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Home My WebLink AboutCO 103 A Image Project Order File Cover Page XHVZE This page identifies those items that were not scanned during the initial production scanning phase. They are available in the original file, may be scanned during a special rescan activity or are viewable by direct inspection of the file. ~.3 ~ Order File Identifier Organizing (done) RESCAN ^ Color Items: ^ Greyscale Items: ^ Poor Quality Originals: ^ Other: NOTES: BY: Maria Project Proofing BY: Maria _..~ Scanning Pre~par'a~tion BY: Ml aria ) naP uii~u~~uu~iii ,, ~v~P x 30 = + =TOTAL PAGES ~~ / ~ //~ (Count does not include cover sheet) , / Date: /a [/ /s/ V Production Scanning Stage 1 Page Count from Scanned File: _p~ (Count does include cove sheet) --~~ Scanning is complete at this point unless rescanning is required. Page Count Matches Number in Scanning Preparation: YES _ BY: Maria Date: ~ ~' /Q l Stage 7 If NO in stage 1, page(s) discrepancies were found: YES BY: Maria Date: NO ISl ,~ NO "iuiiimuiiiuii ReScanned BY: Maria Date: /s/ Comments about this file: ,.o.,d,~ iiuummiuuii DIGITAL DATA ^ Diskettes, No. ^ Other, No/Type: ~es~„-,~eeaea iiiimii0iiili OVERSIZED (Scannable) ^ Maps: ^ Other Items Scannable by a Large Scanner OVERSIZED (Non-Scannable) ^ Logs of various kinds: ^ Other:: Date: Date: a~,~.~~tt~ed iuiimmuiiiiu 10!6/2005 Orders File Cover Page.doc • • Index Conservation Order 103A Trading Bay Field 1. 2. 3. 4. 5. 6. 7. Apri17, 1972 Atlantic Richfield Company request to amend Order 2 of CO 103 deleting the 7/1/72 date and replacing it with 11/1/72 April 7, 1972 Union's request to amend Order 2 of CO 103 deleting the 7/ 1 /72 date and replacing it with 11 / 1 /72 April 14, 1972 Notice of Hearing May 5, 1972 Kenai Peninsula Chapter request for delay on termination of Cook Inlet offshore flaring May 11, 1972 Transcript of hearing October 6, 1972 Union's request for Administrative Approval 103A.1 September 11, 1973 Transcript of hearing Conservation Order 103A • STATE OF ALASKA DEPARTMENT OF NATURAL RESOURCES DIVISION OF OIL AND GAS Alaska Oil and Gas Conservation Committee 3001 Porcupine Drive Anchorage, Alaska 99504 Re: THE APPLICATION OF UNIOhJ OIL ) COMPANY OF CALIFORNIA AND ATLANTIC ) RICHFIELD COMPANY for an order amend-) i ng Rule fdo. 2 of Conservation Order ) No. 103 by deleting the date "July I,) 1972" and substituting the date ) "November I, 1972". > Conservation Order No. 103-A Trading E3ay Field diddle Kenai "f3", ''C", "D", and "E" Oil Pools Hemlock Oil Pool "G" NE Oil Pool Hemlock NE Oil Pool June 8, t972 IT APPEARING THAT: I. The Oil and Gas Conservation Committee published a notice of public hearing in the Anchorage Daily tdews on April 14, 1972, pursuant to Title tl, Alaska Administrative Code, Section 2009. 2. A public hearing was held May il, 197?_ in the City Council Chambers of the Z. J. Loussac Library, 5th Avenue and F Street, Anchorage, Alaska, at which time operators and affected parties were heard. FINDINGS: I. Immediately following issuance of Conservation Order No. 103, operators and affected parties commenced studies to determine a beneficial use or uses of the excess casinghead gas being flared. 2. Following determination of beneficial uses of the excess casinghead gas being flared, engineering and design studies were undertaken and equip- ment and construction contracts were entered into. 3. All of the foregoing was accomplished with due diligence, but was delayed owing to necessary engineering and design time, seasonal Ureather conditions, and construction-and delivery time of specially-designed equipment. CONCLUS I OFJS t. Operators of the referenced pools and affected parties have made a bona fide effort to comply with Conservation Order No. 103, but compliance will be delayed by conditions beyond their control. ~ ~ Conservation Order No. I03-A Page 2 June 8, 1972 2. Compliance with Conservation Order No. 103 can be expected by October 15, 1972. 3. The dates in Rule Nos. 1 and 2 of Conservation Order No. 103 should be changed to the earliest practicable date which is reasonable, but not beyond such date. NOW, THEREFORE, IT IS ORDERED THAT: I. Rule No. I of Conservation Order No. 103 is amended to read as follows: "Casinghead gas in excess of the maximum amount that can be beneficially utilized may be flared until 7:00 A. f~1., ADST, October 15, 1972." 2. Rule Na. 2 of Conservation Order No. 103 is amended to read as follows: "Effective at 7:00 A. M., ADST, October 15, 1972, the flaring or venting of casinghead gas from the Trading Bay Field is prohibited, except for the amount necessary for adet~uate safety flares and except in emergencies." 3. The Oil and Gas Conservation Committee, by administrative order or orders, may extend the date provided for in Rute Nos. I and 2 of this order. No such order or orders may extend the date beyond 7:00 A. M., ADST, November I, 1972, except pursuant to Title 11, Alaska Administrative Code, Section 2012.. DONE at Anchorage, Alaska, and dated June 8, 1972. ~~~,p. OI,C ~~ ti .~ ~ R''" ~ , ~~ ~cn r ' ~~rq I Thomas R. Marshall, Jr., Executive Secretary Alaska Oil and Gas Conservation Committee Concurrence: ~ d~ ~ ~.,: Wo er L. Burrell, Chairman Alaska Oil and Gas Conservation Committee • 0. K. Gilbreth, Jr., P~embe Alaska Oil and Gas Conservation Committee ~. ,. ALASKA Q I L AND CAS CONSERVAT ION COQ^'~J ITTEE October i0, I97?_ Re: r+dministrative Decision Trading C3ay Field Middle Kenai "E~'', ~'~~~~~', and "E'' O i l Poo I s Hemlock Oil Pool Y1G" N.E. Oi i Pool hemlock N.E. Oil Pool Mr. tiVade S. P~1cAlister Union Oil Company of California 909 Vd. 9th Avenue Anchorage, Alaska 99501 Dear f~1r. P~1cA I i stet: No. 103-A.1 ,.D°°, Pursuant to Order fdo. 3 of Conservation Order ~Jo. 103, the Oit and Gas Conservation Committee hereby further amends Rule Pdo. I and rule No. 2 of Conservation Order No. 103 to read as follows: Ruto ~Jo. 1 "Casinghead gas in excess of the maximum amount that can be beneficially utilized may be flared no later than 7 : 00 A . P~1. , AST, November 1 , ! 972.'` Rule CJo. 2 "Effective no later than 7:0~ A. ^-1., AST, J~Jovember I, 1972, the flaring or venting of casing head gas from the Trading E3ay Field is prohibited, except for the amount necessary for adequate safety flares and except in emergencies." Unforseen manufacturing and shipping difficulties affecting fifteen valves and valve gear operating mechanisms have resulted in an unavo'j~1- able delay in the line becoming operatio I. / • Thomas R. !^arsha{i, Jr.~~xecufiive Secretary ,p pIt Alaska Oil and Gas Conservation Committee $~ y R' ~ ~ /.~ .-~`~d .W ~~~ ~~ ~ ~~ ~1 `~ `~r ~~~;~ Concurrence: ~~ Homer L.~E?urrei Chairman Alaska Oil and Gas Conservation Committee ~~ O. K. Gi breth, Jr., ""e. Alaska Oii and Gas Conservation Committee ~? s .7 STAGE OE A~.ASi;A • DEPAR ~ i~IENT DF PJATURA~ RESOURCES D~V~S~Ofv t~F' Obi AI~1D GAS A9as~a ~J~ ~ and Gas Conservafi~on Comm~°~fiee COi~SERVAT~uN DRDER nD5-C d ~G2~E Ga~ar~3~s Po9n~- Fae9d ~~d~~e G~o~nd Show Ple~c~ TEAR 3 i~G Se~fiembe~ i~q ~~73 • • PROCEED i ~JGS "1r. 6urreil: Good morning ladies and gentlemen. This is a hearing of the Alaska Oil and Gas Conservation Committee. Two notices are currently filed on this, they both relate to production in the Cook inlet Oil fields two oil fields, that goes to the East side of the Cook Inlet. One of them relates to two platforms in the Granite Point Field and the other relates to four platforms in the ~~iddle Ground Shoal field. The operators of these two, these portions of these two fields are Amoco Production Company, Shell Oil Company, both of whom ,•~ho have requested this hearing; and since the same question grill be involved largefy in the facts, presumally the findings of this order, we have consolidated these two hearings, at least for testi- moray purposes. i~lotice of both Bearings are published in the Anchorage Daily flews, August 6, 1973 as required by law and regulation. ti1y name is Homer i3urrel(, l'm Chairman of the Committee; to my left is Tom P~larshall, Exxcutive Secretary of the Oii and Gas Conservation Committee; to my extreme right at the end of the table is ~~r. Gi lbreth, 0. K. Gi lbreth, ti~rho is a mernbzr of the Oi l and Gas Conservation Committee; to my right is Per. .John Reader, Assistant Attorney General of the State of Alaska. i.~nless somebody has somefihing else, I'll ask the applicant or applicants to proceed witB their testimony. P.1r. Crews: Thank you dir. Surrel 1. lde have been prepared ~~1r, Burrell : 'vdou l d you identify youse l f? • ~~ P~lr, Crews: }'m Ralpn G. Crews, and l represent Amoco Production Company and the ChakaGafina group for purposes of this hearing and we had originally requesfisd that fihe hearings tie Gonsolidafied beat } shirk you have adequately taken ca re of =chat ~ ' The purpose of our applying for this nearing on an amended order is to amend a respe::tive Gonservat;on order to a}low an operator by administrative action ^~i'r t'r•oufi pearl ng a r^axi mum of 60 days per event per p ! atform within which the operator may flare gas because of an operafiiona9 necessity anti c~~rrently there is a 9~ hour rule in which you muss notify the Commission for' downtime or for` f9aring necessity, and our application would not tamper wifih snafi 96 hour reguiat}on. ror in3stance if we had to fiar'e gas under fihe 96 hour rule, we ^~rou 1 d notify the Commission, and i f t wo~~ l d appear that we ~;JOU i d have to go beyond ~~ hours, the o0 day time in which we applied for i^~ould begin from the first notice on the 9o hour point of time -correction from the downfiime start, and vae would }ike to ask the Commission, first l wou9d say P4r, Evart Gi}es will be PmO~^~ t s f 1 rSt w i tneSS and we hive order 'vV i tne1S2S i `~ neCessa ry . fir, t~ i l BS has test i r' i et; many times be~{ore a1d we wou } d ask thai- his qua } i f i Gat i ors for fiestimony be waived and vie a}so wou}d like to asl< the Commission that they ;^;ith- hold any questions of "sir. Giles until the wisness for She11 pas testified, be- ca3ase the tesfiimory does in fact complement each other. Of course that is the d ; Scret i of O~ -l';1~? ~;omm i SS i On 3 SL? 8s i Sc~'r `~1r. ~ 1 l c?S !-~J i } } b^c fir;lOGO J S f i r'S~' ;a i tress and we call him now to the ~fJ i tress stand. -ir. Burre } ? : ~.~n 1 ass there 's s ob;ect i on, let she record ref le:.t that ,tile ac.Gept l'~1r. G i l es qua l i f i cafi i ors as a expert ~,v i tress . ~^!ou ! d you swear h i rn i n ''~r. '-larsna 1 } - 7 - • • f~1r. P-larshall: Yes. Please raise your right hand, In the matter now at hearing do you swear to tell the truth, the whole truth and nothing but the truth, so help you Cod? T4 r. Giles: i do. f~~r, Marshall: You may be seated, thank you. P•1r,Crews: v~loul d you p lease state your name? P•1r, Giles: P., B, Giles, with Amoco Production Company in Denver. f~1r, Crews: t^ihat is your occupation +Nith that company? "1r. Giles: l am in an engineering capacity with Amoco in Denver, ti1,. Crews: Pair. Giles testimony will be in narrative farm unless you have objection. fir, Burrell: No objections, P~~r. Giles: Gentlemen, lets turn to Exhibit 1, for Amoco, which has just been handed out, which is a three pane list of situaticns requiring flaring due to operations! necessity, P•1 r. Burrell : Excuse Me, P~1r, Giles, i s i t poss i b l e that there i s any way to display this so the public can see any of these exhibits? ~1r, G i ! es : There are on l y the £3Z by l l s i ze Pair. Burrell , so P1r, Burrel3: How about the fold out, can we get those out in any way, or can we lay them out on the table here, then we'll take a break and let people look at them, if anybody is intersted, Per, Giles: Right, Do wQ have any more copies, why don't we just do that on the table. P4r, Burrell: It won't go up any way on that board, it would be a little easier if it would, but i guess it won't will it? -3- • • ~~r. Gi ies: hJot r¢al 1~~, N1r. Crews: 1 rather- doubt unless there is some way, (`sir, E3urre 1 i : di do °t bring any tape, d; d you? Mr. Giles: Stare didn't, 1r, Giles: Going thru this ~,rnoco LxhibiT i, we have listed by Platforms the four platforms and the onshore facility, the various situaTiohs that ~~.~e would have Alarmed or scheduled fo- inspectien of the equipmenT, the component parts of the gas handling system, The compressors, the dehydration units, the safe±y shut-in valves on the pipeline, the production vessels, the main power panel on each of the p'atforms and on the on-share facility the ,has scrubbers ti;at need inspeCTion periodically, The second Column ir;dicates ere length of doatn-time ror This period°sc inspection and the thir'_l coltamr~ ;s ho~~J oaten wculd vre need To do this, carry out this inspection and the last CoBumn, is the estimated gas that would be flared under each of these situations that are listed. Those 2'Stimated qas vol~~mes art based on the aver°agC~ t~c'1.S figures reported t0 V^^.~u, the State, over th;r first six months of this yeas' 1?73, Plow o+.~r Exhibi~fi 1, is strirTly a tabulation of scheduled or planned in- spections of aqui pmcnt, l kind of l i r,ei-? i t to the fast that i ~~ yota or ~ were n b~°°~~ an automobile we g,et an owners manna 3 an^ i n f he back of that man!aa i based upon the recomme;tdati on tlT+ the caY manJ f aCtur~+ ~ i t eel 1 S y"u t~at~ Cs:?n- erally that after 4,Ou0 mi ies or ti:ree months, which e~~=r° occurs first, •you should gefi your of changed at the point in time 'J~hen you have driven 12,00 m i ~ 25 yon bent'"' get yC3?;r p (Ug5 and po i nT5 Changed, c7t ~~, ~iJ~ m i ~ eS }'tau betTer Change the h i gh,poured i+~bri Cant ; ~~ tide differentia 1;, and this i s bas i ca l l y what Tab 9e i, or exhibit I or' ours tens us, It is based upon manufacturers. -4- • C recommendations for the component equipmen± in the gas handling system as to when we should check it out and inspect it, ic;e have tabulated on that exhibit all the items we can determine are oT a regular or anticipafi2d nature, but it does not include any unplanned situations, For your infa rmation we have a back- up of spare parts an hand o~- par°ts are readi I~r a•~ai fable to repair essentially any part of the gas handling equipment with's;~ a four to six week period. 1"his does not of course incl3ade a catastrophiil 'failure cuff covers most oT the nor- malty repairable items. Our requested order toda,~ covers the need to flare gas during much longer downtime periods, however. Ar`~: example would be the unusually long plant turn- around that woi~ 1 d i ncl ade a major' repair., I''do<<1, we P re going to have a :~+i mess after- Shall, from Collier Chzm:oaf, who will talk about plant turn-around, but this requested order oT ours and Shell's ~.~rould also cover the need for longer pe'ri ods than the p 1 anned or sched+.~ led situations, such as under~~rater p i.p° l i np breaks, perish the thought. 1~'e've had enough of those but we never know when it could nap pen again, and on that score 3 might recite for the record that some of the breaks and the lengths oT time on each brea'r., it has taken for us to repair that pipeline break. On the Granite Point l3 line, ~Nhich is the gas line Trom Granite Point to the East Forelands facility, we°ve had five breaks over the years, In June of 14~~, it took '7 days to repair a break, in June of o4 i t took 17 days, i ~? June of ! 970, June seems to be a favori to month oT these breaks, June oT 1470, it took l~ days to repair a break, in April oT 1471, 22 days to repair a break and then on December 7, 1371 the line broke buff we could not re7a'sr sr ants' 1 wet l into the Tot lowing •year and the repelrs aot- wally started the 2b oT September 1472 and took until the 1st of December, P~j72, -a- • • which is a repair length of 66 days. ! think that you'll recall that last ^Jo~~ember ! was here to Testify on that parfi i cu l ar Situation , Piow on the Granite Poi nt A 1 i ne which i s the of ! ! i ne, August ! ti, 8972, roe berian a repa i r that lasted 29 days on that line, On the ~~iddle Ground Shoa! Pipelines, on August 7, i9o6 the B line between Platform Baker and Shell's Platform A, had a leak and it took 64 days to locate the leak and then change out a spool to re- pa i ~° that 1 i ne; ! g i ~~e you those periods of time mere ! y to support the request ~-hat we're making for n0 days, i`he maxi mun of 6(? da•;rs per e°,~ert per p 1 arfor m within +~vhich to flare gas during operational downtime of equipment, Now since the sale of Amoco's c~as tv Union Oil Compan°~ is e^tirely, and so8aly dependent solely and entirely on Col3ier Chemical using the gas for fuel, a turnaround of the Collier Plant results in a djsect eff:=;ct upo~~ Amoco Ys gas handling operations, Collier plans an annu m -Turn-around each year just to main- tain their equipment in good shape, just like aJe are doing the same thing by ~ri;tue of a99 the situat°sons 8shad on our ~.h'sh;t !, for our equipment an:~ e~~ery effort w i ! ! be made by Amoco to word i ;-sate i t as m~.;cb of its ma i n~-enance work as pons i b ~ e with the p I armed Co! I i er turn-around. l-loVJ2Jer', 1 f you ! ook at Arroro's =xb i b ? t care f u I 1 y, you ° l see a nur~be r o s ~ tact i ons that can not bu bandied at that particular time. 1 ° d i a ke now to turn to Exl~ ~ b i t ~, aJb i ch ~ s a Beta i ! ed f l oar scherlat i c of the Amoco operated gas ha,-,d 8 i ng systems „ On the 1 eft side of this Exl1 i b i t aJe show the equipment that ;s on t,e platfo;~m, each of o~.:r four platforms, Bruce Anna, Baker and Di lion,. the compressors, the s;. rubbers, t8;e glycol con actors. This is designed basically to pressure up the gas fc~r transmitting it to shore and to clean up the gas of any crater vapor for transmitting the gas on to -6- • • shore. !n the right hand side of the Exhibit 2 is, shows the components on shore at East i=ore8ands to dry up the gas, take the liquids out the heavier hydrocarbons, which are blended with the crude oil and the dry gas as shown gust above the right hand corner of this Exhibit 2 goes to sale to UnBon Oil Company. This particular Exhibit has no direct meaningful purpose for this hearing, l simply offer it into evidence to allow your staff, Pair. Burre!! to have i t for ~,vhat eve, ease the4, may see f i t i nterna ! . ! t was the des i cin l ay_ out of the entire systzm at the time it was installed. !'d like now to cover tre next three Exhibits, 3 through 5. They are per- formance curves on one Middle Ground Shoal well and two Granite Point we!!s to illustrate the adverse effect on oi! production caused by the exposure of the formation in the producing wet! to produced 'Hater, whenever s?rch a well is shut- in. ! think you'1! race!! as l certainly do that at previous hearings on gas flaring ! was invariably asked by your Committee to present examples of wells where we do see an adverse affect, if a production restriction we re imposed to eliminate the need for flaring during such times when a!l gas cannot be marketed and so in advance of hearing that type of question again, ! thought l'd give yoi~ three of illustrations today. Exhibit 3 is Priiddie Ground Shoa! ;rJel l (~lo. !! in the BCD gone. The we!! was making about lOO barrels of water per day and about !5O barrels of oi! per day when the wei! in the middle of !971 was shut-ir while a pompressor was down at that time and we last the BCD as a p~"oducer. !t was not economics! to repair it and try to get it back to the !5O barrels a day level. The well is an excellent producer on the EFG side.at this time. Exhibit 4 is in Granite Point, the ADL 1872 #P well, that was producing abort 3t?O barrels of of ! per day and lrJO barrels of .rater per day, when in -7- • • August of 1972, the well was shut-in for- practically the whole month, ~0 days in August, during the pipeline failure and subsequent repair that I had talked about just a little earlier. And that well never did come back, it in our apin- ion Lost an equilvalent of If30 barrels of oii per- day, +~rhen it was put back on production, Now whether that oil is lost entirely, forever, is debatable, if anything it may be deferred to the end of the 9ifie of that particular well's producing effort, b+,t the present =~rorth of t~^e future i ncome of course i s pract- ically zilcha Exhibit 5 is another well in granite Point, the ADL .ii3742 #~I0 wel9, Again during the time when the well was shut-ir for- 30 days in August 1972, for that pipeline repair, it had been producing p~ for to that time abo+.at 400 barrels of oiI per day and oh some 40 o r 50 barrels of water per- day and after being shut- in for a month, the well dropped or newer came back to its former productivity and we figured it suffered about a 140 barrel a day loss, We performed a $50,000 acid ,job to try to restore praducti vi ty of the vrel I back to the 400 Barre I a day level, but we were riot successful. It never has quite gotten back up to that pre-shut-in level, despite that expense to pe~°form the acid job, sa we think this is rather reasonably strong ~vicience that we do see an effect when we have a well sh~At dawn that has be?n producing water along with its oils Now there are not many examples available because very few of the wells in the fields praduce water at the present time, however the water production can be expected to increase in both fields as they become depleted and this would pose an increasing prob9em under these situations, The last Exhibit I have is Na~ o, which is an econamical comparison of the value of gas #hat would be flared at c~.rrent rates far the ~hakacatna - 8- • • properties In each field, Midd@e Ground Shoal, South ~~liddie Ground Shoal and Jam./ .'% Granite Point ve taus the dollar lost by v@rtue of pinching back the oil ,ate. e.. duction that would eliminate the need to flare during such times when a@@ the gas cannot be marketed, We ha+le based this Exhibit on the annua@ Col@ier Plant turn-around. l think the signiflranee of Exhibit 6 is shown by comparison to the second column under the va@ue of pinch hack oil versus the lower riraht hand column on Exhibit 5 the value of gas saved in each field and that sign- iflcance is that the value of the pinch back oi@ production far out-strips the value of the gas that would be saved instead of flared during the plant turn- around. Plow, despite this rather obvious conclusion l want the Committee to be assured that we do receive a value now for the gas and so It does indeed be- hoove us to minimize any and all downtime when we are .required to be down for operationa@ inspection of equipment or failure. In conclusion @ would suggest that we continue to report monthly to you any and a@! downfiimes that exceed 96 hours. This is the present requirement, UJe belie+.~e !t should be continued. Again as ~Ar® Crews had pointed out !n his opening remarks, we°re asklr~g for a change in the present Orders only with respect to allowing a maximum of 60 days per event per platform to flare during any downtime or operational necessity. The 6O .days would start when the do~:.+n- time occured, it would not be tacked on to the 96 hours, we're not asking for 04 days, we're asking for 60 as the maximum, I've tried to show with Exhibit ! that we do have the normal preventive maintenance program for our equipment, P,lothlnq on Exhibit 1, except for one situation, the Worthington Compressor on Baker, would exceed 95 hours as we see it. By annual Inspection of the Wurth- ington Compressor on Baker it would be expected to take !d days every two years, -9- • • which would be an a~~erage of five days a year, but we newer know when we go into inspect equipment whether we might see something unusual or dose to failure that would require a repair. We never hope for that of course but we do see the unexpected once in a while, we want your amended order to cover those situations as well as more, you might Cali more extensive in length of time situations like pipeline br~:aks and other matters that serfous„ l be- lieve that concludes our direct testimony. Shell wi91 put on testimony that I understand will be a slightly different approach to the situation that I have ail~ded to and if you could bare ~,vith me on questions, ! think after they are through, why we'd be happy to have both the Shell witness and myself come back on far any questions you may have, if that's fair enough with you Mr, F3urrell. Mr, 8urre I I : Thank you, i~ir, Gi 1 es . N+ou i d you i denti fly these Exhibits you ~~i sh to i ntroduce into the record, Ulere they prepared under your supervision? Mr, Giles: Yes, they were prepared under my supervis'son and we'd like to have Exhibits I thorugh ~ put into the record at this hearing, Mr, Burrell: very good, unless there is some objection we'll enter these Exhibits 1 thrrugh 5. I trtould like to suggest we take a break of ten minutes so that any members of the audience may Zook at these Exhibits he re and if they're still looking we'll extend the break after that,, otherw'sse we'll start after tei~ minutes lair, Barre I I : IrJe' 1 I convene the hea ri ng. age i n at th i s t i me , Mr. Garnet: Mr. Chairman, members of the Committee, my name is Richard garnet, I'm with Ely, Guess ~ Rudd and I'm here this morning to introduce Dick Bates of the She1I ARCO Standard Group. Mr, i3a~l-es is the Division mechan- ical engineer, of the West Coast Division of Shell, her, Bates has been before this -IO- • • Committee in the past, most recently in June, this past June, so 1 would ask that his qualifications, the statement or' his qualifications should also be waived, if that's agreeable, Mr. Burrell: Unless there is some objection from the ~-ly, h1r, Bates qualifies as an expert witness, Mr, Garnet: As Mr. Giles mentioned we would like to have questions held so that they can be presented to both ~1r. Giles and Mr. Bates and their joint input can be tapped by the Committee and also as mentioned before, following P~1r. Bates testimony we wou l d 1 i ke to ca 1 1 Mr. McP~ahan, Bob P~cMahan, who i s with Collier Chemical to give a little more detail to the run down on the nature of the Collier Plant turn-around, With that, l'11 let Mr. Bates take the stand, Mr, Burre 1 ! : Thank you mr, Garnet. ~•~~-. P•~arsha l 1 wi 1 l you swear h i m i n? Mr. Marshall: Will you please raise your right hand. The ma~-ter now at hearing, do yon swear to tail the truth, the whole truth and nothing but the truth, so help you God? Mr. Bates: I do, As has been stated oefo re Mr. Marsha9l: Thank you, i~r, Bates: As has been stated before the purpose of this hearing request that the operators be allowed a 60 day no flare period during operational necessity periods, At the conclusion of my testimony l will request that an annual, that 6G days of operational necessity downtime per event per alatform be granted administratively by the Committee. As Shell's and SAS gr^up's repre- sentative at this hearing, l will revieFf~ the flow schematic of shipping the excess casir~ghead gas from MGS Platform's A&G to the point of its sale as fuel gas at Union's Cal9ier Chemis:al Plant. • • 9 wi99 also review o+~r operating experience since start-gip of the system in November of 9972 arid provide you with informafiion concerning equipment fai9ures and system shutdowns during which time the casinghead gas not used as fuel gas on the p9atforms, was f9ared, in addition, 9 wil9 discuss other possible events whioh cou 9 d req~s i re ~ 9 ari ~?g of cas i nghead gas . Th i s t~;sti moray i s intended to present the operations and probisms involved with oompression of gas on the offshore platforms and its shipment to its final destination, The bene- fits of ras flaring over curtailing of oil production had been presented in previous testimony, most recently in m~ testimony on June ?l, 9973, l want it to be mentioned at this time, A39 proda,cing casinghead gas, which is not ge- q~aired for fuel on o+.~r platforms and for safety flare, is compressed on each of the P~iddie Ground Shoal Platforms and shipped via common line to the East Fore9ands onshore faci9ity. Nere the gas is sc rubbed of a9l liquids which have dropped oat in sub-sea transfer 9i;~e, routed through a sales meter and shipped to Union Oil Compah~,r's Cailier plant where this gas 9s used for f~.~e3> The on- shore system has been shown in detai9 by Amoco's representative, VJe have provided Exhibit No. 1, Which is on the board here showing the ~enera9 flow schematic of the casinghead z?as from the p9atforms to its usage point at the chemioa p9ar+t. For convenience i v.ish to break this system down in fo~~r see~me~ts and discuss each separately in regards to its past performance and posyib9e fut!~re operatirag p;ob9ems, First we have the P@atform Com~ressioh Faci9ities, the excess cas9nghead gas on both Platform A and P9atform C, vrhich are the two midd9e p9atforms in the f9ovr schematic, is compressed from 5?~ psi suction to 2S0 psi discharge pressurep via centrifugal compressor packages 9ocated on each platform, The -92- • • Platform C compressor package has operated satisfactorily since start-up in November of 72, with 97/ availability. I'm using the definition of avai!- ability as the time on-line shipping available gas to sales as compared to total time since start-up, The Platform A compressor package as we discussed in our testimony in June ?_l, l973, has experienced serious operating problems and shut-downs with resultant compressor drive shaft failure on ~iay 2~> This unit has since been rebuilt, brought back on the line on July 28, and is now operating satisfactorily at speeds below 90~ of design rated speed. At these reduced speeds the unit is capable of shippir~? excess casinghead gas to shore, 'rJe are continuing to work with our compressor supplier on design modifications to assure that we have continuous operation of the package. Aga °s n as shown on Exh i b i t No> I the four ~•~1GS P l atforms are connected v i a dual E3" steel, concrete coated, transfer lines, These'lires are lying on the inlet bottom with risers going ap the platform leas tying in at each platform. There are two 8" steel, concrete coated lines traversing from Platform A to ShellPs operated East Forelands Facility, these two lines here, These lines are used for shipping oil and `Hater emulsions and are not satisfactory fc~r shipping natural gas, as we had provided in previous testimony in 1971, t~lr. Giibreth: Pardon me, would you make that statement again? 1~1r> Bates: These lines are not suitable for shipping natural gas but are suitable for or are used to ship oil and water emulsions, Now, we provided testimony to this content in 1971 at the no-flare hearings. Dua! liras connect- ing the four platforms can be the lures shown horizorally across the schematic are also II`' concrete coated fires. However these lines were designed and are suitable for gas transmission, One of these dual fires is generally used for emulsion shipping while the other is used for natural gas shipping. -l3- • • There are also two 8" steel, concrete coated pipelines t reversing from Amoco's Platform Dillon to the Amoco operated East Forelands Onshore Facility. One of these two line in the south area, these two fines here,'ss used to ship natural gas to the beach, the other Bine is used to ship oil and water from Amoco's Platform Dillon to the facilifiies. The third segment, the first two being the Platform Facilities and Trans- ter lines, the third is the onshore facility where the gas is scrubbed of liquids which condense in the Sub-sea pipeline. This is again the facility shown in the Exhibit provided by Amoco. The final portion is fihe gas utilization point. Tthe gas is said through a sales meter and then routed via one l0" steel coated and wrapped butted gas fine about four miles to Collier Chemical Plant, We'll now review our operating history as the SAS platforms in diddle Ground Shoal, During fihe brief ten months of operating history during which time the No Flare Order has been effective, the system or pa rtions of the sys- tem have been shut down with resultant gas flaring for the following reasons, 1 will present Exhibit 2 to generally outline these periods, Ths"s is a continuation of the Exhibit we presented in June again. Flaring of all excess casir,ghead gas occ+ared as a res+,~lt of shutdown of Collier Plant d!a ring the period of June 2'Z to J u f y 14. We understand th i s sh~.~tdown was an annual shutdown complicated somewhat by an accident on one of the process verse 1 s . We a f so s~nderstand the' peri ~d of approx i mate! y four' weeks neces- hating complete plant shutdown wil! be req~3ired on an annual basis. During this period it will be an operational necessity to flare a!l the gas in the MGS field except that gas used for fuel or safety flares. -14- • • The compressor failure on MGS Platform A which occured on May ?_h, 9873 resulted in 53 days of downtime with resultant fla;`ing of Platform A casing- head gas. The compressor fai-ure occured as a result of an original 'snherent compressor problem and cannot be considered routine operational downtime, These problems were covered in detail in our .June 23 testimony at which time the committee granted a temporarary exception to the No Flare Order for P9at- form A, Exhibit 2, generally is a documentation of the compressor on Platform A's operating i•: i story v Some other extended periods of downtime on compressor Platform A occurred in the period prior to ~~tay 2~, These are generally found to be in association with our major failure as we showed again in our previous testimony, Other portions of this system hawse operated satisfactorily without extended downtime to date, For convenience, I will again follow the portions of the casinghead gas sysfiem and discuss some of the potential downtimes which could occur due to operational necessity, On the platform compression facilit'ses, our limited experience with our compression +~~? i -l•s to date, we cannot predict the amount of downtime we wou i d have with high accuracy. However, we believe that each compressor package will require a major o~serhaul every 20,000 operating hours, or every two to three years, These overhau9s require approximately two weeks of downtime, We keep an extensive stock or' spare parts for the compressor packages on the platforms to minimize downtime due to equipment failure, howeve r, it is still possible that unexpected tai l ure of major ccxnpressor component parts which are not locally stocked could cause delays of several days to several weeks, °l5- • • Subsea gas shipping fines are now used for shipping, that we now use for shipping were installed in years 1965, 66 and 67, I~Ve had -h~vo line failures at Platform A in the leg risers in .1966. However the lines connecting the four Plat- forms have not experienced any failures to date, On the dual oil shipping lines from MGS Platform A to the Onshore Eacil~ty we ha`>e experienced two failures, one in i967 and ore in 1968, The two south ~~iddle Ground shoal lines required preven- five maintenance work in the summer of 1972. These were the ones from Platform Dillon to Amoco's Onshore Facility, with resultant temporary line shutins. Due to ±he C=:3ok inlet environmenfi,line failures cannot be guaranteed against. Pipe- line repair cou9d take approximately 2-4 weeks, ~.~nder the best of conditions, to as much as se venal months under the worst of conditions, 1 would say the worst condition would be a failure during the early part of the .ice season. The East Forelands Facility as presented by Amoco, we are not expecting to have prolonged necessary operational downtime in this system, due to the design and nature of the system, The fourth item, which is Collier Chemical Plant again, which we mentioned before, routine plant turnarounds are expected to take four weeks per gear. This is an approximate number, These will require complete plant shutdowns ~v i th res u l taut gas f l a ~° i ng e~cpected an n~~a l l y. Generally speaking the downtime of platform compression facilities +,~ill affect onl<~ that platforms excess casinghead pas. However, any problems occur- ring in the pipeline or do~fnstream facilities will affect all excess casinghead gas produced upstream from the problem area. 6~fe plan to schedule all necessary maintenance and operations where possible to minimize the operational necessity downtime. An example in this would be a scheduled compressor overhauls be con- current with plant turnaround, -16- ~. • There is another area that we have of concern and this is the nature cf unplanned break downs. l'd like to provide you with some information as to the time required to repair a maJor unexpected equipment fa6lure. 1°ll review chronological events of repairing the Platform A compressor after its failure on Slay 25, 193. The time of the failure ~Nas l O p .m, , Fri day i~~ay 25 > The failure type was in parting of the gear box to compressor coupling with extensive damage to compressor rotating element, seals and bearings, Our engineers met with Solar, our prime supplier engineers on Wednesday Ma*~ 30, to formulate p l ans for getting the !.°n i t back i n oparat i on > The un i t was completely disassembled during the period from J~~ne l to :tune 3, this :ass the compressor disassembly, by factory mechar-~ics from 1`ork and Solar. Ocm- :~ :' pressor rotati-gig was shipped ~;ia air freight to York°s factory at York, Pa. Upon arrival at the factory it ~1as further disassembled and completely rebuilt. Since these compressors were specifically custom built for the Job, off-the- shelf items were not available for repair> Farts ~,vere machined as required working on an overtime schedule, and ir~ork was completed on the rotating element on July° 9 > The element was then shipped to Alaska via air freight on July l0> l:~uring this time the Solar turbine was disassembled and checked for possible damage, the Western gear box was removed and sent to the factory in San Die~?o for complete disassembly balance check, and the repairs were made to the seals and the bead ngs i~ the unit, It was also rsturnedro Alaska. The compressor rotating element and gear box arrived on platform on July l3, The compressor was reassembled by factory mechanics and completed on July 18, On July l9 and ~l, 19 through the 21, start up performance test 'was conducted by Solar and Shell> During the startup test, shaft deflect'son probes were installed on the unit to continuously monitor the deflections for -17- • • safety precautions. The unit checked out alright to run at a 90°~ speed limit. The unit was then shutdown, permanent wiring, permanent shutdown reinstalled and the unit was brought up on line on July 28. Although this above mentioned failure is not a part of our routine opera- tion, it does point out the time required to repair major uncommon equipment failures, Of the total 63 days downtime about 50 days were required to disassemble, ship, rebuild, and reassemble the equipment. CJelay or even loss of production at ~~liddle Around Shoal is possible if wP curtail production or shutin wails. V~le provided data to demonstrate this in our Plarch 4, 1970, and June 21, 1973 testimony, Our operating experience in this multi-layered field has shown that shut-in or curtailed production gener- ally takes three months to recover to a stable condition at or slightly below its condition prior to curtailment or shut-in, V~le must admit that generally our data is not totally conclusive; however, there is strong evidence to show that some damage and lost production is caused by restricting or shutting in production. Again the equivalent BTt! value and the dollar value of the oi! is considerably higher than that of the associated gas production as we have shown previous9v/. j~Ve do recognise an operating income from the sages of gas, therefore it again behooves us for our own interest to resume sales of gas as soon as possible after a breakdown or shut-down, Our forecasts predict that for our platforms, MGS Platforms A and C,'ttiat we will not have casinghead gas for sale after 1982. ~Ve will then use this gas for fuel and will be required to provide an outside source of gas, -08- • • fn summary we recommend that Order No. !05 be amended such that the Com- mittee can administratively grant the operator up to F,O days per event per plat- form of excess casinghead gas flaring for downtime due to operational necessity, This 60 day period would be initiated upon the operational failure or shut- down, The request would be made after the 9C hours shutdown period has elasped as now available in Order ~fo, 105. Repo sting of down time should be on a monthly basis until the event is corrected, Further, gas flared onshore for any operational necessity should be considered as, and accounted as, c~as flared on individual platforms, That is we are not distinc~uish'rnq whether the gas is flared on a platform or onshore, if it is produced by that platform and flared then it should be considered as flared gas, We feel that 60 days per event are .Justified by the anticipated one month per year of downtime required for plant maintenance shutdowns and overhauls; and the time required to correct unforeseen system ma9functions as experienced with our past compressor breakdo~vns or pipe- Sine leaks, Gentlemen, this concludes my testimony on this matter, ~^r, Burrell: Thank you, ~~?~°, gates. Would you like to introduce your Exhibits into the record (Can't understand,) Mr, Bates: Yes sir, they were prepared under my supervision. Mr, Burrell: Shell Exhibits l and 2? ~1r, bates: Yes sir, fir, Burref l: Thank you, Shel !'s Exhibits I and 2, ~-ir. Bates, Mr. h,farshaf l wants to know ff you have any small copies? l~~r, Bates: Yes l do. Mfr. Burrell: Are they identical to the large ones? P~lr. Elates: Yes they are, i have a couple copies f believe, -f9- ~J r~1r, Burre I I : We wou! d ! i ke to have those for the record then, rather than the large ane, fihey would be very difficult to file tthose, P~1r, Bates: ! do to. ~~lr, Garnet: "Ar. Chairman, I might ask whether the Committee would prefer to ask questions of the two gentlemen who have already testified at this time or to have Mr. l~1cP~lahan present h i s testimony f i rst, P~tr, Burre 1 l : 1 think we' l l just ask ^-r. h9c~_~ahon to tesfi i fy, to get the who l e thing done at once. 1 ;v i l ! ask one th i net, i n fact th i s a i so applies to r~r. P~9cMahan do you have, thcise of you who have testified, do you have a written copy of your ora l testimony, or sa-nettr i ng typed there i s a great he I p to our g i r l s who type i t? ~~tr. Gannet: A l ri r~ht at th i s t i me l' I l ask l~Ar, ^~cn~ahon to come to the w i mess chair, Mr, Chairman I don't believe h-1r. ~•"cP~an has been before th i s Committee, i f !'m not mistaken, so l will ask him to run through briefly his position, his educa- tional qualifications, his experience with the matters that we're discussing. ~~lr, Burrell: Could we also have his first name and spelling, ~~r, Garnet: Certainly. Mr, NIcP.~ahon : ~iV name i s Robert G. ~~ic"~ahon . r~~1r. Burrell: Thank Vou, ~qr, P~ci`lahon : lvly current position i s the P I ant I`~anage r at the Co I l i er Carbon and Chemical Corparation Plant in Kenai, !'m a chemical engineer, graduate of the University of British Columbia in I~?~(3, In the 23 years since graduation I've been employed in various engineering capacities in the oil and chemical industry both with the P~lobil Oi! Company and the Union Collier group, For the past two years l have been the manager of the Co9lier Facility in Kenai, -2±~- • • Mr, Burrell: Does anybody have any questions for Mc"lahon, unless there is an objection, we°4l accept his qualifications as an expert witness. 1'll ask Mr, Marshall to swear him in, Mr. Marshall: Please stand, Raise your right hand. !n the matter now at hearing, do you swear to tell the truth, the whale truth and nothing but the truth, so help you Cod? Mr. ^~~cMahon : ! do. Mr. P~Rarshall: Please be seated, Mr. Garnet: Mr.. McMahon, why don't you just proceed to te94 the Committee what you have tc say about the nature of the Collier operation, !n particular the annual turn-around procedure that has been di=cussed sa far, P~1r. McMahon: l_et me say f i rst, that ! da not have written data i n support of what 4 say, ! will define the turn-around situation of what we do and will be happy to answer any questions that you might have. The term turn-around, just for definition i s the synonym for overhau l peri od or maintenance repa i r period, or what have you, and it is somethin~n we must do once a year to comoly with the boiler inspections on, by the State requirement, and also the pressure. vessel work, and we select that same period to perform the major overhauls on our Compressors, turbines, pressure vessels, replace catalysts that may be exhausted, to replace defective metallury and so forth, t^1e baps normall~r to accomp9ish ai! of these efforts, in our current program, in about a three week period, but because of unanticipated difficulties we allaw four weeks and in the last two years, four weeks has been standard. Historically, because the plant has been, although not entirely prototype, somewhat developmental, we have run into problems that have sometimes run somewhat It~noer than four weeks. cn one occasion because of -21- • • a severe ~robPem with a metaiPurgical casting we were down for eight weeks during the course of the turnaround, We fee9 however, we have set most of those major problems aside, then we'd hope to meet the four week annual turnaround that we have nova established. Our target for overa99 on-stream efficient+~ for a pPant of this compPexity is about 90% overaPP stream efficiency. '^!e Pook at about fo~.ar weeks outage on this one major turnaround in which we wouPd hope to accompPish everything necessary to permit us to ~-un the remainder of the year continuousPy. But we do reserve the possibility of one other interruption during the course of the year and again because of the compPexity of the equipment we visualize that it too would Past about one week, So our over aPP operating efficiency then would be about 90~ with a four week outage on schedu9e and now we're thinking in terms of September, early October each year and then maybe one other outage during the course of the year at an unspecified time for an unknown reason, we have the duration of approximately one week. !n summary gentlemen P wooed say that is about the way we approach our main- tenance and operating philosophy. Mr. Garnet: Thank you Mr. Mc~~ahon. Mr. BurrelP: Thank you ~~r. McMahon. l think at this time we are ready for questions. P'm sure we wiPP have some, `sir. rilbreth, wooed you like to start with the questions? ~^r. Gi Pbreth: Yes, P'd l ike to start' back with P.Ar. Gi Pes. ~~tr. Gi Pes in the earPier part of your fiestimony you mentioned severaP Pine breaks, I figured i•fi was one or two were oi9 lines, were a9l of the breaks that you recited, actual9y was that of 1 ! i ne breaks or were there some other breaks i n the gas ! °r ne, those carrying gas. -22- • • Nir. Giles: There were five breaks in the Granite Point B line which is a ryas line, that were repaired. There was one in an o!l line in the Granite Point A line and there was one in the line between Baker E3 line between Baker and Shell A, which would be essentially be a bras line. Mr. Gilbreth: On your Exhibit 5, Nir, Giles, looking at the o'sl production curve and the water p~°oduction curve, it appears that after the shutdown that you have recited that the productivity of the we!! itself determined by tote! fl+~ids was considerably reduced. Mr„ Giles: considerably P-ir, Giibreth: reduced, and then your Fxhibit shows that a $~O,OOO,acid job was required to restore the productivity, Ourinq the interim between the acid job and the time the well was shutdown, did, have you eliminated the possib- ilities of problems with the praducing equipment itself, with the equipment of this nature. In other words do you think this reduction is entire9y and con- clusively due to reservoir capacity to produce? Ntr, Giles: Well the acid ,job was to clean, basically to clean the scale from subs~rv! ce equ i ~ment, i t was not i n Ytii~ `i"'hrce of a i maq i net ion an ac i d rack job, so we sti!! believe that this lends pretty strong evidence. That we cet an adverse effect from exposure to this produced water on the formation face, UJe don't know all the answers to this question, but we are concerned as we will bP ~;roducing more and more water with time and more and more wells can be expected to be effected, no matter what the reason for shutdown. I~~r, Gilbreth: I noticed in ail of the curves that you did present here, that we!!s were making considerable quantities of water, anywhere from 1,000 barrels a days -23- • • ly~r, Giles: f~io, you' f ! have to go to the rie~ht hand side of the graph for the water. "fir, GiBbreth: f'm sorry, okay. ! was reading the curve wrong. Mr, Giles: Yes, the felt hand side, that's the oil rieis and the right hand side the water. Mr. Gifbreth: Yes. On your Exhibit 6, ! believe your testimony was that this was indicative of the values of oi! and has during the period of shufidown or turnaround. Eor arhat period of time was this calculated? Mr. Giles: This was cafcufaced on a five weeks basis. ^1ow if you go to Mr. McMahon's customary four week turnaround, that he states is customary, why just take 4/5 of a!f the values but the values wilB remain in relation to one another, dlr. Gilbreth: fn your recitation of downtime that has occured from your properti>es.in the Granite Point and Middle Ground Shoals, your exhibit shows a ten day bi-annual inspection on one of the platforms. !-lave you had any equip- ment downtime other than fine breaks that exceed the ten days. f-#ave you had any Fong equipment failures on any of your platforms? Mr. Giles; f don't recall that we have., no, Mr. Gilbreth: Then most of the downtime on the platform is due to routine maintenance and turnaround and things of that nature. Mr. Giles: Yes, but ! think we have to be practical about this, as the equipment gets older and we get °:nto it on these annual inspections, f think we're going to learn that metaflurigical failures are about to occur and we're going to encounter problems that here-fore we have not had, which will leneithen the down time requirement. -24- • Pair. Gifbreth: Well hopefully the insp€~ctions will preclude that, On your exhibit No, 2, as l reed the Exhibit, all the gas produced from the Baker, SheJI~~ She61~'~, and Dillon, all goes through a common Pine to Platform L~il3on and then ct°oseto shore. dir. Giles: Yes. Nir. Gilbreth: 3s that right. There's no gas going to shore from, directly from Baker or Shell A, ~1r. Giles: No. P~1r. Gilbreth: The existing lines. Mr. Giles: nJo, these l'snes cannot da that, Mr. Gilbreth: I'd like to ask dir. Bates, you mentioned the problems that you'd had with your Shef! A Platform compressor, indicated it$s operating now below 90~ of a design rated speed] what about your platform? I~r. Bates: it's still operating, it's below 90, f believe it's abaz~t 85 or 86~, has a full capacity to flare gas at that rate. Mr, Gilbreth: Dkay, with bath platforms operating in this range, are you able to still move elf the produced gas to shore, al9 except what is necessary for emergency purposes, ~~r. Bates: Yes sir. N1r. Gilbreth: fn your testimony Per. Bates, you indicated that the failure of the compressor on Platform A had required about 6~ days, at feast you flared gas far 6~l days, if l understood. Per. Hates: l believe it was 63. ~~r. Gifbreth: 63, alright. Now the order that you have requested here then wouPd in fact net let you p roduce thane last three days, would it nat. -?.5- • Mr. Bates: This breakdown was of an even more non-routine nature 1 guess you would say than a normal breakdown, l mentioned there were 50 days required for shipping rebuilding and reassembly, the other l3 days were consumed at the beginning, ~ or 4 days of engineering and at the end hooking up of all the safety devices and running performance tests, indeed work we had done at York, Pa, had corrected-tills vibrator problem we had. So a procedure Similar l would expect take on the order at 45 to 50 days between here and back on the line. Mr, Gilbreth: The reason l'm asking this question, ~~t, ~~c ti4ahon indicated that normally they expect a four week turnaround or perhaps five weeks in some cases, and something longer than that would obviously be out of the ordinary, This is what you experienced on your Platform A, something out of the ordinary, Now l'm wondering if the reason for you're requesting the 60 days was because of the Platform A type oocurrance or why the 60 davs. 9t wouldn't fit into Platform A and yet it is considerable longer than the normal that you'dexoect, °~r. Bates: 1 fee! generally that the ma for abnormal types of equipment breakdown or line break could be repaired within 60 days, 30 days is too short ~ --- can't understand --- 3 i Peal the order of magnitude of two months is ample time to repair most failures or correct most operative ~ roblems that have arose. Mr. Oilbreth: As you have requested this order, if you had a failure that required more than 60 days, then would you advocate having another hearing then? Per. Bates: Yes sir, I feel that if we were over 60 days, it would not be the routine in nature and as a matter of fact it may/ be very extensive, it might -26- • • take 62 days or something. 9t is very hard to din down the exact number. l~r. Ciibreth: ~rlouid you object fin an order being written with a Sesser per- iod for without having to cane to this Committee, but with the Committee to have administrative authority to grant up to 60 days. ~~~r. Bates: I believe that would be alright, i think we were really requesting is for the Committee to have the abi9ity to chant up to 60 days~~flaring, ~~r. Ci Ibreth: his I read the application P was under the impression you were asking for unlimited authority to flare 6O days on each occurrence and they could be consecutive. One would flare 6th days and another would flare 60 more > Mr, ~3ates: Pdo, now I see what you°re sayincr but l guess in theory that could happen, except we would have to Dome in after 96 hours and request the Committee's approval to Bare gas,l believe that was indicated in the - where the Committee would give its approve! o r not give its approval, therefore if we violated our business obllgatlon „ you still have control. ~~r, Ciibreth: Let me see, if I understand you ri~7ht. As ! understand you now, you°re saying that if an occurrence happened out there, that looked like it was going to take ~O to 35 to 4f~ days, after 96 hours, you would come to the Committee fio get approval to flare during this time? T~ir, Bates: Yes sir,after, the 96 hours is the provision in the order now, at the end of 96 hours we would be obligated to tell you ~.Ne are down we are flaring and l feel we would be obligated to give you at least an idea of how gong we would be down. Mr> Cues: Can I clarify my view on that. i view the present 9h hour deal befare the expiration of 96 hours, we must notify, report to the Committee, that we foresee that we°re going to be down much longer than 96 hours and we must -27- • :] follo~v up later on and tell you when its been fixed, We want to continue ail that, ! don't think that our view is that we would be asking for your approval per sey to qo beyond 96 hours, fir. P~larsha l l : Nir, ~! ! es, ! wonder i f l cou ! d i nterrupt here, ! think we do need a point of clarification in view of the fact that both the letter from you and from ^~1r. LaGrone, referred to the 96 hours, in what I think is an erroneous application. `(our warding here is 'operating experience has shown that necessary maintenance situations can result in equipment downtime, with the resultant gas flaring exceeding the 96 hours, maximum allowed by the Con- servation ®rder hlo. 9~~." ~.~r. ~aCrone, letter uses simi9ar language, as a matter of fact Conservation Orders 1t~5 and 102, Rule 3 says, the commencment, nature, and termination of a!l emergencies requiring flaring of casinghead gas in excess of the amount required for the safety flaring shall be reported to the Committe within 96 hears after the occurrence" and 96 hours being merely a period of the time which we want to know about it chiefly by telephone communication, Ivlr. C~ ies: Yes, right Mr. ~!arshall: ! know, and l think the 96 hours has come to mean something different like a time in which, flaring qo on, really is a reporting rather than a flaring time, so ! bring this up if we're talking about proposed language, lets bear in mind that the 96 hours is in the existing Conservation order gust recorded, ~~r, Ciles: Alright, but the again back to our basic request were askino for up to Ct9 days per occurrence per event per platform within which to flare, +rle do not intend to use 5c9 days on each event, of course not, but as P~lr. Hates points out, you never know 9h~hen you're going to get into a rather extensive downtime situation that might take up to 6~ days. if it required more than EO days for that -Zi3- • • event to correct the failure, o r the downtime, we would expect that we would have to come before you at a public hearing to get a further extension, but we foresee the advisability and we would hope that you da too, that we've come to a stage in these fields when adminisfi rative approval rather than hearings on everything is the best course of action. This is what we're asking. ~.~r. !~ 1 ! b reth : Let me throw th i s out at you . Can the west s i de of the Inlet the operators have similar problems and my recollection of the, in effect, the effect of the order, l don't recall the exact language, is that an operator can utilise or can flare gas because of these problems that we're talking about up to l5 days per calendar quarter, without getting Committee approval, beyond that they have to get the Committee approval. Cho you see anything wrong with something like this where your` little day to day problems, you have to shutdown for 8 hours to change spark plugs or do somethings else to lubricate or some- thing like that, We realize that those things have to go on and we don't want you to have to come to us for every little thing like that. it's the maJor things -the long periods and a large vol~~me that we're concerned with,.Would you have ob,;ection to an order patterned something like that, ~~r. Giles: Basically what you're then saying is rather fihan 60 days per event per platform, you're saying 6D days per year per platform? Mr. Gilbreth: Yes, yes. Mr, Marshal9: That is, but after that time, then you've got to come to us for Administrative approval which we can give. Mr, Giles: Beyond 60 days? Mr. Marsha!!: Well, beyond !5 days per quarter. The beauty of this thine is,the way ~re're handling it on the other side of the Inlet, is that if you have a problem which you think is going to take b0 days, then we give you administrative -29- • • approved to dare gas in 60 days, but it's actually 62 days, then what are we going to do, :are wp goi+ng to shut you down right there, are talking about a pub}ic h.Qarina~ ~;a don't have time to publish, its sort of Like just an auto- ,~:ati c, we're !.~ rt ',v i th two a i ternat i ves i n a case where you w i ! l run oaae; 00 days and 1 be"ieve that 4;~'ou'ra going to run over v0 days sometimes, Plow d think we'1--<e boxing ourselves in again on the 60 day thing, l think that there's going to be times when you're going to be flaring a lot less than you expect and then there are going to be a time or two when you're going to flare a little more or maybe gulfs a bit more and l rPal9y think that flexibility here is going to help both sides of the fence especda9iy when we get in situations where if we save to h;od d a hearing we have to advertise an d now +.~e ° re d ook i ng at anywhere from 12 to d5 days to effe~tive9y do that, }we've been up against this sort of thing before and I really ~aedieve if yots, if the Committee has discret'~on to administratively permit the flaring beyond a certain time, +~°. can look the sit- uat i on ri t~ht there, d t may be a catastr®ph i s type., i t may take qai to a b i t more time and there always, and we're never sure exa~rt9y how long it takes, P!lr. Giles: Let me be sure I understand what you're saying Mr. ~tarshadl, you've saying if you wrote the order like the one on the west side, the l5 days per quarter, per platform, that's automatic and if +r~e needed more than 15 days per quarter, we'd have to come and ask for administrative approval without a hearing, +~hich you cou9d grant, if we needed more, lets see that 9~ould co`'er, +~~e'd have to forecast at that time how song we'd be down, would we, o~r boat do yo3,~ end, p+.~t the end date on?' Mr. 8urredd: Let me infierrupt here, if i may. The existing orders l~5 and ioz, on the east side, have no provisions for flaring for cases of operational -30_ • • necessity, we oni~I said you can't Bare at al?. it says if you nave to r"fare in case o~ emergency, however you gave to set us know in 96 Hours. Plow we use a rather restrictive definition o~ emergency, until nigher admin±strative aut'nority or° the co~yrts assist gas i ~: our vi e~~r o~ i t, Nre're going to stick to i t as emergency is danger to 9ife and pros~erty. OperationaG necessity is the matter that is uncle, discussion today, Such as mecnanicai probiems, and turnarounds and things like thatq Tne order°s now on the west side provide and discuss i5 days per calendar quarter per pratform and any ~~iar-ing onshore will be aliocated Hack to ali piat- forms. O;nshr~n~-e faci ~ hies, fla,Ping serving two piatr'orms wi i ~ he ai located back to both platforms, both piatro;°ms have been charged with flaring during that per°soda whatever it may be~ Goes that clarify the way things a,,°e now on the rarest side? Now i~ somebody warts to Aare mor°2~ and use up the I5 days per calends; quarter, they corns. to us and tell us now much longer they think they wii8 ha~se t;; !~.eep daring and ask for• an administrative order9 which we may give them, Ude co:~id gi~ra them one for i0 years theoretically, As a practical matter, If it l~aoks like a ma,or probi~m, ne may very well elect to go a public nearing because any number of circumstances coud „ustify that, Suppose the Collier Plant went down for ~0 dayse ror e~amp9e, that's s~o:ands like you have a pretty gr~ d reason Ntr, Giles; VJeI 1, N1r", Barrel 1 : Excuse men by 'char time ci rcumsta;rces may nave changed, There maI be an a l tern at i ve ma r ket ava i l ab l e to you e Ube m i ght rea l l y layan t to thin k of th i s a 9 ternat i ve market, we Sri ght want to no l d a pub l i c hear-i rrg ~ to ~' i nd oat vrny ;°o~a weren't }~s o ng th i s so ca i 3 ed a 3 ter~nat i ve market, A~te~' a i I- tl°i i s i s -31- -J what started the n~o-foere orders in the first place, 1t is o!ur opinion, that there was a market and new it is being marketed so we°re not always right, !~1r, Bates: Are yon empowered now in 1C~2 and ?0~ to allow us to flare by edministrative order for an+r periods desired, h~lr, Burrell: !V`o, flan ing is prohibited ~.!nder i®5 and i02~ ~exeept for emergen~ies~. As a mat#er of fact if the Collier Plant had not had a fire, explosion which coinotded, with their turnaround, we would have conside~°ed it operational necessity and not parmitted by iD5 and ?t32. 1t is an emergency because of an explosion, or fire that occurred in the Collier Carron Punt, !upon svh i ch event you did w i !~ yo!sr tur~!aro~!nd. Does that c 1 ari fy where we stand at all or have i just made it worse? t~ir, Gi 1es: Plc, that~s alright, Mr, Gi loreth: We°re finding more a~!d more as you people are, there°s clot of admin-istrative headaches in trying t® administe~-`this, and i°m interested in eliminat°sng as many or them as we can and covering as much here as we can at the hearing ve pressure. The we 1 1 so we know wherri °~,e are headed, `fin, Gi les: 1 think with that unde;standir!P.;, to answer °~our question!, we could live with that, Mr, Metes: P~?y only question here is ir' you have operational necessity after yo!~r 15 days i n that q~Jart;~,°~, must you rio to public heari no or can .the Committee adm°snistratively extend your flare period. "'?r. Biarre l 1 : linden the west side orders we can .~ i ve an admi n i stmt i ~,re extension, j~lr, Bates; That wo!.~ l d be the same for l02 and 1D5. ~~?r, Giles: That would be at tho discretion of the Committee. -32- +~fr, Burrell: yes, we could call a public hearing if we saw fit, ~Ar. Giles: Depends upon what you hear from use Mr, Bates: Well, i think you have that right at all times. Pn;> Gi9breth: Weil, we're, know i personally, don't know about the rest of the Committee, bat I'm concerned about the request you made, it appears to be very open ended 6th day/s from each ~~ccurrence, and there i s noth i net to say yo~.~ can °t have one right after the other', s;x times out of the year-. This is something that froma +~se standpoi n~fi ; s oad. fair, Bates: ~°+1h7~° ypu~P'-e rB~il^cWi~t7 and 'rih~t J~39' s'°eaj C~C~.!£',rtii%~~, ~i2 f?~iiy about the same. UJh.at eve ° ,gyp beer: after i s not having to come to heari n~°~s, ti 1 1 someth i n•^ Wreaks do4vn and we're notified yoi.~ and yota den °t ha',ie a:^y ~cwer to use your judgment to say, yes, you have a breakde~r+n, we rwnderstand this breakdown, but there is nothing we can do about it-, T~ir. Burred: 1 think, speaking for myself, rather than the whole Committee, 1 think my position is -f•hat we have these minor items under Amoco's ~xhrbit 1, there is nothir?g on there any ion,~er than IG days, scheduled for more than iC days, t^lifih -1'he e~:cent i on of the one i ns-l-ance of the She l 1 P 1 atform, 1 don't know of anyth i nc that's been over fifteen da°/s, s i rce r,o-flare o?-de; has been i n e~f fact., i don't know of uny shutdoavns since the ;±o-Y1are order went into effect, with that one exception who ever had that major problem. Our intent is not to harass you with thes;= minor problems by having hearirsz~s or- messing ar-o~:nd with every spark pfug change and that kind of nonsense, However, if we think that you can - 1. restrict production, 2,fin alternative use of gas; or 3, any other means to eliminate that f 1 ar'e, ire want to rese~°ve the right i f i t i s one hour over that i 5 days per q:~arter to jump in and say, ,veil how come you don't do this, and have a public -33- • • hearing . on i t. [3oes that add anything': Mr. Bates: "•1r. Burre9l, has the order already been publisped in accor- dance with the gas lines? Per. Burre9l: It has been orally given at hearing and 1 think it is on my desk for signatures now. Mr. Crews: As ! had discussed previously with Mr, Marsha9l, perhaps maybe submitting a proposed form of order fd'r your corsidPration. if we°re going to do I might Book afi the one already written, Mr, Burrell: l assume this draft is, this is the 37th and final draft, assuming this is fihe last final draft, it would be appropriate to coma the last day, Mr. Crews° Our suggestion 9rrould be in conjunction with Shell's and Amoco " s. M11r. Gil6reth: l have another question to ask of both Mr. Bates and Mr. Giles, Earlier testimony in these cases indicated it was not feasible to reinj°ct pro- duced gas because of dangers of exceeding natural reservoir containment. There's been considerable amount of fluid withdrawn from each of the oil reservoirs or the defined reservoirs in the Middle Ground Shoal field and the Granite Point f=ield. I'd like to ask you individually is it not now feasible to reinject this used gas from these, two fields, so that excess gas would not go through an emergency flaring. Mr. Giles: l'm PAr, Giles, back into the formation from which it was produced? Mr. Gilbreth: `Yes. Mr, Giles: It would not do for the same reasons presented. at those earlier hear'sngs, Primarily the contrast in mobility ratio, which would just eat us alive, compared to the better mobility ratio between water and oil. -34- Mr. Gilbreth: ~eferrinq to the P~iidd9e Ground Shoa9, particu9ar9y the A Pool ! believe thafi there is a gas zone in the A poo9, a free gas zone, is it not feasible to reinject into this? Mr, Bates: ! believe this is Bates with regard to your point, if ! remember- right, it would about 3000 or 3200 psi to inject gas into this pool in our area. f~lr, Bates: 4~lh`i•1•e ^~lr, Giles is fihinking ! guess, !'l9 answer first of a99 in context with his answer about injecting in the producing formations, We would have the same mobility ratio problems. in addition we have been water flooding ~tidd9e Ground Shoal and we have not reduced bottom ho9e pressure to that great of an extent. ~rle' re replacing produced f l ui ds w i th water- an d maintaining the reservoir above the bubb9e po'snt, Therefore we do not have a situation where weere asking toreduce the injection pressure for nafiura9 gas i n the reservoir, Per. Giibreth: But would it, would it not be feasible to install injection equipment to do this? Mr, Bates: ! believe that depends upon the definition, of the term feasible, 9t could be done. it would be from our view point it ~~rould nct be a very safe operation, we would have to put in 5000 ~ psi gas injection equipment, large, ;aeavy equipment, on the platform, we don't have space for, Yes, we could make space and spend millions of dollars to revamp the platform metering it economi- cally unproductive, Mr. Giles: We would concur it would not be economical9y feasible at this point, -35- • • Sir. Gilbreth: Just for the record, the flow diagrams that we:had on the gas sales or gas production stream on the Lion to go from the platform to the shore and Plant. 1 believe that there is a gas handling either of you see any possible equipment fai9~ down-handling about what we talked about here Dossed. sales repo rt, shows the p roduc- through the line to the Collier facility operated by Union. Do ire there that would result in today, ! think that had bee;; d i s- ~4r. Giles: Not knowing much about much about Uni.on's system fror; the sales meter to the Collier Plant I am not at liberty to know this> 1 wouldn't suspect there would b2, but I don't really know for sure. t~ir. Gi Ibreth: l just wondered i f we covered the possibi 1 ides of failures here, we talked about platform failures, line failures and Colleen's turnaround. Mfr, Giles: 1 think if we're operating under the objectives we've talked about today, then we would notify, or Union would notify, you before 96 hours had elasped, that they were going to be down fora longer period of time and present the problem they haoBe to you and you'd have the administrative decision to allow it or not allow it. PAr. Gilbreth: Union has no obligation to us, to the Conservation Committee, its only the prod9,~cers. "~~r> G i I tis : Therefore we woo ! d notify yo+a . Mr. Bates:. A9 right, that would be the situation, but again if Union ~rrere down for more than !5 days depending on the case you'd have the authority to admin- istratively anew os to flare or call a hearing under the !b day plan, Mr, Burrell: Gentlemen, one other prevision to the proposed order on the west side fields is also concerned with yours and ! should cal! your attenfiion to -3E- ~ • it and that's the reportment requirement, In the event there is any flaring of operational necessity during the month, any at ail for operational necessities distinguished from emergencies, would require be reported within a month after the end of the month in which it happened, especially by location of the flare. Was it onshor® or on the platform and why, the location and nature of the cpera- tional necessity and number of days or hours duration. Pardon me? quarterly, Mr. Giles: Good, much better. `7r, Gilbreth: The volume would still have to be reported monthly on your review report, but the explanation would just come once a quarter, Mr, Giles; That's much better, Mr. Burrell: l've haven't seen fihe last draft, obviously, Mr. >3ates: Well, you know we're at a little bit ~f a handicap, because you9ve looked at it 37 times, and we have not yet sewn it, Mr. Gilbreth: l^till you would see no objection to that type of a inclusion Mr, '? No, ~~ir. Gilbreth: That's all the questions l have. Mr, ~~~arsahl9: l have ona question of Mr. McMahon -Tom Marshall speaking The turnaround time that your talking about something in the nature of how many days? Mr. McMahon: Usually a month Mr, Marshall: Usually 30 days. is most of this time taken up in the inspec- tion or is it taken up in securing replacement of darts or services, l°m just thinking that the chemical process industry in Alaska is very very new and l would just thinking of the mechanical problem of the time .involved in securing the replacement parts that your inspection indicate do need replacement, could be considerable for some of the parts you°re talking about. l suppose they don't lend -37- themselves readily to come up or an airBine, could you just give a Bittle Bight on that please sir. tilr, Mcl~~~ahon : Our turnaround i s usua l l y very thorough l y p Banned operation and we have all of the parts on hand that we can possibly preconceive that we would need, We can get into the condition when we encounter the unanticipated, where a piece of machinery has a metaBlurgical faiBura that we're not prepared for and we haven't gotten the spares in, Bn this one, in the, that we just completed in dune and duly, we reaBly didn't encounter any of the Iona term deliveries that delayed the start-up, leaf it is not inconcei~vaBjl>e thafi it could happen. The one that B mentioned when i was speaking earlier where we had been down for 8 weeks, we did encounter just such a thing, where we found a hydrogen enbrittBement of the very thick forging, We had to remove one and get a new parfi forged and charter a airplane to get it up here and that kind or' thing, That took us eight weeks. That could happen, it could happen next year, we'd tried to ferret them all out, but because of the complexity of the system, the fact we're cutting a tight rope along metalurgicaB and machinery new horizons, B'd say, we cannot always foresee that that kind of thing may not happen, ~Ar, Marshall: Thank you, h1 r, Burrell: B believe that one of you testified that you attempted to schedule your platform turnaround, compressors or whatever it may be, with the Gollier turnaround. f~-, Giles: 6Ve both testified to that point sir. Mr, BurrelB: That of course would be to your advantage with a l5 day order limit, wouldn't it? Nlr. ? Plo, not necessari ly. Mr, Gi lbreth: f~1r. McP•lahon, how far in advance do you schedule these -38- C~ C~ turnarounds and do you notify the operator, how much notice do you give the operator? ~1r. McMahon: Vle try to schedule them a year in advance, We're saying right now we're scheduling our turnaround for next year and the first week- end after Labor Dail and that we would foresee a four week outage at that time. Mr, Giibreth: I see. Mr. McMahon: And our communication with the operators, we°re dealing exclusively with l)nion Oi! Company and they in turn with the operator and we give them as much notice as we can. For, Giibreth: And do the operators have ail the notice they need to try to do any of their own srhedu~6.lnq to coincide with the plant turnaround. Mr, Giles: Ol yes if they do what they just said, why it would be fine, i expect they will. Mr, Giibreth: Well, is that, is it working in practice"? "9r® Mc~~lahon: 4~1e must do this, obviously because of our own Head to get materials if we're looking at a compressor or some comp9ex part like that sometimes we need !0 months leave time for the manufacturer to deliver them. Mr, Giibreth: Weil, the reason 3 asked is the Conservation Committee be- came aware of this Friday before you were scheduled for turnaround on PAonday or' this year and there is an obvious violation or would have been if it had not have emergency because no flaring could be permitted under the exist- ing order and i just wondered if the operators were getting this kind of notice or some other way, P~1r, Burrell: Let'me ask Mr, Giles and Mr, Bates a question, Can the gas -From ~liddie Ground Shoa! or Granite Point or both, casir~ghead gas can it be used i n the Swanson, River F i e °r d for pressure i zat i on, i n the ei>ent that the -39_ • • Coiner P4ant is not avaiiab4e for fihis ~ue3 source or as the suppiier, o^ as the market, Nir. Gi i es; Rio. ~~ot w i thout a e~re~+t dea 4 0~ expense co>> 9 t i t be done, no. N1r, Burre 9 ~ : ~ n other words what i s urt-an~ w 4th i t? ~ s i t °, oo hea°~y? . ~~r, Ci 9es; No, 4t's crude o4 4 pressa.~re and ~r~e've a9 ready testi•~ied at previous hear4n~s or, the ryas ~9are situation several times over that, probably vri 4 9 not e~,~er receive a pay oat o-f the 4nvestment out into this system al- ready and to compound that w4th added investment to accomp4ish somethi~;~ e4se would just compound our situation in reverse ef~`ect, a negative e"F~ect. i~ir, ~3urrei 4a + j~,~st want~:d to hear it. Goes anybody in the au~d4ence have any ~~stions o~ any o¢ the w4tnesses or the ~ommitte= or anybcd~/? An'~r- body "~ i ke tc make a statement? 611e ~ 9 4 ad jo~r7`1 th®z;. Thank °~ou, -4C- ~~ Union Oil and G~ 'vision: Western Region Union Oil Com .~ ~ ~f California 909 W. 9th Avenue, Anchorage, Alaska 99501 Telephone: (907) 279-7681 ~9~L~J'o October 6 , 1' 917L~2 ~~~~~ ~ 6 3 "Fi ' ~ State of Alaska Oil & Gas Conservation Committee 3001 Porcupine Drive Anchorage, Alaska 99504 Re: CONSERVATION ORDERS 103 A and 104 A ----, .._ ~GEOL G ENG 1 ENG ~;` 2 ENG 3 ENG 4 ENG _ _...._ 5 ENG ~ ~Ea~- 2 GEOL 3 GEOL REV DRAFT SEC CONFER: FILE: ~~~ ~. Application of Extension Gentlemen: Reference is made to Conservation Orders affecting the flaring of casinghead gas in Cook Inlet, State of Alaska in requiring such flaring ceased by October 15, 1972. Operators and affected parties have made a bona fide attempt to comply with the above mentioned Conservation Orders. Pipelines have been constructed for the delivery of casinghead gas. to onshore facilities and this. pipeline and. related facilities. and equipment are near completion. Several major components for the 10" and 16" gas pipelines and facilities from East Foreland to the Nikiski Area were up to six weeks late arriving in Alaska due to manufacturing and shipping difficulties. Fifteen valves critical to the final in~ stallation of the two pipeline systems were approximately three months late- arriving in late-September. The late shipment caused several days delay in final pressure testing and clean- ing of these pipelines. The gear operators, shipped separately and needed fn order to open and close these valves, arrived in late September and.-were discovered to be the wrong size. The manufacturer was immediately notified and instructed to expedite delivery on two correct size operators and air freight them to Alaska.. In addition, all available sources of these operators. have been investigated.. At the present time, a .date of October 9 or 10 is the earliest possible shipment to Alaska (from St. Louis, Mo.) . Efforts are continuing in an attempt to improve de-- livery, .Several days of purging the pipelines with natural gas will be required in }4 W • ~ - - .~ State of Alaska 2 October 6, 1972 Oil & Gas Conservation Committee Application of Extension, Conservation Orders order to reduce water content of the gas to market specifications, thus meeting the October 15 "no flare" deadline will not be possible. Due to circumstances beyond the control of the parties constructing. said pipelines, certain items of vital, indispensable equipment are not presently available and is contemplated that this lack of availability of required. equipment will delay opera- tion of said pipeline beyond the date of October 15, 1972. Additional documenta- tion of this fact is available if required. Application is hereby made for an extension of the implementation of the no flare order previously ordered for October I5, 1972, to be extended to November 1, 1972. It is the intention of the operators. and the affected parties to comply with the above referred to Conservation Orders as soon as equipment now lacking has been installed and construction completed on said pipeline. In the event the line becomes opera- tional before the requested extension date of November 1, 1972, the line will be put into operation at the earliest possible date. Should your committee require any additional information or evidence to process this application for extension, we will make such information available on notice. Your Committee will be notified when said pipelines go into operation. Very truly yours , UNION OIL COMPANY OF CALIFORNIA ,. .r , _..,.. re .. _ y MARATHON OIL COMPANY 45 ~~ LJ TRADING BAY Fz~Cp HEARL~JG MAY 11, 1972 ATLANTIC RICHFIELD COMPANY TESTIMONY AND EXHIBITS I - y r _ ~. o. ro s - A c.o..~; It -~o i, t~ 9 i• ENGINEERING TESTIMO~ ' ATLANTIC RICHFIELD COMPANY ALASKA OIL AND GAS CONSERVATION COMMITTEE HEARING TRADING BAY FIELD--CONSERVATION ORDER N0. 103 MAY 11, 1972 Atlantic Richfield Company operates Platforms "A" and Spark in the Trading Bay Field. Exhibit l shows the location of these platforms in relation to the other platforms in the field, the outline of the unitized "G" and Hemlock Northeast Oil Pool productive limits, and the Granite Point onshore production facilities. Conservation Order No. 103 applies to the operation of .these platform and requires that effective July 1, 1972, the .. flaring or venting of casinghead gas from the Trading Bay Field is prohibited except for the amount necessary for adequate safety flares and except in emergencies. • Platforms Spark and "A" do not produce enough casinghead gas to meet their combined fuel requirements. Exhibit 2 shows casinghead gas availability and usage for these platforms under a minimum flare condition. The diagram also shows a gas balance between these platforms,, onshore fuel requirements, and an outside makeup fuel gas supply. Equipment is available on the platforms for this type of operation. On Platform "A", some minor changes in piping will be required and an existing dehydrator must be put into operation before gas can be delivered to shore on a rel3,able basis.- We expect Platform "A" to be operating under minimum safety pilot conditions by July 1, 1972. Out- side requirements for fuel are normally met by the purchase of excess casinghead gas from the Mobil-operated Granite Point platform. As I will show later, this source of fuel has been interruptible. Under emergency conditions, a limited amount of fuel is also available from Texaco's Nicolai No. 3 well for Platform "A" or onshore fuel requirements. • Y N • Platform Spark is essentially a totally electric-powered platform and generates its own power. It has two 3500 KW generators driven by 5000 HP Nordberg turbines. At the present time, one generator operating at 95 percent of its peak capacity is providing all platform electric power. The other turbine-driven generator is normally not operated and serves } '~ only as d standby. As shown on the diagram, fuel requirements when oper- ating with one turbine are 1400 MCFPD. Under the conditions shown, only 900 MCFPD of casinghead gas produced on the platform is available for fuel. This means that 500 MCFPD of casinghead gas must come from shore to meet platform fuel requirements. Without an outside fuel supply or when this service is interrupted, there is not sufficient fuel gas for the Nordberg turbine. It then becomes necessary to convert part of our operations to diesel fuel and flare more of the produced casinghead gas. Nordberg turbines on Platform Spark can use either gas or diesel. but they cannot use a com- bination of these fuels. Conversion from one fuel source to another requires a shutdown of approximately four to six hours and causes a substantial risk of turbine damage due to the temperature changes during shutdown and startup. As already indicated, Atlantic Richfield. Company has entered into contracts with Mobil and Union to purchase sufficient casinghead gas from their Granite Point field operations to combine with our gas, production and meet our fuel needs. The contract pressure for, delivery of this gas is 250 psig. Exhibit 3 shows the amount and pressure of this gas delivered to our Granite Point onshore facilities for subsequent use there-and on Platform Spark. The exhibit supports my previous statement that the service has been interrup- tible. Mobil does have equipment on order to provide gas at contract pressure and to help alleviate some of the problems. However,. even with the planned modifications, the interruptibility will not be completely eliminated. To - 3- N N • ensure a dependable fuel gas supply, we are negotiating an exchange of gas with Union and Marathon that will enable us to obtain gas from the pipeline system currently being constructed from the Trading Bay onshore production facilities to the North Kenai area as a backup for the other sources. With this backup supply, we will be able to consistently utilize all excess casinghead gas produced on ~'latforms "A".and Spark as fuel. Curtailment of production to prevent flaring of excess casinghead gas until a reliable supplemental fuel gas source is developed would impose a signif- icant risk on future performance and recovery of wells now producing in this field. This conclusion is primarily based on the performance of wells on Platform Spark following a shutdown due to equipment failure in June,-1971. Exhibit 4 shows rate performance of well S-2 for a period of time prior to • the June, 1971 shutdown and during subsequent attempts to return the well to oil production. Prior to the shutdown, the well produced at an average s rate of about 600 BOPD with a water cut averaging about 45 percent. Its production since the shutdown has been essentially 100. percent water. Other wells also suffered a loss in oil productivity and a corresponding increase in water cut as a result of the shutdown but subsequently recovered. The explanation of this performance may be cross flow in the well bores. The water-wet intervals in producing wells in this reservoir are pxobab.ly more affected by the limited water drive and have a slightly higher pressure than those producing oil. With a shut-in or limited drawdown situation, water could cross flow from the water bearing intervals in the well and cause high water saturations in the oil bearing formation around the well bore. -This would seriously reduce the relatively permeability to oil. Zf any well is lost prematurely in the reservoir, undoubtedly the recovery from the reservoir ..,~ ~~ N _ _r will be adversely affected. _ In summary, I have shown that Platforms "A" and Spark do not produce enough casinghead gas to meet their combined fuel requirements. An outside source of fuel has been obtained, and our flares are often restricted to minimum safety pilots now. However, the outside fuel source is interruptible and a backup supply is needed to be able to consistently comply with. the order. without production curtailment. We expect the pipeline system currently being constructed-from the Trading Bay onshore production facility to the North Kenai area to supply-this needed backup fuel. Since this pipeline cannot be in operation until November 1; X972, we believe the request for the extension of the effective date for prohibiting the flaring or venting of casinghead gas from Trading Bay Field except for the amount . necessary for adequate safety flares and except in emergencies to November 1, 1972, is reasonable. We respectfully request your consideration of this extension. ~ That concludes my direct testimony. Thank you. i• i~ ~~ MONOPOD~~ .~ EXHIBIT I AtlanticRichfieidCc~mpany ~; TRADING BAY FlELD HEARING MAY I I, 1972 LOCATION MAP • PLATFORM "A" SAFETY PILOT 400 Mcf/D FORMATION GAS 1080 Mcf/D ---r FUEL 500 M cf/D PLATFORM SPARK SAFETY PILOT 600 Mcf/D FORMATION GAS 1500 Mcf/ D --~- FUEL 1400 Mcf/D TO SHORE 180 Mcf/D ---~ ~) `i t 1 ,1 ~ AtlanticRichfieldCompany ~; \~ '~ TRADING BAY FIELD HEARING +~ MAY i 1,1972 r ~ PLATFORMS Aand SPARK ~`\ GAS AVAILABILITY \~ ` ~\~ ~ • ~ NIKOLAI WELL N°O-3 it (Limited Emergency Fuel ) 1, ••-- ~~ ,~ I~ ON-SHORE FACILITIES t( 430 Mcf/D ~\ ,ill f 250 Mcf/D ~ 500 Mcf/D ~, __ ---~-F ..- ~~ / GAS FROM ~~ MOBIL-UNION.. ~~ ~ 750 Mcf/D C • .~.,; Ff ~ ~ • JwHUARY [[pRUARY MARCH APRIL MAY JUN[ JULY AUOU¢T BHPT[MB[R OCTOp¢R NOVEMtl[R DEC[NaCR s ota r . . 4d0~ to s _ a le e t IO In to [a le zo a 2n a 10 16 [O Ha a O t6 t0 a I D a za o Is z 2e B I o as n m zo z n I n o m ~ I n :+ - ..-~' . ~ ~ ~ l. . ' I ..: ~ ~ .. ~ , , ~ .. ~ ~ ~_.. _ ~ ~....c __ I ~ Ql:` ! .1_, i ..G: I~f I I i L;: it '.,.I I I 1 1 i .I L..;I I i .'. I I I .I',' :I i 1 I~ C 1 lip ,l' 'I i :f' I' 1 I ..L j ~( _L I I L_ ~ I ~ i~! I I I I! _L_ ~_ I !~ i to a o Je a ~o le zo ze a w In zo zn. a to le ao za a ro Is zo za a w la zo za a to la zo zn s w la zo a a to In zo za n to In zo ze to Is zo zs. a le zo zn. JANUARY f¢BRU~RY ARCH APRIL MAY :JUNE JULY AUOUBT aEPTEMBEW OCTOBER NOVEMtlER DECEMBER A~~f~~~/!"P OF PUBLITION STATE OF ALASKA, ) THIRD JUDICIAL DISTRICT,) ss. .....1'~ar.~.. L. Shake. - •-- • .............. being first duly sworn on oath she deposes and says that. ............... is the... Le~;al-Clerk--._- pf the Anchorage News, a daily news- paper. That said newspaper has been approved as a legal news- paper by the Third Judicial Court, Anchorage, Alaska, and it is now and has been published in the English language continually as a daily newspaper in Anchorage, Alaska, and it is now and during alt of said time was printed in an office maintained at the aforesaid place of publication of said news- paper. That the annexed is a true copy of a ..regal----,'---Notice 1930 as it was published in regular issues (and not in supplemental form) of seid newspaper for. a period of ..-.-one-..,-, insertions, commencing on the .14.... day of .., Af;z'7.~.........., ,i9 ?.~. ,and ending on the......14........ day of of "aril .................. 19...2., both. dates inclusive, and that such newspaper was regularly distributed to its subscribers dur- ing all of said period. That the full amount of the fee charged .for the foregoing publication is the sum of $ 12•5C which amount has been paid in full at the rate of 25~ per line; Mini- mum charge $7.50. ~ ~ ,~. ~.- /.~~~ ~r~,~~_ ~;~ Subscribed and sworn to before me this .14:.. day of. hpri.l......., 19.x2.. w.~ h« «.yw. Jib~.a e I NOTICE OF PUBLIC NEARING STATE OF ALASKA DEPARTMENT OF NATURAL RESOURCES Alaska Oil and Gas Conserrafian Committee Conservation File Nos. 102, 103, 104 and /a~ ~ 103 s 'e^ ' E O ~ s C 'L ~~~ Ra: The application of Union Oil Company of California, Atlantis Richfield Com- '~ v - pany, Shell Oil Company, end Amoco , i Production Company for orders amend- .t J > >'+ ing Rule No. 2 of Conservation Order Nos. 102, 103, 104 and 103 by delet- Ing the date "July 1, 1972" and :ub- stituting in its place the date "Novem- ' ber 1, 1972.' Notice is hereby given that the rder- enced companies have requested the Oil and Gas Conservation Committee to issue orders ;which extend the Deriod of time from July 1, 1972 to November 1, 1972, during which eesinghead oas in addition to the amount necessary for safety can bs flared from tiie ail pools identified in the refer- enced conservafion orders covering the fob lowing fields: Granite Point, TradinD Say, - McArthur Rive:, and Middle Ground Shod. The hearing will 6e held at 9:00 a.m., May 11, 1972, in the City Council Cham- bars of the Z.J. Loussac library, 5th Ave• !nue and F Street, Anchorage, Alaska, at which time operatort of the identified oil pools and affected and interested parties, will be heard. Thomas R. Marshall, Jr. Executive Secretary Alaska Oil and Gas Conservation Committee 3001 Porcupine Drive Anchorage, Alaska 99504 ] Publish: April 14, 1972 ~ land Notice No. 1930 ^t i NOTICE OF PUBLIC HEARING STATE OF ALASKA DEPARTMENT OF NATURAL RESOURCES Alaska Oil and Gas Conservation Cemmittea ' Conservation Fib Noa. 102, }03, 104 end 103 Re: The application of Unien Oil Company of California, Atlantic Richfield Cem- pang, Shell Oil Company, and Amoco Production fompany far arden amend• ing Rule No. 2 of Conservatien Order ~~ Nos. 102, 103, 104 and 105 by delete ing the date "July 1, 1972" and sub- stituting in its place the data "Novem- ber 1, 1972.' Notice is hereby given that the refer- enced companies have requested the Oil and Gas Conservation Committee to issue erden which extend tha period df time from July 1, 1972 to November 1, 1972, during which tasinghead gas in addition to the amount necessary for safety can be flared from the oil pools identified in the rater- anted conservation orders covering tha fol• lowing fields: Granite Point, Trading lay, McArthur River, and Middle Ground Sheai. The hearing will ba held et :9:00 •.m., May 11, 1972, in the City Council Cham- bers of the Z.J. loussac Library; 6th Ava- nue and F Street, Anchorage, Alaska, at ' which time operators of the identifbd oil pools and affected'arid MhnstBd parfiN " wilt be heard. Thomas R. Marshall, Jr. Executive Secretary Alaska Oil snd Gaa Comervafien Committee 3001 Porcupine Dr{ve Anchorage,-Alaska 99504 Publish: April 14, 1972 = legal Netise No. 1930 w • TRADING BAY FIELD HEARING MAY 11, 1972 ATLANTIC RICHFIELD COMPANY EXHIBITS C '~ ~~ 3- 1~ C.U. /0 3 -~ 1 0 i~ - • ~~ MONOPOD EXHIBIT I AtlanticRichfieldCornpany TRADING BAY FlELD HEARING MAY l I, 1972 LOCATION MAP C. o. io 3- O C-~, ~ < Ca~• '1 • PLATFORM ~~A~~ SAFETY PILOT 400 Mcf/D FORMATION GAS 1080 Mcf/D r FUEL 500 Mcf/D • TO SHORE 180 Mcf/D -~ \~ 1~ -~ I` ~, ~y ~ ~l NIKOLAI WELL N°O-3 jp (Limited Emergency Fuel ) ~~ .~-' I1 i, -, .. ON-SNORE FACILITIES PLATFORM SPARK ~~ 430iNcf/o ~~ SAFETY PILOT ~~ `f 250 Mcf/D . 600 Mcf/D FORMATION GAS ~ ' mm 1500 Mcf/D ~ 500 Mcf/D /- ~ ~1 h 1 ~ GAS FROM ~~ MOBIL-UNION. ^ FUEL ~~ ~ 754 Mcf/D 1400 Mcf/D (i `I 1` 41 • • r ~^ 1 ARCM R APR L _ MAY JUN[ b J 1 -_ r UwRY f[bR ARY E UlY AUGUST bEPTFMRER OCTOBER NOVt'MRRR OCCFMBER [6 p ~ 1 4~0. b ~ EO SO b I b ] ED [ 1 EO 3 O b 2 ~ - 10 E IIO Eb b 10 IS YO 2b b )O Ib 2O Ef b 10 t6 20 E9 3 10 A [O 2S b O 1 10 rrI t ..._ '__.~. ._I.= ~ ~ r ~ - ~ 1 EO [b_ 110 Ip EO YO _ ~. ~ .. ( ]3 I r - I_ ~^'Tl- ~ soon -i-- 1 i ,2000 ... ...~ _ , ~ ~ I ~_. ~_ - . _ r ~ I I :.~._ I .:~ . i ~ ;, j i ~~ ~ .I ~, h I _.. -- I _ _ ~ i ' ~ ~ ~ - - I + _. ~ i .- U loco }~ I i ~ '_ ' ~ I ~ I ~ ~ I i I ~ _ __ _ 1 ' .. ... _ ~ ~ 11 ~ ~ j ~ i s ~. .I I I .-. . ._ ~. ~'.. ~. ~_ .~ -- - _.-~ ~- ~ ~ - - 7- ~ ~ 'I -I- ~ ~_. ~ ~ - _. j. I ~ I - 2(XXJ _ ~ I I I rr I i_ r---- -}-r- ~ -~-_ ~ ~ ,_ _ i ~ r 1.. I ~ ~I ,_ i ~ _ ,, ~ , 1, ; I I ~ ~ I.~ ~ I;, f;i {~ I I _I~ ~ -1 ~_ ~rt_ _ ~ ' ~- ' ;._ ~ C~ _I ~ ~ _~ i I _ I I i ~' ~ , I ; I ~ t ; ~ ~ , ~ T f r r r--- - t50o - --L- - ~ - a ~ ~~~ ~ ~ I ~ I ~~ I . ~' ~ ~ ~ I I I~.~. i ~'. f I i II 1400 --I__ I "_...i. - - I ~ _ T 1-d: ~- ~ ~ I _.,G~POSS ~ ! I i _ I ( I t i _ ~ ~ - ~;' ~ , I ~ I i ~ ~ i {.. _.. _ I ~ 1200 ' ~ ' ~ ~ I j . i ~ ~ -_. ~ ! ~ ~ --r- - _-~--C- 1- ~-+- ~ 1 i I I ~' a m 1000 __~ - k- ~ ~--+ --+--1 I ~ ~ i i ~ I ! ~ ~ ~__I ~, ~~ _ ~ i ~~ I tv I ~ ~ C~ r~ ~ ~ ~ ~~, ~' I ~ i`f i 1 i~ 7 ~- ~~ ~ - -- 100, ~ ~ _ ~ I I,I I I i ~a .~- : ~ I i ~ ~ ~ _ 1 ' ~.~ , ' ' I ~~1 , , i ~' ,r I i I ~ ~ _ P ~ , L i...i ! I I i sa ~ , ~ I I /~ I ~ I ~ ~ r i,~ ~ -~, ~ ~- ~i ~~t{ i i~, ~ 1~ ~ ~ I ~~ - t-t- EXHIGIT 4 \.~f~~-~ .' BOo~° ~ ~ ~ ,~ t { ~ ~ ` ~ ~ .x-~.~_ ~ . ~ ~ ~ ^, ~~1.p ~ I - I i ~ I I , _ ~ ~ ~ I AtlanticRichfioldCtxnpanY O L ~ - .... ~ T ~ ~ k ~ ~ i--r ~ I; i i l ~- TRADING BAY FlELD HEARING 40 V i ' :. I _~::' ~ . __ I I ~__ j ~ ~ ~ r .I '~ : _ _ - /~ I _ I _ ~ I MAY R 1972 200 ~ ~ I ~'>_'~ I I ~ 1 tY ( ~ PRODUCTION HISTORY 1971 _ 20 ,- I , I ; WELL S-2 . . ..: s o b : Ee b o le xn m b 1 e so ao- b to mzo Es a m so Eb to Ib Eo Es b to Ib [o zb a to IO 20 Ea a to le Eo zb b n le so ze u Es 0 I s o f to b 1 + n 10 Is :o. ze JANUARY R[bRUw RY MARCN APRIL 'MAY. JUN[ JULY AVOUbT SEPTEMb[R OCTOOFR N~>vt MRER pEf.f MBfR ~ 4 A~'LASKA CONSERVATION S CIETY ~~ KENAI PENIv`1~I5ULA CHA-P7ER ~'' P. O. BOX 863 ,~. ; o-• , '"'~ ALASKA 99889 . ~ , °~ ~~; ~~ .,~ ~. 4~ Division of Oil and Gas 3001 Porcupine Drive Anchorage, Alaska Ma D 5 ~ ?E3 ~ !'1 !S C O, oivisiorv of oia. ~ »:~ r. _. ; ANCHQ^..` d pIR G. EN6 ~, 1 EnG _~ 4 ENu ~__ 3 FU` I--- -- ( 4 E Ni ~ 5 Er;. ~__ ._, 1 GE7l I.. 2 G€C~L ~ - . -. ,.. 3 GEOL ~__. I REV I bRAFfi^~ ie V -A,10s•A RE: Request for delay on termination of Cook Inlet offshore flaring This organization would oppose a delay in termination of offshore flaring for the following reasons: 1. -Continued flaring provides obvious air pollution which can':be seen from Kenai almost any day as a low-lying cloud of black (the evening of 4/23/72, it looked yellow-greenish) smoke over the Inlet. 2. The flaring of the offshore casinghead gas is a waste of a .resource. 3. The additional wasting of the resource should not be permitted to continue --- lest it make the installation of another .LNG plant or other such type of gas reprocessing for trans-shipment less ` economically feasible. Does not the fact that the proposed plant under consideration by Pacific Electric Service Co. contradict the earlier statements regarding lack of feasibility for the usage of the gas from the offshore platforms? 4. F.ven if it may be essential to extend the deadline, this organization recommends that it be done on a month~to-month basis with the review required-for continuing extensions of an additional month. Z~t~(~d JA ,S E. FISHER Pr sident P. S. The Pipe coating is not bei g accomplished in Alaska for 'the project. Is the lack of the 60-80 jobs involved in the required. ~ipe coating considered b~ this Division in its -:deliberations over the elay in gas flaring termination deadline? ~~ie.e.C'o~`~ ~3 • • PJOTICE OF PUBLIC NEARING STATE OF ALASKA DEPARTMENT OF NATURAL RESOURCES Alaska Oil and Gas Conservation Committee B ~, _.~ Conservation File Nos. 102, 103, 104 and 105 A Re: The application of Union Oil Company of California, Atlantic Richfield Company, Shell 011 Company, and Amoco Production Company for orders amending Rule No. 2 of Conservation Order Nos. 102, 103, 104 and 105 by deleting the date "July I, 1972" and substituting in its place the date "November I, 1972". Notice is hereby given that the referenced companies have requested the pil and Gas Conservation Committee to issue orders which extend the period of time from July (, (972 to November I, 1972, during which casinghead gas in addition to the amount necessary for safety can be flared from the .oil pools identified in the referenced conservation orders covering the following fields; Granite Point, Trading Bay, McArthur River, and ~^iddle Ground Shoal. The hearing wild be held at 9;00 a.m., ~~ay II, 1972, in the City Council Chambers of the Z. J. Loussac Library, 5th Avenue and F Street, Anchorage, Alaska, at which time operators of the identified oil oools and affected and interested parties will he heard. . ~- Thomas R. Marshall, Jr. Executive Secretary Alaska Oil and Gas Conservation Committee 3001 Porcupine Drive Anchorage, Alaska 99504 Publish; April 14, (972 ~'L Union Oil and Ga ion: Western Region Union Oil Company of California 909 W. 9th Avenue, Anchorage, Alaska 99501 Telephone: (907) 279-7681 urn~n Robert T. Anderson .April 7, 1972 District Land Manager Gentlemen: State of Alaska Oil & Gas Conservation Committee 3 001 Porcupine Drive Anchorage, Alaska 99504 Re: CONSERVATION ORDER #103-A STATE OF ALASKA Application of Extension Union Oil Company of California, as Operator of the Trading Bay Field, requests Conservation Order # 103 , Order 2 , be amended by deleting the date "July 1, 1972" and substituting in its place the date "November 1, 1972." Immediately upon issuance of said Conservation Order, Union and Marathon Oil Company jointly proceeded to design and construct a 52 mile pipeline system to deliver excess casinghead gas from the Trading Bay Production Facility West Foreland to the North Kenai Industrial Complex. Barring un- foreseen, adverse circumstances causing delay, the requested amendment will provide sufficient time to complete construction and insure the system is operational thereby allowing compliance with the flare curtailment pro- vision of said Order. In the event it is deemed necessary that a Public Hearing be held in this matter, we respectfully request such hearing be held on May 10, 1972. The 30 day notice period if required for such hearing is hereby waived. All affected working interest owners in the Trading Bay Field have been advised of this request . ju~l~(~l~nM~r} ~~R ~ ~s~z I'~dSIC7,t C~~ Oit AtJD GA5 .~Nt'=~~@ Sam= Very truly yours, ~a Robert T. Anderson ~, RTA/nr ~~ AtlanticRichfieldCompany North An Producing Division ^ Alaska Ex ation & Producing Operations Post Office Box 360 Anchorage, Alaska 99501 Telephone 907 277 5637 Ralph F. Cox Resident Manager April 7, 1972 State of Alaska Oil ~ Gas Conservation Committee 3001 Porcupine Drive Anchorage, Alaska Subject: Application for Extension Conservation Order No. 103 State of Alaska Gentlemen: 1 /\ \/ DIR __ _ ~ -C, E~;G _ ( 7 ENG 2 Fr~G - 3_Ef~G - 4 E~~a I 5 LNG _. ~-o~ ~tFOL s ~ GFC~~ ~ ~~~ ~f2F;€~- 's~~- Atlantic Richfield Company, as an operator in the Trading Bay Field, requests the amendment of Order 2 of Conservation Order No. 103 by deleting the .date "July 1, 1972" and in its place substituting the date "November 1, 1972". Platforms Spark and "A", operated by Atlantic Richfield Company, do not produce enough casinghead gas to meet their combined fuel requirements. A contract has been entered into with Mobil and, Union to purchase sufficient casinghead gas from their Granite Point Field operations to combine with our gas production to meet these fuel needs. This service has been very interruptable although Mobil does have equipment on order to alleviate this problem. When this service is interrupted, it is now necessary to convert part of our operations to diesel fuel and flare part of the produced casinghead gas. To provide a backup gas fuel supply, we are attempting to negotiate an exchange of gas with Union and Marathon that will enable us to obtain gas from the pipeline system currently being constructed from the Trading Bay onshore production facility to the North Kenai area. The requested amendment is expected to provide sufficient time for this system to become oper- ational and allow compliance with the subject order. ~- ~~~ ~ ~ ~ ~~' .~' _~'`'~ 1 Q 1972 ,. - r:;- ~ti. AND GAS ~, • • April 7, 1972 Page 2 In the event the Committee determines a hearing of this matter is required, we request a waiver of the 30-day notice and scheduling of the hearing on May 10, 1972. Very truly yours, :-~''~ ~ Ralph F. Cox RFC/vs ~ "~-~~ CU l~ it V t~ p ~~ ~' ~ ~ 01972 l;~''~'~1; ~3?~! C * ~J!L AND GAS ,p`~.b'"~3(~"A ter.