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Home My WebLink AboutCO 105 A Index Conservation Order lOSA Middle Ground Shoal 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. April 12, 19723 Shell Oil Company re: Extension of Time April 12, 1972 Amoco's request for a hearing to amend CO 105 and 102 April 14, 1972 Notice of Hearing and Affidavit of Publication ----------------- Amoco's Exhibit 1 May 5, 1972 Kenai Peninsula Chapter request for delay on termination of Cook Inlet offshore flaring August 30, 1972 Shell Oil Company re: Extension of Time September 29, 1972 Amoco's re: Extension of Time May 30, 1973 inter-office memo June 5, 1973 inter-office memo September 11, 1973 Transcript of Hearing Conservation Order lOSA STATE OF ALASKA DEPARTP~IENT OF NATURAL RESOURCES D I V I S I OPJ OF O I L AND GAS Alaska Oil and Gas Conservation Committee 3001 Porcupine Drive Anchorage, Alaska 99504 Re: THE APPLICATION OF SHELL OIL ) Conservation Order No. 105-A AND AMOCO PRODUCTION COMPANY for an ) order amending Rule No. 2 of Conser- ) Middle Ground Shoal Field vation Order No. 105 by deleting the ) MGS "A", "~3'", "C", "D", ''E", date °'J m y I, 1972" and substituting ) "F'', and `'G'' O i l Pon I s the date "November I, 1972''. ) June 8, 1972 IT APPEARING THAT: I. The Oil and Gas Conservation Committee published a notice of public hearing in the Anchorage Daily News on April 14, 1972, pursuant to Title II, Alaska Administrative Code, Section 2009. 2. A public hearing was held May II, 1972 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. 105, 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. Gas sale contracts were also executed. 3. All of the foregoing was accomplished with due diligence, but was delayed owing to necessary engineering and design time, seasonal weather conditions, and construction and delivery time of specially-designed equipment. CONCLUSIONS: I. Operators of the referenced pools and affected parties have made a bona fide effort to comply with Conservation Order No. 105, but compliance will be delayed by conditions beyond their control. 2. Compliance with Conservation Order No. 105 can be expected by October 15, 1972. 3. The dates in Rule Nos. 1 and 2 of Conservation Order No. 105 should be changed to the earliest practicable date which is reasonable, but not beyond such date`. i • Conservation Order No. 105-A Page 2 June 8, 1972 NOW, THEREFORE, IT IS ORC~ERE© THAT: I. Rule No. I of Conservation Order PJo. 105 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. M., ApST, October 15, 1972.'' 2. Rule No. 2 of Conservation Order No. 105 is amended to read as follows: "Effective at 7:00 A. M., AD5T, October 15, 1972, the flaring or venting of casinghead gas from the Middle Ground Shoal Field is prohibited, except for the amount necessary for adequate 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 Rule Nos. I and 2 of this order. No such order or orders may extend the date beyond 7:00 A. M., AD ST, PJovember 1, 1972, except pursuant to Title II, Alaska Administrative Code, Section 2012. DONE at Anchorage, Alaska, and dated June 8, 1972. V ~ A oit ~~~ ~'~rd Thomas R. Marsha t I , J r . , Executive ecretary y ~~~ ~ Alaska Oil and Gas Conservation Committee i, ~~"°`'`~~~ ~~ ~~"'~'~~~' Concurrence: O = W . ~. ~~,~ S'M~~' iti~ H er L. Burrell, Chairman r~~N CO~`~ Alaska Oil and Gas Conservation Committee ~ -.~.-.. 0. K. Gi Ibreth, Jr., P1ember Alaska Oil and Gas Conservation Committee X10 • ~ STATE OF ALASKA DEPARTMENT OF NATURAL RESOURCES DIVISION OF OIt_ AND GAS Alaska Oii and Gas Conservation Committee CANSERVATION ORDER I05-C & 102-E Granite Point Field Middle Ground Shoal Field H EAR I N G September II, 1973 P R O C E E D I N G S Per. Burrell: 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,0i1 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 Middle Ground Shoal .field. The operators of these two, these portions of these two. fields are Amoco Production Company, Shell Oil Company, both of whom who have requested this hearing; and since the same question will be involved largely in the facts, presumally the findings of this order, we have consolidated these two hearings, at least for testi- mony purposes. Notice of both hearings are published in the Anchorage Daily News, August 6, 1973 as required by law and regulation. My name is Homer Burr-ell, I'm Chairman of the Committee; to my left is Tom Marshall, Exxcutive Secretary of the Oil and Gas Conservation Committee; to my extreme right at the end of the table is Mr. Gilbreth, 0. K. Gilbreth, who is a member of the Oil and Gas Conservation Committee; to my right is Mr. John .Reader, Assistant Attorney General of the State of Alaska. Unless somebody has something else, I'II ask the applicant or applicants to proceed with their testimony. Mr. Crews: Thank you Mr. Burrell. We have been prepared Mr. Burrell: Would you identify youself? Mr. Crews: I'm Ralph G. Crews, and I represent Amoco Production Company and the Chakacatna group for purposes of this hearing and we had originally requested that the hearings be consolidated but I think you have adequately taken care of that. The purpose of our applying for this hearing on an amended order is to amend a respective conservation order to allow an operator by administrative action without hearing a maximum of 60 days per event per platform within which the operator may flare gas because of an operational necessity and currently there is a 96 hour rule in which you must notify the Commission for downtime or for flaring necessity, and our application would not tamper with that 96 hour regulation. For instance if we had to flare gas under the 96 hour rule, we would notify the Commission, and if it would appear that we would have to go beyond 96 hours, the 60 day time in which we applied for would begin from the first notice on the 96 hour point of time - correction from the downtime start, and we would like to ask the Commission, first I would say PAr. Bart Giles will be Amoco's first witness and we have other witnesses if necessary. Mr. Giles has testified many times before and we would ask that his qualifications for testimony be wai~ed and we also would like to ask the Commission that they with- hold any questions of Mr. Giles until the witness for Shell has testified, be- cause the testimony does in fact complement each other. Of course that is the discretion of the Commission, so as I say P4r. Giles will be Amoco's first witness and we call him now to the witness stand. Mr. Burrell: Unless there is objection, let the record reflect that we accept Mr. Giles qualifications as a expert witness. PJould you swear him in Mr. Marshall? -2- Mr. Marshall: 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 God? Mr. Giles: I do, Mr. Marshall: You may be seated, thank you. Mr.Crews: Would you please state your name? Mr. Giles: R. B. Giles, with Amoco Production Company in Denver. Mr. Crews: What is your occupation with that company? Mr. Giles: I am in an engineering capacity with Amoco in Denver. Mr. Crews: Mr. Giles testimony will be in narrative form unless you have objection. Mr. Burrell: No objections. Mr. Giles: Gentlemen, lets turn to Exhibit I, for Amoco, which has just been handed out, which is a three page list of situations. requiring flaring due to operational necessity. h1 r. Burrell: Excuse me, Mr. Giles, is it possible that there is any way to display this so the public can see any of these exhibits? Mr. Giles: There are only the 8~ by II size Mr. Burrell, so Mr. Burrell: 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. Mr. Giles: Right. Do we have any more copies, why don't we just do that on the table. Mr. 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- Mr. Giles: Not really. Mr. Crews: i rather doubt unless there is some way. Mr. Burrell: I didn't bring any tape, did you? Mr. Giles: Sure didn't. Mr. Giles: Going thru this Amoco Exhibit i, we have listed by Platforms the four platforms and the onshore facility, the various situations that we would have planned or scheduled for inspection of the equipment, the component parts of the gas handling system. The compressors, the dehydration units, the safety shut-in valves on the pipeline, the production vessels, the main power panel on each of the platforms and on the on-shore facility the gas scrubbers that .need inspection periodically. The second column indicates the length of down-time for this periodic inspection and the third column is how often would we need to do this, carry out this inspection and the last column is the estimated gas that would be flared under each of these situations that are listed. Those estimated gas volumes are based on the average gas figures reported to .you, the. State, over the first six months of this year 1973. Now our Exhibit I, is strictly a tabulation of scheduled or planned in- spections of equipment. I kind of liken it to the fact that if you or I were to buy an automobile we get an owners manual and in the back of that manual based upon the recommendation of the car manufacturer, it tells you that, gen- erally that after 4,000 miles or three months, which ever occurs first, you should get your oil changed at the point in time when you have driven 12,000 miles you better get your plugs and points changed, at 36,000 miles you better change the highpoured lubricant in the differential, and this is basically what Table I, or Exhibit ( of ours tells us. It is based upon manufacturers -4- recommendations for the component equipment in the gas handling system as to when we should check it out and inspect it. We have tabulated on that exhibit alt the items we can determine are of a regular or anticipated nature, but it does not include any unplanned situations. For your information we have a back- up of spare parts on hand or parts are readily available to repair essentially any part of the gas handling equipment within a four to six week period. This does not of course include a catastrophic. failure but covers most of the nor-. malty repairable items. Our requested order today covers the need to flare gas during much longer downtime periods, however. An example would be the unusually long plant turn- around that would include a major repair. Now, we're going to have a witness after Shell, from Collier Chemical, who will talk about .plant turn-around, but this requested order of ours and Shell !s would also cover the need for longer periods than the p I armed or scheduled s i tuat i ons, such as underwater,p i,.p~l i r~,e..,.~.....,,. breaks, perish the thought. We've had enough of those but we never know when it could happen again, and on that score I might recite for the record that some of the breaks and the lengths of time on each break, it has taken for us to repair that pipeline break. On the Granite Point B line, which is the gas line from Granite Point to the East Forelands facility, we've had five breaks over the years. In June of 1968, it took 37 days to repair a break, in June of 69 it took 17 days, in June of 1970, June seems to be a favorite month of these breaks, June of 1970, it took 16 days to repair a break, in April. of 1971, 22 days to repair a break and then on December 7, 1971 the line broke but we could not repair it until weft into the following year and the repairs act- ually started the 26 of September 1972 and took until the Ist of December, 1972, -5- which is a repair length of 66 days. 1 think that you'll recall that last November I was here to testify on that particular situation. Now on the Granite Point A line which is the oil line, August 10, 1972, we began a repair that lasted 29 days on that line. On the Middle Ground Shoal Pipelines, on August 7, 1966 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- pair that line. I give you those periods of .time merely to support the request that we're making for 60 days, the maximun of 60 days per event per platform within which to flare gas during operational downtime of equipment. Now since the sale of Amoco's gas to Union Oil Company is entirely, and solely dependent solely and entirely on Collier Chemical using the gas for fuel, a turnaround of the Collier Plant results in a direct effect upor~ Amoco's gas handling operations. Collier plans an annual turn-around each year just to main- tain their equipment in good shape, just like we are doing the same thing by- virtue of all the situations listed on our Exhibit I, for our equipment and every effort will be made by Amoco to coordinate it as much of its maintenance work as possible with the planned Collier turn-around. However, if you look at Amoco's Exhibit I carefully, you'll see a number of situations that can not be handled at that particular time. I'd -ike now to turn to Exhibit 2, which-is a detailed flow schematic of the Amoco operated gas handling systems. On the left side of this Exhibit we show the equipment that is on the platform, each of our four platforms, Bruce Anna, Baker and Dillon, the compressors, the scrubbers, the glycol contactors. This is designed basically to pressure up the gas for transmitting it to shore and to clean up the gas of any water vapor for transmitting the gas on to -6- • shore. In the right hand side of the Exhibit 2 is, shows the components on shore at East Forelands to dry up the gas, take fihe liquids out the heavier hydrocarbons, which are blended with the crude oil and the dry gas as shown just above the right hand corner of this Exhibit 2 goes to sale to Union Oil Company. This particular Exhibit has no direct meaningful purpose for this hearing, I simply offer it into evidence to al ow your staff, Mr. Burrell to have it for what ever use they may see fit internal. It was the design lay- out of the entire system at the time it was installed. I'd like now to cover the next three Exhibits, 3 through 5. They are per- formance curves on one Middle Ground Shoal well and two Granite Point wells to illustrate the adverse effect on oil production caused by the exposure of the formation in the producing well to produced water, whenever such a well is shut- in. I think you'll recall as I certainly do .that at previous hearings on 'gas flaring i was invariably asked by your Committee to present examples of wells where we do see an adverse effect, if a production restriction were imposed to eliminate the need for flaring during such times when all gas cannot be marketed and so in advance of hearing that type of question again, I thought I'd give you three of illustrations today. Exhibit 3 is Middle Ground Shoal Weil No. 11 in the BCD zone. The well was making about 100 barrels of water per day and about 150 barrels of oil per day when the well in the middle of 1971 was shut-in while a compressor was down at that time and we Ic?st the BCD as a producer. it was not economical to repair it and try to get it back to the 150 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 18742 #9 well, that was producing about 300 barrels of oil per day and 100 barrels of water per day, when in -7- August of 1972, the well was shut-in for practically the whole month, 30 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 opin- ion lost an equiivalent of 100 barrels of oil per day, when 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 life of that particular well's producing effort, but the present worth of the future income of course is pract- ically zilch. Exhibit 5 is another well in Granite Point, the ADL:-('8742 #10 well. Again during the time when the well was shut-in for 30 days in August 1972, for that pipeline repair, it had been producing prior-to that time about 400 barrels of oil per day and oh some 40 or 50 barrels of water per day and after being shut- in for a month, the well dropped or never came back. to its former productivity and we figured it suffered about a 140 barrel a day loss. We performed a $50,000 acid job to try to restore productivity of the well back to the 400 barrel a day level, but we were not successful. It never has quite gotten back up to that pre-shut-in level, despite that expense to perform the acid job, so we think this is rather reasonably strong evidence that we do see an effect when we have a well shut down that has been producing water along with its oil. Now there are not many examples available because very few of the wells in the fields produce water at the present time, however the water production can be expected to increase in both fields as they become depleted and this would pose an increasing problem under these situations. The last Exhibit I have is No. 6, which is an economical comparison of the value of gas that would be flared at current rates for the Chakacatna -$- properties in each field, Middle Ground Shoal, South Middle Ground Shoa) and ~ryy ~ ~+.~ Granite Point versus the dollar lost by virtue of pinching back the oil ~`~ duction that would eliminate the need to flare during such times when ail the gas cannot be marketed. We have based this Exhibit on the annual Collier Plant turn-around. I think the significance of Exhibit 6 is shown by comparison to the second column under the value of pinch back oil versus the lower right hand column on Exhibit 6 the .value of gas saved in each field and that sign- ificance is that the value of the pinch back oil production far out-strips the value of the gas that would be saved instead of flared during the plant turn- around. Now, despite this rather obvious conclusion 1 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 operational inspection of equipment or failure. In conclusion 1 would suggest that we continue to report monthly to you any and ail downtimes that exceed 96 hours. This is the present requirement. We believe it should be continued. Again as Mr. Crews had pointed out in his opening remarks, we're asking fora 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 60 days would start when the down- time occured, it would not be tacked on to the 96 hours, we're not asking for 64 days, we're asking for 60 as the maximum...: I've tried to show with Exhibit I that we do have the normal preventive maintenance program for our equipment. Nothing on Exhibit I, except for one situation, the Wurthington Compressor on Baker, would exceed 96 hours as we see it. By annual inspection of the Wurth- ington Compressor on Baker it would be expected to take 10 days every two years, -9- which would be an average of five days a year, but we never know wh~n;we go into inspect equipment whether we might see something unusual or close 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 .call more extensive in length of time situations like pipeline breaks and other matters that serious. I be- lieve that concludes our direct testimony. .Shell wilt put on testimony that I understand will be a slightly different approach to the situation that I have alluded to and if you could bare with me on questions, I think after they are through, why we'd be happy to have both the Sheii witness and myself come back on for any questions you may have, if that's fair enough with you Mr. Burrell. Mr. Burrell: Thank you, Mr. Giles. Would you identify these Exhibits you wish to introduce into the record. Were they prepared under your supervision? Mr. Giles: Yes, they were prepared under my supervision and we'd like to have Exhibits I thorugh 6 put into the record at this hearing. Mr. Burrell: Very good, unless there is some objection we'~I enter these Exhibits I thorugh 6. i would like to suggest we take a break of ten minutes so that any members of the audience may {ook at these Exhibits here and if they're still looking we'll extend the break after that, otherwise. we'll start after ten minutes Mr. Burrell: We'll convene the hearing again at this time. 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 Shell ARCO Standard Group. Mr. Bates is the Division mechan- ical engineer, of the West Coast Division of Shell. Mr. Bates has been before this -10- Committee in the past, most recently in June, this past June, so I would ask that his qualifications, the statement of his qualifications should also be waived, if that's agreeable. ~~~ Mr. Burrell: Unless there is some objection from the ~-1 y, Mr. 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 Mr. Giles and Mr. Bates and their joint input can be tapped by the Committee and also as mentioned before, following Mr. Bates testimony we would like to call Mr. McMahan, Bob McMahan, who is with Collier Chemical to give a little more detail to the run down on the nature of the Collier Plant turn-around. With that, I'II let Mr. Bates take the stand. Mr. Burrell: Thank you mr. Garnet. Mr. Marshall will you swear him in? Mr. Marshall: Will you please raise your right hand. The matter now at hearing, do you swear to tell the truth, the whole truth and nothing but the truth, so help you God? Mr. Bates: i do. As has been stated before. Mr. Marshall: Thank you. Mr. Bates: As has been stated before the purpose of this hea ring request that the operators be allowed a 60 day no flare period during operational necessity periods. At the conclusion of my testimony I will request that an annual, that 60 days of operational necessity downtime per event per platform be granted administratively by the Committee.. As Shell's and SAS group's repre- sentative at this hearing, I will review the flow schematic of shipping the excess casinghead gas from MGS Platform's A&C to the point of :~ta°-eels as fuel gas at Union's Collier Chemical Plant. i ! I will also review our operating experience since start-up of the system in November of 1972 and provide you with information concerning equipment failures and system shutdowns during which time the casinghead gas not used as f uei gas on the platforms, was flared. In addition, 1 will discuss other possible events which could require flaring of casinghead gas. This testimony is intended to present the operations and problems involved with compression of gas on the offshore platforms and its shipment to its final destination. The bene- fits of gas flaring over curtailing of oil production had been presented in previous testimony, most recently in mu testimony on June 21, 1973. I want it to be mentioned at this time. All producing .casinghead gas, which is not;ge- quired for fuel on our platforms and for safety flare, is compressed on each of the Middle Ground Shoal Platforms and shipped via common line to the East Forelands onshore facility. Here the gas is scrubbed of al( liquids which-have dropped out in sub-sea transfer tine, routed through a sales meter and shipped to Union Oil Compahy's Collier plant where this gas is used for fuel. The on- shore system has been shown in detail by Amoco's representative. We have provided Exhibit No. I, which is on the board here showing the general flow schematic of the casinghead gas from the platforms to its usage point at the chemical plant. For convenience I wish to break this system down in four segments and discuss each separately-in regards to its past performance and possible future operating problems. First we have the Platform Compression Facilities, the excess casinghead gas on both Platform A and Platform C, which are the two middle platforms in the flow schematic,. is compressed from 50 psi suction to 250 psi discharge.. pressure, via centrifugal compressor packages located on each platform. The -12- Platform C compressor package has operated satisfactorily since start-up in November of 72, with 97~ availability. I'm using the definition of avail- 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 21, 1973, has experienced serious operating problems and shut-downs with resultant compressor drive shaft failure on May 25. 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 shipping excess casinghead gas to shore. We are continuing to work with our compressor supplier on design modifications to assure that we have continuous operation of the package. Again as shown on Exhibit No. I the four MGS Platforms are connected via dual 8" steel, concrete coated, transfer lines. These lines are lying on the inlet bottom with risers going up the platform legs tying in at each platform.. There are two 8" steel, concrete coated lines traversing from Platform A to'' Shell's operated East Forelands Facility, these two lines here. These lines are used for shipping oil and water emulsions and are not satisfactory for shipping natural gas, as we had provided in previous testimony in 1971. Mr. Gilbreth: Pardon me, would you make that statement again? Mr. 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 context in 1971 at the no-flare hearings. Dual lines connect- ing the four platforms can be the lines shown. horizonally across the schematic are also 8" concrete coated lines. However these lines were designed and are suitable for gas transmission. One of these dual tines is generally used for emulsion shipping while the other is used for natural gas shipping. -13- ~, J There are also two 8" steel, concrete coated pipelines traversing from Amoco's Platform Dillon to the Amoco operated East Forelands Onshore Facility. One of these two line in the south area, these two lines here,is used to ship natural gas to the beach, the other line is used to ship oil and water from Amoco's Platform Dillon to the facilities. The third segment, the first two being .the Platform Facilities and Trans- fer 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 the gas utilization point. Tthe gas is sold through a sales meter and then routed via one 10" steel coated and wrapped buried gas line about four miles to Collier Chemical Plant. We'll now review our operating history as the SAS platforms in Middle Ground Shoal. During the brief ten months of operating history during. which time the Ido Flare Order has been effective, the system or portions of the sys- tem have been shut down with resultant gas flaring for the following reasons. I will present Exhibit 2 to generally outline these periods. This is a continuation of the Exhibit we presented in June again. Flaring of all excess casinghead gas occured as a result of shutdown of Collier Plant during the period of June 22 to July 14. We understand this shutdown was an annual shutdown complicated somewhat by an accident on one of the process vessels. We also understand the period=of approximately four weeks neces- hating complete plant shutdown will be required on an annual basis. During this period it will be an operational necessity to flare all 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 26, 1973 resulted in 63 days of downtime with resultant flaring of Platform A casing- head gas. The compressor failure occured as a result of an original inherent compressor problem and cannot be considered routine operational downtime. These problems were covered in detail in our June 21 testimony at which time the committee granted a temporarary exception to the No Flare Order for Plat- form A. Exhibit 2, generally is a documentation of the compressor on Platform A's operating history. Some other extended periods of downtime on compressor Platform A occurred in the period prior to May 26. 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 have operated satisfactorily without extended downtime to date. For convenience, I will again follow the portions of the casinghead gss system and discuss some of the potential downtimes which could occur due to operational necessity. On the platform compression facilities, our limited experience with our compression units to date, we cannot predict .the amount of downtime we would have with high accuracy. However, we believe that each compressor package wili- require a major overhau I every 20,000 operating hours,. or every two to three years. These overhauls require approximately two weeks of downtime. We keep an extensive stock of spare parts for the compressor packages on the platforms to minimize downtime due to equipment failure, however, it is still possible that unexpected failure of major compressor component parts which are not locally stocked could cause delays of severe! days to several weeks. -15- i ~ Subsea gas shipping lines are now used for shipping, that we now use for shipping were installed in years 1965, 66 and 67. We had two line failures at Platform A in the feg risers in 1966. However the lines connecting: the four Fiat forms have not experienced any failures to date. On the dual oil shipping lines from MGS Platform A to the Onshore Facility we have experienced two failures, one in 1967 and one in 1968. The two south Middle Ground shoal lines required preven- tive 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 the Cook Inlet environment line failures cannot be guaranteed against. Pipe- line repair could take approximately 2-4 weeks, under the best of conditions,. to as much as several months under the worst of conditions. I 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 year. This is an approximate number. These will require complete plant shutdowns with resultant gas flaring expected annually. Generally speaking the downtime of platform canpression facilities will affect only that platform's excess casinghead gas. However, any problems occur- inng in the pipeline or downstream facilities wilt affect all excess casinghead gas produced upstream from the problem area. We plan to schedule ail 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 of unplanned break downs. I'd like to provide you with some information as to the time required to repair a major unexpected equipment failure. I'fl review chronological events of repairing the Platform A compressor after its failure on May 25, 1973. The time of the failure was 10 p.m., Friday May 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 supp{ier engineers on Wednesday May 30, to formulate plans for getting the unit back in operation. The unit was completely disassembled during the period from June i to June 3, this was the compressor disassembly, by factory mechanics from York and Solar. Com- pressor rotati-~ was shipped via air freight to York's factory at hack, Pa. Upon arrival.at the factory it was further disassembled and completely rebuilt. Since these compressors were specifically custom built for the job, off-the- shelf items were not available for repair. Parts were machined as required working on an overtime schedule, and work was completed on the rotating element on July 9 The element was then shipped to Alaska via air freight on July 10. During 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 Diego for complete disassembly balance check, and the repairs were made to the seals and the bearings in the unit. It was also returned to Alaska. The compressor rotating element and gear box arrived on platform on July 13. The compressor was reassembled by factory mechanics and completed on July 18. On July 19 and 2t, 19 through the 21, start up performance test was conducted by Solar and Shell. During the startup test, shaft deflection 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 reassembi~ the equipment. delay or even loss of production at Middle ground Shoal is possible if we curtail production or shutin wells. We provided data to demonstrate this in our March 4, 1971, and June 21, (973 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. We 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 BTU value and the dollar value of the oil is considerably higher than that of the associated gas production as we have shown previously. We do recognize an operating income from the sales 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,'~het we wilt not have casinghead gas for sale after 1982. We will then use this..... gas for fuel and will be required to p rovide an outside source of gas. -18- In summary we recommend that Order No. 105 be amended such that the Com- mittee can administratively grant the operator up to 60 days per event per plat- form of excess casinahead 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 96 hours shutdown period has elasped as now available in Order No. 105. Reporting 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, gas flared on individual platforms. That is we are not distinguishing 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 malfunctions as experienced with our past compressor breakdowns or pipe- line leaks. Gentlemen, this concludes my testimony on this matter. Mr. Burrell: Thank you, Mr. Bates. 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 I and 2? Mr. Bates: Yes sir. Mr. Burrell: Thank you, Shell's Exhibits I and 2. Mr. Bates, Mr. Marshall wants to know if you have any small copies? Mr. Bates: Yes i do. Mr. Burrel Are they identical to the large ones? Mr. Bates: Yes they are, I have a couple copies I believe. -i9- • Mr. Burrell: We would like to have those for the record then, rather than the large one, they would be very difficult to file tthose. Mr. Bates: I do to. Mr. Garnet: Mr. 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. McMahan present his testimony first. Mr. Burrell: I think we'll just ask Mr. McMahon to testify, to get the whole thing done at once. I will ask one thing, in fact this also applies to Mr. McMahan do you have, those of you who have testified, do you have a written copy of your oral testimony, or something typed there is a great help to our girls who type it? Mr. Garnet: Alright at this time I'll ask Mr. McMahon to come to the witness chair. Mr. Chairman i don't believe P~Ir. McP~an has been before th i s Committee, i f t'm not mistaken, so 1 will ask him to run through briefly his position, his educa- tional qualifications, his experience with the matters .that we're discussing. Mr. Burrell: Could we also have his first name and spelling. Mr. Garnet: Certainly. Mr. McMahon: My name is Robert 0. McMahon. Mr. Burrell: Thank you. Mr. McMahon: My current position is the Plant Manager at the Collier Carbon and Chemical Corporation Plant in Kenai. I'm a chemical engineer, graduate of the University of British Columbia in 195Q. In the 23 years since graduation I've been employed in various engineering capacities in the oil and chemical industry both with the Mobil Oil Company and the Union Collier group. Far the past two years 1 have been the manager of the Collier Facility in Kenai. -20- C~ • Mr. Burrell: Does anybody have any questions #or McMahon, unless there is an objection, we'll accept his qualifications as an expert witness. i'Il ask Mr. Marshall to swear him in. Mr. Marshall: Please stand. 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 God? Mr. McMahon: I do. Mr. Marshall: Please be seated. Mr. Garrtot: Mr:~MeMahon, why don't you just proceed to tell the Committee what you have to say about the nature of the Collier operation, in particular the annual turn-around procedure that has been discussed so tar. Mr. McMahon: Let me say first, that I do not have written data in support of what I say, I wilt define the turn-around situation of what we do and wtll be happy to answer any questions that you might have. The term turn-around, just for definition is the synonym for overhaul period or maintenance repair period, or what have you, and it is something we must. do once a year to comply 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, °rep~ace catalysts that may be exhausted, to replace defective metailury and so forth. We hope normally to accomplish all of these , efforts, in our current program, in about a three week period, but because of unanticipated difficulties we allow four weeks and in the last two years, four weeks has been standard. Historically, because the plant has been, although not entirely p rototype, somewhat developmental, we have run into problems that have sometimes run somewhat longer than four weeks. On one occasion because of -21- a severe problem with a metallurgical casting we were down for .eight weeks during the course of the turnaround. We feel however, we have set most of those major problems aside, then we'd hope to meet the four week annual turnaround that we have now established. Our target for overall on-stream efficiency fora plant of this complexity is about 90~ overall stream efficiency. W~ look at about four weeks outage on this one major turnaround in which we would hope to accomplish everything necessary to permit us to run the remainder of the year continuously. But we do reserve the possibility of one other interruption during the course of the year and again because of the complexity of the equipment we visualize that it too would last about one week. So our over ail operating efficiency then wbu~id be about 90~ with a four week outage on schedule 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. In summary gentlemen I would say that is about the way we approach our main- tenance and operating philosophy. Mr. Garnet: Thank you Mr. McMahon. Mr. Burrell: Thank you Mr. McMahon. I think at this time we are ready for questions. I'm sure we will have some. Mr. Gilbreth, would you like to start with the questions? Mr. Gilbreth: Yes, I'd like to start back with R1r. Giles. Mr. Giles in the earlier part of your testimony you mentioned several line breaks, I figured it was one or two were oil lines, were all of the breaks that-you recited, actually was that oil line breaks or were there some other breaks in the gas line, those carrying gas. -22- u Mr. Giles: There were five breaks in the Granite Point B line which is a gas line, that were repaired. There was one in an oil line in the Granite Point A line and there was one in the line between Baker B line between Baker and Shell A, which would be essentially be a gas line. Mr. Gilbreth: On your Exhibit 5, Mr. Giles, looking at the oil production curve and the water production curve, it appears that after the shutdown that you have recited that the productivity of the well itself determined by total fluids was considerably reduced. Mr. Giles: considerably Mr. Gilbreth: reduced, and then your Exhibit shows that a $50,000,acid job was required to restore the productivity. inuring the interim between the acid job and the time the well was shutdown, did, have you eliminated the possib- ilities of problems with the producing equipment itself, with the equipment of this nature. In other words do you think this reduction is entirely and con- elusively due to reservoir capacity to produce? Mr. Giles:. Weil the acid job was to clean, basically to clean the scale from subs rvice equipment, it was not in of a~ imagination an acidrack job, so we still believe that this lends .pretty strong evidence. That we aet an adverse effect from exposure to this produced water on the formation face. We don't know all the answers to this question, but we are concerned as we will be producing more and more water with time and more and more wells can be expected to be effected, no matter what the reason for shutdown. M11r. Gilbreth: I noticed in ail of the curves that you did present here, that welts were making considerable quantities of water, anywhere from (,000 barrels a day. -23- Mr. Giles: No, you'll have to go to the right hand side of the graph .for the water. Mr. Giibreth: I'm sorry, okay. I was reading the curve wrong. Mr. Giles: Yes, the left hand side, that's the oil rigs and the right hand side the water. Mr. Giibreth: Yes. On your Exhibit 6, I believe your testimony was that this was indicative of the values of oil and gas during the period of shutdown or turnaround. For what period of time was this calculated? Mr. Giles: This was calculated on a five weeks basis. Now if you qo to Mr. McMahon's customary four week turnaround, that he states is customary, why ,just take 4/5 of all the values. but the values will remain in relation to one another. Mr. Giibreth: in your recitation of downtime that has occured from your propert es in the Granite Point.. and Middle Ground Shoals, your exhibit shows a'ten day bi-annual inspection on one of the platforms. Have you had any equip- ment downtime other than line breaks that exceed the ten days. Have you had any long equipment failures on any of your platforms? Mr. Giles: I don't recall that we have, no. Mr. Gilb reth: 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 into it on these annual inspections, I think we're going to learn that metallurigical failures are about to occur and we're going to encounter problems. that here-fore we heve`not had, which will lengthen the downtime requirement. -24- Mr. Gilbreth: Well hopefully the<inspections will preclude that. On your exhibit No. 2, as i read the Exhibit, all the gas produced from the Baker, Shel l Sheii~`~, and t)illon, all goes through a common line to Platform Dillon and then cfoseto shore. Mr. Giles: Yes. Mr. Gilbreth: Is that right. There's no gas going to shore from, directly from Baker or Shell A. Mr. Giles: No. Mr. Gilbreth: The existing lines. Mr. Giles: No, those lines cannot do that. Mr. Gilbreth: I'd like to ask Mr. Bates, you mentioned .the problems that you'd had with your Shell A Platform compressor, indicated it's operating now below 94~ of a design rated speed, what about your platform? Mr. Bates: It's still operating, it's below 90, I believe it's about 85 o r 86~, has a fdlk capacity to flare gas at that rate. Mr. Gilbreth: Okay, with :both platforms operating in this range, are you able to stiff! move ati the produced gas to shore, all except what is necessary for emergency purposes. Mr. Bates: Yes sir. Mr. Gilbreth: In yoar testimony Mr. Bates, you indicated that the failure of the compressor on Platform A had required about 64 days, at least you flared gas for 64 days, if 1 understood. Mr. Bates: I believe it was 63. Mr. Gilbreth: 63, airtight. Now the order that you have requested here then would in fact not let you produce those last three days, would it not. -25- r•~ ~~ Mr. Bates: This breakdown was of an even more non-routine nature I guess you would say than a normal breakdown. I mentioned there were 50 days required for shipping rebuilding and reabsembly, the other 13 days were consumed at the beginning, 3 or 4 days of engineering and at the end hooking up of ail the safety devices and running performance tests, indeed work we had done at York, Pa. had corrected.th's vibrator problem we had. So a procedure similar I would expect take on the order at 45 to 50 days between here and back on the line. Mr. Gilbreth: The reason I'm asking this question, Mt. Mc Mahon 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 I'm wondering if the reason for you're requesting the 60 days was because of°the Platform A type occurrence or why the 60 days. It wouldn't fit into Platform A and yet it is considerable longer than the normal that you'd=expect. Mr. Bates: I feel generally that the ma,~or abnormal types of equipment breakdown or line break could be repaired within 60 days, 30 days is too short --- Can't understand --- ) t feel the order of magnitude of two months is ample time to repair most failures or correct most operative problems that have arose. Mr. Gilbreth: 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? Mr. 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 -~6- take 62 days or something. it is very hard to pin down the exact number. Mr. Gilbreth: Would you object to an order being written with a lesser per- iod for without having to come to this Committee, but with the Committee to have administrative authority to grant up to 60 days. Mr. Bates: i believe that would be alright, i think we were really requesting is for the Committee to have the ability to grant up to 60 days ~fiaring. Mr. Gilbreth: As i read the application I was under the impression you were asking for unlimited authority to flare 60 days on each occurrence and they could be consecutive. One would flare 60 days and another would flare 60 more . Mr. Bates: No, now I see what you're saying but I guess in theory that could happen, except we would have to come in after 96 hours and request the Committee's approval to flare gas.i believe that was indicated in the - where. the Committee would give its approval or not give its approval, therefore if we violated our business obligation „ you still have control. Mr. Gilbreth: Let me see, if I understand you right. As 1 understand you now, you're saying that if an occurrence happened out there, that looked like it was going to take 30 to 35 to 40 days, after 96 hours, you would come to the Committee to get appr®vai to flare during this time? Mr. 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 we are down we are. flaring and I feel we would be obligated to give you at least an idea of how long we would be down. Mr. Giles: Can l clarify my view on that. i view the present 96 hour deaf before the expi°ration 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- • follow up later on and tell you when its been fixed. We want to continue all that. I don't think that our view is that we would be asking for your approval per sey to go beyond 96 hours. Mr. Marshall: Mr. Giles, i wonder if i could interrupt here, I think we do need a point of clarification in view of the fact that both the letter from you and from Mr. LaGrone, referred to the 96 hours, in what I think is an erroneous application. Your wording 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 Order No. 102." Mr. LaGrone, letter uses similar Language, as a matter of fact Conservation Orders 105 and 102, Rule 3 says, 11 the commencrr~nt, nature, and termination of all emergencies requiring flaring of casinghead gas in excess of the amount required for the safety flaring shall be reported to the Commute within 96 hours after the occurrence" and 96 hours being merely a period of the time which we want to know. about it chiefly by telephone communication. Mr. Giles: Yes, right Mr. Marshall: I know, and I think the 96 hours has come to mean something different like a time in which, flaring go on, really is a reporting rather than a flaring time, so I bring this up if we're talking about proposed language, lets bear in mind that the 96 hours is in the existing Conservation Order Just recorded.. Mr. Giles: Alright, but the again back to our basic request we're asking for up to 60 days per occurrence per event per platform within which to flare. We do not intend to use 60 days on each event, of course not, but as Mr. Bates points out, you never know when you're going to get into a rather extensive downtime situation that might take up to 60 days. if it required more than 60 days for that -28- event to correct the failure, or 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 do too, that we've come to a stage in these fields when administrative approval rather than hearings on everything is the best course of action. This is what we're asking. Mr. Gilbreth: Let me throw this out at you. On the west side of the inlet the operators have similar problems and my recoliecti`on of the, in effect, the effect of the order, I don't recall the exact language, is that an operator can utilize or can flare gas because of these problems that we're talking about up to 15 days .per calendar quarter, without getting Committee approval, beyond that they have to get the Committee approval. Do 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 something 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 volume that we're concerned with. Would you have objection to an order patterned something like that.. Mr. Giles: Basically what you're then saying is rather than 60 days per event per platform, you're saying 60 days per year per platform? Mr. Gilbreth: Yes, yes. M11r. Marshall: 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. Marshall: Well, beyond 15 days per quarter. The beauty of this thing is,the way we're handling it on the other side of the Inlet, is that if you have a problem which you think is going to take 60 days, then we give you administrative -29- approval to flare gas in 60 days, but it's actually 62 days, then what are we going to do, are we going to shut you down right there, are talking about a public hearing, we don't have time to pubiish,,its sort of like just an auto- matic, we're left with two alternatives in a case where you will run over 60 days and l believe that you're going to run over 60 days sometimes. Now I think we've boxing ourselves in again on the 60 day thing, I 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 quite a bit more and I really think that flexibility here is going to help both sides of the fence especially when we get in situations where if we have to hold a hearing we have to advertise and now we're looking at anywhere from 12 to 15 days to effectively do that, we've been up against this sort of thing before and I really believe if you, it-'the Committee has discretion to administratively permit the flaring beyond a certain time, we can look the sit- cation right there. It may be a catastrophic type, it may take quite a bit more time and there always, and we're never sure exactly how long it takes. Mr. Giles: Let me be sure I understand what you're saying. Mr. Marshall. You've saying if you wrote the order like the one on the west side, the 15 days per quarter, per platform, that's automatic and if we needed more than 15 days per quarter, we'd have to come and ask for administrative approval without a hearing, which you could grant. If we needed more, lets see that would cover, we'd have to forecast at that time how long we'd be down, would we, or how do you end, put the end date on? Mr. Burrell: Let me interrupt here, if I may. The existing orders 105 and i02, on the east side, have no provisions for flaring for cases of operational -30- necessity, we only said you can't flare at all. It says if you have to flare in case of emergency, however you have to let us know in 96 hours. Now we use a rather restrictive definition of emergency, until higher administrative authority or the courts assist us in our view of it, we're going to stick to it as emergency is danger to life and property. Operational necessity is the matter #hat is under. discussion today, such as mechanical problems, and turnarounds and things like that. The order's now on the west side provide and discuss 15 days per calendar quarter per platform and any flaring onshore will be allocated back to all plat- forms. Onshore facilities, flaring serving two platforms will be allocated back to both platforms, both platforms have been charged with flaring during that period, whatever it may be. Does that clarify the way things are now on the west side? Now if somebody wants to flare more, and use up the 15 days per calendar quarter, they come to us and tell us how much longer they think they will have to keep flaring and ask for an administrative order, which we may give them. We could give them one for 10 years theoretically. As a practical matter, if it looks like a major problem, he may very well elect to go a public hearing because any number of circumstances could justify that. Suppose the Collier Plant went down for 90 days, for example, that's sounds like you have a pretty good reason Mr. Giles: Welf, Mr. Burrell: Excuse me, by thar time circumstances mad have changed.:There may be an alternative market available to you. We might really want to think of this alternative market, we might want to hold a public hearing to find out why you weren't using this so called alternative market, After all, this is -31- what started the no-flare orders in the first place. It is our opinion, that there was a market and n®w it is being marketed so we're not always right. Mr. Bates: Are you empowered now in~102 and 105 to allow us to flare by administrative order for any periods desired. Mr. Burrell: No, flaring is prohibited under 105 and 102. texcept for emergencies3. As a matter of fact if the Collier Plant had not had a fire, explosion which coincided, with their turnaround, we would have considered it operational-necessity and not permitted by 105 and 102. It is an emergency. because of an explosion, or fire that occurred in the Collier Carbon Plant, upon which event you did win your turnaround. Does that clarify where we stand at all or have i just made it worse? Mr. Giles: PJo, that's alright. Mr. Gilbreth: We're finding more and more as you people are, there's slot of administrative headaches in trying to°~adrhini~sterthi;s, and I'm interested in eliminating as many of them as we can and covering as much here as we can at the hearing ve pressure. The well ~o we know where we are headed. Mr. Giles: I think with that understanding, to answer your question, we could live with that. Mr. Bates: Ply only question here is if you have operational necessity after your IS days in that quarter, must you go to public hearing or can the Committee administratively extend your flare period. Mr. Burrell: Under the west side orders we can give an administrative extension. Mr. Bates: That would be the same for 102 and 105. Mr. Giles: That would be at the discretion of the Committee. -32- Mr. Burrell: yes, we could call a public hearing if we saw fit. Mr. Giles: Depends upon what you hear from us? Mr. Bates: Well, I think you have that right at all times. Mr. Gilbreth: Well, we're, I know l personally, I don't know about the rest of the Committee, but I'm concerned about the request you made. It appears to be very open ended 60 days from each occurrence, and there is nothing to say you can't have one right after the other, six times out of the year. This is something that from a use standpoint is bad. Mr. Bates: What you're reviewing and what our real objectives, are really about the same. What we've been after is not having to come to hearings, till something breaks down and we're notified you and you don't have any power to use your~judgmen#~;to say, yes, you have a breakdown, we understand this breakdown., but there is nothing we can do about it. Mr. Burrell: I think, speaking for myself, rather than the whole Committee, I think my position is that we have these minor items under Amoco's Exhibit 1, there is nothing on there any longer than 10 days, scheduled for more than 10 days. With the exception of the one instance of the Shell Platform, I don't know of anything that's been over fifteen days, since no-flare order has been in effect. I don't know of any shutdowns since the no-flare order went into effect, with that one exception who ever had that major problem. Our intent is not to harass you with these minor problems by having hearings or messing around with every spark plug change and that kind of nonsense. However, if we think that you can - 1. restrict production; 2.fit'~falternative use of gas; or 3. any other means to eliminate that flare, we want to reserve the right if it is one hour over that 15 days per quarter to jump in and say, well how come you don't do this, and have a pubiic- -33- • • heari ng. on i:'I'. [)oes that add anything? Mr. Bates: h1r, Burrell, has the order already been published in actor- dance with the gas lines? Mr. Burrell: It has been orally given at hearing and i think it is on my desk for signatures now. Mr. Crews: As I had discussed previously with Mr. Marshall, perhaps maybe submitting a proposed form of order far your consideration. If we're going to do i might look at the one already written. Mr. Burrell: 1 assume this-draft is, this is the 37th and final draft, assuming this is the last final draft,_it would be appropriate to come the last day. Mr. Crews: Our suggestion would be in conjunction with Shell's and Amoco " s. Mr. Giibreth: I have another question to ask of both Mr. Bates and Mr. Giles. Earlier testimony in these cases indicated it was not feasible to reinject 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 Field. I'd like to ask you individually is 'rt not now feasible to reinject this used gas from these, two Melds, so that excess gas would not go through an emergency flaring. Mr. Giles: I'm Mr. Giles, back into the formation from which it was produced? Mr. Giibreth: Yes. Mr. Giles: It would not do for the same reasons presented at those earlier hearings. Primarily the contrast in mobility ratio, which would Just eat us alive, compared to the better mobility ratio between water and oil. -34- Mr. Giibreth: Referring to the Middle Ground Shoal, particularly the A Pool i believe that there is a gas zone in the A pool, a free gas zone, is it not feasible to reinject into this? Mr. Bates:. I believe th~,is is Bates with regard to your point, if I remember right, it would about 3000 or 3200 psi to inject gas into this pool in our area. Mr. Bates: Whi+1~e Mr. Giles is thinking I guess, I'll answer first of ali 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 Middle Ground Shoai and we have not reduced bottan hole pressure to .that great of an extent. We're replacing produced fluids with water and maintaining the reservoir above the bubble point. Therefore we do not have a situation where we're asking to ~reduce the injection pressure for natural gas i n the reservoi r. Mr. Giibreth: But would it, would it not be feasible to install injection equipment to do this? Mr. Bates: I believe that depends upon the definition, of the tersm feasible. It could be done. It would be from our view point it would not be a very safe operation, we would have to put in 5000 ± psi gas injection equipment, large, heavy 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 economically feasible at this point. -35- Mr. Gilbreth: Just for the record, the flow diagrams. that we_had on the gas sales or gas production stream on the sales report, shows the produc- tion to go from the platform to the shore and through the line to the Collier. Plant. i believe that there is a gas handling facility operated by Union. [~ ei-ther of you see any possible equipment failure there that would result in down-handling about what we talked about here today, i think that had been d3s.--_: cussed. Mr. Giles: Not knowing much about much about union's system from-tfie < sales meter to the Collier Plant i am not at liberty to know this. I wouldn't suspect there would be, but I don't really know for sure. Mr. Gilbreth: I just wondered if we covered the possibilities of failures here, we talked about platform failures, line failures and Collier's turnaround. Mr. Giles: i 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 for a longer period of time and present the problem they have to you and you'd have the administrative decision to allow it or not allow it. Mr. Gilbreth: Union has no obligation to us, to the Conservation Committee, its only the producers. Mr. Giles: Therefore we would notify you. Mr. Bates: Alright, that would be the situation, but again if Union were down for more than 15 ..days depending on the case you'd have the authority to admin- istratively allow us to flare or call a hearing under the 15 day plan. M r. Burrell: Gentlemen, one other provision to the proposed order on the west side fields is also concerned with yours and I should call your attention to -36- 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 onshore or on the platform and why, the location and nature of the opera- tional necessity and number of days. or hours duration. Pardon me? Quarterly. Mr. Giles: Good, much better. Mr. 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: I've haven't seen the last draft, obviously. Mr. Bates: We°h), you know we're at a little bit of a handicap, because you've looked at it 37 times, and we have not yet seen. it. Mr. Gilbreth: Will you would see no objection to that type of a inclusion? Mr. ? No. Mr. Gi-ibreth: That's all the questions I have. Mr. Marsahll: I have one 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 parts or services. I'm just thinking that the chemical process industry in Alaska is very very new and i 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 sane of the parts you're talking about. I suppose whey don't lend -37- • themselves readily to come up on an airline, could you just give a little light on that please sir. Mr. McMahon: Our turnaround is usually very thoroughly planned operation and we have ail. 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 metallurgical failure that-we're not prepared for and we haven't gotten the spares in. In this one, in the, that we just completed in June and July, we really didn't encounter any of the long term deliveries that delayed the start-up, but it is not inconc~~r.vaf3ke that it could happen. The one that I 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 enbrittlement of the very thick forging. We had to remove one and get a new part forged and charter a airplane to get it up here and that kind of 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 metalurgical and machinery new horizons, I'd say, we cannot always foresee that that kind of thing may not happen. Mr. Marshall: Thank you. Mr. Burrell: I believe that one of you testified that you attempted to ice) "~ schedule your platform turnaround, compressors or whatever it may be, with the Collier turnaround. . Giles: We both testified to that point sir. Mr. Burrell: That of course would be to your advantage with a 15 day order limit, wouldnet it? Mr. ? No, not necessarily. Mr. Giibreth: Mr. McMahon, how far in advance do you schedule these -38- turnarounds and do you notify the operator, how much notice do you give the operator? Mr. McMahon: We 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 Day and that we would foresee a four week outage at that time. Mr. Gilbreth: I see. Mr. McMahon: And our communication with the operators, we're dealing exclusively with Union -0iI Company and they in turn with the operator and we give them as much notice as we can. Mr. Gilbreth: And do the operators have ail the notice they need to trry to do any of their own schedu.~ing to coincide with the plant turnaround. Mr. Giles: Of~ yes if they do what they Just said, why it would be fine.. I expect they will. Mr. Gilbreth: Weil, is that, is it working in practice? Mr. McMahon: We must do this, obviously because of our own need to get materials if we're looking at a compressor or some complex part like that sometimes we need 10 months leave time for the manufacturer to deliver them. Mr. Gilbreth: Well, the reason i asked is the Conservation Committee be- came aware of this Friday before you were scheduled for fiurnaround on Monday of 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. Mr.'~Burrell: Let°me ask Mr. Giles and Mr. Bates a question. Can the gas from Middle Ground Shoal or Granite Point or both, casipghead gas can it be used in the Swanson River-'Fieid for pressure ization, in the event that the -39_ + • Collier Plant is not available for this fuel source or as the supplier, or as the market. Mr. Giles: No. Not without a great deal of expense coult it be done, no. Mr. Barre l l: I n otfier wori"is what i s wnbng with i t? I s i t too heavy-: Mr. Giles: No, it's crude oil pressure and we've already testified at previous hearings on the gas flare situation several times over that, probably will not ever receive a pay out of the investment put into this system ai- ready and to compound that with added investment to accomplish something else would just compound our situation in reverse effect, a negative effect. Mr. Burrell: I just wanted to hear it. Does anybody in the audience have any questions of any of the witnesses or the Committee or anybody? Any- body like to make a statement? We'11 adjourn then. Thank you. -40- ,~ form SA 1 • MEMORANDUM ro: r` F i I es FROM: O. K. Gilbreth, Jr. Chief Petroleum .Engineer State of A/as~k~ DEPARTMENT OF NATURAL RESOURCES DIVISION OF OIL AND GAS DATE : June S, 1973 SUBJECT: ~ ~{ 105 - A On June 5, 1973 Mr. Terry Smith of Shell Oil Corporation called to advise that. the compressor in their platform 9fA" was still down. The two specia- lists from York have been examining the. equipment and had determined that there is internal damage to the compressor. The service engineers boxed up the parts and took them back to Pennsylvania for balancing. It may take up to several weeks and may even be necessary to re-manufacture the parts again. Mr. Smith advised that the installation of this unit cost Shell 600,000 dollars and it has never functioned satisfactorily. Solar was the prime contractor on the Job and Shell is looking to Solar to make necessary repairs and see that a satisfactory installation results. He said that the entire She11 Corporation was behind this move and the company was very concerned and bringing all the pressure to bear that they could on Solar. Mr. Smith advised that it is his personal opinion that the compressor will be down for several weeks and it is not a matter of a few days. I advised him ( would have to cheek Conservation Order No. 105. and determine what course of action must be followed. ~~ Form SA 1 MEMORANDUM To: rF I LE FROM: O. K. Gi Ibreth, Jr. Chief Petroleum En ineer . 9 State of /asks DEPARTMENT OF NATURAL RESOURCES DIVISION OF OIL AND GAS DATE : May 30,1973 sue~ECT: CONSERVATION ORDER #105-A On Thursday May 30, 1973, Mr. Terry Smith of Shell Oil Corporation called to advise that the compressor on their platform "A" was still down. Sola r and York service engineers were on the way to Alaska via airplane to inspect equipment and attempt to determine the problem areas. At this time it appears to be a substantial failure although they are unable to determine the extent of it. They have no estimate of the down time but with advise us early next week when they find out how long it will be from these service engineers. ~? ~~ AMO~ _~~ Amoco Production Company P. 0. Box 779 Anchorage, Alaska September 29, 1972 File: WMJ-554-986..511 Mr. Homer L. Burrell, Director Division of Oil and Gas Department of Natural Resources State of Alaska 3001 Porcupine Drive Anchorage, Alaska 99504. Dear Sir: ~d ,~ ~y/liCa~t~`'t C.d. 1~ S ~ ~ ~ ~ 99510 fi DIR ', ~C. GEOL I C. FNG____..': ---~ 1 ENG I _ I 2 FNG _ I_: __ i 4 ci ~ I-- 5 cr~;G I --I -.- I1G=OLI_ (z c~oL I -~ 3_~ VOL -I- I DRAFT I I -sec _ ~ - - - - -- CONFER: FILE: /tJ ~ .~ Re: Extension of October 15, 1972 date provided in Rule Nos. 1 and 2 of Conservation Order No. 105-A to November 1, 1972 We have experienced unexpected delays in receipt and subsequent in- /~ stallation of gas metering equipment necessary to handle the excess casinghead gas from the MGS an S S platforms. lnstallation of this equipment cannot be accomplished by October 15, 1972 but can be com- pleted by November 1, 1972.. Consequently, we request that administra- tive order or orders be issued to permit the flaring of casinghead gas in excess of the maximum .amount that can be beneficially utilized until November 1, 1972, rather than October 15, 1972 as provided in Conserva- tion Order No. 105-A. Yours very truly, W. M. Jones ~' District Pr~id tion Superintendent. cc: Mr. H. T. Hunter r_ ,', 4 `..-"` i~ ~f iii ~ 1', ~ 4.~ i~ _, 2~+" ~I>r`i=~~~'~ `~ ~~- %i$ ;.7 ~~ SHELL OIL COMPANY SHELL BUILDING 1008 WEST SIXTH STREET LOS ANGELES, CALIFORNIA 90017 August 30, 1972 Alaska Oil and Gas Conservation Committee State of Alaska Department of Natural Resources 3001 Porcupine Drive Anchorage, Alaska 99504 DIR/~ ~C. GEOL G ENG ~i 1 ENG ~2 ENG _~- s Er.~G - ~-a ENG ~re~ - ----- 5 ENG 1 GEOL ~~ } - 2 GEOL ~- ~ 3 GEOL RAY - - 'I ?RAFT ~ C Gentlemen: { / The undersigned Shell Oil Company, as Operator of SAS Platforms "A" and "C" under that certain Offshore-.Joint Operating Agreement dated January 1, 1972, hereby makes application for the extension of the date provided for in :Rule Nos. 1 and 2 of Conservation Order No. 105 to permit .f laring of gas from SAS Platforms "A" and "C" until November 1, 1972.. We ask that this extension of time be granted by administra- tive-order as provided.for-in Conservation Order.No. 105-A in Paragraph 3 of .the order proper appearing on Page 2. .This two-week extension is necessary.due to-delays beyond our control in manufacturing equipment-which .must be installed to comply with Conservation Order No. 105. .Such equipment is now.scheduled to depart from Houston, .Texas on or about September 14, 1972 and should arrive in Kenai, Alaska the second week of October, 1972. It is estimatedthatthis equipment will be installed during the month of October and should be operational by_November 1, 1972. All working interest owners in the.leases subject to the above mentioned Operating Agreement have authorized us to make this application and to proceed as indicated herein.. Very truly .yours, MLB : MK c-^ F. H. Richardson Division Production Man ger West Coast Division cc - Standard Oil Company of California .Post Office .Box 7-839 Anchorage, Alaska 99501 Attention Mr. C. V. Chatterton cc -.Atlantic Richfield Company Post Off ice Box 360 Anchorage, Alaska 99501. Attention Mr. H. A. Slack ~, f; r ~ , ~~ ~' >~- C3lti'f~IC1~^1 ~~~ ~ AP3C::s~ ~ ~~`_~ PHONE: 482-3131 ~5 ~`~ AKA CONSERVATION SOCIETY KENAI PENT" SUL-A CHAPTER P. O. 80X 583 _', ~ SOLDOThA . ~.. ~ ,-.~"' ALASKA 99889. ~ tip, . Division of Oil and Gas 3001 Porcupine Drive Anchorage, Alaska RE: Ma D 5 ~ 1~7~ ~ ~U L~ ~~ C. o, DN'ISION OF Oll ~.lJ~ G."•.. ANCKO^..•+,^ Rec{uest 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 monthLto-month basis with the review required for continuing extensions of an additional month. Z~i~ ~~ ' JA aS E. FISI~ER Pr sident P. S. The Pipe coating is not bei accomplished in Alaska for`the project. Is the lack of the 60-80 jobs involved in the required pipe coating considered by this Division in its=deliberations over the delay in gas flaring termination deadline? X DIR C. GEOL ~, c. en~c 1 f~G -~ r 2 [NG ~~ 4 ENi L I 5 ENS. .I .. ` 1 GE~JL L --~ - ~ ~~c~l• ~ _ ) 3 GEOL' 1-- REV __I_._. bRAFT ~fC ';; CO NFER: FItE, ~. /0 7L~ ~ %o - ~ !a V • p, cos •w ~ 4 NO, 3fL55, FIVE VEAR9 BY MONTH9 X 9 9.tIJCH CYC4E3 RAT70 RV1.ItV 0. .. ~ ` o B OPD 0 0 /~~ CODEX 800X COMPANY, iNC, NORWO00, MN93ACH V3ETl9, ~~ ~ ~' •. 0 o o Dec.: n. rnr.! , I --,-•_-.- N I ; I I ""'----a I t I I I:.L, . 1 -~-~rl 1 l , I I ' I ~ I f I 1 I i~ I t I, I ( l l l i~ ; I , 1 1 h 1 I t I I l I I 4 , I + ' I ~ I I I I'il I ~ ~ N I I I W I I I I I I~ ~';, llll~ I , I ~ I I II ~ I ~'~ I' 1 I + I I I I W ! ( , i i r I l h ! ; _ ` _ I ! '~ T I i Q ! I I I I I, ! I!i1 ! • I I' 11 "if( I ,1 - , W I r _~ I Ll.. I I' !lilt I I_ T'. i-('III ! II ~ , ,- - , - ~ ^•- `~- ~~ ~l ~ APr. G1P _ ' ~-1 ~ I ~~' ~ II . III I~ ~ ~ ' IiI i ! 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II I I y=il 1 k',Iii,It. ~ _ i~4 ,~ (IIII .'J ~,l ~fl' m'11~, ..1 a v ~l~r//'D-GOR v • ~ ; Q ~ ~i d x Z ~ 1 a ; 1 I : ~l ~~ G~ i+\ ~~' o I ~3 NOTICE OF PUBLIC HEARING STATE OF ALASKA DEPARTMENT OF NATURAL RESOURCES Alaska Oil and Gas Conservation Committee Conservation File Nos. 102, 103, 104 and 105 Re: The application of Union Oil Company of California, Atlantic Richfield Company, Shell Oil 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 (, 1972" and substituting in its place the date "PJovember I , 1972". Notice is hereby given that the referenced companies have requested the Oil and Gas Conservation Committee to issue orders which extend the period of t i me from J u I y I , 1972 to PJovember ( , 1972, dur i nc~ which cas i nghead 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 will be held at 9:00 a. m., Play II, (972, 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 Aools 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 1~1, (972 A~Fn6T 0~ PU6LI~r~,l'ION STATE OF ALASKA, ) THIRD JUDICIAL DISTRICT,) ss. .....~:tar.~..L.Shake•----• .............. being first duty sworn on oath she deposes and says that ................ is the... Leal- Clexk_•.•_ of 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 all 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 ..Le~al••..•.•-Notice 1930 as it was published in regular issues (and not in supplemental form) of said newspaper for. a period of ...,.one insertions, commencing on the .14.... day of ...A.F?i^.1~........-.. ,19 ?.~. ,and ending on the......1~!......... day of of "-F~ri1 ................... , 19...72., 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 S 12.50 which amount has been paid in full at the rate of 25Q per line; Mini- mum charge 57.50. %, ... .t ,1. .... Subscribed anfj sworn to before ~; me this .1~..-day of !+pri1......., 19.76.. ;, I:as,1 r...,. r «-.a r.. NOTICE OF PUBLIC NEARING STATE OF ALASKA DEPARTMENT OF NATURAL RESOURCES Alaska Oil and Gas Conservation Committee Conservation File Nos. 102, 103, 104 and l os Re: The application of Union Oil Company of California, Atlantic Richfield Com- pany, Shell Oil Company, and Amoco Production Company for orders amend- ing Rule No. 2 of Conservation Order Nos. 102, 103, 104 and 105 by delet• lno the date "July 1, 1972" and sub- stituting in its place the date "Novem- bar 1, 1972:' Notice is hereby given that the refer- enced companies have requested the Oil and Gas Conservation Committee to issue orders which extend the Deriod of lima from July 1, 1972 to November 1, 1972, during which tasinghead ass in addition to the amount necessary for :slaty tan ba flared from the oil pools identified in the refer- enced conservation orders covering the fol- lowing fields: Granite Poinl, Trading flay, McArthur River, and Middle Ground Shoal. The hearing will be held at 9:00 a.m., May 11, 1972, in the City Council Cham- bers of the Z.J. Loussac Library, 5th Avr !nus and F Street, Anchorage, Alaska, at which time operators 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 ~ legal Notice No. 1930 ~'~ :. '. r ~~ ; ~~ Q.le 'F.~t U ~ 1~ ~ C _. rk l a""'"~" ,, _ v-. p 6~~ K u':. k,,,, ~ ~ '~~ ~~~~ I;C;t ~11,~,,~;;, Comtt~unic:-tions, Ina "~' # v 1972 APR 12 PM 4 57 AL361 U APR 131972 f~iV~~ivN OF OJ! ANO GAS YQYP PST APR 12 72 LA 164 NSA225 ~NGH4'tAGe NS NSA350 C 1-0120 71A 103) PD 04/ 12/72 1800 T W X AMOC 0 PROD D NV - Z C Z C0 01 D E NVEOEL O 4/ 12/72 PMS MR. HOMER L. SURRELL, CHAIRMAN ALASKA OIL AND GAS CONSERVATION CO D IVISION OF OIL AND GAS 3001 PORCUPINE DRIVE PLEASE DELIVER ANCHORAGE, AL ST AMO C 0 R E QUESTS MAY 1 1 }TEARING T 0 AMEND CONSERVATION ORDERS 105 AND 102 FOR MID D LE GROUND SHOAL AND GRANITE POINT FIELDS RESPECTIVELY BY E'~6 - ~XT~b I NG J U1,.Y 1, 19 72, FLARE CURTAILMENT DEADLINES TO NOVEMBER 1, 19 72 ~ A N D R EQUEST NORMAL 30 DAY ADVERTISING PERIOD FOR SUCH HEARINGS BE WAIVED IIV 1 "°'~ INSTANCES 44' 1 s r ~ V _ ~ Y~r .. k~, _~ - ~ _ i ~ ,. ~QR 111.../// 4J x~19~2 . 4M o00/~gN~ GAS ~~ ~~ ~ .~ ~ t' ` ~~ryry ,t .Vd -., ~ t -, .T.G 3 .~ ..-.' ' 'h d ~: ,~7 ~ ~ ' r .~-~ ~ ~s.`.I..~.wt"u:l.L?i`a ~.~i).C -K:'r' ~' r"~~3°.1.L711 ~~ 1 ~ ., N ~ a a .. ~ ~, s. a ~ .~ +,! i~':I~L"~~~:„3; . ~ ~z~ 1 ~ 1 r ~ f ~ ~';;,7 ~~~ G; _, .,u.~~.~~ ~v i =.. i a.:-,. a 'al .l. ~ ~ , ti ..i z ~ ~ ~ ~~„ x ~ , r A ii ~ _ . i u a l., j l ,:1 .... > ~ _ .. 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