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Home My WebLink AboutO 056~ ~ Image Project Or~ler File ~over Page XHVZE This page identifies those items that were not scanned during the initial production scannin~ phase. They are available in the original file, may be scanned during a special rescan actiuity or are viewable by direct inspection of the file. ~ Order File Identifier Organizing~aone> ^ Two-sided IIIII~IIII~IIIIIIII ^ Rescan Needed IIIII~IIII~IIIIIIII RESCAN DIGITAL DA?A OVERSIZED (Scannable) ^ Color Items: ^ Diskettes, No. ^ Maps: ^ Greyscale Items: ^ Other, No/Type: ^ Other Items Scannable by a Large Scanner ^ Poor Quality Originals: OVERSIZED (Non-Scannable) ^ Other: ^ Logs of various kinds: NOTES: ^ Other:: ~ BY: Maria Date: ~ ~S~ Pro,ject Proofing III ~IIIII IIIII I) III BY: Maria Date: ~ /s/ Scanning Preparation x 30 = + = TOTAL PAGES ~~ ~/~~ (Count does not i S~ude cover sheet~ /~ /~ ~ BY: Maria Date: ~~ ~~ ~ Production Scanning Stage 1 Page Count from Scanned File: ~~ (Count does include cove heet) Page Count Matches Number in Scanning Pr paration: YES NO BY: Maria Date: ~~as oq ,S, Stage 1 If NO in sta e 1 a ~ g , p ge(s) discrepancies were found: YES NO gY: Maria Date: /s/ Scanning is complete at this point unless rescanning is required. III IIrI~I III~I II III ReScanned BY~ Maria Date: ~S~ Comments about this file: Quality Checked (II (I~IIIIIIII~III 10/6/2005 Orders File Cover Page.doc ~ ~ Index Other 56 Regulation Package Hydrocarbon Measurement Equipment 1. November 14, 2007 Notice of hearing, affidavit of publication, bulk mailing 2. November 17, 2008 File Opening Request 3. January 13, 2009 Transcript 4. January 23, 2009 Notice of hearing, affidavit of publication, bulk mailing 5. --------------- Public Comments 6. September 1, 2009 AOGCC re: submission of regulation package to the AG's office for signature 7. September 22, 2009 Post Notice and Final, Final regulation and Lt. Governor Order certifying changes to regulations Other 56 ~7 ~ ~ Amended Regulations Dealing with Hydrocarbon Measurement Equipment The Alaska Oil and Gas Conservation Commission has revised its regulations dealing with hydrocarbon measurement equipment requirements in 20 AAC 25.228(b). The amended hydrocarbon measurement equipment regulation requires the operator to provide information to and obtain the approval of the Commission prior to the installing or altering hydrocarbon measurement equipment used for custody transfer purposes and adopting or changing the methodology used for determining hydrocarbon volumes. The Lieutenant Governor signed and filed the regulation changes on September 18, 2009, with an effective date of October 18, 2009. For further information or to obtain a copy of the amended regulations, contact Jody Colombie at (907) 793-1221, fax (907) 276-7542, or e-mail jody.colombie cr,alaska.gov. ~ ~ Page 1 of 1 Colombie, Jody J (DOA) From: Shier, Benjamin P (GOV) Sent: Monday, September 21, 2009 4:27 PM To: Pearson, Robert L (DOA) Cc: Cramer, John W(GOV); Shier, Benjamin P(GOV); Behr, Deborah E(LAV~; Miller, Linda J(LAW); Weaver, Steven C(LAV~; Messing, Kevin J(LAV~; Pound, Jim (LAA); Colombie, Jody J(DOA) Subject: Regulations Filed: 993-09-0052 Attachments: 993-09-0052. pdf On 9/18/2009, Lieutenant Governor Craig E. Campbell filed regulations (993-09-0052) from the Alaska Oil and Gas Commission re: Hydrocarbon Measurement Equipment and Custody Transfer (20 AAC 25.228(b)). The effective date of the regulations is 10/18/2009, and the regulations will be published in Register 192, January 2010. The filing certification and regulation text are attached. Unless requested, no hard copies will be mailed. Thank you, BENJAMI:N SHIER. Special Assistant Office of Lieutenant Governor Craig E. Campbell P.O. Box 110015 Juneau, AK 99811 P H O N E: 907.465.3520 FAX: 907.465.5400 benjamin.shier@alaska,gov_ www.ltgov.alaska._gov 9/22/2009 ~J MEMORANDUM ~ State of Alaska Department of Law To: Daniel T. Seamount, Jr., Chair ~aTe: September 17, 2009 Alaska Oil and Gas Conservation Commission Fi~e No.: 993-09-0052 > ~ ~ , TELEPHONE NO.: 4CS-3E)OO (~ FROnn: Steven C. Weaver _,,.~- \~~ sus~ecT: Regulations re: hydrocarbon Assistant Attorney General measurement equipment and Legislation/Regulations Section--Juneau custody transfer (2~ AAC 25.228(b)) Under AS 44.62.060, we have reviewed the attached amendment of these regulations by the Alaska Oil and Gas Conservation Commission, and approve the changes for filing by the lieutenant governor. I have reviewed this project under a specific delegation dated September I5, 2009 from the Regulations Attorney. A duplicate original of this memorandum is being furnished to the lieutenant governor, along with the one page 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 November 14, 2008 public notice, the January 23, 2009 supplemental public notice, and the September 1, 2009 certification order all 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. scw cc w/enc: Robert Pearson, Special Assistant & Regulations Contact Department of Administration Jody Colombie Alaska Oil and Gas Conservation Commission Thomas Ballantine Assistant Attomey General Oil, Gas & Mining Section--Anchorage Register , r 20 ~~ MISCELLANE~S BOARDS 20 AAC 25.228(b) is amended to read: (b) Hydrocarbon measurement equipment must be fabricated, installed, and maintained in conformance with relevant parts of the API Mant.ral of Petroleum :I~Ieaszsrement Standards, as revised as of November 30, 1998. Before installing or alterin~ hydrocarbon measurement eQUinment used for custody transfer ~urnoses, the onerator shall submit to the commission information demonstratin~ conformance and obtain commission a~proval of the proposed installation or alteration and the methodology nroposed for determining hvdrocarbon volumes. (Eff. 4/2/86, Register 97; am 11/7/99, Register 152; am _/_/ , Register _) Authority: AS 31.05.030 ~ , , ~..8-~-~9~~6- , , • •, '`p..e.~0~e'.~n.G,z. . '~--r.~a~-r.,~.,~, ~z::t.~..~".e2.e u.t~'.~. ~.~e_ 2a ~A^ o~5,a2~' .~~ .,~a.,u. ^ ' + ~ ~------ ' J annroved methodology~et~..c~without commission annroval. ~~ ~ MEMORANDUM • STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION TO: Regulations Attorney DATE: September l, 2009 Legislation/Regulations Section Department of Law SUBJECT: AG File No. 993-09-0052 Request for Legal Review of Regulations Project on Hydrocarbon Measurement Equipment 20 AAC 25.228(b) FROM: Daniel T. Seamount, Jr., Chair ~/;~ R~gulations Contact k~° Department of Administration We are requesting approval of the attached final regulations on the following: 1) requiring an operator to provide information to and obtain the approval of the Alaska Oil and Gas Commission (Commission) prior to installing or altering hydrocarbon measurement equipment used for custody transfer purposes; and 2) adopting or changing the methodology used for determining hydrocarbon volumes. The Commission adopted these changes on July 29, 2009. Enclosed are the following documents: 1. original and one copy of the final regulations; 2. original signed and dated certification order; 3. original public notices; 4. original additional regulations notice information form distributed with the notice; 5. original publisher's affidavit's of publication; 6. original affidavit of notice; 7. original affidavit of oral hearing; 8. original affidavit of commission action; 9. excerpt from unapproved minutes from the July 29, 2009 meeting; We worked with Assistant Attorneys General Alan Birnbaum and Thomas Ballantine on this project. Upon completing your review, please forward the regulations to the lieutenant governor for filing. In accordance with AS 44.62.180, the regulation changes will take effect on the 30`h day after filing. ~ ~ ORDER CERTIFYING THE CHANGES TO REGULATIONS OF ALASKA OIL AND GAS CONSERVATION COMMISSION The attached 1 page of regulations, dealing with hydrocarbon metering under 20 AAC 25, is certified to be a correct copy of the regulation changes that the Alaska Oil and Gas Conservation Commission adopted at its July 29, 2009 meeting, under the authority of AS 31.05.030 and AS 31.05.040 and in compliance with the Administrative Procedure Act (AS 44.62), including the notice provisions (AS 44.62.190 and AS 44.62.200) and opportunity for public comment provision (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. As provided in AS 44.62.180, the subject regulation changes take effect on the 30th day after they are filed by the lieutenant governor. DATE: September l, 2009 ,,~ Anchora~e_ ~ Daniel T. Seamount, Jr. Chair FILING CERTIFICATION I, Craig E. Campbell, Lieutenant Governor for the State of Alaska, certify that on 2009 at .m., I filed the attached regulations according to the provisions of AS 44.62.040 - 44.62.120. Lieutenant Governor Effective: Register: ~ ~ 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 Assistant to the 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 25.228, dealing with hydrocarbon measurements, was given by being (1) 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 44.62.175(a)(1) and (b) and AS 44.62.190(a)(1); (8) furnished electronically, along with a copy of the proposed regulations, to the Legislative Affairs Agency, the chairs of the Senate Resources Committee and House Special Committee of Oil and Gas, 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 was 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 was posted on the Alaska Online Public Notice System. DATE: September 1, 2009 Anchora~e r ~~ Jo J. 1 bie Special Assistant to the Commission SUBSCRIBED AND SWORN TO before me this lst day of Se tember 2009. -` C~ o ry Public in nd for the State of Alaska My commission expires: 11 / 11 /2010 ~ ~ STATE OF ALASKA ) ) ss. THIRD JUDICIAL DISTRICT ) AFFIDAVIT OF ORAL HEARING I, Jody J. Colombie, Special Assistant to the Alaska Oil and Gas Conservation Commission, being sworn, state the following: On January 13, 2009, at 9:00 a.m., at 333 West 7th Avenue, Suite 100, Anchorage, Alaska, a public hearing presided over by Daniel T. Seamount, Jr., Chair, was held in accordance with AS 44.62.21 p for the purpose of voting on the adoption of changes to 20 AAC 25.228, dealing with hydrocarbon measurements. DATE: Sentember 1. 2009 Anchara~e , y ~ Jod J. C e ~ Special Assistant to the Commission SUBSCRIBED AND SWORN TO before me this lst day of September, 2009. ~ ,C G~ Nat y Public in and or the State of Alaska My commission expires: 11/11/2010 ~ ~ STATE OF ALASKA ) ) ss. THIRD JUDICIAL DISTRICT ) AFFIDAVIT OF COMMISSION ACTION I, Jody J. Colombie, Special Assistant to the Alaska Oil and Gas Conservation Commission, being sworn, state the following: The attached motion, dealing with hydrocarbon measurement regulation changes, was passed by the Alaska Oil and Gas Conservation Commission during its July 29, 2009 meeting. Date: September 1, 2009 Anchora~e ~ ,~ Jo } J. C~ o ie Spe ial Assistant to the Commission SUBSCRIBED AND SWORN TO before me this lst day of Septembe.r 2009. .~r ~ Notary Public m an far the State of Alaska My commission expires: 11/11/2010 ~J ~ ALASKA OIL AND GAS CONSERVATION COMMISSION MEETING July 29, 2009 Unapproved Minutes Commissioner Daniel T. Seamount, Jr. moved and Commissioner Cathy P. Foerster seconded the following motion: "I move to adopt the attached draft amendment to 20 AAC 25.228." The motion carried unanimously. ~ ~ Re ister 200 MISCELLANEOUS BOARDS g ~ - 20 AAC 25.228(b) is amended to read: (b) Hydrocarbon measurement equipment must be fabricated, installed, and maintained in conformance with relevant parts of the API Manual of Petroleum Measurement Standards, as revised as of November 30, 1998. Before installin~ or alterin~ hvdrocarbon measurement equipment used for custody transfer purposes, the operator shall submit to the commission information demonstratin~ conformance and obtain commission annroval of the proposed installation or alteration and the methodolo~y pronosed for determinin~ hvdrocarbon volumes. The submitted information shall include, amon~ other thin~s, sample calculations, with the underlving measured data, generated using the proposed methodologv. An annroved methodoloQV mav not be chan~ed without commission approval. (Eff. 4/2/86, Register 97; am 11/7/99, Register 152; am / / , Register ) Authority: AS 31.05.030 Editor's note: A copy of the relevant parts of the API Manual of Pelroleum Measurement Standards may be reviewed during business hours at the commission's office and may be obtained from the American Petroleum Institute, Order Desk, 1220 L Street, N.W., Washington, D.C.2005-4070. ~ Re ister , 200 MISCELLANEO~ BOARDS g - 20 AAC 25.228(b) is amended to read: (b) Hydrocarbon measurement equipment must be fabricated, installed, and maintained in conformance with relevant parts of the API Manual of Petroleum Measurement Standards, as revised as of November 30, 1998. Before installin~ or altering hvdrocarbon measurement equipment used for custody transfer purposes, the operator shall submit to the commission information demonstratin~ conformance and obtain commission annroval of the pronosed_installation or alteration and the methodologv proposed for determinin~ hvdrocarbon volumes. The submitted information shall include, amon~ other thin~s, sample calculations, with the underlvin~ measured data, ~enerated using the pronosed methodolo~y. An annroved methodolo~v mav not be changed without commission apnroval. (Eff. 4/2/86, Register 97; am 11/7/99, Register 152; am / / , Register _) Authority: AS 31.05.030 Editor's note: A copy of the relevant parts of the API Manual of Petroleum Measurement Standards may be reviewed during business hours at the commission's office and may be obtained from the American Petroleum Institute, Order Desk, 1220 L Street, N.W., Washington, D.C. 2005-4070. ~5 Page 1 of 1 a i • Maunder, Thomas E (DOA) From: Maunder, Thomas E (DOA) Sent: Monday, June 22, 2009 10:28 AM To: Birnbaum, Alan J (LAV1n Cc: Seamount, Dan T(QOA); Foerster, Catherine P(DOA); Norman, John K(DOA); Colombie, Jody J (DOA) Subject: Response to Public Comments_25.228.doc Attachments: Response to Public Comments_25.228.doc Alan, Attached is a document replying to comments regarding the proposed amendment to 20 AAC 25.228. 2 electronic comments were received prior to the hearing, but were not discovered until about a week after the hea~ing. It was also discovered that no closing date for comments was included in the original notice so a susequent notice was made. 2 comments, one topical and one non-topical, were received. The attached document addresses the 3 topical comments. An individual reply was only sent to one of the topica! commenters. Would you please review/edit as appropriate and we can move to finalize this subject. Thanks, Tom 6/22/2009 ~ ~ Response to Public Comments regarding Proposed Amendment to 20 AAC 25.228 (b) Alaska Oil and Gas Conservation Commission (AOGCC) Original Notice November 14, 2008 Public Hearing January 13, 2009 Subsequent Notice January 23, 2009 A public hearing was held on January 13, 2009 to consider a proposed amendment to Regulation 20 AAC 25.228 (b) regarding hydrocarbon metering. T'he amendment was proposed by AOGCC and would require an operator to provide information of and obtain approval from the Commission prior to (1) insta.lling or altering ... equipment used for custody transfer purposes and (2) adopting or changing the methodology used for determining hydrocarbon volumes. Public testimony was presented by the Alaska Oil and Gas Association (AOGA) on behalf of their member companies. Several items of concern were raised and the concerns of the testifying party were addressed by the Commission at the hearing. Following the hearing, additional public comments submitted electronically prior to the hearing were discovered on January 20. The Iate discovery did not atlow these specific submissions to be addressed at the public meeting, although after review it is evident that the points raised were substantially addressed at the public meeting. Subsequently it was discovered that the Public Notice published November 14, 2008 did not esta.blish a deadline for written comments to be submitted. A subsequent public notice was published on January 23, 2009 providing notice that all written comments pertaining to this issue must be received by the Commission 4:30 pm February 23, 2009. The purpose of this document is to address, for the record, the public comments not addressed at the January 13 hearing and received prior to 4:30 pm February 23, 2009. Commenter 1 On January 12, Ms. Marsha Yon of Emerison Process Management electronically submitted a comment on behalf to the API Committee on Liquid Measurement. Her comment related to the specification of the November 30, 1998 version of the API Manua1 of Petroleum Measurement Standards and whether that specificity precluded using more recently published standards. A similar comment was addressed at the hearing. It is the Commission's position that the variance provision of 20 AAC 25.228 (j) can be employed to a11ow use of more recently • ~~ published standards. If the newest version of the standards were adopted at this time, an economic penalty could be imposed on operators to up,date or replace their measurement equipment to comply with the newest standards. Specifically citing the November 30, 1998 edition of the Measurement Standards esta.blishes a minimum requirement for custody transfer measurement installations. Comment 2 On January 12, Ms. Sherry Timmerman of ConocoPhillips, Alaska (CPAI) electronically submitted multiple comments on behalf of Mr. Bobby W. Fletcher, Jr. the Greater Kuparuk Operations Support Manager. Similar comments were submitted and addressed at the hearing. CPAI's multiple comments are listed below. 1. CPAI believes the existing regulations are adequa.te and no change is needed. CPAI is referred to the hearing transcript where the Commission believes ample evidence was presented supporting the regulatory amendment. 2. CPAI requests clarification of the Commission's intent for the regulatory change and believes that compliance with the existing reguiations can be confirmed administratively for new pools and by inspections at existing installations. CPAI is again referred to the hearing transcript where an example of newly installed gas measurement equipment with an uncertainty in excess of that for orifice measurement was presented. The Commission believes that amending the regulation to require advance notice will a11ow the Commission to be forewarned when a new custody transfer measurement installation is planned or constructed and that such involvement will prevent delays due to potential design shortcomings. With regards to modifications of existing installations, advance notice will allow the Commission to perform its due diligence regarding oversight of custody transfer metering installations. 3. CPAI believes that the terms "Alter" and "Insta.ll" need clearer definitions so that routine maintenance activities are excluded. AOGA also expressed this concern in their hearing testimony. The Commission stated that it is not intended that routine maintenance and calibration activities be subject to the amended requirements. Replacing a malfunctioning piece of equipment like-for-like would not need prior notification, nor would changing an orifice plate. If an existing orifice station were changed to ultra-sonic, then notice and approval would be required. Upgrading (chart to flow computer or new calculation routine) or replacing (new model or different manufacturer) other portions of the measurement system would also require prior notice. 4. Following on their 2°d comment, CPAI proposes alternate wording for 20 AAC 25.228 (b) to narrow the scope of the notification requirement to apply to only new installations and proposes new wording for 2Q AAC 25.228 (i) covering alterations to custody transfer metering equipment under the 24 hour notice requirement. As discussed in point 2, above, the Cornmission believes that the advance notice requirement should properly apply ta both new and existing custody transfer metering installations. . ~ ~ -_ J Cominent 3 On January 28, Mr. Bruce Webb of Aurora Gas electronically submitted a comment requesting clarification of "altering" as used in the proposed amendment. Mr. Webb's concern is similar to that expressed by AOGA at the hearing and CPAI in their 3`a comment. An electronic response similar to that given in CPAI's 3rd comment, above, was provided to Mr. Webb on January 28. Alan: A non-topical comment was received from Ms. Dana Olsen on January 26. A written reply dated January 2$ from Commissioner Seamount was sent. Does this need to be addressed? • ~ Page 1 of 2 Colombie, Jody J (DOA) From: Maunder, Thomas E (DOA) Sent: Wednesday, January 28, 2009 2:44 PM To: Bruce D Webb Subject: RE: Supplemental Notice AOGCC Hydrocarbon Metering Bruce, The regulation change is not intended to affect maintenance activities (replacing pressure transmitters, temp sensors, changing orifice plates, etc.). Under the new regulation your 2"d set of possible activities (changing from an orifice meter to an ultrasonic meter or changing the flow computer) would require notice to and approval by the Commission. Cleaning a meter is an action that could be of interest depending on what substance is fouling the meter since meter fouling could affect the measurement of the gas. When in doubt, please give me or the on-call Inspector a call or send a message. I hope this response is of benefit. Call or message with any questions. Tom Maunder, PE AOGCC From: Colombie, Jody J (DOA) Sent: Wednesday, January 28, 2009 11:29 AM To: Maunder, Thomas E (DOA) Subject: FW: Supplemental Notice AOGCC Hydrocarbon Metering Importance: High Tom-please respond to Bruce. From: aurorapower@gci.net [mailto:aurorapower@gci.net] On Behalf Of Bruce D Webb Sent: Wednesday, January 28, 2009 10:45 AM To: Colombie, Jody ] (DOA) Subject: RE: Supplemental Notice AOGCC Hydrocarbon Metering Importance: High Jody, Aurora Gas, LLC would like additional information on the referenced proposed regulation. Specifically, what is the definition of "altering" a custody meter? Our concern is that this needs to be clarified and may be ambiguous as written. For instance, does it include replacing pressure transmitters, temp sensors, etc., or does "altering" mean changing how we measure the gas flow (i.e. change from an orifice meter to a ultrasonic meter). We would not want to get into a situation of non-compliance because we had to repair or clean a custody meter. Thank you for the opportunity to comment. Best regards, -Bruce Bruce D. Webb Manager, Land and Regulatory Affairs Aurora Gas, LLC 1400 W. Benson Blvd., Suite 410 Anchorage, AK 99503 1/28/2009 ~ ~ ~ Page 2 of 2 (907) 277-1003 office (907) 229-8398 cell (970)277-1006fax From: Colombie, Jody J (DOA) [mailto:jody.colombie@alaska.gov] Sent: Thursday, January 22, 2009 2:49 PM Subject: Supplemental Notice AOGCC Hydrocarbon Metering Attached is a Supplemental Notice that merely provides a date (February 23, 2009) by which the AOGCC must receive written comments in regards to the proposed regulation changes to 20 AAC 25.228 (b). Attached for the convenience of those legislators who have been newly elected, I am attaching the original notice as well as the proposed regulations along with the supplemental notice. The recent new meter installations have uncovered a gap in our regulations. There is currently nothing to specify that and how an operator must receive initial approval for custody transfer metering equipment. Custody transfer metering systems are used to measure hydrocarbon volumes for revenue and tax determinations. Therefore, initial approval is necessary to prevent an improperly designed, installed, or calibrated custody transfer metering system from going into service. Jody J. Colombie Special Assistant to the Commission Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, Alaska 99501 (907) 793-1221 Direct Line (907) 276-7542 Fax 1/28/2009 ~ ~ , u f,°~ F', ,, i~ ~f ~~ s ~,r'4~ ~~ , ~, r, 4 ~'~ f ~ G~ r f; ~„~ ~ ~ C'~ ,.` SARAH PALIN, GOVERNOR ~ _ ~ e ~~ ~_ F._`_ z. Y _.~ ~- ... ~~ ~ ~ ~, ~r~~ ~T ~S~A ~~ ~ ~i~4S ~ 333 W. 7thAVENUE, SUITE 100 t`. C~~~~~~~~~~ ~~~~~~~~ ~ pHON~E~ 907~279-~ 433~501-3539 FAX (907) 276-7542 January 28, 2009 Dana L. Olson HC-35 Box 5438 Wasilla, AK 99564 Re: Comments Received January 26, 2009 Dear Ms. Olson: The Alaska Oil and Gas Conservation Commission (Commission) has received your comments, dated January 26, 2009. Upon reviewing them, if the Commission determines that additional information will be helpful, we will contact you. Thank you for the comments. 4 /~`~i~$~lA (}C ~ ~oR-S G ~Sc~'~/~1`70?~ ~D7YJll2/SS/D•'~.~ ~ ~ _ . R~ ~ G!/rl ~~ ~'~ ~d'Yr! /s? ~ `l l's ~' ~ ~j'~t~~c/~/~l c~. ~ y G~io ~'yy,6 d,v ~~, o a~u ~'~7 0.,J lv ~~9'~S ~` { ~Y ~e ~I C p~, /w .~I / ,/k 7 ~' .~o ~ ~ l `i~c%.cl rt ~ /~ ~ s u f ~y ~~! A`"io.~i,p~ '~' ~J /K> ,~~, S LC~ ~ ~'~T ~J !/~ 9~ °~ CULt ~ ~'I O~h~ as l,tJ.~f~Q d~~. ~4'.~'1 ~ o .~ r ..~ /., ~ ~ ~'~ o w ~ /,! T ~wt , ~ h ~-vr cf,P ~C.o~z°,a ~`~ li C~ ~ ~~'~ ~Ja~sY, ~.~ ,¢„~~ ~ o ~yh Z' ~ ~ ~~~ ~O f~ o~-r> Cy~ /rJ~' /~ P~ q~t ~ Trs L..~-- . 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'~ y ~ "~~ ~ ~s ~i~s ~ . . ~'n r''j !,S ,Si o~ c ~, , .~r~ i~v ~ r. ~ ~,~~ u,~/ ~~ ~ - . ° -~ ~ ~- ~ n /t~ r.~f-7~7c~ P ,o- ~v ~-.~c.~ ~ /t ~s s~'S ~~l!'frj^j O~v~1~~ ~. // s ~4 ,~,1 h'l ~ ti f~,~- ~~~'s-/ ',S.~a/,~ ~,s ~s ~.9,:~' .~~,~ .~ 9, ~ ~a~r.~. •~/~,~~ ,/~ . ~"" r ~,l~ _ ~~ ~ ~ ~~~~ ~l ~~,, s~~,~ ~. ~ ~ ~,o~ro-r, s ~~ L ~~Y ~/ /~`-L~° . ~~ ~ ~ ~ ~~ ,k _ • I ~ ~ T .1 January 13, 2009 Alaska Oil and Gas~ssociation 121 W. Fireweed Lane, Suite 207 Anchorage, Alaska 99503-2035 Phone: (907)272-1481 Fax: (907)279-8114 EmaiL crockett@aoga.org Marilyn Crockett, Executiv~e ~i~ctor Commissioner Dan Seamount, Chair Alaska Oil and Gas Conservation Commission 333 W. 7~' Avenue, Suite 100 Anchorage, Alaska 99501 Dear Commissioner Seamount: AOGA Comments on Meterin~ Equipment Reg,ulations [20 AAC 25228(bl] The 16 members of the Alaska Oil & Gas Association (AOGA) account for the majority of oil and gas exploration, development, production, transportation, refining and marketing activities in the state. We appreciate the opportunity to comment on these proposed regulations. Our member companies are concerned about the potential broad application, interpretation and implementation of the proposed regulations. Criven that AOGA members are unaware of the background and reasoning for the proposed changes, we are concerned that if the current draft is adopted there is the potential for inadvertent noncompliance. Our questions and concerns are most significant in cases where there will be surface or subsurface commingling of pools/units prior to the actual custody transfer meter. In that case a "methodology" is developed to allocate production to the individual pools/units utilizing the _ existing custody transfer equipment as well as other metering and/or welt test equipment. In these comments, the term "production measurement equipment" refers to Lease Automatic Custody Transfer (LACT) Units and other oil and gas metering installations in similar service. The following questions and comments illustrate our concern: 1. What is the definition of "hydrocarbon measurement equipment" as expressed in section 20 AAC 25.228 entitled 'Production measurement equipment for custody transfer"? Will the hydrocarbon measurement equipment be limited to production metering equipment for liquid and gas as the fluid leaves the lease, or will the proposed language be interpreted to include well testing equipment? Well test equipment is not generally considered for production metering service and then only in commingling operations. = ~ • 1 Alaska Oil and Gas ConservatioT~Commission ~anuary 13, 2009 Page 2 Members companies do no object to the application of the proposed revisions to production metering equipment, however, there is concern about the general application to well test equipment. 2. What does the term "methodology" mean in the conte~ of the proposed revisions? The term "methodology" may refer to the calculations inherent in the operation of the production metering equipment or it may refer to the determination of volumes allocated to commingled pools or units. If the term "methodology" is applied to production metering eyuipment, member companies would not object. However there is concern if the term "methodology" makes reference to well test equipment. The process for gaining approval is also unclear. Will we need to provide our current methodology for approval or simply future methodology changes? 3. What level of equipment changes will be considered "altering hydrocarbon measurement equipment"? That is, what is the definition of altering? The concern with respect to production metering equipment and well test units is the potential requirement to apply for approval for even routine maintenance activities. For example, does it include replacing a gauge on a meter run, and does it include changing orifice plates? 4. There is no change proposed to the referenced API Manual of Petroleum Measurement Standards, as revised as of November 30, 1998. While a standard reference is needed, we suggest language be included that allows operators to use the latest revision of the API standard or methods approved by the AOGCC. For example, the November 30, 1998 standard does not allow the use of ultrasonic meters or coriolos meters for fluid measurement. 5. Use of the term "provide information" is vague and could lead to confusion as to what exactly is required. Required information should be specified in the regulations, such as manufacturer specifications, certifications, or gas flow schematics etc. 6. Timing for approvals - new installations: In cases where a totally new installation is required, the design of the processing and metering equipment is often far in advance of the actual installation. However, in the case of surface commingling, existing metering equipment will most likely be used. The AOGCC approval process for this case is vague with respect to methodology and timing. Our concem is possible delays for approvals of the methodology and custody transfer equipment. We suggest a timeline be established for acquiring AOGCC approvals for new installations. y r ! ~ t Alaska Oil and Gas Conservation Commission ~anuary 13, 2009 Page 3 7. Timing for approvals - existing installations: Shauld there be a failure of the current custody transfer equipment, some provision for rapid approval of changes is required to minimize disruption. What will be required to demonstrate that the changes meet the requirements of the API Manual of Petroleum Measurement Standards? Will approval of replacement with a newer model of the same basic equipment be required? Will existing production metering equipment be grandfathered or be required to be re-approved? Additionally, we have a suggestion regarding approval for surface commingling between units in section 20 AAC 25228(a). We suggest adding specific language to 25.228(a) to allow hydrocarbon production to be measured downstream of an approved commingling point. Due to conflicting schedules and the recent holiday season, we were unable to facilitate a working session with AOGCC staff engineers to clarify the intent and application of these proposed regulations. AOGA believes a future working session would be beneficial to both industry and the AOGCC. Please call Harry Engel, Chairman of the AOGA AOGCC Task Crroup at 564-4194 for any questions or to arrange a work session. Again, thank you for providing this opportunity to comment. We look forward to working with the Commission. Sincerely, ~ /i , '~ . fff ~ ~ , f ' ,;' - ~ % 1` i ~` f`'"~.-'~~ ~'r ~ ,,~~f~' F:-~,~1s~ L.~'' .~.,.t't~r~/ ~ ..~.'~, c- f. L ,, MARII.YN CROCKETT Executive Director Cc: Commissioner Cathy Foerster Commissioner John Norman .~ • ~ Suggested edits to AOGCC's proposed amendment to 20 AAC 25.228. 20 AAC 25.228. Production measurement equipment for custody transfer. (a) Hydrocarbon production must be measured in accordance with this section before severance from the property or unit where produced, u #~I- ~~n t~ aoe~rov+~d ~urfac±~ cc~nin~t~ ~lvwon pr~s~rf~rs ~ un~r. Crude oil sample collection, handling, and analysis in connection with production measurement must be performed in conformance with relevant parts of the API Manual of Petroleum Measurement Standards, as revised as of November 30, 1998. Comment: This exception clarifies that Liberty (and similarly situated units) can sever production prior to measurement through a LACT meter, provided that the operator has sought AOGCC approval of surface commingling. (b) Hydrocarbon measurement equipment must be fabricated, installed, and maintained in conformance with relevant parts of the API Manual of Petroleum Measurement Standards, as revised as of November 30, 1998. Comment: The suggested language allows the operator to install custody transfer meters that meet APl standards without obtaining AOGCC approval, which altows more flexibility in maintaining project schedules. The operator must sfill seek AOGCC approval of custody transfer meters and methodologies prior to commencing production. The operator should be able to conduct maintenance that does not substantively alter the approved meter. Y~~41tli Qf D#t'~S tN t31e'I~~~. Draft Custody Transfer Meter regulat~comments . Page 1 of 2 Colombie, Jody J (DOA) From: Maunder, Thomas E (DOA) Sent: Thursday, December 11, 2008 3:59 PM To: Grimaldi, Louis R(DOA); Regg, James B(DOA) Cc: Foerster, Catherine P(DOA); Colombie, Jody J(DOA) Subject: FW: Draft Custody Transfer Meter regulation comments Attachments: Draft Revision 20 AAC 25 228.doc Lou and Jim, Harry called this morning to discuss the proposed amendment to 25.228 and would like to meet. I indicated that I will not be available until in the New Year and asked him to forward any comments/concerns BP had. I wanted to forward his message for your comments. I just checked with Jody and she has not received any other comments. The hearing will be held as scheduled since it concerns changing a regulation. Tom From: Engel, Harry R [mailto:Harry.Engel@bp.com] Sent: Thursday, December 11, Z008 2:43 PM To: Maunder, Thomas E (DOA) Cc: Bill, Michael L(Natchiq); Crandall, Krissell; Engel, Harry R; moriarty@aoga.org Subject: Draft Custody Transfer Meter regulation comments HiTom- This is a follow up to our telephone conversation today regarding the above subject. As we discussed, BP has several questions and potential concerns with the proposed custody transfer metering regulation changes to 25.228(b). We would like to meet with you prior to the scheduled hearing to discuss the intent of the regulations and our questions. Our questions and concerns are most significant in cases where there will be surface commingling of pools/units prior to the actual custody meter. In that case a"methodology" is developed to allocate production to the individual pools/units utilizing the existing custody transfer equipment as well as other metering and/or testing equipment. Our main questions and concerns are listed below. - Timing for approvals - new installations: In cases where a totally new installation is required, the design of the processing and metering equipment is often far in advance of the actual installation. However, in the case of surface commingling, existing metering equipment will most likely be used. The AOGCC approval process for this case is vague with respect to methodology and timing. Our concern is possible delays for approvals of the methodology and custody transfer equipment. We suggest a timeline be established for acquiring AOGCC approvals for new installations. - Timing for approvals - existing installations: Should there be a failure of the current custody transfer equipment, some provision for rapid approval of changes is required to minimize disruption. What will be required to demonstrate that the changes meet the requirements of the API Manual of Petroleum Measurement Standards? Will approval of replacement with a newer model of the same basic equipment be required? 12/12/2008 Draft Custody Transfer Meter regulat~comments • Page 2 of 2 . - Scope of the regulation: The proposed language uses the term "Hydrocarbon measurement equipment" within the section 25.228 entitled "Production measurement equipment for custody transfer" . Will the new regulation apply only to the actual custody transfer meter installation (LACT) or to all metering and testing equipment that may provide data used in the methodology? Will existing equipment be grandfathered or be required to be re-approved? - Approval for surface commingling between units. Suggest adding specific language to 25.228(a) for clarity. Enclosed is a draft of possible changes to the proposed regulation. «Draft Revision 20 AAC 25 228.doc» Thanks for your help. We look forward to meeting with you in early January after you return to the office and before the scheduled hearing. Please let me know when you will be available during the week of January 5th. Regards, Harold R. Engel (Harry) Engineering Team Leader Integrity Management, Alaska Drilling & Wells 907-564-4194 office 907-564-5510 fax 12/12/2008 20 AAC 25.228 Proposed Changes in~egulation -- CPAI Comments ~ Colombie, Jody J (DOA) From: Timmerman, Sherry A [Sherry.A.Timmerman@ConocoPhillips.com] Sent: Monday, January 12, 2009 4:03 PM To: Colombie, Jody J (DOA) Subject: 20 AAC 25.228 Proposed Changes in Regulation -- CPAI Comments Attachments: 090109 20 AAC 25.228 Comments (CPAI to AOGCC).pdf Ms. Colombie, Attached find comments to the proposed changes in regulation 20 AAC 25.228. Piease confirm your receipt of this document by responding to this e-mail. Thank you. «090109 20 AAC 25.228 Comments (CPAI to AOGCC).pdf» Sherry Timmerman ConocoPhillips Alaska, Inc. DOT Progrom Coordinator 907-263-3704 Sherry.A. TimmermonC~conocophillips com Page 1 of 1 1/20/2009 • ~ Wayne W. Fietcher, Jr. ~~~~~~~~r~'~~~ Greater Kuparuk Area Operations Suppoet Manager 1 Alaska, ICiC. Post Office Box 100360 Anchorage, Alaska 99510-0360 Telephone 907-265-6441 09 January 2009 Ms. Jody Colombie Special Assistant to the Commission ~laska Oil and Gas Conservation Commission 333 W. 7tl' Avenue, Suite 100 Anchorage, AK 99501 Re: Proposed changes to 20 AAC 25.22${b) -- Production measurement equipment for custody transfer Dear Ms. Colombie: ConocoPhillips Alaska, Inc. (CPAT) herein responds to the Alaska Oil and Gas Conservation Commission (Commission) request for comments regarding proposed changes to Title 20, Chapfer 25, of the Alaska Administrative Code (20 AAC 25), published on November 12, 2008. As an operator of both production and transpartation facilities on the North Slope of Ala~ka, CPAI seeks tn maintain custody transfer measurements witl~in the applicable standards, which benefits not only the State of Alaska, but the asset owners and partners, and various other stakeholders. To that end, CPAI offers the comments and recominendations contained herein for the Commission's cansideration. No Change 20 Af1C 2~.228 (a) through (h) establishes the hydrocarbon measurement m~thods and equiprnent standards required by the Commission, (i) identifies opportunities for the Cornmission to evaluate conformance with these approvsd standards, and {j) provides a method for the Gammission to approve exceptions to the required standards when justified. The proposed regulatory chan~e as written appears to establish a new protocol requii•ing Commission approval of all hydrocarbon measurement methods and equipment prior to installation or alteration. Change from exception-based approval to all-inclusive pre-approval may cause a significant and undue burden for all involved parties. . ~ Proposed changes to 20 AAC 25.228(b) Production measurement equrpment for custody ti•ansfer 09 January 2009 Clarify Intent It is unclear why the Commission is proposing the change in the re~ulation. If there is a need to confirm that the methods and equipment planned for new fields meets the API Manual ~f Petroleum Measu~-ement Standard.s (MPMS); the proposed regulation charige should clearly state this intention. Conforrnance can be verified administratively when an operator seeks perrnission to produce the pool. ~ If the intent is to manage change in the existing fields, no change to the existing regulation is necessary. 20 AAC 25.228(b} already requires confirmation with API MPI~IS and 20 AAC 25.228(i) allows conformance to be confirmed by the Commission when witnessing the various operations defined. Define "Alter" and "InstalP' The terms "alter" and "install" are very broad, allow for misinterpretation, and could be restrictive. Although CPAI believes the intent of the proposed regulation is to require Commission approval of substantial changes to measurement methods and equipment {e.g., a new type of flow meter), definitions would provide needed clarity, nai~row the scope of the proposed regulation, and limit rnisinterpretation by all parties. As written, the proposed regulation could be construed to include a variety of routine rnaintenance that should not require agency approval (e.g., replacernent in kind (equal or better) of failed components, device firmware upgrades unrelated to calculations, removing one meter from a bank of meters from service, calibration checks). Proposed Regulation Modi~cations To clarify and narrow the proposed regulation, CPAI recomnlends the Commission, at a minimum, make the following madifications to the proposed regulation: 20 AAC 25.228 (b) ... Before installing e~l~i~g a new hydrocarbon measurement e~tri~~~ system or alterin~ the volume determinatian methodolo~y used for custody transfer• purposes, the operator sl~all submit to the cammission information demonstrating conformance and obtain commission approval of t11e proposed installatidn r~- ^'~°-~°+~^-~ and the methodology proposed for determining hydrocarbon volumes. In addition, the following revision could effectively satisfy t~1e notification protocol for minor alterations without creating a new approval process. Pa~e 2 of ~ _ ~ • ~ Pro~osed changes to 20 AAC 25.228(b) Production measurement equi;pment for custody transfet• 09 Januaiy 2009 20 AAC 25.228 (i) The commission will, in its discretion, require at least 24 hours notice before the following operations so that a representative of the commission can witness the operation: (5) alterations to custody transfer meterin~ equipment CPAI appreciates the opportunity to submit its comments regardrng this proposed re~ula~ion change. If you have any questions, please contact Gary Targac at 265-6586 or 659-7226 or by e-mail at Gary.Targac@conocophillips.com. Sincerely, ~ ~ ~~~ Bobb W. Fletcher, Jr. Greater KuparukArea Operations Support Manager- bc: Alpine Automation E»gineer Alpine Operations and Maintenance Superintendecrt CPF3 Oooguruk Coordinator NSK Automation Engineer NSK Flow Measurement Specialist Johjl Braden, Staff Engineer S~ephen Bradtey, GKA Operations Manager Harry Cellas, Staff E&I Engineer Maleolm Huson, NSOD Pipeliue Operations Supervisor Kenneth Martin, I'roduction Er~gineering Regional Adviso~- Gary Sykes, Exploration Evaluatian and Operations Nlanager Gary 1~argac, Froduction Engineering Supervisor Pase ~ of ~ • ~ Page 1 of 1 Colombie, Jody J (DOA) From: Marsha.Yon@emerson.com Sent: Monday, January 12, 2009 10:36 AM To: Colombie, Jody J (DOA) Cc: Steve.Resnick@emerson.com Subject: Proposed Amendment to 20 AAC 25.228 (b) As a supplier of equipment for hydrocarbon measurement and a member of the API Committee on Liquid Measurement, I'd like to submit the following for your review: The AOGCC proposed amendment statement "Hydrocarbon measurement equipment must be fabricated, installed, and maintained in conformance with relevant parts of the API Manual of Petroleum Measurement Standards, as revised as of November 30, 1998" appears to preclude the use of the more recently published API standards. If the intent is to utilize the most current API standard for new metering installations or changes in flow metering equipment at an existing insta(lafion, the amendment might more clearly state "Hydrocarbon measurement equipment must be fabricated, installed and maintained in conformance with the version of the relevant parts of the AP/ Manual of Petroleum Measurement Standards that is current at the time of the proposed installation or alteration of the equipment " Thank you for the opportunity to comment on the proposed amendment. AAarsha Yo~ (~c~sir~ess Develop~nent Mgr. ~ Micro Motion, Inc. EFnerson Process Management ~ 126~3 Southwest Fnvy, Suite 440 ~ ;t~~ffor;~ I TX ~ 774l7 T+1 281 207 286~ j F±1 281 207 2815 ~ M-~1 281 468 1324 Marsha Yon(i)k?mcrson.com. ~ w~v w. Iimerson Pro ees s. co m/MicroM oti on __ _ _ 1 /20/2009 ~ 4 STATE OF ALASKA ADVERTISING ORDER F AOGCC R 333 W 7th Ave, Ste 100 ° Anchorage, AK 99501 "" 907-793-1238 o Anchorage Daily News PO Box 149001 Ancharage, AK 99514 AGENCY CONTACT Jodv Colombie PHONE OATE OF A.O. January 22, 2009 DATES ADVERTISEMENT REQUIRED: January 23, 2009 THE MATERIAI BETWEEN THE DOUBLE LINES MUST BE PRINTED IN ITS ENTIRETY ON THE DATES SHOWN. SPECIAL INSTRUCTIONS: Advertisement to be published was e-mailed Type of Advertisement Legal~ ^ Display Classified ^Other (Specify) SEE ATTACHED )I~E IN T~2~P~~~RTE ° AOGCC, 333 W. 7th Ave., Suite 100 '~`''~;~ ~,~. ~ '~~""~~~~~~;~~;~~~~«~.~ Anchora e AK 99501 ~ REF TYPE NUMBER AMOUNT 1 VEN z A~ 02910 FIN AMOUNT SY CC PGM ~ 08 02140100 2 r REQUISITIONED BY ,ry~ ~~ . '11V~~n nt~ , ! ! NOTICE TO PUBLISHER ADVERTISING ORDER NO. INVOICE MUST BE IN TRIPLICATE SHOWING ADVERTISING ORDER NO., CERTIFIED AO-02914016 AFFIDAVIT OF PUBLICATION (PART 2 OF THIS FORM) WITH ATTACHED COPY OF ADVERTISEMENT MUST BE SUBMITTED WITH INVOICE DATE PAGE 1 OF TOTAL OF 2 PAGES ALL PAGES COMMENTS LC ACCT FY NMR oisr 73451 DIVISION APPROVAL: 02-902 (Rev. 3/94) ~ Publisher/Original Copies: Department Fiscal, Department, Receiving AO.FRM ~ ~ STATE OF ALASKA SUPPLEMENTAL NOTICE OF PROPOSED CHANGES IN THE REGULATIONS OF THE ALASKA OIL AND GAS CONSERVATION COMMISSION The Alaska Oil and Gas Conservation Commission (Commission) proposes to adopt changes to Title 20, Chapter 25, of the Alaska Administrative Code. The Commission proposes to amend 20 AAC 25.228(b) to require an operator to provide information to and obtain the approval of the Commission prior to the following: (1) installing or altering hydrocarbon measurement equipment used for custody transfer purposes; and (2) adopting ar changing the methodology used for determining hydrocarbon volumes. For a copy of the proposed regulation changes, contact Jody Colombie, Special Assistant to the Commission, at 907-793-1121 or jody.colombie@alaska.gov, or visit www.ao~cc.alaska.gov. The purpose of this supplemental notice it to provide notice of the deadline (which was inadvertently omitted from the notice dated November 12, 2008) for the Commission's receipt of written comments on the proposed regulation changes, including the potential costs to private persons of complying with them. All written comments must be received by the Commission by 4:30 p.m. on February 23, 2009. They must be addressed to Ms. Colombie at jody.colombie cr alaska.~;ov or at the Commission (333 W. 7t~' Ave., Suite 100, Anchorage, AK 99501). If you need a special accommodation because of a disability, contact Ms. Colombie by February 18, 2009. YOU SHOULD COMMENT DURING THE TIME ALLOWED IF YOUR INTERESTS COULD BE AFFECTED BY THE PROPOSED REGULATION CHANGES. After the public comment period, the Commission will, without further notice, adopt the proposed changes or other regulation changes dealing with the same subject ar take no action. Accordingly, the language of any fulal regulations may be different from the proposed changes. (Written and aral comments are public.) Statutory Authority: AS 31.05.030. Statutes Being Implemented, Interpreted, or Made SpeciTic: AS 31.05.030. Fiscal Information: The proposed regulation changes are not expected to require an increased appropriation. DATE: January 23, 2009 Daniel T: ~ ~ eamount, Jr. Chair ~ • STATE OF ALASKA NOTICE TO PUBLISHER I ADVERTISING ORDER NO. ADVERTISING INVOICE MUST BE IN TRIPLICATE SHOWING ADVERTISING ORDER NO., CERTIFIED AO-02914016 AFFIDAVIT OF PUBLICATION (PART 2 OF THIS FORM) WITH ATTACHED COPY OF ORDER ADVERTISEMENT MUST BE SUBMITTED WITH INVOICE F AOGCC R 333 West 7~' Avenue. Suite 100 ° Anch~rage_ AK 995~1 "" 907-793-1238 o Anchorage Daily News PO Box 149001 Anchorage, AK 99514 AGENCY CONTACT ~ DATE OF A.O. PCN ~yvi ~ /7l -ILLI DATES ADVERTISEMENT REQUIRED: January 23, 2009 THE MATERIAL BETWEEN THE DOUBLE LINES MUST BE PRINTED IN ITS ENTIRETY ON THE DATES SHOWN. SPECIAL INSTRUCTIONS: Account # STOF0330 AFFIDAVIT OF PUBLICATION United states ofAmerica REMINDER State of ss INVOICE MUST BE IN TRIPLICATE AND MUST REFERENCE THE ADVERTISING ORDER NUMBER. division. A CERTIFIED COPY OF THIS AFFIDAVIT OF PUBLICATION MUST BE SUBMITTED WITH THE INVOICE. Before me, the undersigned, a notary public this day personally appeared ATTACH PROOF OF PUBLICATION HERE. who, being first duly sworn, according to law, says that he/she is the of Published at in said division and state of and that the advertisement, of which the annexed is a true copy, was published in said publication on the day of 2009, and thereafter for consecutive days, the last publication appearing on the day of . 2009, and that the rate charged thereon is not in excess of the rate charged private individuals. Subscribed and sworn to before me This ` day of 2009, Notary public for state of My commission expires _ Mary Jones XTO Energy, Inc. Cartography 810 Houston Street, Ste 2000 Ft. Worth, TX 76102-6298 George Vaught, Jr. PO Box 13557 Denver, CO 80201-3557 Mark Wedman Halliburton 6900 Arctic Blvd. Anchorage, AK 99502 Baker Oil Tools 4730 Business Park Blvd., #44 Anchorage, AK 99503 Gordon Severson 3201 Westmar Cr. Anchorage, AK 99508-4336 James Gibbs PO Box 1597 Soldotna, AK 99669 Richard Wagner PO Box 60868 Fairbanks, AK 99706 North Slope Borough PO Box 69 Barrow, AK 99723 . I~.J David McCaleb Cindi Walker IHS Energy Group Tesoro Refining and Marketing Co. GEPS Supply & Distribution 5333 Westheimer, Ste 100 300 Concord Plaza Drive Houston, TX 77056 San Antonio, TX 78216 Jerry Hodgden Richard Neahring Hodgden Oil Company NRG Associates 408 18th Street President Golden, CO 80401-2433 PO Box 1655 Colorado Springs, CO 80901 Schlumberger Ciri Drilling and Measurements Land Department 2525 Gambell Street #400 PO Box 93330 Anchorage, AK 99503 Anchorage, AK 99503 Ivan Gillian Jill Schneider 9649 Musket Bell Cr.#5 US Geological Survey Anchorage, AK 99507 4200 University Dr. Anchorage, AK 99508 Jack Hakkila Darwin Waldsmith PO Box 190083 PO Box 39309 Anchorage, AK 99519 Ninilchick, AK 99639 Kenai National Wildlife Refuge Penny Vadla Refuge Manager 399 West Riverview Avenue PO Box 2139 Soldotna, AK 99669-7714 Soldotna. AK 99669-2139 Cliff Burglin Bernie Karl PO Box 70131 K&K Recycling Inc. Fairbanks, AK 99707 PO Box 58055 Fairbanks, AK 99711 - .~~ ~~ 6~ ~ ~ i/zs/~oo9 ~~ ~~ : ~ot ~ ~~ ,n ~ ,~ , ~ ~.- ~ ~_ "R -~ ;. c~, ~ v~„, ,,~ . - . ~: _ ~ ~ t~ , Anchorage Daily News Af~davit of Publication 1001 Northway Drive, Anchorage, AK 99508 AD # DATE PO ACCOUNT 596955 O1/23/2009 02914016 STOF0330 STATE OF ALASKA THIRD JUDICIAL DISTRICT PRICE TO HER OTHER OTHER GRAND PER DAY CHARGES CHARGES #2 CHARGES #3 TOTAL $zz9.os $229.08 $0.00 $0.00 $0.00 $229.08 Shane Drew, being first duly sworn on oath deposes and says that he is an advertising representative of the Anchorage Daily News, a daily newspaper. That said newspaper has been approved by the T1tird 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 advertiseinent 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 ainount of the fee charged for the foregoing publication is not in excess of the rate charged private individuals. Signed< c~\ V W'~/1i~-- Subscribed a d sworn to me before this date: 6 Notary Public in and for the State of Alaska. Third Division. Anchorage, Alaska MY COMMISSION EXPIRES: ~ (~ ' /~ ~~~~ /.~ ~, / - t~~tt~~~r~~~~ ~~~\~~'~N`A -4 ' ~.'QO~- ~L G.~~~T/Q/~y;R!^ ~ ` - e.'_ . ` ° ~~6~..~+ • =~ = :~'~ ---~ ~ ~~ • ~OF ~-~: • - • ,~,1 ~~!! fllj * j','11~~~ ..~...~r STATE QF ALASKA SUFPI,EMENTAI. NOTICE OF PROP(~S~D CI•TANGES IN THE REGULA'F€pNS OF THE ALASKA OIi.AND GAS CONSERVATION COMMISSION The Alaska Oii and Gas Conservation Cornmission '' iGOmmissian) proposes to adopt changes to 7i~te 20, Chapter 25, oP the a{aska AdminfstratAVe Cs~de; TF~ Commission Proposes to arnencf 2U ~,~ 25.228tb} to require arr operator to r0uide i~tformation to and ni obtain the approva! o€ ~ CtSrrtmission prior ia tfie following: {~) insta~l~g czr aFtering hydracarb~at~ ' measurement equfpme~t usetl fo~ Cbstocfy transfer purposes; and f2) aeFppttng or changi~t~ the ' metnodotogy usecf for deFertmining pydfocarbam : volumes: For a copy of the peo~os~ regulation eftan~es, ~ sontact lady cuiombre; Special Assistant to the ~ Commissiott, at 4U7-t93-7~21~ or ~' jody.coUOmbie~alaska;gov; or visiY ! wvvw.aagcc.ataska.8~: i Tkie ptarpose of this suppfer~lentai nQtice it ta provide nottce flf the cEeaekline (whieh was inadvertentty omitted frorit the notice dated November 12, 2008) for the Commission's reeeipt af writteri comments on the proPosed regufatitur Changes, includjng the' potentia! costs to private persons of complping with them. aft written eommenES must be receivetl by tk~ Commission bg 4:30 p>~, on Pebruary 23, 2009. ' They ~ust be addressed ta Ms;, eofombie at jody.eoiombie~alaska~ov or at the CommiSSion c~3 W. 7tft AVe.; Suite 1, AnChoKag2, aK 99501). tf you need a speciaf accommodaRion pecause of a disability, cont~et Ms: GofQmbie by Pebruary 1 s,, 2E109. rou s~rau~.Q con+-a~~r~~r ou~Er~~ Trr~ ~rinne A~LQVlVED ~ YOUR IhITERESTS CQULQ BE A~FEGT~t? : B1f Tk€ PROP~SE6~ R€~SGkERT{QN CFfAN~ES. AfE~F " the pubkic comment period, the Commission wi61, withq~~ further notice, adopt the proposed changes or other reg~tation changes dealingwith t~e sam~ SubjEet tx talee no &Ctiext. Aee€~rdir~ty, tEi6 ang af ar~y final regutations rr~ay b~ different from~e proposed ehanges. NNritten and oraE eomme~ts are public.) StatuMryAuthorlty: AS 39.fT5.fi30. StaNtes Being Imgiemented, Interpireted, or Mede S~eciB~ AS3IAS.Q30. ~i~cal Informstton: Y11~ p~Opms~d r~gtrlatian changes are not ezpected to require an lncreased appropriati0n. ~ DATE: January 23, 2~04 Daniel T. Seamount 1c • Cfrair : AO'-02914015 Putrlished: January 23, 2009 ~ ~ Page 1 of 2 Colombie, Jody J (DOA) _ _ __ _ _ _ __ _ _ _ _ From: Colombie, Jody J (DOA) Sent: Thursday, January 22, 2009 2:49 PM Subject: Supplemental Notice AOGCC Hydrocarbon Metering Attachments: Supplemental Notice.pdf; Hydrocarbon Measurement Equipment Regulation.pdf BCC:Aaron Gluzman; caunderwood@marathonoil.com; Dale Hoffman; Fridiric Grenier; Gary Orr; Joe Longo; Lamont Frazer; Marc Kuck; Mary Aschoff; Maurizio Grandi; P Bates; Richard Garrard; Sandra Lemke; Scott Nash; Steve Virant; Tom Gennings; Willem Vollenbrock; William Van Dyke; Woolf, Wendy C(DNR); Aleutians East Borough; Anna Raff; Barbara F Fullmer; bbritch; Bill Walker; Brad McKim; Brandon Gagnon; Brian Gillespie; Brit Lively; Bruce Webb; buonoje; Cammy Taylor; Cande.Brandow; carol smyth; Cary Carrigan; Charles O'Donnell; Chris Gay; Cliff Posey; Dan Bross; dapa; Daryl J. Kleppin; David Brown; David Gorney; David Hall; David House; David L Boelens; David Steingreaber; ddonkel; Deborah Jones; doug_schultze; Eric Lidji ; Evan Harness; eyancy; foms2@mtaonline.net; Francis S. Sommer; Fred Steece; Garland Robinson; Gary Laughlin; Gary Rogers; Gary Schultz; ghammons; Gordon Pospisil; Gregg Nady; gspfoff; Hank Alford; Harry Engel; Havelock, Brian E(DNR); jah; James Scherr; Janet D. Platt; jejones; Jerry McCutcheon; Jim Arlington; Jim White; Jim Winegarner; Joe Nicks; John Garing; John S. Haworth; John Spain; John Tower; John W Katz; johnny.aiken@north-slope.org; Jon Goltz; Julie Houle; Kari Moriarty; Kaynell Zeman; Keith Wiles; knelson@petroleumnews.com; Krissell Crandall; Kristin Dirks; Laura Silliphant; Lynnda Kahn; mail=akpratts@acsalaska.net; mail=foms@mtaonline.net; Marilyn Crockett; Mark Dalton; Mark Hanley; Mark Kovac; Mark P. Worcester; Marquerite kremer; Matt Rader; Melanie Brown; Mike Bill; Mike Jacobs; Mike Mason; Mikel Schultz; Mindy Lewis; MJ Loveland; mjnelson; mkm7200; Nick W. Glover; NSK Problem Well Supv; NSU, ADW Well Integrity Engineer; Patty Alfaro; Paul Decker; Paul Winslow; Pierce, Sandra M (DNR); Randall Kanady; Randy L. Skillern; rcrotty; Rice, Cody J(DNR); rmclean; Rob McWhorter ; rob.g.dragnich@exxonmobil.com; Robert Campbell; Robert Fowler; Robert Province; Roger Belman; Rudy Brueggeman; Scott Cranswick; Shannon Donnelly; Sharmaine Copeland; Sondra Stewman; Sonja Frankllin; Stan Porhola; stanekj; Steve Lambert; Steve Moothart; Steven R. Rossberg; tablerk; Tamera Sheffield; Temple Davidson; Terrie Hubble; Tim Lawlor; Todd Durkee; Tony Hopfinger; trmjrl; Von Gemmingen, Scott E(DOR); Walter Featherly; Walter Quay; Wayne Rancier; Birnbaum, Alan J(LAW); Crisp, John H(DOA); Davies, Stephen F(DOA); Fleckenstein, Robert J(DOA); Foerster, Catherine P(DOA); Grimaldi, Louis R(DOA); Johnson, Elaine M(DOA); Jones, Jeffery B(DOA); Laasch, Linda K(DOA); Mahnken, Christine R(DOA); Maunder, Thomas E(DOA); McIver, Bren (DOA); McMains, Stephen E(DOA); Noble, Robert C(DOA); Norman, John K(DOA); Okland, Howard D (DOA); Paladijczuk, Tracie L(DOA); Pasqual, Maria (DOA); Regg, James B(DOA); Roby, David S(DOA); Saltmarsh, Arthur C(DOA); Scheve, Charles M(DOA); Seamount, Dan T(DOA); Smith, Chasity R(DOA); Williamson, Mary J(DOA); Austerman, Alan; Buch, Bob (LAA); Bunde, Con (LAA); Chenault, Mike (LAA); Cissna, Sharon (LAA); Coghill, John (LAA); Crawford, Harry (LAA); Dahlstrom, Nancy (LAA); Davis, Bettye J(LAA); Doogan, Mike (LAA); Dyson, Fred (LAA); Edgmon, Bryce E(LAA); Ellis, Johnny (LAA); Elton, Kim S(LAA); Fairclough, Anna (LAA); Foster, Richard; French, Hollis (LAA); Gara, Les (LAA); Gardner, Berta (LAA); Gatto, Carl (LAA); Gruenberg, Max F(LAA); Guttenberg, David (LAA); Harris, John (LAA); Hawker, Mike (LAA); Herron, Bob; Hoffman, Lyman F(LAA); Holmes, Lindsey (LAA); Huggins, Charlie (LAA); Johansen, Kyle B(LAA); Johnson, Craig W(LAA); Joule, Reggie (LAA); Kawasaki, Scott Jw (LAA); Keller, Wes (LAA); Kelly, Mike (LAA); Kerttula, Beth (LAA); Kookesh, Albert (LAA); Lynn, Bob (LAA); McGuire, Lesil L(LAA); Menard, Linda K; Meyer, Kevin G(LAA); Millett, Charisse; Munoz, Cathy; Nelson, Mary (LAA); Neuman, Mark A(LAA); Olson, Donny (LAA); Olson, Kurt E(LAA); Paskvan, Joe; Petersen, Pete; Ramras, Jay B(LAA); Salmon, Woodie W(LAA); Seaton, Paul (LAA); Stedman, Bert K(LAA); Stevens, Gary L(LAA); Stoltze, Bill (LAA); Therriault, Gene (LAA); Thomas, Biti (LAA); Thomas, Joe (LAA); Tuck, Chris; Wagoner, Tom (LAA); Wielechowski, Bill (LAA); Wilken, Gary R (LAA); Wilson, Peggy A(LAA); David Johnson; Kara, Danny T; Leslie Adams; Randy Hicks; Tiffany Stebbins 1 /22/2009 ~ ~ Page 2 of 2 Attachments:Supplemental Notice.pdf;Hydrocarbon Measurement Equipment Regulation.pdf; Attached is a Supplemental Notice that merely provides a date (February 23, 2009) by which the AOGCC must receive written comments in regards to the proposed regulation changes to 20 AAC 25.228 (b). Attached for the convenience of those legislators who have been newiy elected, I am attaching the original notice as well as the proposed regulations along with the supplemental notice. The recent new meter installations have uncovered a gap in our regulations. There is currently nothing to specify that and how an operator must receive initial approval for custody transfer metering equipment. Custody transfer metering systems are used to measure hydrocarbon volumes for revenue and tax determinations. Therefore, initial approval is necessary to prevent an improperly designed, installed, or calibrated custody transfer metering system from going into service. Jody J. Colombie Special Assistant to the Commission Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, Alaska 99501 (907) 793-1221 Direct Line (907) 276-7542 Fax 1 /22/2009 ~3 II ~ ~ 1' ALASKA OIL AND GAS CONSERVATION COMMISSION 2 Before Commissioners: Daniel T. Seamount, Chair Cathy Foerster 3 John K. Norman 4 In the Matter of the Proposed } 5 Amendments to 20 AAC 25.228 and ) 20 AAC 25.230 Regarding ) 6 Production Measurement Equipment ) for Custody Transfer Regulations ) 7 ) 8 ALASKA OIL and GAS CONSERVATION COMMISSION Anchorage, Alaska 9~ ~~ January ~3, 2009 101~ 9:00 o'clock a.m. 11 VOLUME I PUBLIC HEARING 12 BEFORE: Daniel T. Seamount, Chair 13 Cathy Foerster, Commissioner John K. Norman, Commissioner 14 15 16 17 18 19 20 2i 22 23 24 25 I I I 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 1 i 21, 3 4 5 6 7 8 9 1 l~ 11 12 13 i 14 ~ y~ I 16 17 18 19 2Q 21 I 22 23 24 25 ~ ~ TABLE OF CONTENTS Opening remarks by Chair Seamount Testimony by Tom Maunder Testimony by Marilyn Crockett Testimony by Harry Engel 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 03 08 15 17 . ~ 1 I! 2 3I I 4 5 6 7 8 9 10 11 12 13 ~ 14 15 16 17 18 19 ~ 2OI 21 I 22 23 24 25 P R 0 C E E D I N G S Tape 1 0050 (On record - 9:03 a.m.j CHAIR SEAMOUNT: On the record. Today is Tuesday, January 13th, 2009; is it 9:03 a.m. We're located at 333 ~r~est Seventh Avenue, Suite 100, Anchorage, Alaska. Those are the offices of the Alaska Oil & Gas Conservation Commission. To my left is Commissioner Cathy Foerster, to my right is Commissioner John Norman. And I am Dan Seamount, the Chair. If anyone has any special needs; please let Tracie Paladwczuk -- did I do that right? MS. PALADWCZUK: You did. (Off record comments) CHAIR SEAMOUNT; Please see Tracie and she'll make sure that she tries to meet your needs. R& R Court Reporting will be recording the proceedings. You can get a copy from R& R Court Reporters when -- when they are -- when they're ready. The purpose of this hearing is to consider proposed amendments to the Production Measuring Equipment for Custody Transfer regulations of the Alaska Oil & Gas Conservation Commission. The proposed regulation changes requires operators to provide information to and obtain the approval of the Commission prior to one, ~nstalling or altering hydrocarbon 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 • ~ 1 2 3 4 5 6 7 8 9 10 11 12 ~3 14 15 15 17 18 19 20 21 22 23 I 24 25 , measurement equipment used for custody transfer purposes and two, adopting or changing the methodology used for determining hydrocarbon volumes. Notice of this hearirg was published in the Anchorage Daily News on November 14th, 2008. It's also been posted on the State of Alaska online notices website as well as AOGCC's own website. This hearing will be hel~ in accordance with 20 A.AC 25.540 of the Alaska Administrative Code. The hearing will be recorded. Is the sign up shee~ around here somewhere? COMMISSIONER FOERSTER: Somebody just came in who hasn't signed in. CHAIR SEAMOUNT: I want to remind anybody that has an intention to testify this morning that you speak in both the microphones, there's two microphones in front of you, one is for amplification within this room -- can ever~body hear me okay, it's working? Okay. And ~he other is for the purposes of facilitating the court reporter's work. The practice is to swear witness~s and we will follow the practice. Also if you do intend to be testifying as an expert wi~ness, that is someone with experience and background on the subject matter on the regulations, then I will ask you to indicate your background and your experience so the Commission can gauge whether you fall into the cateaory of an expert witness. And where is the sign up sheet? R& R C 0 U R T R E P 0 R T E R S 811 G STREET C907)277-0572/Fax 274-8982 ANCHORAGE, ALASKA 99501 4 ~ ~ i 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 1S I i9l I 20 21 22 23 24 25 (Off record comments) CHAIR SEAMOUNT: We have one, two, three testifiers, One, Tom Maunder, Senior Petroleum Engineer with the AOGCC, I guess he'll testify first to introduce people to the amendments. And then we've got Marilyn Crockett of AOGA who wishes to testify. I assume you want to go next, is that true, Marilyn, you want to go before Harry Engel of BP? Will that be the order? Okay. A11 right, Good deal. If there's anybody -- is there else in the room that wishes to testify? Hearing none, we'~l check one more time after the three for sure testifiers testify. Okay. We'll start with Mr. Tom Maunder, AOGCC. Are you going to be giving sworn testimony? MR. MAUNDER: Yes, sir, I will be. CHATR SEAMOUNT: Raise your right hand. (Oath administered) MR. MAUNDER: I do. CHAIR SEAMOUNT; Please state your name? MR. MAUNDER: Thomas E. Maunder, M-a-u-n-d-e-r. CHAIR SEAMOUNT: VJho do you represent? MR. MAUNDER: I represent the stafi ot the Alaska Oil & Gas Conservation Commission. I'm a Senior Petroleum Engineer working for the Commission. CHAIR SEAMOUNT: Do you wish to be considered an expert witness? i MR. MAUNDER: Yes, sir, I do. , & R C 0 U R T R E P 0 R T E R 811 G STREET (907)277-0572/Fax 274-8982 ANCHORAGE, ALASKA 99501 J i ~ ~ i~ CHAIR SEAMOUNT: Please give us your qual -- oh what is 2 the subject..... 3 MR. MAUNDER: I would..... 4 CHAIR SEAMOUNT: .....or what is the discipline that you 5 want to be the expert in? 6 MR. MAUNDER: Petroleum Engineering. 7 CHAIR SEAMOUNT: And, I guess, just give us your 8~ qualifications? 9 MR. MAUNDER: Thank you Commissioner Seamount. 10 COMMISSIONER FOERSTER: What subset of petroleum 11 engineering so you don't give us all of your quaTifications? 12~ MR. MAUNDER: With regard to the measurement for custody 13 transfer. 14 COMMISSIONER FOERSTER: Ail right. So you just really 15~ need to keep your qualifications to that. 16 MR. MAUNDER: Yes, Commissioner Foerster. I have a il 17 bachelor of science from Montana State Universit~r in 1977 in 18 chemical engineering and have been employed in various aspects 19 of the oil industry since graduating college. 20 Early on in that career employed for Phillips Petroleum 21 Company in Norway. I was involved with the custody transfer I 22i measurement of their Ekofisk project in the North Sea. I've 23 also -- as I have progressed in my career I returned to 24 association with measurement activities when I joined the 25 Commission in September of 1999. , R& R C 0 U R T R E P 0 R T E R S I ~ I 811 G STREET (907>277-0572/Fax 274-8982 ANCHORAGE, ALASKA 99501 6 ! # 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 1F 17 18 19 i 20 21 22 23 24 25 As an Engineer on the Commission and then Senior Petroleum Engineer on the Commission is has been my -- part of my responsibility has been to work with the inspectors as they examine and audit the proving and calibration of the various metering facilities throughout the state of Alaska. We are fortunate to have a very experienced cadre of inspectors that keep close tabs on the equipment that is used for measuring hydrocarbons as they are produced throughout the state both in Cook Inlet and on the North Slope. My experience with the custody transfer measurement in particular has been involved with familiarity with the API petroleum standards and the ability early on in my career when I was involved with the measurement in the North Sea to take the proving equations and program them into hand held calculators to facilitate the work on the inspectors that were employed at t.hat time. I°m not sure what else you would wish me to add. COMMISSIONER FOERSTER: That's enough for me. CHAIR SEAMOUNT: Commissioner Foerster, I guess yau've already -- do you have any other comments or questions? COMMISSIONER FOERSTER: I'm good. CHAIR SEAMOUNT: Commissioner Norman, do you have any comments or questions? COMMISSIONER NORMAN: I have no questions. CHAIR SEAMOUNT: Let's see, how do we do this, it's been a R& s~ 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 7 'i i II ~ ~ 1 while? 2 COMMISSIONER NORMAN: The Chair can just accept..... 3 CHAIR SEAMOUNT: Okay. We wi11 accept Mr. Maunder as an 4 expert witness in the discipline of petroleum engineer with the 5 specific expertise in metering. Is that correct, Commissioner 6 Foerster? 7 COMMISSIONER FOERSTER: Works for me. 8 CHAIR SEAMOUNT: Okay. Before we proceed with Mr. 9 Maunder, I did a fo pa {ph} in hearing etiquette and I was 1G' wondering do an~r of the other Commissioners have any 11 preliminary statements or comments to make regarding this 12 hearing? 13I (Off record comments) i 14j1 COMMISSIONER NORMAN: I have nothing. 15 CHAIR SEAMOUNT: Okay. Please proceed, Mr. Maunder. i i 16 MR. MAUNDER: Thank you, Commissioner Seamount. ~ I ~7 THOMAS E. MAUNDER i 18 previously sworn, called as a witness on behalf of the AOGCC, 19 testified as follows on: 20~ DIRECT EXAMINATTON ' 21 MR. MAUNDER: I have a prepared statement that Tracie has 22 copies of and she'l1 distribute to the audience here. 23 (Off record comments) 24 CHAIR SEAMOUNT: Mr. Maunder, please proceed. 25I MR. MAUNDER, Thank you, Commissioner Seamount. The , I i ~ i R& R C 0 U R T R E P 0 R T E R S 811 G STREET i {907)277-0572/Fax 274-8982 ANCHORAGE, ALASKA 99501 8 I 1 2 3 4 5 6 7 8 9 1G 11 12 13 14 15 16 17 18 ',, i9 2G 21 22 23 24 25 a ~ Commission's authority regarding the measurement of oil and gas may be found at AS 31.05.030(d)(6) where it is stated, the Commission may require the gauging or other measuring of oil and gas to determine the quality and quantity of oil and gas. 20 A.AC 25.228 and 25.230 are the present regulations that implement the authority granted in statute for measurement. 25.228 first appears in the regulations effective April 2nd, 1986 and as written then specifically pertain to the equipment employed to physically measure and mathematically calculate the quantities of oil and gas. 25.230 immediately following contained further requirements pertaining to individual well measurement and allocation as well as a measurement prior to severance from the property or unit where produced. 25.230 in an earlier form was present in the Commission regulations effective July, 1980. Measurement prior to severance from the property or unit is known as custody transfer. It is also known as LACT or lease automated custody transfer. In 1998 25.228 and 25.230 were amended and reorganized. 25.228 in its amended form addresses measurement equipment and procedures for custody transfer measurement. 25.230 as currently written addresses only allocation measurement and production reporting. The intent of the amendment being considered today is to require the operator of the unit or property to involve the ~ommission. before a new custody transfer station is installed R& R C 0 U R T R E P 0 R T E R S 811 G STREET (907)277-0572/Fax Z74-8982 ANCHORAGE, ALASKA 99501 9 ~ ~ 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 ~ 23 24 25 or existing equipment is altered. By adopting this amendment ~he onus is on the operator to apprise the Commission of their plans in advance of the equipment being fabricated and installed or altered. The adoption of this amendment will allow the Commission to conduct our due diligence regarding custody transfer measurement and help avoid situations that have been encountered in the last several years: These include the fabrication and installation of.equipmerit to measure gas leaving Alpine for Nuiqsut. When the Commission was ultimately presented with the information on the meters it was determined that the uncertainty of the meters chosen exceeded that of standard orifice meters and the chosen meters ultimately needed to be replaced. Another situation was encountered where the functional meter elements, inciuding the electronic signaling equipment, were changed and the Commission first became aware of the changes when one of the inspectors was routinely inspecting the measurement location. Ir~ the first case the uncertainties of the chosen meters clearly exceeded the uncertainty of orifice meters which is essentially the`maximum uncertainty presently accepted. Contact up front with the Commission would have eliminated the need to replace the meters. In the second case wh~le the new equipment did meet the requirements of the petroleum 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 10 ~ ~ 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 i i 17 I 1~ 19 I 20 21 ~ i 22 2 3 I~I 24 25 measurement standards which satisfied the present effective regulation, I don't believe it's acceptable that changes in custody transfer measurement equipment are discovered through routine inspection. I do not believe that this amendment places a large burden on the operators. The State is nat the only party interested in quality measurement being performed. There are other parties to the commercial transaction with financial interest in excess of the State's. The present regulation requires that equipment used for custody transfers be fabricated, installed and maintained in accord with petroleum management standards and that the ultimate measurement of hydrocarbon also be in accord with the standards. This proposed arnendment does not change that. The additional requirements being placed in the regulation are to provide the Commission advance notice, copies of the relevant document regarding the equipment and calculations and the opportunity to review and concur with the plans. This concludes my testimony. CHAIR SEAMOUNT: Thank you, Mr. Maunder. Commissioner Foerster, do you have any comments or questions? COMMISSIONER FCERSTER: I do. i have or~e. Mr. Maunder..... MR. MAUNDER: Yes, Commissioner? COMMISSIONER NORMAN: .....somewhere in the back of my R& R C 0 U R T R E P 0 R T E R S 811 G STREET (9~7)277-0572/fax 274-8982 ANCHORAGE, ALASKA 99501 11 . • 1 2 3 4 5 5 7 8 9 10 ' 2i j i I 12 13 ~ 14 15 16 1? j , 18 j 19 20 21 , 22 ~ I 23 ~ 24 25 mind I°m remembering a case where one of our inspectors discovered that there was a custody transfer meter that we weren't aware of or that -- is that true? MR. MAUNDER: Yes, ma'am, that is true. There was a gas measurement station on the Inlet -- on the Kenai peninsula that had been placed in service and again it was discovered when one of the inspectors was down doing routine inspections. COMMISSIONER FOERSTER: Okay. So that's another example of the impetus..... MR. MAUNDER: Yes, ma'am. There are a total, I believe, of about five events in the last four or five years. COMMISSIONER FOERSTER: Okay. Thank you. So I have another question. When you talk about individual well measurement, does that apply to every measurement technique employed everywhere or is it just for custody transfer measurements? MR. MAUI~TDER: This amendment pertains specifically to custody transfer measurement. COMMISSIGNER FOERSTER: Okay. MR. MAUNDER: We are not -- we are not extending it into the equipment that's used for well testing..... COMMISSIONER FOERSTER: Okay, MR. MAUNDER: .....that is not maintained to the standard, the exactness of the equipment used to measure the production being taken from a lease. R& R C 0 U R T R E P O R T E R S 811 G STREET C907)277-0572/Fax 274-8982 ANCHORAGE, ALASKA 99501 l~ • ~ 1 2 3 4 5 6 7 8 9 10 ~l 12 13 14 z5 ~- 6 '' 17 I, 18 19 20 ~ 21 22 i 23 24 ' 25 COMMISSIONER FOERSTER: Okay. Thank you. That's all my questions. CHAIR SEAMOUNT: Commissioner Norman, do you have any questions? COMMISSIONER NORMAN: Just one question, Mr. Maunder. You mentioned the additional burden on private persons, operators or others. Could you elaborate a little bit on how if this change is adopted it might place either an additional financial or administrative or other burden on industry or anyone else? MR. MAUNDER: There may be a slight increase in administrative burden in having to do the -- provide the additional copies and interface with members of the Commission staff regarding the proposed metering installation or the -- or the change to an existing station. My experience at least from what I've seen so far is that the documents are al1 prepared -- the documents that we would want copies of are prepared in the course of the station design and the approvals within the parties -- the operators and the partners in a lease or the property. COMMISSIONER NORMAN: Thank you. Nothing further. CHAIR SEAMOUNT: Thank you. Okay. Thank you, Mr. Maunder, if you could stick around until the end of the hearing in case we need to call you back..... MR. MAUNDER: Certainly. CHAIR SEAMOUNT: .....we'd appreciate it. Okay. We'll R 3~ R C 0 U R 7 R E P 0 R T E R S $11 G STREET (907)277-0572/Fax 274-8982 ANCHORAGE, ALASKA 99501 13 ~ ~ 1 2 3 4 5 6 7 8 9 10 11 12 13 ~4 ~5 16 17 18 ~ 19 20 21 22 23 24 ' 25 have our next testifier or testifiers, please, approach -- I guess approach the bench or sit at the table. Sit at the table. Are you both going to be wanting to give sworn testimony? MR. ENGEL: Yes. CHAIR SEAMOUNT: Okay. Please raise your right hands. (Oath administered) MS. CROCKETT: Yes. MR. ENGEL: Yes. CHAIR SEAMOUNT: Thank you. Who will be testifying first? MS. CROCKETT: Mr. Chairman, my name's Marilyn Crockett, I'm the Executive Director of the Alaska Oil & Gas Association. I'm joined today by Mr. Harry Engel with BP. Mr. Engel is the Chair of the AOGCC Task Group that operates within the Association. I'm here to introduce Mr. Engel. I will turn over the actual technical testimony to him after a short introduction on my part. CHAIR SEAMOUNT: And so I assume you don't want to be qualified as an expert witness, is that true? MS. CROCKETT: That's correct, I do not. CHAIR SEAMOUNT: Okay. Then please proceed. MS. CROCKETT: Thank you, Mr. Chairman. MARILYN CROCKETT previously sworn, called as a witness on behalf of AOGA, testified as follows on: R & R C 0 tJ R T R E P 0 R T E R S 811 G STREET (907)277-OS72/Pax 274-8982 ANCHORAGE, ALASKA 99501 14 • . 1 2 3 4 5 6 7 8 9 10 11 l2 13 14 15 16 17 18 19' 2U~ 21 22 23 24 25 DIRECT EXAMINATION MS. CROCKETT: Again my name is Marilyn Crockett, I'm the Executive Director of the Alaska OiI & Gas Association or AOGA as we're otherwise known. AOGA is a trade association which represents the majority of oil and gas exploration, production, transportation, refining and marketing activities in Alaska and our membership comprises companies that operat2 not only -- and produce not only on the North Slope, but also in Cook Inlet. Our Tasx Group is represented by members of the AOGA membership who have expertise and experience in this particular regard. And as I mentioned earlier, Mr. Engel is the Chair of our Task Group and he will be presenting the detailed comments before you today. We've handed out copies of the three page letter that we prepared in advance of this hearing. CHAIR SEAMOUNT: Thank you. MS. CROCKETT: And I will turn it over to Mr. Engel. MR. ENGEL: Good morning. CHAIR SEAMOUNT: And, Mr. Engel, are you -- I assume you want to be qualified as an expert witness..... MR. ENGEL: Yes. CHAIR SEAMOUNT: .....is that true? Okay. What is the subj ect? MR. ENGEL: Petroleum engineering. CHAIR SEAMOUNT: And specifically? MR. ENGEL: Operations. 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 15 ~ ~ 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 , 16 17 ~~ ! 19 20 21 22 23 24 25 CHAIR SEAMOUNT: And could you, please, give us your quaiifications? MR. ENGEL: Yes, Mr. Chazrman. Good morning. My name is Harry Engel and I'm currently an engineering team leader within BP's drilling and wells organization. T have 28 years of experience in the oil and gas industry, focusing on drilling engineering, field, well side leadership roles, operational auditing and some HSE management positions as well. I've worked in the North American Rocky Mountains and most of the operating areas in Alaska with several international assignments. My expertise is focused on drilling engineering with the emphasis on field operations. I have broad knowledge of production measurement equipment technology and the relevant API standards. Considering this is a specialized topic, I have consulted with our engineering staff within BP to understand more of the day to day operations. And i feel I'm qualified this morning to present our comments to the proposed regulations. CHAIR SEAMOUNT: Thank you, Mr. Engel. Commissioner Foerster, comments, questions? (Off record comments) CHAIR SEAMOUNT: Commissioner Norman? COMMISSIONER NORMAN: The only question I have, I believe that Ms. Crockett clarified it, but you are speaking of the R& R C 0 U R T R E P 0 R T E R S 811 u STREET (907)277-0572/Fax 274-8982 ANCHORAGE, ALASKA 99501 ~~ . . '1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16' 1? ~8I 19 20 21 ' 22 I 23 I 24 25 representative for all of AOGA? MR. ENGEL: Yes, Commissioner Norman, I am. This morning I'm representing the AOGA companies as Chairman of the AOGCC Task Group, COMMISSIONER NORMAN: Thank you. CHAIR SEAMOUNT: Do I hear any opposition to qualifying Mr. Engel as an expert witness? COMMISSIONER FOERSTER: None from me. COMMISSIONER NORMAN: No objection. CHAIR SEAMOUNT: Hearing none, Mr. Engel is considered an expert witness for this hearing. MR. ENGEL: Thank you, Mr. Chairman. HARRY ENGEL previously sworn, called as a witneas on behalf of AOGA, testified as follows on: DIRECT EXAMINATION MR. ENGEL: As Marilyn mentioned, we did provide a letter this morning that summarizes our comments, mainly a series of comments and questions regarding the proposed regulations. And we believe that the broad nature of the regulations could present some problems to member companies with regard to the application of the regulation to certain equipment used for petroleum measurement activities in the field. And we believe that due to our -- unclear nature of the regulation, there may be some inadvertent non-compliance that could result from R& R C 0 U R T R E P 0 R T E R S $11 G STREET (907)277-0572/Fax Z74-8982 ANCHORAGE, ALASKA 99501 17 • ~ ~ 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 i I 22 I I 23 I I 24 25 operators not quite understanding the ~otai application of the regulation. So what I'l1 do this morning is go through the letter and -- I'm not going to read it verbatim, but I thought I would summarize our questions and concerns. And if the Commission feels we can deal with the questions now that would be fine or we can just present the questions and then end up with a request that we meet with staff at a later date to better understand the intent and application of the regulations. Is that an okay approach with the Commission? COMMISSIONER FOERSTER; Yes. MR. ENGEL: Okay. Great. So what I'll start with is our questions are significant in cases where we have a surface and/or subsurface commingling of pools or units that take place at -- before actual custody transfer operations. In those cases a methodology is developed that actually allocates production to individual pools or units. And we just want to make sure that we understand how this is going to work with the commingling -- a commingling situation. So the first question we have is around a definition and the definition that we need clarity around is hydrocarbon measurement equipment that's expressed in the current regulation. And the concern there is are we referring LACT meters like Mr. Maunder mentioned earlier or are we talking about well testing equipment. So there -- there's quite a 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 1~ 1 2 3 4 5 6 ~ 8 9 10 11 12 13 14 15 16 I 17 18 19 20 21 II 22 23 i 24 I 25 ~ ~ difference there between tne application of Li~at to either a well testing operation or a lease automated custody transfer unit. COMMISSIONER Iv~ORMAN: Mr. Engel -- if I can ask a question, Mr. Chairman, on that? CHATR SEAMOUNT: Yes. COMMISSIONER NORMAN: Subsection (a) talks about -- sets up the requirement, the conditions for (b) by talking about hydrocarbon production must be measured before severance from the property or unit which would exclude testing on the property unless there is a severance. Your corcern here on item one, I just want to be sure we understand it before we go on by it, is that the change could also pull in testing equipment as well as the traditional LACT meters? MR. ENGEL: Yes. ~OMMISSIONER NORMAN: Okay. MR. ENGEL: Yes, sir. ~ COMMISSIONER NQRMAN: Thank you. i MR. ENGEL: Okay. The second question we have is related , to the term methodology. And the methodology term may refer to the calculations inherent to the operations of inetering equipment or it may refer to the termination of volumes ( allocated to commingled pools or units. So just getting clarity around how that term would apply would be helpful to I us. R& R C 0 U R T R E P 0 R T~ R S 811 G STREET (907)277-0572/Fax 274-8982 ANCHORAGE, ALASKA 99501 19 • ~ 1 2 3 4 S 6 n 8 9 10 11 12 13 14 15 16 17 ! 18 19 ~ c 20 ~ 21 22 23 24 25 The next question is related to altering equipment. To what extent would an altering activity require approval from the AOGCC. So I think that would be beneficial for us to understand to what extent we would have to apply for an application for taking -- just doing, for example, say preventive maintenance activities on a unit. The next point is related to the reference to the API standard in the regulation. And we would recommend that language be included in the proposed regulations that would allow us to use the most current version of the API standard. The next topic is around the expression that's currently in the draft, providing information. We think that's a vague expression and we think that having specific requirements would help an operator fulfill the requirements of the Commission ard help them approve an"application for metering equipment. And the last point or the next point is related to timing for approvals for both new installations and for existing regulation -- existing installations. And we believe a timeline would help an operator to plan and to submit an application to the AOGCC for consideration. There is one point we want to address and that is -- it's not included actually in the draft of the regulation, but it's in section (a) of 25.228. And we're suggesting -- we have a suggestion regarding approval of equipment that would be used to measure volumes downstream of leaving a commingling point. ~ 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 r+ n G 'v ~ ~ 1 2 3 4 5 6 7 8 9 10 11 12 ~~ la 15 16 17 i 8 ~~I 19 20 21 22 23 24 25 For example, if an operator proposes to bring two units together, having the ability to measure hydrocarbon downstream would be beneficial to an operator. And I think..... COMMISSIONER FOERSTER: Do -- can I ask a question? Can you give me any examples of where you have lease -- you know, custody transfer measurement upstream of the commingling? MR. ENGEL: Well, Commissioner Foerster, there may be a case that may be coming up in the near future in some areas where an operator may bring some production into an existing unit and it may be measured before it actually leaves the lease. So it would be a different approach to measuring than we currently have in place today. So I'm talking vaguely, but it's an area that may come up with future development on the North Slope. COMMISSIONER FOERSTER: You -- I'rn assuming that you'l1 be able to talk to us vaguely when you meet with staff? MR. ENGEL: Well, we'll -- I'll bring a hypothetical situation where new units coming in rnay have that situation..,.. COMMISSIONER FOERSTER: OKay. MR. ENGEL: .....to deal with. Then -- and some may -- I think the operators would support the regulations as proposed with some clarity around the points I've addressed this morning. And I'm recommending that we do arrange a session with the staff to work through the comments that we've brought R& R C 0 U R T R E P OR T E R S. 811 G STREET (907)277-0572/Fax 274-8982 ANCHORAGE, ALASKA 99507 21 ~ ~ 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 ~I, i ~ 19 20 21 22 2 3 ~'I 2 4 !I 2 5 II forward and understand the breadth and the broad application of the -- of the regulations so we can comply with them. CHAIR SEAMOUNT: So your proposal is number 1 on our- decisions, meet with staff later instead of address your concerns now? Okay. Thank you. MR. ENGEL: Yes. CHAIR SEAMOUNT; Commissioner Foerster, do you have any questions or comments? COMMISSIONER FOERSTER: I was rude and interrupted every time I had them. (Off record comments) CHAIR SEAMOUNT: Do you have any polite questions or comments, Commissioner Norman? COMMISSIONER NORMAN: I will try to be polite. I have one -- just one question and then one comment. Mr. Engel, I understand that there is a concern about the breadth of this, I'l1 express it that way, that it may pick up pieces of equipment not intended. MR. ENGEL: Right. COMMISSIONER NORMAN: And I'm looking at the change right here. Before installing or altering hydrocarbon measurement equipment used for custody transfer purposes. So that to me would seem to exclude measurement equipment not used for custody transfer purposes, Does that address some of your concerns or do you think that that's still -- that that still 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 GG , .i • ~ ~ ~ ~ ~ i ~ , lj requires clarification? ~ 2I MR. ENGEL: We still think that we need to get clarity 3 around application of this specifically to well testing 4 equipment. 5 COMMISSIONER NORMAN: Okay. And then, Mr. Chairman, just 5~ a comment. I think it would be efficient perhaps rather than I 7 getting into minute details to have a staff ineeting, but I 8 would like to suggest and perhaps request though that we be 9 sure to come back on the record and spread on the public record 10 whatever evolves from those discussions and afford the public 11 also a chance to participate. 12 CHAIR SEAMOUNT: For sure. 13I COMMISSIONER NORMANc I have nothing more. 14 CHAIR SEAMOUNT: Okay. Other -- I guess I'll provide some 15 opportunity right now for questions from any other persons in 16i the audience. Are there -- is there anyone else that would 17~ like to testify. Hearing none, I think maybe tnre should take a 18 l0 minute recess to make sure. Is that..... ~~ 19 COMMISSIONER FOERSTER: That works for me_ 20 CHAIR SEAMOUNT: .....that's appropriate? Okay. Let's 21 take a-- I say 10 minutes, we usually go late on that. We'll 22 try to keep it at 10 minutes. So we'll be back at 9:46 and a 23 half. Off the record. I~ 24 (Off record - 9:36 a.m.) 25 (On record - 9:54 a.m.) I R& R C 0 U R T R E P 0 R T E R S 811 G STREET (9073277-0572/Fax 274-8982 ~ ANCHORAGE, ALASKA 99501 G 3 s ~r , 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17~ 18 ~ 19 20 21 22 23 24 25 CHAIR SEAMOUNT: Let's go on the record. Okay. Mr. Engel, you presented us with two options, one to take care of ~ this matter today and the other to hold a meeting with staff later on which would require a 30 day notice once you guys got things taken care of. The Commission believes that we can address your concerns today. And so we're going to go ahead and do that, try to do that -- attempt to do that in this meeting. And our petroleum engineer Commissioner who has a lot more expertise than I do will take over the managing of this hearing at this time. COMMISSIONER FOERSTER: Okay. Let's take your issues one by one and..... MR. ENGEL: Okay. COMMISSIONER FOERSTER: .....we'll have a discussion among the Commissioners and..... MR. ENGEL: Okay. COMMISSIONER FOERSTER: .....you and Mr. Maunder. MR. ENGEL: Okay. Commissioners, may -- a point of clarification, please. So we're going to move into a working session right now? COMMISSIONER FOERSTER: No, we're still in the hearing. MR. ENGEL: Okay. Okay. So will we be resolving our questions today? COMMISSIONER FOERSTER: We're going to be done today. Okay. The first question -- issue that you raised. We felt 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 ANCNORAGE, ALASKA 99501 ~~ i~ ~ ~ ~ 1 that our verbiage very clearly states that it relates to 2 custody transfer make that a moot point. That, you know, if 3 you read the part about custody transfer then it's not for well 4 testing equipment, it's custody transfer equipment. So we've I 5 clarif~ed that to you. 6 MR. ENGEL: So the intent is that it will not apply to ~ 7I well testing equipment? I 8 COMMISSIONER FOERSTER: Non custody transfer equzpment. 9 viR. ENGEL: Okay. 10 MR. MAUNDER: That is correct, Commissioner Foerster. 11 COMMISSIONER FOERSTER: Okay. ~our second concern relates 12 to using the term methodology and whether that's vague -- too 13 vague or not. And, Mr. Maunder, would you care to comment on 14 your plan to address that concern? 15 MR. MAUNDER: Looking at the covenant that AOGA has 16 subrnitted, it is looking at the calculations inherent in the 17 opera~ion of the metering and not the allocation which as they 18 say in their second paragraph, if the term methodology is 19 applied to production metering equipment they do not object. 20 And that is the intent, is the production metering. 21 COMMISSIONER FOERSTER: Okay. Now your third concern 22 deals with level of equipment changes considering altering and 23 you talk about routine maintenance. If in the caurse of 24 routine maintenance you installed the -- a replacement version 25 of the exact same thing that's not altering, but if you take a R& R C~ U R T R E P 0 R 7 E R S ~ $11 G STREET (907)277-0572/Fax 274-8982 RNCHORAGEy ALASKA 99501 2 S I ~ ~ 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 I 17 18 i9 20 I 21 22 23 24 2 5 ~~ part and replace it with a different part that does not have the same characteristics that's altering. MR. ENGEL: So replace..... COMMISSIONER FOERSTER: Does that make sense? I MR. ENGEL: .....replacing the same, not altering? COMMISSIONER FOERSTER: Just doing routine maintenance is nct altering, but in the course of routine maintenance if vou replace a certain product with a different product that has different characteristics that's altering. MR. ENGEL: Okay. COMMISSIONER FOERSTER: Does that make sense? MR. ENGEL: Yes. COMMISSIONER FOERSTER: Okay. Number 4..... MS. CROCKETT: Commissioner Foerster..... COMMISSIONER FOERSTER: Yes? MS. CROCKETT: ..... excuse me, may I interrupt for just a moment? COMMISSIONER FOERSTER: Sure. MS. CROCKETT: Then help me understand then that -- what you said makes sense, help me understand then what the quick approval process would be in a situation where you've done some maintenance, you've had to replace a piece of equipment and now you've got a newer piece of equipment so it's diiferent. What sort of transition or approval process would the Commission undertake to make sure that that's -- that a piece of equipment R& R C 0 U R T R E P 0 R T E R S 811 G STREET C907)277-0572/Fax 274-8982 ANCHORAGE, ALASKA 99501 26 ~ ! • 1 isn't taken off line for a long period of time waiting for i 21 approvai? 3 COMMISSIONER FOERSTER: Well, ideally the operator would 4 know what equipment he has in his tool kit when he shows up to 5 fix something and he could get advanced approval simply by a 6 phone call to one of the inspectors that's always on the Slope 7 or aiways available in the Inlet. So I'm assuming that the 8 operator knows wi~at he takes out to do work before he gets 9 there, he could make a phone call and get it approved before he 10 did it. 11 MR. ENGEL: Okay. Great. And on the same case, 12 Commissioner, there may be a case where a failure may happen, I ~3i, you may have to substitute a piece of equipment waiting for an 14 appropriate piece. So again, dialogue would be important to 15 understand the approval process for that situation. 15 COMMISSTONER FOERSTER: And we can -- we do always have 17 inspectors, at least one, usually two on the North Slope, ar~d 18i one is always available on call in the Inlet. So if you know ; 19~ what you're doing and you know how to use the phone then 20 approval should not be an issue. 21 MR. ENGEL: Thank you. 22 COMMISSIONER FOERSTER: -0kay. Number 4, I think Mr. 23 Maunder had some concerns that he wanted to share with going to 24 the latest API standard. 25 MR. MAUNDER: At this time -- thank you, 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 I ANCHORAGE, ALASKA 99501 2~ I; • • 1~ Foerster. At this time we are not in favor of bianketly 2i ad~opting the newest versions of the Petroleum Measurement 3 Standards. We are not opposed to operators using them for the 4 design and -- of their metering stations. Such a intent or 5 approval can be secured through subjection (j) of the present 6 regulations where it's stated upon request the Commission will 7~~ in its discretion approve a variance from the requirements of ~ 8' this section if the variance wiil result in equal or improved 9 accuracy in measuring hydrocarbons severed from the property or 10 unit. The Commission staff and the inspectors have a concern 11 that if we blanketly adopted the most recent version of the 12 Petroleum Measurement Standards that that would likely impose , i3 an economic penalty or harm on most of the operators in that it 14 would require them to adopt those standards and potentially 15 alter their equipment and the methodologies with -- you know, 16 carte blanche and not in a more organized fashion. 17I COMMISSIONER FOERSTER: Does that make sense to you guys? 18~ MR. ENGEL: It does. 19~ COMMISSIONER FOERSTER: Okay. 20 MR. ENGEL: What I understand -- what I heard, Tom, was 21 that an operator may submit an application for a technology -- 22 for a metering application..... 23 MR. MAUNDER: That is correct. 24 MR. ENGEL: .....to be considered by the Commission. 25 MR. MAUNDER: Yeah, that is how we've handled approval R& R C 0 U R T R E P 0 R T E R S I ; 811 G STREET , ` t9Q7)277-0572/Fax 274-8982 ~ ~I ` ;! ANCHORAGE, ALASKA 99501 ~ ~ I( ~ ~ . ~ 1 2 3 4 5 5 7 8 9 10 il 12 13 14 I5 16 17 18' 19 20 21 22 ~ 23 I 24 25 I for..... MR. ENGEL: Okay. MR. MAUNDER: .....ultrasonic gas meters in Cook Inlet. MR. ENGEL: Okay. Very good. That's acceptable. COMMISSIONER NORMAN: Mr. Chairman. CHAIR SEAMOUNT; Go ahead. COMMISSIONER NORMAN: And if it is a consensus that a more recent version -- we're working right now with the November 30, 1998, that that should be done, then the Commisslon would be receptive to that. I think the thought is that the Corrtmission needs time to get comfortable with that and also to get the word out that that's what we're doing. So that's another option that's open to you, to suggest to the Commission that we amend it to incorporate the absolute most recent version. MR. ENGEL: Thank you, Commission. COMMISSIONER FOERSTER: On number 5, we felt like that in the verbiage that we included that it's specific enough, information should include, but not be limit~d to. And an operator should be familiar enough with what we do and what your other applications have been and what information is normally required that that should not be too vague. Tom, did you want to add to that and then you might want to say something to that. MR. MAUNDER: Yes. I agree with what your comment is there, Commissioner ~'oerster. You know, the -- trying to be R& R C 0 U R T R~ P 0 R T E R S 811 G STREET (907)277-0572/Fax 274-5982 ANCHORAGE, ALASKA 99501 29 • • 1 2 3 4 5 6 7 8 9 10 ?1 12 13 14 15 ~! i 16 i 17 18 19 20 21 ~~ 22 23 24 25 specific on every bit of information that couid be provided, you know, could box us into a corner. And, you know, the intent of regulations like this that I look at is not to limit what the operator could supply. I believe it's important, you know, from their point of view to educate the Commission as to what the intended plans are. And while I don't want boxes of things, I'd like, you know, a complete description of the metering equipment and the station. COMMTSSIONER FOERSTER: And if the operatcr provided you too little infarmation, what would be your remedy? MR. MAUNDER: It would be to contact him to,,.4, COMMISSIONER FOERSTER: Pick up the phone. MR. MAUNDER: .....seek clarification. COMMISSIONER FOERSTER: Okay. MR. ENGEL: We11, Commissioner, take for example an analogy of a drilling permit. The State has or the Commission has stated very clearly what's required to submit an application for a permit to drill. And because of that an operator knows what to put in the application, they receive, review it and they're handled quite timely. In this case there is not si.lch detail like a drilling permit. So our point was around at least give us some of the broad -- the -- some basics that you want to see in an application to cover the required information otherwise it could create delays in getting authorization. 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 C~ • ~ 1 2 3 4 5 6 7 8 9 ~~ 11 12 13 14 15 16 17 18 19 i I 20I I 21 ~ 22 j I 23 2 4 I;I i 25 COMMISSIONER FOERSTER: Okay. Part of the reason that we're vague is that there is a variety of inetering techniques..... MR. ENGEL: Uh-huh. COMMISSIONER FOERSTER: .....and if we get too specific we may leave something out. And these sorts of things are -- if we need to get more specific we generally do those via specific pool rules. MR. ENGEL: Well, again our concern is around potential delays in submitting applications and receiving approval. So that's why we were considering at least the minimum requirements for an application. And then you -- I agree with you ~hat all conditions are not the same, but all do have fundamentally similar components (indiscernible - simultaneous s~eech) . . . . COMMISSIONER FOERSTER: We can take a harder look at our verbiage and with those concerns in mind. MR. ENGEL: Okay. MR. MAUNDER: If I may add, Commissioner Foerster, it would also be possible to come up with a guidance document as we have with other -- other regulations..... COMMISSTONER FOERSTER: Okay. MR. MAUNDER: .....to guide the implementation. MR. ENGEL: That's a good option, Tom. COMMISSIONER FOERSTER: Okay. 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 31 ~ i ~ 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 ,I 17 18 i 19 20 2i ~ 22 23 24 I G~ I MR. ENGEL: Yeah. COMMISSIONER FOERSTER: Okay. Timing for approvals, We talked about both for new and existing instaliations and we felt pretty strongly that based on some experiences we've had recently that that -- the onus needs to be on the operator to know what he's doing and take care of his business. If we told you we needed six months in advance -- if we told Oooguruk we needed it six months in advance we'd still be contemplating it. MR. ENGEL: Yes. COMMISSIONER FOERSTER: So we do -- we are very reluctant to put timings on these approvals. That onus needs to remain with the operator. MR. ENGEL: I don't feel the Commission can appreciate the design and procurement of such equipment for new places, new fields, and it's months and months of engineering, planning, procurement activities. So an operator would need to understand the expectation from the Commission on how long it will take to get an application approved and therefore we would be able to schedule that in our planning process to meet the..... COMMISSIONER FOERSTER: It -- but it depends on the complexity of the -- of installation. I mean the operator is the most experienced with what they're going to install. So it's totally inappropriate for us to guesstimate what you're going to do and how complicated it is. We are going to leave R& R C 0 U R T R E P 0 R T E R S $11 G STREET (907)277-0572/Fax 274-8982 ANCHORAGE, ALASKA 49507 32 • ~ 1 2 3 4 5 6 -, 8 9 10 11 12 l~ 14 15 16 17 i8 19 20 ~ 21 22 23 24 25 that onus on the operator. MR. MAUNDER: If I may add, Commissioner Foerster, from the staff point of view we look at it that the early in the process the Commission's involved, the better it would be. In my prepared remarks I spoke of the metering installation for the gas skid for gas in Nuiqsut. You know, the first contact we had~ that facility was in place and ~hat surely is much further down the timeline than we should have been -- should have been contacted. Had we been brought in to or notified of the design intent when it first hit paper or prior to things being ordered, then the reservations with regard to the chasen equipment that had been made at that time and the accommodation or the resolution determined at that point rather than after things were in the field. COMMISSIONER FOERSTER: Thank you. Okay. The last point..... MR. ENGEL: Well, Commissioner, on that point I understand your comments related to the timing on it and I believe from an operation standpoint for a existing instaiiation I believe that can be handled easily by contacting the Commission and discussing the situation at hand, but new installation is a different consideration. Because of the -- you may be commingling with existing equipment or you may be bringing in new equ~pment. So again the timing on that could be troublesome to us. 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 ~~ ~ ~ 1 2 3 4 5 6 7 8 9 10 11 l~ 13 14 15 16 ,~ l~ 19 20 2l 22 23 24 25 I COMMISSIONER FOERSTER: Well, let me just clarify it for you. The timing expectation for us is the sooner you bring us into the process the more likely you'l1 have the approval when you need it. That's your timing requirement from us. MR. ENGEL: Okay. So -- all right. So I think these are -- as we're going through these we're making decisions now that will be implemented when these regulations become effective. And I can see situations where we'd be having more dialocrue with the Commission to maybe fine tune things down the road to help this become more clear. So I understand your point, but I do want to leave the Commission with the concern we have around potential delays that may result in these..... COMMISSIONER FOERSTER: Nobody like delays..... MR. ENGEL: Okay. COMMISSIONER FOERSTER: .....and the planner is the best person..... MR. ENGEL; Okay. Very good. COMMISSIONER FOERSTER: .....at avoiding the delays and I hope that your experience with this Commission is that we do everything we can to help you get through us without delays. And we have -- this regulation change is not intended to change that. MR. ENGEL: Very good. COMMISSIONER FOERSTER: Okay. MR. ENGEL: Thank you for that. R& R C 0 U R T R E P 0 R T E R S 817 G STREET (907)277-0572/Fax 274-8982 ANCHQRAGE, ALASKA 99501 34 ! ~ 1 2 3 4 5 6 7 8 9 10 il 12 13 14 15 16 17 18 19 20 21 22 23 24 25 COMMISSIONER FOERSTER: Lastly you had a suggestion that we do something a little dif~erently for a hypothetical future case. But I want to ask Mr. Maunder, from the description of Mr. Engel's hypothetical future case do we have any existing experience with a similar hypothetical case and how did we handle tha~? MR. MAUNDER: Yes, we do. Thank you, Commissioner Foerster. Yes, we do have experience with what I would perceive to be a similar case and that was with the field that you mentioned earlier, with Oooguruk where the production outside of the Kuparuk River Unit is measured using multi-phase meters and then commingled prior to the custody transfer point. COMMISSIONER FOERSTER: Okay. How do we handle it in that instance? MR. MAUNDER: That was handled in the pool rules. COMMISSIONER FOERSTER: In the pool rules. And is -- the pcint that we are making with this discussion, Mr. Engel, is that we try to leave regulations broad so that they -- one size fits all. MR. ENGEL: Right. COMMISSIONER FOERSTER: And when you need to do something special the appropriate place to address special needs..... MR. ENGEL: Right. COMMISSIONER FOERSTER: .....is in the pool rules and we..... R& R ~ 0 U R T R E P 0 R T E R S B11 G STREET (907)277-0572/Fax 274-8982 ANCHORAGE, ALASKA 99501 35 ~ ~ 1 2 3 4 ~ 6 7 8 9 10 11 l2 13 14 15 lb 17 18 19 I GO 21 22 23 24 25 MR. ENGEL: Yes. COMMISSIONER FOERSTER: .....want to keep it that way. MR. ENGEL: Yeah, I understand tha~. And the reason we brought it up is because of section (a), it does get very specific about measuring before leavincr the lease. And in the case that Mr. Maunder just mentioned, it may be measured downstream of that. COMMISSIONER FOERSTER: And -- but we took care of that in special pool rules. MR. ENGEL: In a difierent process. COMMISSIONER FOERSTER: And that's the way we prefer to take care of..... MR. ENGEL: Okay. COMMISSIONER FOERSTER: .....special instances like that. MR. ENGEL: Okay. COMMISSIONER FOERSTER: Did we -- I'm checking off and I'm thinking we've covered everything in your letter. Have we left anything out? MR. ENGEL: No, I think we've covered everything..... COMMISSIONER FOERSTER: Okay. MR. ENGEL: .....Commissioner. And I want to thank -- thank you for taking the time this morning to do it and I believe that in the past we've always worked so well with the staff here at the Commission to understand the intent and the nature of the regulations. However in this case due to several 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 36 ~ ~ ' 1 2 3 4 5 6 7 S ~ 9 10 11 12 13 14 15 i 16 I 17 18 I 19 2G 21 22 23 24 25 ~ reasons we weren't able to make that happen before the hearing. So thank you for that time this morning, it did clarify our question.s and I think it will be effective in our application of the proposed regs. COMMISSIONER FOERSTER: Well, thank you, Mr. Engel, for giving so much attention -- and the rest of the AOGA group for giving so much attention to the details. MR. ENGEL: Thank you. COMMISSIONER FOERSTER: And I'm going to turn it back over to you. (Off record comments) CHAIR SEAMOUNT: Commissioner Norman, do you have any comments or questions? COMMISSIONER NORMAN: Just one question. One of the things that any regulatory agency is required to consider and should consider is the burden that might be imposed, any unintended consequences that may fall upon an operator as a result of adoptin~ a new regulation. So my question for you is the flip side of what was asked to Mr. Maunder, do you have any , concerns that if this is adopted with the clarifications that ~ have been provided by Commissioner Foerster and staff, do you have any concerns about imposition of an additional financial or regulatory administrative burden? ~ MR. ENGEL: Commissioner Norman, the new regulations will i 1 require some additional administrative requirements to submit ~ 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 37 ~ ~ 1 2 3 4 5 6 7 ~ 9 10 11 12 y3 14 15 16 17 I I 18 19 ! 20 I 21 22 23 24 I 25 ~ applications and prepare applications, things of that nature. I don't think it would be significant to the point where it would burden an operator where it would become a troublesome burden. But I would like to maybe leave that question open for us as we get into it, as time goes down we can see the actual impact as we work with the new regulations as proposed. COMMISSIONER NORMAN: Yes. And, of course it's always open, so if something turns out to impose a burden that no one , may have foreseen or that is more onerous than intended, then there's several ways to approach that, one of them is simply to contact the Commission. The Commission has the ability on its own initiative to initiate some further clarification or initiate a formal petition to request something more formal. So that option is always open to you. MR. ENGEL: Yes, appreciate that. And like everything that we deal with, the devils are in the details and once we actually get into submitting applications then we'll figure out a system to manage it effectively. And I believe that working with the staff here at AOGCC and also the field staff has been very helpful to us in the future -- I mean, in the past and I believe it will be helpful to us as we move forward with this regulation too. So I do appreciate the willingness to work with us both from the office standpoint and the field application. It helps we're all on the same page. COMMISSIONER NORMAN: I have nothing further, Mr. j 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 38 1 2 3 4 5 6 7 8 9 10 il 12 13 14 15 16 ~ 17 ' .l 8 ~ 19 ' 20 21 22 ~ 23 ~ 2 4 i' 25 ~ II Chairman. ~ CHAIR SEAMOUNT: Okay. Tnlell, chank you, Ms. Crockett and Mr. Engel for your thoughtful concerns and comments as usual. We appreciate industry working with us on these things, we couldn't do it without you. Okay. At this time are there -- I'll give -- I'11 hand out the opportunity one more to anybody else in the room and the public that would like to comment, testify? MR. ENGEL: Well, Commissioner Seamount, one question I have for a-- it's a process question really, could you summarize the next step for us now with the regulations after this meeting today? CHAIR SEAMOUNT: I believe we're going tc come out with a decision witri 30 days. COMMISSIONER NORMAN: Would you like me to..... CHAIR SEAMOUNT: Yes. COMMISSIONER NORMAN: And I'd -- our Assistant Attorney General is here, but we would consider each and every comment that you've made I think on a few points and I'd ask staff to correct me or Commissioner Foerster, but for example possibly on number 2 we're going to look at that and make sure that that is not overly broad, the use of the term methodology. I just raise that as an example, but we would consider all of the comments that have been raised. And then following that we would adopt the regulation and the regulation adoption would -- 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 3g ~ ~ y 2 3 4 5 ~ 7 8 9 10 11 12 13 14 15 16 I LI) 1~ ( 19 I ~ 20 21 22 23 24 25 and couid occur at a public meeting witnout any further notice other than that it would be on the agenctae MR. ENGEL: Okay. Thank you. MR. BIRNBAUM: Doesn't need to be for 30 days, I mean, I don't believe it needs to be 30 days or (indiscernible - away f rorn mi crophone ) . , . . . CHAIR SEAMOUNT: Okay. I stand corrected as usual. Okay. Is there anything else? Hearing none, do I hear a motion? COMMISSIONER FOERSTER: I move to adjourn CHAIR SEAMOUNT: Do I hear a second? COMMISSIONER NORMAN: Second. CHAIR SEAMOUNT: Anybody opposed? Hearing none, we stand adjourned. (Adjourned - 10:18 o'clock a.m.) 1777 (END OF PROCEEDINGS) * * * * * * R& R C 0 U R T R E P 0 R T E R S 811 G STREET C907)277-0572/Fax 274-8982 ANCHORAGE, ALASKA 99501 ~a ~ ~ 1 2 3 4 5 6 7 8 9 10 11 12 13 ,~ 15 i~ 17 ; 18 19 20 21 I Z2 23 24 25 C E R T I F I C A T E UNITED STATES OF AMERICA ) ) ss . STATE OF ALASKA j I, Rebecca Nelms, Notary Public in and for the State of Alaska, residing at Anchorage, Alaska, and Reporter for R& R Court Reporters, Inc., do hereby certify: THAT the annexed and foregoing Public Hearing In the Matter of the Proposed Amendments to 20 AAC 25.228 and 20 AAC 25.230 Regarding Production Measurement Equipment for Custody Transfer Regulations, was taken by Lynn Hall on the 13th day of January, 2009, commencing at the hour of 9:03 a.m., at the Alaska Oi1 and Gas Conservation Commission, Anchorage, Alaska; THAT this Hearing Transcripr_, as heretofore annexed, is a true and correct transcription of the proceedings taken and transcribed by Lynn Hall; IN WITNESS WHEREOF, I have hereunto set my hand and affixed my seal this 22nd day of January, 2009. , ,~,~y ~ ~ ` ~~.~ ~ __ >u.. Notary Public ~ and for Alaska My Commi~sion Expires: 10/10/10 R& R C 0 U R T R E P 0 R T E R S 811 G STREET (907)Z77-0572/Fax 274-8982 ANCHORAGE, ALASKA 99501 . ~ STATE OF ALASKA OIL AND GAS CONSERVATION COMMISSION Production Measurement Equipment for Custody Transfer Regulations January 13, 2009 at 9:00 a.m. NAME AFFILIATION PHONE # TESTIFY (Yes or No) ~ ~ ~ ~~ F~ n 7 -`17L~~ -" ~ < < ,~l " ' ~~ ~ 6 ~ ~ ~ ~ I~ \ _ J" , ~ .~ ~~~;~%;~i.~~i,~,~1 l ~~~~/',~. /,'~~~//'~-- ,~ 72-/~~ l ~./~'S ~ o ~`~"~c~~ ~ ~ ~-0G ~~ '~ ~~ ~- \~a--~~ `~ F S ~~~C C. Z ~..1 L ~ - ~~' S G ~~-~ . `~~~ ~ ~~ . ~~i ~ ~~- t~~t, ~ P Zu.o~. -f~-~r=-ec. 7~3 -- -2~3°1 ~-/~ ~~~~ ~'~t`'w~A~Z-~ ~?~ D ~-~3 2-t O~j '~--~D ~~T ~~r~~s,~/ ~D~cG ~~.r-ia..~o ~b `~; r~, ~ ~ ~~ C.c~ ~t ~'~- ~ Z~ ~ uv ~ ,n G~ i9 c s~ 1 ~~ ~. ~-~ r ~ ~ ~ ~ ~ ~'-~~= L_ ~ ~= ~ `C~1~3 ~ .U°~ c~ ~('~ ~i r~i ~ r,~. ~1~. Z~ ~ S'~. 6~ ~~ ~ f . Alaska Oil and Gas~ssociation J~~~ January 13, 2009 121 W. Fireweed Lane, Suite 207 Anchorage, Alaska 99503-2035 Phone: (907)272-1481 Fax: (907)279-8114 Emaii: crockett@aoga.org Mari/yn Crockett, Executive Dir~cfor Commissioner Dan Seamount, Chair Alaska Oil and Gas Conservation Commission 333 W. 7'~ Avenue, Suite 100 Anchorage, Alaska 99501 AOGA Comments on Meterin~Equipment Reg,ulations [20 AAC 25.228~b~] Dear Commissioner Seamount: The 16 members of the Alaska Oil & Gas Association (AOGA) account for the majority of oil and gas exploration, development, production, transportation, refining and marketing activities in the state. We appreciate the opportunity to comment on these proposed regulations. Our member companies are concerned about the potential broad application, interpretation and implementation of tY~e proposed regulations. Given that AOGA members are unaware of the background and reasoning for the proposed changes, we are concerned that if the current draft is adopted there is the potential for inadvertent noncompliance. Qur questions and concerns are most significant in cases where there will be surface or subsurface commingling of pool~/units prior to the actual custody transfer meter. In that case a "methodology" is developed to allocate production to the individual pools/units utilizing the existing custody transfer equipment as well as other metering and/or well test equipment. In these comments, the term "production measurement equipment" refers to Lease Automatic Custody Transfer (LACT) Units and other oil and gas metering installations in similar service. The following c~uestions and comments illustrate our concern: 1. What is the definition of "hydrocarbon measurement equipment" as expressed in section 20 AAC 25.228 entitled "Production measurement equipment for custody transfer"? Will the hydrocarbon measurement equipment be limited to production metering equipment for ~ liquid and gas as the fluid leaves the lease, or will the proposed language be interpreted to include well testing equipment? Well test equipment is not generally considered for production metering service and then only in commingling operations. • Alaska Oil and Gas Conservat~Commission January 13, 2009 ~ Page 2 Members companies do no object to the application of the proposed revisions to production metering equipment, however, there is concern about the general application to well test equipment. 2. What does the term "metliodology" mean in the context of the proposed revisions? The term "methodology" may refer to the calculations inherent in the operation of the production metering equipment or it may refer to the determination of volumes allocated to commingled pools or units. If the term "methodology" is applied to production metering equipment, member companies would not object. However there is concem if the term "methodology° makes reference to well test equipment. The process for gaining approval is also unclear. Will we need to provide our current methodology for approval or simply future methodology changes? 3. What level of equipment changes will be eonsidered "altering hydrocarbon measurement equipment"? That is, what is the definition of altering? The concern with respect to production metering equipment and well test units is the potential requirement to apply for approval for even routine maintenance activities. For example, does it include replacing a gauge on a meter run, and does it include changing orifice plates? 4. There is no change proposed tothe referenced API Manual of Petroleum Measurement Standards, as revised as of November 30, 1998_ While a standard reference is needed, we suggest language be included that allows operators to use the latest revision of the API standard or methods approved by the AOGCC. For example, the November 30, 1998 standard does not a11ow the use of ultrasonic meters or coriolos meters for fluid measurement. 5. Use of the term "provide information" is vague and could lead to eonfusion as to what exactly is required. Required information should be specified in the regulations, such as manufacturer specifications, certifications, or gas flow schematics etc. 6. Timing for approvals - new installations: In cases where a totally new installation is required, the design of the processing and metering equipment is often far in advance of the actual installation. However, in the case of surface commingling, existing metering equipment will most likely be used. The AOGCC approval process for this case is vague with respect to methodology and timing. Our concern is possible delays for approvals of the methodology and custody transfer equipment. We suggest a timeline be established for acquiring AOGCC approvals for new installations. ,~ i ~ Alaska Oil and Gas Conservation Commission January 13, 2009 Page 3 7. Timing for approvals - existing installations: Should there be a failure of the current custody transfer equipment, some provision for rapid approval of changes is required to minimize disruption. What will be required to demonstrate that the changes meet the requirements of the API Manual of Petroleum Measurement Standards? Will approval of replacement with a newer model of the same basic equipment be required? Will existing production metering equipment be grandfathered or be required to be re-approved? Additionally, we have a suggestion regarding approval for surface commingling between units in section 20 AAC 25.228(a). We suggest adding specific language to 25228(a) to allow hydrocarbon production to be measured downstream of an approved commingling point. Due to conflicting schedules and the recent holiday season, we were unable to facilitate a working session with AOGCC staff engineers to clarify the intent and application of these proposed regulations. AOGA believes a future working session wouid be beneficial to both industry and the AOGCC. Please call Harry Engel, Chairman of the AOGA AOGCC Task Group at 564-4194 for any questions or to arrange a work session. Again, thank you far providing this opportunity to comment. We look forward to working with the Commission. Sincerely, . . . ~ ~ - ~ { ~ `` 0 . . j~~ . ~ . . ~ ~ . . t~ ~ ~ d~~ ` ~~`~.{ ~~e~~ {~ . ~~f~~ ~ . . . . ~ . . . t ~~~;. ~;~ ~. MARILYN CROCKETT Executive Director Cc: Commissioner Cathy Foerster Commissioner John Norman I ~ • ~ TO: Commissioners, AOGCC January 13, 2008 FR: Thomas E. Maunder, PE RE: Commission Staff Statement Regarding Amending 20 AAC 25.228 Hearing before the Commission The Commission's authority regarding the measurement of oil and gas may be found at AS 31.05.030 (d) (6) - where it is stated that "The Commission may require ... the gauging or other measuring of oil and gas to determine the quality and quantity of oil and gas". 20 AAC 25.228 and 25.230 are the regulations that implement the authority granted in statute for measurement. 25.228 first appears in the regulations effective April 2, 1986 and as written them specifically pertained to the equipment employed to physically measure and mathematically calculate the quantities of oil and gas. 25.230 immediately following contained further requirements pertaining to individual well measurement and allocation as well as the measurement prior to severance from the property or unit where produced. 25.230 in an earlier form was present in the Commission regulations effective July, 1980. Measurement priar to severance from the property or unit is known as custody transfer. It is also known as L.A.C.T. or Lease Automated Custody Transfer. In 1998, 25.228 and 25.230 were amended and reorganized. 25.228 in its amended form addresses measurement equipment and procedures for custody transfer measurement. 25.230 as currently written addresses only allocation measurement and production reporting. The intent of the amendment being considered today is require the Operator of a unit or property to involve the Commission before a new custody transfer station is installed or existing equipment is altered. By adopting this amendment, the onus is on the Operator to apprise the Commission of their plans in advance of the equipment being fabricated and installed or altered. The adoption of this amendment will allow the Commission to conduct our due diligence regarding custody transfer measurement and help avoid situations that have been encountered in the last several years. These include the fabrication and installation of equipment to measure gas leaving Alpine for Nuiqsut. When the Commission was ultimately presented with information on the meters, it was determined that the uncertainty of the meters chosen exceeded that of standard orifice meters and the chosen meters ultimately needed to be replaced. Another situation was encountered where the functional meter elements including the electronic signaling equipment were changed and the Commission first became aware of the changes when one of the Inspectors was routinely inspecting the metering location. In the first case, the uncertainties of the chosen meters clearly exceed the uncertainty of orifice meters which is essentially the m~imum uncertainty presently accepted. Contact "up front" with Commission would have eliminated the need to replace the meters. In the 2"d case, while the new equipment did meet the requirements of the Petroleum Measurement Standards which satisfied the present effective regulation, I don't believe it is acceptable that changes in custody transfer measurement equipment are discovered during a routine inspection. ~ ~ I do not believe that this amendment places a large burden on the Operators. The State is not the only party interested in quality measurement being performed. There are other parties to the commercial transaction with financial interests in excess of the State's. The present regulation requires that equipment used for custody transfer be fabricated, installed and maintained in accord with the Petroleum Measurement Standards and that the ultimate measurement of hydrocarbons also be in accord with the Standards. This proposed amendment does not change that. The additional requirements being placed in the regulation are to provide the Commission advance notice, copies of the relevant documentation regarding the equipment and calculations and the opportunity to review and concur with the plans. ~ ~ ~ MEMORANDUM To: Daniel T. Seamount, Jr., Chair Oil and Gas Conservation Commission Dept. of Administration From: Deborah E. ef~ Chief Assistant Attorney General and Regulations Attorney Legislation and Regulations Section ~ ~~~~~~~~=~ ~i~~_. ~ ~ 2~n~ '~ii~,~`ittt~ ~~a~ ~`L ~~t5 i ~,F3?; ~ L ~„ .,. State of Al~~~~~a ~ Department of Law Date: November 17, 2008 File No.: 993-09-0052 7'e~, ~vo.: 465-3600 Re: Regu~ations File Opening Re: 20 AAC 25.228(b): Hydrocarbon Measurement Equipment We have received your commission's memorandum of November 12, 2008 regarding this project, along with a copy of the proposed regulations and related documents. The project has been assigned to Assistant Attorney General Alan Birnbaum, phone number 269-5100. Our department's file number for this project is 993-09-0052. This file number should be used on any further conespondence pertaining to this project. DEB:pvp cc: Carol Beecher, Regulations Contact Dept. of Administration Jody Colombie, Special Assistant to the Commissioner Oil and Gas Conservation Commission Dept. of Administration Jason Hooley, AAC Coordinator Lt. Governor's Office Tina Kobayashi, Supervising Attorney Oil, Gas & Mining Section Alan Birnbaum, Assistant Attorney General Anchorage ~ i~ ~ ~ ~ ~ ~~~~~~~~ a~~~~ ; l 2or~9 MEMORANDUM STATE OF ALASKA ~;~~~~~, ~~~~ ~, ~~~ ~;Q~~_ t~~~3nr~i~;sit~r~ ~:~s;€~~,rli~,~~ ALASKA OIL AND GAS CONSERVATION COMMISSION TO: Deborah E. Bel~r DATE: November 12, 2008 Chief Assistant Attorney General Legislation and Regulations Section SUBJECT: Request to Open File Regarding Amendments to Hydrocarbon Measurement Equipment Regulations, 20 AAC 25.228(b) FROM: Daniel T. Seamount, Jr. '~~~~ Regulations Contact Department of Administration Please open a file for an Alaska Oil and Gas Conservation Commission (Commission) project to amend Title 20, Chapter 25, Section 228(b) of the Alaska Administrative Code, regarding hydrocarbon measurement equipment. Enclosed is the public notice, Additional Regulations Notice Information, and proposed amendments to 20 AAC 25.228(b). Please assign Assistant Attorney General Alan Birnbaum to this project. The Commission's contact person is Jody Colombie at 793-1221 or jody.colombic~c~alaska.~,~ov. ~~ ~ • STATE OF ALASKA NOTICE TO PUBLISHER ~ ADVERTISING ORDER NO. ADVERTISING ORDER INVOICE MUST BE IN TRIPLICATE SHOWING ADVERTISING ORDER NO., CERTIFIED AFFIDAVIT OF PUBLICATION (PART2 OF THIS FORM) WITH ATTACHED COPY OF ADVERTISEMENT MUST BE SUBMITTED WITH INVOICE AO-02914012 SEE BOTTOM FQR INVQIGE ADDI~ESS. ,: it4i i : F R AOGCC 333 W 7th Ave, Ste 100 AGENCY CONTACT Jod Colombie DATE OF A.O. November 12, 2008 ° "" Anchorage, AK 99501 907-793-1238 PHONE - Pcrv DATES ADVERTISEMENT REQUIRED: o Anchorage Daily News PO Box 149001 Anchora e AK 99514 g~ November 14, 2008 THE MATERIAL BETWEEN THE DOUBLE LINES MUST BE PRINTED IN ITS ENTIRETY ON THE DATE3 SHOWN. SPECIAL INSTRUC710NS: Advertisement to be published was e-mailed Type of Advertisement Legal~ ^ Display Classif ied ^Other (Specify) SEE ATTACHED SEND INVOICE T ;IN TRIPLICATE f~ ~~~ ; AOGCC, 333 W. 7th Ave., Suite 100 Anchora e AK 99501 PAGE 1 OF 2PAGES TOTAL OF ALLPAGES$ REF TYPE NUMBER AMOUNT DATE COMMENTS 1 VEN z A~ 0291 O FIN AMOUNT SY CC PGM LC ACCT FY NMR DIST LIQ ~ 08 02140100 73451 2 REQUISITIONED B : DIVISION APPROVAL: 02-902 (Rev. 3/94) v Publisher/Original Copies: Department Fiscal, Department, Receiving AO.FRM ~ 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 (Commission) proposes to adopt changes to Title 20, Chapter 25, of the Alaska Administrative Code. The Commission proposes to amend 20 AAC 25.228(b) to require an operator to provide information to and obtain the approval of the Commission prior to the following: (1) installing ar altering hydrocarbon measurement equipment used for custody transfer purposes; and (2) adopting or changing the methodology used for determining hydrocarbou volumes. For a copy of the proposed regulation changes, contact Jody Colombie, Special Assistant to the Commission (at 907-793-1121 or jody.colo~nbie@alaska.gov), or visit www.aobcc.alaska.~r~,ov. Written comments on the proposed regulation changes, including the potential costs to private persons of complying with them, may be submitted to Ms. Colombie at jodticolombie cr alaska. ~ov or the Commission: 333 W. 7`~' Avenue, Suite 100, Anchorage, AK 99501. Written and oral comments may also be submitted at a January 13, 2009, 9:00 a.m. hearing at the Commission. The hearing might be extended to accommodate those present before 9:30 a.m. who do not have an opportunity to comment. If, because of a disability, you need a special accommodation, contact Ms. Colombie by January 8, 2009. YOU SHOULD COMMENT DURING THE TIME ALLOWED IF YOUR INTERESTS COULD BE AFFECTED BY THE PROPOSED REGULATION CHANGES. After the public comment period, the Commission will, without further notice, adopt the proposed changes or other regulation changes dealing with tbe same subject ar take no action. Accordingly, the language of any final regulations may be different from the proposed changes. (Written and oral comments are public.) Statutory Authority: AS 31.05.030. 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. DATE: November 12, 2008 Daniel T. Seamount, Jr. Chair ~ ~ ADDITIONAL REGULATIONS NOTICE INFORMATION (AS 44.62.190(d)) l. Adopting agency: Alaska Oil and Gas Conservation Commission. 2. General subject of regulations: hydrocarbon measurement equipment. 3. Citation of regulations: 20 AAC 25.228(b). 4. Reason for the proposed action: to require an operator to provide information to and obtain the approval of the Alaska Oil and Gas Conservation Commission prior to the following: (1) installing or altering hydrocarbon measurement equipment used for custody transfer purposes; and (2) adopting or changing the methodology used for determining hydrocarbon volumes. 5. RDU/component affected: Alaska Oil and Gas Conservation Commission. 6. Cost of implementation to the state agency: zero. 7. Contact person for the regulations: Name: Daniel T. Seamount, Jr. Title: Chair Address: 333 W. 7t" Avenue, Suite 100, Anchorage, AK 99501 Telephone: (907) 793-1221 E-mail: jody.colombie@alaska.gov 8. Origin of the proposed action: Alaska Oil and Gas Conservation Commission staff. 9. Date: November 12, 2008. 10. Prepared by: / Jod . Col bi Spe al A'st to the Commission Alaska Oil and Gas Conservation Commission (907) 793-1221 5. RDU/comPon~t affe~~d= A~ask~ ENi 8nd Gas conse+vation CommiSSion. b. Cost of imp~Ernentation to the state aSency zero. 7, ConNameerDanielThseamo~u~t 1r. Title: Cltau AddreSS: 333 Ws7th Avenue,Suite 100; Anchorage, AK 99501 Telephone. ~colomb e~alaska.gov E mad: Jody. 8 GasCOnsenrva it on e0cnmission stAaffska oiF and 9. Date: Novembe~ ~2, 2008. 70. PrePared bY lody J Cotombie 5 ciai Assistant to the Commission A~jj 7g8~ 1221Ga5 Con5ervafion Commission ~A AO-0291A012 Pubi~shed: November 1a, 2008 AD # DAT" PO ~ ~ 11 ~14r2ooa _ . ~i Anchorage Daily News Affidavit of Publication ]001 Northway Drive, Anchora,qe, AK 99508 PRICE OTHEK OTHER OTHER GRAND ACCOUNT PER DAY CHARGES CHARGES #2 CHARGES ~t3 TOTAL 577438 11/14/2~8 02914012 STOF0330 $375.16 $375.16 $0.00 $0.00 $0.00 $375.16 -- -..._.,..-- - - --- ---- - - - - - . .... ~w.~.~.....~.~. ~ STATE OFALASKA NQTTCE OP PROPOSED (:HANGES 1N THfi ' REGULAT[ONSOFTHE STATE OF ALASKA ~ AIASK2-OILANDGqSCONSERVpTION ~ GOMMtSSION THIRD JUDICIAL DISTRICT : Yhe ,w~aska oif and Gas conservation commESSi~n Shane Drew, bein first dul sworn on oath de oses and sa s that : g y p Y ; he is an advertising representative of the Anchorage Daily News, ' ~~~~ssion proposes to amend 2o anc zs.22sEb) ta require an operator to rpvide informatian to and obtain the approv8f of t~ie commission prior ta the =. a daily newspaper. i me su ement~e~u~am n used o~cu iod~ t ansE ~ That said news a er has been a roved b the Third udicial P P PP Y 1 , a r e s e Purposes; and (~ adopting or changing the '~ methodology used for determining hydrocarbon ' Court, Anchorage, Alaska, and it now and has been published in vo~umes. the En lish lan a e continuall as a dail news a er in g ~ g y y p p k For a co py of the pvopased re utat~an ch~nges, ~ eontacc ~ody.Gotomb(e s eeial qssistanf ta th ' Anchora e, Alaska, and it is now and durin all said time was S g p : e . Commissron (at 907-793-1121 oF ` printedinanofficemaintainedattheaforesaidplaceof ~ lody.coiombie~ataska.gov}, ar visit ' www.aogcc.afas&agw. , publication of said newspaper. That the annexed is a copy of an advertisement as it was ublished in re lar issues and not in P S~ ~ written comments on the propased regufation ' changes, mctudin~ the potent~al evsts to priveFe < supplemental form) of said newspaper on the above dates and Persons vf comply~ng witti them, may be submi~€ed , that such news a er was re ularl distributed to its subscribers p p g y to nris. cotompie at jody.colombie~ataska.gov or the ` Cammisston: 333 w. 7th Avenue, Suite 100, during all of said period. That the full amount of the fee charged anchorage,,aK 9QSa~. for the foregoing publication is not in excess of the rate charged written and oral comments may a~so be submitted rivate individuals. p at a ~anuary ~s, 2009, 4:00 a.m, ftiearing at the Car~rreissFon_ The hearf~g migk~t Fie extended ta ? ~ aceommodate those present before 9:3o a.m. who ' ; do not have an opportunity to comment. It, because of a disability, yan need a speciat ; Signed ~~- accommodation, contaet Ms. Colombie by January ; s; aoo9. i Subscribed and sworn to me before this date: , YOU SHOVLD COMMENT DURt:NG THE Ttlv1E ALLtlWED tF YOUR IN7ERESTS CQUtD BE AFFECTED BY THE PROPOSED RECrULATION CHRNGES. Aft2r ~ the public commeRt period, tl2e CommiSSion will, withvut further notiCe, adopt tf~e proposed Chan~es j/ /~ j~ or other regutation efqangc~s deal~ng' with the same , ' ~///if s~bject oa take n0 aetion. Accordmgly, the faqguage R~oposea cnanges. (wertten antl orat comments are pubtic.) : Notary Public in and for the State of Alaska. s~cutoryn,~~n~ty: nssa.os.oao. ~ Statutes B Lnplemented Interpreted or Made ' Third Division. Anchorage, Alaska ! , , sg~~: ~~.os.o3o. ; F scal Information: The proposed regulatipn changes are not expeeted to require an increased MY COMMISSION EXPIRES: l f appropriation, I ~ DATE: NOVeritbCr 12; 200& ~ ~ ~ ,~~~ ' QaFllef T. SeamOUnt, tI'. ' i ~ ~ Chair ADDITIONAL REGUtATI(5NS NOTIGE INFORMA710N (AS 44.62.790(d)1 \`~~~~~A ~,r~(~lj~~ ~~ ConseivatgionCOmmissionska oif and Gas ~ ` ~ `t ~l~ • ~ ' . ~Q ~ ' L ~ 2. GeneraF sub~ect of regutatiorts: hydrocarbon ' ` ~ ~ ~, • o ~ • measurement eq~ipment. ~ ` ; ~ ~~ ~ •~ ~' 3. Citation of regufations~ 20 AAC 25.228(b). ~ ~ {~B~4~y ~ ~ • ' 4, Rea&on fOr the prOposed action: to require an o erator to ro id i f d b ~ - 1 A •' ~ ~~ ~ p p v e n ormatwn to an o fain ~~ th~ apprP~~k flt th& k4~ska ~il ar~el ~tas ~ .'9~ ~ ~ E~rvservatb~+er ~~e~ntission peier ~u ~he ~ , QF A~: ' ~ ./ ~ o ~ • • ~~. (tl iersi~f ~r att~rk~ f~ycleocarbon rtteasu~~tet~~ e~vi~e€sFlt uS~tFfPr etastOdy ~ , \ JJ 11 Jj ~Ol * trBttS'FG°r w4 E83~s; 8ntl (F) ad~ tlng O~r ~harrg^rr~~g t~~ rrr.ethodot€rgy used for J ~~Illl )1 ~ ~ decsrrr~g ~r~aebcm votumes. . ~ STATE OF ALASKA NOTICE TO PUBLISHER I ADVERTISING ORDER NO. ADVERTISING INVOICE MUST BE IN TRIPLICATE SHOWING ADVERTISING ORDER NO., CERTIFIED AO-02914012 AFFIDAVIT OF PUBLICATION (PART 2 OF THIS FORM) WITH ATTACHED COPY OF ORDER qDVERTISEMENT MUST BE SUBMITTED WITH INVOICE F AOGCC R 333 West 7th Avenue. Suite 100 ° Anch~ra~e_ AK 995(11 "" 907-793-1238 o Anchorage Daily News PO Box 149001 Ancharage, AK 99514 CONTACT PHONE 1 7V / 1 / 7_7 - 1 GG 1 DATES ADVERTISEMENT REQUIRED: November 14, 2008 DATE OF A.O. PCN THE MATERIAL BETWEEN THE DOUBLE LINES MUST BE PRINTED IN ITS ENTIRETY ON THE DATES SHOWN. SPECIAL INSTRUCTIONS: Account # STOF0330 AFFIDAVIT OF PUBLICATION United states of America R EM I N D ER State of ss INVOICE MUST BE IN TRIPLICATE AND MUST REFERENCE THE ADVERTISING ORDER NUMBER. division. A CERTIFIED COPY OF THIS AFFIDAVIT OF PUBLICATION MUST BE SUBMITTED WITH THE INVOICE. Before me, the undersigned, a notary public this day personally appeared ATTACH PROOF OF PUBLICATION HERE. who, being first duly sworn, according to law, says that he/she is the of Published at in said division and state of and that the advertisement, of which the annexed is a true copy, was published in said publication on the day of 2008, and thereafter for consecutive days, the last publication appearing on the day of , 2008, and that the rate charged thereon is not in excess of the rate charged private individuals. Subscribed and sworn to before me This _ day of 2008, Notary public for state of My commission expires _ i ~ Re ister 200 MISCELLANEOIIS BOARDS g ~ - 20 AAC 25.228(b) is amended to read: (b) Hydrocarbon measurement equipment must be fabricated, installed, and maintained in conformance with relevant parts of the API Manual of Petroleum Measurement Standards, as revised as of November 30, 1998. Before installin~ or alterin~ hvdrocarbon measurement equipment used for custodv transfer purposes, the operator shall submit to the commission information demonstrating conformance and obtain commission approval of the proaosed install_ation or alteration and the methodologv proposed for determining hvdrocarbon volumes. The submitted information shall include, among other thin~s, sample calculations, with the underlving measured data, generated usin~ the proposed methodologv. An approved methodolo~y mav not be chan~ed without commission anproval. (Eff. 4/2/86, Register 97; am 11/7/99, Register 152; am /_/ , Register ) Authority: AS 31.05.030 Editor's note: A copy of the relevant parts of the API Manual of Petroleum Measurement Standards may be reviewed during business hours at the commission's office and may be obtained from the American Petroleum Institute, Order Desk, 1220 L Street, N.W., Washington, D.C. 2005-4070. 1 Mary Jones XTO Energy, Inc. Cartography 810 Houston Street, Ste 2000 Ft. Worth. TX 76102-6298 George Vaught, Jr. PO Box 13557 Denver. CO 80201-3557 Mark Wedman Halliburton 6900 Arctic Blvd. Anchorage, AK 99502 Baker Oii Tools 4730 Business Park Bivd., #44 Anchorage, AK 99503 Gordon Severson 3201 Westmar Cr. Anchorage, AK 99508-4336 James Gibbs PO Box 1597 Soldotna, AK 99669 Richard Wagner PO Box 60868 Fairbanks, AK 99706 North Slope Borough PO Box 69 Barrow. AK 99723 ~ r ~ LJ David McCaleb Cindi Walker IHS Energy Group Tesoro Refining and Marketing Co. GEPS Supply & Distribution 5333 Westheimer, Ste 100 300 Concord Plaza Drive Houston, TX 77056 San Antonio, TX 78216 Jerry Hodgden Richard Neahring Hodgden Oil Company NRG Associates 408 18th Street President Golden, CO 80401-2433 PO Box 1655 Colorado Springs, CO 80901 Schlumberger Ciri Drilling and Measurements Land Department 2525 Gambell Street #400 PO Box 93330 Anchorage, AK 99503 Anchorage, AK 99503 Ivan Gillian Jill Schneider 9649 Musket Bell Cr.#5 US Geological Survey Anchorage, AK 99507 4200 University Dr. Anchorage, AK 99508 Jack Hakkila Darwin Waldsmith PO Box 190083 PO Box 39309 Anchorage, AK 99519 Ninilchick, AK 99639 Kenai National Wildlife Refuge Penny Vadia Refuge Manager 399 West Riverview Avenue PO Box 2139 Soldotna, AK 99669-7714 Soldotna, AK 99669-2139 Cliff Burglin Bernie Karl PO Box 70131 K&K Recycling Inc. Fairbanks, AK 99707 PO Box 58055 Fairbanks, AK 99711 ~ ~' Q/ / ~ ~ .~ ~" ~ ~ ~~~ ~ ~~ {~ ~ ~ ~ Page 1 of 2 Colombie, Jody J (DOA) From: Colombie, Jody J (DOA) Sent: Thursday, November 13, 2008 9:24 AM Subject: AOGCC Amending Regulations Hydrocarbon Measurement Equipment Attachments: Hydrocarbon Measurement Equipment Regulation.pdf BCC:'Aaron Gluzman'; caunderwood@marathonoil.com; 'Dale Hoffman'; Fridiric Grenier; 'Joe Longo'; 'Lamont Frazer'; Marc Kuck; 'Mary Aschoff; Maurizio Grandi; P Bates; Richard Garrard; 'Sandra Lemke'; 'Scott Nash'; 'Steve Virant'; Tom Gennings; 'Willem Vollenbrock'; 'William Van Dyke'; Woolf, Wendy C(DNR);'Aleutians East Borough'; 'Anna Raff ;'Barbara F Fullmer'; 'bbritch'; 'Bill Walker'; 'Brad McKim'; 'Brandon Gagnon'; 'Brian Gillespie'; 'Brian Havelock'; 'Brit Lively'; 'Bruce Webb'; 'buonoje'; 'Cammy Taylar'; 'Cande.Brandow'; 'carol smyth'; 'Cary Carrigan'; caunderwood@marathonoil.com; 'Charles O'Donnell'; 'Chris Gay'; 'Cliff Posey'; 'Dan Bross'; 'dapa'; 'Daryl J. Kleppin'; 'David Brown'; 'David Hall'; David House; 'David L Boelens'; 'David Steingreaber'; 'ddonkel'; 'Deborah J. Jones'; 'doug_schultze'; 'Eric Lidji '; 'Evan Harness'; 'eyancy'; 'foms2@mtaonline.net'; 'Francis S. Sommer'; 'Fred Steece'; 'Garland Robinson'; 'Gary Laughlin'; 'Gary Rogers'; 'Gary Schultz'; 'ghammons'; 'Gordon Pospisil ; `Gregg Nady'; 'gregory micallef; 'gspfoff; 'Hank Alford'; 'Harry Engel'; 'jah'; 'James Scherr'; 'Janet D. Platt'; 'jejones'; 'Jerry McCutcheon'; 'Jim Arlington'; 'Jim White'; 'Jim Winegarner'; 'Joe Nicks'; 'John Garing'; 'John S. Haworth'; 'John Spain'; 'John Tower'; 'John W Katz'; johnny.aiken@north-slope.org; 'Jon Goltz'; 'Julie Houle'; 'Kari Moriarty'; 'Kaynell Zeman'; 'Keith Wiles ; knelson@petroleumnews.com; 'Krissell Crandall'; 'Kristin Dirks'; 'Laura Silliphant'; 'Lois'; 'Lynnda Kahn'; 'mail=akpratts@acsalaska.net'; 'mail=foms@mtaonline.net'; 'Marilyn Crockett'; 'Mark Dalton'; 'Mark Hanley'; 'Mark Kovac'; 'Mark P. Worcester'; 'Marquerite kremer'; 'Matt Rader'; Melanie Brown; 'Mike Bill'; 'Mike Mason'; 'Mikel Schultz'; 'Mindy Lewis'; 'MJ Loveland'; 'mjnelson'; 'mkm7200'; 'Nick W. Glover'; NSK Problem Well Supv; NSU, ADW Well Integrity Engineer; 'Patty Alfaro'; 'Paul Decker'; 'Paul Winslow'; Pierce, Sandra M(DNR); 'Randall Kanady'; 'Randy L. Skillern'; 'rcrotty'; Rice, Cody J(DNR); 'rmclean'; 'Rob McWhorter '; rob.g.dragnich@exxonmobil.com; 'Robert Campbell'; 'Robert Fowler'; 'Robert Province'; 'Roger Belman'; 'Rudy Brueggeman'; 'Scott Cranswick'; 'Shannon Donnelly'; 'Sharmaine Copeland'; 'Sondra Stewman'; 'Sonja Frankllin'; 'Stan Porhola'; 'stanekj'; 'Steve Lambert'; 'Steve Moothart'; 'Steven R. Rossberg'; 'tablerk'; 'Tamera Sheffield'; 'Temple Davidson'; 'Terrie Hubble'; 'Tim Lawlor'; 'Todd Durkee'; Tony Hopfinger; 'trmjrl'; 'Walter Featherly'; 'Walter Quay'; 'Wayne Rancier'; Birnbaum, Alan J(LAW); Crisp, John H(DOA); Davies, Stephen F(DOA); Fleckenstein, Robert J (DOA); Foerster, Catherine P(DOA); Grimaldi, Louis R(DOA); Johnson, Elaine M(DOA); Jones, Jeffery B(DOA); Laasch, Linda K(DOA); Mahnken, Christine R(DOA); Maunder, Thomas E(DOA); McIver, C(DOA); McMains, Stephen E(DOA); Noble, Robert C(DOA); Norman, John K(DOA); Okland, Howard D(DOA); Paladijczuk, Tracie L (DOA); Pasqual, Maria (DOA); Regg, James B(DOA); Roby, David S(DOA); Saltmarsh, Arthur C(DOA); Scheve, Charles M(DOA); Seamount, Dan T(DOA); Smith, Chasity R(DOA); Williamson, Mary J(DOA); Alan J Birnbaum (LAW) (Other Fax); Buch, Bob (LAA); Bunde, Con (LAA); Chenault, Mike (LAA); Cissna, Sharon (LAA); Coghill, John (LAA); Cowdery, John (LAA); Crawford, Harry (LAA); Dahlstrom, Nancy (LAA); Davis, Bettye J(LAA); Doll, Andrea (LAA); Doogan, Mike (LAA); Dyson, Fred (LAA); Edgmon, Bryce E(LAA); Ellis, Johnny (LAA); Elton, Kim S(LAA); Fairclough, Anna (LAA); 'Foster, Richard'; French, Hollis (LAA); Gara, Les (LAA); Gardner, Berta (LAA); Gatto, Carl (LAA); Green, Lyda N(LAA); Gruenberg, Max F(LAA); Guttenberg, David (LAA); Harris, John (LAA); Hawker, Mike (LAA); Hoffman, Lyman F(LAA); Holmes, Lindsey (LAA); Huggins, Charlie (LAA); Johansen, Kyle B(LAA); Johnson, Craig W(LAA); Joule, Reggie (LAA); Kawasaki, Scott Jw (LAA); Keller, Wes (LAA); Kelly, Mike (LAA); Kerttula, Beth (LAA); Kookesh, Albert (LAA); Ledoux, Gabrielle R(LAA); Lynn, Bob (LAA); McGuire, Lesil L(LAA); Meyer, Kevin G(LAA); Nelson, Mary (LAA); Neuman, Mark A(LAA); Olson, Donny (LAA); Olson, Kurt E(LAA); Ramras, Jay B(LAA); Roses, Bob (LAA); Salmon, Woodie W(LAA); 5amuels, Ralph (LAA); Seaton, Paul (LAA); Stedman, Bert K(LAA); Stevens, Gary L(LAA); Stoltze, Bill (LAA); Therriault, Gene (LAA); Thomas, Bill (LAA); Thomas, Joe (LAA); Wagoner, Tom (LAA); Wielechowski, Bill (LAA); Wilken, Gary R (LAA); Wilson, Peggy A (LAA) 11 /13/2008 ~ ~ Page 2 of 2 Attachments:Hydrocarbon Measurement Equipment Regulation.pdf; Recent new meter instal~ations have uncovered a gap in our regulations. There is currently nothing to specify that and how an operator must receive initial approval for custody transfer metering equipment. Custody transfer metering systems are used to measure hydrocarbon volumes for revenue and tax determinations. Therefore, initial approval is necessary to prevent an improperly designed, installed, or calibrated custody transfer metering system from going into service. Attached are the Public Notice, Additional Information and Proposed Regulation. Jody J. Colombie Special Assistant to the Commission Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, Alaska 99501 (907} 793-1221 Direct Line (907) 276-7542 Fax 11/13/2008 ~ ~ SERVICE LIST FOR PROPOSED AMENDMENTS TO 20 AAC 25.228(b) On November 13, 2008, the public notice of proposed amendments to 20 AAC 25.228(b), Additional Regulations Notice Information, and proposed regulation were mailed to: Annette Kreitzer Commissioner Department of Administration PO Box 110200 Juneau, AK 99811 Legislative Reference Library Legislative Affairs Agency State Capitol Juneau, AK 99801 Mail Stop: 3101 Senator Charlie Huggins, Chair Senate Resources State Capitol Juneau, Alaska 99801 Representative Kurt Olson, Chair House Oil & Gas Special Committee State Capitol Juneau, Alaska 99801 Senator Lesil McGuire, Chair Administrative Regulation Review State Capitol Juneau, Alaska 99801 Senator Kim Elton, Chair Legislative Council State Capitol Juneau, Alaska 99801 On November 13, 2008, the file-opening memorandum, public notice of proposed amendments to 20 AAC 25.228(b), Additional Regulations Notice Information, and proposed regulation were mailed to: Debra Behr Chief Assistant Attorney General Legislation and Regulations Section Department of Law PO Box 110300 Juneau, AK 99811