Department of Commerce, Community, and Economic Development
Alaska Oil and Gas Conservation
Commission
HOME
EVENTS
DATA
Data List
Drilling
Production
Orders
Data Miner
Document Search
REPORTS
Reports and Charts
Pool Statistics
FORMS
LINKS
Links
Test Notification
Data Requests
Regulations
Industry Guidance Bulletins
How to Apply
ABOUT US
History
Staff
HELP
Loading...
The URL can be used to link to this page
Your browser does not support the video tag.
Home
My WebLink
About
CO 102 E
• • Image Project t~rder File Cover Page xMVZc This page identifies those items that were not scanned during the initial production scanning. phase. 1-hey are available in the original file, may be scanned during a special rescan activity or are viewable by direct inspectioCn of the file. !~. Order File Identifier UrganiZing (done) RESCAN ^ Color Items: ^ Greyscale Items: ^ Poor Quality Originals: ^ Other: NOTES: BY: Maria ~~~ --a, Project Proofing BY: Maria Scanning Preparation BY: Maria Production Scanning _x30= Date: ~I P + =TOTAL PAGES (Count does not include cover sheet) ~ /s/ Stage 7 Page Count from Scanned File: ~ (Count does include cover heet) Page Count Matches Number in Scanning Preparation: YES NO BY: Maria Date: ~ ~ ~ I ~ lsl Stage 1 If NO in stage 1, page(s) discrepancie were found: YES NO BY: Maria Date: /s/ Scanning is complete at this point unless rescanning is required. III II iIII III II II III ReScanned BY: Maria Date: /s/ Comments about this file: Date: ~~` Date: V `~ „iuiaumiaiiiu ^ Two-sided IIIII~IIIIIIIIIIIII DIGITAL DATA ^ Diskettes, No. ^ Other, No/Type: o~a~,,.~~e~ke, iiiumiiiiiiiiii ^ Rescan Needed III IIII II (~ II III III OVERSIZED (Scannable) ^ Maps: ^ Other Items Scannable by a Large Scanner OVERSIZED (Non-Scannable) ^ Logs of various kinds: ^ Other.: 10/6/2005 Orders File Cover Page.doc Index Conservation Order 102E 1. August 1, 1973 2. September 11, 1973 3. August 16, 1973 4. February 1, 1974 5. May 31, 1974 6. December 17, 1974 7. February 12, 1975 8. March 26, 1975 9. Apri128, 1975 10. May 29, 1975 11. May 11, 1977 12. June 6, 1978 13. June 14, 1978 Amoco Application for Amendment Hearing Proceedings Notice of Hearing, Affidavit of publication Amoco letter re: Failure of Granite Pt Gas pipeline Amoco Application for CO 102 E.2 Amoco Application for CO 102 E.3 Amoco Application for CO 102 E.4 Amoco Application for 102 E.5 Amoco Application for 102 E.6 Amoco Application for 102 E.7 Amoco Application for 102 E.8 Amoco Application for 102 E.9 Memo re: flaring Conservation Order 102E STATE OF ALASKA DEPARTMENT OF NATURAL RESOURCES DIVISION OF OIL AND GAS Alaska Oil and Gas Conservation Committee 3001 Porcupine Drive Anchorage, Alaska 99501 Re: THE APPLICATION OF AMOCO PRO- DUCTION COMPANY for an order amend- ing Conservation Order No. 102 to permit administrative approval of gas flaring for a maximum of 60 days in cases of operational necessity. Conservation Order No. 102-E Granite Point Field Middle Kenai Oil Poo l Amoco Production Company Platforms. January 28, 1974 IT APPEARING THAT: 1. The Oil and Gas Conservation Committee published a notice of public hearing in the Anchorage Daily News on August 16, 1973, pursuant to Title 11, Alaska Administrative Code, Section 22.540. 2. A public hearing was held on September 11, 1973, in the City Council Chambers in the Z. J. Loussac Library, 5th Avenue and F Street, Anchorage, Alaska, at which time the applicant and other parties were heard. 3. The hearing record was combined with that for Conservation File No. 105-C, which related to Middle Ground Shoal Field, because the same order was requested and Amoco Production Company was an applicant for both orders. 4. The Committee gave the substance of this order verbally to the applicant after the hearing. FINDINGS: 1. Pursuant to Rules 2 and 3 of Conservation Order No. 102, flaring or venting of casinghead gas in excess of the volume required for safety is permitted only in case of emergencies, and must be reported to the Committee within 96 hours after occurrence. 2. The Committee considers emergencies to be situations involving a danger to life or property. 3. During the period of routine repairs of gas handling equipment on the platforms, gas pipeline breaks, "turnarounds" of facilities using the gas, and other required repairs, overhauls and work on equipment downstream from the oil wells, beneficial utilization of some casinghead gas may not be feasible. These repairs and other work arise out of opera- tional necessity. Conservation Orde~~2-E Page 2 January 28, 1974 4. The history of such repairs and other work indicates gas handling equipment can usually be repaired or overhauled within a few days, pipe- line breaks may take several months to repair depending upon the time of year and weather conditions, .and overhaul or "turnaround" of the Collier Carbon and Chemical Plant which is the market for the gas will .probably take less than two months. 5. Most overhauls of gas handling equipment can be scheduled. to coincide with the "turnaround" of the Collier Carbon-and Chemical Plant, thereby minimizing the time during which the gas is not beneficially utilized. 6. No reasonable alternative use of the casinghead gas exists during the periods the gas handling equipment, pipeline or Collier Carbon and Chemical Plant'is inoperative. 7. Operating experience in the referenced pool indicates that the shutting-in of wells may result in reduced production rates after the wells are re-opened to production. 8. The unrestricted flaring of casinghead gas from the Mobil Oil Corp- oration - operated platform in the referenced pool is permitted pursuant to Superior Court Order dated October 10, 1972, Mobil Oil Corporation vs. State of Alaska, et a1, No. 71-3432. CONCLUSIONS: 1. Repairs, overhauls or other work on gas handling equipment, pipe line and the onshore facilities beneficially. utilizing the casinghead gas may be required. 2. The time required for these repairs, overhaul and other work may depend on conditions beyond. the applicant's control. 3. Some wells within the referenced pool are producing water with the oil, this water production is .expected to increase, and the possibility exists. that shutting-in the wells will damage the producing zones. 4. Additional beneficial uses of the casinghead gas do not presently exist. 5. The flaring of casinghead gas, when required because of repairs, overhaul and other work on wells or on equipment and facilities down- stream from the wells in the referenced pools, may be an operational necessity. 6. Pursuant to the Superior Court order dated October 10, 1972, Mobil Oil Corporation ys. State of`Alaska, et al, No. 71-3432, this order is inapplicable to the Mobil Oil Corporation - operated .platform in the referenced pool. Conservation Order~2-E Page 3 January 28, 1974 NOW, THEREFORE, IT IS ORDERED INSOFAR AS THE AMOCO PRODUCTION COMPANY - OPERATED PLATFORMS IN THE REFERENCED POOL ARE CONCERNED: Rule 1. Rule No. 1 of Conservation Order No. 102 is hereby revoked. Rule 2. Rule No. 2 of Conservation Order No, 102 is hereby amended to read as follows: Effective 7:00 a.m., October 1, 1973,. the flaring or venting of gas from the Granite Point Field is prohibited except for the amount necessary for adequate safety flares or emergencies or as may be authorized by the Committee in cases of operational necessity exceeding 96 hours. Rule 3. The commencement, nature and termination of all emergencies requiring flaring of casinghead gas in excess of the amount required for safety flares shall be reported to the Committee within 96 hours after occurrence. Rule 4. Any flaring or venting of gas in excess of 15 days per calendar quarter per platform, other than that required for safety, shall require Committee approval. Flaring or venting of gas in excess of the volume required for safety at a location other than a platform shall be deemed to have taken place at each platform. Rule 5. Commencing with the calendar quarter beginning January 1, 1974, the operator of each platform or facility in or serving the referenced pool shall report in writing to the Committee the number of days gas was flared or vented in excess of the volume required for safety, the reason-for the flaring or venting, and shall identify the platform or facility. The report shall be submitted within 30 days following each calendar quarter. DONE at Anchorage, Alaska and dated ~~~~ ~~~ r - ~~ ~~~ - I ~ --_ _ _. .~ _- _ ~, .. € . s ~, ' ~ January 28~ 1974. Thomas R. Marshall, Jr., Executive Secretary Alaska Oil and Gas Conservation Committee Concurrence: ~'~~.~ fS ,~.Q~P Homer L. Burrell, Chairman Alaska Oil and Gas Conservation Committee ^Y ~ . `/ • 0. K. Gi breth, Jr., ber Alaska Oil and Gas Conservation Committee Cc~.~et~v~:tc~e JUG I.3, 1~7s~ ~T~P~rPdI~`~RATIVE '~~VAL ~Tt • Ap~I i:ct3.c~ ~ ~ P~~ic Ctx ~c~r ~~~~at~~re ~'" Fes- pta~zt ~ ~ ~ Q~ ~a C~xZ' l~Ca. 1~3-~ ~v ~3 ~sit~c~ '~ ~. ~aoro Prc.t~i.~ I~' ~ ~~tfc~m "~ sal. "~~'o'~ a st+c ps z~ ~. . L. ~., P~:nc~uct3~n ~Y J P. Q. Bay '~'T9 Ate. -~lca 99SIQ Un.]ll~ Q].~. j7Z'C7E~LE~.f~'! '~ ~ ~~i f4~:` ~3 Cads ~servat~4.cn ~1~at~e ~ auti ~~~ Qf 'KWMWVY~ ~ Y.W1. 4Y~ i+F.. ~ KNM i~ LN.f~ ~W~• ~~~1Y~ it ,i `/! c,~' R~ ~i~''. a /. ~r ~v~ Conservation ALASKA OIL AkYp f,AS C4PdSERVATIOii COi~'~ITTEE i~ay l3, 1977 • A D N1 I R I S T R A T. I V L A P F R O V R L Pi O. 102 - E. 8 Re: -Application of Amoco Production Company for administrative apprnvai .pursuant to Rule 2 of Conservation Qrder Pio. 102-E to flare casing- head Qas at the East fioreland Onshore Facility produced from Amoco Production Company's Platforms Anna and Bruce as an operationai necessity uoEtii the Coilier Carbon and Cher~icai Company pi ant has cor,pleted the annual "turn-around". Mr. L. A. parso Area Superintendent Amoco Production Corspany Box 779 Anchorage, Alaska 99510 Dear i~ir. Oarso~; On i~ay i2, i973, the referenced appiicatic~n was received which requested that excess fiarina continue beyond the i5 days per calendar quarter limitation due to a prolonged "turn-around" of the Coiner Carbon and Cheu:icai Plant. l3ninterrupted oii production appears to be desirable, for the reasons stated in Administrative Approval Fia. 102-E.2. The Oii and Gas Conservation Co~nittee hereby authorizPS the flaring of casinghead gas from the referenced platforms pursuant to Ruie 2 of Conserva- tion Order iio. 102-E anti] the Collier Carbon and Chemical Company plant is again oPerationa7. Sincerely, ~hor~as R. Marshall , Jr. xecutive Secretary T:ti~~ ; b,~ rs __-- - )AY ST HAMMOND, Governor O -----__--y-__- ~Ep~RTM~NT ~~~ Na-TU~a~. >~~s~~u~,cEs QiVISiON Of Oil ANtd GAS 3001 PQRCUPINf DRIVE-ANGHQRAGf 9950t '~ ALASKA OIL AND GAS CONSERVATION COMMITTEE April 30, 1975 ADMi NI STRATIVE APPROVAL N0. 102-E.6 Re: Application of Amoco Production Company, operator for the Chakachatna_ Group, for administrative approual pursuant to Rule 2 of Conservation Order No. 102-E to flare casinghead gas produced on Amoco Production Company's Platforms Anna and Bruce as an operational necessity until June 1, 1975.. Mr. George J. Ross Area Superintendent Amoco Production. Company Box 779 Anchorage, Aiaska 9951.0 Dear Mr. Ross: On April- 28, 1975 the referenced application was received which stated that construction of the twin pipelines from Granite Point Platform Bruce to the onshore Mobil Oil Corporation Granite Point treating facility has been com- pleted but during operations to displace crude oil from the pipeline with gas., the gas pipeline to .the East.Foreland became plugged with ice. Uninterrupted oil production appears to be desirable, for the reasons stated in Administrative Approval No. 102-E.2. i The Oil and Gas Conservation Committee hereby authorizes the flaring of casin head as from the referenced latforms ursuant to Rule 2 of Conser- 9 9 P P vation Order No. 102-E until all :pipelines are operational or until June 1, 1975, whichever occurs first. Sincerely, G~ Thomas R. Marshall, Jr. Executive Secretary Ap~,~ 30 ~~ ~~ f ~w ~~~~ ~I' Vie, lli~~k~t 99~tfl fit. ,~ ~ the ~~~~~t# -~~i~~~ ~# ~~t~ s'~a t ~~~i ~~ t ~ g1~iia~s~ ~ #~d~t ~`~~~ '~ to t pied ~ ring tit ~ d4sp~~€~ ~r#3~r ~#~t~ ~r~ ~ ~~ ~~~ ~ fist ~cire'~~d iii w# #~~ i~a~t~d e~#t prt~~ ors ter irx-bl~,' ~+~~ tt~ ~s ~~~ "€~ fit e~~~i~n ~ ~! ~c~i~~ ~~ ~~' cited s ~ pi:~t~+ ~~t tv i~ Z ~# ar;- ~- "~~~ ~-hic~ ~ fiat. S~ra~1y, f~`'' IJ ~ ~''~` ,~ ~ ~~~ .~ ~ , ;~ ~~_ fit. €~b~7i, ~. Exa~~t9~ ~^et ~: • ~ Al.~SKA OIL ~ ~~~T~~. i~E Re: Applic~t#~ ~~' ~ FrS1 Cry, ~ra#,~r 4`vr ~ C~h~ ~` ft~r ~#~+~R~~r~y~y4s~~a ~~~-r'p~ ~j:.#~rs~cty~{~~,~,~~a~~ 2 ~~ +~`r~~egk~rt~~lt~ ~s ~~~ 4V ~~L[7 ~i ~~~~iM1~ ~~ ~7 VYi~~3 ~ ~ ~• ~'~if~i~V-~ y/, ~,Yr`~P~@~a~~C~r~ /~tr~ d ~ ~- an ~-~~rna~ 5ft~ ~i1 PICT ~ili i.iR~a ~'". ~iBtfr~ ~. ~~S ~#~~~~ ~r~~- ~~- _ ~X ~ ~~ ~tlC~~x ~~+~~~ ~~~ ' tit ~~ar+r~- 'f 3, 'l97~ ' ~''+~~~ ~~1 ic~t~t~s~ ~~ ri f s~3 ~tar't ~ ~L'~iC~ C~~ ~~ ~r1n pi~li~ i ntt~ P~~it~t Pl~ti`~r~ ~r~c~ ~© $ t~tISYltfr~ bi~b$1 ~i 1 CQr~r~tis~ ~"`+~#~~ FE~9 ~t tr~~~#~ f~~# t f ~y ~S r~ ~e ~~ d~ ~- ~x~~~ c~1d ~~Lia~r~ sic#ss ~F reai tr~n~art~#~ ~v~i I ~bi~ i &y ~ ~~ b~1 ky ~ter1 a1 ac~^rts~ ~ It~l~t, ~'1 ec- trica~ i~s~-dT#t~+~n ar~d ~~rr work ~ ~ 14,E s~i t~s fs ~~ ,yet ct~~te. lretir~n i~ e~~d by ~~ ~~, ~97a. i~pp~~t~rlr~~S~~ ~atl tia~ ~//~~II~~~~` ~t#j~ ~ c~~~I~, #~r tie ~ ~~a# c~~i~~d i Lie rr~f platforms p~s~~~ ~ ~1~ ~ ~~' vatic, £~r do-. l~-E #1 ~ R~ri~ p9pt~4s ~d ass~~a'~ ~#t#+~~a ~-r~ o~arat~ttl ar ti1 35, 19~~a',, rr~~tc~r oc+~urs fire. Sf rely, -` ~ ~ ~ ~~ is lx: ttal~ ~ Jr. €x~tive ~~~~ "+~ G !~.l~~A ~t~, ~T~ alt ~~~ #x'14 ,.,,.~. fN t ~ J ~ i1S ~ •a~"~ ~ is !A ~ ~ _$., rVe'.. 'R ! 'ir, t! '~Jr ~""~,1~ _. ~+! },1cx~ ~# 1~ d~cf~i~ ~~ ~$~" fits"' t ~~ fir ~~#s~#a~ ±~~# ~~t~~at ~tr- ~~ ~ ~~ ~t~ Vii s ~~ At 3. .~ t?tt ° -8, !~?~ t~ t~efi 11t~~~ ~ airy t ~ t ## ~u~'Pi~s- ~# fi~ri~ ~~~r~ t '~ar~ ~ai~s #~^!' ~I~fifi 8 tit t~sefiTa~, tt~ +~i+~ .~f '! ptt t4~t+~~~c f ~' +le'tts~ + ~ f~~,i t~t~ Ott ~ d~1ed t~ ~ti~s- t~ T {~# ! ~ ~t ~+~ fltt fits .~~ ~ i # f ! ~ ~ ~ gat _ai # # ~ ~#~t~'f p~t~t~ ~ ~+~ ~ of 8~~$ t +~ ?'~' ~ ~! tom' 3~'$-~ ~ ~~"y 1'.3", ! $~~ ~ vii ~ t'~1~'~@-~' !"~ . , fi l t~#. ~g~~y~ i " ~i l ~ ~;,~~~,~ ~~~ ~', ~~ ; -; ~~ ~~ i ,~ ~-~ , ~ rte, ,-~ t ~ i ' ~ ~ ~ - 1 J; ; ~ ,~j~~ ' ~~ WILLIAMA EGAN, GOVERNOR t ~ ~~~g"t$II$TI~~F~TT ~~' ld'ATIJitAi. ItFS~iT~,[,I~S ,r i DI VISION OF 0!L AND GAS l 3IX71 PORCUPINE DRIVE ALASKA OIL AND GAS CONSERVATION COMP~tITTEE ~~ ANCIIORAGESSSOI June 4, 1974. ADP~9I NI STRATI VE APPROVAL N0. 102-E.2 Re: Application of Amoco Production Company, operator for the Chakachatna Group, for administrative approval pursuant to Rule 2 of Conservation Order No. 102-E to flare casinghead gas produced on Amoco Production .Company's Platforms Anna and Bruce as an operational necessity until January 1, 1975 or until the new lines are operational due to the failure of the Granite Point gas pipeline. Per. George. J. Ross Area Superintendent Amoco Production Company Box 779. Anchorage, Alaska 99510 Dear h1r. Ross: On June 3, 1974 the referenced application was received which stated that after the previous administrative approval 102-E.1 was granted February T4, 1974, permitting casinghead gas flaring due to a broken gas, pipeline Amoco's oil pipeline to Platforms Anna and Bruce broke on February 22, 1974 and re- guired shutting in the platforms until the oil line was repaired on May 1, .1974. Rmoco, as operator for the Chakachatna Group, is planning to install a new oil and a new gas line to the west side of Cook Inlet and expects their lines to be operational by the end of 1974. Uninterrupted oil production appears to be desirable from an oil and gas con- servation standpoint because the shutdown of production necessitated by the break of the line on February 22, 1974 resulted in a 10% reduction in stabi]ized ofi production rates. The Oil and Gas Conservation Committee hereby authorizes-the flaring of casing- head gas from the referenced platforms pursuant to Rule 2 of Conservation Order No. i02-E until new lines to the west side of Cook Inlet are operational or until January 1, 1975, whichever occurs first. Sincerely, ~~ G~ ~ ~~~~~~ Thomas R. Plarshal l , Jr. .Executive Secretary Febmiary 14, 1974 Rt'N I.ft 1.8 AT 1 V,j,, h P'P A OVAl Bt .1' t#e Apolicelon of Amoco, PnWmtfcni/, operator for the Chakschatne . for e"Wjr$,tj%tI%*1 00a el pursuant to Rat o Z of Cmaervotion Order No. 1024 to ftwo c"Ingbeed Wo produced as Amom Preductfew Ompeny9s, Plutforms Amm and brum as an aporattemal seensity fer On lsrdeftetl+e perfed dew to ftlhere► of that Greativ Polet on ptpellee. Mr. 4660vo J. ftss SvperlstwWwt Production Vampsay Sam 779 Meeks 9"10 Door W. Ross s On sm 44IM "a 1,tls "PI10*14A Was mftiv" which e tImt + the WIV00 - fte referenced l 1pe ant . 2.7 per Pt ar! ftm � -6t .9 MW- per day wt Pt Brow 4 ever 'fit V mad 91r Qt%m . f w! a" o opereft lts solace pl lot f I w e, wout4 °be, f *Not w-# # # spsl roc amid be made. A Vs Wspositima, #nB 00 100041UH404Oft, 40 Mad f#MM, Vol 6084 40t 1cl the The Of l aw an comeorwation comm tee 060that It 1s table, afJQW #ensl tft ftaerlag #* tardetlatte period. wr, 4ae-4 inlet tde oWith - prectuda► rust plprlteee krMwIft wt11 tips a ft% of 1*74, and time "m vapt rod f4w stibt i se and repair which must ip requires sewrei a m"w of of fwt,, lair Committee ft** July, to 1974 is s reasonable date to ietod repal rs. Thu ("I and r vatl c" Committee hereby ` ri s "w4farlog of # #mow tlefe refe p lavt! Wom pwlwmt iv, 2 . of le er fly awl the Its* to ropet red or antll July. ! 1,9740 1hl ft r ct. r "'tret* Ff Thowas IL ll, Jr. Executive seat► X13 -~12 i ~~ O ®~~ L. A. Darsow Area Superintendent June 6, 1978 File: LAD-590-986.511 Mr. 0. K. Glbreth, Chairman Alaska Oil & Gas Conservation Committee 3001 Porcupine Drive Anchorage, Alaska99501 ~~ ~:. Attn: Thomas R. Marshall, Jr. Dear Mr. Marshall: Operational Necessity Flaring Granite Point Field, Conservation Order No._102-E ~,. °~ ,,. ~. ~ ~ ~ Pursuant with the provisions of Rule 4 of Conservation Order 102-E dated January 28, 1974, Amoco Production Company respectfully requests Committee Approval for the flaring of casinghead gas from our Granite Point Platforms Anna and Bruce. -~ On May 1, 1978, we notified your office that due to Collier Carbon and Chemical's annual "turnaround" we had an excessive flare at our East Forelands Delivery Facility.. Colliers turnaround commenced at 0600 hours on Apri1.29, _..1928 and_._te~-+~+~*~~ted at. OslS a.m. on May 15, 1978. -~. As you are aware, we also. experienced five a s,_:_,_of excessive flare on Platform. Anna during April. due to a stuc`pig in the. gas line. As the accumulative number of excessive flare. days exceed 15 days in this quarter,. we are respectfully requesting administrative approval for the ~t excessive flare. ` Very truly yo ~ _. _. L. A. Darsow Area Superintendent cc: V. J. Sheppard -Kenai DMS:sls Amoco Production Company P.O. Box 779 Anchorage, Alaska 99510 ~. ~g ~ •~ .-~. ~: pp~ ~w t b ~ 6~ s ~ f S ~~fSjnij 0~ tr~:1 ~. ,r~;.~ A;1c~t;~, ~;,, ~~ ~J ~ ~_ ~~ v^ X11 _~ ~A~ ~MOCO L. A Darrow Aron Suporintondenl May 11, 1977 File: LAD-388-986.511 Mr. Hoyle Hamilton, Chairman Alaska Oil & Gas Conservation Committee 3001 Porcupine Drive Anchorage, AK 99501 Attn: Thomas R. Marshall, Jr. Dear Sir: C Amoco Production Company P O. C~c~x 779 Anchorage. Alaska 99510 I)G G' ~ c 1 ~ r' ,.-=~. ~ ~~ r I~ ~,.. ~ ,l~ ~ o Z~ E .8 ~~~,~~1~, (~.~. ~ ~ 1oS•c,7 Re: Operational Necessity Flaring Granite Point Field, Conservation Order No. 102-E Middle Ground Shoal, Conservation Order No. 105-C " DIR C G~CL I~i' ---. C. f_fiv ~ 2 ,.:; I ~ ' ,; I i~ --I__c ,~~,,,r ~ _ ~ ~,.. CC:iJF Lc. i ILL: -7o2~F.`f3 Pursuant with the provisions of Rule 4 of Conservation Orders 105-C and 102-E, dated January 28, 1974, Amoco Production Company respectfully requests Committee Approval for the flaring of casinghead gas from our Granite Point Platforms Anna and Bruce, Middle Ground. Shoal Platform Baker bnd South Middle Ground Shoal Platform Dillon. On May 2, 1977, we notified your office that due to Collier Carbon and Chemical's annual "turnaround" we have an excessive flare at our East Forelands Delivery Facility. We have been advised by Collier that the "turnaround" would extend to at least May 21, 1977, and possibly beyond. We request administrative approval for the excessive flare until such time that we are able to ship gas to Collier. Since May 5, 1977, we have had excessive flare on Platforms Baker s.nd Dillon due to an obstruction that has plugged the gas line between llillon and our onshore .facility. At this time, we have not deteranined the cause of the plugged line, but ~.re making every effort to clear the line. Again, we request administrative approval for the excessive flare on the platforms until the gas'line has been cleared. Very f`ruly your,, ~°Q,,o h. A. Dar.:;ow Arca Supcriutcud~ut ~~ ~ ~ ~ , cc: V. J. Sheppard - iCcnai ~~ X10 s ~1 ~OC~O _~- May 29, 1975 File: GJR-457-986.511 Mr. 0. K. Gilbreth, Chairman Alaska Oil and Gas Conservation Committee 3001 Porcupine Drive Anchorage, Alaska 99501 Dear Sir: Amoco Production Company P. 0. Box 779 Anchorage, Alaska 99510 ~ c. °.~ 1 .,~` ~ ~~ ,~ ~t , ~ ~` ~2 ~ ' .y ~ k ~ `x Re: Operational Necessity Flaring Granite Point Field, Conservation Order No. 102-E 4 ~~ .,~ ` ~~`% t _~ ___+ s c~o~ ~ . _-I____pty ____ ~ _ Administrative Approval No. 102-E6 dated April 30, 1975, granted Con- servation Committee approval for flaring of casinghead gas from Amoco's Granite Point platforms until all pipelines are operational or June 1, 1975, whichever occurs first. As discussed in prior correspondence ending with our letter of April 28, 1975, File: GJR-364-986.511, the pipeline between Granite Point Platform Anna and our East Foreland facility became plugged with ice during displacement of the line with gas. Since that time, we have pressured the line at least once each week to determine if the plug had softened enough to be displaced from the line. The latest attempt to clear the line was completed on May 28, 1975 when the line was pressured to 1000 psig from East Foreland four times. Since Cook Inlet water temperature is now about 38° F, we felt that there was a good chance for clearing the line on May 28. Available hydrate curves, however, indicate that at the estimated pressures in- volved at the plug, we are just now approaching the hydrate melting point. As discussed in prior correspondence regarding this subject, we are flaring about 1.5 MMCFD of casinghead gas in excess of the volume re- quired for a safety flare. In order to reduce gas production by this volume, we would either have to shut-in our high GOR wells or partially restrict all wells. Restriction of production by either method is un- desirable due to the likelihood of damage to the produced wells as discussed in prior correspondence and defined in Finding No. 7 and Con- clusion No. 3 of Order No. 102-E dated January 28, 1974. In addition, reducing gas production by 1.5 MMCFD will result in a minimum oil pro- duction loss in excess of 1000 BOPD. D ~~~ ~t~.. DIR ENG f D!V!~1CN ~~ AIL ANA SAS AI~CHQRAG - 2 - i In view of the above, we respectfully request authority under Rule 2 of Conservation Order No. 102-E to flare gas as an operational necessity until the ice or gas hydrate plug can be displaced from the pipeline. Yours very truly, 1. `~ George. Ross Area Superintendent cc: A. M. Roney, Denver ~~~~od~~ DIV"510N Gt~ Oil AND GAS ANCHORAGE MWWWO-1 MLIWU • ,. ~~ ~ ^' ~" AMOCO ~ ~ ~' -~`~ ~ ~ III ~a~~ ~ ~ ~, ~,~ ,~ ~~ - „~~ r' i ~` Amoco Production Company P. 0. Box 779 Anchorage, Alaska 99 April 28, 1975 ~ ` File: GJR-364-986.511 yr" Mr. 0. K. Gilbreth, Chairman ~ f' .~ Alaska Oil and Gas Conservation Committee 3001 Porcupine Drive Anchorage, Alaska 99501 Dear Sir: lJ ,b~ Re: Operational Necessity Flaring, Granite Point Field Conservation Order No. 102-E Administrative Approval No. 102-E5 granted Conservation Committee approval for flaring of casinghead gas from Amoco's Granite Point plat- forms until all pipelines are operational or May 1, 1975, whichever occurs first. As discussed in our letter of March 26, 1975, File: GJR- 267-986.511, the pipeline between Granite Point Platform Anna and our East Foreland Facility became plugged with ice during displacement of the line with gas. Since that time, we have pressured the line from the platform at least once each week to determine if the plug had softened enough to be displaced from the line. Unfortunately, we have been unable to clear the line. We therefore respectfully request that the _ry, ,~ v _ ,~,,. Committee grant us authority toF flare ,casinghead gas until t"he plug can lie d si plac,~.~.~,e„pipeline. On the basis of present Cook Inlet water temperatures, this is pected to occur before June 1, 1975. As discussed in our referenced letter, we are currently flaring about 1.5 MMCFD of casinghead gas in excess of the volume required for a safety flare. In order to reduce gas production by this volume, we would either have to shut-in our high GOR wells or partially restrict all wells. Restriction of production by either method is undesirable due to the likelihood of damage to the producing wells as discussed in prior correspondence and defined in Finding No. 7 and Conclusion No. 3 of Order No. 102-E dated January 28, 1974. In addition, reducing gas production by 1.5 MMCFD will result in a minimum oil production loss in excess of 1000 BOPD. ~ ~~ ~ ~ ~l1.~~s~~iv ~.. -Y ~~~~ k~~ ~~.s a ~ - 2 - We therefore respectfully request authority under Rule 2 of Conservation Order No. 102-E to flare gas as an operational necessity until the ice or gas hydrate plug can be displaced from the pipeline. Yours very truly, ...~... ~~ Georg., ~. Ross Area Superintendent cc: A. M. Roney, Denver ~$ ~~ ~O~ _~~ .~ ,oz's ~ ~~~~ ~X. 1 {~ g ~ ~ ~ ° ~ d Amoco Production Company P. 0. Box 779 Anchorage, Alaska 99510 March 26, 1975 d, ~ ~ ,r g ~t 3 +° . y ,="x ~ `4 ~. `~ sad 4a+f ° ~ t. ~ ,~~~~se -'*4 ~~~ ~ ~ ~~ .. File: GJR-267-986.511 ~~ ~~ ~(~ ,~ r , ~ r ~ c~ ~ ~:.., ~ ~ -c., ~ Mr. 0. K. Gilbreth, Chairman ' -~ + ~ ~ ~`~ ~` ' ~ ~ ~ ~ Alaska Oil and Gas Conservation ~ r, $ t~ 7 0 ~ ~ ~ ~ ~ . , Committee ~ ~ ~, `~' ~` `~ _ ~ -~ t ~ w.f ~`~ ~ ~~ ~ ~ ~ °~ ,. e °` Q ~ 3001 Porcupine Drive ~ ~ '~' to ~ r ~~ off ~ ~ -~ ~ _ 4 Anchorage, Alaska 99501 `~ 7 0 ~, ~ 1 ' `' ~ ~(`. t ~ { ^ ~ ` p ~ Dear Sir: J ~^~ Re: Operational Necessity Flaring Granite Point Field Conservation Order No. 102-E Please refer to your February 18, 1975 Administrative Approval No. 102-E.4, wherein the Conservation Committee authorized the flaring of casinghead gas from Amoco's Granite Point platforms until the new pipelines to the west side of Cook Inlet were operational or until March 15, 1975, which- ever occurred first. Since granting this authority, Amoco has completed the major construction of the pipelines and treating facility and is treating the entire Granite Point crude oil stream at the new facility. However, during operations to displace crude oil from the pipeline to our East Foreland facility with gas, the pipeline has become plugged, apparently with ice. We therefore respectfully request that the Com- mittee grant us authority to flare casinghead gas until the plug can be displaced from the pipeline. This is expected to occur by May 1, 1975. We began treating the crude oil stream from Platform Bruce at our new facility on March 6, 1975. Following adjustment of the equipment and controls, the crude oil stream from Platform Anna was run to the facility on March 13, 1975. At that time, we began displacing the crude oil from our pipeline to the East Foreland facility with dehydrated gas. While pigging the pipeline to clear it of all fluid, movement of the pig stopped after travelling approximately halfway through the pipeline. Repeated attempts to move the pig by surging with gas at 180 psig from Platform Anna were unsuccessful. Repeated attempts to move the pig by pumping crude oil alternately from Platform Anna at 400 psig maximum and from our East Foreland facility at 1000 psig maximum have also been unsuccessful. These are the maximum pressures to which we can safely expose the pipeline without a significant risk to its integrity. The lower maximum pressure at the platform end of the line is due to the presence of numerous flanges in the area of previous pipeline breaks. ~ "- ~ i - 2 - We believe that the pipeline is plugged with ice or gas hydrates that may have formed when the dehydrated gas contacted the crude oil stream containing 3-5% water. We plan to continue attempts to displace the plug from the pipeline, but expect that we will be unsuccessful until Cook Inlet temperatures increase. We are currently flaring approximately 1.5 MMCFD in excess of the volume required for a safety flare. In order to reduce gas production by this volume, we would either have to shut-in our higher GOR wells or partially restrict all wells. By shutting in 18742 Wells Nos. 4 and 25 and re- stricting 18742 Well No. 3 to half its current rate, gas production would be reduced 1.5 MMCFD with a loss in oil production of 1077 BOPD based on latest well tests. By partially restricting all wells, the loss in oil production would be approximately 1900 BOPD. Neither course of action is desirable due to the likelihood of damage to the producing wells as defined by Finding No. 7 and Conclusion No. 3 of the Order No. 102-E dated January 28, 1974 and discussed in our letter of May 31, 1974, File: GJR-350-986.511. We therefore respectfully request authority under Rule 2 of Conservation Order No. 102-E to flare gas as an operational necessity until the ice or gas hydrate plug can be displaced from the pipeline. Yours very truly, ~~ George J. Ross Area Superintendent cc: A. M. Roney ~ 7 ,' ~1 ~O~ _~~ February 12,.1975 File: GJR-136-9$6.511 Mr. 0. K. Gilbreth, Chairman Alaska Oil and Gas Conservation Committee 3001 Porcupine Drive Anchorage, Alaska 99501 Dear Sir: ;~ fy~ Amoco Production Company P. 0. Pox 779 Anchorage, Alaska 99510 r ~, Re: Operational Necessity Flaring Granite Point Fie1c1 Rule 2 of Conservation Order No. 102-P Please refer to your December 23, 1974 Administrative Approval No. 102-E.3, wherein the Conservation Committee authorised the flaring of casinghead gas from Amoco's. Granite Point platforms until the new pipelines to the west side of Cook Inlet were operational or until February l5, 1975, whichever occurred first. Since granting this authority, Amoco has worked diligently toward completion of the pipeline. and the associated treating facility construction. Until recently, we believed we could complete the necessary construction in adequate time to comply with the Conservation Order. We now find, however, that circumstances have combined to slow construction at the Mobil facility site at Granite Point. We therefore respectfully request that the Committee extend our authority to flare casinghead gas until Maxch 15, 1975. Most significantly, we have been delayed two to three weeks by extremely cold weather in January, extensive colds and flu among workmen at the site, and air transportation availability to move bulky materials. across the Cook Inlet. In spite of these difficulties, we have completed the major construction effort and have only the electrical installation remaining along with. minor work on the two 10,000 barrel tanks. ~f"~° - 2 - ~~ Although we feel confident that cons-traction can be completed prior to March 15, we believe it prudent to request adequate construction time to insure that another extension is unnecessary. Since we haue diligently attempted to meet the February l5 timetable and have failed to meet it solely as a result of factors beyond. our control, we respectfully request an extension of authority to flare gas until March 15, 1:375. Yours eery truly, t' George J. Ross Area .Superintendent cc: A. M. Roney ~6 ~• ~o~ _~~ December 17, 1974 File: GJR-889-986.511 Mr. Homer L. Burrell, Chairman Alaska Oil and Gas Conservation Committee 3001 Porcupine Drive Anchorage, Alaska 99501 Dear Sir: • Amoco Production Company P. 0. Box 779 Anchorage, Alaska 99510 6~ ~~~ ti~ ,o Re: Operational Necessity Flaring - Granite Point Field Rule 2 of Conservation Order No. 102-E ~~ r~ ~ ~' ~y ~~ 4 ~~ ~~ ~ .~ ~+t~C - ! 1y14 Please refer to your June 4, 1974 Administrative Approval No. 102-E.2, wherein the Conservation Committee authorized the flaring of casinghead gas from Amoco's Granite Point platforms until the new pipelines to the west side of Cook Inlet-are operational or until January ~., 1975, which- ever occurred first. Since granting this authority, Amoco has completed construction of twin pipelines from our Granite Point Platform Bruce to the Mobil Oil Corporation Granite Point treating facility. Until re- cently, we believed we could also complete the associated construction at the Mobil facility and on the platforms. We now feel that construc- tion will not be completed by January 1 and we respectfully request that the Committee extend our authority to flare casinghead gas until February l5, 1975. Discussions were initiated with Mobil Oil Corporation in July to deter- mine if production from the Amoco operated Granite Point platforms could be dehydrated at their onshore treating facility. Following a thorough review of the facility capacity and future production estimates from the three Granite Point platforms, it was determined that Amoco would be required to install two 10,00© barrel tanks, a treater, a heat exchanger, pig traps, and associated piping at the Mobil facility to accommodate the additional anticipated throughput. A statement of intent was sub- sequently obtained from Mobil in September to allow this construction to begin while negotiations continued for an operating agreement. • • - 2 - Recognizing the possibility of early Cook Inlet iae conditions, we con- centrated our fall construction efforts toward all phases of the pipe- line construction work which .required ice-free water conditions. Installation of the pipeline risers on the platforms and the offshore pipelines was subsequently finished in October. Installation of the onshore segments of the pipelines coincided with initial work at the Mobil facility. The work on these line segments was completed in mid- November when the pipelines .were successfully pressure tested from the platforms to the pig traps at the Mobil facility. Shore-based construction .also .began in October following .receipt of the initial Mobil approvals and completion of a majority of .the offshore pipeline construction. Dirt and foundation work began at the onshore facility while the major treating equipment components were being moved to Granite Point. In an effort to expedite work at the Granite Point facility, we also prefabricated facility piping and buildings near .Kenai prior to barging them across Cook Inlet. erection of .the 10,000 barrel tanks began in late November and the l2' x 65' treater, heat exchanger, and glycol heater were set on .their foundations the .week of December 1. We now estimate that erection of one 10,000 barrel tank, building con- struction, and a majority of the onshore facility piping will be com- pleted in December. We estimate, however, that a major portion of the electrical installation will be completed in January along with the last portion of the onshore facility piping and the erection of the second 10,000 barrel tank. We also anticipate that piping modifications on the platforms will be completed during January. We have not experienced any single extended .delay .during pipeline con- struction. There have, however, been numerous occasions of late equip- ment delivery, workboat availability, snow and freezing weather .which have caused minor construction .delays. Combined, .these individual minor delays will apparently prevent our completion of construction by January 1, 1975. In view of .our major construction effort, our con- tinuing progress, and the minor amount of remaining work, we respect- fully request that .the Committee extend our .authority to flare casing- head gas until February 15, 1975. We submit that .this extension is appropriate as a result of our major construction effort and extremely desirable as it has been demonstrated that extended downtime may result i,n decreased well productivity. Yours .very truly, \ ,- ~. George J. Ross Area Superintendent cc: A. M. Roney, Denver V. J. Sheppard, Kenai '' ~' !~ ~ 1, ~ U ~5 _~ ~~ ~O~ Amoco Production Company ®~- P. 0. Box 779 Anchorage, Alaska 99510 May 31, 1974 ~ DIR File: GJR-350-986.511 I ' ~N`' ' 2 ~iJG 3 Et~fv Mr . Homer L . Burrell, Chairman _ j 4 "`'v Alaska Oil and Gas Conservation Committee _~ 5e\G 3001 Porcupine Drive ji cEOC Anchorage, Alaska 99501 ~' G o~ f ) Dear Sir: P~~~ ~ --REV DRAFT Re: Operational Necessity Flaring - Granite Point Field _~ sEc Rule 2 of Conservation Order No. 102-E CONFER: Please reference your letter of February l4, 1974, Re: Application of Amoco Production Company, operator for the Chakachatna Group, for adminis- trative approval pursuant to Rule 2 of Conservation Order No. 102-E to flare casnghead gas produced on Amoco Production Company's Platforms Anna and Bruce as an operational necessity for an indefinite period due to failure of the Granite Point gas pipeline. This letter granted administrate approval to flare gas as an operational necessity until July 1, 1974. Since granting this authority, Amoco's oil pipeline to Platforms Anna and Bruce broke on February 22, 1974 and required shutting in the plat- forms until a line was repaired on May 1, 1974. Currently, the platforms are producing through the repaired line, but Amoco has been unable to repair the second line and it is necessary to continue to flare gas as authorized above. Amoco, as operator for the Chakachatna Group, is planning to install new lines to the north shore and expects these lines to be operational by the end of the year. Therefore, it is requested that the authorization to flare gas to July 1, 1974, as given by the above referenced letter of February l4, 1974, be extended to January 1, 1975 or until the new lines are operational. .- ._ ~_,~_..____ This authorization would be pursuant to Rule 2 of Order No. 102-E, dated January 28, 1974, in respect to operational necessity. The opera- tional necessity is more specifically defined by Findings No. 7 and Conclusions No. 3, of the Order No. 102-E dated January 28, 1974, in which production losses have been experienced as a result of shutting in the producing wells. i ~' ~y ., f _qq .{~ 4„.J ` w ~ - ~ - As an example, the shutdown of the platforms required by the above referenced failure of the oil pipeline on February 22, 1974 .resulted in a l0% reduction in oil production. This loss is a comparison between the stabilized production since the platforms have started up after the repair of the pipeline and the production rate immediately .before the platforms .were shut-in. Specifically, the production before the break was 8118 BOPD and .currently is stabilized. at about .7289 BOPD. Sufficient time has elapsed since the pipeline was repaired to indicate that the current rate is stabilized. The fact that this reduction in oil produc- tion is a result of well damage is .substantiated by changed operational characteristics. These operational characteristics are: 1. Frequent subsurface pump changes to insure peak pump efficiencies in an attempt to bring the wells back to pre-shut-in rates, 2. Higher .surface pressures required to power the subsurface hydraulic .pumps. This indicates the subsurface .pumps are producing with a lower fluid level than pre-shut-in values. 3. More frequent subsurface .pump .changes .due to failures attributed to the lower producing fluid levels and the related increased pro- duction of abrasive formation fines. 4. The one remaining flowing well is producing very erratically and it appears that it will be necessary to .put this .well on .pump in the immediate .future. Zn order to .keep the platforms in operation and stop any .further reduc- tion in production, Amoco respectfully .requests that an authorization be granted to flare gas to January 1, 1975 or until the new north shore pipelines .become operational. It is anticipated that the net volume of excess flared gas will be 1665 MCFD over that required to maintain a safety flare and operate the platform, including the waterflood injec- tion facility. The waterflood injection facility is .currently shut down, but it is anticipated that it will be in operation in the near future. Yours very truly, -- /? ~ ~ ,~ j, N't~ ~ ti it John C. Schillereff Supervisor-in-Charge, Acting cc: A. M. Roney ~ 4 _ 1 '- j ~~ ~O~ ~~- February 1, 1974 File: GJR-066-615 J Amoco Production Company P. 0. Box 779 Anchorage, Alaska 99510 Mr. Homer L. Burrell, Chairman - _~ Alaska Oil and Gas Conservation Committee ' ~~ e,~o` ~ 3001 Porcupine Drive ~ `~~'~~~~~- Anchorage, Alaska 99501 ~I ~3'c~ci ~ "~ Dear Sir : ~ E~RAFT~~~-~ -- ~_~ ~ Re: Failure of Granite Point Gas Pipeline 2 ~, <,'~, / U~-.~ CC?NF~R; ~~~ ~ __ Now comes Amoco Production Company, operator for the Chakachatna Group, requesting Administrative Approval to flare Granite Point Field casing- head gas for an indefinite period due to failure of the Granite Point gas pipeline. Flare volumes will be approximately 3238 MCF per day from Plat- form Anna and 1227 MCF per day from Platform Bruce. A breakdown of esti- mated gas production, utilization and flare volumes is shown by attachment. As discussed in a telephone conversation between Messrs. J. R. Eaton and 0. K. Gilbreth on January 11, 1974, the Granite Point gas pipeline failed at approximately 5:30 a.m. on January 11, 1974. As a result of this failure, no pollution occurred as gas was being shipped in a normal manner at the time of failure. Since that time, operations have been normal .except that casinghead gas is being flared at the platform. We have made surveillance flights over the break area and conclude that this failure is in the general area of prior failures. Ice conditions in Cook Inlet prevent more positive identification of .the break location and the extent of the damage. In view of this, we are unable to make a realis- tic estimate of repair possibilities or the time required to accomplish this work if repair is feasible. We have been verbally informed that an Operational Necessity for Flaring order is already prepared or will soon be published. Therefore, this re- quest is made pursuant to any conditions contained in the forthcoming order. We therefore respectfully request approval of the flaring of gas as outlined herein. Yours very truly, f..~.y.,,,~ George ~~. R~'ss Area Superintendent +°` ; ~ - ~~ ~~~, ,~ ~~ Attachment ''AMOCb PRODUCTION COMPANY Granite Point Field Gas Disposition P i r or to January ll, 1974. Average Average Average Platform Gas Pilot Fuel Production Flare Usage .Platform MCF/D MCF/D MCF/D Anna 4442 449 1204 Bruce 2269. 285 1042 After January 11, 1974 Estimated Average Shore Average Facility Sales Fuel Usage Volume MCF/D MGF/D 2.30 0 2559 942 Estimated Platform Estimated Gas Fuel Flare. Production Usage Volume o platform MCF/D MCF/D MCF/D r-, _, ~ ~ Anna 4442 1204 3238 F YD T ,~ Bruce 2269 1042 1227 ,, r ~, I ~ ~~ t wr ~ ~' ~ -- .- All volumes are based on fourth quarter 1973 statistics. ~ l"'~j,~~" ~~ ~3 .~. r ~- NOTICE OF PUEiLIC NEARING STATE OF ALASKA DEPARTMENT OF NATURAL RESOURCES DIVISION OF OIL AND GAS Alaska Oil and Gas Conservation Committee Conservation File No. 102-E Re: Granite Paint Oil Field Amoco Production Company Platforms. Notice is hereby given that an application was received from Amoco Production Company on August I, (973, applying for an order amending Conser- vation Order No. 102 to allow by administrative approval a maximum of 60 days of gas flaring or venting due to operational necessity downtime. A hearing on this matter will be held in the City Council Chambers at the Z. J. Loussac Library, 5th Avenue and F Street, Anchorage, Alaska at .9:30 A.M. on September II, 1973, at which time the operator and affected and interested parties will be heard. ~ ~~a~H.l~t~"i Thomas R. PMarsha I I , J r. Executive Secretary Alaska Oil and Gas Conservation Committee 300) Porcupine Drive Anchorage, Alaska 99501 Publish August Ifs, 1973 AFFI~aVIT OF PUBLI~;ATION STATE OF ALASKA, ) THIRD JUDICIAL DISTRICT,) ss. ---- ~~ ry_---~.._ShakQ---------------- being first duly sworn on oath sre deposes and says that._....._________ is the...:Lega_1 C1eTkof 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- NOTIEf ,OF PUBLIC NFAR11~1~G- paper. That the BnneXed IS a true STATE QE-ALASKA 1)FPARTftifi:NT QF Copy of a .I,e ~.~...~j{3~~.~,e ..8051 NATURAL R'ESO(fR1ES as it was published in regular nlvlslaN OF .OIL AMfr- GAS ISSUeS (and nOt In Supplemental Alaska Oil-and Gas Conserration Committee form) of said newspaper for. a - Conservation Fi a No, n102-E _ '- ~--~ period of ..OIlQ_._..___. insertions, We: Granite. Point Qil Feld 1 5 Anroco ` Production Correpamj commencing on the _.._..____.day Platforrt+s: Q1agTaSt 73 Notice is I*ereby siven that an ap- Of ,i9 ..__._ , end plication was recgived _frarri Arnaco Production Company;- on Aususf 1, 1973, .3pplYins _for_:an order. amend= ending on the_._____'1_b...._._. day of ins Eonservation order. No. 102 fo allow by adminis#atiue approval a, Of T~~t , ~9_r_j_ ._, maximum of bo days of gas flaring: both ~a~eS InC1U51Ve, 8nd ~et or venting °due ~ operational neces-. such newspaper was regularly sfty downtrr'ne ~~ - fi x .== l distributed to its subscribers dur- A hearins on this. matier will be ing all of said period. That the held in 1he;Gty "Council' Chambers of full amount of the fee char ed the Z. J. LpussatLibrary,., Sth Avenue. g and F Strtet a~~worase, Alaska at for the foregoing publication is 9:30 A M. `on sep~ein5er 12, i973, ar which time the oeprator and 'affected 1 ~ e00 and interested parties 'wil~;6e'.heard. the sum of ~ which - amount has been paid in full at Thomas R.`NlarshaEl', 1r. the rate of 25¢ per line; Mini- - 'Execdtive'Secretatiy "- Alaska a~l~~'hd~~Gas mum charge $7.50. Conservation Committee 3oQl Porcupine- Drive ~.~ Anc€wrase~;,Alaska 4951?1 "~'~~' Publish: /lug~ust TZ~, 1973 Subscribed a sworn to before legal Notice No. ao¢1' i me this _._:~~ day of._.__,g~~~s~ X9__73 ,~ . ,, ~' _ ~~%. - .. .. ,r- ~ - ,~ ________________________'~. Y~. Notary Public in and ~~r the Stste of Alaska, Third Division, Anchorage, Alaska ~ ~IWY COMMISSION EXPIRES F!V ELLLn '~ i STATE OF ALASKA DEPARTMENT OF NATURAL RESOURCES DIVISION OP Oil. AND GAS A9aska OiI and Gas C©nservation Cammittee CONSERVATION ORDER iO5-C & IO2-E Granite Point f=ield Middle Gro~snd Shoal Field N EAR I N G September II, 1973 • PROCEE[3 i .JGS -1r. 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 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 ~Aiddle Ground Shoal field. The operators of these two, these portions of these two fields are Amoco Production Company, 5hel! Oii 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 consol°s dated these two hearings, at least for testi- many purposes. i~{otice of both hearings are published in the Anchorage Dai6y ~~lews, August 5, 1973 as required by law and regulation, 1~9y name is ~!omer F3urre{{, I'm Chairman of the Committee; to my {eft is Tom "~arshall, Exxcutive Secretary of the Oi{ and Gas Conservation Committee; to my extreme right at the end of the table is nJr. Gilbreth, O. K. Gilbreth, who is a member of the Oil and Gas Conservation Committee; to my right is P1r. ,lohn Reader, Assistant Attorney General of the State of ,~{asha. Unless somebody has something else, I'{I ask the applicant or applicants to proceed with their testimony. Ar. Crews: Thank you Mr. 9urrell. l+le have been prepared Ar, Burrell: YJould you identify youse{f? "~Ir, Crews: I'm Ralph G, Crews, and 9 represent Amoco f roduction Company and the Chakacatna cjroup for purposes of this hearing and we had originally requested that the hearings be consoiidated bait 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 adminisfi native 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 ruie in v~rhich 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 v~rould notify the Commission, and if it would appear that we would have to go beyond 96 hours, the 60 day time in arhich we applied for would begin from the first notice on the 96 hour point of time - correction from the downtime start, and we would iike to ask the Commission, first l would say i`1r, Bart Giies will be Amoco's first witness and we have other witnesses if necessary. "1r. Giles has testified many times before and we wouid ask that his qualifications for testimony be waived and we also woa~ld like to ask the Commission that they v~;ith- hold any questions of Mr. Giles until the witness for Shen 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 P„ir, Ciles will be Amooofs first witness ar:d we cali him now to the witness stand. Mr. Burreli: Unless there is objection, let the record reflect that w+e accept i~~1r, G i l es qua 1 i f i cat i ons as a expert witness . Ulou I d you s~rear h i m i n I„ir, "larsha l l': -2- • P1 r. P~larshail: Yes. Please raise your right hand. In the matter now at hearing do you swear to tall the truth, the whole truth and nothing but the truth, so hePp you God? Mr. Giles: l do. dlr. Marshall: You may be seated, thank you. P~1r.Crews: 4~1ou1d you please state your name? Mr. Giles: P.. B. Giles, with Amoco Production Company in Denver. i~1r. Crews: Hlhat is your occupation with that company? Mr. Giles: I am in an engineering capacity with Amoco in Denver. ti1r. Crews: Mr. Giles testimony will be in narrative form unless you have objection. Mr. Burrell: No objections. Mr. Giles: Gentlemen, lets turn to Exhibit 1, for Amoco, which has just been handed out, which is a three page list of situations requiring flaring due to operational necessity. P~1r. Burrell: Excuse me, P~1r. Giles, is it possible that there is any way to display this so the public can see any of these exhibits? ~1r. Giles: There are only the i32 by I i size i~lr. Burrei !, so Mr. Burrell: Ho~a 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. l~~r. Giles: Right, Do we have any more copies, why don't we just do that on the table. Per. Burrell: 1t won't go up any way on that board, it would be a little easier if it would, but 1 guess it won't will it? -3- Per, Giles: rJot really, Mr, Crews: i rather doubt unless there is some way. (~~tr, E3urreil: ( didn't bring any tape, did you? Mr, Giles: Sure didn't. •1r, Giles: Going thru this ~;moco Exhibit 1, 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 va9ves 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 vae need to do this, carry out this inspection and the last column is the estimated gas that vaould be flared under each of these situations that are listed. Those estimated gas volumes ar°e based on the average gas figures reported to you, the State, over the first six months of this year 1973, flow our Exhibit 1, is strictly a tabulation of scheduled or planned in- spections of equipment, ! kind of liken it to the fact that if you or ! were to buy an automobile we get an owners manual and in ~1-he 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 e~~er occurs first, you should get your oil changed at the point in time vahen you have driven 12,000 mites you better get your pings and points changed, at 36,G0G miles you better change the highpoured lubricant in the differential, and this is basically what Table i, or Exhibit i 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. ~r+e have tabulated on that exhibit all 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 essentia9fy 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- maf Iy repairable i tams. 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. Plow, we're going to have a witness after Shell, from Collier Chemical, who will toile about plant turn-around, but this requested order of ours and Shell:'s would also cover the need for longer periods than the planned or scheduled situations, such as underwater pipeline breaks, perish the thought. V~'e{ve had enough of those but we ne>>er know when it could happen again, and on that score f 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 fine which is fihe 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 Jung of 9970, June seems to be a favorite month of these breaks, June of f970, it took fb days to repair a break, in April of 197f, 22 days to repair a break and then on December 7, fa'?7f the line broke but we could not repair it until well into the following year and the repairs act- uaffy started the 26 of September f972 and took until the 1st of December, 1972, -5- • which is a repair length of 66 days. l think that you'll recall that last November I was here to testify on that particular situation, ~Jow on the Granite Point A line which is the oil line, August 10, 1972, we bean a repair that lasted 29 days on that line. On the P~liddie 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, ! give you those periods of time merely to support the request tl;at we're making for 60 days, °t`he maximun of 6f) 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 direc~° effect upo~~ Amoco's gas handling operations. Collier plans an annual turn-around each year Just to main- to i n the i r equipment i n gad shape, Just l i ke vre are doing the same th i nr~ by virtue of a41 the situations listed on our Exhibit 1, for our equipment and every effort vain be made by Amoco to coordinate it as much of its main~enance work as possible with the planned Collier turn-around. l-lowever, if you look at Rmoco's Exhibit l carefully, you'll see a number of situations that can not be handled at that particular time. l°d like no°a to turn to Exhibit ~, which is a detailed flour schematic of the Hmoco operated gas handling systems, On the left side of this Exhibit we show the equipment that is on tl7e 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 vrater 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 the 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 !t into evidence to allow your staff, Mr. Burrell to have it for what ever use they may see fit internal, !t 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 Shoa! well and two Granite Polnt 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. ! think you'll recall as 1 certainly do that at previous hearings on gas flaring l 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 arhen 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 i~liddie Ground Shoal 1~Je11 No, it 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 197! was shut-in while a compressor was down at that time and we lost the BCD as a producer. !t was not economical to repair it and try to get it back to the 150 barrels a day level, The welt is an excellent producer on the EFG side,at this time. Exhibit 4 'ss in Granite i'oint, the ADL 18742 #9 well, that was producing about 300 barrels of oil per day and 100 barrels of ti~~ater per day, when in -7- August of 1972, the we!! was shut-in for practically the whole month, 30 days in August, during the pipeline failure and subsequent repair that ! had talked about just a little earlier. And that well never did come back, it !n our opin- ion lost an equiiva6ent of l00 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 wel9'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 l£3742 #~l0 well, Again during the time when the welt was shut-in for 30 days in August l972, for that pipeline repair, it had been producing. prior to that time about 400 barrels of oi! 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 !40 barrel a day loss, We performed a $50,000 acid job to try to restore productivity of the well back to the 400 Barre! a day level, but we were not successful. !t 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 eve!! shut down that has been producing water along with its oil. Now there are not many examples available because vary 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 ! have is No, 6, which is an economical comparison of the value of gas thafi would be flared at current rates for the Ghakacatna - 8- L~ properties in each field, Middle Ground Shoal, South P~tiddle Ground Shoal and ~~r ~' ~.. Granite Point versus the do4lar lost by virtue of pinching back the oil ,ems duction that would eliminate the need to flare dur'sng such times when all the gas cannot be marketed. We have based this Exhibit on the annual Co#iier Plant t~.srn-around. ! th#nk the significance of Exhibit 6 is shown by comparison to the second column under the vague of pinch back oil versus the lower rictht 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 l want the Committee to be assured that we do race#ve a value now for fihe gas and so it does indeed be- hoove us to minimize any and al! downtime when we are required to be down for operations! inspection of equipment or failure, In conclusion l wou#d suggest that we continue to report monthly to you any and a## downtimes that exceed 9b hours. This is fihe present requirement. We believe it should be continued, Again as Mr, Crews had pointed out in his opening remarks, we're asking for a change in the present Orders only with respect to allowing a maximum of 60 days per event per platform to flare durinr~ any downtime or operational necessity. The 5th days would start when the do~.~n- time occured, it wou#d not be tacked on to the 96 hours, we're not asking for 64 days, we're asking for 60 as the maximum. !'ve tried to show with Exhibit I that we do have the norms! preventive maintenance program for our equipment, Nothing on Exhibit !, except for one situation, the Worthington Compressor on Baker, wou#d exceed 95 hours as we see it, By anrual 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 when we go into inspect equipment whether we might sae something tan usual 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 whi9e, 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 ofiher matters that serious. 9 be- lieve that concludes our direct testimony.. Shell will put on testimony that l 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 Shell witness and myself come back on for any questions you may have, if that's fair enough with you Mr. [=3urreil. Mr. Burrell: Thank you, N1r. 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 1 through 6 put into the record at this hearing, l~~r, Burrell: Very good, unless there is some objection we'll enter these Exhibits i thoough 6. I ~wouid like to suggest we take a break of ten minutes so that any members of the audience may look at these Exhibits he re 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 of this time. Mr> Garnet: Mr, Chairman, members of the Committee, my name is Richard Garnet, l'm with Ely, Guess & Rudd and I'm here this morning to introduce Dick Bates of the Shell ARCO Standard Group. Per. Bates is the Division mechan- icai engineer, of the t~dest Coast Division of Shell, P1r. Bates has been before this -I©- • • Committee in the past, most recently in June, this past June, so l would ask that his qualifications, the statement of his qualifications should also be waived, i t that's agreeable . Mr, Burrell: Unless there is some objection from the fly, h1r, Bates qualifies as an expert witness, Mr, Garnet: As Mr, Giles mentioned we would dike to have questions held so that they oan be presented to both P4r. Gides and Mr. Bates and their joint input oan be tapped by the Committee and also as mentioned before, following Mr, Bates testimony we wou l d I i ke to oa! l Per. MoP~ahan, Bob McPAahan, 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, d°l! let Mr. Bates take the stand. Mr. Burrell: Thank you mr, Garnet. M1~r. Marshal! will you swear him in? Mr, Marshal9: Wil! you please raise your ri~aht 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: d do, As has been stated before Mr. Marshall: Thank you. Mr-. 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 oonodusion of my testimony ! ati!! 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 paint of its sale as fuel gas at Union's Collier Chemical Plant. l will also review our operating experience since start-up of the system in November of 1972 and provide you with information conce ruing equipment failures and system shutdowns during which time the casinghead gas not used as fuel gas on the plat#orms, was flared, !n addition, l will discuss other possible events which could require flaring of casinghead gas. This testimony is intended fio present the operations and problems involved with compression of gas on the offshore platforms and its shipment to its fine! 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 2i, 1973, l want it to be mentioned at this time. All prod~.acing 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 Plafiforms and shipped via common line to the East Forelands onshore facility. Here the gas is scrubbed of ail liquids which have dropped out in sub-sea transfer line, routed through a seise meter and shipped to Union Oil Compahy's Coiiier plant where this gas !s used for fuel, The on- shore system has been shown in detail by Amoco's representative. VJe have provided Exhibit No. i, which is on the board here showing the general flour schematic of the casinghead nas from the platforms to its usage point at the chemical p9ant. For convenience ! 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 fihe Platform C~m~ression F~ciiities, 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 centrifuge! 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 P4atform A compressor package as we discussed in our testimony in June 2l, 1973, has experienced serious operating problems and shut-downs with resultant compressor drive shaft failure on May ?_5. This unit has since been rebuilt, brought bads 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. ! the #our ~~1GS 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 leas 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. Nlr. 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. ~uaf lines connect- ing the four platforms can be the lines shown horizonal9y across the schematic are also 8" concrete coated lines. However these lines were designed and are suitable for gas transmission. One of these dual lines is generally used for emulsion shipping while the other is used for natural gas shipping. -13- There are also two 8" steel, concrete coated pipelines traversing from Amoco's Platform Di!!on 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 Diiion to the facilities, The third segment, the first two being the Platform Fac°slities 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 6s again the facility shown in the Exhibit provided by Amoco. The fine! portion is the gas utilization point. Tthe gas is sold through a sales meter and then routed via one l0" 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 No Flare Order has been effective, the system or po rtions of the sys- tem have been shut down with resultant gas flaring for the following reasons. ! will present Exhibit 2 to generally outline these periods, This is a continuation of the Exhibit we presented in June again. Flaring of ail excess casinghead gas occured as a result of shutdown of Collier Plant during the period of June 22 to Juiy l4, We understand this shutdown was an annual shutdown complicated somewhat by an accident on one of the process vessels. We also understand the perioi of approximately four weeks neces- hating complete plant shutdown viii be required on an annual basis. During this period it will be an operational necessity to flare ail the gas in the MGS field except that gas used for fuel or safety flares. l4- ~~ The compressor failure on MGS Platform A which occured on May ?_6, 9973 resulted in 63 days of downtime v~rith 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 rautine operationa! downtime, These problems were covered in detail in our vane 2l testimony at which time the committee granted a temporarary exception to the No Flare Order for P~at- form A. Exhibit 2, genera9ly 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, ! wil8 again follow the portions of the casinghead gas 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 will require a major overhaul 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 faiiure, however, it is still possible that unexpected faiiure of major compressor component parts which are not locally stocked could cause delays of several days to several weeks, -15- 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 leg risers in 1966. However fibs Bines 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 Facility we have experienced two failures, one in 1967 and one in 1963. The two south Middle Ground shoal lines required preven- tive maintenance work in the summer of 1977_. These were the ones from Platform Dillon to Amoco's Onshore Facility, with resultant temporary line shutins. due to the Cook Inlet environment line faiiures-cannot be guaranteed against. Pipe- line repair could take approximately 2-d weeks, under the best of conditions, to as much as several 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 Coiner 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 comp9ete plant shutdowns with resultant gas flaring expected ann~,ally. Generally speaking the downtime of p9att~rm compression facilities wi91 affect only that platform's excess casinghead qas. However, any problems occur- icing in the pipeline or downstream facilities will affect all excess casinghead gas produced upstream from the problem area. iVe 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 p 9 ant turnaround. -l6- 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. !'l! review chronological events of repairing the Platform A compressor after its failure on May 25, 1973. The time of the (allure was 10 p,m., Friday it~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 V~lednesday May 30, to formulate plans for getting the unit back in operation. The unit was completely disassembled during the period from Jane l to June 3, this was the compressor disassembly, by factory mechanics from York and Solar, Com- ~?. -; pressor rotati-~ was shipped via air fre'sght to York's factory at York, Pa, llpon 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 awai !able 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 rerr~ved and sent to the factory in San Diego for complete disassemb9y 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 !3, The compressor was reassembled by factory mechanics and completed on July 18. On July l9 and 2!, !9 through the 2!, 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 fihe unit was brought up on line on July 2S. Although this above mentioned failure is not a part of our routine opera- tion, it does point out the time requi red to repair major uncommon equipment failures. Of the totaP 63 days downtime about 50 days were required to disassemble, ship, rebuild, and reassemble the equipment. Delay or even loss of production at ~~iddle Ground Shoal is possible if we curtail production or shutin wells. I+Je provided data to demonstrate this in our March 4, 1971, and June 2l, 1973 testimony. Our operating experience in this multi-layered field has shown thaf 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. 4^le must admit that genera!!y our data is not totally conclusive; however, there is stronca evidence to show that some damage and lost production is caused by restricting or shutting in production. Again the equivalent F3Tll value and the dollar value of the oiP 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,-`that we will not have casinghead gas for sale after 19f32. We will then use this gas for fuel and will be required to provide an outside source of gas. - ! 8- !n summary we recommend that Order No. 105 be amended such that the Com- mittee can administratively grant the operator up to F0 days per event per pPat- form of excess casinghead gas flarincr 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 eiasped as now available in Order No. i05. Reporting of down time should be on a monthly basis until the event is corrected. Further, gas fared onshore for any operational necessity should be considered as, and accounted as, gas flared on individual platforms, That is we are not distinguishing ~Nhether the gas is flared on a platform or onshore, if it is produced by that platform and flared then it should be considered as feared gas. We feel that 60 days ner 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 hreakdoavns or pio2- line leaks, Gentlemen, this concludes my testimony on this matter. Mr, Burrell: Thank you, PAr, Bates. Would you like to introduce your Exhibits into the record tCan't understand.) Mr. Bates: Yes sir, they were prepared under my supervision, Mr, Burrell: Shell Exhibits I and 2? Mr. Bates: Yes sir. Mr. Burre l I : Thank you, She i I's Exhibits I and 2. n~tr. Bates, Mr. P~larsha I wants to know if you have any small copies? Mr. Bates: Yes I do. Mr. Burrell: Are they identical to the large ones? Mr. Bates: Yes they are, i have a couple copies I believe. -19- 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: "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, h1cPAahan present his testimony first, P/Ir. Barre I I : I think we' I I just ask Mr, h1cPlah~n to testify, to get the who l e thing done at once. I °w i i I ask one thing, i n fact th i s a I so app I i es to ~~r. 1~1cMahc~n 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 aids who type it? ^~r. Garnet: Alright at th i s time I' ! I ask Mr. Mc~~aho,~ to come to the witness chair. Mr. Chairman I don't believe ~-1r. McMan has been before this Committee, if I'm not mistaken, so I 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. McP~ahon : My name i s Robert D. Mc~Aahon . P~1r. Barrel I: °fhank you, Mr. ~•dcMahon: 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 1950. In the 2~ 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 iJnion Collier group. For the past two years 1 have been the manager of the Collier Facility in Kenai. -20- Mr, Burrell: Does anybody have any questions for Mc"_lahon, unless there is an objection, we'll accept his qualifications as an expert witness. 1'Il 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 whole truth and nothing but the truth, so help you Cod? Mr. ~"~cMahon : I do. Mr. Marshall: Please be seated, Mr. Garnet: M'r:.'McMahon, 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 far. Mr. McMahon: Let me say first, that 1 do not have written data in support of what I say, I 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 is the synonym for overhaul period or maintenance repair period, or what have you, and it is somethin~a 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, repl-ace catalysts that may be exhausted, to replace defective metallury and so forth, 1^!e hope normally to accomplish al! 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 prototype, somewhat developmental, we have run into problems that have sometimes run somewhat longer than four weeks. On one occasion because of -21- a severe nrobiem with a metallurgical castine~ 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. t^!e 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 all operatinn efficiency then would 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 unknoum reason, we have the duration of approximately one week. In summary gentlemen l would say that is about the way we approach our main- tenance and operating philosophy, i`~r. Garnet: Thank you Mr. McMahon. Mr. Burrell: Thank you ~4r. McMahon. I think at this time we are ready for questions, I'm sure we will have some. PAr. Gilbreth, would you like to start with the questions? p^r, Gilbreth: Yes, I'd like to start back with Mr. Giles. Per. Giles in the earlier part of your testimony you mentioned several line breaks, I figured it was one or two were oi! 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 carry t nca gas . -22- Nir. 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 Raker B line between Baker and Shell A, which would be essentially be a qas line. ~Ir. Gilbreth: On your Exhibit 5, Mr, Giles, looking at the oi! production curve and the water production curve, it appears that after the shutdown that you have recited that the productivity oft the we!! itself determined by total fluids was considerably reduced, Mr. Giles: considerably P.~r. Gi(breth: reduced, and then your Exhibit shows that a $50,000 .acid job was required to restore the productivity. Boring the interim between the acid job and the time the wel! was shutdown, did, have you eliminated the possib- ilities of problems with the producing equipment itself, with the equipment of this nature, (n other words do you think this reduction is entire9y and con- clusively due to reservoir capacity to produce? Mr. Giles: Well ;~ Lj ~ ~ ;,* .4.i subs rvice equipment, job, so we sti!( bell the acid job was to clean, i t was not i n ~ii~ °"i'Ysce of eve that this lends pretty basically to clean the scale from sr,F ~ ~., a imagination an acid rack ~t rong evidence. That we aet an adverse effect from exposure to this produced wafter on the farmation face. We don't know a!I the answers to this question, but we are concerned as we will be producing more and mare water with time and more and more wells can be expected to be effected, no matter what the reason for shutdown. 1~1r. Gi(breth: I noticed in all of the curves that you did present here, that wells were making considerable quantities of water, anywhere from 1,000 barrels a days -23- Mr, riles: t<lo, you'll have to go to the right hand side of the graph for the water. Mr. Gilbreth: 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. Gilbreth: Yes. Qn your Exhibit 6, 1 believe your testimony was that this was indicative of the values of oil and gas during the period of shutdown or turnaround. 1=or what period of time was this calculated? Mr. Giles: This aras calculated on a five weeks basis. Eiow if you qo to h1 r. McMahon's customary four week turnaround, that he states is customary, achy Just take 415 of all the values but the values will remain in relation to one another, Mr. Gilbreth: In your recitation of downtime that has occured from your properties.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: ! 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 I think we have to be practical about this, as the equipment gets older and we get into it on these annual Inspections, l think +ae're going to learn that metallurigical failures are about to occur and we're going to encounter problems that here-fare we have not had, which aril! lengthen the downtime requirement. -24- Mr. Gilbreth: Well hopefully the-:inspections will preclude that, On your exhibit No> 2, as l red the Exhibit, all the gas produced from fihe Baker, Shell Shell and Dillon, all goes through a common Iine to Platform Dillon and then ctoseto shore, ~1r. 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. Nir> Giles: No, those lines cannot do that, Mr. Gilbreth: 1'd like to ask Mr> Bates, you mentioned the problems that you'd had with your Shel! A Platform compressor, indicated it's operating now below 90~ of a design rated speed, what about your platform? i~ir. Bates: it's still operating;, it's below 9O, I believe it's about 85 o r 86~, has a full capacity to flare gas at that rate, Nir, G i l t reth : Okay, w i th .both p l atforms aperat i ng i n th i s range, are you able to still move all the produced gas to shore, all except what is necessary for emergency purposes . P9r. Bates: Yes sir. Mr, Gilbreth: In your testimony PAr. E3ates, you indicated that the failure of the compressor on Platform A had required about 6~ days, at least you flared gas for 64 days, if i understood, Per , ''3ates : I be 1 i eve i t was 63 , Mr. Gilbreth: 63, alrighfi. Now the order that you have requested here then would in fact not let you produce those last three days, would et not. -?_5- 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 reassembly, the other 13 days were consumed at the beginning, 3 or 4 days of engineering and at the end hooking up of a!! the safety devices and running performance tests, indeed work we had done at York, Pa, had corrected<ti'is 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. f~1r. Oi lbreth: The reason l'm asking this question, Pelt, Mc P~ahon 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 youPre requesting the 60 days was because of the Platform A type occurrence or why the 60 days. It wouldn't fit into ?latform A and yet it is considerable lo;~ger than the normal that you'd expect. Per. Bates: I feel generally that the major abnormal types of equipment breakdown or line break could be repaired within 60 days, 30 days is too short ! --- C'an't understand --- ) I 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? P~lr. 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. !t is very hard to pin down the exact number. Mr. Giibreth: 4~Jould you object to an order being written with a lesser per- sod for without having to come to this Committee, but with the Committee to have administrative authority to grant up to b0 days. h4r. Hates: 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 flaring. i•~r. Giibreth: 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 anofiher wouid flare 60 more . Mr, Bates: ado, now ! see what you're saying but I guess in theory that could happen, except we wouid have to come in after 96 hours and request the Committee's approval to fiare gas,l believe that was indicated in the - where the Committee would give its approve! or not give its approval, therefore if we violated our business obligation„ you still have control. ~4r. Giibreth: Let me see, if i understand you right. As i 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 wouid come to the Committee to get approval to fiare 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 wouid be obligated to tail you we are down we are flaring and i feel we wouid be obligated to give you at least an idea of how long we wouid be dawn. Mr. Giles: Can I c9arify my view on that. i view the present 96 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 loner than 9fi hours and we must -27- • follow up later on and tel9 you when its been fixed. We want to continue a9l that. 9 don't think that our view is that we would be asking for your approval per sey to go beyond 96 hours, Mr. P~arshall: Mr, Giles, 1 wonder if 1 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 1 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 l~Jo. 102," r~r, LaGrone, letter uses similar language, as a matter of fact Conservatian Orders l05 and 102, Rule 3 says, °' the commencment, nature, and termination of all emergencies requiring flaring of casinghead gas in excess of the amount required for the safety flaring shal9 be reported to the Committe 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 'sf we're talking about proposed language, gets 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 pew occurrence per event per platform within which to f9are. We do not intend to use 60 days on each event, of course not, but as Mr, ~3ates 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, 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 do too, that we've come to a stage in these fields when administrative approval rather than hearin®s on everything is the best course of action. This is whet we're. asking. Pair. Gilbreth: Let me throw this out at you. On the west side of the Inlet the operators have similar problems and my recollection 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 !5 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 mayor things -the long periods and a large volume that we're concerned with, Would you have obJection to an order patterned something like that, P4r. Giles: Basically what you're then saying is rather than 60 days per e~aent per platform, you're saying 60 days per year per platform? Mr. Gilbreth: Yes, yes. Mr, Marshall: That is, but after that time, then you've got to come to us fc~r Administ native approval which we can give. M r. 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, °ss that if you have a problem which you think is going to take 60 days, then we give you administrative -29- approval to flare gay in 60 days, but it's actually 62 days, then what are we going to do, are we goi+na to shot you down right there, are talking about a public hearing, ~vs don't have time to publish, 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 6th days sometimes„ Now 9 think we've boxing ourseives in again on the 60 day thing, 1 think that there's going to be times when you're going to be flaring a lot less than you expect and than 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 +.~e're looking at anywhere from 12 to 15 days to eftectively do that, we've been up against this sort of thing before and I really believe if you,.. if the Committee has discretion to admin'sstratively permit the flaring beyond a certain time, we can look the sit- uation 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, P_~r. 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 l5 days per quarter, per platform, that's automatic and if .~~e needed more than 15 days ner 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 9~re, or how do you end, past the end date on? Mr. Sorrell: Let me interrupt here, if l may. The existing orders 1~5 and lQ2_, on the east side, have no provisions for flaring for cases of operational -3G_ necessity, we only said you can't flare at all. it says if you have to flare in case of emergency, however yo+.~ have to let us know in 96 hours. f~,iow we use a rather restrictive definition of emergency, until higher administrative authority or the cox~rts 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 that 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 i5 days per calendar quarter per platform and any flaring onshore will be allocated back to ai! p~at- forms. Onshore facilities, flaring serving two platforms wii! be aliocated 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 Bare more, and use up the i5 days per calendar quarter, they come to us and fel! us how much longer they think they will have to keep fisting and ask for an administrative order, which we may give them, trJe could give them ona for lfl years theoretically. As a practical matter, if it looks like a major problem, he may very wel! elect to go a public hearing because any number of circumstances could justify that, Suppose the Collier Plant went down for g0 days, for e,cample, that's sounds like you have a pretty good reason Mr. Gi ies: '~lel 1, Nir. Burrell: Excuse me, by Char time circumstances may have changed. There may be an alternative market available to you. l~Je 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 -3l- what started the ~~m-flare orders in the first place. It is our opinion, that there was a market and na~w it is being marketed so we're not always right. Mr. Bates: Are you empowered now in F02 and l05 to allow us to flare by administrative order for any periods desired. P~~r. Burrell: lvo, flaring is prohibited under l05 and 102. iexcept for emergencies. 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 l05 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: rio, that's alright. Mr. Gilbreth: We're finding more and more as you people are, there's alot of administrative headaches in trying #o administer this, and l'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 so we know where we are headed, Mr. Giles: l think with that understanding, to answer your question, we could live with that> Mr. Sates: ~~1y only question here is if you have operational necessity after your l5 days in that quarter, must you qo to public hearing or can the Committee administratively extend your flare period. "fir. Barre I ! ; l)nder the west s i de orders we can q i ve an admi n i stmt i tie extension. Mr. Bates: That would be the same for 102 and 105. h~tr. Giles: That would be at the discretion of the Committee, -32- Mr, Burrell: yes, we could call a public hearinti if we saw fit. Mr, Giles: Depends upon what you hear from us? Mr. Bates: Well, l think you have that right at all times, P_7 r, Gilbreth: Well, we're, l know l personally, I don°t know about the rest of the Committee, bat !'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: UJhat you're reviewing and °Nhat our real objectives, are really about the same. UJhat aye°ve been after is not having to come to hearings, ti l ! something breaks down and we're notified y~?u and you don't have an~~ pcwer to use your judgment to say, yes, you have a breakdown, we understand this breakdown, but there is nothing we can do about it, Mr, Burrell: ! think, speaking for myself, rather than the whole Committee, ! think my position is that we have these minor items under Amoco's Exhibit !, there is nothing on there any lon~~er than !0 days, scheduled for more than !0 days.. 1^lith the exception of the one instance of the Shell PBatform, l don't know of anything that's been over fifteen days, since no-f9are order has been in effect, ! don't know cf any shutdowns since the no-flare order went into effect, with thafi 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 - !, restrict production; 2,fin alternative 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 !5 days per quarter to jump in and say, well how come you don't do this, and have a public -33- • heating.on it. C3oes that add anything? Mr. Bates: h9r. Burrell, has the order already been published in accor- 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 l had discussed previously with Mr. Marshall, perhaps maybe sEJbmitting a proposed form of order far your consideration. if we're going to do 1 might look at the one already written. Mr. Burrell: l assume this draft is, this is the 37th and fina9 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 Sheii's and Amoco " s. Mr. Giibreth: l 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. l'd like to ask you individually is it not noaJ feasible to reinject this used gas from these, two fields, so that excess gas would not go through an emergency fisting. Mr. Giles. I'm Mr. Giles, back into the formation from which it was produced? Mr. Gi9breth: Yes. Mr. Giles: !t 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- • C~ Mr, Gilbreth: Deferring to the Middle Ground Shoal, particularly the A Pool l 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'es is Bates with regard to your point, it I remember right, it would about 3000 or 3200 psi to inject gas into this pool in our area, Mr, Bates: 4~h`i ~e PAr. Giles is thinking i guess, l' I l answer first of al! in context with his answer aboufi injecting in the producing formations, We would have the same mobility ratio problems, !n addition we have been water flooding Middle Ground Shoal and we have not reduced bottom hole pressure to that great of an extent, We're replacsng produced fluids with water and maintaining the reservoir above the bubbly point, Therefore we do not have a situation where we're asking to~reduce the injection pressure for natural gas i n the reservoir. Mr. Gilbreth: 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, 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- LJ r~ L 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. Do either of you see any poss'sble equipment failure there that would result in down-handling about what we talked about here today, I think that had been dis- cussed. Mr. Giles: Not knowing much about much about Union's system from the 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. M r. 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 fihink 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 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, Gilcs: Therefore we would notify you. Mr, Bates: Alright, that would be the situation, but again 'rf URiOn were down for more than l5 days depending on the case you'd have the authority to admin- istratively allow us to flare or call a hearing under the l5 day plan. Mr. Burrell: Gentlemen, one other provision to the proposed order an the west side fields is also concerned with yours and l should call your attention to -36- i ~ it and that's the reportment requirement. In the event there is any flaring of operationa! necessity during the month, any at al! for operational necessities distinguished from emergencies, would require be reported with'sn 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- tiona! necessity and number of days or hours duration. Pardon me? ~uarteriy. 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: !'ve haven't seen the last draft, obviously. Mr. Bates: Well, you know we're at a littie bit of a handicap, because you've looked at it 37 times, and we have not yet seen it. Mr. Gilbreth: Wiii you would see no objection to that type of a inclusion? Mr. ? No. Mr. Gilbreth: That's ali the questions ! have. Mr. P~7arsahll: ! 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: lJsually a month Mr. Marshall: Usually 3C 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 some of the parts you're talking about. ! suppose they don't lend -37- themselves readily to come up on an airline, could you just give a little light on that please sir. Mr. McP~lahon: Our turnaround is usua!!y very thoroughly planned operation and we have a!l 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 lone term deliver°s es that delayed the start-up, but it is not inconce'rvabte that it could happen. The one that l mentioned when ! 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, 9Ne'd tried to ferret them all out, but because of the complexity of the system, the fact we're cutting a tight rope along metalurgica! and machinery new horizons, I'd say, we cannot always foresee that that kind of thing may not happen. Mr. Marshall: Thank you. N1 r. Burrell: I believe that one of you testified that you attempted to schedule your platform turnaround, compressors or whatever it may be, with the Co! ! ier turnaround. -. Giles: 6Ve both testified to that point sir. Mr. Burrell: That of course would be to your advantage with a l5 day order limit, wouldn't it? Mr. ? No, not necessarily. Mr. Gilbreth: l~r. McP9ahon, how far in advance do you schedule these -38- s • turnarounds and do you notify the operator, how much notice do you give the operator? Mr. 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 Day and that we would foresee a four week outage at that time. Mr. Gilbreth: I see. Mr. McP~lahon: And our communication with the operators, we're dealing exclusively with Union Oi! 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 a!l the notice they need to try to do any of their own schedu.t:ing to coincide with the plant turnaround Mr. Giles: Oil yes if they do what they Just said, why it would be fine. I exprect they will. Mr. Gilbreth: Well, is that, is it working in practice? Per. McMahon: bVe 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 Priday before you were scheduled for turnaround on PAonday 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. N1r.'Burrell: Let me ask Mr. Giles and Mr. Bates a question. Can the gas from Midd9e Ground Shoal or Granite Point or both, casigghead gas can it be used in the Swanson River'Field for pressure ization, in the event that the -3g_ Col9ier i'lant is not available for th°os fue! source or as the supplier, or as the market. Mr. tai ! es: No, blot w i thout a great deg! of expense cc~;~ ! t i t be done, no. Mr. Barre!!: !n other' words what is wr'ont~ with it? !s it too heavy? l~~r, Ciles: No, it's crude o°s! press+a re and we°ve already testified at previous hearings on the gas flare Situation several times over that, probab9y will not ever receive a pay out of the investment put into this system al- ready and to compound that with added investment to accomplish something else would just compound our' situation in reverse effect, a negative effect. t~ir, Burred: ! j+.ast wanted to hear it, Does anybody in the audience have any questions of any of the witnesses or the Committee or anybody? Any- oody like to make a statement? We'!! adjourn then. Thank you. -40- A copy of the Hearing for Conservation Order 102-E. can be found in the file for Conservation Order 105-C. ( the two-hearings are. covered in one transcript} * 1 ~~ ~O~ ~'- August 1, 1973 ' • ~~~ Amoco Production Comp Security Life Building Denver, Colorado 80202 Filer : VDP-349-986.511 DIR G GEOL ~. ENG 1 ENG 2 ENG --.. . _.. 3 ENG 4 L-NG S ENG 1 GEOL 4 GEOL 3 GEOL Mr . Homer L . 'Burrell (4) © (~~ ~ " ~ l " DRAFT Alaska 0i1 and Gas Conservation Committee ~`~ `""' ~ ~ ~ ~ SEC Division of Oil and Gas ,~ ,~ ~ ,. ~ ~~ CONFER: 30'0'1'Porcupne-Drive ~'~,'? -- ~ ~'"' FILE: n ; Anchorage, Alaska 99504. ~".~ ,,3:~ i. ' ' ~' I°~ ~G~a Dear Mr. Burrell: i C' 41~ ~° h ~~ ~ ~.J ~~ .Subject:.. Application for Amendment of Alaska Conservation Order No. 102, Granite Point Field Amoco, Operator in the subject field; on behalf of the Chakachatna Group respectfully requests that the Alaska Oil and Gas Conservation Committee Bold a .public hearing for the purpose of amending State of Alaska. Conservation Order No , 102' to allow the- flaring or venting during operational necessity downtime by administrative permission. 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 Conservation Order No , 102'. Consequently; we request that the Committee, as a result of the herein requested hearing,. grant an operator by administrative action without a hearing a maximum of 60 days within which. it may flare or vent gas because of any operational necessity. Such requested future flaring would be separate and apart from the amount necessary for adequate safety flares and be separate and apart from the amount required in emergency situations . ,~ We suggest that. this application be: heard. the same day th Shell' application for the same purpose and our separate application for the same .purpose, both concern- ing Middle Ground Shoal Field; are set for hearing,. for the convenience of all parties . Yours very trul1ly, b rl . Gi s • • File:: VDP-349-986.511 August 1, 1973 Page 2 cc: Mr. H. A. Slack. Atlantic. Richfield Company P . O . Box 36'0 Anchorage., .Alaska: 99501' Mr. F. L.'Franz Skelly Oil Comp any 1088 Lincoln Tower Building Denver, Colorado 80203 ' Mr . J . P ..Denny Phillips Petroleum Company 130'0' Security Life Building Denver, Colorado 80202 Mr. J. W. Walker Standard Oil Company of California P. O. Box 7-839 Anchorage, Alaska. 99501 Mr . W . M . Jones Amoco Production Company P, O. Box 779 Anchorage., .Alaska 99501 Mr . H . O . Hickman Amoco .Production Company Security Life Building Denver, Colorado 80202' Mr . Ralph G. Crews a 1, :~ ~ ~ '~ ' ~ ~~ ~ !'1 ~ ! ~ ' First National Building -~ , 425'. "G" Street ~-a Anchorage, .Alaska: 99501 ~~ ji~l " `~ ~` f'' i
