Department of Commerce, Community, and Economic Development
Alaska Oil and Gas Conservation Commission
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10/6/2005 Orders File Cover Page. doc
1.
July 26, 2006
July 28, 2006
July 28, 2006
2.
3.
4.
August 31, 2006
5.
October 9, 2006
6.
November 6, 2006
7.
November 15, 2006
8.
November 28, 2006
9.
December 4, 2006
.
.
Other 45
Permit to Drill and BOPE Regulations
Proposed Regulations
Notice of Hearing, distribution list
File opening memo to AGO Juneau
Transcript of Hearing
Entire package mailed to the AGO in Juneau
Affidavit of Jody Colombie
Final Regulations
Order Certifying the changes to regulations of AOGCC
Changes made by the Lt. Governor's Office
.
.
Notice of Adopted Changes to Regulations
On August 31, 2006 the Alaska Oil and Gas Conservation Commission adopted
regulation changes in Title 20 of the Alaska Administrative Code, Chapter 25 dealing
with Permit to Drill requirements and blowout prevention equipment requirements. The
affected regulations are 20 AAC 25.005(c)(4)(A), 20 AAC 25.035(e)(1), 20 AAC
25.035(e)(2), 20 AAC 25.035(e)(4), 20 AAC 25.035(e)(10), 20 AAC 25.036(c)(1), 20
AAC 25.036(c)(2), 20 AAC 25.036(c)(4)(H), 20 AAC 25.036(d), 20 AAC 25.280(b), 20
AAC 25.285(c)(2), 20 AAC 25.285(c)(3), 20 AAC 25.285(c)(9)(A), 20 AAC
25.285(c)(10), 20 AAC 25.285(f), 20 AAC 25.286(d)(1), 20 AAC 25.286(d)(3), 20 AAC
25.286(e). The regulation changes were reviewed and approved by the Department of
Law, signed and filed by the Lieutenant Governor on November 28, 2006, and will go
into effect on December 28, 2006. The new regulations will be printed in Register 180,
January 2007 of the Alaska Administrative Code.
For further information or to obtain a copy of the amended regulations, contact Jody
Colombie, Alaska Oil and Gas Conservation Commission, at (907) 793-1221, fax (907)
276-7542, or e-mail JodyColombie@admin.state.ak.us.
Register ~
.
200
MISCELLANEOUS B'ARDS
20 AAC 25.005(c)(4)(A) is amended to read:
(A) the maximum downhole pressure that may be encountered, criteria
used to determine it, and maximum potential surface pressure based on a pressure
e:radient to surface of 0.1 psi per foot of true vertical depth. unless the commission
approves a different pressure e:radient that provides a more accurate means of
determinine: the maximum potential surface pressure [METHANE GRADIENT];
(Eff. 4/13/80, Register 74; am 4/2/86, Register 97; am 11/7/99, Register 152; am 6/4/2000,
Register 154; am 1/5/2006, Register 177; am~~~ Register---.-J
Authority: AS 31.05.030 AS 31.05.090
20 AAC 25.035(e)(l) is amended to read:
(l) in rotary drilling rig operations,
(A) for an operation with a maximum potential surface pressure of
3.000 psi or less [REQUIRING A BOP STACK LESS THAN API 5K], BOPE must
have at least three preventers, including
(i) one equipped with pipe rams that fit the size of drill pipe,
tubing, liner or casing being used, except that pipe rams need not be sized to
bottom-hole assemblies (BHAs) or drill collars;
(ii) one with blind rams, except that a subsea BOPE assembly
must have blind/shear rams in place of blind rams; and
(iii) one annular type; and
(B) for an operation. other than a casine: or liner operation. with a
maximum potential surface pressure of e:reater than 3.000 psi [REQUIRING A BOP
1
Register -'
.
200
.
MISCELLANEOUS BOARDS
STACK EQUAL TO OR GREATER THAN API 5K], BOPE must have at least four
preventers, including
(i) two equipped with pipe rams that fit the size of the drill pipe
!!! [,] tubing [, OR CASING] being used, except that pipe rams need not be sized
to BHAs and drill collars;
(ii) one with blind rams, except that a subsea BOPE assembly
must have blind/shear rams in place of blind rams; and
(iii) one annular type;
(C) for a casine: or liner operation with a maximum potential surface
pressure of e:reater than 3.000 psi. BOPE must have at least four preventers.
includine:
(0 one equipped with pipe rams that fit the size of the drill
pipe or tubine: beine: used. except that pipe rams need not be sized to BRAs
and drill collars;
(m one equipped with pipe rams that fit the size of casine: or
liner beine: used;
(iü) one with blind rams. except that a subsea BOPE
assembly must have blind/shear rams in place of blind rams; and
(iv) one annular type;
20 AAC 25.035(e)(2) is amended to read:
(2) in coiled tubing unit operations, the well control equipment must include
2
Register _,
.
200
.
MISCELLANEOUS BOARDS
(A) for an operation with a maximum Dotential surface Dressure of
5.000 Dsi or less [REQUIRING A BOP STACK EQUAL TO OR LESS THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
(ii) a high pressure pack-off, stripper, or annular type preventer;
(iii) if pressure deployment of tools, tubing, liner, or casing is
planned, a riser or lubricator sized to the BHA and providing for pressure
integrity from the BOPE rams to the high pressure pack-off, stripper, or annular
type preventer; and
(iv) at least one preventer equipped with pipe rams that fit the size
of tubing, liner, or casing being used, except that pipe rams need not be sized to
BHAs and drill collars; and
(B) for an operation. other than a casine: or liner oDeration. with a
maximum Dotential surface Dressure of e:reater than 5.000 Dsi [REQUIRING A BOP
STACK GREATER THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
(ii) two high pressure pack-offs, strippers, or annular type
preventers;
(iii) if pressure deployment of tools, tubing, liner, or casing is
planned, a riser or lubricator sized to the BHA and providing for pressure
integrity from the BOPE rams to the high pressure pack-off, stripper, or annular
type preventer; and
3
Register _,
.
200
.
MISCELLANEOUS BOARDS
(iv) at least two preventers equipped with pipe rams that fit the
size oftubing[, LINER, OR CASING] being used, except that pipe rams need not
be sized to BHAs and drill collars;
(C) for a casine: or liner oDeration with a maximum Dotential surface
Dressure of e:reater than 5.000 Dsi.
(i) BOPE rams Drovidine: for DiDe. SliD. curtine:. and blindine:
oDerations on the coiled tubine: in service:
(ii) two him Dressure Dack-otTs. striDDers. or annular tvDe
Dreventers:
(ill) if Dressure deDlovment of tools. tubine:. liner. or casine: is
Dlanned. a riser or lubricator sized to the BHA and Drovidine: for Dressure
intee:ritv from the BOPE rams to the him Dressure Dack-otT. striDDer. or
annular tvDe Dreventer:
(iv) at least one Dreventer eauiDDed with DiDe rams that fit the
size of the tubine: beine: used. exceDt that DiDe rams need not be sized to
BHAs and drill collars: and
(v) at least one Dreventer eauiDDed with DiDe rams that fit the
size of casine: or liner beine: used.
20 AAC 25. 035(e)(4)(F) is amended to read:
(F) a kill line and a choke line each connected to a flanged or hubbed
outlet on a drilling spool or on the BOP body with two full-opening valves on each
outlet, conforming to the following specifications:
4
Register _,
.
200
.
MISCELLANEOUS BOARDS
(i) the outlets must be at least two inches in nominal diameter,
except that for rotary drilling rig operations, if the operation has a maximum
potential surface pressure of e:reater than 3.000 psi [REQUIRED BOP IS
RATED EQUAL TO OR GREATER THAN API 5K], the nominal diameter of
the choke outlets must be at least three inches;
(ii) each valve must be sized at least equal to the required size of
the outlet to which it is attached;
(iii) the outer valve on the choke side must be a remotely
controlled hydraulic valve;
(iv) the inner valve on both the choke and kill sides may not
normally be used for opening or closing on flowing fluid;
20 AAC 25. 035(e)(4)(H) is amended to read:
(H) a choke manifold equipped with
(i) two or more adjustable chokes, one of which must be hydraulic
and remotely controlled from near the driller's station if the operation has a
maximum potential surface pressure of e:reater than 3.000 psi [REQUIRES A
BOP STACK EQUAL TO OR GREATER THAN API 5K];
(ii) a line at least two inches in nominal diameter downstream of
each choke;
(iii) immediately upstream of each choke, at least one full-opening
valve for an operation with a maximum potential surface pressure of 3.000 psi
or less [REQUIRING A BOP STACK LESS THAN API 5K], or at least two
5
Register _,
.
200
.
MISCELLANEOUS BOARDS
full-opening valves for an operation with a maximum potential surface
pressure of 2reater than 3.000 psi [REQUIRING A BOP STACK EQUAL TO
OR GREATER THAN API 5K]; and
(iv) a bypass line, at least the diameter of the choke line, with at
least one full-opening valve for an operation with a maximum potential surface
pressure of 3.000 psi or less [REQUIRING A BOP STACK LESS THAN API
5K], or at least two full-opening valves for an operation with a maximum
potential surface pressure of 2reater than 3.000 psi [REQUIRING A BOP
STACK EQUAL TO OR GREATER THAN API 5K];
20 AAC 25.035(e)(10) is amended to read:
(l0) the BOPE must be tested as follows:
(A) when installed, repaired, or changed on a development or service
well and at time intervals not to exceed each 14 days thereafter, BOPE, including kelly
valves, emergency valves, and choke manifolds, must be function pressure-tested to the
required working pressure specified in the approved Permit to Drill, using a non-
compressible fluid, except that an annular type preventer need not be tested to more than
50 percent of its rated working pressure; however, the commission will require that the
BOPE be function pressure-tested weekly, if the commission determines that a weekly
BOPE pressure test interval is indicated by a particular drilling rig's BOPE performance;
(B) when installed, repaired, or changed on an exploratory or
stratigraphic test well and at least once a week thereafter, BOPE, including kelly valves,
emergency valves, and choke manifolds, must be function pressure-tested to the required
6
Register _,
.
200
e
MISCELLANEOUS BOARDS
working pressure specified in the approved Permit to Drill, using a non-compressible
fluid, except that an annular type preventer need not be tested to more than 50 percent of
its rated working pressure;
(C) if any BOP [SEALING RAM TYPE] equipment components have
[HAS] been used for well control or other equivalent purpose. or when routine use of
the equipment may have compromised its effectiveness. the components used [IT]
must be function pressure-tested, before the next wellbore entry, to the required working
pressure specified in the approved Permit to Drill, using a non-compressible fluid, except
that an annular type preventer need not be tested to more than 50 percent of its rated
working pressure;
(D) BOP ram and annular components except blind rams must be
function-tested weekly, and all BOP ram and annular components must be function-
tested after an action that disconnects the hydraulic system lines from the BOPE, except
that if the workstring is continuously in the well, function-testing of blind rams must be
performed as soon as possible after the workstring is pulled out of the well and the BHA
clears the BOP;
(E) for each BOPE test durine: drilline: and completion operations.
variable bore rams must be function pressure-tested to the required pressure on the
smallest outside diameter (OD) and lare:est outside diameter (OD) tubulars that
may be used durine: that test cYcle. except that variable bore rams need not be
tested on BHAs and drill collars:
(F) after installine: casine: rams in the BOP stack. the ram bonnets
must be tested to the required pressure before runnine: casine::
7
Register _,
.
200
e
MISCELLANEOUS BOARDS
illl. BOPE test results must be recorded as part of the daily record
required by 20 AAC 25.070(1), and must be provided to the commission. in a format
approved bv the commission. within fIVe days after completine: the test;
.an [(F)] at least 24 hours notice of each BOPE function pressure test
must be provided to the commission so that a commission representative can witness the
test;
(EfT. 4/13/80, Register 74; am 2/22/81, Register 77; am 4/2/86, Register 97; am 11/7/99, Register
152; am 10/24/2004, Register 172; am~~-, Register ~
Authority: AS 31.05.030
20 AAC 25.036(c)(1) is amended to read:
(1) in rotary drilling rig operations,
(A) for an operation with a maximum potential surface pressure of
5.000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS THAN API 5K],
BOPE must have at least three preventers, including
(i) one equipped with pipe rams that fit the size of drill pipe,
tubing, liner, or casing being used, except that pipe rams need not be sized to
bottom-hole assemblies (BHAs) and drill collars;
(ii) one with blind rams, except that a subsea BOPE assembly
must have blind/shear rams in place of blind rams; and
(iii) one annular type; [AND]
(B) for an operation other than a casine: or liner operation. with a
maximum potential surface pressure of e:reater than 5.000 psi [REQUIRING A BOP
8
Register _,
.
200
.
MISCELLANEOUS BOARDS
STACK GREATER THAN API 5K], BOPE must have at least four preventers,
including
(i) two equipped with pipe rams that fit the size of the drill pipe !!!
[,] tubing[, OR CASING] being used, except that pipe rams need not be sized to
BRAs and drill collars;
(ii) one with blind rams, except that a subsea BOPE assembly must
have blind/shear rams in place of blind rams; and
(iii) one annular type; and
(C) for a casine: or liner operation with a maximum potential surface
pressure of !!reater than 5.000 psi. ROPE must have at least four preventers.
includine:
(i) one equipped with pipe rams that fit the size of the drill pipe
or tubin!! bein!! used. except that pipe rams need not be sized to RHAs and
drill collars;
(Ü) one equipped with pipe rams that fit the size of casin!! or
liner bein!! used;
(iÜ) one with blind rams. except that a subsea BOPE assemblv
must have blind/shear rams in place of blind rams; and
(iv) one annular type;
20 AAC 25.036(c)(2) is amended to read:
(2) in coiled tubing unit operations, the well control equipment must include
9
Register _,
.
200
.
MISCELLANEOUS BOARDS
(A) for a.."'1 operation with a maximum Dotential surface Dressure of
5.000 Dsi or less [REQUIRING A BOP STACK EQUAL TO OR LESS THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
(ii) a high pressure pack~off, stripper, or annular type preventer;
(iii) if pressure deployment of tools, tubing, liner, or casing is
planned, a riser or lubricator sized to the BHA and providing for pressure
integrity from the BOPE rams to the high pressure pack-off, stripper, or annular
type preventer; and
(iv) at least one preventer equipped with pipe rams that fit the
size of the tubing, liner, or casing being used, except that pipe rams need not be
sized to BHAs and drill collars; [AND]
(B) for an operation. other than a casinlf or liner oDeration with a
maximum Dotential surface Dressure of Ifreater than 5.000 Dsi [REQUIRING A BOP
STACK GREATER THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
(ii) two high pressure pack-offs, strippers, or annular type
preventers;
(iii) if pressure deployment of tools, tubing, liner, or casing is
planned, a riser or lubricator sized to the BHA and providing for pressure
integrity from the BOPE rams to the high pressure pack-off, stripper, or annular
type preventer; and
10
Register _,
.
200
.
MISCELLANEOUS BOARDS
(iv) at least two preventers equipped with pipe rams that fit the size
of the tubing [, LINER, OR CASING] being used, except that pipe rams need not
be sized to BHAs and drill collars; and
(C) for a casine: or liner operation with a maximum potential surface pressure
of e:reater than 5.000 psi.
(i) BOPE rams providine: for pipe. slip. cuffine:. and blindine:
operations on the coiled tobine: in service:
(ü) two him pressure pack-offs. strippers. or annular tvpe
preventers:
Wi) if pressure deployment of tools. tobine:. liner. or casine: is
planned. a riser or lubricator sized to the BHA and providine: for pressure
intee:ritv from the BOPE rams to the hie:h pressure oack-off. stripper. or
annular type preventer:
(iv) at least one preventer equipped with pipe rams that fit
the size of the tobine: beine: used. except that pipe rams need not be sized to
BHAs and drill collars: and
(v) at least one preventer equipped with pipe rams that fit the
size of casine: or liner beine: used:
20 AAC 25.036(c)(4)(H) is amended to read:
(H) for conventional open loop fluid process drilling operations, a choke
manifold equipped with
11
Register _,
2'
MISCELLANEOUS BLs
(i) two or more adjustable chokes, one of which must be hydraulic
and remotely controlled from near the driller's or operator's station if the
operation has a maximum notential suñace nressure of 2J'eater than 3.000 nsi
[REQUIRES A BOP STACK EQUAL TO OR GREATER THAN API 5K];
(ii) a line at least two inches in nominal diameter downstream of
each choke;
(iii) immediately upstream of each choke, at least one full-opening
valve for an operation with a maximum notential surface nressure of 5.000 nsi
or less [REQUIRING A BOP STACK EQUAL TO OR LESS THAN API 5K],
or at least two full-opening valves for an operation with a maximum notential
suñace nressure of e:reater than 5.000 nsi [REQUIRING A BOP STACK
GREATER THAN API 5K]; and
(iv) a bypass line at least two inches in nominal diameter with at
least one full-opening valve immediately upstream of each choke for an operation
with a maximum notential suñace nressure of 5.000 nsi or less [REQUIRING
A BOP STACK EQUAL TO OR LESS THAN API 5K], or with at least two full-
opening valves immediately upstream of each choke for an operation with a
maximum potential suñace pressure of e:reater than 5.000 psi [REQUIRING
A BOP STACK GREATER THAN API 5K];
20 AAC 25.036(d) is amended to read:
(d) A BOPE assembly must be tested as follows:
12
Register _,
.
200
.
MISCELLANEOUS BOARDS
(1) when installed, repaired, or changed on a development or service well and at
time intervals not to exceed each 14 days thereafter, BOPE, including kelly valves, emergency
valves, and choke manifolds, must be function pressure-tested to the required working pressure
specified in the approved Permit to Drill, using a non-compressible fluid, except that an annular
type preventer need not be tested to more than 50 percent of its rated working pressure; however,
the commission will require that the BOPE be function pressure-tested weekly, if the
commission determines that a weekly BOPE pressure test interval is indicated by a particular
drilling rig's BOPE performance;
(2) when installed, repaired, or changed on an exploratory or stratigraphic test
well and at least once a week thereafter, BOPE, including kelly valves, emergency valves, and
choke manifolds, must be function pressure-tested to the required working pressure specified in
the approved Permit to Drill, using a non-compressible fluid, except that an annular type
preventer need not be tested to more than 50 percent of its rated working pressure;
(3) other well control equipment must be pressure-tested to the maximum
potential wellhead pressure after each installation of the well control equipment and before
wellbore entry, except that an annular type preventer need not be tested to more than 50 percent
of its rated working pressure;
(4) ifanv BOP [SEALING RAM TYPE] equipment components have [HAS]
been used for well control or other equivalent purpose. or when routine use of the
equipment may have compromised its effectiveness. the components used [IT] must be
function pressure-tested, before the next wellbore entry, to the required working pressure
specified in the approved Permit to Drill, using a non-compressible fluid, except that an annular
type preventer need not be tested to more than 50 percent of its rated working pressure;
13
Register _,
.
200
.
MISCELLANEOUS BOARDS
(5) BOP ram and annular components except blind rams must be function-tested
weekly, and all BOP ram and annular components must be function-tested after an action that
disconnects the hydraulic system lines from the BOPE, except that if the workstring is
continuously in the well, function-testing of blind rams must be performed as soon as possible
after the workstring is pulled out of the well and the [BHA] clears the BOP;
(6) for each DOPE test durin!! drillin2 and completion operations. variable
bore rams must be function pressure-tested to the required pressure on the smallest outside
diameter (OD) and lar!!est outside (OD) tubulars that mav be used durin!! that test cvcle.
except that variable bore rams need not be tested on DRAs and drill collars;
ill DOPE test results must be recorded as part of the daily record required by 20
AAC 25.070(1). and must be provided to the commission. in a format approved by the
commission. within five days after completin!! the test;
00 [(7)] at least 24 hours notice of each DOPE function pressure test must be
provided to the commission so that a representative of the commission can witness the test.
(Eff. 11/7/99, Register 152; am 10/24/2004, Register 172; am ___-L-~ _, Register ~
Authority: AS 31.05.030
20 AAC 25.280(b) is amended to read:
(b) The Application for Sundry Approvals must set out
(1) the current condition of the well;
(2) a copy of the proposed program for well work;
14
Register _,
.
MISCELLANEOUS BLs
(3) unless already on file with the commission, a diagram and description of the
well control equipment to be used, including if applicable a list of the blowout prevention
equipment (BOPE) with specifications;
(4) the maximum downhole pressure that may be encountered. criteria used
to determine it. and the maximum potential suñace pressure based on a pressure e:radient
to suñace of 0.1 psi per foot of true vertical depth. unless the commission approves a
different pressure ~radient that provides a more accurate means of determinin!! the
maximum potential suñace pressure. such as usin!! a stabilized shut-in tobin!! pressure:
œ a description of any wellbore fluid to be used for primary well control; and
œ [(5)] the current bottom-hole pressure, or, if data setting out the actual
pressure are not available, an estimate of the current bottom-hole pressure.
(Eff. 4/2/86, Register 97; am 11/7/99, Register 152; am~~--, Register )
Authority: AS 31.05.030
20 AAC 25.285(c)(2) is amended to read:
(2) in rotary drilling rig operations,
(A) for an operation with a maximum potential suñace pressure of
3.000 psi or less [REQUIRING A BOP STACK LESS THAT API 5K], at least three
preventers,including
(i) one equipped with pipe rams that fit the size of drill pipe,
tubing, !i!!£!: or casing being used, except that pipe rams need not be sized to
bottom-hole assemblies (BHAs) and drill collars;
15
Register _,
.
200
.
MISCELLANEOUS BOARDS
(ii) one with blind rams, except that a subsea BOPE assembly
must have blind/shear rams in place of blind rams; and
(iii) one annular type; [AND]
(B) for an operation. other than a casine: or liner operation. with a
maximum potential surface pressure of e:reater than 3.000 psi [REQUIRING A BOP
STACK EQUAL TO OR GREATER THAN API 5K], at least four preventers, including
(i) two equipped with pipe rams that fit the size of the drill pipe !!!
[,] tubing[, OR CASING] being used, except that pipe rams need not be sized to
BHAs and drill collars;
(ii) one with blind rams, except that a subsea BOPE assembly
must have blind/shear rams in place of blind rams; and
(iii) one annular type; and
(C) for a casine: or liner operation. with a maximum potential
surface pressure of e:reater than 3.000 psi. at least four preventers. includine:
(i) one equipped with pipe rams that fit the size of the drill
pipe or tubine: beine: used. except that pipe rams need not be sized to BHAs
and drill collars:
(m one equipped with pipe rams that fit the size of casine: or
liner beine: used:
(Ui) one with blind rams. except that a subsea BOPE assemblv
must have blind/shear rams in place of blind rams: and
(iv) one annular type:
16
Register _,
t
MISCELLANEOUS B'ARDS
20 AAC 25.285(c)(3) is amended to read:
(3) in coiled tubing unit operations,
(A) for an operation with a maximum potential suñace pressure of
5.000 psi or less [REQillRING A BOP STACK EQUAL TO OR LESS THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
(ii) a high pressure pack-off, stripper, or annular type preventer;
(iii) if pressure deployment of tools is planned, a riser or lubricator
sized to the BRA and providing for pressure integrity from the BOPE rams to the
high pressure pack-off, stripper, or annular type preventer; and
(iv) at least one preventer equipped with pipe rams that fit the size
of the tubing, liner, or casing being used, except that pipe rams need not be sized
to BRAs and drill collars; [AND]
(B) for an operation. other than a casin2 or liner operation. with a
maximum potentia) suñace pressure of ~eater than 5.000 psi [REQUIRING A BOP
STACK GREATER THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
(ii) two high pressure pack-offs, strippers, or annular type
preventers;
(iii) if pressure deployment of tools is planned, a riser or
lubricator sized to the BRA and providing for pressure integrity from the BOPE
rams to the high pressure pack-off, stripper, or annular type preventer; and
17
Register _,
.
200
.
MISCELLANEOUS BOARDS
(iv) at least two preventers equipped with pipe rams that fit the
size of the tubing [, LINER, OR CASING] being used, except that pipe rams
need not be sized to BHAs and drill collars; and
(C) for a casine: or liner operation with a maximum potential surface
pressure of e:reater than 5.000 psi.
(i) BOPE rams providine: for pipe. slip. cuffine:. and blindine:
operations on the coiled tobine: in service:
(ii) two him pressure pack-offs. strippers. or annular tvpe
preventers:
(ÏÜ) ü pressure deplovment of tools is planned. a riser or
lubricator sized to the BRA and providine: for pressure intee:ritv from the
BOPE rams to the hie:h pressure pack-off. stripper. or annular tvpe
preventer:
(iv) at least one preventer eQuipped with ~ipe rams that fit
the size of the tubine: beine: used. except that pipe rams need not be sized to
BRAs and drill collars: and
(v) at least one preventer eQuipped with pipe rams that fit the
size of casine: or liner beine: used:
20 AAC 25.285(c)(9)(A) is amended to read:
(9) a kill line and a choke line each connected to a flanged or hubbed outlet on a
drilling spool or on the BOP body with two full-opening valves on each outlet, conforming to the
following specifications:
18
Register --'
,
MISCELLANEOUS B'ARDS
(A) the outlets must be at least two inches in nominal diameter, except
that for rotary drilling rig operations, if the operation has a maximum potential suñace
pressure of 2reater than 3.000 psi [REQUIRED BOP IS RATED EQUAL TO OR
GREATER THAN API 5K], the nominal diameter of the choke outlets must be at least
three inches;
(B) each valve must be sized at least equal to the required size of the
outlet to which it is attached;
(C) the outer valve on the choke side must be a remotely controlled
hydraulic valve;
(D) the inner valve on both the choke and kill sides may not normally be
used for opening or closing on flowing fluid; and
20 AAC 25.285(c)(10) is amended to read:
(10) a choke manifold equipped with
(A) two or more adjustable chokes, one of which must be hydraulic and
remotely controlled from near the driller's station if the operation has a maximum
potential surface pressure of2reater than 3.000 psi [REQUIRES A BOP STACK
EQUAL TO OR GREATER THAN API 5K];
(B) a line at least two inches in nominal diameter downstream of each
choke;
(C) immediately upstream of each choke, at least one full-opening valve
for an operation with a maximum potential surface pressure of 3.000 psi or less
[REQUIRING A BOP STACK LESS THAN API 5K], or at least two full-opening
19
Register _,
.
200
.
MISCELLANEOUS BOARDS
valves for an operation with a maximum potential surface pressure of 2reater than
3.000 psi [REQUIRING A BOP STACK EQUAL TO OR GREATER THAN API 5K];
and
(D) a bypass line, at least two inches in nominal diameter, with at least
one full-opening valve for an operation with a maximum potential surface pressure of
3.000 psi or less [REQUIRING A BOP STACK LESS THAN API 5K], or at least two
full-opening valves for an operation with a maximum potential surface pressure of
2reater than 3.000 psi [REQUIRING A BOP STACK EQUAL TO OR GREATER
THAN API 5K].
20 AAC 25.285(f) is amended to read:
(f) The BOPE must be tested as follows:
(1) when installed, repaired, or changed, and at least once a week thereafter,
BOPE, including emergency valves and choke manifolds, must be function pressure-tested, using
a non-compressible fluid, to the required working pressure specified in an approved Application
for Sundry Approvals under 20 AAC 25.280 or, if that application is not required, to the
maximum potential surface pressure to which the BOPE may be subjected, except that an
annular type preventer need not be tested to more than 50 percent of its rated working pressure;
(2) if any BOP [SEALING RAM TYPE] equipment components have [HAS]
been used for well control or other equivalent purpose. or when routine use of the
equipment may have compromised its effectiveness, the components used [IT] must be
function pressure-tested before the next wellbore entry, using a non-compressible fluid, to the
required working pressure specified in an approved Application for Sundry Approvals under
20
Register _,
.
200
.
MISCELLANEOUS BOARDS
20 AAC 25.280 or, if that application is not required, to the maximum potential surface pressure
to which that equipment may be subjected, except that an annular type preventer need not be
tested to more than 50 percent of its rated working pressure;
(3) non-sealing equipment must be function-tested weekly, after a repair or
change, and after an action that disconnects the hydraulic system lines from the BOPE, except
that if the workstring is continuously in the well, function-testing must be performed as soon as
possible after the workstring is pulled out of the well and the BHA clears the BOP;
(4) for each BOPE test durine: drilline: and completion operations. variable
bore rams must be function pressure-tested to the required pressure on the smallest outside
diameter (OD) and lare:est outside diameter (OD) tubulars that may be used durine: that
test cvcle. except that variable bore rams need not be tested on BRAs and drill collars;
(5) after installine: casine: rams in the BOP stack. the ram bonnets must be
tested to the required pressure before runnine: casine:;
(6) BOPE test results must be recorded as part of the daily record required by 20
AAC 25.070(1). and must be provided to the commission. in a format approved by the
commission. within five days after completine: the test;
í1l. [(5)] at least 24 hours notice of each DOPE function pressure test must be
provided so that a representative of the commission can witness the test,;,
(8) the operator shall report to the commission within 24 hours any instance
of DOPE use to prevent the flow of fluids from a well.
(Eff. 4/2/86, Register 97; am 11/7/99, Register 152; am---1---1_, Register ~
Authority: AS 31.05.030
21
Register ~
.
200
.
MISCELLANEOUS BOARDS
20 AAC 25.286(d)(2) is amended to read:
(2) in rotary drilling rig operations,
(A) for an operation with a maximum potential suñace pressure of
5.000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS THAN API 5K],
at least three preventers, including
(i) one equipped with pipe rams that fit the size of drill pipe,
tubing, liner or casing being used, except that pipe rams need not be sized to
bottom-hole assemblies (BHAs) and drill collars;
(ii) one with blind rams, except that a subsea BOPE assembly
must have blind/shear rams in place of blind rams; and
(iii) one annular type; and
(B) for an operation. other than a casine: or liner operation. with a
maximum potential suñace pressure of e:reater than 5.000 psi [REQUIRING A BOP
STACK GREATER THAN API 5K], at least four preventers, including
(i) two equipped with pipe rams that fit the size of the drill pipe
or[,] tubing[, OR CASING] being used, except that pipe rams need not be sized
to BHAs and drill collars;
(ii) one with blind rams, except that a subsea BOPE assembly
must have blind/shear rams in place of blind rams; and
(iii) one annular type;
(C) for a casine: or liner operation with a maximum potential suñace
pressure of e:reater than 5.000 psi. at least four preventers. includine:
22
Register --'
e
200
.
MISCELLANEOUS BOARDS
(i) one equipped with pipe rams that fit the size of the drill
pipe or tubine: beine: used. except that pipe rams need not be sized to BRAs
and drill collars:
(ii) one equipped with pipe rams that fit the size of casine: or
liner beine: used:
(üi) one with blind rams. except that a subsea BOPE
assemblv must have blind/shear rams in place of blind rams: and
(iv) . one annular type:
20 AAC 25.286(d)(3) is amended to read:
(3) in coiled tubing unit operations,
(A) for an operation with a maximum potential surface pressure of
5.000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
(ii) a high pressure pack~off, stripper, or annular type preventer;
and
(iii) if pressure deployment of tools is planned, a riser or lubricator
sized to the BRA and providing for pressure integrity ftom the BOPE rams to the
high pressure pack-off, stripper, or annular type preventer; and
(B) for an operation with a maximum ~otential surface pressure of
e:reater than 5.000 psi [REQUIRING A BOP STACK GREATER THAN API 5K],
23
Register _,
.
200_
.
MISCELLANEOUS BOARDS
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
(ii) two high pressure pack-offs, strippers, or annular type
preventers; and
(iii) if pressure deployment of tools is planned, a riser or lubricator
sized to the BHA and providing for pressure integrity from the BOPE rams to the
high pressure pack-off, stripper, or annular type preventer;
20 AAC 25.286(e) is amended to read:
(e) The operator shall test the BOPE assembly as follows:
(1) at least once a week, and after each [USE,] repair, [OR] change, or use for
well control or other equivalent purpose. or when routine use of the equipment mav have
compromised its effectiveness. BOP equipment [BOPE PIPE AND BLIND RAMS] must be
function pressure-tested, using a non-compressible fluid, to the required working pressure
specified in an approved Application for Sundry Approvals under 20 AAC 25.280 or, if that
application is not required, to the maximum potential surface pressure to which they may be
subjected, except that the annular type preventer need not be tested to more than 50 percent of its
rated working pressure;
(2) after each installation of BOPE or other well control equipment, the
equipment must be pressure-tested, before wellbore entry, to the maximum potential wellhead
pressure to which it may be subjected, except that when testing against the annular type
preventer, pressure testing need not exceed 50 percent of the rated working pressure of the
annular type preventer;
24
Register _,
.
200_
.
MISCELLANEOUS BOARDS
(3) non-sealing equipment must be function-tested weekly, after a repair or
change, and after an action that disconnects the hydraulic system lines from the BOPE, except
that if the workstring is continuously in the well, function-testing must be performed as soon as
possible after the workstring is pulled out of the well and the BRA clears the BOP;
(4) after each well installation of the BOPE, the BOPE hydraulic connections to
the rams must be visually verified before wellbore entry,¡
(5) for each BOPE test durine: drilline: and completion operations. variable
bore rams must be function pressure-tested to the required pressure on the smallest outside
diameter (OD) and lare:est outside diameter (OD) tubulars that may be used durine: that
test cycle. except that variable bore rams need not be tested on BHAs and drill collars:
(6) BOPE test results must be recorded as part of the daüv record required
by 20 AAC 25.070(1). and must be provided to the commission. in a format approved by
the commission. within five days after completine: the test:
(7) at least 24 hours notice of each DOPE function pressure test must be
-provided so that a representative of the commission can witness the test:
(8) the operator shall report to the commission within 24 hours any instance
of BOPE use to prevent the flow of fluids from a well.
(Eff. 11/7/99, Register 152; am~~_, Register ~
Authority: AS 31.05.030
25
Amended Regulations
.
.
Subject: Amended Regulations
From: Jody Colombie <jody_colombie@admin.state.ak.us>
Date: Thu, 28 Dec 2006 09:51:53 -0900
To: undisclosed-recipients:;
BCC: Christine Hansen <c.hansen@iogcc.state.ok.us>, Terrie Hubble <hubbletl@bp.com>, Sondra
Stewman <StewmaSD@BP.com>, stanekj <stanekj@unoca1.com>, ecolaw <ecolaw@trustees.org>,
trmjr 1 <trmjr l@aol.com>, jdarlington <jdarlington@forestoi1.com>, nelson
<knelson@petroleumnews.com>, cboddy <cboddy@usibelli.com>, Mark Dalton
<markdalton@hdrinc.com>, Shannon Donnelly <shannon.donnelly@conocophillips.com>, "Mark P.
Worcester" <markp.worcester@conocophillips.com>, Bob <bob@inletkeeper.org>, wdv
<wdv@dnr.state.ak.us>, tjr <tjr@dnr.state.ak.us>, bbritch <bbritch@alaska.net>, mjnelson
<mjnelson@purvingertz.com>, Charles O'Donnell <charles.o'donnell@veco.com>, "Randy L. Skillern"
<SkilleRL@BP.com>, "Deborah J. Jones" <JonesD6@BP.com>, "Steven R. Rossberg"
<RossbeRS@BP.com>, Lois <lois@inletkeeper.org>, Dan Bross <kuacnews@kuac.org>, Gordon
Pospisil <PospisG@BP.com>, "Francis S. Sommer" <SommerFS@BP.com>, Mikel Schultz
<Mike1.Schultz@BP.com>, "Nick W. Glover" <GloverNW@BP.com>, "Daryl J. Kleppin"
<KleppiDE@BP.com>, "Janet D. Platt" <PlattJD@BP.com>, "Rosanne M. Jacobsen"
<JacobsRM@BP.com>, ddonkel <ddonkel@cfl.rr.com>, mckay <mckay@gci.net>, Barbara F Fullmer
<barbara.f.fullmer@conocophillips.com>, Charles Barker <barker@usgs.gov>, doug_schultze
<doug_schultze@xtoenergy.com>, Hank Alford <hank.alford@exxonmobil.com>, Mark Kovac
<yesno1@gci.net>, gspfoff <gspfoff@aurorapower.com>, Gregg Nady <gregg.nady@shell.com>, Fred
Steece <fred.steece@state.sd.us>, rcrotty <rcrotty@ch2m.com>, jejones <jejones@aurorapower.com>,
dapa <dapa@alaska.net>,jroderick <jroderick@gci.net>, eyancy <eyancy@seal-tite.net>, "James M.
Ruud" <james.m.ruud@conocophillips.com>, Brit Lively <mapalaska@ak.net>,jah
<jah@dnr.state.ak.us>, buonoje <buonoje@bp.com>, Mark Hanley <mark _ hanley@anadarko.com>, Julie
Houle <julie_houle@dnr.state.ak.us>, John W Katz <jwkatz@sso.org>, tablerk <tablerk@unoca1.com>,
Brady <brady@aoga.org>, Brian Havelock <beh@dnr.state.ak.us>, bpopp
<bpopp@borough.kenai.ak.us>, Jim White <jimwhite@satx.rr.com>, "John S. Haworth"
<john.s.haworth@exxonmobi1.com>, marty <marty@rkindustrial.com>, ghammons
<ghammons@ao1.com>, rmclean <rmclean@pobox.alaska.net>, mkm7200 <mkm7200@aol.com>, Brian
Gillespie <ifbmg@uaa.alaska.edu>, David L Boelens <dboelens@aurorapower.com>, Todd Durkee
<TDURKEE@KMG.com>, Gary Schultz <gary_schultz@dnr.state.ak.us>, Wayne Rancier
<RANCIER@petro-canada.ca>, Brandon Gagnon <bgagnon@brenalaw.com>, Paul Winslow
<pmwinslow@forestoil.com>, Sharmaine Copeland <copelasv@bp.com>, Kristin Dirks
<kristin_dirks@dnr.state.ak.us>, Kaynell Zeman <kjzeman@marathonoil.com>, John Tower
<John.Tower@eia.doe.gov>, Bill Fowler <Bill_Fowler@anadarko.COM>, Scott Cranswick
<scott.cranswick@mms.gov>, Brad McKim <mckimbs@BP.com>, Steve Lambe
<lambes@unocal.com>, jack newell <jacknewell@acsalaska.net>, James Scherr
<james.scherr@mms.gov>, n1617@conocophillips.com, Tim Lawlor <Tim_Lawlor@ak.blm.gov>,
Lynnda Kahn <Lynnda_Kahn@fws.gov>, Jerry Dethlefs <Jerry.C.Dethlefs@conocophillips.com>,
crockett@aoga.org, Tamera Sheffield <sheffield@aoga.org>, Jon Goltz
<Jon.Goltz@conocophillips.com>, Roger Belman <roger.belman@conocophillips.com>, Mindy Lewis
<mlewis@brenalaw.com>, Kari Moriarty <moriarty@aoga.org>, Patty Alfaro <palfaro@yahoo.com>,
Jeff <smetankaj@unocal.com>, Gary Rogers <gary Jogers@revenue.state.ak.us>, Arthur Copoulos
<Arthur_Copoulos@dnr.state.ak.us>, Ken <ken@secorp-inc.com>, Steve Lambert
<salambert@unocal.com>, Joe Nicks <news@radiokenai.com>, Jerry McCutcheon
<susitnahydronow@yahoo.com>, Bill Walker <bill-wwa@ak.net>, Iris Matthews
<Iris_Matthews@legis.state.ak.us>, Paul Decker <paul_decker@dnr.state.ak.us>, Aleutians East Borough
10f2
12/28/200610:06 AM
Amended Regulations
.
.
<admin@aleutianseast.org>, Marquerite kremer <marguerite_kremer@dnr.state.ak.us>, Mike Mason
<mike@kbbi.org>, Garland Robinson <gbrobinson@marathonoil.com>, Cammy Taylor
<Camille_Tay10r@law.state.ak.us>, Winton GAubert <winton_aubert@admin.state.ak.us>, Thomas E
Maunder <tom_maunder@admin.state.ak.us>, Stephen F Davies <steve_davies@admin.state.ak.us>,
Keith Wiles <kwiles@marathonoil.com>, Deanna Gamble <dgamble@kakivik.com>, James B Regg
<jimJegg@admin.state.ak.us>, Catherine P Foerster <cathy_foerster@admin.state.ak.us>, Bob
<Bob@fairweather.com>, gregory micallef <micallef@clearwire.net>, Laura Silliphant
<laura _ silliphant@dnr.state.ak.us>, David Steingreaber <david.e.steingreaber@exxonmobil.com>,
akpratts@acsalaska.net, Robert Campbell <Robert.Campbell@reuters.com>, Steve Moothart
<steve_moothart@dnr.state.ak.us>, Anna Raff <anna.raff@dowjones.com>, Cliff Posey
<cliff@posey.org>, Paul Bloom <paul_bloom@m1.com>, Meghan Powell
<Meghan.Powell@asrcenergy.com>, Temple Davidson <temple_davidson@dnr.state.ak.us>, Walter
Featherly <WFeatherly@PattonBoggs.com>, Tricia Waggoner <twaggoner@nrginc.com>, Mike
Stockinger <Mike.Stockinger@anadarko.com>, , John Spain <jps@stateside.com>
This serves as a notification that the Alaska Oil and Gas Conservation has adopted regulation changes in
Title 20 of the Administrative Code, Chapter 25 dealing with Permit to Drill and Blowout Prevention
Equipment requirements. These adopted regulations can be found on our website at aogcc.alaska.gov. If
you have any questions, please feel free e-mail or call me at 907-793-1221. Jody Colombie, Special
Assistant to the Commission
Jody Colombie <iody colombie(a¿admin.state.ak.us>
Special Staff Assistant
Alaska Oil and Gas Conservation Commission
Department of Administration
20f2
12/28/200610:06 AM
#q
·
Office of the Attorney General
Oil, Gas & Mining Section
1031 W. 4th Avenue, Suite 200
Anchorage, AK 99501-1994
Phone: (907) 269-5255
Fax: (907) 279·8644
Fax Transmission
The information contained in this fax is confidential and/or privileged. This fax is intended to be
reviewed initially by only the individual named below. If the reader of this transmittal page is not the
intended recipient or a representative of the intended recipient, you are hereby notified that any review,
dissemination or copying of this fax or the information contained herein is prohibited. If you have
received this fax in error, please immediately notify the sender by telephone and return this fax to the
sender at the above address. Thank you.
To: Jn~
From: ~
Fax#:
21~ -1Yf~
Date:
/')-{ tJ ( 0 (.
,~
Subject: J'\l~ f\~
Message:
Pages:
, including
cover sheet
~0vLL-~~ ~~+k-
L\-. Gtevt~ ~.
.--'"
If you do not receive all the pages or have any problems with
this fax, lease call for assistance at 907) 269-5255.
I:\FORMS\FAX - CONFIDENTIAL.DOC.DOC
12/04/2006 11:52 FAX 9072798644
ATIORNEY GENERAL'S OFF
141001
*********************
*** TX REPORT ***
*********************
TRANSMISSION OK
TX/RX NO
RECIPIENT ADDRESS
DESTINATION ID
ST. TIME
TIME USE
PAGES SENT
RESULT
2917
2767542
12/04 11: 51
00'54
5
OK
Office of the Attorney General
Oil, Gas & Mining Section
1031 W. 4th Avenue, Suite 200
Anchorage. AK 99501-1994
Phone: (907) 269·5255
Fax: (907) 279·8644
Fax Transmission
The information contained in this fax is confidential and/or privileged. This fax is intended to be
reviewed initially by only the individual named·below. If the reader of this transmittal page is not the
intended recipient or a representative of the intended recipien~ you are hereby notified that any review,
dissemination or copying of this fax or the information contained herein is prohibited. If you have
received this fax in e"or, please immediately notify the sender by telephone and return this fax to the
sender at the above address. Thank you.
To: .Jn~
From: ~.
Subject: J)t~ j\1~
Message:
Fax#:
2-"1 ~ - 1s1-;;t
Date:
/,./ tJ (/) '"
~ . including
cover sheet
Pages:
~ IÀ.A..<- ~ ~ ~; +k-
Lt. Gtøv·~ ~.
Register ,
--
MISCELLANEOUS .DS
(B) when installed, repaired, or changed on an exploratory or
stratigraphic test well and at least once a week thereafter, BOPE, including kelly valves,
emergency valves, and choke manifolds, must be function pressure-tested to the required
working pressure specified in the approved Permit to Drill, using a non-compressible
fluid, except that an annular type preventer need not be tested to more than 50 percent of
its rated working pressure;
(C) if any BOP [SEALING RAM TYPE] equipment components have
[HAS] been used for well control or other equivalent purpose, or when routine use of
must be function pressure-tested, before the next wellbore entry, to the required working
pressure specified in the approved Permit to Drill, using a non-compressible fluid, except
that an annular type preventer need not be tested to more than 50 percent of its rated
working pressure;
(D) BOP ram and annular components except blind rams must be
function-tested weekly, and all BOP ram and annular components must be function-
tested after an action that disconnects the hydraulic system lines from the BOPE, except
that if the workstring is continuously in the well, function-testing of blind rams must be
performed as soon as possible after the workstring is pulled out of the well and the BHA
clears the BOP;
(E)
~cdf-
'i17F'
be used durin
A :;A CJr
, t2. 7/'2.00"
7
Register _,
--
MISCELLANEOUS .RDS
specified in the approved Permit to Drill, using a non-compressible fluid, except that an annular
type preventer need not be tested to more than 50 percent of its rated working pressure;
(5) BOP ram and annular components except blind rams must be function-tested
weekly, and all BOP ram and annular components must be function-tested after an action that
disconnects the hydraulic system lines from the BOPE, except that if the workstring is
continuously in the well, function-testing of bl' d rams must be performed as soon as possible
ßI-\A .(,
after the workstring is pulled out of the well ;-theE~clears the BOP;
1\
;.( cðï (6) for each BOPE test during drilling and completion operations, variable
"/ï..7fwo(. ~- ~ . . I_
. ---- . ;; ~ ev-tside dlo.W\C-C~
bore rams must be function ressure tested to the re uired ressure on the sma est D
~s\kd-¡~~4 .4
t· ~ r ~and larest D tubulars that ma be used durin that test c
'-<71 .1- "
1I/1.7/1.ooL -.
J rams need not be tested on BHAs and drill collars;
~~
JI /7..7/z.o0 ("
m BOPE test results must be recorded as part of the daily record required by 20
AAC 25.070(1), and must be provided to the commission, in a format approved by the
"Iv> '" ",\4 þ{ '" <'\d.-u- Ii VI -c.
commission, within five days after completing the test;
....,
~(7)] at least 24 hours notice of each BOPE function pressure test must be
provided to the commission so that a representative of the commission can witness the test.
iT' ,f l' /\'
\'-
Hi~tgr~(¥ff. 11/7/99, Register 152; am 10/24/2004, Register 172; am_/_/_, Register
~
Authority: AS 31.05.030
Yea. d pr
'<f-- 20 AAC 25.280(b) is amended to a@d-a R']U'1"Rl'RgU :
(b) The Application for Sundry Approvals must set out
Ii
Register _,
--
MISCELLANEOUS .RDS
(2) if any BOP [SEALING RAM TYPE] equipment components hav~HAS]
been used for well control or other equivalent purpose. or when routine use of the
equipment may have compromised its effectiveness, the components used [IT] must be
function pressure-tested before the next wellbore entry, using a non-compressible fluid, to the
required working pressure specified in an approved Application for Sundry Approvals under
20 AAC 25.280 or, ifthat application is not required, to the maximum potential surface pressure
to which that equipment may be subjected, except that an annular type preventer need not be
tested to more than 50 percent of its rated working pressure;
(3) non-sealing equipment must be function-tested weekly, after a repair or
change, and after an action that disconnects the hydraulic system lines from the BOPE, except
that ifthe workstring is continuously in the well, function-testing must be performed as soon as
possible after the workstring is pulled out of the well and the BHA clears the BOP;
r
0ICðfr
, 1"2.'7/ùM.
/0-- -
rams need not be tested on BHAs and drill collars;
a:...
~flter installing casing rams in the BOP stack. the ram bonnets must be
r~ tested to the required pressure before running casing;
~ BOPE test results must be recorded as part of the daily record required by 20
-
AAC 25.070(1). and must be provided to the commission. in a format approved by the
commission. within five days after completing the test;
ffi[(5)] at least 24 hours notice of each BOPE function pressure test must be
.}, , ¡ß.
provided so that a representative of the commission can witness the test;if'
02./
Register _,
--
MISCELLANEOUS .DS
(2) after each installation ofBOPE or other well control equipment, the
equipment must be pressure-tested, before wellbore entry, to the maximum potential wellhead
pressure to which it may be subjected, except that when testing against the annular type
preventer, pressure testing need not exceed 50 percent of the rated working pressure of the
annular type preventer;
(3) non-sealing equipment must be function-tested weekly, after a repair or
change, and after an action that disconnects the hydraulic system lines from the BOPE, except
that if the workstring is continuously in the well, function-testing must be performed as soon as
possible after the workstring is pulled out of the well and the BHA clears the BOP;
(4) after each well installation of the BOPE, the BOPE hydraulic connections to
the rams must be visually verified before wellbore entry.i~
~Ldr
'1/l7/~o, (5) for each HOPE test durin!! drillin!! and completion operations. variable
bore ra'::-must be function res~~sted to the re Ulred
~S!<tti.~I(;lfl'l.e.te.~
t and lar est OD_ tubulars that ma be used durin that test c
~Cdr ..(-
Jlj"17jw;I'.. rams need not be tested on HRAs and drill collars;
(6) BOPE test results must be recorded as part ofthe daily record required
d(d0
1'/27/200'
by 20 AAC 25.0700). and must be provided to the commission. in a format approved by
the commission. within five days after completin!! the test;
(7) at least 24 hours notice of each HOPE function pressure test must be
provided so that a representative of the commission can witness the test;
(8) the operator shall report to the commission within 24 hours any instance
rf.., .......bølJ Q( lìn(.
of BOPE use to prevent the flow of fluids from a well. .,,11.«("
....
:25
~8
12/18/2006 17:55
907465~1
LT GOV SEAN PAR~
PAGE 02
ORDER CERTIFYING THE CHANGES TO
REGUL \. TIONS OF ALASKA OIL AND GAS CONSERVATION
COMMISSION
The attached 26 pages )f regulations, dealing with Permit to Drill requirements and blowout
prevention equipment ur der 20 AAC 25 are hereby certified to be a correct copy of the regulation
changes that the Alask l Oil and Gas Conservation Commission adopted at its September 27,
2006 meeting, under tJ: e authority of AS 31.05.030 and 31.05.040 and after compliance with the
Administrative ProcedlU'e Act (AS 44.62), specifically including notíce under AS 44.62.190 and
44.62.200 and opportu llty for public corrunent under AS 44.62.210.
This action is not exp~~ ~ted to require an increased appropriation.
On the record, in consi ::lering public comments, the Alaska Oil and Gas Conservation
Commission paid spec lal attention to the cost to private persons of the regulatory action being
taken.
The regulation change; described in this order take effect on the 30th day after they have been
filed by the lieutenant :;ovemor, as provided in AS 44.62.180.
DATE:
Octobe; . 9. 2006
Anch Jrage
~t~
C y P. Foerster
Commissioner
FILING CERTIFICATION
I, Loren Leman, Lieut mant Governor for the State of Alaska~ certify that on
~~, 28 . . 2006 at II: r¡ ~., I filed the attached regulations according to the
provisions of AS 44.6 !.040 - 44.62.120. ~ -&. ~
.' Lie:utenant Governor
Ei:fective:
~ rJJ.u-.;;g , dð'O{'
..
Rcgister~
lKl4~
*1
.
.
MEMORANDUM
State of Alaska
Department of Law
To: John K. Norman, Chair Date: November 15,2006
Oil & Gas Conservation Commission
Dept. of Administration File No.: 993-07-0029
Tel. No.: 465-3600
4J-A-.lrw.-LJ;::~' ~
From: Deborah E. Behr
Chief Assistant Attorney General
and Regulations Attorney
Legislation and Regulations Section
Re: Alaska Oil and Gas Conservation
Commission Regulations Re:
Permit to Drill Requirements and
Blowout Prevention Equipment
(20 AAC 25)
Under AS 44.62.060, we have reviewed the Alaska Oil and Gas Conservation
Commission's adoption, amendment, and repeal of these regulations and approve the
changes for filing by the lieutenant governor. A duplicate original of this memorandum
is being furnished the lieutenant governor, along with the 26 pages of regulations and
the related documents.
You might wish to contact the lieutenant governor's office to confirm the filing
date and effective date of the attached regulation changes.
The July 26, 2006 public notice and the October 9, 2006 certification order both
state that this action is not expected to require an increased appropriation. Therefore, a
fiscal note under AS 44.62.195 is not required.
In accordance with AS 44.62.125(b)(6), some corrections have been made in the
regulations, as shown on the attached copy.
DEB:pvp
cc w/enc.:
Kevin Brooks, Regulations Contact
Dept. of Administration
Cammy Taylor, Assistant Attorney General
Anchorage
.
.
MEMORANDUM
State of Alaska
Department of Law
To: Hon. Loren Leman
Lt. Governor
Date: November 15, 2006
File No.: 993-07-0029
~¿'~
From: Deborah E. Behr
Chief Assistant Attorney General
and Regulations Attorney
Legislation and Regulations Section
Tel. No.: 465-3600
Re: Alaska Oil and Gas Conservation
Commission Regulations Re:
Permit to Drill Requirements and
Blowout Prevention Equipment
(20 AAC 25)
We have reviewed the attached regulations from the Alaska Oil and Gas Conservation
Commission (AOGCC). A duplicate of this memorandum is being furnished to Chair John K.
Norman, along with a copy ofthe regulations.
The Department of Law has reviewed the attached regulations against the statutory
standards of the Administrative Procedure Act. Based upon our review, we find no legal
problems. This memorandum and the attached duplicate memorandum dated November 15,
2006 constitute the written statement of approval under AS 44.62.060(b) and (c) that authorizes
your office to file the attached regulations.
The regulation changes were adopted by the AOGCC after the close of the public
comment period. The regulations concern permit to drill requirements and blowout prevention
equipment.
The certification order for the regulations states that this action is not expected to require
an increased appropriation. Therefore, a fiscal note under AS 44.62.195 is not required.
We have made technical corrections to conform the regulations with the drafting manual
under AS 44.62.060 and 44.62.125. The corrections are shown on the attached copy of the
regulations.
DEB:pvp
cc: John K. Norman, Chair
Oil & Gas Conservation Commission
Dept. of Administration
/~ .
Register _,
'0
MISCELLANEOUS lARDS
E:-- 20 AAC 25.005(c)(4)(A) is amended to read:
(A) the maximum downhole pressure that may be encountered, criteria
used to determine it, and maximum potential surface pressure based on a pressure
gradient to surface of 0.1 psi per foot of true vertical depth. unless the commission
approves a different pressure gradient that provides a more accurate means of
determinin the maximum otential surface
'1 t l' 1'. 1"
(Eff. 4/13/80, Register 74; am 4/2/86, Register 97; am 11/7/99, Register 152; am 6/4/2000,
Register 154; am 1/5/2006, Register 177; am _/ ~ _, Register ~
Authority: AS 31.05.030 AS 31.05.090
ç- 20 AAC 25.035(e)(1) is amended to read:
(1) in rotary drilling rig operations,
(A) for an operation with a maximum potential surface pressure of
3.000 psi or less [REQUIRING A BOP STACK LESS THAN API 5K], BOPE must
have at least three preventers, including
(i) one equipped with pipe rams that fit the size of drill pipe,
tubing, liner or casing being used, except that pipe rams need not be sized to
bottom-hole assemblies (BHAs) or drill collars;
(ii) one with blind rams, except that a subsea BOPE assembly
must have blind/shear rams in place of blind rams; and
(iii) one annular type; and
J
~. Register _,
t
MISCELLANEOUS 'ARDS
(B) for an operation, other than a casine: or liner operation. with a
maximum potential surface pressure of e:reater than 3.000 psiJREQUIRlNG A BOP
STACK EQUAL TO OR GREATER THAN API 5K], BOPE must have at least four
preventers, including
(i) two equipped with pipe rams that fit the size of the drill pipe
..¡
Q![,] tubing [, OR CASING] being used, except that pipe rams need not be sized
^
to BHAs and drill collars;
(ii) one with blind rams, except that a subsea BOPE assembly
must have blind/shear rams in place of blind rams; and
(iii) one annular type;
(C) for a casine: or liner operation with a maximum potential surface
pressure of e:reater than 3.000 psi, BOPE must have at least four preventers,
includine:
(n one equipped with pipe rams that fit the size of the drill
pipe or tobine: beine: used. except that pipe rams need not be sized to BHAs
and drill collars;
(in one equipped with pipe rams that fit the size of casine: or
liner bein2 used;
(Hi) one with blind rams. except that a subsea BOPE
assembly must have blind/she·ar rams in place of blind rams; and
(iv) one annular type;
<. 20 AAC 25.035(e)(2) is amended to read:
c2
~
Register _,
I
MISCELLANEOUS 'ARDS
(2) in coiled tubing unit operations, the well control equipment must include
(A) for an operation with a maximum potential surface pressure of
5.000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
(ii) a high pressure pack-off, stripper, or annular type preventer;
(iii) if pressure deployment of tools, tubing, liner, or casing is
planned, a riser or lubricator sized to the BHA and providing for pressure
integrity from the BOPE rams to the high pressure pack-off, stripper, or annular
type preventer; and
(iv) at least one preventer equipped with pipe rams that fit the size
of tubing, liner, or casing being used, except that pipe rams need not be sized to
BHAs and drill collars; and
(B) for an operation. other than a casin~ or liner operation. with a
maximum potential surface pressure of ~reater than 5.000 psi [REQUIRING A BOP
STACK GREATER THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
(ii) two high pressure pack-offs, strippers, or annular type
preventers;
(iii) if pressure deployment of tools, tubing, liner, or casing is
planned, a riser or lubricator sized to the BHA and providing for pressure
3
Register _,
to
MISCELLANEOUS 'ARDS
integrity from the BOPE rams to the high pressure pack-off, stripper, or annular
type preventer; and
(iv) at least two preventers equipped with pipe rams that fit the
size oftubing[, LINER, OR CASING] being used, except that pipe rams need not
be sized to BHAs and drill collars;
(C) for a casine or liner operation with a maximum potential surface
pressure of ereater than 5.000 psi.
(i) BOPE rams providine for pipe. slip. cuttine. and blindine
operations on the coiled tubine in service;
(m two hieh pressure pack-offs. strippers. or annular type
preventers;
(Hi) if pressure deplovment of tools. tubine. liner. or casine is
planned. a riser or lubricator sized to the BRA and providine for pressure
inteeritv from the BOPE rams to the hieh pressure pack-off. stripper. or
annular tvpe preventer;
(iv) at least one preventer equipped with pipe rams that fit the
size of the tubine beine used. except that pipe rams need not be sized to
BHAs and drill collars; and
(v) at least one preventer equipped with pipe rams that fit the
size of casine or liner beine used.
)
<E-- 20 AAC 25. 035(e)(4)(F) is amended to read:
'-/-
Register _,
I
MISCELLANEOUS 'ARDS
(F) a kill line and a choke line each connected to a flanged or hubbed
outlet on a drilling spool or on the BOP body with two full-opening valves on each
outlet, conforming to the following specifications:
(i) the outlets must be at least two inches in nominal diameter,
except that for rotary drilling rig operations, if the operation has a maximum
potential surface pressure of 2reater than 3.000 psi [REQUIRED BOP IS
RATED EQUAL TO OR GREATER THAN API 5K], the nominal diameter of
the choke outlets must be at least three inches;
(ii) each valve must be sized at least equal to the required size of
the outlet to which it is attached;
(iii) the outer valve on the choke side must be a remotely
controlled hydraulic valve;
(iv) the inner valve on both the choke and kill sides may not
normally be used for opening or closing on flowing fluid;
<E:--20 AAC 25. 035(e)(4)(H) is amended to read:
(H) a choke manifold equipped with
(i) two or more adjustable chokes, one of which must be hydraulic
and remotely controlled from near the driller's station if the operation has a
10,,1"'\
--
maximum potential surface pressure of 2reater than 3.000 psi [REQUIRES A
BOP STACK EQUAL TO OR GREATER THAN API 5K];
(ii) a line at least two inches in nominal diameter downstream of
each choke;
s-
Register _,
.
200
MISCELLANEOUS 'ARDS
(iii) immediately upstream of each choke, at least one full-opening
valve for an operation with a maximum potential surface pressure of 3.000 psi
or less [REQUIRING A BOP STACK LESS THAN API 5K], or at least two
full-opening valves for an operation with a maximum potential surface
pressure of I!reater than 3,000 psi [REQUIRING A BOP STACK EQUAL TO
OR GREATER THAN API 5K]; and
(iv) a bypass line, at least the diameter of the choke line, with at
least one full-opening valve for an operation with a maximum potential surface
pressure of 3,000 psi or less [REQUIRING A BOP STACK LESS THAN API
5K], or at least two full-opening valves for an operation with a maximum
potential surface pressure of I!reater than 3.000 ps\[REQUIRlNG A BOP
STACK EQUAL TO OR GREATER THAN API 5K];
~ 20 AAC 25.035(e)(10) is amended to read:
(10) the BOPE must be tested as follows:
(A) when installed, repaired, or changed on a development or service
well and at time intervals not to exceed each 14 days thereafter, BOPE, including kelly
valves, emergency valves, and choke manifolds, must be function pressure-tested to the
required working pressure specified in the approved Permit to Drill, using a non-
compressible fluid, except that an annular type preventer need not be tested to more than
50 percent of its rated working pressure; however, the commission will require that the
BOPE be function pressure-tested weekly, if the commission determines that a weekly
BOPE pressure test interval is indicated by a particular drilling rig's BOPE performance;
~
Register _,
t
MISCELLANEOUS 'ARDS
(B) when installed, repaired, or changed on an exploratory or
stratigraphic test well and at least once a week thereafter, BOPE, including kelly valves,
emergency valves, and choke manifolds, must be function pressure-tested to the required
working pressure specified in the approved Permit to Drill, using a non-compressible
fluid, except that an annular type preventer need not be tested to more than 50 percent of
its rated working pressure;
(C) if any BOP [SEALING RAM TYPE] equipment components have
[HAS] been used for well control or other equivalent purpose. or when routine use of
must be function pressure-tested, before the next wellbore entry, to the required working
pressure specified in the approved Permit to Drill, using a non-compressible fluid, except
that an annular type preventer need not be tested to more than 50 percent of its rated
working pressure;
(D) BOP ram and annular components except blind rams must be
function-tested weekly, and all BOP ram and annular components must be function-
tested after an action that disconnects the hydraulic system lines from the BOPE, except
that if the workstring is continuously in the well, function-testing of blind rams must be
performed as soon as possible after the workstring is pulled out of the well and the BHA
clears the BOP;
(E) for each BOPE test durinf! drillinf! and completion operations.
variable bore rams must be function pressure tested to the required pressure on the
smallest outside diameter (OD) and larf!est OD tubulars that may be used durinf!
7
Register _,
.
200
MISCELLANEOUS 'ARDS
that test cycle. except that variable bore rams need not be tested on BRAs and drill
collars;
(F) after installin£! casin£! rams in the BOP stack. the ram bonnets
must be tested to the required pressure before runnin£! casin£!ø
,
í!!l. BOPE test results must be recorded as part of the daily record
required by 20 AAC 25.070(1), and must be provided to the commission. in a format
approved bv the commission. within five days after completin£! the test;
(H) [(F)] at least 24 hours notice of each BOPE function pressure test
must be provided to the commission so that a commission representative can witness the
test;
l' f IÎ' Iì'
(Hfstory;ÍEff. 4/13/80, Register 74; am 2/22/81, Règister 77; am 4/2/86, Register 97; am 11/7/99,
Register 152; am 10/24/2004, Register 172; am _I _I _, Register ~
Authority: AS 31.05.030
<: 20 AAC 25.036(c)(1) is amended to read:
(1) in rotary drilling rig operations,
(A) for an operation with a maximum potential surface pressure of
5.000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS THAN API 5K],
BOPE must have at least three preventers, including
(i) one equipped with pipe rams that fit the size of drill pipe,
tubing, liner, or casing being used, except that pipe rams need not be sized to
bottom-hole assemblies (BHAs) and drill collars;
<1
Register _,
.
200
MISCELLANEOUS !ARDS
(ii) one with blind rams, except that a subsea BOPE assembly
must have blind/shear rams in place of blind rams; and
AroJD
(iii) one annular type; ~ J
(B) for an operation other than a casinl! or liner operation, with a
maximum potential surface pressure of I!reater than 5,000 psi [REQUIRING A BOP
STACK GREATER THAN API 5K], BOPE must have at least four preventers,
including
(i) two equipped with pipe rams that fit the size ofthe drill pipe
o~,] tubing[, OR CASING] being used, except that pipe rams need not be sized
^
to BHAs and drill collars;
(ii) one with blind rams, except that a subsea BOPE assembly must
have blind/shear rams in place of blind rams; and
(iii) one annular type; ~ Y' Ò,
(C) for a casinl! or liner operation with a maximum potential surface
pressure of I!reater than 5,000 psi, BOPE must have at least four preventers,
includinl!
(n one equipped with pipe rams that fit the size of the drill pipe
or tubinl! beinl! used, except that pipe rams need not be sized to BHAs and
drill collars;
(m one equipped with pipe rams that fit the size of casinl! or
liner beinl! used;
(iii) one with blind rams, except that a subsea BOPE assembly
must have blind/shear rams in place of blind rams; and
9
Register _,
.
200
MISCELLANEOUS lARDS
(iv) one annular type;
~o AAC 25.036(c)(2) is amended to read:
(2) in coiled tubing unit operations, the well control equipment must include
(A) for an operation with a maximum potential surface pressure of
5,000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
(ii) a high pressure pack-off, stripper, or annular type preventer;
(iii) if pressure deployment of tools, tubing, liner, or casing is
planned, a riser or lubricator sized to the BHA and providing for pressure
integrity from the BOPE rams to the high pressure pack-off, stripper, or annular
type preventer; and
(iv) at least one preventer equipped with pipe rams that fit the
size of the tubing, liner, or casing being used, except that pipe rams need not be
MP
sized to BHAs and drill collars;~.J
(B) for an operation, other than a casill!! or liner operation with a
maximum potential surface pressure of greater than 5,000 psi [REQUIRING A BOP
STACK GREATER THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
(ii) two high pressure pack-offs, strippers, or annular type
preventers;
/0
Register ,
.
200
MISCELLANEOUS 'ARDS
(iii) if pressure deployment of tools, tubing, liner, or casing is
planned, a riser or lubricator sized to the BHA and providing for pressure
integrity from the BOPE rams to the high pressure pack-off, stripper, or annular
type preventer; and
(iv) at least two preventers equipped with pipe rams that fit the size
of the tubing[, LINER, OR CASING] being used, except that pipe rams need not
,..
be sized to BHAs and drill collars;QJ'\ d
-
(C) for a casine: or liner operation with a maximum potential surface pressure
of e:reater than 5.000 psi.
(i) BOPE rams urovidine: for pipe. slip. cuttine:. and blindine:
operations on the coiled tubine: in service:
(ii) two hie:h pressure pack-offs. strippers. or annular type
preventers:
(iii) if pressure deployment of tools. robine:. liner. or casine: is
planned. a riser or lubricator sized to the BHA and providine: for pressure
intee:ritv from the BOPE rams to the hie:h pressure pack-off. stripper. or
annular type preventer:
(iv) at least one preventer equipped with pipe rams that fit
the size of the tubine: beine: used. except that pipe rams need not be sized to
BHAs and drill collars: and
(v) at least one preventer equipped with pipe rams that fit the
size of casine: or liner beine: used:
) I
Register _,
I
MISCELLANEOUS .ARDS
<:::f-- 20 AAC 25.036(c)(4)(H) is amended to read:
(H) for conventional open loop fluid process drilling operations, a choke
manifold equipped with
(i) two or more adjustable chokes, one of which must be hydraulic
and remotely controlled from near the driller's or operator's station if the
operation has a maximum potential surface pressure of e:reater than 3.000 psi
[REQUIRES A BOP STACK EQUAL TO OR GREATER THAN API 5K];
(ii) a line at least two inches in nominal diameter downstream of
each choke;
(iii) immediately upstream of each choke, at least one full-opening
valve for an operation with a maximum potential surface pressure of 5.000 psi
or less, [REQUIRING A BOP STACK EQUAL TO OR LESS THAN API 5K],
\(
or at least two full-opening valves for an operation with a maximum potential
surface pressure of e:reater than 5.000 psi [REQUIRING A BOP STACK
I(
GREATER THAN API 5K]; and
(iv) a bypass line at least two inches in nominal diameter with at
least one full-opening valve immediately upstream of each choke for an operation
with a maximum potential surface pressure of 5.000 psi or less [REQUIRING
A BOP STACK EQUAL TO OR LESS THAN API 5K], or with at least two full-
opening valves immediately upstream of each choke for an operation with a
maximum potential surface pressure of e:reater than 5.000 psi~REQUIRING
A BOP STACK GREATER THAN API 5K];
12
Register _,
.
200
MISCELLANEOUS ARDS
~ 20 AAC 25.036(d) is amended to read:
(d) A BOPE assembly must be tested as follows:
(1) when installed, repaired, or changed on a development or service well and at
time intervals not to exceed each 14 days thereafter, BOPE, including kelly valves, emergency
valves, and choke manifolds, must be function pressure-tested to the required working pressure
specified in the approved Permit to Drill, using a non-compressible fluid, except that an annular
type preventer need not be tested to more than 50 percent of its rated working pressure; however,
the commission will require that the BOPE be function pressure-tested weekly, if the
commission determines that a weekly BOPE pressure test interval is indicated by a particular
drilling rig's BOPE performance;
(2) when installed, repaired, or changed on an exploratory or stratigraphic test
well and at least once a week thereafter, BOPE, including kelly valves, emergency valves, and
choke manifolds, must be function pressure-tested to the required working pressure specified in
the approved Permit to Drill, using a non-compressible fluid, except that an annular type
preventer need not be tested to more than 50 percent of its rated working pressure;
(3) other well control equipment must be pressure-tested to the maximum
potential wellhead pressure after each installation of the well control equipment and before
wellbore entry, except that an annular type preventer need not be tested to more than 50 percent
of its rated working pressure;
(4) if any BOP [SEALING RAM TYPE] equipment components hav~AS]
been used for well control or other equivalent purpose, or when routine use of the
equipment may have compromised its effectiveness, the components used [IT] must be
function pressure-tested, before the next wellbore entry, to the required working pressure
/)
Register _,
.
200
.
MISCELLANEOUS BOARDS
specified in the approved Permit to Drill, using a non-compressible fluid, except that an annular
type preventer need not be tested to more than 50 percent of its rated working pressure;
(5) BOP ram and annular components except blind rams must be function-tested
weekly, and all BOP ram and annular components must be function-tested after an action that
disconnects the hydraulic system lines from the BOPE, except that if the workstring is
continuously in the well, function-testing of blind rams must be performed as soon as possible
ßHA
after the workstring is pulled out of the well and the ~ clears the BOP;
(6) for each BOPE test durinl! drillinl! and completion operations. variable
ov-+ .s i cleo d i C:l1IYH~...1t: v-
bore rams must be function ressure tested to the re uired ressure on the sma est D
and larl!est OD tubulars that may be used durinl! that test cycle. except that variable bore
rams need not be tested on BHAs and drill collars~
ill BOPE test results must be recorded as part of the daily record required by 20
AAC 25.070(1). and must be provided to the commission. in a format approved by the
'")u> 10 ,p\4 ." ... M'CK Ii VI 'Co
commission. within five days after completinl! the test~
....,
~(7)] at least 24 hours notice of each BOPE function pressure test must be
provided to the commission so that a representative of the commission can witness the test.
0' ,t t /\'
\-
HijìtQf)9.~ff. 11/7/99, Register 152; am 10/24/2004, Register 172; am~_/_, Register
~
Authority: AS 31.05.030
Ye OL d ~
'f-- 20 AAC 25.280(b) is amended to add::a :SBW pfJl'Rg :
(b) The Application for Sundry Approvals must set out
11
Register _,
.
200
MISCELLANEOUS BIRDS
(1) the current condition of the well;
(2) a copy of the proposed program for well work;
(3) unless already on file with the commission, a diagram and description ofthe
well control equipment to be used, including if applicable a list of the blowout prevention
equipment (BOPE) with specifications;
(4) the maximum downhole pressure that may be encountered, criteria used
to determine it, an~ximum potential surface pressure based on a pressure eradient to
1\
surface of 0.1 psi per foot of true vertical dept~unless the commission approves a different
pressure eradient that provides a more accurate means of determinine the maximum
potential surface pressure, such as usine a stabilized shut-in tubine pressure.
.J
æ a description of any wellbore fluid to be used for primary well control; and
.Γ [(5)] the current bottom-hole pressure, or, if data setting out the actual
pressure are not available, an estimate of the current bottom-hole pressure.
l' 1" l' l' ~
~&'£f.~4/2/86, Register 97; am 11/7/99, Register 152; am~~_, Register )
Authority: AS 31.05.030
~ 20 AAC 25.285(c)(2) is amended to read:
(2) in rotary drilling rig operations,
(A) for an operation with a maximum potential surface pressure of
3,000 psi or less [REQUIRING A BOP STACK LESS THAT API 5K], at least three
preventers, including
}5
Register _,
e
200
MISCELLANEOUS !tRDS
(i) one equipped with pipe rams that fit the size of drill pipe,
tubing, liner or casing being used, except that pipe rams need not be sized to
bottom-hole assemblies (BHAs) and drill collars;
(ii) one with blind rams, except that a subsea BOPE assembly
must have blind/shear rams in place of blind rams; and
(iii) one annular type; ~~
(B) for an operation. other than a casine; or liner operation. with a
maximum
STACK EQUAL TO OR GREATER THAN API 5K], at least four preventers, including
(i) two equipped with pipe rams that fit the size of the drill pipe
o~,] tubing[, OR CASING] being used, except that pipe rams need not be sized
/'
to BHAs and drill collars;
(ii) one with blind rams, except that a subsea BOPE assembly
must have blind/shear rams in place of blind rams; and
(iii) one annular type; tÎ.Y'I '^
-
(C) for a casine; or liner operation. with a maximum potential
surface pressure of e;reater than 3.000 psi. at least four preventers. includine;
(i) one equipped with pipe rams that fit the size of the drill
pipe or tubine; beine; used. except that pipe rams need not be sized to BHAs
and drill collars;
(ii) one equipped with pipe rams that fit the size of casine; or
liner beine; used;
/(:;
Register _,
e
200
.
MISCELLANEOUS BOARDS
(iii) one with blind rams. except that a subsea BOPE assembly
must have blind/shear rams in place of blind rams; and
(iv) one annular type;
~20 AAC 25.285(c)(3) is amended to read:
(3) in coiled tubing unit operations,
(A) for an operation with a maximum potential surface pressure of
5.000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
(ii) a high pressure pack-off, stripper, or annular type preventer;
(iii) if pressure deployment of tools is planned, a riser or lubricator
sized to the BHA and providing for pressure integrity from the BOPE rams to the
high pressure pack-off, stripper, or annular type preventer; and
(iv) at least one preventer equipped with pipe rams that fit the size
of the tubing, liner, or casing being used, except that pipe rams need not be sized
ANi>
to BHAs and drill collars;§rl J
(B) for an operation. other than a casing or liner operation. with a
maximum potential surface pressure of greater than 5.000 psi [REQUIRING A BOP
STACK GREATER THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
1/
Register _,
.
200
MISCELLANEOUS ARDS
(ii) two high pressure pack-offs, strippers, or annular type
preventers;
(iii) if pressure deployment of tools is planned, a riser or
no bolJ o(vl\ð.(...VIi'l-!
lubricator sized to the BHA ~Jt providing for pressure integrity from the BOPE
rams to the high pressure pack-off, stripper, or annular type preventer; and
(iv) at least two preventers equipped with pipe rams that fit the
./
size of the tubing[, LINER, OR CASING] being used, except that pipe rams need
^
not be sized to BRAs and drill collars; ct.Y' cf
(C) for a casin2 or liner operation with a maximum potential surface
pressure of 2reater than 5.000 psi.
(0 BOPE rams providin2 for pipe. slip. cuttin2. and blindin2
operations on the coiled tubin2 in service;
(ii) two hi2h pressure pack-offs. strippers. or annular type
preventers;
(iii) if pressure deployment of tools is planned. a riser or
lubricator sized to the BHA and providin2 for pressure inte2rity from the
BOPE rams to the hi2h pressure pack-off. stripper. or annular type
preventer;
(iv) at least one preventer equipped with pipe rams that fit
the size of the tubin2 bein2 used. except that pipe rams need not be sized to
BHAs and drill collars; and
(v) at least one preventer equipped with pipe rams that fit the
size of casin2 or liner bein2 used;
)$>
Register _,
.
200
MISCELLANEOUS ~RDS
<:;-- 20 AAC 25.285(c)(9)(A) is amended to read:
(9) a kill line and a choke line each connected to a flanged or hubbed outlet on a
drilling spool or on the BOP body with two full-opening valves on each outlet, conforming to the
following specifications:
(A) the outlets must be at least two inches in nominal diameter, except
that for rotary drilling rig operations, if the operation has a maximum potential surface
pressure of e;reater than 3,000 psi~(REQUIRED BOP IS RATED EQUAL TO OR
GREATER THAN API 5K], the nominal diameter of the choke outlets must be at least
three inches;
(B) each valve must be sized at least equal to the required size of the
outlet to which it is attached;
(C) the outer valve on the choke side must be a remotely controlled
hydraulic valve;
(D) the inner valve on both the choke and kill sides may not normally be
used for opening or closing on flowing fluid; and
~20 AAC 25.285(c)(10) is amended to read:
(10) a choke manifold equipped with
(A) two or more adjustable chokes, one of which must be hydraulic and
remotely controlled from near the driller's station if the operation has a maximum
potential surface pressure of e;reater than 3,000 psi fEQUIRES A BOP STACK
EQUAL TO OR GREATER THAN API 5K];
I~
Register _,
e
200
MISCELLANEOUS ARDS
(B) a line at least two inches in nominal diameter downstream of each
choke;
(C) immediately upstream of each choke, at least one full-opening valve
for an operation with a maximum potential surface pressure of 3.000 psi or less
[REQUIRING A BOP STACK LESS THAN API 5K], or at least two full-opening
valves for an operation with a maximum potential surface pressure of e;reater than
3.000 psi~REQUIRING A BOP STACK EQUAL TO OR GREATER THAN API 5K];
and
(D) a bypass line, at least two inches in nominal diameter, with at least
one full-opening valve for an operation with a maximum potential surface pressure of
3.000 psi or lest[REQUlRlNG A BOP STACK LESS THAN API 5K], or at least two
full-opening valves for an operation with a maximum potential surface pressure of
e;reater than 3.000 ps~REQUIRING A BOP STACK EQUAL TO OR GREATER
THAN API 5K].
~ 20 AAC 25.285(f) is amended to read:
~ (f) The BOPE must be tested as follows:
(1) when installed, repaired, or changed, and at least once a week thereafter,
BOPE, including emergency valves and choke manifolds, must be function pressure-tested, using
a non-compressible fluid, to the required working pressure specified in an approved Application
for Sundry Approvals under 20 AAC 25.280 or, if that application is not required, to the
maximum potential surface pressure to which the BOPE may be subjected, except that an
annular type preventer need not be tested to more than 50 percent of its rated working pressure;
~o
Register _'
.
200
MISCELLANEOUS ARDS
(2) if any BOP [SEALING RAM TYPE] equipment components hav\:HAS]
been used for well control or other equivalent purpose. or when routine use of the
equipment may have compromised its effectiveness, the components used [IT] must be
function pressure-tested before the next wellbore entry, using a non-compressible fluid, to the
required working pressure specified in an approved Application for Sundry Approvals under
20 AAC 25.280 or, if that application is not required, to the maximum potential surface pressure
to which that equipment may be subjected, except that an annular type preventer need not be
tested to more than 50 percent of its rated working pressure;
(3) non-sealing equipment must be function-tested weekly, after a repair or
change, and after an action that disconnects the hydraulic system lines ftom the BOPE, except
that if the workstring is continuously in the well, function-testing must be performed as soon as
possible after the workstring is pulled out of the well and the BHA clears the BOP;
and lareest OD tubulars that may be used durine that test cycle. except that variable bore
rams need not be tested on BHAs and drill collars:
~
mflter installine casine rams in the BOP stack. the ram bonnets must be
l~ tested to the required pressure before runnine casine;
.Œl. BOPE test results must be recorded as part of the daily record required by 20
-
AAC 25.070(1). and must be provided to the commission. in a format approved by the
commission. within five days after completine the test:
ffi[(5)] at least 24 hours notice of each BOPE function pressure test must be
~)o ~ LÌ>
provided so that a representative of the commission can witness the test;~
02./
Register _,
.
200
MISCELLANEOUS ARDS
Œl the operator shall report to the commission within 24 hours any instance
---
J. ^" 10.1 ð oc.¡"¿'(.o(lirl(.
of BOPE use to prevent the flow of fluids from a well.
N
~t f /'
~(Eff. 4/2/86, Register 97; am 11/7/99, Register 152; am_/_/_, Register ~
Authority: AS 31.05.030
~ 20 AAC 25.286(d)(2) is amended to read:
(2) in rotary drilling rig operations,
(A) for an operation with a maximum potential surface pressure of
5,000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS THAN API 5K],
at least three preventers, including
(i) one equipped with pipe rams that fit the size of drill pipe,
tubing, liner or casing being used, except that pipe rams need not be sized to
bottom-hole assemblies (BHAs) and drill collars;
(ii) one with blind rams, except that a subsea BOPE assembly
must have blind/shear rams in place of blind rams; and
(iii) one annular type; and
(B) for an operation. other than a casin~ or liner operation. with a
maximum potential surface pressure of ~reater than 5,000 psi [REQUIRING A BOP
STACK GREATER THAN API 5K], at least four preventers, including
(i) two equipped with pipe rams that fit the size of the drill pipe
or[,] tubing[, OR CASING] being used, except that pipe rams need not be sized
to BHAs and drill collars;
),:2.
Register _,
.
200
MISCELLANEOUS .ARDS
(ii) one with blind rams, except that a subsea BOPE assembly
must have blind/shear rams in place of blind rams; and
(iii) one annular type;
(C) for a casine or liner operation with a maximum potential surface
pressure of ereater than 5,000 psi, at least four preventers, includine
(i) one equipped with pipe rams that fit the size of the drill
pipe or tubine beine used, except that pipe rams need not be sized to BHAs
and drill collars;
(ii) one equipped with pipe rams that fit the size of casine or
liner beine used;
(iii) one with blind rams, except that a subsea BOPE
assembly must have blind/shear rams in place of blind rams; and
(iv) one annular type;
<:-- 20 AAC 25.286(d)(3) is amended to read:
(3) in coiled tubing unit operations,
(A) for an operation with a maximum potential surface pressure of
5,000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
(ii) a high pressure pack-off, stripper, or annular type preventer;
and
,)3
Register _,
.
200
MISCELLANEOUS ARDS
(iii) if pressure deployment of tools is planned, a riser or lubricator
sized to the BHA and providing for pressure integrity from the BOPE rams to the
high pressure pack-off, stripper, or annular type preventer; and
(B) for an operation with a maximum potential surface pressure of
greater than 5.000 psi [REQUIRING A BOP STACK GREATER THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
(ii) two high pressure pack-offs, strippers, or annular type
preventers; and
(iii) if pressure deployment of tools is planned, a riser or lubricator
sized to the BHA and providing for pressure integrity from the BOPE rams to the
high pressure pack-off, stripper, or annular type preventer;
< 20 AAC 25 .286( e) is amended to read:
(e) The operator shall test the BOPE assembly as follows:
(1) at least once a week, and after each [USE,] repair, [OR] change, or use for
well control or other equivalent purpose. or when routine use of the equipment may have
~
compromised its effectiveness. BOP!ÉfeqUipmentrIPE AND BLIND RAMS] must be
function pressure-tested, using a non-compressible fluid, to the required working pressure
specified in an approved Application for Sundry Approvals under 20 AAC 25.280 or, if that
application is not required, to the maximum potential surface pressure to which they may be
subjected, except that the annular type preventer need not be tested to more than 50 percent of its
rated working pressure;
J.+
Register _,
.
200
.
MISCELLANEOUS BOARDS
(2) after each installation of BOPE or other well control equipment, the
equipment must be pressure-tested, before wellbore entry, to the maximum potential wellhead
pressure to which it may be subjected, except that when testing against the annular type
preventer, pressure testing need not exceed 50 percent of the rated working pressure of the
annular type preventer;
(3) non-sealing equipment must be function-tested weekly, after a repair or
change, and after an action that disconnects the hydraulic system lines from the BOPE, except
that if the workstring is continuously in the well, function-testing must be perfonned as soon as
possible after the workstring is pulled out of the well and the BHA clears the BOP;
(4) after each well installation of the BOPE, the BOPE hydraulic connections to
the rams must be visually verified before wellbore entry.iif
(5) for each BOPE test durin!! drillin!! and completion operations. variable
bore rams must be function pressure tested to the required pressure on the smallest OD
and lar!!est OD tubulars that may be used durin!! that test cycle. except that variable bore
rams need not be tested on BHAs and drill collars:
(6) BOPE test results must be recorded as part of the daily record required
by 20 AAC 25.0700). and must be provided to the commission. in a format approved by
the commission. within five days after completin!! the test;
(7) at least 24 hours notice of each BOPE function pressure test must be
provided so that a representative of the commission can witness the test:
(8) the operator shall report to the commission within 24 hours any instance
rf., ~b.,¡J qf "'nC-
of BOPE use to prevent the flow of fluids from a well. .,./('"
...
:25
. Register ,
.
200
MISCELLANEOUS ARDS
~ff. 11/7/99, Register 152; am~_/_, Register-.--J
Authority: AS 31.05.030
~(p
4t./P
.
.
STATE OF ALASKA
)
) ss.
)
THIRD JUDICIAL DISTRICT
AFFIDAVIT OF NOTICE OF PROPOSED ADOPTION OF REGULATIONS
AND FURNISHING OF ADDITIONAL INFORMATION
I, Jody J. Colombie, Special Staff Assistant, of Alaska Oil and Gas Conservation Commission, being
sworn, state the following:
As required by AS 44.62.190, notice of the proposed adoption of changes to 20 AAC 25, Permit to Drill
Requirements and Blowout Prevention Equipment Requirements has been given by being
(I) published in a newspaper or trade publication;
(2) furnished to interested persons;
(3) furnished to appropriate state officials;
(4) furnished to the Department of Law, along with a copy of the proposed regulations;
(5) electronically transmitted to incumbent State of Alaska legislators;
(6) furnished to the Legislative Affairs Agency, Legislative Library;
(7) posted on the Alaska Online Public Notice System as required by AS 44.62.175(a)(1) and (b)
and 44.62.l90(a)(l);
(8) furnished electronically, along with a copy of the proposed regulations, to the
Legislative Affairs Agency, the chair of the House and Senate Resources Committee, House
Special Committee on Oil and Gas, and the Administrative Regulation Review Committee,
and the legislative council.
As required by AS 44.62.l90( d), additional regulations notice information regarding the proposed
adoption of the regulation changes described above has been furnished to interested persons and those in
(5) and (6) of the list above. The additional regulations notice information also has been posted on the
Alaska Online Public Notice System.
DATE: \ \, G 0 U
Anchorage, Alaska
~r~~C~~N'~
Jo J. olom~ J
Special Staff Assistant
SUBSCRIBED AND SWORt'\[ TO before me this ~ day of \ìo'leVYìß~ ( , d-.DOIo.
/-~~~
/ /Notary Publ1c.-ir{and for the
'.,.../
State of Alaska /
My commission expires: // ) / I /6 b .
, ,
*5
.
.
MEMORANDUM
STATE OF ALASKA
ALASKA OIL AND GAS CONSERV A TION COMMISSION
TO:
Regulations Attorney
Legislation/Regulation Section
Department of Law
DA TE: October 9, 2006
FROM:
a¡¡¡ ¡/~~
Cathy P ~oerster
Regulations Contact
Department of Administration
SUBJECT: Request for Legal Review
of Regulations Project on
dealing with the method of
determining a well's
maximum potential
surface pressure and
blowout prevention
equipment
993-07 -0029
20 AAC 25.005 - .286
Weare requesting legal review and approval of the attached final regulations on changes
to the method of detennining a well's maximum potential surface pressure and blowout
prevention equipment, which were adopted by Alaska Oil and Gas Conservation
Commission.
Enclosed are the following documents:
I. the original and one copy of the final regulations for the Department of Law's
use;
2. the original of the signed and dated certification order;
3. the original of the public notice;
4. the original of the additional regulations notice information form distributed with
the notice;
). the original of the publishers' affidavit of publication;
6. the original of the affidavit of notice;
7. affidavit of oral hearing
8. affidavit of commission action;
9. excerpt from unapproved minutes from the September 27,2006 meeting;
We have worked with Assistant Attorney General Cammy Taylor on this project.
Upon completion of your review, pleas forward the regulations to the lieutenant governor
for filing.
Register _,
.0_
MISCELLANEOU.ARDS
\/ ~_ _~ i _ ~ a _
20 AAC 25.005(c)(4)(A) is amended to read:
(A) the maximum downhole pressure that may be encountered, criteria
used to determine it, and maximum potential surface pressure based on a pressure
gradient to surface of 0.1 psi per foot of true vertical depth, unless the commission
approves a different pressure gradient that provides a more accurate means of
determining the maximum potential surface pressure [METHANE GRADIENT];
(Eff. 4/13/80, Register 74; am 4/2/86, Register 97; am 11/7/99, Register 152; am 6/4/2000,
Register 154; am 1/5/2006, Register 177; am _I_I _, Register~
Authority: AS 31.05.030 AS 31.05.090
20 AAC 25.035(e)(1) is amended to read:
(1) in rotary drilling rig operations,
(A) for an operation with a maximum potential surface pressure of
3,000 psi or less [REQUIRING A BOP STACK LESS THAN API 5K], BOPE must
have at least three preventers, including
(i) one equipped with pipe rams that fit the size of drill pipe,
tubing, liner or casing being used, except that pipe rams need not be sized to
bottom-hole assemblies (BHAs) or drill collars;
(ii) one with blind rams, except that a subsea BOPE assembly
must have blindlshear rams in place of blind rams; and
(iii) one annular type; and
/
Register _,
.0_
MISCELLANEOU.ARDS
(B) for an operation, other than a casine: or liner operation, with a
maximum potential surface pressure of e:reater than 3,000 psi [REQUIRING A BOP
STACK EQUAL TO OR GREATER THAN API 5K], BOPE must have at least four
preventers, including
(i) two equipped with pipe rams that fit the size of the drill pipe
Q![,] tubing [, OR CASING] being used, except that pipe rams need not be sized
to BHAs and drill collars;
(ii) one with blind rams, except that a subsea BOPE assembly
must have blind/shear rams in place of blind rams; and
(iii) one annular type;
(C) for a casine: or liner operation with a maximum potential surface
pressure of e:reater than 3,000 psi, BOPE must have at least four preventers,
includine:
(n one equipped with pipe rams that fit the size of the drill
pipe or tubine: beine: used, except that pipe rams need not be sized to BRAs
and drill collars;
(in one equipped with pipe rams that fit the size of casine: or
liner beine: used;
(iin one with blind rams, except that a subsea DOPE
assembly must have blind/shear rams in place of blind rams; and
(iv) one annular type;
20 AAC 25.035(e)(2) is amended to read:
¿
Register _,
.0_
MISCELLANEOU.ARDS
(2) in coiled tubing unit operations, the well control equipment must include
(A) for an operation with a maximum potential surface pressure of
5,000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS THAN API 5KJ,
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
(ii) a high pressure pack-off, stripper, or annular type preventer;
(iii) if pressure deployment of tools, tubing, liner, or casing is
planned, a riser or lubricator sized to the BHA and providing for pressure
integrity from the BOPE rams to the high pressure pack-off, stripper, or annular
type preventer; and
(iv) at least one preventer equipped with pipe rams that fit the size
of tubing, liner, or casing being used, except that pipe rams need not be sized to
BHAs and drill collars; and
(B) for an operation, other than a casin2 or liner operation, with a
maximum potential surface pressure of 2reater than 5,000 psi [REQUIRING A BOP
STACK GREATER THAN API 5KJ,
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
(ii) two high pressure pack-offs, strippers, or annular type
preventers;
(iii) if pressure deployment of tools, tubing, liner, or casing is
planned, a riser or lubricator sized to the BHA and providing for pressure
3
Register _,
.0_
MISCELLANEOU.ARDS
integrity from the BOPE rams to the high pressure pack-off, stripper, or annular
type preventer; and
(iv) at least two pre venters equipped with pipe rams that fit the
size oftubing[, LINER, OR CASING] being used, except that pipe rams need not
be sized to BHAs and drill collars;
(C) for a casing or liner operation with a maximum potential surface
pressure of greater than 5,000 psi,
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
(in two high pressure pack-offs, strippers, or annular type
preventers;
(iii) if pressure deplovment of tools, tubing, liner, or casing is
planned, a riser or lubricator sized to the BRA and providing for pressure
integrity from the BOPE rams to the high pressure pack-off, stripper, or
annular type preventer;
(iv) at least one preventer equipped with pipe rams that fit the
size of the tubing bein2 used, except that pipe rams need not be sized to
BRAs and drill collars; and
(v) at least one preventer equipped with pipe rams that fit the
size of casing or liner being used.
20 AAC 25. 035(e)(4)(F) is amended to read:
Lj
Register _'
.0_
MISCELLANEOU.ARDS
(F) a kill line and a choke line each connected to a flanged or hubbed
outlet on a drilling spool or on the BOP body with two full-opening valves on each
outlet, conforming to the following specifications:
(i) the outlets must be at least two inches in nominal diameter,
except that for rotary drilling rig operations, if the operation bas a maximum
potential surface pressure of g:reater than 3,000 psi [REQUIRED BOP IS
RATED EQUAL TO OR GREATER THAN API 5K], the nominal diameter of
the choke outlets must be at least three inches;
(ii) each valve must be sized at least equal to the required size of
the outlet to which it is attached;
(iii) the outer valve on the choke side must be a remotely
controlled hydraulic valve;
(iv) the inner valve on both the choke and kill sides may not
normally be used for opening or closing on flowing fluid;
20 AAC 25. 035(e)(4)(H) is amended to read:
(H) a choke manifold equipped with
(i) two or more adjustable chokes, one of which must be hydraulic
and remotely controlled from near the driller's station if the operation has a
maximum potential surface pressure of 2:reater than 3,000 psi [REQUIRES A
BOP STACK EQUAL TO OR GREATER THAN API 5K];
(ii) a line at least two inches in nominal diameter downstream of
each choke;
5"
Register _,
.0_
MISCELLANEOUaARDS
(iii) immediately upstream of each choke, at least one full-opening
valve for an operation with a maximum potential surface pressure of 3,000 psi
or less [REQUIRING A BOP STACK LESS THAN API 5K], or at least two
full-opening valves for an operation with a maximum potential surface
pressure of greater than 3,000 psi [REQUIRING A BOP STACK EQUAL TO
OR GREATER THAN API 5K]; and
(iv) a bypass line, at least the diameter of the choke line, with at
least one full-opening valve for an operation with a maximum potential surface
pressure of 3,000 psi or less [REQUIRING A BOP STACK LESS THAN API
5K], or at least two full-opening valves for an operation with a maximum
potential surface pressure of e:reater than 3,000 psi [REQUIRING A BOP
STACK EQUAL TO OR GREATER THAN API 5K];
20 AAC 25.035(e)(10) is amended to read:
(10) the BOPE must be tested as follows:
(A) when installed, repaired, or changed on a development or service
well and at time intervals not to exceed each 14 days thereafter, BOPE, including kelly
valves, emergency valves, and choke manifolds, must be function pressure-tested to the
required working pressure specified in the approved Permit to Drill, using a non-
compressible fluid, except that an annular type preventer need not be tested to more than
50 percent of its rated working pressure; however, the commission will require that the
BOPE be function pressure-tested weekly, if the commission determines that a weekly
BOPE pressure test interval is indicated by a particular drilling rig's BOPE performance;
~
Register _,
.0
MISCELLANEOU&ARDS
(B) when installed, repaired, or changed on an exploratory or
stratigraphic test well and at least once a week thereafter, BOPE, including kelly valves,
emergency valves, and choke manifolds, must be function pressure-tested to the required
working pressure specified in the approved Permit to Drill, using a non-compressible
fluid, except that an annular type pre venter need not be tested to more than 50 percent of
its rated working pressure;
(C) if any BOP [SEALING RAM TYPE] equipment components have
[HAS] been used for well control or other equivalent purpose, or when routine use of
the equipment may have compromised its effectiveness, the components used [IT]
must be function pressure-tested, before the next well bore entry, to the required working
pressure specified in the approved Permit to Drill, using a non-compressible fluid, except
that an annular type pre venter need not be tested to more than 50 percent of its rated
working pressure;
(D) BOP ram and annular components except blind rams must be
function-tested weekly, and all BOP ram and annular components must be function-
tested after an action that disconnects the hydraulic system lines from the BOPE, except
that if the workstring is continuously in the well, function-testing of blind rams must be
performed as soon as possible after the workstring is pulled out of the well and the BHA
clears the BOP;
(E) for each BOPE test durine; drilline; and completion operations,
variable bore rams must be function pressure tested to the required pressure on the
smallest outside diameter (OD) and lare;est OD tubulars that may be used durine;
7
Register _,
.0
MISCELLANEOUaARDS
that test cycle. except that variable bore rams need not be tested on BHAs and drill
collars;
(F) after installing casing rams in the BOP stack. the ram bonnets
must be tested to the required pressure before running casing.
íQì. BOPE test results must be recorded as part of the daily record
required by 20 AAC 25.070(1), and must be provided to the commission. in a format
approved by the commission. within five days after completing the test;
an [(F)] at least 24 hours notice of each BOPE function pressure test
must be provided to the commission so that a commission representative can witness the
test;
History: Eff. 4/13/80, Register 74; am 2/22/81, Register 77; am 4/2/86, Register 97; am 11/7/99,
Register 152; am 10/24/2004, Register 172; am_/_/_, Register ~
Authority: AS 31.05.030
20 AAC 25.036(c)(l) is amended to read:
(1) in rotary drilling rig operations,
(A) for an operation with a maximum potential surface pressure of
5.000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS THAN API 5K],
BOPE must have at least three preventers, including
(i) one equipped with pipe rams that fit the size of drill pipe,
tubing, liner, or casing being used, except that pipe rams need not be sized to
bottom-hole assemblies (BHAs) and drill collars;
g
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(ii) one with blind rams, except that a subsea BOPE assembly
must have blind/shear rams in place of blind rams; and
(iii) one annular type; and
(B) for an operation other than a casine or liner operation, with a
maximum potential surface pressure of ereater than 5,000 psi [REQUIRING A BOP
STACK GREATER THAN API 5K], BOPE must have at least four preventers,
including
(i) two equipped with pipe rams that fit the size of the drill pipe
Q!:[,] tubing[, OR CASING] being used, except that pipe rams need not be sized
to BHAs and drill collars;
(ii) one with blind rams, except that a subsea BOPE assembly must
have blind/shear rams in place of blind rams; and
(iii) one annular type;
(C) for a casine or liner operation with a maximum potential surface
pressure of ereater than 5,000 psi, HOPE must have at least four preventers,
includine
(i) one equipped with pipe rams that fit the size of the drill pipe
or tubine beine used, except that pipe rams need not be sized to HHAs and
drill collars;
(in one equipped with pipe rams that fit the size of casine or
liner beine used;
(iii) one with blind rams, except that a subsea HOPE assembly
must have blind/shear rams in place of blind rams; and
q
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(iv) one annular type;
20 AAC 25.036(c)(2) is amended to read:
(2) in coiled tubing unit operations, the well control equipment must include
(A) for an operation with a maximum potential surface pressure of
5,000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
(ii) a high pressure pack-off, stripper, or annular type preventer;
(iii) if pressure deployment of tools, tubing, liner, or casing is
planned, a riser or lubricator sized to the BHA and providing for pressure
integrity from the BOPE rams to the high pressure pack-off, stripper, or annular
type pre venter; and
(iv) at least one pre venter equipped with pipe rams that fit the
size of the tubing, liner, or casing being used, except that pipe rams need not be
sized to BHAs and drill collars; and
(B) for an operation, other than a casin2 or liner operation with a
maximum potential surface pressure of 2reater than 5,000 psi [REQUIRING A BOP
STACK GREATER THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
(ii) two high pressure pack-offs, strippers, or annular type
preventers;
/0
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MISCELLANEouAARDS
(iii) if pressure deployment of tools, tubing, liner, or casing is
planned, a riser or lubricator sized to the BHA and providing for pressure
integrity from the BOPE rams to the high pressure pack-off, stripper, or annular
type preventer; and
(iv) at least two preventers equipped with pipe rams that fit the size
of the tubing[, LINER, OR CASING] being used, except that pipe rams need not
be sized to BHAs and drill collars;
(C) for a casin2 or liner operation with a maximum potential surface pressure
of 2reater than 5.000 psi.
(n BOPE rams providine for pipe. slip. cuttine. and blindine
operations on the coiled tubin2 in service;
(in two hieh pressure pack-offs. strippers. or annular type
preventers;
(iii) if pressure deplovment of tools. tubin2. liner. or casin2 is
planned. a riser or lubricator sized to the BRA and providin2 for pressure
inteerity from the BOPE rams to the hieh pressure pack-off. stripper. or
annular type preventer;
(iv) at least one preventer equipped with pipe rams that fit
the size of the tubine beine used. except that pipe rams need not be sized to
BRAs and drill collars; and
(v) at least one preventer equipped with pipe rams that fit the
size of casine or liner bein2 used;
II
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20 AAC 25.036(c)(4)(H) is amended to read:
(H) for conventional open loop fluid process driIling operations, a choke
manifold equipped with
(i) two or more adjustable chokes, one of which must be hydraulic
and remotely controlled from near the driller's or operator's station if the
operation has a maximum potential surface pressure of greater than 3,000 psi
[REQUIRES A BOP STACK EQUAL TO OR GREATER THAN API 5K];
(ii) a line at least two inches in nominal diameter downstream of
each choke;
(iii) immediately upstream of each choke, at least one full-opening
valve for an operation with a maximum potential surface pressure of 5,000 psi
or less [REQUIRING A BOP STACK EQUAL TO OR LESS THAN API 5K],
or at least two full-opening valves for an operation with a maximum potential
surface pressure of greater than 5,000 psi [REQUIRING A BOP STACK
GREA TER THAN API 5K]; and
(iv) a bypass line at least two inches in nominal diameter with at
least one full-opening valve immediately upstream of each choke for an operation
with a maximum potential surface pressure of 5,000 psi or less [REQUIRING
A BOP STACK EQUAL TO OR LESS THAN API 5K], or with at least two full-
opening valves immediately upstream of each choke for an operation with a
maximum potential surface pressure of greater than 5,000 psi [REQUIRING
A BOP STACK GREATER THAN API 5K];
/z
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20 AAC 25.036(d) is amended to read:
(d) A BOPE assembly must be tested as follows:
(1) when installed, repaired, or changed on a development or service well and at
time intervals not to exceed each 14 days thereafter, BOPE, including kelly valves, emergency
valves, and choke manifolds, must be function pressure-tested to the required working pressure
specified in the approved Permit to Drill, using a non-compressible fluid, except that an annular
type preventer need not be tested to more than 50 percent of its rated working pressure; however,
the commission will require that the BOPE be function pressure-tested weekly, if the
commission determines that a weekly BOPE pressure test interval is indicated by a particular
drilling rig's BOPE performance;
(2) when installed, repaired, or changed on an exploratory or stratigraphic test
well and at least once a week thereafter, BOPE, including kelly valves, emergency valves, and
choke manifolds, must be function pressure-tested to the required working pressure specified in
the approved Permit to Drill, using a non-compressible fluid, except that an annular type
preventer need not be tested to more than 50 percent of its rated working pressure;
(3) other well control equipment must be pressure-tested to the maximum
potential wellhead pressure after each installation of the well control equipment and before
well bore entry, except that an annular type pre v enter need not be tested to more than 50 percent
of its rated working pressure;
(4) if any BOP [SEALING RAM TYPE] equipment components have rHAS]
been used for well control or other equivalent purpose, or when routine use of the
equipment may have compromised its effectiveness, the components used [IT] must be
function pressure-tested, before the next well bore entry, to the required working pressure
/3
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MISCELLANEOUaARDS
specified in the approved Permit to Drill, using a non-compressible t1uid, except that an annular
type pre venter need not be tested to more than 50 percent of its rated working pressure;
(5) BOP ram and annular components except blind rams must be function-tested
weekly, and all BOP ram and annular components must be function-tested after an action that
disconnects the hydraulic system lines from the BOPE, except that if the workstring is
continuously in the well, function-testing of blind rams must be performed as soon as possible
after the workstring is pulled out of the well and the BRA clears the BOP;
(6) for each BOPE test durin2: drillin2: and completion operations, variable
bore rams must be function pressure tested to the required pressure on the smallest OD
and lar2:est OD tubulars that may be used durin2: that test cycle, except that variable bore
rams need not be tested on BHAs and drill collars;
ill BOPE test results must be recorded as part of the daily record required by 20
AAC 25.070(1), and must be provided to the commission. in a format approved by the
commission, within five days after completin2: the test;
~[(7)] at least 24 hours notice of each BOPE function pressure test must be
provided to the commission so that a representative of the commission can witness the test.
History: Eff. 11/7/99, Register 152; am 10/24/2004, Register 172; am~_/_, Register
-----.J
Authority: AS 31.05.030
20 AAC 25 .280(b) is amended to add a new paragraph:
(b) The Application for Sundry Approvals must set out
14
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MISCELLANEOUSeARDS
(1) the current condition of the well;
(2) a copy of the proposed program for well work;
(3) unless already on file with the commission, a diagram and description of the
well control equipment to be used, including if applicable a list of the blowout prevention
equipment (BOPE) with specifications;
(4) the maximum downhole pressure that may be encountered, criteria used
to determine it, and maximum potential surface pressure based on a pressure 2:radient to
surface of 0.1 psi per foot of true vertical depth unless the commission approves a different
pressure 2:radient that provides a more accurate means of determinin2: the maximum
potential surface pressure, such as usin2: a stabilized shut-in tubin2: pressure.
æ a description of any wellbore fluid to be used for primary well control; and
œ [(5)] the current bottom-hole pressure, or, if data setting out the actual
pressure are not available, an estimate of the current bottom-hole pressure.
History: Eff. 4/2/86, Register 97; am 11/7/99, Register 152; am_/_/_, Register_)
Authority: AS 31.05.030
20 AAC 25.285(c)(2) is amended to read:
(2) in rotary drilling rig operations,
(A) for an operation with a maximum potential surface pressure of
3,000 psi or less [REQUIRING A BOP STACK LESS THAT API 5K], at least three
preventers, including
JS
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MISCELLANEOU.ARDS
(i) one equipped with pipe rams that fit the size of drill pipe,
tubing, liner or casing being used, except that pipe rams need not be sized to
bottom-hole assemblies (BHAs) and drill collars;
(ii) one with blind rams, except that a subsea BOPE assembly
must have blind/shear rams in place of blind rams; and
(iii) one annular type; and
(B) for an operation, other than a casin2 or liner operation, with a
maximum potential surface pressure of 2reater than 3,000 psi [REQUIRING A BOP
ST ACK EQUAL TO OR GREATER THAN API 5K], at least four preventers, including
(i) two equipped with pipe rams that fit the size of the drill pipe
Q!:[,] tubing[, OR CASING] being used, except that pipe rams need not be sized
to BRAs and drill collars;
(ii) one with blind rams, except that a subsea BOPE assembly
must have blind/shear rams in place of blind rams; and
(iii) one annular type;
(C) for a casin2 or liner operation, with a maximum potential
surface pressure of 2reater than 3,000 psi, at least four preventers, includin2
(i) one equipped with pipe rams that fit the size of the drill
pipe or tubin2 bein2 used, except that pipe rams need not be sized to BHAs
and drill collars;
(in one equipped with pipe rams that fit the size of casin2 or
liner bein2 used;
/0
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MISCELLANEOU.ARDS
(iii) one with blind rams, except that a subsea BOPE assembly
must have blind/shear rams in place of blind rams; and
(iv) one annular type;
20 AAC 25.285(c)(3) is amended to read:
(3) in coiled tubing unit operations,
(A) for an operation with a maximum potential surface pressure of
5,000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS THAN API 5KJ,
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
(ii) a high pressure pack-off, stripper, or annular type preventer;
(iii) if pressure deployment of tools is planned, a riser or lubricator
sized to the BHA and providing for pressure integrity from the BOPE rams to the
high pressure pack-off, stripper, or annular type preventer; and
(iv) at least one preventer equipped with pipe rams that fit the size
of the tubing, liner, or casing being used, except that pipe rams need not be sized
to BHAs and drill collars; and
(B) for an operation, other than a casin2 or liner operation, with a
maximum potential surface pressure of 2reater than 5,000 psi [REQUIRING A BOP
STACK GREATER THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
r7
I I
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MISCELLANEouAARDS
(ii) two high pressure pack-offs, strippers, or annular type
preventers;
(iii) if pressure deployment of tools is planned, a riser or
lubricator sized to the BHA and providing for pressure integrity from the BOPE
rams to the high pressure pack-off, stripper, or annular type preventer; and
(iv) at least two preventers equipped with pipe rams that fit the
size of the tubing[, LINER, OR CASING] being used, except that pipe rams need
not be sized to BHAs and drill collars;
(C) for a casing or liner operation with a maximum potential surface
pressure of greater than 5,000 psi,
(i) HOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
(in two high pressure pack-offs, strippers, or annular type
preventers;
(iin if pressure deployment of tools is planned, a riser or
lubricator sized to the HHA and providing for pressure integrity from the
HOPE rams to the high pressure pack-off, stripper, or annular type
preventer;
(iv) at least one preventer equipped with pipe rams that fit
the size of the tubing being used, except that pipe rams need not be sized to
HHAs and drill collars; and
(v) at least one preventer equipped with pipe rams that fit the
size of casing or liner being used;
iX
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20 AAC 25.285(c)(9)(A) is amended to read:
(9) a kill line and a choke line each connected to a flanged or hub bed outlet on a
drilling spool or on the BOP body with two full-opening valves on each outlet, conforming to the
following specifications:
(A) the outlets must be at least two inches in nominal diameter, except
that for rotary drilling rig operations, if the operation has a maximum potential surface
pressure of e;reater than 3.000 psi [REQUIRED BOP IS RATED EQUAL TO OR
GREATER THAN API 5K], the nominal diameter of the choke outlets must be at least
three inches;
(B) each valve must be sized at least equal to the required size of the
outlet to which it is attached;
(C) the outer valve on the choke side must be a remotely controlled
hydraulic valve;
(D) the inner valve on both the choke and kill sides may not normally be
used for opening or closing on flowing fluid; and
20 AAC 25.285(c)(lO) is amended to read:
(10) a choke manifold equipped with
(A) two or more adjustable chokes, one of which must be hydraulic and
remotely controlled from near the driller's station if the operation has a maximum
potential surface pressure of e;reater than 3.000 psi [REQUIRES A BOP STACK
EQUAL TO OR GREATER THAN API 5K];
/'1'
(.;
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(B) a line at least two inches in nominal diameter downstream of each
choke;
(C) immediately upstream of each choke, at least one tùll-opening valve
for an operation with a maximum potential surface pressure of 3,000 psi or less
[REQUIRING A BOP STACK LESS THAN API 5K], or at least two full-opening
valves for an operation with a maximum potential surface pressure of 2reater than
3,000 psi [REQUIRING A BOP STACK EQUAL TO OR GREATER THAN API 5K];
and
CD) a bypass line, at least two inches in nominal diameter, with at least
one full-opening valve for an operation with a maximum potential surface pressure of
3,000 psi or less [REQUIRING A BOP STACK LESS THAN API 5K], or at least two
full-opening valves for an operation with a maximum potential surface pressure of
2reater than 3,000 psi [REQUIRING A BOP STACK EQUAL TO OR GREATER
THAN API 5K].
20 AAC 25.285(f) is amended to read:
Cf) The BOPE must be tested as follows:
(1) when installed, repaired, or changed, and at least once a week thereafter,
BOPE, including emergency valves and choke manifolds, must be function pressure-tested, using
a non-compressible fluid, to the required working pressure specitìed in an approved Application
for Sundry Approvals under 20 AAC 25.280 or, if that application is not required, to the
maximum potential surface pressure to which the BOPE may be subjected, except that an
annular type preventer need not be tested to more than 50 percent of its rated working pressure:
~o
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(2) if any BOP [SEALING RAM TYPE] equipment components have rHAS]
been used for well control or other equivalent purpose, or when routine use of the
equipment may have compromised its effectiveness, the components used [IT] must be
function pressure-tested before the next wellbore entry, using a non-compressible fluid, to the
required working pressure specified in an approved Application for Sundry Approvals under
20 AAC 25.280 or, if that application is not required, to the maximum potential surface pressure
to which that equipment may be subjected, except that an annular type preventer need not be
tested to more than 50 percent of its rated working pressure;
(3) non-sealing equipment must be function-tested weekly, after a repair or
change, and after an action that disconnects the hydraulic system lines from the BOPE, except
that if the workstring is continuously in the well, function-testing must be performed as soon as
possible after the workstring is pulled out of the well and the BHA clears the BOP;
(4) for each BOPE test durine drilIine and completion operations, variable
bore rams must be function pressure tested to the required pressure on the smallest OD
and lareest 00 tubulars that may be used durine that test cvcle. except that variable bore
rams need not be tested on BHAs and drill collars;
@l After instaIIine casine rams in the BOP stack. the ram bonnets must be
tested to the required pressure before runnine casine.
í.2l. BOPE test results must be recorded as part of the daily record required by 20
AAC 25.070(1), and must be provided to the commission, in a format approved by the
commission, within five days after completine the test;
ill [(5)] at least 24 hours notice of each BOPE function pressure test must be
provided so that a representative of the commission can witness the test;[.]
~ /
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MISCELLANEOU.ARDS
Œl. the operator shall report to the commission within 24 hours any instance
of BOPE use to prevent the flow of fluids from a well.
History: Eff. 4/2/86, Register 97; am 11/7/99, Register 152; am_/_/_, Register _)
Authority: AS 31.05.030
20 AAC 25.286(d)(2) is amended to read:
(2) in rotary drilling rig operations,
(A) for an operation with a maximum potential surface pressure of
5,000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS THAN API 5K],
at least three preventers, including
(i) one equipped with pipe rams that fit the size of drill pipe,
tubing, liner or casing being used, except that pipe rams need not be sized to
bottom-hole assemblies (BHAs) and drill collars;
(ii) one with blind rams, except that a subsea BOPE assembly
must have blind/shear rams in place of blind rams; and
(iii) one annular type; and
(B) for an operation, other than a casing or liner operation, with a
maximum potential surface pressure of greater than 5,000 psi [REQUIRING A BOP
ST ACK GREATER THAN API 5K], at least four preventers, including
(i) two equipped with pipe rams that fit the size of the drill pipe
or[,] tubing[, OR CASING] being used, except that pipe rams need not be sized
to BHAs and drill collars:
aJ
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MISCELLANEOU.ARDS
(ii) one with blind rams, except that a subsea BOPE assembly
must have blind/shear rams in place of blind rams; and
(iii) one annular type;
(C) for a casing or liner operation with a maximum potential surface
pressure of greater than 5,000 psi, at least four preventers, including
(i) one equipped with pipe rams that fit the size of the drill
pipe or tubing being used, except that pipe rams need not be sized to BHAs
and drill collars;
(in one equipped with pipe rams that fit the size of casing or
liner being used;
(iii) one with blind rams, except that a subsea BOPE
assembly must have blind/shear rams in place of blind rams; and
(iv) one annular type;
20 AAC 25.286(d)(3) is amended to read:
(3) in coiled tubing unit operations,
(A) for an operation with a maximum potential surface pressure of
5,000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS THAN API 5KJ,
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
(ii) a high pressure pack-off, stripper, or annular type preventer;
and
,a3
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MISCELLANEOUaARDS
(iii) if pressure deployment of tools is planned, a riser or lubricator
sized to the BHA and providing for pressure integrity from the BOPE rams to the
high pressure pack-off, stripper, or annular type preventer; and
(B) for an operation with a maximum potential surface pressure of
greater than 5,000 psi [REQUIRING A BOP STACK GREATER THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
(ii) two high pressure pack-offs, strippers, or annular type
preventers; and
(iii) if pressure deployment of tools is planned, a riser or lubricator
sized to the BHA and providing for pressure integrity from the BOPE rams to the
high pressure pack-off, stripper, or annular type preventer;
20 AAC 25.286(e) is amended to read:
(e) The operator shall test the BOPE assembly as follows:
(1) at least once a week, and after each [USE,] repair, [OR] change, or use for
well control or other equivalent purpose, or when routine use of the equipment may have
compromised its effectiveness, BOP[E] equipment [PIPE AND BLIND RAMS] must be
function pressure-tested, using a non-compressible fluid, to the required working pressure
specified in an approved Application for Sundry Approvals under 20 AAC 25.280 or, if that
application is not required, to the maximum potential surface pressure to which they may be
subjected, except that the annular type preventer need not be tested to more than 50 percent of its
rated working pressure;
dL/
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MISCELLANEOU.ARDS
(2) after each installation of BOPE or other well control equipment, the
equipment must be pressure-tested, before well bore entry, to the maximum potential wellhead
pressure to which it may be subjected, except that when testing against the annular type
preventer, pressure testing need not exceed 50 percent of the rated working pressure of the
annular type preventer;
(3) non-sealing equipment must be function-tested weekly, after a repair or
change, and after an action that disconnects the hydraulic system lines from the BOPE, except
that if the workstring is continuously in the well, function-testing must be performed as soon as
possible after the workstring is pulled out of the well and the BHA clears the BOP;
(4) after each well installation of the BOPE, the BOPE hydraulic connections to
the rams must be visually verified before wellbore entrYi[.]
(5) for each BOPE test durin~ drillin~ and completion operations, variable
bore rams must be function pressure tested to the required pressure on the smallest OD
and lar~est OD tubulars that may be used durin~ that test cycle, except that variable bore
rams need not be tested on BHAs and drill collars;
(6) BOPE test results must be recorded as part of the daily record required
bv 20 AAC 25.0700), and must be provided to the commission, in a format approved by
the commission, within five days after completin~ the test;
(7) at least 24 hours notice of each BOPE function pressure test must be
provided so that a representative of the commission can witness the test;
(8) the operator shall report to the commission within 24 hours any instance
of BOPE use to prevent the flow of fluids from a well.
(J5
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MISCELLANEOU.ARDS
History: Eft. 11/7/99, Register 152; am_/_/_, Register---->
Authority: AS 31.05.030
tjG
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l'vIISCELLANEOLJWARDS
20 AAC 25.005(c)(4)(A) is amended to read:
(A) the maximum downhole pressure that may be encountered, criteria
used to determine it, and maximum potential surface pressure based on a pressure
eradient to surface of 0.1 psi per foot of true vertical depth, unless the commission
approves a different pressure eradient that provides a more accurate means of
determinin!! the maximum potential surface pressure [METHANE GRADIENT];
(Eff. 4/lJi80, Register 74; am 4/2/86, Register 97; am 11/7/99, Register 152; am 6/4/2000,
Register 154; am 115/2006, Register 177; am _ _/_, Register~
Authority: AS 31.05.030 AS 31.05.090
20 AAC 25.035(e)(l) is amended to read:
(1) in rotary drilling rig operations,
(A) for an operation with a maximum potential surface pressure of
3,000 psi or less [REQUIRING A BOP STACK LESS THAN API 5K], BOPE must
have at least three preventers, including
(i) one equipped with pipe rams that tìt the size of drill pipe,
tubing, liner or casing being used, except that pipe rams need not be sized to
bottom-hole assemblies (BHAs) or drill collars:
(Íi) one with blind rams, except that a subsea BOPE assembly
must have blind/shear rams in place of blind rams; and
(iii) one annular type; and
/
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MISCELLANEOU.ARDS
(B) for an operation, other than a casin2 or liner operation, with a
maximum potential surface pressure of 2reater than 3,000 psi [REQUIRING A BOP
STACK EQUAL TO OR GREA TER THAN API 5K]. BOPE must have at least four
preventers, including
(i) two equipped with pipe rams that fit the size of the drill pipe
!U:[,J tubing [, OR CASING] being used, except that pipe rams need not be sized
to BHAs and drill collars;
(ii) one with blind rams, except that a subsea BOPE assembly
must have blind/shear rams in place of blind rams; and
(iii) one annular type;
(C) for a casin2 or liner operation with a maximum potential surface
pressure of 2reater than 3,000 psi, BOPE must have at least four preventers,
incIudin2
(i) one equipped with pipe rams that fit the size of the drill
pipe or tubin2 bein2 used, except that pipe rams need not be sized to BHAs
and drill collars;
(ii) one equipped with pipe rams that fit the size of casin2 or
liner bein2 used;
(iin one with blind rams, except that a subsea BOPE
assemblv must have blind/shear rams in place of blind rams; and
(iv) one annular type;
20 AAC 25.035(e)(2) is amended to read:
¿
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rvIISCE LLANEO U.ARDS
(2) in coiled tubing unit operations, the "veIl control equipment must include
(A) for an operation with a maximum potential surface pressure of
5.000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
(ii) a high pressure pack-off, stripper, or annular type preventer;
(iíi) if pressure deployment of tools, tubing, liner, or casing is
planned, a riser or lubricator sized to the BHA and providing for pressure
integrity from the BOPE rams to the high pressure pack-off, stripper, or annular
type preventer; and
(iv) at least one preventer equipped with pipe rams that fit the size
of tubing, liner, or casing being used, except that pipe rams need not be sized to
BHAs and drill collars; and
(B) for an operation. other than a casin2 or liner operation. with a
maximum potential surface pressure of 2reater than 5.000 psi [REQUIRING A BOP
STACK GREATER THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
(ii) two high pressure pack-offs, strippers, or annular type
preventers;
(iii) if pressure deployment of tools. tubing, liner, or casing is
planned, a riser or lubricator sized to the BHA and providing for pressure
3
Register _,
.0_
MISCELLANEOU.ARDS
integrity from the BOPE rams to the high pressure pack-off, stripper, or annular
type preventer; and
(iv) at least two preventers equipped with pipe rams that fit the
size oftubing[, LINER, OR CASING] being used, except that pipe rams need not
be sized to BHAs and drill collars;
(C) for a casin!?; or liner operation with a maximum potential surface
pressure of !?;reater than 5,000 psi,
(i) HOPE rams providin!?; for pipe, slip, cuttin!?;, and blindin!?;
operations on the coiled tubin!?; in service;
(in two hi!?;h pressure pack-offs, strippers, or annular type
preventers;
Wi) if pressure deplovment of tools, tubing, liner, or casing is
planned, a riser or lubricator sized to the HHA and providing for pressure
integrity from the HOPE rams to the hi!?;h pressure pack-off, stripper, or
annular type preventer;
(iv) at least one preventer equipped with pipe rams that fit the
size of the tubing bein!?; used, except that pipe rams need not be sized to
HHAs and drill collars; and
(v) at least one preventer equipped with pipe rams that fit the
size of casing or liner being used.
20 AAC 25. 035(e)(4)(F) is amended to read:
Lj
Register ~,
.0_
.'vffSCELLANEOU.ARDS
(F) a kill line and a choke line each connected to a flanged or hub bed
outlet on a drilling spool or on the BOP body with two full-opening valves on each
outlet conforming to the fo!!mving specifications:
(i) the outlets must be at least two inches in nominal diameter,
except that for rotary drilling rig operations, if the operation has a maximum
potential surface pressure of e;reater than 3,000 psi [REQUIRED BOP IS
RA. TED EQUAL TO OR GREATER THAN API 5K], the nominal diameter of
the choke outlets must be at least three inches;
(ii) each valve must be sized at least equal to the required size of
the outlet to which it is attached:
(iii) the outer valve on the choke side must be a remotely
controlled hydraulic valve;
(iv) the inner valve on both the choke and kill sides may not
normally be used for opening or closing on flowing fluid;
20 AAC 25. 03 5( e )(4 )(H) is amended to read:
(H) a choke manitàld equipped with
(i) two or more adjustable chokes, one of which must be hydraulic
and remotely controlled from near the driller's station if the operation has a
maximum potential surface pressure of e;reater than 3,000 psi [REQUIRES A
BOP STACK EQUAL TO OR GREATER THAN API 5K];
(ii) a line at least two inches in nominal diameter downstream of
each choke:
.5'
Register ~,
.0_
\;fISCELLANEOUeARDS
(iii) immediately upstream of each choke, at least one full-opening
valve for an operation with a maximum potential surface pressure of 3,000 psi
or less [REQUIRING A BOP STACK LESS THAN API 5K], or at least t\VO
full-opening valves for an operation with a maximum potential surface
pressure of 2reater than 3,000 psi [REQUIRNG A BOP STACK EQUAL TO
OR GREATER THAN API 5K]; and
(i v) a bypass line, at least the diameter of the choke line, \vith at
least one full-opening valve for an operation with a maximum potential surface
pressure of 3,000 psi or less [REQUIRING A BOP STACK LESS THAN API
5K], or at least two full-opening valves for an operation with a maximum
potential surface pressure of 2reater than 3,000 psi [REQUIRING A BOP
STACK EQUAL TO OR GREATER THAN API 5K]:
20 AAC 25.035(e)(1O) is amended to read:
(10) the BOPE must be tested as follows:
(A) when installed, repaired, or changed on a development or service
well and at time intervals not to exceed each 14 days thereafter, BOPE, including kelly
valves, emergency valves, and choke manifolds, must be function pressure-tested to the
required working pressure specified in the approved Permit to Drill, using a non-
compressible tluid, except that an annular type preventer need not be tested to more than
50 percent of its rated \vorking pressure; however, the commission will require that the
BOPE be function pressure-tested weekly, if the commission determines that a weekly
BOPE pressure test interval is indicated by a particular drilling rig's BOPE performance;
Co
Register _,
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MISCELLANEOU.ARDS
(B) when installed, repaired, or changed on an exploratory or
stratigraphic test well and at least once a week thereafter, BOPE, including kelly valves,
emergency valves, and choke manifolds, must be function pressure-tested to the required
working pressure specified in the approved Permit to Drill, using a non-compressible
fluid, except that an annular type preventer need not be tested to more than 50 percent of
its rated working pressure;
(C) if any BOP [SEALING RAM TYPE] equipment components have
[HAS) been used for well control or other equivalent purpose, or when routine use of
the equipment mav have compromised its effectiveness, the components used [IT]
must be function pressure-tested, before the next wellbore entry, to the required working
pressure specified in the approved Permit to Drill, using a non-compressible Duid, except
that an annular type preventer need not be tested to more than 50 percent of its rated
working pressure;
(D) BOP ram and annular components except blind rams must be
function-tested weekly, and all BOP ram and annular components must be tùnction-
tested after an action that disconnects the hydraulic system lines from the BOPE, except
that if the workstring is continuously in the well, function-testing of blind rams must be
performed as soon as possible after the 'vvorkstring is pulled out of the well and the BHA
clears the BOP;
(E) for each BOPE test during drilling and completion operations,
variable bore rams must be function pressure tested to the required pressure on the
smallest outside diameter (OD) and largest OD tubulars that may be used during
~
Register _,
.-
MISCELLANEOUeARDS
that test cycle, except that variable bore rams need not be tested on BHAs and drill
collars;
(F) after installin2 casin2 rams in the BOP stack, the ram bonnets
must be tested to the required pressure before runnin2 casin2.
llil. BOPE test results must be recorded as part of the daily record
required by 20 AAC 25.070(1), and must be provided to the commission, in a format
approved bv the commission, within five days after completin2 the test;
an [(F)] at least 24 hours notice of each BOPE function pressure test
must be provided to the commission so that a commission representative can witness the
test;
History: Eff. 4/13/80, Register 74: am 2/22/81, Register 77; am 4/2/86, Register 97: am 117/99,
Register 152; am 10/24/2004, Register 172; am _/_ _, Register ~
Authority: AS 31.05.030
20 AAC 25.036(c)(1) is amended to read:
(1) in rotary drilling rig operations,
(A) for an operation with a maximum potential surface pressure of
5,000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS THAN API 5K],
BOPE must have at least three preventers, including
(i) one equipped with pipe rams that fit the size of drill pipe,
tubing, liner, or casing being used, except that pipe rams need not be sized to
bottom-hole assemblies (BHAs) and drill collars:
."'ì
¡ ¡
X
(j
Register~, _~_
MISC ELLANEO UeARDS
(ii) one with blind rams, except that a subsea BOPE assembly
must have blind/shear rams in place of blind rams; and
(iii) one annular type; and
(B) for an operation other than a casing or liner operation, with a
maximum potential surface pressure of I!reater than 5,000 psi [REQUIRING A BOP
STACK GREATER THAN API 5K], BOPE must have at least four preventers,
including
(i) two equipped with pipe rams that fit the size of the drill pipe
Q![,] tubing[, OR CASING] being used, except that pipe rams need not be sized
to BHAs and drill collars;
(ii) one \vith blind rams, except that a subsea BOPE assembly must
have blind/shear rams in place of blind rams; and
(iii) one annular type;
(C) for a casing or liner operation with a maximum potential surface
pressure of I!reater than 5,000 psi, BOPE must have at least four preventers,
including
(i) one equipped with pipe rams that fit the size of the drill pipe
or tubinl! being used, except that pipe rams need not be sized to BHAs and
drill collars;
(in one equipped with pipe rams that fit the size of casing or
liner being used;
(iii) one with blind rams, except that a subsea BOPE assemblv
must have blind/shear rams in place of blind rams; and
q
Register _,
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MISCELLA.\JEOU.ARDS
(iv) one annular type;
20 AAC 25.036(c)(2) is amended to read:
(2) in coiled tubing unit operations, the well control equipment must include
(A) for an operation with a maximum potential surface pressure of
5,000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
(ii) a high pressure pack-off~ stripper, or annular type preventer;
(iii) if pressure deployment of tools, tubing, liner, or casing is
planned, a riser or lubricator sized to the BHA and providing tàr pressure
integrity from the BOPE rams to the high pressure pack-off, stripper, or annular
type preventer; and
(iv) at least one preventer equipped with pipe rams that fit the
size of the tubing, liner, or casing being used, except that pipe rams need not be
sized to BHAs and drill collars; and
(B) for an operation, other than a casine or liner operation with a
maximum potential surface pressure of ereater than 5,000 psi [REQUIRING A BOP
STACK GREATER THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
(ii) two high pressure pack-offs, strippers, or annular type
preventers;
/0
Register _,
.
MISCELLANEOUS.ARDS
(iii) if pressure deployment of tools, tubing, liner, or casing is
planned, a riser or lubricator sized to the BHA and providing for pressure
integrity from the BOPE rams to the high pressure pack-off, stripper, or annular
type preventer; and
(iv) at least two pre venters equipped with pipe rams that tIt the size
of the tubing(, LINER, OR CASING] being used, except that pipe rams need not
be sized to BHAs and drill collars;
(C) for a casing or liner operation with a maximum potential surface pressure
of greater than 5,000 psi,
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
(ii) two high pressure pack-offs, strippers, or annular type
preventers;
(iii) if pressure deplovment of tools, tubing, liner, or casing is
planned, a riser or lubricator sized to the BHA and providing for pressure
integrity from the ROPE rams to the high pressure pack-off, stripper, or
annular type preventer;
(iv) at least one preventer equipped with pipe rams that fit
the size of the tubing being used, except that pipe rams need not be sized to
BHAs and drill collars; and
(v) at least one preventer equipped with pipe rams that fit the
size of casing or liner being used;
II
Register _,
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MISCELLANEOU.ARDS
20 AAC 25.036(c)(4)(H) is amended to read:
(H) for conventional open loop fluid process drilling operations, a choke
manifold equipped with
(i) two or more adjustable chokes, one of which must be hydraulic
and remotely controlled from near the driller's or operator's station if the
operation has a maximum potential surface pressure of greater than 3,000 psi
[REQUIRES A BOP STACK EQUAL TO OR GREATER THAN API 5K];
(ii) a line at least two inches in nominal diameter downstream of
each choke:
(iii) immediately upstream of each choke, at least one full-opening
val ve for an operation with a maximum potential surface pressure of 5,000 psi
or less [REQUIRING A BOP STACK EQUAL TO OR LESS THAN API 5K],
or at least two full-opening valves for an operation with a maximum potential
surface pressure of greater than 5,000 psi [REQUIRING A BOP STACK
GREATER THAN API 5K]; and
(iv) a bypass line at least two inches in nominal diameter with at
least one full-opening valve immediately upstream of each choke for an operation
with a maximum potential surface pressure of 5,000 psi or less [REQUIR[\iG
A BOP STACK EQUAL TO OR LESS THAN API 5K], or with at least two full-
opening valves immediately upstream of each choke for an operation with a
maximum potential surface pressure of greater than 5,000 psi [REQUIRING
A BOP STACK GREATER THAN API 5K]:
/z
Register_.
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MISCELLANEOU.ARDS
20 AAC 25.036(d) is amended to read:
(d) A BOPE assembly must be tested as follows:
(1) when installed, repaired, or changed on a development or service well and at
time intervals not to exceed each 14 days thereafter, BOPE, including kelly valves, emergency
valves, and choke manifolds, must be function pressure-tested to the required working pressure
specified in the approved Permit to DrilL using a non-compressible fluid, except that an annular
type preventer need not be tested to more than 50 percent of its rated working pressure; however,
the commission will require that the BOPE be function pressure-tested weekly, if the
commission determines that a weekly BOPE pressure test interval is indicated by a particular
drilling rig's BOPE performance;
(2) when installed, repaired, or changed on an exploratory or stratigraphic test
well and at least once a week thereafter, BOPE, including kelly valves, emergency valves, and
choke manifolds, must be function pressure-tested to the required working pressure specified in
the approved Permit to Drill, using a non-compressible fluid, except that an annular type
preventer need not be tested to more than 50 percent of its rated \-vorking pressure;
(3) other well control equipment must be pressure-tested to the maximum
potential wellhead pressure after each installation of the well control equipment and before
wellbore entry, except that an annular type preventer need not be tested to more than 50 percent
of its rated working pressure;
(4) if!!!y BOP [SEALING RA.~l TYPE] equipment components have fHAS]
been used for well control or other equivalent purpose, or when routine use of the
equipment may have compromised its effectiveness, the components used [IT] must be
function pressure-tested, before the next \vellbore entry, to the required working pressure
j/
,J
Register _.
.
MISCELLANEOUS eA.RDS
specified in the approved Permit to Drill, using a non-compressible fluid, except that an annular
type preventer need not be tested to more than 50 percent of its rated vvorking pressure;
(5) BOP ram and annular components except blind rams must be function-tested
weekly, and all BOP ram and annular components must be function-tested after an action that
disconnects the hydraulic system lines trom the BOPE, except that if the workstring is
continuously in the well, function-testing of blind rams must be performed as soon as possible
after the workstring is pulled out of the well and the BRA clears the BOP;
(6) for each BOrE test durin!! drillin!! and completion operations, variable
bore rams must be function pressure tested to the required pressure on the smallest OD
and lar!!est OD tubulars that mav be used durin!! that test cvcle, except that variable bore
rams need not be tested on BHAs and drill collars;
ill BOPE test results must be recorded as part of the daily record required by 20
AAC 25.070(1), and must be provided to the commission, in a format approved bv the
commission, within five days after completin!! the test;
.@.L[(7)] at least 24 hours notice of each BOPE function pressure test must be
provided to the commission so that a representative of the commission can witness the test.
History: Eff. 11/7/99, Register 152; am 10/24/2004, Register 172: am_/ _ _, Register
Authority: AS 31.05.030
20 AAC 25.280(b) is amended to add a ne"v paragraph:
(b) The Application for Sundry Approvals must set out
14
Register _,
.
rvfISCELLANEOUS.ARDS
(l) the current condition of the we!!;
(2) a copy of the proposed program for we!! work;
(3) unless already on file with the commission, a diagram and description of the
well control equipment to be used, including if applicable a list of the blowout prevention
equipment (BOPE) with specifications;
(4) the maximum downhole pressure that may be encountered, criteria used
to determine it, and maximum potential surface pressure based on a pressure eradient to
surface of 0.1 psi per foot oftrue vertical depth unless the commission approves a different
pressure eradient that provides a more accurate means of determinine the maximum
potential surface pressure, such as usine a stabilized shut-in tubine pressure.
ill a description of any we!!bore fluid to be used for primary well control; and
@ [(5)] the current bottom-hole pressure, or, if data setting out the actual
pressure are not available, an estimate of the current bottom-hole pressure.
History: Eff. 4/2/86, Register 97; am 1117/99, Register 152: am_/_/_, Register_)
Authority: AS 31.05.030
20 AAC 25.285(c)(2) is amended to read:
(2) in rotary drilling rig operations,
(A) for an operation with a maximum potential surface pressure of
3,000 psi or less [REQUIRING A BOP STACK LESS THAT API 5K], at least three
preventers, including
IC¡
J...J
Register _,
.
l\ifISCELLANEOUS .A.RDS
(i) one equipped \vith pipe rams that fit the size of drill pipe,
tubing, liner or casing being used, except that pipe rams need not be sized to
bottom-hole assemblies (BHAs) and drill collars:
(ii) one with blind rams, except that a subsea BOPE assembly
must have blind/shear rams in place of blind rams; and
(iii) one annular type; and
(B) for an operation, other than a casin2: or liner operation, with a
maximum potential surface pressure of 2:reater than 3,000 psi [REQUIRING A BOP
STACK EQUAL TO OR GREATER THAN API 5K], at least four preventers, including
(i) t\VO equipped with pipe rams that fit the size of the drill pipe
or[,] tubing[, OR CASING] being used, except that pipe rams need not be sized
to BHAs and drill collars;
(ii) one with blind rams, except that a subsea BOPE assembly
must have blind/shear rams in place of blind rams; and
(iii) one annular type;
(C) for a casin2: or liner operation, with a maximum potential
surface pressure of 2:reater than 3,000 psi, at least four preventers, includinf!
(i) one equipped with pipe rams that fit the size of the drill
pipe or tubinf! beinf! used, except that pipe rams need not be sized to BHAs
and drill collars;
(in one equipped with pipe rams that fit the size of casinf! or
liner beinf! used;
Jlo
I
Register _,
.
MISCELLANEOU.ARDS
(iii) one with blind rams, except that a subsea BOrE assemblv
must have blind/shear rams in place of blind rams; and
(iv) one annular tvpe;
20 AAC 25.285(c)(3) is amended to read:
(3) in coiled tubing unit operations,
(A) for an operation with a maximum potential surface pressure of
5,000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
(ii) a high pressure pack-off, stripper, or annular type pre venter;
(Ìii) if pressure deployment of tools is planned, a riser or lubricator
sized to the BHA and providing for pressure integrity from the BOPE rams to the
high pressure pack-off, stripper, or annular type preventer; and
(iv) at least one preventer equipped with pipe rams that fit the size
of the tubing, liner, or casing being used, except that pipe rams need not be sized
to BHAs and drill collars; and
(B) for an operation, other than a casine or liner operation, with a
maximum potential surface pressure of ereater than 5,000 psi [REQUIRING A BOP
STACK GREATER THAN API 5K],
(Ì) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service:
;/1
¡ .
f I
, !
Register _,
.
MISCELLANEOUSeARDS
(ii) two high pressure pack-offs, strippers, or annular type
preventers;
(iii) if pressure deployment of tools is planned, a riser or
lubricator sized to the BHA and providing for pressure integrity from the BOPE
rams to the high pressure pack-otl, stripper, or annular type preventer; and
(iv) at least two preventers equipped with pipe rams that fit the
size of the tubing[, LINER, OR CASING] being used, except that pipe rams need
not be sized to BHAs and drill collars;
(C) for a casin2 or liner operation with a maximum potential surface
pressure of 2reater than 5,000 psi,
(i) HOPE rams providin2 for pipe, slip, cuttin2, and blindin2
operations on the coiled tubin2 in service;
(in two hi2h pressure pack-offs, strippers, or annular type
preventers;
(iii) if pressure deployment of tools is planned, a riser or
lubricator sized to the HHA and providin2 for pressure inte2rity from the
HOPE rams to the hi2h pressure pack-off, stripper, or annular type
preventer;
(iv) at least one preventer equipped with pipe rams that fit
the size of the tubin2 bein2 used, except that pipe rams need not be sized to
HHAs and drill collars; and
(v) at least one preventer equipped with pipe rams that fit the
size of casin2 or liner bein2 used;
,,/
J' \.".
1\
,{j
Register
.-
MISCELLANEOUS .RDS
20 AAC 25.285(c)(9)(A) is amended to read:
(9) a kill line and a choke line each connected to a flanged or hubbed outlet on a
drilling spool or on the BOP body with two full-opening valves on each outlet, conforming to the
following specifications:
(A) the outlets must be at least two inches in nominal diameter, except
that for rotary drilling rig operations, if the operation has a maximum potential surface
pressure of ereater than 3,000 psi [REQUIRED BOP IS RATED EQUAL TO OR
GREA TER THAN API 5 K], the nominal diameter of the choke outlets must be at least
three inches;
(B) each valve must be sized at least equal to the required size of the
outlet to which it is attached;
(C) the outer valve on the choke side must be a remotely controlled
hydraulic valve;
(D) the inner valve on both the choke and kill sides may not normally be
used for opening or closing on flowing fluid; and
20 AAC 25 .285( c)(1 0) is amended to read:
(10) a choke manifold equipped with
(A) two or more adjustable chokes, one of which must be hydraulic and
remotely controlled from near the driller's station if the operation has a maximum
potential surface pressure of ereater than 3,000 psi [REQUIRES A BOP STACK
EQUAL TO OR GREATER THAN API 5K];
; /"\
/~!
Register _,
.
MISCELLANEOUSeARDS
(B) a line at least two inches in nominal diameter dO\vnstream of each
choke:
(C) immediately upstream of each choke, at least one fu[[-opening valve
for an operation with a maximum potential surface pressure of 3,000 psi or less
[REQUIRING A BOP STACK LESS THAN API 5K], or at least two full-opening
valves for an operation with a maximum potential surface pressure of 2:reater than
3,000 psi [REQUIRING A BOP STACK EQUAL TO OR GREATER THAN API 5K];
and
(D) a bypass line, at least tvvo inches in nominal diameter, with at least
one full-opening valve for an operation with a maximum potential surface pressure of
3,000 psi or less [REQUIRING A BOP STACK LESS THAN API 5K], or at least tvvo
full-opening valves for an operation with a maximum potential surface pressure of
2:reater than 3,000 psi [REQUIRING A BOP STACK EQUAL TO OR GREATER
THAN API 5K].
20 AAC 25.285(f) is amended to read:
(D The BOPE must be tested as follows:
(I) when installed, repaired, or changed, and at least once a week thereafter,
BOPE, including emergency valves and choke manifolds, must be function pressure-tested, using
a non-compressible fluid, to the required working pressure specified in an approved Application
for Sundry Approvals under 20 AAC 25.280 or, if that application is not required, to the
maximum potential surface pressure to which the BOPE may be subjected, except that an
annular type preventer need not be tested to more than 50 percent of its rated vvorking pressure:
~{7
Register _,
.
MISCELLANEOUS.ARDS
(2) if any BOP [SEALING R.AM TYPE] equipment components have rHAS]
been used for well control or other equivalent purpose, or when routine use of the
equipment may have compromised its effectiveness, the components used [IT] must be
function pressure-tested before the next wellbore entry, using a non-compressible tluid, to the
required working pressure specified in an approved Application for Sundry Approvals under
20 AAC 25.280 or, if that application is not required, to the maximum potential surtàce pressure
to which that equipment may be subjected. except that an annular type preventer need not be
tested to more than 50 percent of its rated working pressure;
(3) non-sealing equipment must be function-tested weekly, after a repair or
change, and after an action that disconnects the hydraulic system lines from the BOPE, except
that if the \vorkstring is continuously in the well, function-testing must be performed as soon as
possible after the \vorkstring is pulled out of the well and the BHA clears the BOP;
(4) for each BOPE test durine drilline and completion operations, variable
bore rams must be function pressure tested to the required pressure on the smallest OD
and lareest OD tubulars that may be used durine that test cycle, except that variable bore
rams need not be tested on BHAs and drill collars;
(5) After installine casine rams in the BOP stack, the ram bonnets must be
tested to the required pressure before runnine casine.
ill.. BOPE test results must be recorded as part of the daily record required by 20
AAC 25.070(1), and must be provided to the commission, in a format approved by the
commission, within five days after completine the test;
ill.. [(5)] at least 24 hours notice of each BOPE function pressure test must be
provided so that a representative of the commission can witness the test:[.]
/"', I
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..~
Register
.
:vrISCELLANEO US.ARDS
ŒL the operator shall report to the commission within 24 hours anv instance
of HOPE use to prevent the flow of fluids from a well.
History: Eff. 4/2/86, Register 97; am II T99, Register 152; am_ _ _' Register _)
Authority: AS 31.05.030
20 AAC 25.286(d)(2) is amended to read:
(2) in rotary drilling rig operations,
(A) for an operation with a maximum potential surface pressure of
5,000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS THAN API 5K],
at least three preventers, including
(i) one equipped with pipe rams that fit the size of drill pipe,
tubing, liner or casing being used, except that pipe rams need not be sized to
bottom-hole assemblies (BHAs) and drill collars;
(ii) one \vith blind rams, except that a subsea BOPE assembly
must have blind/shear rams in place of blind rams; and
(iii) one annular type; and
(B) for an operation, other than a casill1! or liner operation, with a
maximum potential surface pressure of greater than 5,000 psi [REQUIRING A BOP
STACK GREATER THAN API 5K], at least four preventers, including
(i) two equipped with pipe rams that fit the size of the drill pipe
or[,J tubing[, OR CASING J being used, except that pipe rams need not be sized
to BHAs and drill collars;
1)
:/)~
Register
.
MISCELLANEOUS.ARDS
(ii) one with blind rams, except that a subsea BOPE assembly
must have blind/shear rams in place of blind rams; and
(iii) one annular type;
(C) for a casin2 or liner operation with a maximum potential surface
pressure of 2reater than 5,000 psi, at least four preventers, includin2
(i) one equipped with pipe rams that fit the size of the drill
pipe or tubin2 bein2 used, except that pipe rams need not be sized to BHAs
and drill collars;
(ii) one equipped with pipe rams that fit the size of casin2 or
liner bein2 used;
(iii) one with blind rams, except that a subsea BOPE
assembly must have blind/shear rams in place of blind rams; and
(iv) one annular type;
20 AAC 25 .286( d)(3) is amended to read:
(3) in coiled tubing unit operations,
(A) for an operation with a maximum potential surface pressure of
5,000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS THAN API 5K],
(i) BOPE rams pro\'iding for pipe, slip, cutting, and blinding
operations on the coiled tubing in service:
(ii) a high pressure pack-off stripper, or annular type preventer:
and
--.,
'Î /
I)
.~ .--..1
Register .
c.. _
.
MfSCELLANEOU.ARDS
(Ìii) if pressure deployment of tools is planned, a riser or lubricator
sized to the BHA and providing for pressure integrity from the BOPE rams to the
high pressure pack-off stripper, or annular type preventer; and
(B) for an operation with a maximum potential surface pressure of
2;reater than 5,000 psi [REQUIRING A BOP STACK GREATER THAN API 5KJ,
(i) BOPE rams providing for pipe, slip, cutting, and blinding
operations on the coiled tubing in service;
(ii) tvvo high pressure pack-offs, strippers, or annular type
preventers; and
(Ìii) if pressure deployment of tools is planned, a riser or lubricator
sized to the BHA and providing for pressure integrity from the BOPE rams to the
high pressure pack-off, stripper, or annular type pre venter:
20 AAC 25.286(e) is amended to read:
(e) The operator shall test the BOPE assembly as follows:
(1) at least once a \veek, and after each [USE,] repair, [OR] change, or use for
well control or other equivalent purpose, or when routine use of the equipment may have
compromised its effectiveness, BOP[E] equipment [PIPE AND BLIND RAMS] must be
function pressure-tested, using a non-compressible fluid, to the required working pressure
specified in an approved Application for Sundry Approvals under 20 AAC 25.280 or, if that
application is not required, to the maximum potential surtàce pressure to \vhich they may be
subjected. except that the annular type preventer need not be tested to more than 50 percent of its
rated \\larking pressure;
è~~
Reaister
to __.
.
~nSCELLA;\[EOUS .RDS
(2) after each installation of BOPE or other well control equipment the
equipment must be pressure-tested, before weIIbore entry, to the maximum potential weIIhead
pressure to which it may be subjected, except that when testing against the annular type
pre venter, pressure testing need not exceed 50 percent of the rated working pressure of the
annular type preventer;
(3) non-sealing equipment must be function-tested weekly, after a repair or
change, and after an action that disconnects the hydraulic system lines from the BOPE, except
that if the workstring is continuously in the \vell, function-testing must be performed as soon as
possible after the workstring is pulled out of the well and the BHA clears the BOP:
(4) after each \vell installation of the BOPE, the BOPE hydraulic connections to
the rams must be visually veritìed before weIIbore entry.;lJ
(5) for each BOPE test during drillinl! and completion operations, variable
bore rams must be function pressure tested to the required pressure on the smallest OD
and larl!est OD tubulars that mav be used during that test cycle, except that variable bore
rams need not be tested on BHAs and drill collars;
(6) BOPE test results must be recorded as part of the dailv record required
by 20 AAC 25.070(1), and must be provided to the commission, in a format approved bv
the commission, within five davs after completing the test;
(7) at least 24 hours notice of each BOPE function pressure test must be
provided so that a representative of the commission can witness the test;
(8) the operator shall report to the commission within 24 hours anv instance
of BOPE use to prevent the flow of fluids from a well.
/ì--
cr) ~
Register _,
.
MISCELLANEOUS e'\RDS
History: Eff. ] [17/99, Register 152; am_ _ _, Register ~
Authority: AS 3] .05.030
/\ lo
I r
eX .
.
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ORDER CERTIFYING THE CHANGES TO
REGULATIONS OF ALASKA OIL AND GAS CONSERVATION
COMMISSION
The attached 26 pages of regulations, dealing with Permit to Drill requirements and blowout
prevention equipment under 20 AAC 25 are hereby certified to be a correct copy of the regulation
changes that the Alaska Oil and Gas Conservation Commission adopted at its September 27,
2006 meeting, under the authority of AS 31.05.030 and 31.05.040 and after compliance with the
Administrative Procedure Act (AS 44.62), specifically including notice under AS 44.62.190 and
44.62.200 and opportunity for public comment under AS 44.62.210.
This action is not expected to require an increased appropriation.
On the record, in considering public comments, the Alaska Oil and Gas Conservation
Commission paid special attention to the cost to private persons of the regulatory action being
taken.
The regulation changes described in this order take effect on the 30th day after they have been
filed by the lieutenant governor, as provided in AS 44.62.180.
DATE:
October 9,2006
Anchorage
t~f~
C y P. Foerster
Commissioner
FILING CERTIFICATION
I, Loren Leman, Lieutenant Governor for the State of Alaska, certify that on
,2006 at
provisions of AS 44.62.040 - 44.62.120.
.m., I filed the attached regulations according to the
Lieutenant Governor
Effective:
Register:
.
.
STATE OF ALASKA
NOTICE OF PROPOSED CHANGES IN THE REGULATIONS OF THE
ALASKA OIL AND GAS CONSERVATION COMMISSION
The Alaska Oil and Gas Conservation Commission ("AOGCC") proposes to adopt regulation
changes in Title 20, Chapter 25, of the Alaska Administrative Code, dealing with Penn it to Drill
requirements and blowout prevention equipment requirements including the following:
The method of determining a well's maximum potential surface pressure is
precisely specified in 20 AAC 25.005(c)(4)(A); and
Blowout prevention equipment requirements are clarified in 20 AAC 25.035(e)(I), 20
AAC 25.035(e)(2), 20 AAC 25.035(e)(I0), 20 AAC 25.036(c)(I), 20 AAC 25.036(c)(2),
20 AAC 25.036(d), 20 AAC 25.285(c)(2), 20 AAC 25.285(c)(3), 20 AAC 25.285(t), 20
AAC 25.286(d)(I), 20 AAC 25.286(d)(3), 20 AAC 25.286(e)
You may comment on the proposed regulation changes, including the potential costs to private
persons of complying with the proposed changes, by writing to AOGCC, 333 W. th Avenue,
Suite 100, Anchorage, AK 99501. The comments must be received no later than 4:30 p.m. on
September 8, 2006.
Oral or written comments may be submitted at a hearing to be held on August 31,2006 at 333 W.
th A venue, Suite 100, Anchorage, AK 99501. The hearing will begin at 9:00 a.m. and might be
extended to accommodate those present before 9:30 a.m. who did not have an opportunity to
comment.
If you are a person with a disability who may need a special accommodation in order to
participate in the process, please contact Jody Colombie at 793-1221 by 4:00 p.m., August 18,
2006 to ensure that any necessary accommodations can be provided.
For a copy of the proposed regulation changes, contact Jody Colombie at AOGCC, 333 W. th
A venue, Suite 100, Anchorage, Alaska 99501, or by telephoning the AOGCC at 907-793-1221,
or on the AOGCC website at:
http://www .aogcc.alaska. gov.
After the public comment period ends, the AOGCC will either adopt this or another proposal
dealing with the same subject, without further notice, or decide to take no action on it. The
language of the final regulations may be different from that of the proposed regulations. YOU
SHOULD COMMENT DURING THE TIME ALLOWED IF YOUR INTEREST COULD BE
AFFECTED. Written comments received are public records and are subject to public inspection.
S 3 1.05.030.
pected to require an increased
Statutory Authority: AS 31.05.030.
Statutes Being Implemented, Interpreted, or
Fiscal Information: The proposed regulati
appropriation.
Date: July 26, 2006
Published: July 28. 2006
AO-02714001
.
.
ADDITIONAL REGULA TrONS NOTICE INFORMATION
(AS 44.62. 1 90(d))
1. Adopting agency: Alaska Oil and Gas Conservation Commission.
2. General subject of regulations: Permit to Drill requirements and blowout prevention
equipment requirements.
3. Citation of regulations: 20 AAC 25.005(c)(4)(A), 20 AAC 25.035(e)(1), 20 AAC
25.035(e)(2), 20 AAC 25.035(e)(10), 20 AAC 25.036(c)(1), 20 AAC 25.036(c)(2), 20
AAC 25.036(d), 20 AAC 25.285(c)(2), 20 AAC 25.285(c)(3), 20 AAC 25.285(t), 20
AAC 25.286(d)(1), 20 AAC 25.286(d)(3), 20 AAC 25.286(e)
4. Reason for the proposed action: clarification of the subject regulatory requirements.
5. Program category and BRU affected: Alaska Oil and Gas Conservation Commission.
6. Cost of implementation to the state agency: zero.
7. The name of the contact person for the regulations John K. Norman, Alaska Oil and
Gas Conservation Commission, 333 W. th Avenue, Suite 100, Anchorage, AK
99501, (907) 279-1433.
8.
9. Date:
10. Prepared by:
4tnchOrage Daily News
Affidavit of Publication
.
lOO! Northway Drive. Anchorage. AK 99508
PRICE OTHER OTHER OTHER OTHER OTHER GRAND
AD# DATE PO ACCOUNT PER DAY CHARGES CHARGES #2 CHARGES #3 CHARGES #4 CHARGES #5 TOTAL
889675 07/28/2006 002714001 STOF0330 5270.18
$270.18 $0.00 $0.00 $0.00 $0.00 $0.00 $270.18
STATE OF ALASKA
THIRD JUDICIAL DISTRICT
Christine Clark, being first duly sworn on oath deposes and
says that she is an advertising representative of the Anchorage
Daily News, a daily newspaper.
That said newspaper has been approved by the Third Judicial
Court, Anchorage, Alaska, and it now and has been published in
the English language continually as a daily newspaper in
Anchorage, Alaska, and it is now and during all said time was
printed in an office maintained at the aforesaid place of
publication of said newspaper. That the annexed is a copy of an
advertisement as it was published in regular issues (and not in
supplemental form) of said newspaper on the above dates and
that such newspaper was regularly distributed to its subscribers
during all of said period. That the full amount of the fee charged
for the foregoing publication is not in excess of the rate charged
private individua~¡
/~.. /
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5i~~v!dl/fYJL(I:'~'
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Subscribep and sworn to me before this date:
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Nota~y Public in and for the State of Alaska,
Third Division. Anchorage, Alaska
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. J}).nm\ì
STATE OF ALASKA
NOTICE OF PROPOSED CHANGES IN THE REGULATIONS OF THE
ALASKA OIL AND GAS CONSERVATION COMMISSION
The Alaska Oil and Gas Conservation Cammission ("AOGCC") proposes. to
adopt regulation changes in Title 20, Chapter 25, of the Alaska Administrative
Cade, dealing with Permit to Drill requir~ments and blowout prevention
equipment requirement s including the follo\/,!lng:
The method of determining a well's maximum potential surface pressure
is preciselY specified in 20 AAC 25.005(c)(4)(A); and
Blowout prevention equipment requirements are clarified In
20 AAC 25.035(e)(1), 20 AAC 25.035(e)(2h 20 AAC 25.035(e)(10),
20 AAC 25.036(c)(1), 20 AÄC 25.036(c)(2), 20 AAC 25.036(dh
20 AAC 25.285(c)(2), 20 AAC 25.285(c)(3), 20 AAC 25.285(f),
20 AAC 25.286(d)(l), 20 AAC 25.286(d)(3), 20 AAC 25.286(e)
You may comment on the praþosedregulatiOO changes, including the )()t~tntial
costs to private persons of complying with the proposed changes, bY writIng to
AOGCC, 333 W. 7th Avenue, Suite 100, Anchorage, AK 99501. The comments
must be received no later than 4:30 p.m. on September 8, 2006.
Oral or written comments may be submitted at 0 hearing to be held on Augu!'t
31. 2006 at 333 W. 7th Avenue, Suite 100, Anchorage, AK 99501. The hearing "'1111
begin at 9:00 a.m. and might be extended to accommodate those present be-
fore 9:30 a.m. who did not hove an opportunity to comment.
If yau ore a person with 0 disability who may need a special ac~ommodation in
order to participate In the process, please contact Jody ColombIe at 793-1221 bY
4:00p.m., August 18,2006 to ensure that any necessary accommodatIOns con be
provided.
For a copy of the prap()sed regulation changes, contact Jody Colombie at
AOGCC, 333W. 7th Avenue, Suite 100, Anchorage, Ala.ska 99501. or bY telephon-
ing the AOGCC at 907-793-1221. or on the AOGCC webslte at:
http://www;aa9cc.a laska. gav.
After the public comment period ends, the AOGCC will either adapt this or ,!n-
other proposal dealing with thesamesubiect, without further notice, or decide
to take no action on it. The language of the final regulations may be different
from thot of the proposed regulations.. YOU SHOULD COMMENT DURING.
THE TIME ALLOWED IF YOUR INTEREST COULD. BE AFFECTED. Writ-
ten comments received ore public records and are sublect to public inspectIOn.
Statutory Authority: AS 31.05.030; AS 31.05.040. . .
Statutes Being Implemented, Interpreted, or Made SpecIfIc: AS 31.05.030.
Fiscal Information: The proposed regulation changes are not expected to
require an increased appropriation.
Dote: July 26, 2006
Isf: John K. Norman, Chairman
Alaska Oil and Gas Conservation Commission
AO# 02714001
Published: JulY 28, 2006
.
.
SI A IE OF ALASKA.
)
) ss.
)
THIRD JUDICIAL DISTRICT
AFFIDA VIr OF NOTICE OF PROPOSED ADOPTION OF REGULATIONS
AND FURNISHING OF ADDITIONAL INFORMATION
I, Jody J. Colombie, Special Staff Assistant, of Alaska Oil and Gas Conservation Commission, being
sworn, state the following:
As required by AS 44.62.190, notice of the proposed adoption of changes to 20 AAC 25, Permit to Drill
Requirements and Blowout Prevention Equipment Requirements has been given by being
(I) published in a newspaper or trade publication;
(2) furnished to interested persons [as shown on the attached list];
(3) furnished to appropriate state officials;
(4) furnished to the Department of Law, along with a copy of the proposed regulations;
(5) electronically transmitted to incumbent State of Alaska legislators;
(6) furnished to the Legislative Affairs Agency, Legislative Library;
(7) posted on the Alaska Online Public Notice System as required by AS 44.62.1 75(a)(1) and (b)
and 44.62.190(a)( I);
(8) furnished electronically, along with a copy of the proposed regulations, to the
Legislative Affairs Agency, the chair of the House and Senate Resources Committee, House
Special Committee on Oil and Gas, and the Administrative Regulation Review Committee,
and the legislative council.
As required by AS 44.62.190( d), additional regulations notice information regarding the proposed
adoption of the regulation changes described above has been furnished to interested persons [as shown on
the attached list] and those in (5) and (6) of the list above. The additional regulations notice information
also has been posted on the Alaska Online Public Notice System.
DATE: /0/9106
AnclSorage, Alaska
SUBSCRIBED AND SWORN TO before me this C¡~day of OC~ f1¡~ ( ,'}.,OC~
~;~na1ø:?~
State of Alaska /
My commission expires: 1/ /1/ IDb·
t I
.
.
STATE OF ALASKA
)
) ss.
)
THIRD JUDICIAL DISTRICT
AFFIDA VII OF ORAL HEARING
I, Jody 1. Colombie, Special Staff Assistant of the Alaska Oil and Gas Conservation
Commission, being sworn, state the following:
On August 31,2006, at 9:00 a.m., 333 West 7th Avenue, Suite 100, Anchorage, Alaska 99501, a
public hearing presided over by John K. Norman, Chairman, was held in accordance with
AS 44.62.210 for the purpose of taking testimony in connection with the adoption of changes to .
20 AAC 25.005(c)(4)(A), 20 AAC 25.035(e)(1), 20 AAC 25.035(e)(2), 20 AAC 25.035(e)(4), 20
AAC 25.035(e)(lO), 20 AAC 25.036(c)(1), 20 AAC 25.036(c)(2), 20 AAC 25.036(c)(4)(H), 20
AAC 25.036(d), 20 AAC 25.280(b), 20 AAC 25.285(c)(2), 20 AAC 25.285(c)(3), 20 AAC
25.285(c)(9)(A), 20 AAC 25.285(c)(10), 20 AAC 25.285(f), 20 AAC 25.286(d)(1), 20 AAC
25.286(d)(3), 20 AAC 25.286(e).
DATE: October 9, 2006
Anchorage
SUBSCRIBED AND SWORN TO before me this 9th day of October, 2006.
.
.
ALASKA OIL AND GAS CONSERVATION COMMISSION MEETING
September 27, 2006
Excerpt From Unapproved l'vfinutes
Commissioner Cathy P. Foerster moved and Commissioner Daniel T. Seamount, Jr. seconded the
following motion:
"I move to adopt the amendments, specifically to 20 AAC 25.005(c)(4)(A), 20 AAC
25.035(e)(l), 20 AAC 25.035(e)(2), 20 AAC 25.035(e)(4), 20 AAC 25.035(e)(lO), 20 AAC
25.036(c)(l), 20 AAC 25.036(c)(2), 20 AAC 25.036(c)(4)(H), 20 AAC 25.036(d), 20 AAC
25.280(b), 20 AAC 25.285(c)(2), 20 AAC 25.285(c)(3), 20 AAC 25.285(c)(9)(A), 20 AAC
25.285(c)(lO), 20 AAC 25.285(f), 20 AAC 25.286(d)(l), 20 AAC 25.286(d)(3), 20 AAC
25 .286( e), all of which pertain generally to the same subject as written in the September 27th
draft of regulations."
The motion carried unanimously.
.
.
STATE OF ALASKA
)
) ss.
)
THIRD JUDICIAL DISTRICT
AFFIDAVIT OF COMMISSION ACTION
I, Jody 1. Colombie, Special Staff Assistant for the Alaska Oil and Gas Conservation
Commission, being duly sworn, state the following:
The attached motion dealing with the method of determining a well's maximum potential surface
pressure and blowout prevention equipment regulation changes was passed by the Alaska Oil and
Gas Conservation Commission during its September 27, 2006 meeting.
Date: October 9,2006
Anchorage
SUBSCRIBED AND SWORN TO before me this 9th day of October 2006.
-r7 ¿P ~
ot Public in and for the
State of Alaska
My commission expires: 11111/06.
:#=4
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10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
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1
ALASKA OIL AND GAS CONSERVATION COMMISSION
2
Before Commissioners:
John K. Norman, Chairman
Daniel T. Seamount
Cathy Foerster
3
4 Proposed Changes to Blow Out
Prevention Equipment Regulations
5
6
ALASKA OIL and GAS CONSERVATION COMMISSION
Anchorage, Alaska
7
8
August 31, 2006
9:00 o'clock a.m.
9
PUBLIC HEARING
BEFORE:
John K. Norman, Chairman
Cathy Foerster, Commissioner
R & R C 0 U R T R E P 0 R T E R S
811 G STREET
(907)277-0572/Fax 274-8982
ANCHORAGE, ALASKA 99501
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1
PRO C E E DIN G S
2
Tape 1
3 0015
4 (On record - 9:00 a.m.)
5
CHAIRMAN NORMAN: Good morning. This is a hearing before
6 the Alaska Oil and Gas Conservation Commission being held on
7 the morning of Thursday, September 30th -- correction,
8 September 31st [sic] at the hour of 9:00 o'clock a.m. The
9 purpose of the hearing is to receive comments on the proposed
11 out prevention equipment, more specifically to the regulations
10 amendments to the Commission's regulations pertaining to blow
12 found in 20 AAC 25.005 and forward. I will not read each of
13 the specific amendments because they will be addressed in the
14
15
course of these proceedings.
16 the Commission. To my left is Commissioner Cathy Foerster, the
I'll first introduce myself, I'm John Norman, Chairman of
17 Engineering Commissioner. Commissioner Dan Seamount is unable
18 to be with us today, but we do have a quorum present and can
19 proceed with this hearing.
20 In compliance with the Americans with Disabilities Act, if
21 any persons have any special needs for accommodations to enable
22 them to participate in this hearing or provide testimony,
23 please, see the Commission's Special Assistant, Jody Columbie,
24 and she will assist you. Ms. Columbie is in the back of the
25 room, would you, please, hold your hand up, please, for
R & R C 0 U R T R E P 0 R T E R S
811 G STREET
(907)277-0572/Fax 274-8982
ANCHORAGE, ALASKA 99501
2
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.
1
identification? Thank you.
2
Before we get into the testimony I'll remind everyone to,
3 please, first identify yourself, your company affiliation if
4 any, and your name clearly for the record. Also be sure to
5 speak into the microphone so that those in the rear of the room
6
can hear you. And also a transcript is being made of these
proceedings and it will be important that the court reporter
also be able to have clear testimony to prepare that record.
7
8
9
Notice of this hearing was published on July 28, 2006, in
10 the Anchorage Daily News. Any persons desiring to see a copy
11 of that notice can see the Commission's Special Assistant and
12 that will be provided to you.
13 This hearing is proceeding in accordance with the general
14
15
hearing regulations applicable to this Commission and those
16 Alaska Administrative Code.
regulations are specifically found at 20 AAC 25.540 of the
17 We have a sign up sheet and if there are any persons who
18 wish to testify that have not signed up, we would appreciate
19 you doing so.
20 I'll pause now and see if Commissioner Foerster has
21 anything to add before we go forward?
22
23
COMMISSIONER FOERSTER: No.
CHAIRMAN NORMAN: Then we will first hear briefly from the
24 Commission's staff concerning the regulations. Dr. Aubert?
25
DR. AUBERT: Thank you. For the record my name is Winton
R & R C 0 U R T R E P 0 R T E R S
811 G STREET
(907)277-0572/Fax 274-8982
ANCHORAGE, ALASKA 99501
3
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1
Aubert, spelled W-i-n-t-o-n, last name A-u-b-e-r-t, and I'm on
2
the Commission staff.
3 Before the Commission today are proposed changes to Title
4 20, Chapter 25 of the Alaska Administrative Code which I'll
5 henceforth refer to either as Commission regulations or as
6 AOGCC regulations. Also since a number of proposed changes
7 today concern blowout prevention equipment I will refer to
8 that equipment occasionally as BOP or BOPE or BOP equipment.
9 Our first proposed change is to Section 005 of the
11 change to the method by which a well's maximum anticipated
10 Commission regulations. We're proposing a straight forward
12 surface pressure is calculated.
13 Our next series of changes are to Sections 035, 036, 285
14
15
and 286 of the Commission regulations. Current AOGCC
regulations in these sections express blowout prevention
17 Petroleum Institute or API pressure ratings of individual BOP
16 equipment configurations in terms of required American
18 components. Our proposed changes will express required blow
20 maximum potential surface pressure on which the equipment is
19 out prevention equipment configurations in terms of a well's
21 installed.
22 We also propose amendments to Section 035, 036, 285 and
23 286 of the Commission regulations to one, clarify testing after
24 use requirements of BOP equipment; second, to specify a time
25 limit on reporting of BOP test results; and third, to codify an
R & R C 0 U R T R E P 0 R T E R S
811 G STREET
(907)277-0572/Fax 274-8982
ANCHORAGE, ALASKA 99501
4
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1
area on which current regulations are silent, namely required
2
testing of variable bore ram BOP equipment.
3 To conclude, we believe the present proposed changes to
4 the Commission regs will reduce regulatory ambiguity and
5 variations in interpretation, will reduce instances of
6 regulatory noncompliance, will reduce the numbers of regulatory
7 waivers and variances the Commission issues and will improve
8 time utilization of Commission staff and Commission inspectors.
10 change the regulatory burden on Alaska's petroleum industry.
9 We also believe that the proposed changes do not appreciably
11
12
13
14
CHAIRMAN NORMAN: Thank you, Dr. Aubert.
DR. AUBERT: Thank you.
CHAIRMAN NORMAN: Commissioner Foerster?
15 increase, do they do anything to decrease the regulatory
COMMISSIONER FOERSTER: You said they don't appreciably
16 burden?
17
18
19
DR. AUBERT: They do not.
COMMISSIONER FOERSTER: Okay.
CHAIRMAN NORMAN: Thank you. And if you would remain
20 available in case there are questions.
21 We have several persons testifying and I'm not sure if
22 you've simply indicate you're here or if you wish to testify.
23 So I will ask persons that wish to testify to, please, come
24 forward and -- yes, Ms. Moriarty?
25
MS. MORIARTY: Good morning. My name is Kara Moriarty,
R & R C 0 U R T R E P 0 R T E R S
811 G STREET
(907)277-0572/Fax 274-8982
ANCHORAGE, ALASKA 99501
5
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I'm the External Affairs Manager for the Alaska Oil and Gas
2
Association. AOGA is a private, non-profit trade association
3 whose member companies represent the majority of oil and gas
4 exploration, production, transportation, refining and marketing
5 in Alaska.
6 AOGA has reviewed the draft AOGCC regulation changes and
7 we appreciate the opportunity to provide testimony and comment
8 today. AOGA commends the Commission in its efforts to provide
10 We support the proposed regulation changes and would offer
9 clarity and consistency to existing regulation.
11 minor clarifications and additions. Ilm going to give the
12 Commissioners our packet of information now and then I'm going
13 to ask Jerome Eggemeyer from ConocoPhilips Alaska and Harry
14
15
16
Engel from B.P. to walk through the minor suggested
clarifications and additions that we would like to propose.
CHAIRMAN NORMAN: Let the record reflect that a copy has
17 been provided to both Commissioners and also a copy to the
18 court reporter and this copy will be affixed to the transcript
19 of this meeting.
20 Mr. Engel or Mr. Eggemeyer, which one of you wants to go
21 first?
22
MR. ENGEL: Good morning, Commissioners Norman and
23 Foerster. My name is Harry Engel. For the record, the last
24 name is spelled E-n-g-e-l. I am a staff engineer for B.P.
25 Exploration here in Anchorage and B.P. is a member of AOGA.
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I also want to echo the comments made by Kara a few
2
minutes ago regarding the effort by the AOGCC to modify these
3 regulations. We do also agree that the effort provides clarity
4 and consistency across Alaska with respect to BOP requirements
5 in our industry.
6 Kara has provided a list of our comments, I can go through
7 them with you in detail if you'd like and we'll start with the
8 first recommendation in Section 25.005(c) (4) (a). We'd like to
9 add a minor suggest -- a minor recommendation referring to the
10 words, an equally effective means of determining. We'd
11 recommend changing that to read, a more accurate means of
12 determining the surface pressure. We think that would
13 strengthen the regulation.
14
15
The next comment is in regard to wording related to
16 regulations there are sections in there where this remains
requiring a stack of less than API 5K. Throughout the
17 unchanged and we would like to recommend that for consistency
18 purposes that the language that's used which is, with a maximum
19 potential surface pressure of 3,000 PSI which is used in the
20 regulations, be used throughout the proposed regulations for
21 consistency purposes. And we've identified the areas in which
22 we feel that may be appropriate in the revised regulation.
23 The next comment we have is in regards to Section
24 25.035(e) (10) (c). And we suggest that the proposed language,
25 if BOP equipment has been used, be clarified to state, if any
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BOP equipment components have been used. We feel this will add
some clarity into what component of the BOP equipment will be
3 required in that section of the regulation.
2
4 The next comment is in relationship to the requirement for
5 submitting test results to the Commission within two days which
6 is the proposed amendment to the regulation. We would like to
7 recommend that we change that to within a five day period to
8
allow for weekend and holiday periods throughout the year and
allow us time to submit the reports in a timely manner without
being in noncompliance of the proposed regulation.
9
11 And I'll ask Jerome to address the next comment related to
12 the addition of a subsequent regulation we'd like to propose to
13 the Commission.
14
15
MR. EGGEMEYER: For the record, I'm Jerome Eggemeyer, last
16 m-e, employee for ConocoPhilips, Engineering Team Lead in the
name's spelled, E-g-g-e-m-e-y-e-r, first name Jerome, J-e-r-o-
17 Drilling and Wells group. And I will address a couple other
18 items with regard to the proposed regulation.
19
20 have two suggested additions to the regulation. One addition
We have two suggested additions to the regulation. We
21 would affect regulation -- Notice for Revision in the set of
22 revisions in 20 AAC 25.035. We would suggest that a new
23 subsection is inserted between (10) (e) and (10(f) and that
24 would address testing of the ram bonnets after installing
25 casing rams into the stack before casing is run.
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CHAIRMAN NORMAN: Mr. Eggemeyer, so I can -- let's see,
2
are you -- you're referring -- I'm looking at your handout and
3 it's numbered at the bottom, so you're referring right now to
4 page to 5, the subsection (f), is that -- is that what you're
5 mentioning?
6
MR. EGGEMEYER: Page 5, item (f).....
7
CHAIRMAN NORMAN: Item (f). Okay. I'm with you.
8
MR. EGGEMEYER:
.... . about a third of the way down on the
9 page.
CHAIRMAN NORMAN: Yes, I'm with you.
MR. EGGEMEYER: Yes.
CHAIRMAN NORMAN: Thank you.
MR. EGGEMEYER: And so that particular addition would say
that after installing casing rams in the BOP stack the ram
16 the casing. And this would just offer a clarification on that
bonnets must be tested to the required pressure before running
17 for -- for consistency and continuity. This is also consistent
18 with language, I believe, used by the MMS which is one resource
19 we used to see how this was addressed in other places.
20 Additionally, the -- another item -- other proposed
21 addition to -- is to insert a new subsection 20 AAC
22 25.280(b) (6), to add a requirement to the Sundry notice
23 application addressing the maximum surface pressure
24 calculation. And on the handout that is towards the back, page
25 9, I believe. Okay. We suggest that the Commission apply the
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surface pressure calculation concept articulated in the
2
proposed revision, 25.05(c) (4) (a) [sic] to work over operations
3 with additional wording to indicate that using stabilized shut-
4 in tubing pressure may be -- may provide an alternative way
5 that is acceptable to the Commission for determining the
6 maximum potential surface pressure for proposed work over
7 operations. Our suggested language is included in the handout
8 which I think you're looking at there.
9 And if this suggested addition to the regulations does not
10 fit within the scope of the proposed revisions then that would
12 could be considered on a future revision. So depending on
11 -- that has been publicly noticed so far, then that change
13 order of business of how we can address that.
14
But that actually is a fairly important component just to
15 add clarity for the work over sector. Otherwise we often end
16 up falling back to the drilling rig to get guidance for that.
17
18 understand it, that revision will be included in a future
COMMISSIONER FOERSTER: Mr. Eggemeyer, the way I
19 revision to the regulations and we appreciate your comment and
20 it will be addressed.
21
22
23
MR. EGGEMEYER: Okay. Great. Thank you.
CHAIRMAN NORMAN: Okay. Anything further?
MR. ENGEL: Yes, Commissioner Norman, I want to just
24 clarify that we do have in our package this morning a reference
25 of the MMS regulations referring to testing casing rams after
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installation and before running casing as an amendment. And
2
it's MMS regulation 30CFR Part 250, Subpart D, Oil and Gas
3 Drilling Operations and it's Section .451, and it's attached
4 for your reference in our package.
5
CHAIRMAN NORMAN: Yes, I think -- I see we have it right
6 here.
7
MR. EGGEMEYER: Thank you.
8
CHAIRMAN NORMAN: Commissioner Foerster, any further
10 the testimony of these two witnesses that you feel would
9 questions of the witnesses? Dr. Aubert, was anything said in
11 require some clarification? If there is, I'd ask that you come
12 forward. If not, why I just want to give you the opportunity
13 if they have any questions?
14
15
DR. AUBERT: No, but I would like to thank the AOGA
16 which are very germane as usual.
representatives for their -- for their comments and suggestions
17
18 have only one question and that relates to the opinion of the
CHAIRMAN NORMAN: Okay. The record will reflect that. I
19 Commission that this will not add to the regulatory burden on
20 industry and included in that is added cost to industry. Is
21 that your opinion of these regulations if they're adopted that
22 they will not increase the costs or regulatory burden on the
23 industry?
24
MR. ENGEL: Yes, Commissioner, I agree with that statement
25 that we don't see any additional burden to industry in regards
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to the regulation.
2
MR. EGGEMEYER: I would agree with that statement and
3 actually I think it is a benefit because it offers clarity and
4 less administration, less administervia (ph) I'll call it, in
5 understanding what the best solution is whenever there is lack
6 of clarity.
7
CHAIRMAN NORMAN: Yes. All right. Well, we thank you
8 very much for taking your time to come in and offer comments on
10 effort between the Commission and industry and the goal, of
9 these regulations and this is an example of a good cooperative
11 course, is to have a very safe and well-functioning oil
12 industry operating in the state of Alaska.
13 So again we thank all of you and thank you, Ms. Moriarty.
14
15
Do you have anything now to finish your testimony? Okay.
16 awake, the audience has pointed out that when we started the
COMMISSIONER FOERSTER: I do. To prove to us that they're
17 hearing we said that the date today was September 31st, but
18 it's August 31st.
19
CHAIRMAN NORMAN: Thank you for that correction. We'll
20 excuse you, gentlemen, and ask you to remain.
21 And I'll just ask generally now if there are any other
22 persons present who wish to offer any comments on these
23 regulations? Okay. The Chair sees no one asking to be
24 recognized.
25 The regulations have been duly noticed, a quorum of
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Commissioners is present to receive the testimony. And so we
2
will now take your comments into consideration as well as any
3 other information and then in due course there will be a
4 subsequent hearing at which the Commission will vote formally
5 to adopt these regulations. They will then be sent to Juneau
6 to be filed with the Lieutenant Governor. And then following
7 that there will be a new effective date and they'll become part
8 of the regulations assuming that they are adopted.
9
COMMISSIONER FOERSTER: Can I move to adopt -- to adjourn
10 the meeting, please?
11
CHAIRMAN NORMAN: It's been moved and without objection we
12 are adjourned.
13 (Recessed - 9:25 a.m.)
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C E R T I F I CAT E
2
UNITED STATES OF AMERICA )
) ss.
STATE OF ALASKA )
3
4 I, Rebecca Nelms, Notary Public in and for the State of
Alaska, residing at Anchorage, Alaska, and Reporter for R & R
5 Court Reporters, Inc., do hereby certify:
6 THAT the annexed and foregoing Public Hearing Regarding
Proposed Changes to Blow Out Prevention Equipment Regulations
7 was taken by Lynn Hall on the 31st day of August, 2006,
commencing at the hour of 9:00 a.m., at the Alaska Oil and Gas
8 Conservation Commission, Anchorage, Alaska;
9 THAT this Hearing Transcript, as heretofore annexed, is a
true and correct transcription of the proceedings taken and
10 transcribed by Lynn Hall;
12
11 IN WITNESS WHEREOF, I have hereunto set my hand and
affixed my seal this 1st day of September 2006.
13
14
15
16
17
18
19
20
21
22
23
24
25
~~~..c.~
Notary Public in and for Alaska
My Commission Expires: 10/10/06
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STATE OF ALASKA
OIL AND GAS CONSERVATION COMMISSION
Permits and Equipment Regulations Hearing
August 31, 2006 at 9:00 am
NAME - AFFILIATION
ADDRESS/PHONE NUMBER
TESTIFY (Yes or No)
~RINT)Ðù~f1
J!.c.y 11 W1~¡"(l.yf¡ j
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·
Alaska Oil and Gas Isociation
A0GA
121 W. Fireweed Lane, Suite 207
Anchorage, Alaska 99503-2035
Phone: (907)272-1481 Fax: (907)279-8114
Email: brady@aoga.org
Judith Brady, Executive Director
August 30, 2006
Commissioner John Norman
Alaska Oil and Gas Conservation Commission
333 W. 7th Avenue, Suite 100
Anchorage, AK 99501-3539
Re: AOGA Comments on AOGCC Permit to
Drill/BOPE ReQulation ChanQes
DearCommissioner Norman:
The Alaska Oil & Gas Association (AOGA) is a private non-profit trade association. Its
member companies represent the majority of oil and gas exploration, production,
transportation, refining and marketing activities in Alaska. AOGA has reviewed the draft
Alaska Oil and Gas Conservation Commission (AOGCC) regulation changes and
appreciates the opportunity to provide comment and testimony.
AOGA commends the AOGCC in its efforts to provide clarity and consistency to existing
regulations. We support the proposed regulation changes, and would offer minor
clarifications and additions. FoUowing is a brief description of the changes we suggest,
and the specific changes are shown in the attached redline document.
1. In the new language proposed for 20 AAC 25.005(c)(4)(A), line 5, we
suggest revising the words "an equally effective means of determining. . ." to
read "a more accurate means of determining. . ,II
2. In the existing regulations, there are a couple of places where the wording
"requiring a stack less than API 5k" remains unchanged by the proposed
regulation revisions. Based on the consistent use of the phrase "with a
maximum potential surface pressure of 3,000 psi or less" in the revised
regulations, we suggest that all such references to the API 5k stack be
revised to use the new proposed language. The regulations that would
require additional changes to the new wording are at 20 AAC
25.035(e)(4)(H)(iii) and (iv) and 20 AAC 25.285(c)(10)(C) and (D).
August 31, 2006
Page 2
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3. In the proposed revision to 20MC 25.035(e)(10)(C), we suggest that the
proposed language "if BOP equipment has been used. . ." be clarified to "if
any BOP equipment components have been used. . ."
4. We propose changing the requirement of submitting BOPE test results to the
Commission from "within two days" to "within five days." We believe that this
timeframe is an acceptable timeframe for what is normally a non-urgent
submission and allows for weekends and holidays without putting a party in
non-compliance. This time requirement is found in proposed revised
regulations 20 MC 25.035(e)(10)(F), 20 MC 25.036(d)(7), 20 MC
25.285(f)(5), and 20 MC 25.286(e)(6).
We have two suggested additions to the proposed regulations. One addition would affect
a regulation noticed for revision in this set of revisions. In 20 MC 25.035(e)(10), we
suggest that a new subsection be inserted between (10)(E) and (10)(F), which would
address testing the ram bonnets after installing casing rams, before running casing. The
U.S. Minerals Management Service includes a similar requirement in its OCS regulations,
a copy of which is attached to these comments. Suggested language is included in the
attached redlined document.
The other proposed addition is to insert a new subsection, 20 MC 25.280(b)(6), to add a
requirement to the Sundry Notice application addressing the maximum surface pressure
calculation. We suggest that the Commission apply the surface pressure calculation
concept articulated in the proposed revision to 20 MC 25.005(c)(4)(A) to workover
operations, with additional wording to indicate that using a stabilized shut-in tubing
pressure may provide an alternative way that is acceptable to the Commission for
determining the maximum potential surface pressure for proposed workover operations.
Suggested language is included in the attached redlined document. If this suggested
addition to the regulations does not fit within the scope of the proposed revisions that have
been publicly noticed for change at this time, we ask that this addition be considered for
inclusion in a future revision of the Commission regulations.
Thank you for the opportunity to provide comment and testimony on these proposed
revisions to the Commission's regulations.
Sincerely,
Enclosures (2) [red line; MMS reg]
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MISCELLANEOt BOARDS
20 AAC 25.005(c)(4)(A) is amended to read:
(A) the maximum downhole pressure that may be encountered,
criteria used to determine it, and maximum potential surface pressure
based on a pressure s:radient to suñace of 0.1 psi per foot of tme
vertical de..th. unless the commission aporoves a different pressure
2radient that provides aft eq8ftBv dJedÎVe more ¡tCl'urate meaDS of
determinin2 the maximum ootential suñace pressure [METHANE
GRADIENT];
/
(Eft: 4/13/80, Register 74; am 4/2186, Register 97; am 1117/99, Register 152; am
6/412000, Register 154; am 1/5/2006, Register 177; am ---1---1--> Register.---J
Authority: AS 31.05.030 AS 31.05.090
20 AAC 25.035(e)(1) is amended to read:
(1) in rotary drilling rig operations,
(A) for an operation with a maximum QC)tential suñace pressure
of3..ooo psi or less [REQUIRING A BOP STACK LESS THAN API
5K], BOPE must have at least three preventers, including
(i) one equipped with pipe rams that fit the size of drill
pipe, tubing, liner or casing being used, except that pipe rams need
not be sized to bottom-hole assemblies (8RAs) or drill collars;
(ii) one with blind rams, except that a subsea BOPE
assembly must have blind/shear rams in place of blind rams; and
(iii) one annular type; and
(8) for an operation. other than a casin~ or liner operation.. with
a muimum POtential suñace pressure of 2reater than 3.000 psi
[REQUIRING A BOP STACK EQUAL TO OR GREATER THAN API
5K], BOPE must have at least four preventers, including
(i) two equipped with pipe rams that fit the size of the drin
pipe !.!: tubing [OR CASING] being used, except that pipe rams
need not be sized to BHAsand drill collars;
(ii) one with blind rams, except that a subsea BOPE
assembly must have blind/shear rams in place of blind rams; and
(iii) one annular type;
1
Register --->
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MISCELLANEO'BOARDS
(C) for a casine or üner operation with a maximum pOtential
sudate pressure of ereater than 3.000 osi. DOPE must have at least
four preventers.indudinJ
(n one e{Juipped with pipe rams that fit the size of the
driB pine or tobin, beÎDe used. except that pine rams need not
be sized to DHAsaad drill eolian;
(ü) oae equipped with Dine rams that fit the size of
casine or üner heine used:
(ill) oae with blind rams.. ex~t that as.Mea BOPE
assemblv must have blind/shear nuBS m ølate of bliød rams:
and
(iv) oneauDular tvøe:
20 MC 25.035(eX2) is amended to read:
(2) in coiled tubing unit operations, the well control equipment must
include
(A) for an operation with a maximum pOtential sudace pressure
of 5.000 osi or less [REQUIRING A BOP STACK EQUAL TO OR LESS
THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and
blinding operations on the coiled tubing in service;
(ii) a high pressure pack-off: stripper, or annular type
preventer;
(iii) if pressure deployment of tools, tubing, liner, or casing
is planned, a riser or lubricator sized to the BHA and providing for
pressure integrity trom the BOPE rams to the high pressure pack-
off, stripper, or annular type preventer, and
(iv) at least one preventer equipped with pipe rams that fit
the size of tubing, liner, or casing being used, except that pipe rams
need not be sized to BRAs and drill coUars;and
(B) for an operation. other than a casine or liner operation. with
a ...xi.... DOteøtial s.riace press.re of ereater than 5.000 øsi
[REQUIRING A BOP STACK GREATER THAN API5K],
2
Register ---'
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MISCELLANEOI BOARDS
(i) BOPE rams providing for pipe, slip. cutting. and
blinding operations on the coiled tubing in service;
(ii) two high pressure pack: -offs. strippers, or annular type
preventers;
(iü) if pressure deployment of tools. tubing, liner. or casing
is planned, a riser or lubricator sized to the BHA and providing for
pressure integrity «om the BOPE rams to the high pressure pack-
off, stripper. or annular type preventer~ and
(iv) at least two preventers equipped with pipe rams that fit
the size of tubing[. LINER OR CASING] being used, except that
pipe rams need not be sized to BRAs and drillcoUars;
(c) for a cuin!! or liner operation with a maximum ootential
soda" oressure of ereater than 5.000 osi.
(n BOPE rams orovidillf! for oipe.. sliD. atttiD~..d
blindiB!! oøeratioDs OR tile œiIed tub~ in ~
(ü) two 11_ oressure oack-offs. striopers. or annular
type oreventen;
(üi) if oressure deøIoYIDeRt of tools. tubiu.Iioer. or
cuin!! is ~ a riser or lubricator sized to die BBAalld
onwidin!! for uressure iatet!1'ÍtY from the BOPE ~s to the
IIn onssure .-ck-off.. MODer.. or aanular t\1Je oreventer;
(iv)at least ORe ,reveRter ea..... with OM raDII that
fit the size of tile tRbiB~ IteiMo ..... e:s:Ͽt that. nuBS Deed
DOt be sized to BBAs aDd drill collars; aDd
(v) at least ORe preveDtereauipøed with pipe nuns that
fit the .size of casiaS! or liner heia!! used.
20 AAC 25.()35(e)(4} is amended to ..ead:
(4) a BOPE assembly must include
(H) a choke manifold equipped with
(iii) immediately upstream of each choke, at least one full-
opening valve for an operation with a maximum I>otential
3
Register ----7
·200
MISCELLANEOI BOARDS
slIrfafe pressure of 3.000 psi or less [REQUIRING A BOP
STACK LESS THAN API 5K], or at least two fuU-opening valves
for an operation requiring a BOP stack equal to or greater than API
5K; and
(iv) a bypass line, at least the diameter of the choke line,
with at least one full-opening valve for an operation with a
maximum notentÎaJ surf~lce [H'eSSure of 3,000 psi or less
[REQUIRING A BOP STACK LESS THAN API SK], or at least
two ful1-opening valves for an operation requiring a BOP stack
equal to or greater than API 5K;
20 AAC 25.03S(e)(IO) is amended to read:
(10) the BOPE must be tested as follows:
(A) when installed, repaired, or changed on a development or
service well and at time intervals not to exceed each 14 days thereafter,
BOPE, including kelly valves, emergency valves, and choke manifolds,
must be function pressure-tested to the required working pressure
specified in the approved Permit to Drill, using a non-compressible fluid,
except that an annular type preventer need not be tested to more than 50
percent of its rated working pressure; however, the commission will
require that the BOPE be function pressure-tested weekly, if the
commission determines that a weeldy BOPE pressure test interval is
indicated by a particular drilling rig's BOPE perfonnance;
(8) when installed, repaired, orcbanged on an exploratory or
stratigraphic test well and at least once a week: thereafter, BOPE, including
kelly valves, emergency valves, and choke manifolds, must be function
pressure-tested to the required working pressure specified in the approved
Permit to Drill, using a non-compressible fluid, except that an annular type
preventer need not be tested to more than 50 percent of its rated working
pressure;
!
(C) if'lliY_BOP [SEALING RAM TYPE] equipmen(çç'J}lPS~Der!!l?
ha}'..çs been used for well control or other equivalent purpose. or when
routine use of the eouipment may have com,romised its effectiveness.
the eouiøment [IT] must be function pressure-tested, before the next
wellbore entry, to the required working pressure specified in the approved
Permit to Drill, using a non-compressible fluid, except that an annular type
preventer need not be tested to more than 50 percent of its rated working
pressure;
(D) BOP ram and annular components except blind rams must be
function-tested weeldy, and all BOP ram and annular components must be
4
Register ~
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NUSCELLANEOttBOARDS
function-tested after an action that disconnects the hydraulic system lines
from the BOPE, except that if the workstring is continuously in the well,
function-testing of blind rams must be performed as soon as possible after
the workstring is pulled out of the well and the BHA clears the BOP;
(E) for each DOPE test durine: drilline: and comoletion
ooerations. variable bore rams must be function oressure tested to the
reQuired oressure on the smallest outside diameter (OD) and lare:est
OD tubulal'S that mav be used durine: that test cvcle. exceot that
variable bore rams need not be tested on DBAs and drill collars:
(F) After installin2 casin2 rams in the BOP stack. the ram
bonnets must be tested to the reQuired pressure before runnin2
casim!.
/
fF.)(G) BOPE test results must be recorded as part of the daily
record required by 20 AAC 25.070(1), and must be rovided to th
commission in a format a roved b the commission within
days after comoletin2 the test:
fG}(H) [(F)] at least 24 hours notice of each BOPE function
pressure test must be provided to the commission so that a commission
representative can witness the test;
History: Eff 4/13/80, Register 74; am 2/22/81, Register 77; am 4/2/86, Register 97; am
11/7/99, Register 152; am 10/24/2004, Register 172; am-1-1----, Register ~
Authority: AS 31.05.030
20 AAC 25.036(c)(1) is amended to read:
(1) in rotary drilling rig operations,
(A) for an operation with a maximum potential surface oressure
of 5.000 osi or less [REQUIRING A BOP STACK EQUAL TO OR LESS
THAN API 5K], BOPE must have at least three preventers, including
(i) one equipped with pipe rams that fit the size of drill
pipe, tubing, liner, or casing being used, except that pipe rams need
not be sized to bottom-hole assemblies (BHAs) and drill collars;
(ii) one with blind rams, except that a subsea BOPE
assembly must have blind/shear rams in place of blind rams; and
(iii) one annular type; and
5
Register ---'
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MISCELLANEOI BOARDS
(B) for an operation other than a casin2 or liner ooeration. with
a maximum ootential suñace pressure of ~reater than 5.000 osi
[REQUIRING A BOP STACK GREATER THAN API 5K], BOPE must
have at least four preventers, including
(i) two equipped with pipe rams that fit the size of the drill
pipe or[,] tubing[, OR CASING] being used, except that pipe rams
need not be sized to BRAs and drill collars;
(ii) one with blind rams, except that a subsea BOPE
assembly must have blind/shear rams in place of blind rams; and
(iii) one annular type;
(C) for a casin2 or liner operation with a maximum ootential
suñace oressure of 2reater than 5.000 osi. BOPE must have at least
four oreventers. includin2
(n one eauiooed with pioe rams that fit the size of the
drill pioe or tubin2 bein2 used. exceot that oipe rams need not
be sized to BRAs and drm collars:
em one eauiooed with pioe rams that fit the size of
casin2 or liner bein2 used:
(iii) one with blind rams. exceot that a subsea BOPE
assemblv must have blind/shear rams in place of blind rams:
and
(iv) one annular tvoe:
20 AAC 25.036(c)(2) is amended to read:
include
(2) in coiled tubing unit operations, the well control equipment must
(A) for an operation with a maximum potential suñace Dressure
of 5.000 osi or less [REQUIRING A BOP STACK EQUAL TO OR LESS
THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and
blinding operations on the coiled tubing in service;
(ii) a high pressure pack-off, stripper, or annular type
preventer;
6
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MISCELLANEOI BOARDS
(iii) if pressure deployment of tools, tubing, liner, or casing
is planned, a riser or lubricator sized to the BHA and providing for
pressure integrity from the BOPE rams to the high pressure pack-
off, stripper, or annular type preventer; and
(iv) at least one preventer equipped with pipe rams that fit
the size of the tubing, liner, or casing being used, except that pipe
rams need not be sized to BHAs and drill collars; and
(B) for an operation. other than a casing or liner operation with
a maximum ootential suñace oressure of 2reater than 5.000 osi
[REQUIRING A BOP STACK GREATER THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and
blinding operations on the coiled tubing in service;
(ii) two high pressure pack-offs, strippers, or annular type
preventers;
(iii) if pressure deployment of tools, tubing, liner, or casing
is planned, a riser or lubricator sized to the BHA and providing for
pressure integrity from the BOPE rams to the high pressure pack-
off, stripper, or annular type preventer; and
(iv) at least two preventers equipped with pipe rams that fit
the size of the tubing[, LINER, OR CASING] being used, except
that pipe rams need not be sized to BHAs and drill collars;
(C) for a casin2 or liner ooeration with a maximum ootential
suñace oressure of 2reater than 5.000 osi.
{n DOPE rams orovidin2 for oioe. SliD. cuttin2. and
blindin2 ooerations on the coiled tubin2 in service:
(m two hip pressure oack~otTs. striDDen. or annular
tvoe oreventers:
eiii) if oressure deolovment of tools. tubin2. liner. or
casin2 i. olanned. a riser or lubricator sized to the DRA and
providin2 for oressure inteJri1y from the BOPE rams to the
hi2h oressure oack-otT. striooer. or annular tvoe oreventer:
(iv) at least one oreventer eauiooed with oioe rams that
fit the size of the tubin~ bein~ used. exceot that oipe rams need
not be sized to BRAs and drill collars: and
7
Register ----J
. ZOO
MISCELLANEOI BOARDS
(v) at least one preventer eQuipped with pipe rams that
fit the size of casine or liner beine used:
ZO AAC Z5.036(d) is amended to read:
(d) A BOPE assembly must be tested as follows:
(1) when installed, repaired, or changed on a development or service well
and at time intervals not to exceed each 14 days thereafter, BOPE, including kelly
valves, emergency valves, and choke manifolds, must be function pressure-tested
to the required working pressure specified in the approved Permit to Drill, using a
non-compressible fluid, except that an annular type preventer need not be tested
to more than 50 percent of its rated working pressure; however, the commission
will require that the BOPE be function pressure-tested weekly, if the commission
determines that a weekly BOPE pressure test interval is indicated by a particular
drilling rig's BOPE performance;
(Z) when installed, repaired, or changed on an exploratory or stratigraphic
test well and at least once a week thereafter, BOPE, including kelly valves,
emergency valves, and choke manifolds, must be function pressure-tested to the
required working pressure specified in the approved Permit to Drill, using a non-
compressible fluid, except that an annular type preventer need not be tested to
more than 50 percent of its rated working pressure;
(3) other well control equipment must be pressure-tested to the maximum
potential wellhead pressure after each installation of the well control equipment
and before well bore entry, except that an annular type preventer need not be
tested to more than 50 percent of its rated working pressure;
(4) if BOP [SEALING RAM TYPE] equipment has been used for well
control or other eQuivalent purpose. or when routine use of the equipment
mav have compromised its effectiveness. the eQuipment [IT] must be function
pressure-tested, before the next wellbore entry, to the required working pressure
specified in the approved Permit to Drill, using a non-compressible fluid, except
that an annular type preventer need not be tested to more than 50 percent of its
rated working pressure;
(5) BOP ram and annular components except blind rams must be function-
tested weekly, and all BOP ram and annular components must be function-tested
after an action that disconnects the hydraulic system lines from the BOPE, except
that if the workstring is continuously in the well, function-testing of blind rams
must be performed as soon as possible after the workstring is pulled out of the
well and the BRA clears the BOP;
(6) for each BOPE test durine driUine and completion operations.
variable bore rams must be function pressure tested to the reQuired pressure
8
Register ---'
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MISCELLANE+OARDS
on tbe smallest on and laœest on tubulars tbat may be used durin!! tbat
test cvcle. except tbat variable bore rams need not be tested on BRAs and
drill collars;
ill DOPE test results must be recorded as part of the daily record required
by 20 AAC 25. 070( 1 ). and must be provided to the commission. in a format
approved bv tbe commission. within· -1 days after completin!! the test;
Γ.[(7)] at least 24 hours notice of each BOPE function pressure test must
be provided to the commission so that a representative of the commission can
witness the test.
History: Eff 11/7/99, Register 152; am 10/24/2004, Register 172; am-.-f _/-->
Register ---.J
Autbority: AS 31.05.030
(b) The Application for Sundry Approval must set out
20 AAC 25.285(c)(2) is amended to read:
(2) in rotary drilling rig operations,
(A) for an operation with a maximum potential surface pressure
of 3.000 psi or less [REQUIRING A BOP STACK LESS THAT API 5K],
at least three preventers, including
(i) one equipped with pipe rams that fit the size of drill
pipe, tubing, liner or casing being used, except that pipe rams need
not be sized to bottom-hole assemblies (BHAs) and drill collars;
(ii) one with blind rams, except that a subsea BOPE
assembly must have blind/shear rams in place of blind rams; and
9
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MISCELLANEOI BOARDS
(iii) one annular type; and
(B) for an operation. other than a casin2 or liner oDeration. with
a maximum Dotential sudace Dressure of ¥reater than 3.000 Dsi
[REQUIRING A BOP STACK EQUAL TO OR GREATER THAN API
SK], at least four preventers, including
(i) two equipped with pipe rams that fit the size of the drill
pipe su:[,] tubing[, OR CASING] being used, except that pipe rams
need not be sized to BHAs and drill collars;
(ii) one with blind rams, except that a subsea BOPE
assembly must have blind/shear rams in place of blind rams; and
(iii) one annular type;
(C) for a casin2 or liner oDeration. with a maximum Dotential
surface Dressure of 2reater than 3.000 Dsi. at least four Dreventers.
includin2
(0 one eauiDDed with DiDe rams that fit the size of the
drill DiDe or tubin2 bein2 used. exceDt that DiDe rams need not
be sized to BRAs and drill collars:
(ii) one eauiD~ed with DiDe rams that fit the size of
casin2 or liner bein2 used:
(iii) one with blind rams. exceDt that a subsea BOPE
assemblv must have blind/shear rams in Dlace of blind rams:
and
(iv) one annular tvDe:
20 AAC 25.285(c)(3) is amended to read:
(3) in coiled tubing unit operations,
(A) for an operation with a maximum potential sudace Dressure
of 5.000 Dsi or less [REQUIRING A BOP STACK EQUAL TO OR LESS
THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and
blinding operations on the coiled tubing in service;
(ii) a high pressure pack-off, stripper, or annular type
preventer;
10
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MISCELLANEO' BOARDS
(ìiì) if pressure deployment of tools is planned, a riser or
lubricator sized to the BHA and providing for pressure integrity
ftom the BOPE rams to the high pressure pack-off, stripper, or
annular type preventer; and
(iv) at least one preventer equipped with pipe rams that fit
the size of the tubing, liner, or casing being used, except that pipe
rams need not be sized to BRAs and drill collars; and
(B) for an operation. other than a casine or liner otJeration. with
a maximum ootential suñace oressure of ereater than 5.000 osi
[REQUIRING A BOP STACK GREATER THAN API SK],
(i) BOPE rams providing for pipe, slip, cutting, and
blinding operations on the coiled tubing in service;
(ii) two high pressure pack-off's, strippers, or annular type
preventers;
(iii) if pressure deployment of tools is planned, a riser or
lubricator sized to the BHA and providing for pressure integrity
from the BOPE rams to the high pressure pack-off, stripper, or
annular type preventer; and
(iv) at least two preventers equipped with pipe rams that fit
the size of the tubing[, LINER, OR CASING] being used, except
that pipe rams need not be sized to BHAs and drill collars;
(C) for a casine or liner ooeration with a maximum potential
suñace oressure of 3reater than 5.000 psi.
(n DOPE rams orovidine for oioe. slip. cuttinJ. and
blindine ooerations on the coiled tubin3 in service:
(ii) two hieh oressure oack-otTs. striooen. or annular
tv{)e oreventers:
(iii) if oressure deolovment of tools is olanned. a riser or
lubricator sized to the BRA and orovidine for oressure
inteeritv from the DOPE rams to the hieh oressure oack-otT.
striooer. or annular tvoe oreventer:
(iv) at least one oreventer eauiooed with pioe rams that
fit the size of the tubine beine used. exceot that oioe rams need
not be sized to DRAs and drill collars: and
11
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MISCELLANEOI BOARDS
tv) at least one preventer equipped with pipe rams that
fit the size of casine or liner beine used:
20 AAC 25.285(c)(10) is amended to read:
(10) a choke manifold equipped with
(C) immediately upstream of each choke, at least one full-opening
for an operation with a maximum potential surface pressure of 3.000
psi or less [REQUIRING A BOP STACK LESS THAN API 5K], or at
least two full-opening valves for an operation requiring a BOP stack equal
to or greater than API 5K; and
(D) a bypass line, at least two inches in nominal diameter, with at
least one full-opening valve for an operation with a maximum potential
surface pressure of 3.000 psi or less [REQUIRING A BOP STACK
LESS THAN API 5K], or at least two full opening valves for an operation
requiring a BOP stack equal to or greater than API 5K.
20 AAC 25.285(f) is amended to read:
(f) The BOPE must be tested as follows:
(1 ) when installed, repaired, or changed, and at least once a week
thereafter, BOPE, including emergency valves and choke manifolds, must be
function pressure-tested, using a non-compressible fluid, to the required working
pressure specified in an approved Application for Sundry Approvals under 20
AAC 25.280 or, if that application is not required, to the maximum potential
surface pressure to which the BOPE may be subjected, except that an annular type
preventer need not be tested to more than 50 percent of its rated working pressure;
(2) if BOP [SEALING RAM TYPE] equipment has been used for well
control or other equivalent purpose. or when routine use of the equipment
may have compromised its effectiveness, the equipment [IT] must be function
pressure-tested before the next wellbore entry, using a non-compressible fluid, to
the required working pressure specified in an approved Application for Sundry
Approvals under 20 AAC 25.280 or, if that application is not required, to the
maximum potential surface pressure to which that equipment may be subjected,
except that an annular type preventer need not be tested to more than 50 percent
of its rated working pressure;
(3) non-sealing equipment must be function-tested weekly, after a repair
or change, and after an action that disconnects the hydraulic system lines from the
BOPE, except that if the workstring is continuously in the well, function-testing
12
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MISCELLANEO' BOARDS
must be perfonned as soon as possible after the workstring is pulled out of the
well and the BHA clears the BOP;
(4) for each DOPE test durin!! drillin!! and comDletion oDerations.
variable bore rams must be function ~ressure tested to the required Dressure
on the smallest 0» and lal'2est 0» tubulars that may be used durin!! that
test cycle. except that variable bore rams need not be tested on DRAs and
drill collars:
œ DOPE test results must be recorded as part of the daily record required
by 20 AAC 25.070(1). and must be Drovided to the commission. in a format
apDroved by the commission. within five tw&-davs after completin2 the test:
í!l.[(5)] at least 24 hours notice of each DOPE function pressure test must
be provided so that a representative of the commission can witness the test;[.]
ill the ODerator shall reDO" to the commission within 24 hours any
instance of BOPE use to Drevent the flow of fluids from a well.
History: Eff 4/2/86, Register 97; am 11/7/99, Register 152; am ~ ~ ~ Register
~
Authority: AS 31.05.030
20 AAC 25.286(d)(1) is amended to read:
(1) at least one positive seal manual or hydraulic valve or blind ram
flanged to the wellhead or tree;
(2) in rotary drilling rig operations,
(A) for an operation with a maximum potential suñace Dressure
of 5.000 Dsi or less [REQUIRING A BOP STACK EQUAL TO OR LESS
THAN API 5K], at least three preventers, including
(i) one equipped with pipe rams that fit the size of drill
pipe, tubing, liner or casing being used, except that pipe rams need
not be sized to bottom-hole assemblies (BRAs) and drill collars;
(ii) one with blind rams, except that a subsea BOPE
assembly must have blind/shear rams in place of blind rams; and
(iii) one annular type; and
(B) for an operation. other than a casin!! or liner oDeration. with
a maximum Dotential surface Dressure of !!reater than 5.000 Dsi
13
Register -'
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MISCELLANEOI BOARDS
[REQUIRING A BOP STACK GREATER THAN API 5K], at least four
preventers, including
(i) two equipped with pipe rams that fit the size of the drill
pipe or[,] tubing[, OR CASING] being used, except that pipe rams
need not be sized to BRAs and drill collars;
(ii) one with blind rams, except that a subsea BOPE
assembly must have blind/shear rams in place of blind rams; and
(iii) one annular type;
(C) for a casin2 or liner operation with a maximum potential
surface pressure of 2reater than 5.000 psi. at least four preventen.
includin2
(0 one eauipped with pipe rams that fit the size of the
drill pipe or tubin2 bein2 used. except that pipe rams need not
be sized to BRAs and drill collars:
(ii) one eauipped with pipe rams that fit the size of
c~sin2 or liner bein2 used:
(iii) one with blind rams. except that a subsea BOPE
assemblv must have blind/shear rams in place of blind rams:
and
(iv) one annular type:
20 AAC 25.286(d)(3) is amended to read:
(3) in coiled tubing unit operations,
(A) for an operation with a maximum potential surface pressure
of 5.000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS
THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and
blinding operations on the coiled tubing in service;
(ii) a high pressure pack-off, stripper, or annular type
preventer; and
iii) if pressure deployment of tools is planned, a riser or
lubricator sized to the BRA and providing for pressure integrity
14
Register -'
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MISCELLANEOI BOARDS
ITom the BOPE rams to the high pressure pack-off, stripper, or
annular type preventer; and
(B) for an operation with a maximum potential surface pressure of
greater than 5,000 psi [REQUIRING A BOP STACK GREATER THAN
API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and
blinding operations on the coiled tubing in service;
(ii) two high pressure pack-offs, strippers, or annular type
preventers; and
(iii) if pressure deployment of tools is planned, a riser or
lubricator sized to the BRA and providing for pressure integrity
ITom the BOPE rams to the high pressure pack-off, stripper, or
annular type preventer;
20 AAC 25.286(e) is amended to read:
(e) The operator shall test the BOPE assembly as follows:
(1) at least once a week, and after each [USE,] repair, [OR] change, or use
for well control or other equivalent ourpose. or when routine use of the
eQuioment may have comoromised its effectiveness. BOP[E] equioment [PIPE
AND BLIND RAMS] must be function pressure-tested, using a non-compressible
fluid, to the required working pressure specified in an approved Application for
Sundry Approvals under 20 AAC 25.280 or, if that application is not required, to
the maximum potential surface pressure to which they may be subjected, except
that the annular type preventer need not be tested to more than 50 percent of its
rated working pressure;
(2) after each installation ofBOPE or other well control equipment, the
equipment must be pressure-tested, before wellbore entry, to the maximum
potential wellhead pressure to which it may be subjected, except that when testing
against the annular type preventer, pressure testing need not exceed 50 percent of
the rated working pressure of the annular type preventer;
(3) non-sealing equipment must be function-tested weekly, after a repair
or change, and after an action that disconnects the hydraulic system lines ITom the
BOPE, except that if the workstring is continuously in the well, function-testing
must be performed as soon as possible after the workstring is pulled out of the
well and the BRA clears the BOP;
(4) after each well installation of the BOPE, the BOPE hydraulic
connections to the rams must be visually verified before wellbore entry;[.]
15
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MISCELLANEOI BOARDS
(5) for each DOPE test durine drilline and comDletion oDerations.
variable bore rams must be function oressure tested to the required pre~sure
on the smallest OD and lan!est OD tubulars that mav be used durine that
test cycle. exceot that variable bore rams need not be tested on DBAs and
drill collars:
(6) DOPE test results must be recorded as part of the daily record
required bv 20 AAC 25.070(1). and must be orovided to the commission. in a
format aooroved bv the commission. within five twe-days after comoletine
the test:
(7) at least 24 hours notice of each DOPE function oressure test must
be orovided so that a representative of the commission can witness the test:
(8) the ooerator shall reoort to the commission within 24 hours any
instance of BOPE use to ~revent the flow of fluids from a well.
History: Eff 11/7/99, Register 152; am--.!--.! ----' Register --..--J
Authority: AS 31.05.030
16
.
.
MMS regulation reference related to testing ram bonnets
after installing casing rams.
MMS Regulations
30CFR Part 250
Subpart D Oil & Gas Drilling Operations
Sec. 250.451 What must I do in certain situations
involving BOP equipment or systems?
The table in this section describes actions that
lessees must take when certain situations occur with BOP
systems during drilling activities.
-----------------------------------------------------------
If you e?counter the following situation: Then you must...
-----------------------------------------------------------
(f) Install casing rams in a BOP stack....Test the ram
bonnets before running casing.
Register ----y
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MISCELLANEOulOARDS
-,- ~
20 AAC 25.005(c)(4)(A) is amended to read:
(A) the maximum downhole pressure that may be encountered,
criteria used to determine it, and maximum potential surface pressure
based on a pressure 2radient to surface of 0.1 psi per foot of true
vertical depth. unless the commission approves a different pressure
2radient that provides aft equallY eff-eetive ' .'. means of
determinin2 the maximum potential surface pressure [11ETHANE
GRADIENT];
(Eff 4/13/80, Register 74; am 4/2/86, Register 97; am 11/7/99, Register 152; am
6/412000, Register 154; am 1/5/2006, Register 177; am_/_/_, Register--.-J
Authority: AS 31.05.030 AS 31.05.090
20 AAC 25.035(e)(1) is amended to read:
(1) in rotary drilling rig operations,
(A) for an operation with a maximum potential surface pressure
of 3.000 psi or less [REQUIRING A BOP STACK LESS THAN API
5K], BOPE must have at least three preventers, including
(i) one equipped with pipe rams that fit the size of drill
pipe, tubing, liner or casing being used, except that pipe rams need
not be sized to bottom-hole assemblies (BRAs) or drill collars;
(ii) one with blind rams, except that a subsea BOPE
assembly must have blind/shear rams in place of blind rams; and
(iii) one annular type; and
(B) for an operation. other than a casin2 or liner operation. with
a maximum potential surface pressure of 2reater than 3.000 psi
[REQUIRING A BOP STACK EQUAL TO OR GREATER THAN API
5K], BOPE must have at least four preventers, including
(i) two equipped with pipe rams that fit the size of the driB
pipe ill: tubing [OR CASING] being used, except that pipe rams
need not be sized to BRAs and drill collars;
(ii) one with blind rams, except that a subsea BOPE
assembly must have blind/shear rams in place of blind rams; and
(iii) one annular type;
Register _,
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MISCELLANEOulOARDS
(C) for a casin2 or liner operation with a maximum potential
surface pressure of 2reater than 3.000 psi. DOPE must have at least
four Dreventers. including
(i) one eauipped with piDe rams that fit the size of the
drill pipe or tubin2 bein2 used. except that pipe rams need not
be sized to BRAs and drill collars;
(in one eauipped with pipe rams that fit the size of
casin2 or liner being used;
(iii) one with blind rams. except that a subsea BOPE
assemblv must have blind/shear rams in place of blind rams;
and
(iv) one annular tyDe;
20 AAC 25.035(e)(2) is amended to read:
(2) in coiled tubing unit operations, the well control equipment must
include
(A) for an operation with a maximum Dotential surface pressure
of 5.000 Dsi or less [REQUIRING A BOP STACK EQUAL TO OR LESS
THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and
blinding operations on the coiled tubing in service;
(ii) a high pressure pack-off, stripper, or annular type
preventer;
(iii) if pressure deployment of tools, tubing, liner, or casing
is planned, a riser or lubricator sized to the BHA and providing for
pressure integrity ITom the BOPE rams to the high pressure pack-
off; stripper, or annular type preventer; and
(iv) at least one preventer equipped with pipe rams that fit
the size of tubing, liner, or casing being used, except that pipe rams
need not be sized to BHAs and drill collars; and
(B) for an operation. other than a casin2 or liner oDeration. with
a maximum potential surface Dressure of 2reater than 5.000 psi
[REQUIRING A BOP STACK GREATER THAN API 5K],
2
Register ----------y
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MISCELLANEoutOARDS
(i) BOPE rams providing for pipe, slip, cutting, and
blinding operations on the coiled tubing in service;
(ii) two high pressure pack-offs, strippers, or annular type
preventers;
(iii) if pressure deployment of tools, tubing, liner, or casing
is planned, a riser or lubricator sized to the BHA and providing for
pressure integrity ITom the BOPE rams to the high pressure pack-
off, stripper, or annular type preventer; and
(iv) at least two preventers equipped with pipe rams that fit
the size of tubing[, LINER, OR CASING] being used, except that
pipe rams need not be sized to BHAs and drill collars;
(C) for a casin2 or liner operation with a maximum potential
surface pressure of 2reater than 5.000 psi.
in DOPE rams providin2 for pipe. slip. cuttiD!!. and
blindin2 operations on the coiled tubin2 in service:
(ii) two hi2h pressure pack-offs. strippers. or annular
type preventers:
(iii) if pressure deplovment of tools. tubin2. liner. or
casin2 is planned. a riser or lubricator sized to the BRA and
providin2 for pressure inte2rity from the BOPE rams to the
hi2h pressure pack-off. stripper. or annular type preventer:
(iv) at least one preventer equipped with pipe rams that
fit the size of the tubin2 bein2 used. except that pipe rams need
not be sized to BRAs and drill collars: and
(v) at least one preventer equipped with pipe rams that
fit the size of casin2 or liner bein2 used.
(4) a BOPE assembly must include
(H) a choke manifold equipped with
(iii) immediately upstream of each choke, at least one fi.1ll-
opening valve for an operation
3
Register -----'
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MISCELLANEOulOARDS
[REQUIRING A BOP
ST ACK LESS THAN API 5K], or at least two full-opening valves
for an operation requiring a BOP stack equal to or greater than API
5K; and
(iv) a bypass line, at least the diameter of the choke line,
with at least one full-opening valve for an operation
[REQUIRING A BOP STACK LESS THAN API 5K], or at least
two full-opening valves for an operation requiring a BOP stack
equal to or greater than API 5K;
20 AAC 25.035(e)(1O) is amended to read:
(10) the BOPE must be tested as follows:
(A) when installed, repaired, or changed on a development or
service well and at time intervals not to exceed each 14 days thereafter,
BOPE, including kelly valves, emergency valves, and choke manifolds,
must be function pressure-tested to the required working pressure
specified in the approved Permit to Drill, using a non-compressible fluid,
except that an annular type preventer need not be tested to more than 50
percent of its rated working pressure; however, the commission will
require that the BOPE be function pressure-tested weekly, if the
commission determines that a weekly BOPE pressure test interval is
indicated by a particular drilling rig's BOPE performance;
(B) when installed, repaired, or changed on an exploratory or
stratigraphic test well and at least once a week thereafter, BOPE, including
kelly valves, emergency valves, and choke manifolds, must be function
pressure-tested to the required working pressure specified in the approved
Permit to Drill, using a non-compressible fluid, except that an annular type
preventer need not be tested to more than 50 percent of its rated working
pressure;
(C) if BOP [SEALING RAM TYPE] equipment
ha oS been used for well control or other equivalent purpose. or when
routine use of the equipment may have compromised its effectiveness.
the equipment [IT] must be function pressure-tested, before the next
wellbore entry, to the required working pressure specified in the approved
Permit to Drill, using a non-compressible fluid, except that an annular type
preventer need not be tested to more than 50 percent of its rated working
pressure;
(D) BOP ram and annular components except blind rams must be
function-tested weekly, and all BOP ram and annular components must be
4
Register ---y
~oo
MISCELLANEOUttOARDS
function-tested after an action that disconnects the hydraulic system lines
rrom the BOPE, except that if the workstring is continuously in the well,
function~testing of blind rams must be performed as soon as possible after
the workstring is pu]]ed out of the we]] and tbe BRA clears tbe BOP;
(E) for each DOPE test durint! drillint! and completion
operations. variable bore rams must be function pressure tested to the
required pressure on the smallest outside diameter (0)>) and laNest
0» tubulars that may be used durint! that test cvcle. except that
variable bore rams need not be tested on BRAs and drill collars;
æ BOPE test results must be recorded as part of the daily
record required by 20 AAC 25.070(1), and must be provided to the
commission. in a format approved bv the commission. within twi)-p
days after completint! the test;
flli·· [(F)) at least 24 hours notice of each BOPE :fi.mction
pressure test must be provided to the commission so that a commission
representative can witness the test;
History: Eff 4/13/80, Register 74; am 2/22/81, Register 77; am 4/2/86, Register 97; am
1117/99, Register 152; am 10/24/2004, Register 172; am_/_/_, Register----.--J
Authority: AS 31.05.030
20 AAC 25.036(c)(1) is amended to read:
(1) in rotary drilling rig operations,
(A) for an operation with a maximum potential surface pressure
of 5.000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS
THAN API 5K], BOPE must have at least three preventers, including
(i) one equipped with pipe rams that fit the size of drill
pipe, tubing, liner, or casing being used, except that pipe rams need
not be sized to bottom-hole assemblies (BHAs) and drill collars;
(ii) one with blind rams, except that a subsea BOPE
assembly must have blind/shear rams in place of blind rams; and
(iii) one annular type; and
5
Register --y
_00
MIS CELLANEOU.OARDS
(B) for an operation other than a casint! or liner operation. with
a maximum potential surface pressure of t!reater than 5.000 psi
[REQUIRING A BOP STACK GREATER THAN API 5K], BOPE must
have at least four preventers, including
(i) two equipped with pipe rams that tit the size of the drill
pipe or[,] tubing[, OR CASING] being used, except that pipe rams
need not be sized to BRAs and drill collars;
(ii) one with blind rams, except that a subsea BOPE
assembly must have blind/shear rams in place of blind rams; and
(iii) one annular type;
(C) for a casint! or liner operation with a maximum potential
surface pressure of t!reater than 5.000 psi. BOPE must have at least
four preventers. includint!
(n one eQuipped with pipe rams that fit the size of the
drill pipe or tubint! beint! used. except that pipe rams need not
be sized to BRAs and drill collars;
em one eQuipped with pipe rams that fit the size of
casint! or liner beint! used;
(iii) one with blind rams. exceot that a subsea ROPE
assemblv must have blind/shear rams in place of blind rams;
and
(iv) one annular tvpe:
20 AAC 25.036(c)(2) is amended to read:
include
(2) in coiled tubing unit operations, the well control equipment must
(A) for an operation with a maximum potential surface pressure
of 5.000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS
THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and
blinding operations on the coiled tubing in service;
(ii) a high pressure pack-off, stripper, or annular type
preventer;
6
..
Register ----y
_00
MISCELLANEOulOARDS
(iii) if pressure deployment of tools, tubing, liner, or casing
is planned, a riser or lubricator sized to the BHA and providing for
pressure integrity from the BOPE rams to the high pressure pack-
off, stripper, or annular type preventer; and
(iv) at least one preventer equipped with pipe rams that fit
the size of the tubing, liner, or casing being used, except that pipe
rams need not be sized to BRAs and drill collars; and
(B) for an operation. other than a casine or liner operation with
a maximum potential surface pressure of ereater than 5.000 psi
[REQUIRING A BOP STACK GREATER THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and
blinding operations on the coiled tubing in service;
(ii) two high pressure pack-offs, strippers, or annular type
preventers;
(iii) if pressure deployment of tools, tubing, liner, or casing
is planned, a riser or lubricator sized to the BRA and providing for
pressure integrity from the BOPE rams to the high pressure pack-
off, stripper, or annular type preventer; and
(iv) at least two preventers equipped with pipe rams that fit
the size of the tubing[, LINER, OR CASING] being used, except
that pipe rams need not be sized to BHAs and drill collars;
(C) for a casine or liner operation with a maximum potential
surface pressure of ereater than 5.000 psi.
(i) BOPE rams providine. for DiDe. sliD. cuttine.. and
blindine. oDerations on the coiled tubine in service:
(ii) two hieh pressure pack-offs. striPDen. or annular
type preventers:
(iii) if pressure deplovment of tools. tubine. liner. or
casine. is planned. a riser or lubricator sized to the BRA and
providine for pressure intee.rity from tbe BOPE rams to tbe
hie.h pressure pack-off. stripper. or annular type preventer:
(iv) at least one preventer eqUiDPed with DiDe rams that
fit the size of the tubine. beine. used. except that pipe rams need
not be sized to BRAs and drill collars: and
7
Register ---y
_00
MIS CELLANEoutOARDS
(v) at least one preventer equipped with pipe rams that
fit the size of casin!! or liner bein!! used:
20 AAC 25.036(d) is amended to read:
(d) A BOPE assembly must be tested as follows:
(1) when installed, repaired, or changed on a development or service well
and at time intervals not to exceed each 14 days thereafter, BOPE, including kelly
valves, emergency valves, and choke manifolds, must be function pressure-tested
to the required working pressure specified in the approved Permit to Drill, using a
non-compressible fluid, except that an annular type preventer need not be tested
to more than 50 percent of its rated working pressure; however, the commission
will require that the BOPE be function pressure-tested weekly, if the commission
determines that a weekly BOPE pressure test interval is indicated by a particular
drilling rig's BOPE performance;
(2) when installed, repaired, or changed on an exploratory or stratigraphic
test well and at least once a week thereafter, BOPE, including kelly valves,
emergency valves, and choke manifolds, must be function pressure-tested to the
required working pressure specified in the approved Permit to Drill, using a non-
compressible fluid, except that an annular type preventer need not be tested to
more than 50 percent of its rated working pressure;
(3) other well control equipment must be pressure-tested to the maximum
potential wellhead pressure after each installation of the well control equipment
and before wel1bore entry, except that an annular type preventer need not be
tested to more than 50 percent of its rated working pressure;
(4) if BOP [SEALING RAM TYPE] equipment has been used for well
control or other equivalent purpose. or when routine use of the equipment
may have compromised its effectiveness. the equipment [IT] must be function
pressure-tested, before the next wellbore entry, to the required working pressure
specified in the approved Permit to Drill, using a non-compressible fluid, except
that an annular type preventer need not be tested to more than 50 percent of its
rated working pressure;
(5) BOP ram and annular components except blind rams must be functÎon-
tested weekly, and all BOP ram and annular components must be function-tested
after an action that disconnects the hydraulic system lines fÌ"om the BOPE, except
that if the workstring is continuously in the well, function-testing of blind rams
must be performed as soon as possible after the workstring is pulled out of the
wel1 and the BRA clears the BOP;
(6) for each BOPE test durin!! drillins: and completion operations.
variable bore rams must be function pressure tested to the required pressure
8
Register ---'
'0
MISCELLANEOU.OARDS
on tbe smallest 0» and la~est 0» tubulaJ'S tbat may be used durin!! tbat
test cycle.. exceot that variable bore rams need not be tested on BRAs and
drill collars:
ill BOPE test results must be recorded as part of the daily record required
by 20 AAC 25.070(1). and must be provided to tbe commission. in a format
approved by the commission. within 4 days after completin!! the test:
!n,[(7)] at least 24 hours notice of each BOPE function pressure test must
be provided to the commission so that a representative of the commission can
witness the test.
History: EfT 11/7/99, Register 152; am 10/24/2004, Register 172; am~~---,
Register ~
Autbority: AS 31.05.030
(b) The Application for Sundry Approval must set out
20 AAC 25.285(c)(2) is amended to read:
(2) in rotary drilling rig operations,
(A) for an operation with a maximum potential surface pressure
of 3.000 psi or less [REQUIRING A BOP STACK LESS THAT API SKI,
at least three preventers, including
(i) one equipped with pipe rams that fit the size of drill
pipe, tubing, liner or casing being used, except that pipe rams need
not be sized to bottom-hole assemblies (BHAs) and drill collars;
(ii) one with blind rams, except that a subsea BOPE
assembly must have blind/shear rams in place of blind rams; and
9
Register ----'
~oo
MISCELLANEOUttOARDS
(iii) one annular type; and
(B) for an operation. other than a casin2 or liner operation. with
a maximum potential surface pressure of 2reater than 3.000 psi
[REQUIRING A BOP STACK EQUAL TO OR GREATER THAN API
SK], at least four preventers, including
(i) two equipped with pipe rams that fit the size of the drill
pipe m:[,] tubing[, OR CASING] being used, except that pipe rams
need not be sized to BRAs and drill collars;
(ii) one with blind rams, except that a subsea BOPE
assembly must have blind/shear rams in place of blind rams; and
(iii) one annular type;
(C) for a casin2 or liner operation. with a maximum potential
suñace pressure of 2reater than 3.000 psi. at least four preventers.
includin2
(n one equipped with pipe rams that fit the size of the
drill pipe or tubin2 bein2 used. except that pipe rams need not
be sized to BRAs and drill collars:
(m one equipped with pipe rams that fit the size of
casin2 or liner bein2 used:
(iii) one with blind rams. except that a subsea BOPE
assemblv must have blind/shear rams in place of blind rams:
and
(iv) one annular type:
20 AAC 25.285(c)(3) is amended to read:
(3) in coiled tubing unit operations,
(A) for an operation with a maximum potential suñace pressure
of 5.000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS
THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and
blinding operations on the coiled tubing in service;
(ii) a high pressure pack -off, stripper, or annular type
preventer;
10
Register _,
_00
MIS CELLANEOulOARDS
(iii) if pressure deployment of tools is planned, a riser or
lubricator sized to the BHA and providing for pressure integrity
ftom the BOPE rams to the high pressure pack-off, stripper, or
annular type preventer; and
(iv) at least one preventer equipped with pipe rams that fit
the size of the tubing, liner, or casing being used, except that pipe
rams need not be sized to BHAs and drill collars; and
(B) for an operation. other than a casim~ or liner operation. with
a maximum potential surface pressure of !!:reater than 5.000 psi
[REQUIRING A BOP STACK GREATER THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and
blinding operations on the coiled tubing in service;
(ii) two high pressure pack-offs, strippers, or annular type
preventers;
(iii) if pressure deployment of tools is planned, a riser or
lubricator sized to the BHA and providing for pressure integrity
ftom the BOPE rams to the high pressure pack-off, stripper, or
annular type preventer; and
(iv) at least two preventers equipped with pipe rams that fit
the size of the tubing(, LINER, OR CASING] being used, except
that pipe rams need not be sized to BHAs and drill collars;
(C) for a casin!!: or liner operation with a maximum potential
surface pressure of ~reater than 5.000 psi.
(i) BOPE rams providin!!: for pipe. slip. cuttin2. and
blindin!!: operations on the coiled tubin!!: in service:
(ii) two hi!!:h pressure pack-ofTs. strippers. or annular
type preventers:
(iii) if pressure deployment of tools is planned. a riser or
lubricator sized to the BBA and providin!!: for pressure
inteIDity from tbe BOPE rams to the hi!!:h nressure nack-otT.
stripper. or annular type preventer:
(iv) at least one preventer equipped with pipe rams that
fit the size of the tubin!!: bein!!: used. exce~t that {)ipe rams need
not be sized to BRAs and drill collars; and
11
Register _,
.00
MISCELLANEOulOARDS
(v) at least one preventer equipped with pipe rams that
fit the size of casinS! or liner beinS! used;
(10) a choke manifold equipped with
(C) immediately upstream of each choke, at least one fhl1-opening
tor an operation
[REQUIRING A BOP STACK LESS THAN API 5K], or at
least two full-opening valves for an operation requiring a BOP stack equal
to or greater than API 5K; and
(D) a bypass line, at least two inches in nominal diameter, with at
least one full-opening valve for an operation
[REQUIRING A BOP STACK
LESS THAN API 5K], or at least two full opening valves for an operation
requiring a BOP stack equal to or greater than API 5K.
20 AAC 25.285(f) is amended to read:
(f) The BOPE must be tested as follows:
(1) when installed, repaired, or changed, and at least once a week
thereafter, BOPE, including emergency valves and choke manifolds, must be
function pressure-tested, using a non-compressible fluid, to the required working
pressure specified in an approved Application for Sundry Approvals under 20
AAC 25.280 or, if that application is not required, to the maximum potential
surface pressure to which the BOPE may be subjected, except that an annular type
preventer need not be tested to more than 50 percent of its rated working pressure;
(2) if BOP [SEALING RAM TYPE] equipment has been used for well
control or other equivalent purpose. or when routine use of the equipment
may have compromised its effectiveness, the equipment [IT] must be function
pressure-tested before the next well bore entry, using a non-compressible fluid, to
the required working pressure specified in an approved Application for Sundry
Approvals under 20 MC 25.280 or, if that application is not required, to the
maximum potential surface pressure to which that equipment may be subjected,
except that an annular type preventer need not be tested to more than 50 percent
of its rated working pressure;
(3) non-sealing equipment must be function-tested weekly, after a repair
or change, and after an action that disconnects the hydraulic system lines from the
BOPE, except that if the workstring is continuously in the well, function-testing
12
Register ~
_00
MISCELLANEOulOARDS
must be performed as soon as possible after the work string is pulled out of the
well and the BHA clears the BOP;
(4) for each BOPE test durin2 driUin~ and completion operations.
variable bore rams must be function pressure tested to the reauired pressure
on the smallest OD and lar;est OD tubulars that may be used durin2 that
test cycle. except that variable bore rams need not be tested on BRAs and
drill collars;
æ BOPE test results must be recorded as part of the daily record required
by 20 AAC 25.070(1). and must be provided to the commission. in a format
approved by the commission. within .. ...... twtHIays after completin2 the test;
í§l.[(5)] at least 24 hours notice of each BOPE function pressure test must
be provided so that a representative of the commission can witness the test;[.]
ill the onerator shall report to the commission within 24 hours any
instance of BOPE use to prevent the flow of fluids from a well.
History: Eff 4/2/86, Register 97; am 11/7/99, Register 152; am~~~ Register
--.J
Authority: AS 31.05.030
20 AAC 25.286(d)(I) is amended to read:
(1) at least one positive seal manual or hydraulic valve or blind ram
flanged to the wellhead or tree;
(2) in rotary drilling rig operations,
(A) for an operation with a maximum potential surface pressure
of 5.000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS
THAN API 5K], at least three preventers, including
(i) one equipped with pipe rams that fit the size of drill
pipe, tubing, liner or casing being used, except that pipe rams need
not be sized to bottom-hole assemblies (BHAs) and drill collars;
(ii) one with blind rams, except that a subsea BOPE
assembly must have blind/shear rams in place of blind rams; and
(iii) one annular type; and
(B) for an operation. other than a casin2 or liner operation. with
a maximum potential surface pressure of 2reater than 5.000 psi
13
, .
Register ~
_00
MISCELLANEOulOARDS
[REQUIRING A BOP STACK GREATER THAN API 5K], at least four
preventers, including
(i) two equipped with pipe rams that fit the size of the drill
pipe or[,] tubing[, OR CASING] being used, except that pipe rams
need not be sized to BRAs and drill collars;
(ii) one with blind rams, except that a subsea BOPE
assembly must have blind/shear rams in place of blind rams; and
(iii) one annular type;
(C) for a casine: or liner operation with a maximum potential
suñace pressure of e:reater than 5.000 psi. at least four preventers.
includine:
(i) one eauipped with pipe rams that fit the size of the
drill pipe or tubine: bein~ used. except that pipe rams need not
be sized to BRAs and drill collars;
(ii) one eauipped with pipe rams that fit the size of
casin~ or liner beine: used;
(iii) one with blind rams. except that a subsea DOPE
assemblv must have blind/shear rams in place of blind rams;
and
(iv) one annular type;
20 AAC 25.286(d)(3) is amended to read:
(3) in coiled tubing unit operations,
(A) for an operation with a maximum potential surface pressure
of 5.000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS
THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and
blinding operations on the coiled tubing in service;
(ii) a high pressure pack -off, stripper, or annular type
preventer; and
iii) if pressure deployment of tools is planned, a riser or
lubricator sized to the BRA and providing for pressure integrity
14
Register ---'
_00
MISCELLANEOulOARDS
/ ~
from the BOPE rams to the high pressure pack-ofT, stripper, or
annular type pre venter; and
(B) for an operation with a maximum potential surface pressure of
greater than 5,000 psi [REQUJRING A BOP STACK GREATER THAN
API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and
blinding operations on the coiled tubing in service;
(ii) two high pressure pack -offs, strippers, or annular type
preventers; and
(iii) if pressure deployment of tools is planned, a riser or
lubricator sized to the BHA and providing for pressure integrity
from the BOPE rams to the high pressure pack-ofT, stripper, or
annular type preventer;
20 AAC 25.286(e) is amended to read:
( e) The operator shall test the BOPE assembly as follows:
(1) at least once a week, and after each [USE,] repair, [OR] change, or use
for well control or other equivalent purpose. or when routine use of the
e9uioment may have compromised its effectiveness. BOP[E] equipment [PIPE
AND BLIND RAMS] must be function pressure-tested, using a non-compressible
fluid, to the required working pressure specified in an approved Application for
Sundry Approvals under 20 AAC 25.280 or, if that application is not required, to
the maximum potential surface pressure to which they may be subjected, except
that the annular type preventer need not be tested to more than 50 percent of its
rated working pressure;
(2) after each installation ofBOPE or other well control equipment, the
equipment must be pressure-tested, before well bore entry, to the maximum
potential wellhead pressure to which it may be subjected, except that when testing
against the annular type preventer, pressure testing need not exceed 50 percent of
the rated working pressure of the annular type preventer;
(3) non-sealing equipment must be function-tested weekly, after a repair
or change, and after an action that disconnects the hydraulic system lines from the
BOPE, except that if the workstring is continuously in the well, function-testing
must be performed as soon as possible after the workstring is pulled out of the
well and the BHA clears the BOP;
(4) after each well installation of the BOPE, the BOPE hydraulic
connections to the rams must be visually verified before wellbore entry;[.]
15
Register _,
_00
MISCELLANEouttOARDS
~ .
(5) for each BOPE test durin!! drillin!! and completion operations.
variable bore rams must be function pressure tested to the reauired pressure
on the smallest on and lal1!est on tubulars that may be used durin!! that
test cvcle. except that variable bore rams need not be tested on BRAs and
drill collars:
(6) BOPE test results must be recorded as part of the daily record
reauired by 20 AAC 25.0700). and must be provided to the commission. in a
format approved by the commission. within! . tw6-days after comvletin~
the test:
(7) at least 24 hours notice of each BOPE function pressure test must
be provided so that a representative of the commission can witness the test:
(8) the operator shaU report to the commission within 24 hours any
instance of DOPE use to prevent the flow of fluids from a well.
History: Eff. 1117/99, Register 152; am~~--, Register ~
Authority: AS 31.05.030
16
.
.
MMS regulation reference related to testing ram bonnets
after installing casing rams.
MMS Regulations
30CFR Part 250
Subpart D Oil & Gas Drilling Operations
Sec. 250.451 What must I do in certain situations
involving BOP equipment or systems?
The table in this section describes actions that
lessees must take when certain situations occur with BOP
systems during drilling activities.
-----------------------------------------------------------
If you encounter the following situation: Then you must...
------------------------------------------~----------------
(f) Install casing rams in a BOP stack.. ..Test the ram
bonnets before running casing.
[Fwd: Tomorrow's Public Hearing]
.
"
Subject: [Fwd: Tomorrow's Public Hearing]
From: John Norman <john_norman@admin.state.ak.us>
Date: Tue, 29 Aug 2006 16:29:38 ~0800
To: Jödy J Còlpmhi¢ <jodyjcolombie@admin.state.ak.ûs>
-------- Original Message --------
Subject:Tomorrow's Public Hearing
Date:Tue, 29 Aug 2006 13:15:36 -0800
From:Kara Moriarty <moriarty(G}aoga.org>
Reply- T o:moriarty(G}aoga.org
Organization:Alaska Oil & Gas Association
To:'John Norman' <john norman(G}admin.state.ak.us>, 'Dan Seamount'
<dan seamount(G}admin.state.ak.us>, 'Cathy Foerster'
<cathy foerster(G}admin.state.ak. us>
TO: AOGCC Commissioners
I will be unable to attend your monthly meeting tomorrow due to a conflict here at our office.
I did want to let you know that AOGA will be providing supporting comments and testimony at the
hearing on August 31 in regards to the proposed regulation changes. We appreciate the Commission's
efforts in providing clarity to these regulations. We will be offering additional minor edits and
suggestions for your consideration, and we will review these suggestions in testimony and in writing.
Industry folks have discussed these proposed minor edits and suggestions with AOGCC staff.
I look forward to seeing you all on Thursday.
Kara
Kara Moriarty
External Affairs Manager
Alaska Oil & Gas Association
121 W. Fireweed Lane, #207
Anchorage, AK 99503
(907) 272-1481
Cell: (907) 441-5272
Fax: (907)279-8114
moriarty(G}aoga.org
John K. Norman <John Norman(G}admin.state.us>
Chairman
Alaska Oil & Gas Conservation Commission
1 of 1
8/30/2006 8:32 AM
*3
.
.
.
MEMORANDUM
State of Alaska
Department of Law
To: John K.Norman, Chair
Alaska Oil and Gas
Conservation Commission
Dept. of Administration
Date:
July 28, 2006
File No.:
993-07-0029
Tel. No.: 465-3600
"om' ~~9£~
Chief Assistant Attordey Deneral
and Regulations Attorney
Legislation and Regulations Section
Re: Regulations File Opening Re:
AOGCC: Permits and
Equipment
(20 AAC 25.005 - .286)
We have received your memorandum of July 26, 2006 regarding this project,
along with a copy of the proposed regulations and related documents. The project has
been assigned to Assistant Attorney General Cammy Taylor, phone number 269-5100.
Our department's file number for this project is 993-07-0029. This file number
should be used on any further correspondence pertaining to this project.
DEB:pvp
cc: Kevin Brooks, Regulations Contact
Dept. of Administration
Lauren Yocom, AAC Coordinator
Lt. Governor's Office
Larry Ostrovsky, Supervising Attorney
Oil, Gas and Mining Section
Cammy Taylor, Assistant Attorney General
Anchorage
.
MEMORANDUM
.
STATE OF ALASKA
ALASKA OIL AND GAS CONSERV A TION COMMISSION
TO:
Deborah E. Behr
Assistant Attorney General
And Regulations Attorney
Legislation and Regulations Section
FROM:
DATE: July 26, 2006
SUBJECT: File-opening request for
Regulations Project on
Permit to Drill
Requirements and
Blowout Prevention
Equipment Requirements
20 AAC 25.005(c)(4)(A)
20 AAC 25.035(e)(1)
20 AAC 25.035(e)(2)
20 AAC 25.035(e)(10),
20 AAC 25.036(c)(1),
20 AAC 25.036(c)(2),
20 AAC 25.036(d),
20 AAC 25.285(c)(2)
20 AAC 25.285(c)(3)
20 AAC 25.285(f)
20 AAC 25 .286( d)(1)
20 AAC 25.286(d)(3)
20 AAC 25.286(e)
We are requesting that you open a new file for a regulations project regarding changes in
Title 20, Chapter 25, of the Alaska Administrative Code, dealing with Permit to Drill
requirements and blowout prevention equipment requirements for the Alaska Oil and Gas
Conservation Commission.
Enclosed is a copy of the public notice, Additional Regulations Notice Information, and a
draft of the regulation.
Please assign Assistant Attorney General Cammy Taylor to this project. Our contact person
for the project is Jody Colombie at 793-1221.
:#;1.
STATE OF ALASKA
e NOTICE TO PUBLISHER
e
ADVERTISING ORDER NO.
ADVERTISING
ORDER
INVOICE MUST BE IN TRIPLICATE SHOWING ADVERTISING ORDER NO., CERTIFIED
AFFIDAVIT OF PUBLICATION (PART 2 OF THIS FORM) WITH ATTACHED COPY OF
ADVERTISEMENT MUST BE SUBMITTED WITH INVOICE
AO-02714001
F AOGCC
AGENCY CONTACT
DATE OF A.O.
R 333 W 7th Ave, Ste 100
o Anchorage, AK 99501
M
Jod Colombie
PHONE
Jul 26 2006
PCN
~ Anchorage Daily News
PO box 149001
Anchorage, AK 99514
July 28, 2006
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REQUISITIO
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02-902 (Rev. 3/94)
pUblisher/olal Copies: Department Fiscal, Department,IeiVing
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Anchorage Daily News
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July 28, 2006
THE MATERIAL BETWEEN THE DOUBLE LINES MUST BE PRINTED IN ITS
ENTIRETY ON THE DATES SHOWN.
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division.
Before me, the undersigned, a notary public this day personally appeared
who, being first duly sworn, according to law, says that
he/she is the
of
Published at
in said division
and
state of
and that the advertisement, of which the annexed
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day of
2005, and thereafter for _ consecutive days, the last
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individuals.
Subscribed and sworn to before me
This _ day of
2005,
Notary public for state of
My commission expires
[Fwd: Re: Public Notice]
.
.
Subject: [Fwd: Re: Public Notice]
From: Ceresa Tolley <ceresa_tolley@admin.state.ak.us>
Date: Thu, 27 Jul 2006 15 :49: 19 -0800
-------- Original Message --------
Subject:Re: Public Notice
Date:Thu, 27 Jul 2006 11 :30:00 -0800
From:Ads, Legal <legalads~adn.com>
To:Ceresa Tolley <ceresa tolley~admin.state.ak.us>
Hello Ceresa:
Following is the confirmation information on your legal notice. Please
review and let me know if you have any questions or need additional
information.
Account Number: STOF 0330
Legal Ad Number: 889675
Publication Date(s): July 28, 2006
Your Reference Number: 02714001
Cost of Legal Notice: $270.18
Thank You,
Kim Kirby
Anchorage Daily News
Legal Classified Representative
E-Mail: legalads@adn.com
Phone: (907) 257-4296
Fax: (907) 279-8170
On 7/26/06 4:09 PM, "Ceresa Tolley" <ceres a tolley@actmin.state.ak.us> wrote:
> Please publish on 7/28/06.
>
> Jody Colombie
1 of 1
7/27/20063:49 PM
Mary Jones
XTO Energy, Inc.
Cartography
810 Houston Street, Ste 2000
Ft. Worth, TX 76102-6298
.
David McCaleb
IHS Energy Group
GEPS
5333 Westheimer, Ste 100
Houston, TX 77056
.
Mona Dickens
Tesoro Refining and Marketing Co.
Supply & Distribution
300 Concord Plaza Drive
San Antonio, TX 78216
George Vaught, Jr.
PO Box 13557
Denver, CO 80201-3557
Jerry Hodgden
Hodgden Oil Company
408 18th Street
Golden, CO 80401-2433
Richard Neahring
NRG Associates
President
PO Box 1655
Colorado Springs, CO 80901
John Levorsen
200 North 3rd Street, #1202
Boise, ID 83702
Kay Munger
Munger Oil Information Service, Inc
PO Box 45738
Los Angeles, CA 90045-0738
Michael Parks
Marple's Business Newsletter
117 West Mercer St, Ste 200
Seattle, WA 98119-3960
Mark Wedman
Halliburton
6900 Arctic Blvd.
Anchorage, AK 99502
Schlumberger
Drilling and Measurements
2525 Gambell Street #400
Anchorage, AK 99503
Baker Oil Tools
4730 Business Park Blvd., #44
Anchorage, AK 99503
Ciri
Land Department
PO Box 93330
Anchorage, AK 99503
Ivan Gillian
9649 Musket Bell Cr.#5
Anchorage, AK 99507
Jill Schneider
US Geological Survey
4200 University Dr.
Anchorage, AK 99508
Gordon Severson
3201 Westmar Cr.
Anchorage, AK 99508-4336
Jack Hakkila
PO Box 190083
Anchorage, AK 99519
Darwin Waldsmith
PO Box 39309
Ninilchick, AK 99639
James Gibbs
PO Box 1597
Soldotna, AK 99669
Kenai National Wildlife Refuge
Refuge Manager
PO Box 2139
Soldotna, AK 99669-2139
Penny Vadla
399 West Riverview Avenue
Soldotna, AK 99669-7714
Richard Wagner
PO Box 60868
Fairbanks, AK 99706
Cliff Burglin
PO Box 70131
Fairbanks, AK 99707
Bernie Karl
K&K Recycling Inc.
PO Box 58055
Fairbanks, AK 99711
North Slope Borough
PO Box 69
Barrow, AK 99723
Williams Thomas
Arctic Slope Regional Corporation
Land Department
PO Box 129
Barrow, AK 99723
Iv OW
~i ~1.~Þ·
Public Notice
.
.
Please publish on 7/28/06.
Jody Colombie
Ceresa Tolley <ceresa tolley(â¿admin.state.ak.us>
Staff Assistant 907-793-1238
Alaska Oil & Gas Conservation Commission
Department of Administration
Content-Type: applicationlmsword
Content-Encoding: base64
to Drill, DOPE
Content-Type: applicationlmsword
Content-Encoding: base64
1 of 1
7/26/2006 4: 11 PM
Public Notice, Additional Regulation Notice Information and Amend...
e
e
>, "MarkP.
,w
, mjnelson
>, "Randy L. Skillern"
ssberg"
s>, Ken
adiokenai.com> ,
lof3
7/26/20062:15 PM
Public Notice, Additional Regulation Notice Infonnation and Amend...
. e
e
Jerry McCutc
<Iris Matthe
<rob.g.dragruch@e
kremer <m
Mason <m"
<Camille
Maunder
Keith Wi
<jim~r
>, Hollis
20f3
7/26/20062:15 PM
Public Notice, Additional Regulation Notice Infonnation and Amend...
e
e
<representa .
<represe
<senator
Tom An
<repr
<sen
Jody Colombie <iody colombie~admin.state.ak.us>
Special Staff Assistant 907-793-] 221
Alaska Oil and Gas Conservation Commission
Department of Administration
30f3
7/26/20062:15 PM
.
.
Copy of Notice and Additional Regulations Notice Information was mailed to the
following on July 26, 2006.
Scott N ordstrand
Commissioner
D~partment of Administration
PO Box 110200
Juneau, AK 99811
Legislative Reference Library
Legislative Affairs Agency
State Capitol
Juneau, AK 99801
Mail Stop: 3101
Senator Tom Wagoner, Chair
Resources
145 Main St Lp Ste 226
Kenai AK 99611
Rep Vic Kohring, Chair
House Special Committee on Oil and Gas
600 E Railroad Ave
Wasilla AK 99654
Rep Tom Anderson, Chair
Administrative Regulation Review
716 W 4th Ave Ste 610
Anchorage AK 99501-2133
Rep Pete Kott, Chair
Legislative Council
State Capitol Rm 3
Juneau AK 99801-1182
File Opening Memo, Copy of Notice, Additional Regulations Notice Information, draft
regulation was mailed to the following on July 26, 2006.
Debra Behr
Assistant Attorney General
Department of Law
PO Box 110300
Juneau, AK 99811
Address Book
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Legislative Affairs
Juneau, AK
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-----
10 of 10
7/18/2006 11 :46 AM
~1
Register _,
200
MrSCELLANEOU~ úOARDS
20 AAC 25.005(c)(4)(A) is amended to read:
(A) the maximum downhole pressure that may be encountered,
criteria used to determine it, and maximum potential surface pressure
based on a pressure gradient to surface of 0.1 psi per foot of true
vertical depth, unless the commission approves a different pressure
gradient that provides an equally effective means of determining the
maximum potential surface pressure [METHANE GRADIENT];
(EtI. 4/13/80, Register 74; am 4/2/86, Register 97; am 11/7/99, Register 152; am
6/4/2000, Register 154; am 1/5/2006, Register 177; am _/ _/ _, Register---.J
Authority: AS 31.05.030
AS 31.05.090
20 25.035(e)(1) is amended to read:
(1) in rotary drilling rig operations,
(A) for an operation with a maximum potential surface pressure
of 3,000 psi or less [REQUIRING BOP STACK LESS THAN API
SK], BOPE must have at least three preventers, including
(i) one equipped with pipe rams that fit the size of drill
pipe, tubing, liner or casing being used, except that pipe rams need
not be sized to bottom-hole assemblies (BHAs) or drill collars;
(ii) one with blind rams, except that a subsea BOPE
assembly must have blind/shear rams in place of blind rams; and
(iÜ) one annular type; and
(B) for an operation, other than a casing or liner operation, with
a maximum potential surface pressure of greater than 3,000 psi
[REQUIRING A BOP STACK EQUAL TO OR GREATER THAN API
5K], BOPE must have at least four preventers, including
(i) two equipped with pipe rams that fit the size of the drill
pipe or tubing [OR CASING] being used, except that pipe rams
need not be sized to BHAs and drill collars;
(ii) one with blind rams, except that a subsea BOPE
assembly must have blind/shear rams in place of blind rams; and
(iii) one annular type;
Register _,
~OO
MISCELLANEouloARDS
(C) for a casin2: or liner operation with a maximum potential
surface pressure of 2:reater than 3.000 psi. BOPE must have at least
four preventers. includin2:
(i) one equipped with pipe rams that fit the size of the
drill pipe or tubin2: bein2: used. except that pipe rams need not
be sized to BHAs and drill collars;
(ii) one equipped with pipe rams that fit the size of
casin2: or liner bein2: used;
(iii) one with blind rams. except that a subsea BOPE
assembly must have blind/shear rams in place of blind rams;
and
(iv) one annular type;
20 AAC 25.035(e)(2) is amended to read:
(2) in coiled tubing unit operations, the well control equipment must
include
(A) for an operation with a maximum potential surface pressure
of 5.000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS
THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and
blinding operations on the coiled tubing in service;
(ii) a high pressure pack-off, stripper, or annular type
preventer;
(iii) if pressure deployment of tools, tubing, liner, or casing
is planned, a riser or lubricator sized to the BHA and providing for
pressure integrity from the BOPE rams to the high pressure pack-
off, stripper, or annular type preventer; and
(iv) at least one preventer equipped with pipe rams that fit
the size of tubing, liner, or casing being used, except that pipe rams
need not be sized to BHAs and drill collars; and
(B) for an operation. other than a casin2: or liner operation. with
a maximum potential surface pressure of 2:reater than 5.000 psi
[REQUIRING A BOP STACK GREATER THAN API 5K],
2
Register _,
_00
MISCELLANEouloARDS
(i) BOPE rams providing for pipe, slip, cutting, and
blinding operations on the coiled tubing in service;
(ii) two high pressure pack-offs, strippers, or annular type
preventers;
(iii) if pressure deployment of tools, tubing, liner, or casing
is planned, a riser or lubricator sized to the BHA and providing for
pressure integrity from the BOPE rams to the high pressure pack-
off, stripper, or annular type preventer; and
(iv) at least two preventers equipped with pipe rams that fit
the size oftubing[, LINER, OR CASING] being used, except that
pipe rams need not be sized to BHAs and drill collars;
(C) for a casine: or liner operation with a maximum potential
surface pressure of e:reater than 5.000 psi.
(i) HOPE rams providine: for pipe. slip. cuttine:. and
blindine: operations on the coiled tubine: in service;
(m two hie:h pressure pack-offs. strippers. or annular
type preventers;
(im if pressure deployment of tools. tubine:. liner. or
casine: is planned. a riser or lubricator sized to the HHA and
providine: for pressure intee:rity from the HOPE rams to the
hie:h pressure pack-off. stripper. or annular type preventer;
(iv) at least one preventer equipped with pipe rams that
fit the size of the tubine: beine: used. except that pipe rams need
not be sized to BHAs and drill collars; and
(v) at least one preventer equipped with pipe rams that
fit the size of casine: or liner beine: used.
20 AAC 25.035(e)(10) is amended to read:
(10) the BOPE must be tested as follows:
(A) when installed, repaired, or changed on a development or
service well and at time intervals not to exceed each 14 days thereafter,
BOPE, including kelly valves, emergency valves, and choke manifolds,
must be function pressure-tested to the required working pressure
specified in the approved Permit to Drill, using a non-compressible fluid,
except that an annular type preventer need not be tested to more than 50
3
Register ,
_00
MISCELLANEOU.OARDS
percent of its rated working pressure; however, the commission will
require that the BOPE be function pressure-tested weekly, ifthe
commission determines that a weekly BOPE pressure test interval is
indicated by a particular drilling rig's BOPE performance;
(B) when installed, repaired, or changed on an exploratory or
stratigraphic test well and at least once a week thereafter, BOPE, including
kelly valves, emergency valves, and choke manifolds, must be function
pressure-tested to the required working pressure specified in the approved
Permit to Drill, using a non-compressible fluid, except that an annular type
preventer need not be tested to more than 50 percent of its rated working
pressure;
(C) if BOP [SEALING RAM TYPE] equipment has been used for
well control or other equivalent purpose. or when routine use of the
equipment may have compromised its effectiveness. the equipment
[IT] must be function pressure-tested, before the next wellbore entry, to
the required working pressure specified in the approved Permit to Drill,
using a non-compressible fluid, except that an annular type preventer need
not be tested to more than 50 percent of its rated working pressure;
(D) BOP ram and annular components except blind rams must be
function-tested weekly, and all BOP ram and annular components must be
function-tested after an action that disconnects the hydraulic system lines
from the BOPE, except that if the workstring is continuously in the well,
function-testing of blind rams must be performed as soon as possible after
the workstring is pulled out of the well and the BHA clears the BOP;
(E) for each BOPE test durine: drilline: and completion
operations. variable bore rams must be function pressure tested to the
required pressure on the smallest outside diameter (OD) and lare:est
OD tubulars that may be used durine: that test cycle. except that
variable bore rams need not be tested on BHAs and drill collars;
Œ:l BOPE test results must be recorded as part ofthe daily record
required by 20 AAC 25.070(1), and must be provided to the
commission. in a format approved by the commission. within two days
after completine: the test;
!ill [(F)] at least 24 hours notice of each BOPE function pressure
test must be provided to the commission so that a commission
representative can witness the test;
History: Eff. 4/13/80, Register 74; am 2/22/81, Register 77; am 4/2/86, Register 97; am
11/7/99, Register 152; am 10/24/2004, Register 172; am~_/_, Register ~
4
Register ,
_00
MISCELLANEOU.OARDS
Authority: AS 31.05.030
20 AAC 25.036(c)(1) is amended to read:
(1) in rotary drilling rig operations,
(A) for an operation with a maximum potential surface pressure
of 5.000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS
THAN API 5K], BOPE must have at least three preventers, including
(i) one equipped with pipe rams that fit the size of drill
pipe, tubing, liner, or casing being used, except that pipe rams need
not be sized to bottom-hole assemblies (BHAs) and drill collars;
(ii) one with blind rams, except that a subsea BOPE
assembly must have blind/shear rams in place of blind rams; and
(iii) one annular type; and
(B) for an operation other than a casin2 or liner operation. with
a maximum potential surface pressure of 2reater than 5.000 psi
[REQUIRING A BOP STACK GREATER THAN API 5K], BOPE must
have at least four preventers, including
(i) two equipped with pipe rams that fit the size of the drill
pipe or[,] tubing[, OR CASING] being used, except that pipe rams
need not be sized to BHAs and drill collars;
(ii) one with blind rams, except that a subsea BOPE
assembly must have blind/shear rams in place of blind rams; and
(iii) one annular type;
(C) for a casin2 or liner operation with a maximum potential
surface pressure of 2reater than 5.000 psi. BOPE must have at least
four preventers. includin2
(i) one equipped with pipe rams that fit the size of the
drill pipe or tubin2 bein2 used. except that pipe rams need not
be sized to BRAs and drill collars:
(m one equipped with pipe rams that fit the size of
casin2 or liner bein2 used;
(im one with blind rams. except that a subsea BOPE
assembly must have blind/shear rams in place of blind rams;
and
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MISCELLANEOU.OARDS
(iv) one annular type;
20 AAC 25.036(c)(2) is amended to read:
include
(2) in coiled tubing unit operations, the well control equipment must
(A) for an operation with a maximum potential surface pressure
of 5.000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS
THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and
blinding operations on the coiled tubing in service;
(ii) a high pressure pack-off, stripper, or annular type
preventer;
(iii) if pressure deployment of tools, tubing, liner, or casing
is planned, a riser or lubricator sized to the BHA and providing for
pressure integrity from the BOPE rams to the high pressure pack-
off, stripper, or annular type preventer; and
(iv) at least one preventer equipped with pipe rams that fit
the size of the tubing, liner, or casing being used, except that pipe
rams need not be sized to BHAs and drill collars; and
(B) for an operation. other than a casin~ or liner operation with
a maximum potential surface pressure of ~reater than 5.000 psi
[REQUIRING A BOP STACK GREATER THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and
blinding operations on the coiled tubing in service;
(ii) two high pressure pack-offs, strippers, or annular type
preventers;
(iii) if pressure deployment of tools, tubing, liner, or casing
is planned, a riser or lubricator sized to the BHA and providing for
pressure integrity from the BOPE rams to the high pressure pack-
off, stripper, or annular type preventer; and
(iv) at least two preventers equipped with pipe rams that fit
the size of the tubing[, LINER, OR CASING] being used, except
that pipe rams need not be sized to BHAs and drill collars;
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MISCELLANEOU.OARDS
(C) for a casinl! or liner operation with a maximum potential
surface pressure of e:reater than 5.000 psi.
(i) DOPE rams providine: for pipe. slip. cuttine:. and
blindine: operations on the coiled tubine: in service;
(ii) two hie:h pressure pack-offs. strippers. or annular
tvpe preventers;
(iii) if pressure deployment of tools. tubine:. liner. or
casine: is planned. a riser or lubricator sized to the DHA and
providine: for pressure intee:ritv from the DOPE rams to the
hie:h pressure pack-off. stripper. or annular tvpe preventer;
(iv) at least one preventer eauipped with pipe rams that
fit the size of the tubine: beine: used. except that pipe rams need
not be sized to DHAs and drill collars; and
(v) at least one preventer eauipped with pipe rams that
fit the size of casine: or liner beine: used;
20 AAC 25.036(d) is amended to read:
(d) A BOPE assembly must be tested as follows:
(1) when installed, repaired, or changed on a development or service well
and at time intervals not to exceed each 14 days thereafter, BOPE, including kelly
valves, emergency valves, and choke manifolds, must be function pressure-tested
to the required working pressure specified in the approved Permit to Drill, using a
non-compressible fluid, except that an annular type preventer need not be tested
to more than 50 percent of its rated working pressure; however, the commission
will require that the BOPE be function pressure-tested weekly, if the commission
determines that a weekly BOPE pressure test interval is indicated by a particular
drilling rig's BOPE performance;
(2) when installed, repaired, or changed on an exploratory or stratigraphic
test well and at least once a week thereafter, BOPE, including kelly valves,
emergency valves, and choke manifolds, must be function pressure-tested to the
required working pressure specified in the approved Permit to Drill, using a non-
compressible fluid, except that an annular type preventer need not be tested to
more than 50 percent of its rated working pressure;
(3) other well control equipment must be pressure-tested to the maximum
potential wellhead pressure after each installation of the well control equipment
and before wellbore entry, except that an annular type preventer need not be
tested to more than 50 percent of its rated working pressure;
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MISCELLANEOU.OARDS
(4) if BOP [SEALING RAM TYPE] equipment has been used for well
control or other equivalent purpose. or when routine use of the equipment
may have compromised its effectiveness. the equipment [IT] must be function
pressure-tested, before the next wellbore entry, to the required working pressure
specified in the approved Permit to Drill, using a non-compressible fluid, except
that an annular type preventer need not be tested to more than 50 percent of its
rated working pressure;
(5) BOP ram and annular components except blind rams must be function-
tested weekly, and all BOP ram and annular components must be function-tested
after an action that disconnects the hydraulic system lines from the BOPE, except
that if the workstring is continuously in the well, function-testing of blind rams
must be performed as soon as possible after the workstring is pulled out of the
well and the BRA clears the BOP;
(6) for each DOPE test durin2 drillin2 and completion operations.
variable bore rams must be function pressure tested to the required pressure
on the smallest OD and lar2est OD tubulars that may be used durin2 that
test cycle. except that variable bore rams need not be tested on DHAs and
drill collars;
ill DOPE test results must be recorded as part of the daily record required
by 20 AAC 25.070(1). and must be provided to the commission. in a format
approved by the commission. within 2 days after completin2 the test;
Œl.[(7)] at least 24 hours notice of each BOPE function pressure test must
be provided to the commission so that a representative of the commission can
witness the test.
History: Eff. 11/7/99, Register 152; am 10/24/2004, Register 172; am_/_/_,
Register ~
Authority: AS 31.05.030
20 AAC 25.285(c)(2) is amended to read:
(2) in rotary drilling rig operations,
(A) for an operation with a maximum potential surface pressure
of 3.000 psi or less [REQUIRING A BOP STACK LESS THAT API 5K],
at least three preventers, including
8
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MISCELLANEOU.OARDS
(i) one equipped with pipe rams that fit the size of drill
pipe, tubing, liner or casing being used, except that pipe rams need
not be sized to bottom-hole assemblies (BHAs) and drill collars;
(ii) one with blind rams, except that a subsea BOPE
assembly must have blind/shear rams in place of blind rams; and
(iii) one annular type; and
(B) for an operation. other than a casine: or liner operation. with
a maximum potential surface pressure of e:reater than 3.000 psi
[REQUIRING A BOP STACK EQUAL TO OR GREATER THAN API
5K], at least four preventers, including
(i) two equipped with pipe rams that fit the size of the drill
pipe or[,] tubing[, OR CASING] being used, except that pipe rams
need not be sized to BHAs and drill collars;
(ii) one with blind rams, except that a subsea BOPE
assembly must have blind/shear rams in place of blind rams; and
(iii) one annular type;
(C) for a casine: or liner operation. with a maximum potential
surface pressure of e:reater than 3.000 psi. at least four preventers.
includine:
(i) one equipped with pipe rams that fit the size of the
drill pipe or tubine: beine: used. except that pipe rams need not
be sized to BRAs and drill collars:
(m one equipped with pipe rams that fit the size of
casine: or liner beine: used:
(iii) one with blind rams. except that a subsea BOPE
assembly must have blind/shear rams in place of blind rams:
and
(iv) one annular type:
20 AAC 25.285(c)(3) is amended to read:
(3) in coiled tubing unit operations,
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MISCELLANEOulOARDS
(A) for an operation with a maximum potential surface pressure
of 5.000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS
THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and
blinding operations on the coiled tubing in service;
(ii) a high pressure pack-off, stripper, or annular type
preventer;
(iii) if pressure deployment of tools is planned, a riser or
lubricator sized to the BHA and providing for pressure integrity
from the BOPE rams to the high pressure pack-off, stripper, or
annular type preventer; and
(iv) at least one preventer equipped with pipe rams that fit
the size ofthe tubing, liner, or casing being used, except that pipe
rams need not be sized to BHAs and drill collars; and
(B) for an operation. other than a casine: or liner operation. with
a maximum potential surface pressure of e:reater than 5.000 psi
[REQUIRING A BOP STACK GREATER THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and
blinding operations on the coiled tubing in service;
(ii) two high pressure pack-offs, strippers, or annular type
preventers;
(iii) if pressure deployment of tools is planned, a riser or
lubricator sized to the BHA and providing for pressure integrity
from the BOPE rams to the high pressure pack-off, stripper, or
annular type preventer; and
(iv) at least two preventers equipped with pipe rams that fit
the size of the tubing[, LINER, OR CASING] being used, except
that pipe rams need not be sized to BHAs and drill collars;
(C) for a casine: or liner operation with a maximum potential
surface pressure of e:reater than 5.000 psi.
(i) BOPE rams providine: for pipe. slip. cuttine:. and
blindine: operations on the coiled tubine: in service;
(ii) two hie:h pressure pack-offs. strippers. or annular
type preventers;
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MIS CELLANEOU'OARD S
(iii) if pressure deployment of tools is planned. a riser or
lubricator sized to the BHA and providin2 for pressure
inte2ritv from the BOPE rams to the hi2h pressure pack-off.
stripper. or annular type preventer;
(iv) at least one preventer equipped with pipe rams that
fit the size of the tubin2 bein2 used. except that pipe rams need
not be sized to BHAs and drill collars; and
(v) at least one preventer equipped with pipe rams that
fit the size of casin2 or liner bein2 used;
20 AAC 25.285(f) is amended to read:
(f) The BOPE must be tested as follows:
(1) when installed, repaired, or changed, and at least once a week
thereafter, BOPE, including emergency valves and choke manifolds, must be
function pressure-tested, using a non-compressible fluid, to the required working
pressure specified in an approved Application for Sundry Approvals under 20
AAC 25.280 or, if that application is not required, to the maximum potential
surface pressure to which the BOPE may be subjected, except that an annular type
preventer need not be tested to more than 50 percent of its rated working pressure;
(2) if BOP [SEALING RAM TYPE] equipment has been used for well
control or other equivalent purpose. or when routine use of the equipment
may have compromised its effectiveness, the equipment [IT] must be function
pressure-tested before the next wellbore entry, using a non-compressible fluid, to
the required working pressure specified in an approved Application for Sundry
Approvals under 20 AAC 25.280 or, if that application is not required, to the
maximum potential surface pressure to which that equipment may be subjected,
except that an annular type preventer need not be tested to more than 50 percent
of its rated working pressure;
(3) non-sealing equipment must be function-tested weekly, after a repair
or change, and after an action that disconnects the hydraulic system lines from the
BOPE, except that if the workstring is continuously in the well, function-testing
must be performed as soon as possible after the workstring is pulled out of the
well and the BHA clears the BOP;
(4) for each BOPE test durin2 drillin2 and completion operations.
variable bore rams must be function pressure tested to the required pressure
on the smallest OD and lar2est OD tubulars that may be used durin2 that
test cycle. except that variable bore rams need not be tested on BHAs and
drill collars;
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MISCELLANEouloARDS
ill BOPE test results must be recorded as part of the daily record required
by 20 AAC 25.070(1), and must be provided to the commission, in a format
approved bv the commission, within two days after completine: the test;
~[(5)] at least 24 hours notice of each BOPE function pressure test must
be provided so that a representative of the commission can witness the test; [.]
ill the operator shall report to the commission within 24 hours any
instance of BOPE use to prevent the flow of fluids from a well.
History: Eff. 4/2/86, Register 97; am 11/7/99, Register 152; am _1_1_, Register
->
Authority: AS 31.05.030
20.AAC 25.286(d)(1) is amended to read:
(1) at least one positive seal manual or hydraulic valve or blind ram
flanged to the wellhead or tree;
(2) in rotary drilling rig operations,
(A) for an operation with a maximum potential surface pressure
of 5,000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS
THAN API 5K], at least three preventers, including
(i) one equipped with pipe rams that fit the size of drill
pipe, tubing, liner or casing being used, except that pipe rams need
not be sized to bottom-hole assemblies (BHAs) and drill collars;
(ii) one with blind rams, except that a subsea BOPE
assembly must have blind/shear rams in place of blind rams; and
(iii) one annular type; and
(B) for an operation, other than a casine: or liner operation, with
a maximum potential surface pressure of e:reater than 5,000 psi
[REQUIRING A BOP STACK GREATER THAN API 5K], at least four
preventers, including
(i) two equipped with pipe rams that fit the size of the drill
pipe or[,] tubing[, OR CASING] being used, except that pipe rams
need not be sized to BHAs and drill collars;
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MISCELLANEouloARDS
(ii) one with blind rams, except that a subsea BOPE
assembly must have blind/shear rams in place of blind rams; and
(iii) one annular type;
(C) for a casine: or liner operation with a maximum potential
surface pressure of e:reater than 5.000 psi. at least four preventers.
includine:
(i) one equipped with pipe rams that fit the size of the
drill pipe or tubine: beine: used. except that pipe rams need not
be sized to BHAs and drill collars;
(in one equipped with pipe rams that fit the size of
casine: or liner beine: used;
(iii) one with blind rams. except that a subsea BOPE
assemblv must have blind/shear rams in place of blind rams;
and
(iv) one annular type;
20 AAC 25.286(d)(3) is amended to read:
(3) in coiled tubing unit operations,
(A) for an operation with a maximum potential surface pressure
of 5.000 psi or less [REQUIRING A BOP STACK EQUAL TO OR LESS
THAN API 5K],
(i) BOPE rams providing for pipe, slip, cutting, and
blinding operations on the coiled tubing in service;
(ii) a high pressure pack-off, stripper, or annular type
preventer; and
iii) if pressure deployment of tools is planned, a riser or
lubricator sized to the BHA and providing for pressure integrity
from the BOPE rams to the high pressure pack-off, stripper, or
annular type preventer; and
(B) for an operation with a maximum potential surface pressure of
greater than 5,000 psi [REQUIRING A BOP STACK GREATER THAN
API 5K],
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MISCELLANEOultOARDS
(i) BOPE rams providing for pipe, slip, cutting, and
blinding operations on the coiled tubing in service;
(ii) two high pressure pack-offs, strippers, or annular type
preventers; and
(iií) if pressure deployment of tools is planned, a riser or
lubricator sized to the BHA and providing for pressure integrity
from the BOPE rams to the high pressure pack-off, stripper, or
annular type preventer;
20 AAC 25.286(e) is amended to read:
( e) The operator shall test the BOPE assembly as follows:
(1) at least once a week, and after each [USE,] repair, [OR] change, or use
for well control or other equivalent purpose. or when routine use of the
equipment may have compromised its effectiveness. BOP[E] equipment [PIPE
AND BLIND RAMS] must be function pressure-tested, using a non-compressible
fluid, to the required working pressure specified in an approved Application for
Sundry Approvals under 20 AAC 25.280 or, if that application is not required, to
the maximum potential surface pressure to which they may be subjected, except
that the annular type preventer need not be tested to more than 50 percent of its
rated working pressure;
(2) after each installation of BOPE or other well control equipment, the
equipment must be pressure-tested, before well bore entry, to the maximum
potential wellhead pressure to which it may be subjected, except that when testing
against the annular type preventer, pressure testing need not exceed 50 percent of
the rated working pressure of the annular type preventer;
(3) non-sealing equipment must be function-tested weekly, after a repair
or change, and after an action that disconnects the hydraulic system lines from the
BOPE, except that if the workstring is continuously in the well, function-testing
must be performed as soon as possible after the workstring is pulled out of the
well and the BHA clears the BOP;
(4) after each well installation of the BOPE, the BOPE hydraulic
connections to the rams must be visually verified before well bore entry;[.]
(5) for each BOPE test durin2 drillin2 and completion operations.
variable bore rams must be function pressure tested to the required pressure
on the smallest OD and lar2est OD tubulars that may be used durin2 that
test cycle. except that variable bore rams need not be tested on BRAs and
drill collars;
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MISCELLANEouloARDS
(6) DOPE test results must be recorded as part of the daily record
required by 20 AAC 25.0700). and must be provided to the commission. in a
format approved by the commission. within two days after completing the
test;
(7) at least 24 hours notice of each DOPE function pressure test must
be provided so that a representative of the commission can witness the test;
(8) the operator shall report to the commission within 24 hours any
instance of DOPE use to prevent the flow of fluids from a well.
History: Eff. 11/7/99, Register 152; am~_/_, Register ~
Authority: AS 31.05.030
15