLAJ,} ss.sv Location: 's)--./A~øI" - ~ i Supèrvisor: (:, \ l-IoJ.T AFE# J C"1arge Code:. . - ., ~ t W¡r~line Unit N1Jmber: '. .,JJ. uµr\-- Pollard W reline Crew: ~/~¡""IJ~'¡A/~~ 'ì Tr~e Valve Cà-'\dltlon ----!1øð.,l Total W.rlllne MH~:, ~ I Fluid Le~91 ]f Idtntlfled Max Jepth (KB): ' ¥Y5 I ;' Zero Wir~ ine at: _. TJ!bt~~9fi Well KB: 7'{ i . Mini.mum Tubing Ie: '-"J :.' ~~. -¡/Y)/ Max Tool 00: ~.. '81 ! Sttrt Tbg. & c¡~~: PSI~_':-";:':'_"'-",;;;.o» Ending Tbg & CsgfSI l?C / . ;Tlme L Op'rJtlonD'JI't~ 100Dect Unit "'. M/T AJI,q , .. 11"00 _ .::S!.H~U1.' ""''0'0'-_ O1'A.Jw,s. ?Jf,.,¥ ~~""'r w/';/4!. _~~~~IV' R)I (!;.r, /j ~_ ~:~-4A~r&R-ð ~ .~~. ~~. (~""~ wJ Jn~'" SN.a- ~ ~-ç-) ,. .7-' ; " ~..,. ~ IN It.. ~ s-rn s... '-I. e~~~ STArri,." I&JF.. - - 1Ì6~~ _:;¡ ..sß~ .......-r,)~ ~ P¡,I.-b op~~~~ I~ 00 . ¡. _plr~ . -Pt. .J 6'C)~ "I'.¡ t - 01\ ' )."}':J þ. :. ::SN ~., tJ lUelf. L j 't '1o ~~. ~, J¿ ¡J'3~ 6J. ~ f"pa-S ~ I{¥S' ~ð I ~ ~cJ/~ .$iss~ p.ok ; -ào 0 .;' /'. H J. 34 1(-J.·UA'" JJteJIV .su v i PItJ-]' e{tJ þ.rV'JC.~. ~ ~$""'K8.. I .:: P~oß -. t 0.3 S· ~ ~ PLO~ .'f'e.$'r."~.t: SeØ . fJ.4., oW .$.$$"., Ú 0 ,.., ^'~ 'tLlls ,;~'" DC~ ItAI.~L.. /2..~-rv,'(&1'.J W6>1 .A fpÞ~lOro.! . j~~A.J u,p '7O'ÞLA & P'f..fI'( ? 33~ ~ ~.,.p":14r~ "~TFor"- ! I./fIO· :' .... , ;. ~.~ G::. - ZZ Q '!!! it'll, X'4JiJe - ~in.--e 1 01:) \" CQ ':tT' - --'j ;¡ '. . ¡, L· \'''or~ siring D.t.;¡:~"J/~ J.~"<S. t'D ·;"re."., Shfo\c¡,';.,G-C.. .;. ~ . ¡. !)eacrlptlo'n ot any~ ¡fJOCV.r¿ -- . . 1001' or debrl. l.tÙ '. in the hole:; ; \ - --.' - 8rí.ef ~~mm8ry. ot~ ~~11C8Q 't.¡\J) ,ss$V tr:ÁjJ~ - ~ AiSP\... Jour Wor~~ l~IV" ftle-uJ SS¿U): - Tê$7' ~~. Completod. , . _i - I\., . - - ~ fetal ~o~...rs ~Qrk~d : <t ..... Total Tool Coat ¥¥.O. ~ TO<II· Hour Cost : I. . T~ék&t N : . . ""' . . . . Day # : .. I . Oai~ Co~t: "(.Or>~. ~, CU"UI~t've Coat: I ~ell Do~.rHlm(' Hr. s~. . l' ~..Hß ç . H29 PPM AJ t" WIre TøtÍl ~pprov~d bJ': n~ ~H H<.CLtJ Code: J.~~~ l , . ~Ot)~.~ z.z,. ?7" sep l~ 200~ 6:~~HM unUJ..;HL t:.t"Ut" ." -' ;' ;;:JU { ( (CCiDiD.;:) ..1:". ~ .&.. ~__.___ ~- 511512005 UNOCALtI .... Sunday " ::" - Sales Rate Une Press Gas WeI M - Oil Well M - 55: MMCF' 973 PSI T!®./ ---~ 25, 0230 ramping M-9 closed. 0234 M-9 shut in for 8 hour pressure build up survey. 0700 Shipped 01 PIg to TPBF. 0800 Cleaned Omnlpure BookoeU. 1000 Ran SE d~ FW Pump 30 mins for MonthIy(95.85+57 hrs. at SID) 1230 PWL POOH on M-9. 1,250 RIH With bailer fur... -Ø:r- ~ ,~ ..... Doc Holiday came over to work ,on some valves for Drillling Rig. . . 1313 Started putr~ ~ off "A" series· injections pumps. 1340 POOH .Had to shut: the master, ~b leaks ..... Poured 9144 &5784. 1430 lubricator off ~. . 1430 SID T Water Inj. ~ps(outbrd seal leak on P-27B) 1445 Started I4AI4 Inj. Pumps. 1500 M-9 back on li1e. . : 1545 SID P-26 & 27"A14 ahd an waterflood for new line to mud pits. 1830 pre wireline meeting. 1p-t5 pressure testing lu~tor. 1930 ~ shut tn, PWL ~ng ~ to pull SSSY. 2100 M-5 BOL. . Pot Drill Diesel Dew pt 80% 91% 40% 2.6 2 t .~ ,0 s-kyl-J fA) F PUfrtpS f~W R'.51~ rbwY\ + ~oi'5 ~)M.. 5ep l~ ~uu~ D:~~Nn unu,"-nL I:.rur .¡;,'" , , , "''''~~..... r--- " . ~ ~~.., 612112005 UNOCAL. ~'~...- . .. :-¡~ " -. . , ,I Tuesday ,'" ~ Sates Rate Ø9 MMCF Une Press 1043 PSI Gas Well M·- 12; Oil Well M - 28' Þot 79% Drill 87% Diesel 39% Dew Pt -48 . 0630 SII M-!i to test SSSY. State I~ will be here this morning to check 0700 State Insp on board:to test rig bop"s and M-5 SSSV 0830 The State mcin was here for drflftng and wh1Ie he was here he blessed M-5Issv. Tested OK.. back to prod. 1300 lOTO on itA- Gas ~ in preparation for cleaning. 1730 stwted -c- Turbíne~~. for drIIlng (SU=5min) ..... Poured CRW-01~ to Vac. Pumps H2O day tank.( 8 oz. } . , -- UNOCALI ~ ~-oc.¡ S~~ 'Alaska Safety/Obligations Inspection Report MONTH: CRAFT DATE Discrlption FREQ ASSIGNED CHECKED PERFORMED BY REMARKS 1 Eye Wash Stations & Showers Monthly Oper r,¡r qo 2 AED (Defibrillator Station) Monthly Oper ~ 2.t%¡ ("'t;-. l- I" ()l{ St'r z 3 Life Ring Bouys & Life Jackets Monthly Oper w :i 0- 4 Air Pack Inspection Monthly Oper fo.:J.,fj ~ :5 a w 5 Chemical Gear Station Monthly Oper ~·bt B-Q. ~ w 6 Stretchers & Backboards Monthly Oper C, " J() I<G ~ v ...J 7 ETT Trauma Kit (First Responders) Quarterly Oper ~ Due 8/04 w z z 8 Fall Arrest Systems Monthly Oper ~/o '-( c;7('J~ 0 C/) 0::: 9 Oxygen Resuscitator Monthly Oper w 0- 10 Medical Room and Stock Quarterly Oper Due 7/04 11 First Aid Cabinet Inventory Quarterly Oper Due 7/04 12 Drill, Abandon Platform Monthly Oper (¡1 (;f 13 Drill, Fire Monthly Oper I...,~ uJB >- Drill, Man Overbooard Monthly Oper (¿.t3 1'''9 P I- 14 w u. (~z;, C~ « 15 Facility Inspection Monthly Oper (j) 16 Good Operations Meeting Monthly Oper ~~ 6r 17 Safety Meeting Monthly Oper ~ ~o, 6 P 18 Explosimeter & 02 Calibratiol) Weekly Inst &(1,6 6 V Ansul Units (Wheeled) Monthly Oper I 'k~ Me. 19 '- 15 'M. 1"M 20 Fire Extinguishers Monthly Oper ~'~k æM '1-~ I- 21 Bunker Gear and Bum Paks Quarterly Oper Due 8/04 z w 22 Heliport Monitor Semi Oper ¿./ Due 8104 :E a. ~/1 ø~J{ l't. ~~ :5 23 H20 Hose Reels Monthly Oper " f-M. w 24 Stroke Ventilation Louvers Semi Oper Due 8/04 (j) v- « 25 UV Detectors and Strobes Quarterly Inst C) oð w 26 ,Deluge System Annually Cont Due 4/05 0:: ü: 27 Flush Fire Water System and Flow Test Annually Cont Due 4/05 28 . Halon System Annually Cont Due 4/05 29 Heat Detectors Annually Cont Due 4/05 30 Smoke Detectors Annually Cont Due 4/05 31 Emergency Battery Check Monthly Elect ~ 12.~ 13P 0:: 32 Test Diesel Firewater Pumps Monthly Oper I#l~ ~ w 3: Mech fl- ¡/JY I- í?t:3 0 3~ Escape Capsule/Boat Inspections 8;....Weekly a. C) 34 Emergency Generator Monthly Mech/Oper Ú. -'~ 1 S B 0:: w :E 35 EmerQency Lights Quarterly Elect 1tJ~/:; ~ Duel04 w 36 Electric Firewater Pump Monthly Oper C.W 37 Car Seal/ PSV Semi Oper Due 9/04 38 Oil Storage Tank Visuallnsp > 10K Gal Monthly Oper ¿, '(J- é6 39 Oil Tank High Level Alarms>10K Gal Monthly Oper b'f" ~ 0- C/) 40 Wellhead Safeties - Hi Lo's Quarterly Oper Due 4/04 3: ¡¡¡ 41 Fuel Hoses (Transfer and Cra~e) Annually Oper ~. Due 9/04 u. ~ 42 Cathodic Protection Monthly Elect tDf'Cof a-f ~a(- 0- s 43 Navigational Aids Monthly Elect ~~ ~ a w 44 Ground Fault Protection Quarterly Elect 45 Rigging Inspection Annually Crane Oper, & -' ,- -- -.- --' - '"'''''' 46 Water Heater PSV inspection Monthly Oper (,(J. ~ ~ø , 0 ~ 3 ov-.4 ð~ S-\tV'(.4. /¿'30-~ r1¿J. A · Date (Facility Supervisor O:/SteelheadlSafety Obligations #1 Operator: Turn this form in to the Foreman at the end of the month MONTH: 1 2 3 4 5 6 7 8 9 10 11 12 13 > Iü 14 u.. ~ ·15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 ~ !z w :E Q,. 5 a w ~ w ~ ..J W Z Z o U) 0:: W Q,. ... z w ::liE 0- S a w t.n c( C) ofS w a: u: a: w ~ 0- C) a: w ::& w Q,. tn æ ~ ~ Q,. 5 a w URDCAL' <:- J4laska Safety/Obligations Inspection Report -- ?-oc.f Dlscriptlon Eye Wash Stations & Showers AED (Defibrillator Station) Life Ring Bouys & Life Jackets Air Pack Inspection Chemical Gear Station Stretchers & Backboards ETT Trauma Kit (First Responders) Fall Arrest Systems Oxygen Resuscitator Medical Room and Stock First Aid Cabinet Inventory Drill, Abandon Platform Drill, Fire Drill, Man Overbooard Facility Inspection Good Operations Meeting Safety Meeting Explosimeter & 02 Calibration Ansul Units (Wheeled) Fire Extinguishers Bunker Gear and Bum Paks , Heliport Monitor H20 Hose Reels Stroke Ventilation Louvers UV Detectors and Strobes Deluge System Flush Fire Water System and Flow Test Halon System Heat Detectors Smoke Detectors Emergency Battery Check Test Diesel Firewater Pumps Escape Capsule/Boat Inspections Emergency Generator Emergency Lights Electric Firewater Pump Car Seal/ PSV Oil Storage Tank Visuallnsp > 10K Gal Oil Tank High Level Alarms> 1 OK Gal Wellhead Safeties - Hi Lois Fuel Hoses (Transfer and Crane) Cathodic Protection Navigational Aids Ground Fault Protection Rigging Inspection Water Heater PSV inspection 7- 3/- 0+ Date O:/Steelhead/Safety Obligations -- CRAFT DATE FREQ ASSIGNED CHECKED PERFORMED BY Monthly Oper Monthly Oper Monthly Oper Monthly Oper Monthly Oper Monthly Oper Quarterly Oper Monthly Oper Monthly Oper Quarterly Oper Quarterly Oper Monthly Oper Monthly Oper ~. Monthly Oper - Monthly Oper Monthly Oper Monthly Oper Weekly Inst Monthly Oper Monthly Oper Quarterly Oper Semi Oper Monthly Oper r ¡, Semi Oper Quarterly Inst Annually Cont Annually Cont Annually Cont Annually Cont Annually Cont Monthly Elect 7/ ~ / Monthly Oper ~I Weekly Mach iN I' Monthly Mech/Oper ~?/ Quarterly Elect Monthly Oper ~ Semi Oper Monthly Oper ~~ Monthly Oper ~ : u Quarterly Oper Annually Oper Monthly Elect Monthly Elect aatrtorly, Elect Annually Crane Oper Monthly Oper 7-25 7-Z5-- 7-7.~ 7-?S- 7-ZS 7" 2.:>- 7 - z.s- 7-2;5 7-Z; 7-¥ REMARKS c..::J n?AJe.- /70 C-.:T ~ c..~ J ;??? w c.... :To Due 8104 ~~c. ,rD. Due 7/04 Due 7/04 ~y:J ~?/ ø~ f!Q r: 6/: s/ rj£ ~A/ ~¡'J rr rfí7J ~~ tJ - SfV' (z. 7ft k nt c- ,Iz y; .e. 6 /J1t" - i~7 717 Due 8104 Due 8/04 A::.ð, 7Ø1c..' Due 8/04 Due 4/05 Due 4/05 Due 4/05 Due 4/05 Due 4/05 ¡JILt ~# .~ SK Due ~ Sf SA Due 9/04 ¿~ ~s6 Due 4/04 Due 9/04 / p,L j>At /2 -o¢ ~" to.~ V\.~. (Facility Supervisor) #1 Operator: Turn this form in to the Foreman at the end of the month UNOCALI ~~- Alaska Safety/Obligations Inspection Report - MONTH: F oc.f Dlscriptlon 1 Eye Wash Stations & Showers 2 AED (Defibrillator Station) 3 Life Ring Bouys & Life Jackets 4 Air Pack Inspection 5 Chemical Gear Station 6 Stretchers & Backboards 7 ETT Trauma Kit (First Responders) 8 Fall Arrest Systems 9 Oxygen Resuscitator 10 Medical Room and Stock 11 First Aid Cabinet Inventory 12 Drill, Abandon Platform 13 'prill, ri,e \\~~ '"Or..\\ 14 Drill, Man-Overbooard 15 Facility Inspection 16 Good Operations Meeting 17 Safety Meeting 18 Explosimeter & 02 Calibratio~ 19 Ansul Units (Wheeled) 20 Fire Extinguishers 21 Bunker Gear and Bum Paks : 22 Heliport Monitor 23 H20 Hose Reels 24 Stroke Ventilation Louvers 25 UV Detectors and Strobes 26 Deluge System 27 Flush Fire Water System and Flow Test 28 Halon System 29 Heat Detectors 30 Smoke Detectors 31 Emergency Battery Check 32 Test Diesel Firewater Pumps 33 Escape Capsule/Boat Inspections 34 Emergency Generator 35 Emergency Lights 36 Electric Firewater Pump 37 Car Seal/ PSV 38 Oil Storage Tank Visuallnsp > 10K Gal 39 Oil Tank High Level Alarms>10K Gal 40 Wellhead Safeties - Hi Lo's E 41 Fuel Hoses (Transfer and Crane) ~ 42 Cathodic Protection Q" :5 g - 43 Navigational Aids 44 Ground Fault Protection 45 Rigging Inspection 46 Water Heater PSV inspection !Ë w :IE Q. :5 a w ~ w ~ ..... w z z ß IX W Q" ~ W LL. -« en t- Z w :IE Q. :s a w en « C) oð w ~ ~ ~ w 3: o Q. C) ~ w :IE w Q" (/) 2!: '1- //,- ec;L Date O:/Steelhead/Safety Obligations - CRAFT DATE FREQ ASSIGNED CHECKED PERFORMED BY Monthly Oper Monthly Oper Monthly Oper Monthly Oper Monthly Oper Monthly Oper Quarterly Oper Monthly Oper Monthly Oper Quarterly Oper Quarterly Oper Monthly Oper Monthly Oper Monthly Oper Monthly Oper Monthly Oper Monthly Oper Weekly Inst Monthly Oper Monthly Oper Quarterly Oper / Semi Oper Monthly Oper v" Semi Oper Quarterly Inst Annually Cont Annually Cont Annually Cont Annually Cont Annually Cont Monthly Elect Monthly Oper Weekly Mech Monthly Mech/Oper Quarterly Elect Monthly Oper Semi Oper Monthly Oper ./" Monthly Oper Quarterly Oper Annually Oper Monthly Elect Monthly Elect Quarterly Elect Annually Crane Oper V' Monthly Oper '1/ 'L tl/ ".... 8-;30 $/~/o'1 tj .. z,r- ~ g-3f ~"'31 g -:, 0 ß-"11 ß"'~O ß.. ~ D g·30 <Y.;).~ ~..~o <¥'~\ ~-\3 ~·1 ')'-'J.o REMARKS \D L<Þ _ áo (5ÍŠ- CS- C5 LVI-~ ~.s L6. Le, / c.r c.'S' ~Ç> ~T ~- Due 8/04 Due 7/04 Due 7104 ~-r E.? ~ ~\ k~\)-tJ4 ~,¡;~vJ t({¡ooo l:j 'CII- f(r Due 8/04 Due 8/04 "is' -J. '"\ 6-3) Æ.. J I ¡C..va <c I (jf \0 Due 8104 , 4¡ Due 4/05 Due 4/05 Due 4/05 Due 4/05 Due 4/05 ?-3/ ß~ ?/5} ~~I?-¡; .//VÇ/ &ðìd/bJ~e- ~-J g Go 1^ Due Î/04 ~-r Due 9/04 --s- -r GI~ Due 4/04 Due 9/04 ~ ~ ~ .~ 1L 4~;;s~r) #1 Operator: Turn this form in to the Foreman at the end of the month ~..~, «·31 (';'.~ '6 L;?ð / IJL} S p7jð'l -' UNOWI -'- ',~'~~AJau /0 -of SafetylObllgations Inspection Report MONTH: , CRAFT DATE DIIcIfpIion FREQ ASSIGNED CHECKED PBFORIIEÐ B'l REMARKS 1 Eye Wæd1 StatkIns & Shavøs Monthly Oper ¡dt) élf.G 2 AEO (DefIñIator Sbiion) Monthly Oper /tJ/J( I 3 ure ~ Bouys & Life JacIœIs Monthly Oper JOlt) 1:..~ 4 A'I På Inspection Monthly O[Ier IO/]1!) i 5 ChenicaI Geer StatIon Monthly Oper JIJ/JD ~ß.. 6 SU8:hers & BacIcIxøds MontIt1 Opel' IDAo Æß i 1 En Trauma KI (fiind: ~~) QuartBrIy Oper --- Cue 11/04 a 8 FaI Arrest SysIBms Þ.tmIhIy Oper /CII' ~ ~ 9 Oxygen RNtJsciWor Monthly Oper i~£ LG- II. 10 Medt8I Room n Slack Quarterty Oper II r.Q:, ~b Due 1Dr01 11 First AkI Cabi1et II;Ivermry Quarterly Oper t~1-ItP ~ Due 1004 12 DriI, Abandon PIátform MontIt¡ Oper /PI's ( JU!-- 13 DrII, FIr8 Moothfy Oper ~ - ~ 14 DrII. Mæ CMrbooard MJnIhtt Oper - 15 FacIIy InspecIIon Monthly Oper fI~ 16 Good Open¡lIons Meeti1g Monthly Oper '~~ 41 t' 17 Safety MøeIkIg Monthly Oper ~~r 18 ,ExpIosImetør & 02 CåInIion Weekly Inst tf$f It 1t"d.(~ 19' . AnsuI UnIIs (Wheeled) Monthly Oper 20 FIre Exlquishers Monthly Oper ~I ,ðfØf N:..- /'tV ~ 21 BtI1Iœr G8II' and Bum Pales Quarterly Oper ~ A. ' [g1004 I 22 HeIport MonitDr Sen1 Oper .---. --- Dua11JD4 ø. ~~{ 10(" 1lC,.,~ a ' 23 H2O Hose Reels f.mIhIy ()per ¡ 24 Stroke Ventilation Louvers Seri Oper ,.,--- Dua11R14 25 UV DøIødDrs and Strobes QuarIerIy IfISt .. I 26 ; Deqe System Annualy Cont - Due .ws ¡¡: Xl Flush F"n W_ System ånd Flow Test Annual¡ Cant - Due oW5 28 ~ SyrdBm Annually Coot - Due .tJ06 29 He8t Detectors Annually Coot - - Due -4ID5 30 SrrDœ DeB:m . AmuaIIy Cont Due 4J05 31 Emergency Battery Check MnhJy Elect 11)- /7 ø~ II: 32 Test DIesel FIrewaIBr Puß1)S ~ ~ ì!' ~ ~ ø. 33 Escape CapsuIeI80at I~ = ~ ~~ ~~~þt '·1 34 Emergency Gener8tor aI 35 Emergency I.Vds t1uIIbt1 EJect Dœ 1004 38 EIedrt Fi8watør ~ Monfhtt Oper /t?-¡~ £,T -g c. Seal fPSV SenÎ ' Oper ~ -' Due 3105 38 01 Storage Tank VisuBllnsp > 10K Gel Monthtj Oper 'f)-tO ~ i 39 08 Tank High Level Alllms>1OK Gal t.bdhtt Oper to..1 (tt:. 40 WeIIIead Saf8IIes.. tllds Quarf8rt¡ Oper Due11W4 i 41 Fuel Hoses {Transfw &1d Crane} Annualy Oper DœM)S 42 CaIhod1c ProIecIion Monthly Elect J 0 '_~'( ~ ¡ 43 _ N~Akfs t.bdItt Elect /b-/t ø 44 GItuId Fault ProtecIIon Seni Elect ~ Due 1A35 45 RIgging 1nsp8ctD1 ; . AnIudIy, CrnOper ___ - ìJrJt. Ji¿ 46 w.. Heater PSV~ia¡pection Monthly Oper 1'/30 Êß , \0- O\..\. ('"t. Ar',\ ~ Qs.~ Dâe (Føcity SqJeMsor) . O-~ u~'hd'eIy 0bIgI¡IIans .., 0pendDr: Tum thia form in to the Foreman at the end d ItIe month - -- - ------- ----.----- -. --.-. --- --- -- UN 0 CALI - "'-:1'~ALuIrø ~~ -05 -SafetylObllgations Inspection Report MONTH: CRAFT DATE- DiIaIpIaa REa ASSIGIIED CIECIŒD Pbct-O::r-' BY REIIARKS 1 Eye Wash Stations & Showers Monthly oper ç:-~'6 L.v 2 : AED (Defbi.4- ~ station) Monthly Oper ~-26 J...~? I 3 lIJe ~ Bouys & ute Jackets Mcnfhly Oper ~I\ - 1h 4 Ak' Pick Inspection Monthly Oper £"-¡r c.s i 5 Chemical Gear StatIon Monthly Oper ~"/I (~ 6 streti:hers .& BacihoanJs McnhIy Oper - S"-I I'r I 7 ETT Trauma Kit (F"rst Responders) ~ Oper 5-'U t.J"? 8 FaI Arrest Systems Monthty Oper Sf II ~A w 9 Oxygen ResuscItatør t-b1ttdy Oper 5"'35 ~~¡; IL 10 MedIcal Room and 9Dck Quarterly Oper 5-16 . L.. \TG- n. 50S 11 Rrst Ail Cabinet Inventory McnIhIy Oper $-U' ~ 7r;;. 12. DrI, Abandon PIstronn MontNy Oper S-Ar c¡# 13 DrIll. Fire Monthly Oper J!Zr r/ .l: 14 DrII, Man CMrtJooard Monthly Oper rbr rtl .. ¡ 15 Facility Inspection MonIhIy , Oper s/zr r:1- 16 Goad 0penIti0ns MeetiIg Monthly Oper ~r ~tf- 17 Safety ~ ' Monthly Oper £j M{, 18 E4IoÅlli!fbr & 02 CaßntIon W~ Inst ;é f 19 AnsuI Units (Wheeled) ~- Oper 20 Fir8 extinguishers MønthIy Oper s¡r .. i 21 BII1ker G82I' and awn Paks Monthly Oper 5"-¡"V LG- ;- 22 Heliport Monftor Seni Oper ~ t, DueMJ5 . 23 H2O Hose Reels MontNy ~ 1G - 51 24 Stroke VentIatiOn LoIMrs Seni, Oper Due6œ. ~ 25 UV Detectors and strobes Quartsrty ~ - I! 26 Deluge SysEm AmualJy COnt' . Ii: Zl Flush FIre WaIør System and FlówTest Annually Cant 28 Halon System Annualy. Cant 29 Heet Detectors ArnJaIy Cant 30 Smoke DeØ:tors Annually Coot.: 31 Emergency BaItsry Check Monthly Elect '. 5'. J./l 'ßI~ II: 32 Test Diesel Firewater PtInps Monthty Oper ,"?-/IIf./> -~ktH"l« I 33 Escape CaprdBIBoat Inspectk)ns Weekly Mech ~-hr ~ ~ ;.. ,I 34 Emergency Genenmr i.!onItt¡ ~J-/Z f l6~þ w ifj 35 Emergency Lights Quarterly EIeØ s~ Du& MIS 36 EIecirk: Firewater ~ ~ Oper S' -/9 - " &.c1r-11v11Q. 37 Emergency VnID· Car 8eaI Seni -Oper Due.MIS 38 01 Sbage TêI1k VIsuaIlnsp > 10k Gal t.bdhIy Oper 7/17 q /I 39 01 Tink ~h LMlAØms>10K Gal MontNy Oper ... 5/~.:.-0I- J F"f( ~. , . 40 WeIhead Sar8ties . Hi Lds QuarIerfy Oper Due twS ¡ l.- I 41 Fuel Hoses (Transfer tnI Cnn) Annualy Oper Due 9105 ~; 42 Cathodic Protection Þtb1tI1Iy .EIect 5-11 BP J a 43 ~Ak1s Monthly Elect $" -;). k liT' ~ 44 Ground FUt ProIøctIon Quarterty Elect £ ~: . 1>11£ -tlfŒét~ 1( , 45 RIgg~!nspection Aru1uøIy CrëœOper 1Ji:V. _ ::'8£ nu£ - /-1'--0(, n' 48 w_.... PSV i1&pectIon Monthly Oper Dø~L F/l.i'¿, ~. .r-~/J-of fI~~/ PI ì Date (Fdty SIJpeMsor) 1 0'~0bI0II0ns ~ Operator: Tum this fOnn in to lite Foreman at the end of the monlfl 1 - 1. n 'j! ;-j - . UNUI;AL, ;J Alaska Safety/Obligations Inspection Report MONTH: /1- o~ Dlscrlption f- Z w :::E 0. S a w ~ ~ en -l w Z z o en 0:: w 0. 1 Eye Wash Stations & Showers 2 AED (Defibrillator Station) 3 Life Ring Bouys & Life Jackets 4 Air Pack Inspection 5 Chemical Gear Station 6 Stretchers & Backboards 7 ETT Trauma Kit (First Responders) 8 Fall Arrest Systems 9 Oxygen Resuscitator 10 Medical Room and Stock 11 First Aid Cabinet Inventory 12 Drill, Abandon Platform 13 Drill, Fire 14 Drill, Man Overbooard 15 Facility Inspection 16 Good Operations Meeting 17 Safety Meeting 18 Explosimeter & 02 Calibration 19 Ansul Units (Wheeled) 20 Fire. Extinguishers, 21 Bunker Gear and Bum Paks 22 Heliport Monitor 23 H20 Hose Reels 24 Stroke Ventilation Louvers 25 UV Detectors and Strobes 26 Deluge System 27 Flush Fire Water System and Flow Test 28 Halon System 29 Heat Detectors 30 Smoke Detectors 31 Emergency Battery Check 32 Test Diesel Firewater Pumps 33 Escape Capsule/Boat Inspections 34 Emergency Generator 35 Emergency Lights 36 Electric Firewater Pump 37 Car Seal! PSV 38 Oil Storage Tank Visuallnsp > 10K Gal 39 Oil Tank High Level Alarms>10K Gal 40 Wellhead Safeties - Hi Lo's 41 Fuel Hoses (Transfer and Crane) 42 Cathodic Protection 43 Navigational Aids 44 Ground Fault Protection 45 Rigging Inspection 46 Water Heater PSV inspection > .... W 11. ~ .... z w ::t 0- S o w U) « C» oð w 0:: ¡¡ 0:: W 3: o 0- t!) 0:: W ::t w c. en ~ ~ ~ c. S a w l~-q -O~: Date n· J!=;tAAlhp.ad/~afetv ObliQ~tions '-' ~ FREQ CRAFT ASSIGNED REMARKS DATE CHECKED PERFORMED BY ¡/Jy,ío~ ~O /1/;. Lf 1-. 6- 7~/~~~~c // iÆt £c /t~ŸJc¡ J(JC / ! - ;;..~~ J-G ///p vO (¡ /¡¡Lj LG Monthly Oper Monthly Oper Monthly Oper Monthly Oper Monthly Oper Monthly Oper Quarterly Oper Monthly Oper Monthly Oper Quarterly Oper Quarterly Oper Monthly Oper Monthly Oper Monthly Oper Monthly Oper Monthly Oper Monthly Oper Weekly Inst Monthly Oper Monthly Oper Quarterly Oper Semi Oper J':J.Ø Monthly Oper Semi Oper Quarterly Inst Annually Cont . Annually Cont Annually Cont ____" Annually Cont Annually Cont Monthly Elect 11; t I~i ¡ß æ Monthly Oper I -;$/0{ ifé,(, G Weekly Mech I'/h S~ ÆJ Monthly Mech/Oper lhfh'f I? c - Á6 Quarterly Elect Monthly Oper I JAr- £ £{ f( ç - J b Semi Oper Monthly Oper . ·11- d. V Monthly Oper \.\-J.<é Quarterly Oper Annually Oper Monthly Elect J /-- ðO ~ Monthly Elect ( I - ~ t.¡ r3 tP Semi Elect Annually Crane Oper Monthly Oper I /3..') I? c- Due 11/04 ~ ~ ~A /-stJ 71(1 6~1/ . sr Jfr . (,y? - ~r 11'3:0- L~ 5'" Due 2/05 Due 2/05 /11~o 1& flfl¡,° Ilr I?I%' /fc í+t Due11/04 Due11/04 ~ Due11/04 --..... Due 4/05 Due 4/05 Due 4/05 Due 4/05 Due 4/05 IF 10 Due 10/04 Due 3/05 ~ ~..,- Due10/04 Due 9/05 Due 1/05 ...c::::::L' ..::::> , C>--\. v-.\J (Facility Supervisor) #1 Operator: Turn this form in to the Foreman at the end of the month -~~ UNOCALI "-- - ':,'th 'Alaska Safety/Obligations Inspection Report MONTH: PI:Y.~t~ ~Cl:> 0/ CRAFT DATE Dlscrlptlon FREQ ASSIGNED CHECKED PERFORMED BY REMARKS 1 Eye Wash Stations & Showers Monthly Oper , Il..22 U, 2 AED (Defibrillator Station~ Monthly Oper , 2/" 3 Le; l- E/] z 3 Life Ring Bouys & Life JaCkets Monthly Oper. J1/:t3 w :::E ·'Opet· -i> J 1ß3 a. 4 Air Pack Inspection Monthly L:! 8 w 5 Chemical Gear Station , Monthly Oper 12/'3 ê~ ~ :s 6 Stretchers & Backboards. Monthly Oper l o/~3 6.) .... 7 ETT Trauma Kit (First Responders) Quarterly, Oper 1JJA Due 2/05 w z z 8 Fall Arrest Systems Monthly Oper ')'·1~ £A 0 en 0:: 9 Oxygen Resuscitator Monthly Oper _ IZþ3 L~ w a. 10 Medical Room and Stock Quarterly Oper MIA Due 2/05 11 First Aid Cabinet InventorY Quarterly Oper NIA Due 2/05 12 Drill, Abandon Platform Monthly Oper·· Monthly ? . L.. ~~- .:þ 13 Drill, Fire Ope(" . ~ 14 Drill, Man Overbooard Monthly Oper w u.. Orier ' 0( 15 Facility Inspection Monthly tJ) 16 Good Operations Meeting Monthly Oper , 2r1' ·04 £.8 17 Safety Meeting Monthly Oper IJ,t8 r6- 18 Explosimeter & 02 Calib~tion Weekly 1nst 19 Ansul Units (Wheeled) Monthly Oper I'M! /lAC-- 20 Fire Extinguishers Monthly Oper J -&'lIf ~ .f- 21 Bunker Gear and Burn P~ks Quarterly Oper rv fA Due2/05 z w :.'''' - ..'4~-. \:.,"" IV/A :IE 22 Heliport Monitor Sëmi Ope(" "~ Due 2/05 a. 1«/6-- d4.C- :5 23 H20 Hose Reels Monthly Oper·· a w 24 Stroke Ventilation Louvers Semi Oper I\JJA DueS/OS tJ) c( UV Detectqrs and Strobes Quarterly Inst t!) 25 cð ¡vIA- w 26 Deluge System Annually Cont Due 4/05 ~ ü: 27 Flush Fire Water System and Flow Test Annually Cont J\lIA Due 4/05 28 Halon System Annually Cont ,vIA Due 4/05 29 Heat Detectors Annually Cont tJ/ A- Due 4/05 30 Smoke Detectors Annually Cont Nlf+. Due 4/05 Monthly , ~¡~.. ~. 31 Emergency Battery Check Elect " j <:u.t., ~ 32 Test Diesel Firewater Pumps Monthly Oper ¿ß. 1..6- w ~'1.. 1 \of ~ 0 33 Escape Capsule/Boat Inspections Weekly Mach jP-Je; q a. t!) 34 Emergency Generator Monthly Mech/Oper ,¥ç 8J "'-~_ 0:: W :E 35 Emergency Lights Quarterly Elect NIl+- Due 1/05 w 36 Electric Firewater Pump Monthly Oper lJ~J. '1 tA L&- 37 Car Seal I PSV Semi Oper NIPr Due 3/G5 38 Oil Storage Tank Visuallnsp > 10K Gal Monthly Oper 1J.<rJ. '( £15 39 Oil Tank High Level Alarm~>10K Gal Monthly . "Ope~,~ ~ f;?j.-;;~ ~C- 0.. en 40 Wellhead Safeties - Hi Lo's Quarterly Oper ¡viA Due10/04 ~ ¡::: 41 Fuel Hoses (Transfer and Crane) Annually Oper (\JIlt Due 9/05 w u. « 42 Cathodic Protection Monthly Elect \?- ( q R.o.At en 0.. :5 43 Navigational Aids Monthly Elect tL.-l~ ~aK CJ w 44 Ground Fault Protection Semi Elect tJJIt Due 1/05 45 Rigging Inspection Annually Crane Oper j)¡r- 46 Water Heater PSV inspection Monthly Oper 'J. 2 J. f:.ß .~ ~1.. .......~.~... .t~. \~~. 1/· J I-'óy ; 2> ~ Date (Facility Supervisor) O:/SteelheadlSafety Obligations #1 Operator: Tum this form in to the Foreman at the end of the month - UNOCALI -~ f'~ :Alaska J¡L)¡rJ ;2a;/5" Safety/Obligations Inspection Report MONTH: CRAFT DATE DI8crlptlon FREQ ASSIGNED CHECKED PERFORMED BY REMARKS 1 Eye Wash Stations & Showers Monthly Oper 1/1, ~/'S- <70 2 AED (Defibrillator Statio'n) Monthly Oper J~ X)""6- hC-- .... Life Ring Bouys & Life Jackets Monthly Oper / Iz:y/s- qrJ z 3 LLI 2 /..t' tH a.. 4 Air Pack Inspection Monthly Oper ~ LLI 5 Chemical Gear Station Monthly Oper /--- l-~ &~ ~ 6 Stretchers & Backboards Monthly Oper 1,2 £1 b~ u.. ~ ..J 7 ETT Trauma Kit (First Responders) Quarterly Oper ~ Due 2/05 LLI z l/l1 ~ z 8 Fall Arrest Systems Monthly Oper 0 (/) a: 9 Oxygen Resuscitator Monthly Oper /. $t:J4'" LLI a.. ~ 10 Medical Room and Stock Quarterly Oper Due 2/05 11 First Aid Cabinet Inventory Quarterly Oper Due 2/05 12 Drill, Abandon Platform Monthly Oper l-Ç 111C- 13 Drill, Fire Monthly Oper ~ 14 Drill, Man Overbooard Monthly Oper w u.. « 15 Facility Inspection Monthly Oper en 16 Good Operations Meeting Monthly Oper 17 Safety Meeting Monthly Oper 18 Explosimeter & 02 Calibration Weekly Inst 1- n 1-1 ttJr _t.- 19 Ansul Units (Wheeled) Monthly Oper {!' $- 20 Fire Extinguishers Monthly Oper ,·0 -¡ ~ w-c.-- 1/.;19 ~ I- 21 Bunker Gear and Bum Paks Quarterly Oper ~~ Due2/05 z w 22 Heliport Monitor Semi Oper Due 2/05 :IE a. 114~ 5 23 H20 Hose Reels Monthly Oper a w 24 Stroke Ventilation Louvers Semi Oper ~ DueS/05 en « UV Detectors and Strobes Quarterly Inst ~ C) 25 olS ~ w 26 Deluge System Annually Cont Due 4/05 ~ ¡¡: 27 Flush Fire Water System and Flow Test Annually Cont Due 4/05 28 Halon System Annually Cont Due 4/05 29 Heat Detectors Annually Cont Due 4/05 30 Smoke Detectors Annually Cont Due 4/05 31 Emergency Battery Check Monthly Elect t/JI l3P ~ 32 Test Diesel Firewater Pumps Monthly Oper 1/31 w I ~ 3: Weekly Mech yf; ~ 6E.f-v.¡l, 0 33 Escape Capsule/Boat Inspections a. C) 34 Emergency Generator Monthly Mech/Oper 1/3 ~ ~ w :IE 35 Emergency Lights Quarterly Elect Due 1/05 w 36 Electric Firewater Pump Monthly Oper l··:=31-dâ ~ 37 Car Seal / PSV . Semi Oper Due 3/05 38 Oil Storage Tank Visuallnsp > 10K Gal Monthly. Oper I'Zh ~ 39 Oil Tank High Level Alarms>10K Gal Monthly Oper I-M ~ a.. (/) 40 Wellhead Safeties - Hi Lo's Quarterly Oper Due10/04 æ ~ - 41 Fuel Hoses (Transfer and Crane) Annually Oper Due 9/05 u.. ë1j 42 Cathodic Protection Monthly Elect 1·021) I<.AK.. . a.. ~ 43 Navigational Aids Monthly Elect l-~ <l RAJ< LLI 44 Ground Fault Protection Semi Elect l-d-~ ó«lIt.. Due 1/05 45 Rigging Inspection Annually Crane Oper 46 Water Heater PSV inspection Monthly Oper J. ~ t!H1... ~ -l~ oS ~ "' \~~ Date (Facility Supervisor) #1 Operator: Turn this form in to the Foreman at the end of the month ð:¡Steelhead/Safety Obligations .-. UNOCALI -~ <'~Alaska ~~~- Safety/Obligations Inspection Report MONTH: c~ CRAFT DATE Dlscription FREQ ASSIGNED CHECKED PERFORMED BY REMARKS 1 Eye Wash Stations & Showers Monthly Oper 2/L//O) ~D 2 AED (Defibrillator Station) Monthly Oper ;{-~/-()5 /..r;:. ~ ~ ~·10.0) f~ z 3 Life Ring Bouys & Life Jackets: Monthly Oper w ~ Q. 4 Air Pack Inspection Monthly Oper '2.. -~-t::JÇ Ec.. :5 a w 5 Chemical Gear Station Monthly Oper ~..;<O ·o~ ~ ~ w 6 Stretchers & Backboards Monthly Oper tç.- La.. ~-'JD-DS ~ ...I 7 ETT Trauma Kit (First Responders) Quarterly Oper ?-~ ld-tJ5 Due 2/05 w z jJ.2J z 8 Fall Arrest Systems Monthly Oper z- -tX' 0 In 0:: 9 Oxygen Resuscitator Month!y Oper ;Z~ ~/-05 L6- w Q. 10 Medical Room and Stock Quarterly Oper ~~'lI~5 J-if Due 2/05 11 First Aid Cabinet Inventory Quarterly Oper ~-?J~, 1-(;- Due 2/05 12 Drill, Abandon Platform Monthly Oper 'J..'i.oS-- S-r 13 Drill, Fire Monthly Oper '1. ..'.0<"' S, >- ~ 14 Drill, Man Overbooard Monthly Oper w u.. « 15 Facility Inspection Monthly Oper .~ -\~-o'S ~\ UJ 16 Good Operations Meeting Monthly Oper 1·19·0S" s-r 17 Safety Meeting Monthly Oper 1..'f'..~ j-r 18 Explosimeter & 02 Calibration. . Weekly Inst 19 Ansul Units (Wheeled) Monthly Oper ).~~). 't ·t~ \{&.. ~ 20 Fire Extinguishers Monthly Oper ~-~ ¥G /lJ1 'Z -"l.Q ~ 21 Bunker Gear and Bum Paks Quarterly Oper Due2/05 z w 22 Heliport Monitor Semi Oper :2 Due 2/05 0.. ~-~~ tG- 5 23 H20 Hose Reels Monthly Oper l,. t.~ þA.. 0 w 24 Stroke Ventilation Louvers Semi Oper DueS/OS UJ « UV Detectors and Strobes Quarterly Inst C) 25 GIS w 26 Deluge System Annually Cont Due 4/05 0:: ü: 27 Flush Fire Water System and Flow Test Annually Cont Due 4/05 28 Halon System Annually Cont Due 4/05 29 Heat Detectors Annually Cont Due 4/05 30 Smoke Detectors Annually Cont Due 4/05 31 Emergency Battery Check Monthly Elect ~ ...:)o·efî ß? 0:: 32 Test Diesel Firewater Pumps ,,/' Monthly Oper .~l<t..of t!-mllL~(f w .~ 0 33 Escape Capsule/Boat Inspections Weekly Mech ~-l5/2.-2'i.r; ,fTl . 0.. C) 34 Emergency Generator Monthly Mech/Oper ~ -J<1'~S- (} þÝéP1 µ. 0:: w ::i 35 Emergency Lights . Quarterly Elect Due 1/05 w 36 Electric Firewater Pump L--" Monthly Oper 9-t <¡ -Þ5 ¡;rj~ 37 Car Seal/ PSV ®X Semi Oper Due 3/05 38 Oil Storage Tank Visuallnsp > 10K Gal Monthly Oper ~ -~ (þo5 ~~ 39 Oil Tank High Level Alarms> 1 OK Gal Monthly Oper ':"\ - ~ '05 ~"T Q. . In 40 Wellhead Safeties - Hi Lo's Quarterly Oper Due10/04 æ ~ 41 Fuel ~oses (Transfer and Cran~) Annually Oper Due 9/05 w ~ 42 Cathodic Protection Monthly Elect Q. :5 43 Navigational Aids Monthly Elect ;1.·J~"c:6 '0-.,. \::... a w 44 Ground Fault Protection Semi Elect Due 1/05 45 Rigging Inspection Annually Crane Oper ~ i 17t.It'> ~ ß 46 Water Heater PSV inspection Monthly Oper '~-Ll-C)'S ~ " \~~. Date (Facility Supervisor) O:fSteelheadfSafety Obligations #1 Operator: Turn this form in to the Foreman at the end of the month Safety Valve Testing Schedule 2002 2003 2004 ) April Tanner Witnessed April Tanner Witnessed April Tanner Witnessed July Payment July Payment July Payment Oct Payment Witnessed Oct Payment Witnessed Oct Payment Witnessed Jan Tanner Jan Tanner Jan Tanner ) Notes: 1 If the test is to be witnessed, be sure and call the state people in advence 2 Safety valves are to be tested every 90 days and witnessed every 180 days. 3 State form, our form, procedure and schedule are located at O:\FORMS\SSVTEST.xls 4 Component failure rate less than 10% is acceptable, over 10% is considered neg/egent and could be fined '--' SHP test sheet STEELHEAD PLATFORM VALVE TESTING I D~e: I Person Testing: PSL PSH Comments: SSV SCSSV LIFTLINE FSV FLOWLINE FSV SWAB VALVE WING VALVE MASTER VALVE _(Upper) MASTER VALVE (Lower) Comments: HI-LO PILOTS I Flow Line Pressure Req. Setting Setting Found WELLHEAD CHECKS Pressures SSV Closing Time - Sec. Start Test After 5 Min. 2nd Test if req. Start Test After 5 Min. 2nd Test if req. Start Test After 5 Min. N/A Start Test After 5 Min. 2nd Test if req. N/A Start Test After 5 Min. 2nd Test if req. N/A Start Test After 5 Min. 2nd Test if req. N/A Start Test After 5 Min. 2nd Test if req. N/A Start Test After 5 Min. 2nd Test if req. N/A Page 1 -~I Well Number: Setting Adjust. To: / Date: Pass Y/N Initial Initial Line * &to 1ST QUARTER I QUA~¡ERL Y WELLHEAD SAFWES þND QUARTER I þRD QUARTER I xxxxxx f4TH QUARTER (ESP) NO-FLOW ...1,.,.. (OTISfTR) NO-FLOW ~ (WlRBV) NO-FLOW III ~ (WlRXE) NO-FOW ~...-- ~.' . - (WLRBV) NO-FLOW ~(TRFV) = NO FLOW I I I I I N/A Comments: (TRFV) NO FLOW Comments: I FV) NO-FlOW Comments: "K"/wellsafe.xls ~~ Operator: UNOCAL Operator Rep: AOGCC Rep: . A~ka Oil and Gas Conservation Commissì"mí Safety Valve System Test Report Submitted By: FieldlUnitlPad: TBU / Steelhead Platfonn Separator psi: LPS f;j~kf!ij£~l4ftl/!iIJ1i:~~}t~1~~·~.~".~;k~¡il1&¡/Ø::·_:"::':-: :::'>:-";'; ~~"' i ":'.: ~i_~§~-"l:i: " Well Permit Separ Set LIP Test Test Test Number Number PSI PSI Trip Code Code Code M-Ol 1870460 M-02 1870610 M-03 18911 10 M-04 1900710 M-05 1891330 M-07 1920590 M-09 1961270 M-12 2011760 M-13 1890490 M-14 1890570 M-14RD 2011710 M-15 1901090 M-16 1971620 M-19RD 19311 70 M-25 1870860 M-28 1900190 M-29 1910270 M-31 1931900 M-32RD 1990970 Wells: o Components: Remarks: RJF 11/29/01 Date: HPS Date Tested and or Passed Retest or SI o Failures: o Failure Rate: Page 1 of 2 GINJ, GAS, CYCLE, SI #DIV/o¿]90 Day SSVTEST SHIPPING ADDRESS 'Work OrderlPÒ/AFE # BILLING ADDRESS UnocaJ 76 a- tþl~ñ1t _'.' Unocal76 52300 Nikiski Beach Road PO Box 8129 Nildski, AI< 99635 Nikiski, AK 99635 Date:. 3· ~\...t'"'1A. Pacility From: ~WQ.'O~"", _. Manifest Number: Sent By: Helicopter Boat .('" TfI~t ") Rcntal Item: Yes No Send To: .. CoC"'9-'t\ ''1s", Attention: \')n...c. n."..\p,n RMA# Address:.Ii City: - State:_ Zip Code: Phone # Equipment, Equipment Number, or Project For: r Ño~ of Size Serial Number Deseriptioa Òmd ArtideI or tJocD I 3'/ ",3" ~cn"'l- ~,~ntP.f'n~~ \I~\,,(._ ß ~ - aepair InstruCÜ~nslAdd1IiO~ InfonDat¡~ - , " r Y\Cf<i\ r-&: ) ". J,¡I ... ,..... Repair & Return Repair & Store Return to Vendor: Credit Exchange ContnIctOtIV~ NGCe: ,,!ftPatr Is pea_ than SO" ol_I~~.~~...uåo1Ull a¡t!I'OYaI will. be ~,. nacî1îty Foreman Signature: r ~O 1/ ~.. J. J.. -~ Contact Ph~ne # ~ L , 1:"' '. ~~~ ". " ,. . E . terUse Only , IacornbJc Date Received: Seat To: , Sblpped Via: Shipped By:. Manife$t , Date: OutgoIng Date Shipped.: Manifest j . Facî1îty Shipped To: __ __ , Deticopter Boat Truck Shipped By: If RCR~r & StcUe: S.torase Location . _, )D~ . Rack ~tion.. . Vendor'Note: A é:opy of this form must accompany pacldng slip with shipment. White ~ Facility Yellow - 2xpediter Pink . Material EO 'd 920Þ9LL 'ON}{ij~ WN Uij 6t:Ot NOW 9002-21-d3S ..~- '"-" . t. I." I" ", ... . ~ . ""'-/~ Unocal Alaska Material Movement Fonn SHIPPING ADDRESS Work OrderlPOlAFE # BILLING ADDRESS Unoca176 --.0\1 *' ~f(~t) Unoca176 52300 Nikisld Beach Road PO Box 8129 Nikiski. AK 99635 Nikiski, AK 99635 Oate: .~..I..J- n~ .. Pacility From: ~y..'nn~"-..("\ 'u Manifest Number; Sent By; Helicopter Boat (Tìùè~ Rental Item: Yes <H§) Send To: f)ðl\" \lnr-qr,i'\ n .... Attention: ()~hn 4e.p· RMA #_ Addrcss:_ City: '. State:_ Zip Code: . Phone #, Equipment, Equipment Number, or Project For: nu - No. ot Size SerIal Number Desertption Cond ArtIeI. or UOCD ConttoI# 27555- \ 3" .. ..oC\o;Çnt' *' SaÇp~ \Ja\\Je.~. ~1<.P.\~~ ~ ~. . . - .- Repair Instructions! Additional 1nf00000't~un: J' ., .,,, ... - ') \¡ C\\~e. .-. ~\.< 1é\. . _.u.-/ (' ,on Repair Be Return Repair & Store Return to Vendor: Credit Exchange . CofttradadV~ ~ II ~ Is ~ tIwI SOfb or replácaÞmt ~ue, addltloal approval ~. be CUCßU). Facility Foreman Signature: ~.r kd T:"htv\M H . Contact Phone # &1.1:; c.lt.I . ,.. ~ ~'ExpedIter Use onty IöcoadDg , Date Received:_ Sent To; Shipped VIa= Shipped By: 'n. Outgoing . - Manifest # 'Date: : Date Sbipped: Facility Sbipped. To~ He1icopter Boat Manifest II Truck Shipped By; If RepAir k_Store: Storage Lo~tion ..' . .. . ID# _h - Rack ~~~n - - Vendor Note: A copy of this form must accompany pacldng slip with shipment.. White .. Facility Ye110w - Expediter Pink . Material GO Id SGOÞ9LL ION Xij~ UN Uij 6t:01 NOU 900G-Gt-d3S #3 ,... _.... ..... ...~ ...__._...~.._~._..___.__...__..________._...._,...",,, ._.__ ....\oo......"",.....~,......,,...._......,......~_:...,_......~.......'.../...."'__" ."....._...... .....,'~.. -........_........;...........J\ ..."._...... ........ UNITED STATES POSTAL SERVICE First-Class Mail Postage & Fees Paid USPS Permit No. G-10 · Sender: Please print your name, address, and ZIP+4 in this box · r) r""'~ '" H""~ r..... ( ~\f-.., '. L.... ~."$~ ...... ¡ ~/r·· . " .,"'>" t r'" k ) ~~G~~th Ave, Ste 100 'lUG J 0 IUO;' t. . Anchorage, AK 99501..., , . .J ~; "J n ('" . . "! {"I' ,'J ," I' (>,\ ",IJit\ CHI ,. ,; , ¡hI(' 'I ì II, ..·r.:!'¡P!f ., nt'..~1¡n I.. 7Õ¿¿ 5)~é'//;ìéad U.S. Postal ServiceTM CERTI,FIEI;) MAIL;M RECEIPT I. v;.: u; I" 'i' " " . · . ;.:'. ,., ru U1 ...D r-=I ~ i··,~'lll",.:~:.€t.":'::'I:i¡'llt'.,\."""""'."""'"""È I m Postage $ O.~)7 iJjNI ~>~@!~~ ~ Certified Fee fQ$j~ ó',.)\ o Return Reclept Fee ? . ~\O Ò[ Postmark Q, o (Endorsement Required) 1. n 75 rL AlIG '!a 2f8j íÎÍ o Restricted Delivery Fee ~~i .~. KilTY"· CO U1 (Endorsement Required) .: e~ ~. . ", .:¡ ,1. ,.~ r-=I ,.\- '- / t:5' m $, '. r¡ 0011,.. ìì¡-~ .- ,/ 'A/ Total Postage & Fees 1..\ .I.·rt:, u :::;(;¡.~S P ß /" ~ .~~'.~Or__lJøL~___hhlnÆ;~____ .~~:;;~4-I!O~7ët-q~!ë1_h_--- .~iI'li""I:I'IIJIIl1Tir::l''¡''IIJ'_L/~· 1.1 0.~~t;.,:J\~lIõTi1'J SENDER: COMPLETE THIS SECTION · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front If space permits. 1. Article Addressed to: , da /¿ Ha/ //(';5 /Þ?æé:? c? /0/.5 /91Þ~L/7 C?m/~jQJG Q9?)/Cj 2. Article Number (Transfer from service lat PS Form 3811 , August 2001 COMPLETE THIS SECTION ON DELIVERY A. Signature (' i4/' , fì ,j1 . '"\. '- AM~.a Agent , X ~t> ç).,lJlMN') 0 Addressee B. Received by ( ;Qnted Name) C. Date of Delivery Af\~()t'\'1 OLAi y\f'\ ~~<1-~ D. Is delivery address different from item 1? 0 Yes If YES, enter delivery address below: 'P-'No 3. Service Type )8'"Certified Mail o Registered o Insured Mail o Express Mail o Return Receipt for Merchandise o C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 7002 3150 0005 3521 1652 102595·02-M·0835 Domestic Return Receipt ) ') :!..~ r·B ;1·1 ·:!U··, !" . l¡ .fll..'~~ " r L"::í! FRANK H. MURKOWSKI, GOVERNOR AI~ASIiA. OIL AND GAS CONSERVATION COMMISSION 333 W. 7TH AVENUE, SUITE 100 ANCHORAGE, ALASKA 99501-3539 PHONE (907) 279-1433 FAX (907) 276-7542 August 25, 2005 MAILED CERTIFIED MAIL 7002 3150000535211652 Mr. Dale Haines Operations Manager U nocal P.O. Box 196247 Anchorage, Alaska 99519-6247 Re: TBU Steelhead Platform Automatic Shut-in Equipment Dear Mr. Haines: The Alaska Oil and Gas Conservation Commission recently initiated an investigation of Unocal's , operations on the Trading Bay Unit (" TBU") Steelhead platform. Specifically, the Commission is seeking to determine whether the installation, operation and testing of the safety valve system ("SVS") are in accordance the requirements of 20 AAC 25.265. Additional guidance about the SVS is provided in the document titled "AOGCC Policy - SVS Failures". Triggering this investigation were discrepancies surrounding SVS testing during 2004 and most recently, Unocal's apparent lack of response to SVS failures noted during March 2005 testing witnessed by the Commission. Unocal is requested to provide the following information: Copies of all SVS test reports documenting the results of tests performed on Steelhead platform wells beginning December 2003; include 6-month SVS tests, miscellaneous tests, and retests after failures; Documents confirming the completion of repairs to SVS components that failed a test; this should include a description of the failure and repair, and the date completed; Unocal's policies and procedures regarding installation and removal of safety devices, lock-out/tag-out provisions, maintenance pra£,tices and schedules, testing, and response to failures. the Commission no later than September 16, formation request, please contact Jim Regg at Attachment ) ) svsdirO 3 AOGCC POLICY SVS FAILURES ( Amended 3/94) This document sets forth the Commission's policy regarding the testing of production/injection well safety valve systems (SVS), this includes low pressure sensor (LPS) with pilot valve, surface safety valve (SSV), and subsurface safety valve (SSSV). Wells must be tested by platform, pad, or driUsite every 6 months unless a shorter period is designated by the Commission. The Commission intends to witness at least 25%, by facility, of all SVS tests; the Inspector must be given 24 hours notice prior to testing. All test results must be signed by an authorized representative of the operator and submitted to the Commission. Each field operator must maintain a "single-point-of-contact" for SVS monitoring, testing, and data handling. 2. WeBs that have neither produced nor injected during the preceding 6 months need not be tested, but must be tested within 48 hours after being returned to production or injection. The inspector is to be given 24 hour notice prior to the test. 3. If a SSV or a SSSV fail, production/injection may continue, but the valve must be repaired and ready for a witnessed re-test within 2 weeks. If the valve fails the re-test, the well must be shut-in until the valve has been repaired or replaced and passes a test. 4. If both the SSV and the ssSV fail, the wcll must be shut-in until at least one of the valves is repaired or replaced and passes a test. The other valve must be repaired and ready for re-test within two weeks as in #3 above. 5. LPSs will be tcstcd as part of the SVS. If the prcssure at which thc pilot trips during the test is less then 50% of thc primary separator pressure, or 25% of the flowing tubing pressure, or the designated minimum LPS pressure, whichever is greater, the LPS fails. 6. If the LPS trips at a pressure not less than 20% below the required trip pressure, at the Inspectors discretion, the well may be shut-in until repaired and re-tested or must be repaired and re-tested within 24 hours. If the LPS fails to trip, or trips at less than 20% of the required trip pressure, the well must be shut-in until it has been repaired and re-tested demonstrating the LPS and at least one of the safety valves are working properly. 7. Velocity type (differential pressure) valves, locally called ilK valves", are to be flow tested like any other valve except that only 10%, by primary separation facility, need be tested each 6 months. Different wells must be tested each 6 months so that all "K:' valves are tested at least every 5 years. Departures, if any, to the above requirements arc to be recommended by a petroleum inspector and must be approved by their supervisor or a commissioner. " BY ORDER OF THE COMMISSION ~o,hï #2 ) ') AOGCC Memorandum Date: 8/9/2005 From: Jim Regg, Petroleum Engineer 'Rqtt 6/10)05 Subject: SSSV Failures in TBU M-05 and M-19RD Mr. Glen Payment (Unocal; Steelhead platform; 907-776-6836) left a voice message this date requesting an inspector to witness retests on the failed subsurface safety valves ("SSSV") in 2 wells: TBUM-05 (PTD 1891330) and TBUM-19RD (PTD 1931170). I researched the inspection records (attached) and noted the failures occurred during a Commission-witnessed safety valve system ("SVS") test performed March 22,2005. I also checked production records for both wells (attached). With this information, I returned Mr. Payment's call. I confirmed with him the request for an inspector to witness a retest of failed SSSVs in both M- 05 and M-19RD; he said Unocal is flexible in scheduling the retests. He also stated that they are approaching the 6-month test due date so the inspector could witness all SVS tests. I asked him when the SSSV failures in the two wells occurred - he confirmed that both occurred on March 22, 2005. I asked if wells had been shut in or producing, his response was the wells were never shut in - they have been in continuous operation since the failures occurred. He also confirmed that there was no Commission approval to allow the wells to continue operating with failed SSSV, and seemed surprised that the well would have to be shut in for SSSV failure. I read to him the Commission policy ("SVS Failures"; signed March 30, 1994 by then Commission Chair David W. Johnston) that states: "If a SSVor SSSV fail, production/injection may continue, but the valve must be repaired and ready for a witnessed re-test within 2 weeks. If the valve fails the re-test, the well must be shut-in until the valve has been repaired or replaced and passes a test." Commission regulations at 20 AAC 25.265 address requirements for an SSSV in offshore wells, and note that if a failure occurs, the system or associated equipment must be repaired within the time frame specified by the Commission or the well must be shut in. It appears Unocal is in violation of20 AAC 25.265, specifically violating paragraph (d) by continuing to produce wells M-05 and M-19RD with failed SSSVs. ) ) Production History Well PTC Compl Type Facility Operator TBU M-19RD 1931170 1GAS Steelhead Platform Unocal Jun-05 0 161106 128 May-05 0 244818 641 Apr-05 0 283145 134 Mar-05 0 273869 450 SSSV failure 3/22/05 Feb-05 0 284447 544 28 Jan-05 0 303968 617 31 Dec-04 0 319159 579 31 Nov-04 0 316619 543 30 Oct-04 0 327107 568 31 Sep-04 0 329836 638 30 Aug-04 0 324638 549 31 Jul-04 0 345272 559 31 Jun-04 0 318639 388 30 May-04 0 243813 67 31 Apr-04 0 387145 580 30 Mar-04 0 395448 85 31 Feb-04 0 359354 478 29 Jan-04 0 431690 607 31 Dec-03 0 427293 630 31 Nov-03 0 426981 586 30 Oct-03 0 443585 548 31 Sep-03 0 333606 544 30 Aug-03 0 307117 562 31 Jul-03 0 433511 551 31 Jun-03 0 415890 553 30 May-03 0 497313 552 31 Apr-03 0 545420 583 30 Mar-03 0 574442 626 31 Feb-03 0 520220 604 28 Jan-03 0 563009 614 31 Dec-02 0 595761 591 31 Nov-02 0 513680 570 30 Oct-02 0 544486 572 31 Sep-02 0 480316 512 30 Aug-02 0 496008 527 31 Jul-02 0 552588 558 31 Jun-02 0 543588 567 30 May-02 0 468036 452 31 Apr-02 0 578998 536 30 Mar-02 0 595482 549 31 F eb-02 0 576967 479 28 Jan-02 0 623406 541 31 Dec-O 1 0 654778 514 31 Nov-01 0 612284 418 29 Oct -01 0 578453 414 31 Sep-01 0 516909 447 30 Aug-01 0 557358 442 31 Jul-01 0 534482 438 31 Jun-01 0 535709 379 30 Page 1 of 3 ) ) Production History Well PTD Compl Type Facility Operator TBU M-19RD 1931170 1GAS Steelhead Platform Unocal May-01 0 572612 392 31 Apr-01 0 555103 393 30 Mar-01 0 613759 445 31 Feb-01 0 555855 476 28 Jan-01 0 535576 861 31 Dec-OO 0 122119 732 14 N ov-OO 0 218613 216 28 Oct-OO 0 295120 449 31 Sep-OO 0 257284 457 30 Aug-OO 0 314324 433 31 Jul-OO 0 317347 456 31 Jun-OO 0 310717 465 30 May-OO 0 294588 458 31 Apr-OO 0 309794 418 30 Mar-OO 0 318982 409 31 F eb-OO 0 304687 381 29 Jan-OO 0 330620 394 31 Dec-99 0 366791 428 31 Nov-99 0 352392 481 30 Oct-99 0 352332 445 31 Sep-99 0 275807 354 30 Aug-99 0 231035 540 31 Jul-99 0 255691 800 31 Jun-99 0 355104 790 30 May-99 0 373374 814 31 Apr-99 0 331330 705 30 Mar-99 0 337680 748 31 F eb-99 0 298295 690 28 Jan-99 0 346888 631 31 Dec-98 0 351367 630 31 Nov-98 0 371027 258 30 Oct-98 0 384981 255 31 Sep-98 0 355403 66 30 Aug-98 0 331759 397 28 Jul-98 0 401147 732 31 Jun-98 0 391105 735 30 May-98 0 367987 278 31 Apr-98 0 396361 909 30 Mar-98 0 415942 498 31 F eb-98 0 399067 889 28 Jan-98 0 443914 988 31 Dec-97 0 446273 1074 30 Nov-97 0 450863 1094 30 Oct-97 0 419573 1183 31 Sep-97 0 446575 1058 30 Aug-97 0 424413 423 31 Jul-97 0 422430 1135 31 Jun-97 0 404241 926 30 May-97 0 414182 836 31 Page 2 of 3 ., ) ) Production History Well PTC Compl Type Facility Operator TBU M-19RD 1931170 1 GAS Steelhead Platform Unocal Apr-97 0 396879 1019 30 Mar-97 0 387054 1086 31 Feb-97 0 379508 956 28 Jan-97 0 307444 836 24 Dec-96 0 432171 1060 31 Nov-96 0 406223 1017 29 Oct-96 0 464304 1223 31 Sep-96 0 424501 1116 29 Aug-96 0 515632 997 31 Jul-96 0 526525 706 30 Jun-96 0 539231 672 30 May-96 0 554125 704 30 Apr-96 0 495469 755 30 Mar-96 0 606726 837 31 Feb-96 0 618770 874 29 Jan-96 0 712849 957 31 Dec-95 0 698193 0 31 Nov-95 0 628464 0 30 Oct-95 0 591117 0 31 Sep-95 0 368238 0 28 Aug-95 0 525480 0 31 Jul-95 0 400902 0 31 J u n-95 0 453278 0 30 May-95 0 467552 0 30 Apr-95 0 639112 0 30 Mar-95 0 722111 0 31 F eb-95 0 378962 0 28 Jan-95 0 726582 0 31 Dec-94 0 764625 0 31 Nov-94 0 874150 0 30 Oct-94 0 732075 0 31 Sep-94 0 565361 0 30 Aug-94 0 390289 0 30 Jul-94 0 307625 0 31 Jun-94 0 298796 0 30 May-94 0 281890 0 31 Apr-94 0 412739 0 30 Mar-94 0 493154 0 31 Feb-94 0 452457 0 28 Jan-94 0 506680 0 31 Dec-93 0 475195 0 31 Nov-93 0 395531 0 30 Page 3 of 3 ) ) Production History Well PTe Compl Type Facility Operator TBU M-05 1891330 1 GAS Steelhead Platform Unocal 01-Jun-05 0 52880 27 01-May-05 0 77219 2 01-Apr-05 0 127609 4 01-Mar-05 0 96693 33 SSSV failure 3/22/05 01-Feb-05 0 96679 31 28 01-Jan-05 0 109033 42 31 01-Dec-04 0 115660 29 31 01-Nov-04 0 118394 9 30 01-0ct-04 0 67097 11 16 01-Sep-04 0 79173 22 30 01-Aug-04 0 78606 4 31 01-Jul-04 0 70400 31 31 01-Jun-04 0 62461 30 30 01-May-04 0 58999 14 31 01-Apr-04 0 71642 34 30 01-Mar-04 0 82683 52 31 01-Feb-04 0 73285 22 29 01-Jan-04 0 82329 1 31 01-Dec-03 0 78904 39 31 01-Nov-03 0 24099 13 21 01-0ct-03 0 49616 14 31 01-Sep-03 0 38790 0 30 01-Aug-03 0 46471 0 30 01-Jul-03 0 94432 0 31 01-Jun-03 0 78373 0 30 01-May-03 0 165799 0 31 01-Apr-03 0 172542 0 30 01-Mar-03 0 37239 217 10 01-Feb-03 0 0 0 0 01-Jan-03 0 0 0 0 o 1-Dec-02 0 0 0 0 01-Nov-02 0 0 0 0 01-0ct-02 0 0 0 0 01-Sep-02 0 80783 240 11 01-Aug-02 0 81058 325 17 01-Jul-02 0 278498 584 31 01-Jun-02 0 237083 812 30 01-May-02 0 224851 142 31 01-Apr-02 0 317226 84 30 01-Mar-02 0 339115 77 31 01-Feb-02 0 321812 61 28 01-Jan-02 0 337397 41 31 01-Dec-01 0 355503 31 31 01-Nov-01 0 368180 41 30 01-0ct-01 0 365694 42 31 01-Sep-01 0 363465 41 30 01-Aug-01 0 387593 8 31 01-Jul-01 0 389347 0 31 01-Jun-01 0 376852 11 30 Page 1 of 4 ) ) Production History Well PTD Compl Type Facility Operator TBU M-05 1891330 1 GAS Steelhead Platform Unocal 01-May-01 0 409419 40 31 01-Apr-01 0 420580 46 30 01-Mar-01 0 467443 48 31 01-Feb-01 0 415342 42 28 01-Jan-01 0 467125 34 31 01-Dec-00 0 26246 16 3 01-Nov-00 0 41548 399 9 01-0ct-00 0 90323 6186 31 01-Sep-00 0 254149 6437 30 01-Aug-00 0 227100 2569 31 01-Jul-00 0 240779 5443 31 01-Jun-00 0 311856 6971 30 01-May-00 0 335608 3178 23 01-Apr-00 0 300774 3786 30 01-Mar-00 0 390253 2507 31 01-Feb-00 0 325475 999 29 01-Jan-00 0 423653 1350 31 o 1-Dec-99 0 570534 1619 31 01-Nov-99 0 532633 1509 30 01-0ct-99 0 513967 604 31 01-Sep-99 0 326177 25 30 01-Aug-99 0 300053 28 31 01-Jul-99 0 382243 28 31 01-Jun-99 0 507058 23 30 01-May-99 0 696551 25 31 01-Apr-99 0 721065 37 30 01-Mar-99 0 777994 42 31 01-Feb-99 0 547255 78 28 01-Jan-99 0 714906 52 31 o 1-Dec-98 0 741910 20 31 01-Nov-98 0 848251 14 30 01-0ct-98 0 857219 5 31 01-Sep-98 0 646519 12 30 01-Aug-98 0 542958 6 27 01-Jul-98 0 673189 29 31 01-Jun-98 0 582004 31 30 01-May-98 0 625400 12 31 01-Apr-98 0 631795 36 30 01-Mar-98 0 558443 51 31 01-Feb-98 0 456036 32 28 01-Jan-98 0 649887 29 31 01-Dec-97 0 833850 30 31 01-Nov-97 0 751734 58 30 01-0ct-97 0 871353 81 31 01-Sep-97 0 595362 59 30 01-Aug-97 0 591170 30 31 01-Jul-97 0 585855 37 31 01-Jun-97 0 744234 45 30 01-May-97 0 908378 51 31 Page 2 of 4 ) ) Production History Well PTe Campi Type Facility Operator TBU M-05 1891330 1 GAS Steel head Platform Unocal 01-Apr-97 0 1112238 37 30 01-Mar-97 0 1035950 8 28 01-Feb-97 0 910283 29 28 01-Jan-97 0 1086088 37 24 01-Dec-96 0 1575774 48 31 01-Nov-96 0 1404613 67 30 01-0ct-96 0 1045706 55 31 01-Sep-96 0 488577 32 21 01-Aug-96 0 297842 29 28 01-Jul-96 0 357140 35 27 01-Jun-96 0 219205 10 25 01-May-96 0 124143 3 24 01-Apr-96 0 140041 6 30 01-Mar-96 0 203481 9 31 01-Feb-96 0 213262 12 28 01-Jan-96 0 292626 26 30 01-Dec-95 0 364162 0 31 01-Nov-95 0 355035 0 30 01-0ct-95 0 191268 0 20 01-Sep-95 0 118009 0 18 01-Aug-95 0 172388 0 20 01-Jul-95 0 53563 0 10 01-Jun-95 0 287556 0 29 01-May-95 0 175139 0 19 01-Apr-95 0 101863 0 8 01-Mar-95 0 512048 0 31 01-Feb-95 0 379465 0 28 01-Jan-95 0 447339 0 28 01-Dec-94 0 278343 0 19 01-Nov-94 0 445344 0 26 01-0ct-94 0 485810 0 27 01-Sep-94 0 67782 0 6 01-Aug-94 0 0 0 0 01-Jul-94 0 0 0 0 01-Jun-94 0 39929 0 3 01-May-94 0 1351 0 1 o 1-Apr -94 0 254832 0 17 01-Mar-94 0 531548 0 30 01-Feb-94 0 211763 0 13 01-Jan-94 0 142359 0 8 01-Dec-93 0 450808 0 19 01-Nov-93 0 778738 0 30 01-0ct-93 0 213592 0 17 01-Sep-93 0 196254 0 19 01-Aug-93 0 157153 0 9 01-Jul-93 0 545165 0 22 01-Jun-93 0 570508 0 26 01-May-93 0 360331 0 17 01-Apr-93 0 332469 0 15 Page 3 of 4 ) ) Production History Well PTe Compl Type Facility Operator TBU M-05 1891330 1 GAS Steelhead Platform Unocal 8/9/2005 01-Mar-93 0 381877 0 27 01-Feb-93 0 381897 0 20 01-Jan-93 0 697526 0 30 01-Dec-92 0 917927 0 31 01-Nov-92 0 816619 0 29 01-0ct-92 0 725769 0 30 01-Sep-92 0 236083 0 10 01-Aug-92 0 246525 0 30 01-Jul-92 0 908408 0 30 01-Jun-92 0 1061727 0 30 01-May-92 0 1141880 0 31 01-Apr-92 0 1174459 0 30 01-Mar-92 0 1152793 0 31 01-Feb-92 0 1200343 0 29 01-Jan-92 0 1272714 0 31 01-Dec-91 0 1234603 0 30 01-Nov-91 0 982097 0 30 01-0ct-91 0 856528 0 27 01-Sep-91 0 1058475 0 30 01-Aug-91 0 1221496 0 31 01-Jul-91 0 1178284 0 31 01-Jun-91 0 1204219 0 30 01-May-91 0 1190744 0 30 01-Apr-91 0 1265911 0 30 01-Mar-91 0 1341531 0 31 01-Feb-91 0 1264471 0 28 01-Jan-91 0 1318759 0 31 01-Dec-90 0 1349873 0 31 01-Nov-90 0 979660 0 30 01-0ct-90 0 1143569 0 31 01-Sep-90 0 958226 0 30 01-Aug-90 0 933811 0 31 01-Jul-90 0 836639 0 29 01-Jun-90 0 943655 0 29 01-May-90 0 1031590 0 30 01-Apr-90 0 823657 0 30 01-Mar-90 0 237641 0 11 Page 4 of 4 Combined SVS TeSt .l¿esults Summary ) Jan 01, 2000 Through S~p 01, 2005 (Excludes Reason = "Retest") Date Tested Tests Components Failures 3/15/2000 11 33 1 10/19/2000 14 30 3 4/12/2001 16 45 4 4/3/2002 13 39 5 4/9/2002 5 15 0 11/16/2002 15 41 0 5/31/2003 17 46 1 ,'JO *-ç.~ 12/17/2003 17 51 1 1'\ :Ùû > 3/22/2005 17 47 4 5/4/2005 1 2 0 TBU_STEELHEAD_PLATF 126 349 19 _..._"._---~.--_.".- Failure Rate 5.44% --- ------_.,--,. ---..-.--. ----..-----------------.---.-- Friday, August 12,2005 Page 1 of 1 ~~{( ~\\~()'5' #1 ') ) (Çù '1f ~\ IF rE '.\ I! ¡pt, ,¡ .~.~..t '-,'¡ ! ~ t....;. 'ï. ~ ¡ j ¡ nL~ !~ ,f',rï\ II ¡L"~ I.¡.....,::..~: ~-.:.,,~ :n..t;'l.o ~1'~ ~U,;;' ¡I.,,~..: fffilC , " " r" l .! ~ "U) I, -~ ""..,.j ~ f1 /-, ~-" -" r"l/í," /-, ¡^ '¡ ¡ " í~' (,~ r ( , !~ \. U . Î !, ~ f i._, \ , ,-'" \ ~IJ\ \ f, ~'::.. \ L.r¡J U::J Lr¡j (lJ) \~) U U FRANK H. MURKOWSKI, GOVERNOR AI1ASKA. OIL AND GAS CONSERVAnONCO~SSION JUllG 1 ß, 20Q.1 333 W. TrH AVENUE, SUITE 100 ANCHORAGE. ALASKA 99501-3539 PHONE (907) 279-1433 FAX (907)276-7542 --.......- .--..-----.,.- ._'~...._--""_.._...., .....-- Dwight Johnson Field Superintendent Unocal PO Box 196247 Anchorage, Alaska 99519 RE: Reporting Safety Valve System Tests Dear Mr. Johnson: Safety valve system regulations at 20 AAC 25.265 require testing at intervals and times prescribed by the Alaska Oil and Gas Conservation Commission ("Commission") to confirm the equipment is in proper working condition. Commission policy establishes the normal test interval to be every 6 months unless a shorter period is designated based primarily on performance. It is the Commission's intent to witness the required 6-month safety valve system testing. Inspection priorities, a limited inspection staff, and other challenges make it difficult at times to attain this goal. Absent our witness, we rely on the operator's test results to validate the safety valve system integrity. --..- . -- -~_., ..-. -.- Regardless of a Commission Inspector's witness, please ensure that safety valve system test r~~lll~__are provided to the Commission within~..w~eks of completing the tests. You~h():t!~-º_____'__'_'_h contact Mr. Bob Fleckenstein of this office at 907 - 793-1242 (email bob fleckenstein@admin.state.ak. us) for the proper electronic form to report the safety valve system test results. Please contact me at 907-793-1236 with any questions regarding this letter. Sincerely, ~b,J?~r James B. Regg , I Petroleum Inspection Supervisor cc: Bob Fleckenstein