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Home My WebLink AboutO 066 • Other Index #066 1. November 3, 2010 Notice of Hearing, Affidavit of Publication 2. December 6, 2010 Public Hearing Transcript Other Index #066 • • STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West 7 Avenue, Suite 100 Anchorage, Alaska 99501 Re: AN ORDER rescinding those rules within ) Docket Number: CO -10 -21 existing Conservation Orders relating to ) Other Order No. 66 well safety valve systems. ) ) Statewide, Alaska ) January 11, 2011 IT APPEARING THAT: 1. On October 13, 2010 the Alaska Oil and Gas Conservation Commission (AOGCC or Commission) formally adopted new regulations relating to well safety valve systems, at 20 AAC 25.265. 2. The newly adopted well safety valve system regulations underwent final review by the Regulations Section of the Alaska Attorney General's Office and were forwarded to the Alaska Lieutenant Governor's Office on October 28, 2010. 3. The new regulations were signed by the Lieutenant Governor and took legal effect on December 3, 2010. 4. To ensure consistency with the new regulations, the AOGCC, on its own motion, proposed to rescind part or all of the outdated rules within existing Commission Orders relating to well safety valve systems. 5. On November 4, 2010, pursuant to 20 AAC 25.540, the Commission published in the Alaska Daily News notice of opportunity for public hearing on December 6, 2010. 6. The Commission received written comments in response to its public notice, and held a public hearing on December 7, 2010. 7. Oral testimony and written comments were provided at the December 7, 2010 hearing. FINDINGS: 1. Well safety valve systems are regulated under newly- adopted 20 AAC 25.265, which consolidates the requirements previously established in legacy documents, policies, and statewide guidelines relating to safety valve systems. 2. Thirty -four existing Commission Orders contain rules governing well safety valve systems. Twenty of those Orders contain broad regulatory requirements for safety valve systems that are now covered by the newly- adopted regulations. The remaining fourteen Orders include field- or pool - specific safety valve system requirements. Other Order 66 • • Page 2 Statewide, AK January 11, 2011 3. Within existing Commission Orders are rules unrelated to well safety valve systems; these rules will continue in effect, unmodified. 4. Existing Commission Orders containing individual rules relating to well safety valve systems are enumerated in the attached Table. CONCLUSIONS: 1. Eliminating redundant requirements and standardizing wording for those field - and pool- specific safety valve system requirements deemed appropriate to retain will improve regulatory clarity. 2. Twenty existing Commission Orders that include rules relating to well safety valve systems are rendered unnecessary, and can be replaced by newly- adopted 20 AAC 25.265. As more fully set forth in the attached Table, those Orders are Conservation Orders 98A, 207A, 300, 311B, 317B, 329A, 341E, 345, 402B, 432D, 452, 457B, 471, 477, 484A, 505B, 553, 559, 570, and a Commission unnumbered Order signed March 30, 1994 (policy dictating SVS performance testing requirements). 3. Fourteen existing Commission Orders include field- or pool- specific safety valve system requirements that the Commission considers appropriate for retention. Wording for the same safety valve system requirements existing in different Commission Orders has been standardized. As more fully set forth in the attached Table, those Orders are Conservation Orders 406B, 423, 430A, 435A, 443B, 449, 456A, 458A, 562, 563, 569, 596, 597, and 605. NOW, THEREFORE, IT IS ORDERED THAT individual rules in thirty-four existing Commission Orders that relate to well safety valve systems are hereby rescinded or revised as enumerated in the Table. Remaining rules unrelated to safety valve systems within affected Commission Orders remain in effect, unmodified. DONE at Anchorage, Alaska, and dated ail .- ary 11, 2011 `1 1100 Daniel T. Sear ou., Commissioner, Chair A - . • it . • : s Conservation Commission Alli ; .a 014 , 0 fr ' IV ill . • aman, Co ner a Oi , • a Conserva ion Commission A p, - - - a ��N �' ' Cat y P. oerst r, Commissioner Alaska 11 and Gas Conservation Commission Other Order 66 • • Page 3 Statewide, AK January 11, 2011 RECONSIDERATION AND APPEAL NOTICE As provided in AS 31.05.080(a), within 20 days after written notice of the entry of this order or decision, or such further time as the Commission grants for good cause shown, a person affected by it may file with the Commission an application for reconsideration of the matter determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration must set out the respect in which the order or decision is believed to be erroneous. The Commission shall grant or refuse the application for reconsideration in whole or in part within 10 days after it is filed. Failure to act on it within 10 -days is a denial of reconsideration. If the Commission denies reconsideration, upon denial, this order or decision and the denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after the date on which the Commission mails, OR 30 days if the Commission otherwise distributes, the order or decision denying reconsideration, UNLESS the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which the application for reconsideration was filed. If the Commission grants an application for reconsideration, this order or decision does not become final. Rather, the order or decision on reconsideration will be the FINAL order or decision of the Commission, and it may be appealed to superior court. That appeal MUST be filed within 33 days after the date on which the Commission mails, OR 30 days if the Commission otherwise distributes, the order or decision on reconsideration. As provided in AS 31.05.080(b), "[t]he questions reviewed on appeal are limited to the questions presented to the Commission by the application for reconsideration." In computing a period of time above, the date of the event or default after which the designated period begins to run is not included in the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00 p.m. on the next day that does not fall on a weekend or state holiday. • • . • Orders Establishing Requirements for Well Safety Valve Systems 1/7/2011 Unit/Field Pool Conservation Rule Rescind Rule? Existing Order Requirement New Regulation Provisions Revised Rule - "Well safety valve systems" (2) Comment Order (1) Addressing Reqts from Order fail -safe auto SSV and SCSSV; injection wells (except disposal) require ; 25.265(b); 25.265 d 2 H "Injection wells (excluding disposal injectors) must be equipped w ith(i) a double check valve 25.265 a Check valve requirements injectors for injectors are not covered b y Colville River Unit Qannik 605 5 no 0) double check valve, or (ii) single check valve and SSV; injection 25.265(a); ) ( )( )( )' arrangement or (ii) a single check valve and a SSV. A subsurface - controlled injection valve or 25.265(h)(5) requirements readopted regulation valve satisfies single check valve requirement; test every 6 months SCSSV satisfies the quirements of a single check valve." fail -safe auto SSV and SCSSV; injection wells (except disposal) require "I wells (excluding disposal injectors) must be equipped with(i) a double check valve 25.265(a); 25.2659(b); 25.265(d)(1); Check valve requirements for injectors are not covered by Oooguruk Oooguruk - Nuiqsut 597 6 no (i) double check valve, or (ii) single check valve and SSV; injection . arrangement or (ii) a single check valve and a SSV. A subsurface - controlled injection valve or 25.265(h)(5) readopted regulation valve satisfies single check valve requirement; test every 6 months ( )( 5 ) SCSSV satisfies the requirements of a single check valve." fail -safe auto SSV and SCSSV; injection wells (except disposal) require "I wells (excluding disposal injectors) must be equipped with(i) a double check valve 25.265(a); 25.265(b); 25.265(d)(1); Check valve requirements for injectors are not covered by Oooguruk Oooguruk - Kuparuk 596 6 no (i) double check valve, or (ii) single check valve and SSV; injection h . arrangement or (ii) a single check valve and a SSV. A subsurface - controlled injection valve or 25.265(h)(5) readopted regulation valve satisfies single check valve requirement; test every 6 months ( )( 5 ) SCSSV satisfies the requirements of a single check valve." 1 fail -safe auto SSV and SCSSV; maintain list of wells w/ removed or 25.265(a); 25.265(b); 25.265(d)(2)(F); Requirement to maintain a wellhead sign and list of wells with Prudhoe Bay Unit Raven 570 5 yes r N/A deactivated SVS was replaced with requirement to maintain a deactivated SVS; sign on wellhead 25.265(m) tag on well when not manned fail -safe auto SSV and SCSSV; injection wells (except disposal) require 25.26�- " wells (excluding disposal injectors) must be equipped with(i) a double check valve 25.265(a); 25.265(b); 25.265(d)(2)(H)' Check valve requirements for injectors are not covered by Colville River Unit Fiord 569 5 no (i) double check valve, or (ii) single check valve and SSV; injection .265 arrangement or (ii) a single check valve and a SSV. A subsurface - controlled injection valve or 25.265(h)(5) readopted regulation valve satisfies single check valve requirement; test every 6 months ( )( 5 ) SCSSV satisfies the requirements of a single check valve." fail -safe auto SSV and SCSSV; injection wells (except disposal) require "I wells (excluding disposal injectors) must be equipped with(i) a double check valve 25.265(a); 25.265(b); 25.265(d)(2)(H); Check valve requirements for injectors are not covered by Colville River Unit Nanuq - Kuparuk 563 6 no (i) double check valve, or (ii) single check valve and SSV; injection . arrangement or (ii) a single check valve and a SSV. A subsurface - controlled injection valve or 25.265(h)(5) readopted regulation valve satisfies single check valve requirement; test every 6 months ( )( 5 ) SCSSV satisfies the requirements of a single check valve." fail -safe auto SSV and SCSSV; injection wells (except disposal) require r "I nject i on we ll s (exc disposal injectors) must be equipped with(i) a double check valve 25.265(a); 25 25 Check valve requirements for injectors are not covered by Colville River Unit Nanuq 562 6 no (i) double check valve, or (ii) single check valve and SSV; injection . arrangement or (ii) a single check valve and a SSV. A subsurface- controlled injection valve or 25.265(h)(5) readopted regulation valve satisfies single check valve requirement; test every 6 months ( )( 5 ) SCSSV satisfies the requirements of a single check valve." Prudhoe Ba Unit Put River 559 3 yes fail -safe auto SSV; SSSV landing nipple below permafrost; test as 25.265(a); 25.265(b); 25.265(d); N/A Readopted 25.265(d) dictates which wells require SSSV; Y prescribed by Commission 25.265(h)(5) replaces SSSV nipple requirement for all wells Deep Creek Unit Happy Valley 553 3 yes SSV or SSSV s 25.265 N/A Prudhoe Ba Unit Orion 505B 3 yes fail -safe auto SSV; SSSV landing nipple below permafrost; test as 25.265(a); 25.265(b); 25.265(d); N/A Readopted 25.265(d) dictates which wells require SSSV; Y prescribed by Commission 25.265(h)(5) replaces SSSV nipple requirement for all wells Prudhoe Ba Unit Polaris 484A 3 yes fail -safe auto SSV; SSSV landing nipple below permafrost; test as 25.265(a); 25.265(b); 25.265(d); N/A Readopted 25.265(d) dictates which wells require SSSV; Y prescribed by Commission 25.265(h)(5) replaces SSSV nipple requirement for all wells _ fail -safe auto SSV; SSSV landing nipple below permafrost; gas /MI 25.26li a ; 25.265 b 2 Milne Point - () (); 25.265(d); Readopted 25.265(d) dictates which wells require SSSV; Milne Point Unit Schrader Bluff 477 5 yes injection well require SSSV or injection valve below permafrost; test 25.265(h)(5) N/A replaces SSSV nipple requirement for all wells every 6 months Prudhoe Ba Unit Borealis 471 3 yes fail -safe auto SSV; SSSV landing nipple below permafrost; gas /MI 25.265(a); 25.265(b); 25.265(d); WA Readopted 25.265(d) dictates which wells require SSSV; Y injection well require SSSV below permafrost; test every 6 months 25.265(h)(5) replaces SSSV nipple requirement for all wells fail -safe auto SSV and SCSSV; test as prescribed by Commission; 500- Existing pool rule established a minimum setting depth for the Northstar Northstar 458A 4 no ft minimum setting depth for SSSV 25.265(a); 25.265(b); 25.265(d)(1) The minimum setting depth for a tubing conveyed subsurface safety valve is 500 feet." SSSV Prudhoe Ba Unit Aurora 457B 3 es fail -safe auto SSV; SSSV landing nipple below permafrost; test every 6 25.265(a); 25.265(b); 25.265(d); N/A Readopted 25.265(d) dictates which wells require SSSV; Y Y months 25.265(h)(5) replaces SSSV nipple requirement for all wells fail -safe auto SSV; gas /MI injectors require SSV and single check 25.265(a); 25.265(b); 25.265(d); "Injection wells (excluding disposal injectors) must be equipped with(i) a double check valve Check valve requirements for injectors are not covered by Kuparuk River Unit Meltwater 456A 5 no valve and SSSV landing nipple; water injection wells require (1) double arrangement or (ii) a single check valve and a SSV. A subsurface controlled injection valve or readopted regulation; readopted 25.265(d)(5) does not include check valve, or (ii) single check valve and SSV; test every 6 months 25 SCSSV satisfies the requirements of a single check valve." SSSV requirement for MI injectors - Prudhoe Bay Unit Midnight Sun 452 6 yes fail -safe auto SSV (all injectors and producers capable of unassisted 25.265(a); 25.265(b); 25.265(d); N/A Readopted 25.265(d) dictates which wells require SSSV; flow to surface); test every 6 months 25.265(h)(5) replaces SSSV nipple requirement for all wells fail -safe auto SSV and SCSSV; SSSV may be installed above or below "The setting depth of a required subsurface safety valve must be located in the tubing either Existing pool rule established alternate SSSV setting depth; 25.265(a); 25.265(b); 25.265(d)(1); Duck Island Unit Eider 449 7 no permafrost; injection wells require double check valve; LPS trip above or below permafrost. Injection wells must be equipped with a double check valve check valve requirements for injectors are not covered by pressure; test every 6 months 25 arrangement." readopted regulation fail -safe auto SSV and SCSSV (producers and gas injectors); water "Injection wells (excluding disposal injectors) must be equipped with(i) a double check valve Check valve requirements for injectors are not covered by Colville River Unit Alpine 443B 5 no injection wells require (i) double check valve, or (ii) single check valve 25.265(a); 25.265(b); 25.265(d)(2)(H) arrangement or (ii) a single check valve and a SSV. A subsurface - controlled injection valve or readopted regulation and SSV SCSSV satisfies the requirements of a single check valve." fail -safe auto SSV; gas /MI injectors require SSV and single check 25.265(a); 25.265(b); 25.265(d); "Injection wells (excluding disposal injectors) must be equipped with(i) a double check valve Check valve requirements for injectors are not covered by Kuparuk River Unit Tabasco 435A 6 no valve and SSSV landing nipple; water injection wells require (i) double arrangement or (ii) a single check valve and a SSV. A subsurface-controlled injection valve or readopted regulation; readopted 25.265(d)(5) does not include check valve, or (ii) single check valve and SSV; test every 6 months 25 SCSSV satisfies the requirements of a single check valve" SSSV requirement for MI injectors fail -safe auto SSV (S /D well and artificial lift); sign on well if SVS Requirement to maintain a wellhead sign and list of wells with deactivated; maintain list of wells w /deactivated SVS; test as a ; 25.265 b 25.265(h)(5); deactivated SVS was replaced with requirement to maintain a 25.265 Kuparuk River Unit; O Kuparuk 432D 5 yes prescribed by Commission; CO 432D.009 modifies Rule 5(b) - LPP N/A tag on well when not manned; administrative approval CO 25 m Milne Point Unit may be defeated on W. Sak injectors w /surface pressure <500psi w/ 25.265(m) 432D.009 remains effective [re:defeating the LPS when surface notice when defeated and placed back in service injection pressure for West Sak water injector is <500psi] Page 1 of 2 • • • • Orders Establishing Requirements for Well Safety Valve Systems 1/7/2011 Conservation New Regulation Provisions Unit/Field Pool Order (1) Rule Rescind Rule? Existing Order Requirement Addressing Reqts from Order Revised Rule - "Well safety valve systems" (2) Comment fail -safe auto SSV; gas /MI injectors require SSV and single check 25.265(a); 25.265(b); 25.265(d); "Injection wells (excluding disposal injectors) must be equipped with(i) a double check valve Check valve requirements for injectors are not covered by Kuparuk River Unit Tarn 430A 6 no valve and SSSV landing nipple; water injection wells require (i) double arrangement or (ii) a single check valve and a SSV. A subsurface-controlled injection valve or readopted regulation; readopted 25.265(d)(5) does not include check valve, or (ii) single check valve and SSV; test every 6 months 25 SCSSV satisfies the requirements of a single check valve." SSSV requirement for MI injectors Milne Point - Sag fail -safe auto SSV; injection wells require double check valve; test Check valve requirements for injectors are not covered by Milne Point Unit 423 7 no every 6 months 25.265(a); 25.265(b); 25.265(h)(5) "Injection wells must be equipped with a double check valve arrangement." River readopted regulation fail -safe auto SSV; gas /MI injectors require SSV and single check , valve requirements for injectors are not covered by valve and SSSV landing nipple; water injection wells require (i) double "Injection wells (excluding disposal injectors) must be equipped with(i) a double check valve readopted regulation; readopted 25.265(d)(5) does not include Kuparuk River Unit Kuparuk - West Sak 406B 6 no check valve or (ii) single check valve and SSV; test every 6 months; 25.265(a); 25.265(b); 25.265(d); arrangement or (ii) a single check valve and a SSV. A subsurface - controlled injection valve or SSSV requirement for MI injectors; administrative approval CO CO 4068.001 modifies Rule 6(e) - LPP may be defeated on W. Sak 25.265(h)(5) satisfies the may SCSSV th re of a single check valve. The Low Pressure Pilot ma be remains effective [re:defeating the LPS when surface injectors w /surface pressure <500psi w/ notice when defeated and defeated on West Sak water injectors with surface injection pressure less than 500psi." injection pressure for West Sak water injector is <500psi] placed back in service fail -safe auto SSV and SCSSV; LPS trip pressure; readily accessible Badami Badami 402B 6 yes control unit; SSSV below permafrost; NTE 210days between tests; 25.265(a); 25.265(b); 25.265(h); N/A submit test results electronically within 14days; SVS defeated /removed 25.265(m) only if well SI or pad continuously manned fail -safe auto SSV (S /D well and artificial lift); sign on well if SVS 25.265(a); 25.265(b); 25.265(h)(5); Requirement to maintain a wellhead sign and list of wells with Prudhoe Bay Unit North Prudhoe 345 4 yes deactivated; maintain list of wells w/deactivated SVS; test as 25.265 m N/A deactivated SVS was replaced with requirement to maintain a prescribed by Commission ( ) tag on wet when not manned fail -safe auto SSV (S /D well and artificial lift); if SSSV installed it must Prudhoe Ba Unit Prudhoe 341E 5 yes be maintained and tested as part of SVS; sign on well if SVS 25.265(a); 25.265(b); 25.265(d); N/A Readopted 25.265(d) dictates which wells require SSSV; Y deactivated; maintain list of wells wldeactivated SVS; test as 25.265(h)(5) replaces SSSV nipple requirement for all wells prescribed by Commission Prudhoe Ba Unit Niakuk 329A 5 es fail -safe auto SSV and SCSSV; maintain list of wells w/ removed or 25.265(a); 25.265(b); 25.265(d); N/A Readopted 25.265(d) dictates which wets require SSSV; Y Y deactivated SVS; sign on wellhead 25.265(h)(5); 25.265(m) replaces SSSV nipple requirement for all wells Prudhoe Ba Unit Pt. McIntyre 3178 8 es fail -safe auto SSV and SCSSV; SSSV may be rermoved as pa rt o 25.265(a); 25.265(b); 25.265(d); N/A routine well ops w/o notice 2 5.265(j); 25.265(m) Readopted 25.265(d) dictates which wells require SSSV; y ty y replaces SSSV nipple requirement for all wells _ Prudhoe Ba Unit West Beach 311 B 6 yes fail -safe auto SSV; sign on well if SVS deactivated; maintain list of wells 25.265(a); 25.265(b); 25.265(d); N/A Readopted 25.265(d) dictates which wells require SSSV; Y w /deactivated SVS; test as prescribed by Commission 25.265(h)(5); 25.265(m) replaces SSSV nipple requirement for all wells West Fork (Sterling West Fork A &B) 300 5 yes fail -safe auto SVS on each production tubing 25.265(a); 25.265(b) N/A fail -safe auto SSV; sign on well if SVS deactivated; maintain list of wells 25.265(a); 25.265(b); 25.265(h)(5); Requirement to maintain a wellhead sign and list of wells with Prudhoe Bay Unit Lisburne 207A 7 yes N/A deactivated SVS was replaced with requirement to maintain a Y w /deactivated SVS; test as prescribed by Commission 25.265(m) tag on well when not manned suitable automatic safety valve installed below base of permafrost to Readopted 25.265(d) dictates which wells require SSSV; I Prudhoe Bay Unit Prudhoe - Kuparuk 98A 5 yes 25.265(d) N/A prevent uncontrolled flow replaces SSSV nipple requirement for all wells Commission policy dictating SVS performance testing AOGCC Policy - SVS Failures; issued by order of the Statewide N/A N/A N/A yes requirements 25.265(h); 25.265(n); 25.265(o) N/A Commission 3/30/1994 (signed by Commission Chairman Dave Johnson) Footnotes (1) No SVS rules found in Injection Orders (2) New title for Revised Rule; "N /A" means entire pool rule to be rescinded Page 2 of 2 • • Fisher, Samantha J (DOA) From: Fisher, Samantha J (DOA) Sent: Tuesday, January 11, 2011 4:08 PM To: Ballantine, Tab A (LAW); '(foms2 @mtaonline. net)'; '( michael .j.nelson @conocophillips.com)'; '(Von.L .Hutchins @conocophillips.com)'; 'AKDCWelllntegrityCoordinator; 'Alan Dennis'; 'alaska @petrocalc.com'; 'Anna Raff; 'Barbara F Fullmer'; 'bbritch'; 'Becky Bohrer'; 'Bill Penrose'; 'Bill Walker; 'Bowen Roberts'; 'Brad McKim'; 'Brady, Jerry L'; 'Brandon Gagnon'; 'Brandow, Cande (ASRC Energy Services)'; 'Brian Havelock'; 'Bruce Webb'; 'carol smyth'; 'caunderwood'; 'Chris Gay'; 'Cliff Posey'; 'Crandall, Krissell'; 'D Lawrence'; 'daps'; 'Daryl J. Kleppin'; 'Dave Matthews'; 'David Boelens'; 'David House'; 'David Steingreaber; 'ddonkel @cfl.rr.com'; 'Deborah J. Jones'; Delbridge, Rena E (LAA); 'Dennis Steffy'; 'Elowe, Kristin'; 'Erika Denman'; 'eyancy'; 'Francis S. Sommer; 'Fred Steece'; 'Gary Laughlin'; 'Gary Rogers'; 'Gary Schultz'; 'ghammons'; 'Gordon Pospisil'; 'Gorney, David L.'; 'Greg Duggin'; 'Gregg Nady'; 'gspfoff; 'Harry Engel'; 'Jdarlington (jarlington @gmail.com)'; 'Jeanne McPherren'; 'Jeff Jones'; 'Jerry McCutcheon'; 'Jill Womack'; 'Jim White'; 'Jim Winegarner; 'Joe Nicks'; 'John Garing'; 'John Katz'; 'John S. Haworth'; 'John Spain'; 'John Tower'; 'Jon Goltz'; 'Judy Stanek'; 'Julie Houle'; 'Kari Moriarty'; 'Kaynell Zeman'; 'Keith Wiles'; 'Kelly Sperback'; 'Kim Cunningham'; 'Larry Ostrovsky'; 'Laura Silliphant'; 'Marilyn Crockett; 'Mark Dalton'; 'Mark Hanley (mark.hanley @anadarko.com)'; 'Mark Kovac'; 'Mark P. Worcester; 'Marguerite kremer; 'Michael Dammeyer; 'Michael Jacobs'; 'Mike Bill'; 'Mike Mason'; 'Mikel Schultz'; 'Mindy Lewis'; 'MJ Loveland'; 'mjnelson'; 'mkm7200'; 'nelson'; 'Nick W. Glover; 'NSK Problem Well Supv'; 'Patty Alfaro'; 'Paul Decker (paul.decker @alaska.gov)'; 'Paul Figel'; 'PORHOLA, STAN T'; 'Randall Kanady'; 'Randy L. Skillern'; ' rob.g.dragnich @exxonmobil.com'; 'Robert Brelsford'; 'Robert Campbell'; 'Ryan Tunseth'; 'Scott Cranswick'; 'Scott Griffith'; Scott, David (LAA); 'Shannon Donnelly'; 'Sharmaine Copeland'; Shellenbaum, Diane P (DNR); Slemons, Jonne D (DNR); 'Sondra Stewman'; 'Steve Lambert; 'Steve Moothart'; 'Steven R. Rossberg'; 'Suzanne Gibson'; 'tablerk'; 'Tamera Sheffield'; Taylor, Cammy 0 (DNR); 'Temple Davidson'; 'Teresa Imm'; 'Terrie Hubble'; 'Thor Cutler; 'Tina Grovier; 'Todd Durkee'; 'Tony Hopfinger; 'trmjrl'; 'Valenzuela, Mariam '; Vicki Irwin'; 'Walter Featherly'; 'Will Chinn'; Williamson, Mary J (DNR); 'Yereth Rosen'; 'Aaron Gluzman'; Bettis, Patricia K (DNR); caunderwood @marathonoil.com; 'Dale Hoffman'; 'David Lenig'; 'Gary Orr; 'Jason Bergerson'; 'Joe Longo'; 'Lara Coates'; 'Marc Kuck'; 'Mary Aschoff; 'Matt Gill'; 'Maurizio Grandi'; Ostrovsky, Larry Z (DNR); 'Richard Garrard'; 'Sandra Lemke'; 'Talib Syed'; 'Tiffany Stebbins'; 'Wayne Wooster; 'William Van Dyke'; Woolf, Wendy C (DNR); Aubert, Winton G (DOA) (winton.aubert@alaska.gov); Brooks, Phoebe L (DOA) (phoebe.brooks @alaska.gov); Colombie, Jody J (DOA) (jody.colombie @alaska.gov); Crisp, John H (DOA) (john.crisp @alaska.gov); Davies, Stephen F (DOA) (steve.davies @alaska.gov); Foerster, Catherine P (DOA) (cathy.foerster @ alaska.gov); Grimaldi, Louis R (DOA) (lou.grimaidi @alaska.gov); Johnson, Elaine M (DOA) (elaine.johnson @ alaska.gov); Jones, Jeffery B (DOA) (jeff.jones @alaska.gov); Laasch, Linda K (DOA) (linda.laasch @alaska.gov); Maunder, Thomas E (DOA) (tom.maunder @alaska.gov); McIver, Bren (DOA) (bren.mciver @alaska.gov); McMains, Stephen E (DOA) (steve.mcmains @alaska.gov); Mumm, Joseph (DOA sponsored); Noble, Robert C (DOA) (bob.noble @alaska.gov); Norman, John K (DOA) (john.norman @alaska.gov); Okland, Howard D (DOA) (howard.okland @alaska.gov); Paladijczuk, Tracie L (DOA) ( tracie.paladijczuk @alaska.gov); Pasqual, Maria (DOA) (maria.pasqual @alaska.gov); Regg, James B (DOA) (jim.regg @alaska.gov); Roby, David S (DOA) (dave.roby @alaska.gov); Saltmarsh, Arthur C (DOA) (art.saltmarsh @alaska.gov); Scheve, Charles M (DOA) (chuck.scheve @alaska.gov); Schwartz, Guy L (DOA) (guy.schwartz @alaska.gov); Seamount, Dan T (DOA) (dan.seamount @alaska.gov); Shartzer, Christine R (DOA) Subject: Other 66 Safety Valve Systems Attachments: other66.pdf ScimaaNtattai 1i4h.er Alcuska'OW a a4,-Co-wserva. ulwG (907)793 - 1223 (907)276 (fix ) 1 • • Mary Jones David McCaleb XTO Energy, Inc. IHS Energy Group George Vaught, Jr. Cartography GEPS P.O. Box 13557 810 Houston Street, Ste 200 5333 Westheimer, Suite 100 Denver, CO 80201 -3557 Ft. Worth, TX 76102 -6298 Houston, TX 77056 Richard Neahring Jerry Hodgden Hod den Mark Wedman Hodgden Oil Company NRG Associates Halliburton 408 18 Street President 6900 Arctic Blvd. Golden, CO 80401 -2433 P.O. Box 1655 Anchorage, AK 99502 Colorado Springs, CO 80901 Bernie Karl CIRI K &K Recycling Inc. Land Department Baker Tools Oil h 7 E . 94th a. P.O. Box 58055 P.O. Box 93330 795 E Fairbanks, AK 99711 Anchorage, AK 99503 Anchorage, AK 99515 -4295 Jill Schneider North Slope Borough Gordon Severson US Geological Survey P.O. Box 69 4200 niv r i Drive 3201 Westmar Circle Barrow, AK 99723 Anchorage, AK 99508 Anchorage, AK 99508 -4336 Jack Hakkila Darwin Waldsmith James Gibbs P.O. Box 190083 P.O. Box 39309 P.O. Box 1597 Anchorage, AK 99519 Ninilchick, AK 99639 Soldotna, AK 99669 Kenai National Wildlife Refuge Penny Vadla Cliff Bur tin Refuge Manager I da g efuge anager 399 West Riverview Avenue 319 Charles Street P.O. Box 2139 Soldotna, AK 99669 -7714 Fairbanks, AK 99701 Soldotna, AK 99669 -2139 Richard Wagner P.O. Box 60868 Fairbanks, AK 99706 \1 3 ` U ` \ `�` \ \\ 2 • • 1 ALASKA OIL AND GAS CONSERVATION COMMISSION 2 Before Commissioners: Daniel T. Seamount, Chairman John K. Norman 3 Cathy Foerster 4 In the Matter of Rescinding ) 5 Safety Valve System Rules ) in Existing Conservation ) 6 Orders ) 7 ) 8 ALASKA OIL and GAS CONSERVATION COMMISSION Anchorage, Alaska 9 December 6th, 2010 10 2:00 o'clock p.m. 11 PUBLIC HEARING 12 BEFORE: Daniel T. Seamount, Chairman Cathy Foerster, Commissioner 13 14 15 16 17 18 19 20 21 22 23 24 25 R & R C O U R T R E P O R T E R S 811 G STREET (907)277- 0572 /Fax 274-8982 ANCHORAGE, ALASKA 99501 S 1 TABLE OF CONTENTS 2 Opening Remarks by Chair Seamount 03 3 Testimony by Dr. Winton Aubert Testimony by Mr. Harry Engel 07 Y Y Y g 4 Testimony by b Ms. M.J. Loveland 17 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 R & R C O U R T R E P O R T E R S 811 G STREET (907)277- 0572 /Fax 274 -8982 ANCHORAGE, ALASKA 99501 • 1 P R O C E E D I N G S 2 (On record - 2:02 p.m.) 3 CHAIR SEAMOUNT: On the record. I'd like to call this 4 hearing to order. Today is December 6th, 2010, and the time is 5 2:02 1/2 p.m. We're located at 333 West 7th Avenue, Suite 100, 6 Anchorage, Alaska. Those are the offices of the Alaska Oil & 7 Gas Conservation Commission. 8 To my left is Commissioner Cathy Foerster. I'm Dan 9 Seamount, the Chair. We have a quorum. That's two out of 10 three. 11 If anybody has any special needs, which I think we all do, 12 please contact Jody Colombie, our Special Assistant in the back 13 there. Raise your hand, Jody. I don't think everybody knows 14 you. Okay. There you go. 15 R & R Court Reporting will be recording our proceedings. 16 You can get a copy of the transcript from R & R Court 17 Reporting. And then as you guys have all experienced this, but 18 I'll just remind you, speak on both of the microphones when you 19 testify so that people in the back can hear you and so that the 20 recorder can get a clear recording. 21 This is Docket No. CO- 10 -21. And that's regarding AOGCC's 22 own motion to have a hearing on rescinding safety valve system 23 rules in existing Conservation Orders. And it's rescinding, 24 not resending, right? Or do the British say resending, they 25 say schedule. All right. R & R C O U R T R E P O R T E R S 811 G STREET (907)277- 0572 /Fax 274 -8982 ANCHORAGE, ALASKA 99501 3 . . 1 Anyway, notice of this hearing was published on November 2 4th, 2010, in the Anchorage Daily News as well as on the Alaska 3 online notices and the AOGCC web site. 4 The hearing is being held in accordance with 20 AAC 25.540 5 of the Alaska Administrative Code. And the hearing will be 6 recorded. 7 So I'm looking at the sign -up sheet and people are still 8 really interested in talking about this. Let's see, one, two, 9 three, it looks like four people are interested in testifying 10 today. And one of them happens to be our very own AOGCC Senior 11 Petroleum Engineer, Dr. Winton Aubert. Is he going to be the 12 first one to testify? 13 COMMISSIONER FOERSTER: I can hardly wait. 14 CHAIR SEAMOUNT: But he's the first, right? Okay. Well, 15 Winton, Dr. Aubert will kick it off then. Please approach the 16 bench, Dr. Aubert. I mean -- well, I don't even know your name 17 yet 'cause I've got to swear you in, so, please raise your 18 right hand. 19 (Oath administered) 20 DR. AUBERT: I do so swear. 21 CHAIR SEAMOUNT: And so you can, therefore, state your 22 name for the record, and proceed, please. 23 WINTON AUBERT 24 called as a witness on behalf of AOGCC, testified as follows 25 on: R & R C O U R T R E P O R T E R S 811 G STREET (907)277- 0572 /Fax 274 -8982 ANCHORAGE, ALASKA 99501 4 . . 1 DIRECT EXAMINATION 2 DR. AUBERT: For the record I'm Winton Aubert, Senior 3 Engineer on the Commission Staff. 4 Our repealed and re- adopted well safety valve systems 5 regulations at 20 AAC 25.265 were signed by the Alaska 6 Lieutenant Governor and took legal effect on December 3rd, 7 2010. These new regulations consolidate requirements 8 previously established in Commission legacy documents, 9 policies, and statewide guidelines relating to safety valve 10 systems. 11 We believe that latter embodiments are now redundant and 12 unnecessary and can be eliminated. Our review of Commission 13 records revealed 33 existing orders that contained rules 14 governing well safety valve systems. 17 of those Commission 15 orders contain only broad, regulatory requirements for safety 16 valve systems that are now covered by our newly adopted regs. 17 The remaining 16 orders include field or pool specific safety 18 valve requirements. We believe that within existing 19 Conservation orders that contain rules unrelated to well safety 20 valve system such rules, obviously, should continue in effect 21 unmodified. We further believe that eliminating redundant 22 requirements and standardizing wording for appropriate field 23 and pool specific rules will improve regulatory clarity and 24 reduce confusion. Our subject proposed other order number 58 25 puts these beliefs in motion. R & R C O U R T R E P O R T E R S 811 G STREET (907)277- 0572 /Fax 274 -8982 ANCHORAGE, ALASKA 99501 5 1 CHAIR SEAMOUNT: Do you have any comments or questions, 2 Commissioner Foerster? 3 COMMISSIONER FOERSTER: None. 4 CHAIR SEAMOUNT: Thank you, Dr. Aubert. Okay. Please 5 hang around in case we have any additional questions for you. 6 Okay. One, two -- no, one. It looks like we have one 7 person wanting to testify from BP and two from ConocoPhillips. 8 And it looks like nobody from AOGA. 9 MR. ENGEL: I'm with AOGA and BP. 10 CHAIR SEAMOUNT: Oh, you are AOGA, okay. 11 Okay. It looks like unanimously AOGA /BP gets to go first. 12 And this is the biggest type I've ever seen in any documents 13 put up here. And I assume you think that Commissioner Foerster 14 or I have gotten too old to read regular type, is that correct? 15 Please approach the bench. Please raise your right hand? 16 (Oath administered) 17 MR. ENGEL: I do so swear. 18 CHAIR SEAMOUNT: Do you wish to be considered as an expert 19 witness 20 MR. ENGEL: I do. 21 CHAIR SEAMOUNT: since you've been conside- -- you've 22 been designated an expert witness probably a dozen times so 23 far, but we'll go through the motions. 24 Commissioner Foerster, do you have any questions or 25 comments that you'd like to make about Mr. Engel? R & R C O U R T R E P O R T E R S 811 G STREET (907)277- 0572 /Fax 274 -8982 ANCHORAGE, ALASKA 99501 6 • 1 COMMISSIONER FOERSTER: I'm very familiar with Mr. Engel 's 2 qualifications and I'm willing to accept him anyway. 3 CHAIR SEAMOUNT: You haven't heard his qualifications yet. 4 COMMISSIONER FOERSTER: But I'm very familiar with 5 them 6 CHAIR SEAMOUNT: Okay. 7 COMMISSIONER FOERSTER: without hearing them. 8 CHAIR SEAMOUNT: I wonder if we should put them on the 9 record anyway. 10 COMMISSIONER FOERSTER: Sure. 11 CHAIR SEAMOUNT: Okay. 12 HARRY ENGEL 13 called as a witness on behalf of BP and AOGA, testified as 14 follows on: 15 DIRECT EXAMINATION 16 CHAIR SEAMOUNT: Please give us your qualifications, what 17 you'd like to be considered as an expert witness in. 18 MR. ENGEL: Good morning -- or good afternoon, Chairman 19 Seamount and Commissioner Foerster. 20 CHAIR SEAMOUNT: Did I swear him in? 21 COMMISSIONER FOERSTER: No. 22 CHAIR SEAMOUNT: Did I swear you in? 23 MR. ENGEL: Yes, sir. 24 CHAIR SEAMOUNT: I did. Okay. I just wanted to make sure 25 that Commissioner Foerster was paying attention, and R & R C O U R T R E P O R T E R S 811 G STREET (907)277- 0572 /Fax 274 -8982 ANCHORAGE, ALASKA 99501 7 1 COMMISSIONER FOERSTER: I'm not. 2 CHAIR SEAMOUNT: she wasn't. 3 MR. ENGEL: Very well My name is Harry Engel. And this 4 afternoon I will be wearing two hats. I'll be representing BP 5 Exploration regarding the subject of this hearing and I'll also 6 be representing the Alaska Oil & Gas Association as chairman of 7 the AOGCC Task Group on several related topics. 8 I am the engineering team leader responsible for integrity 9 management in BP's Alaska wells organization. My 10 responsibilities span all of BP's well operations in Alaska. I 11 hold undergraduate engineering degrees in Civil and 12 Environmental Engineering, and have over 30 years experience of 13 experience in the oil and gas industry primarily related to 14 drilling and well intervention activities. My assignments have 15 included drilling engineering, well site leader, and various 16 health, safety and environmental management positions. The 17 majority of my experience has been most -- has been in most of 18 the operating areas in Alaska. I've also worked in the Rocky 19 Mountains and have had several temporary international 20 assignments. 21 CHAIR SEAMOUNT: Okay. I will again ask the question. 22 Commissioner Foerster? 23 COMMISSIONER FOERSTER: What's the question? 24 CHAIR SEAMOUNT: Do you have any questions or comments of 25 Mr. Engel, and if you do or do not do, would you have any R & R C O U R T R E P O R T E R S 811 G STREET (907)277- 0572 /Fax 274 -8982 ANCHORAGE, ALASKA 99501 8 1 objections to us designating him as an expert witness? 2 COMMISSIONER FOERSTER: No objection. 3 CHAIR SEAMOUNT: I have none either. You're hereby 4 designated an expert witness, Mr. Engel. Please proceed. 5 MR. ENGEL: I submitted written comments to the Commission 6 on December 3rd, 2010, concerning the proposed changes to the 7 safety valve system rules in existing Conservation orders. 8 Does the Commissioner have copies of my December 3rd letter? 9 If not I've got copies here I could give you. 10 CHAIR SEAMOUNT: I don't have them with me 11 COMMISSIONER FOERSTER: I just read it. I read it right 12 before the hearing so I'm fine. 13 MR. ENGEL: Do you want a copy? Do you want a copy right 14 now? 15 COMMISSIONER FOERSTER: No, thanks. 16 MR. ENGEL: Okay. I request that my letter of December in the record for this subject. II 17 3rd be included � 18 COMMISSIONER FOERSTER: If you have an extra copy, give it 19 to the court reporter for inclusion in the record. 20 CHAIR SEAMOUNT: And I assume you have no objections to 21 putting this into the record? 22 COMMISSIONER FOERSTER: None at all. 23 CHAIR SEAMOUNT: Okay. We are going to put a letter from 24 BP signed by Mr. Engel, dated December 3rd, 2010, the title is 25 Proposed Changes to Safety Valve Systems Rules in Existing R & R C O U R T R E P O R T E R S 811 G STREET (907)277- 0572 /Fax 274 -8982 ANCHORAGE, ALASKA 99501 9 410 411 1 Conservation Orders, two pages, into the record. Please 2 proceed. 3 MR. ENGEL: Thank you, Commissioner Seamount. We agree 4 with the intent to rescind language from Conservation orders 5 that is redundant to the recently adopted changes to the safety 6 valve regulations, and we commend the AOGCC for taking this 7 step to simplify and standardize the safety valve system 8 requirements. We also agree with nearly all of the proposed 9 specific changes, however, we do question the proposed language 10 in two of the orders included in the public notice, 11 specifically the Prudhoe Bay Borealis oil pool, Conservation 12 Order 471, and Milne Point Schrader Bluff oil pool, 13 Conservation Order 477 14 During the process leading up to the new safety valve 15 system regulations there were extensive discussion related to 16 the potential requirement for subsurface safety valves in 17 water - alternating gas or WAG wells. The new safety valve 18 system regulations specifically require subsurface safety 19 valves in gas only injection wells, but not in WAG wells. 20 Miscible injections or MI wells referenced in the proposed 21 changes to the two Conservation orders could be MI only or MI 22 WAG wells. Per the new safety valve system regulations, MI 23 wells are required to have a subsurface safety valve in gas 24 only injection wells, yet MI WAG wells do not require a 25 subsurface safety valve. Maintaining the requirement for R & R C O U R T R E P O R T E R S 811 G STREET (907)277- 0572 /Fax 274 -8982 ANCHORAGE, ALASKA 99501 10 410 411 1 subsurface safety valves in WAG wells at Prudhoe Bay Borealis 2 and Milne Point Schrader Bluff oil pools seems inconsistent 3 with the intent of standardizing the safety valve system 4 regulations. It is not apparent why these pools would have 5 differential subsurface safety valve requirements compared to 6 nearby pools. We respectfully request the Commission rescind, 7 without replacement, the existing language in the Milne Point 8 Schrader Bluff and Prudhoe Bay Borealis Conservation orders 9 related to subsurface safety valves. 10 At this point I would be happy to address any questions to 11 that part of my testimony. 12 COMMISSIONER FOERSTER: I have a question for Dr. Aubert. 13 CHAIR SEAMOUNT: Aubert. 14 COMMISSIONER FOERSTER: Aubert. 15 CHAIR SEAMOUNT: Aubert. 16 COMMISSIONER FOERSTER: Aubert, Win. Was it an oversight? 17 DR. AUBERT: Yes. 18 COMMISSIONER FOERSTER: Okay. 19 CHAIR SEAMOUNT: Okay. We'll seriously consider that 20 request. If you could proceed, Mr. Engel. 21 MR. ENGEL: Very good. Now I'm going to switch hats. Now 22 I would like to represent the Alaska Oil & Gas Association as 23 chairman of the AOGCC task group on several related topics that 24 are of interest to AOGA member companies. 25 The main topic I would like to present is the transition R & R C O U R T R E P O R T E R S 811 G STREET (907)277- 0572 /Fax 274 -8982 ANCHORAGE, ALASKA 99501 11 i 1 period for operators to design, order, fabricate, transport, 2 install and test necessary equipment to comply with the new 3 safety valve system regulations that became effective December 4 3rd, 2010. 5 The interpretation of 20 AAC 25.265(f), as in Frank, could 6 significantly impact the number of wells required to have 7 subsurface safety valves and the type of valve installed before 8 the next tubing workover. Section (f), as in Frank, refers to 9 wells completed December 3rd, 2010, that are subject to section 10 (d), delta, and are not equipped with functional hardware that 11 would allow installation of a subsurface safety valve. These 12 wells must comply with section (d) no later than the date of 13 the next tubing workover. Section (d) requires.a fail -safe 14 automatic surface controlled subsurface safety valve. It's 15 reasonable to interpret that if a well does not have the 16 functional hardware necessary to install a surface controlled 17 -- subsurface safety valve, the operator would be required to 18 install a surface controlled subsurface safety valve no later 19 than the next tubing workover. 20 It is not clear if the Commission would expect an operator 21 to install non - surface controlled subsurface safety valves in 22 wells that have a suitable profile for that type of subsurface 23 safety valve in the tubing. We would appreciate clarity 24 related to this issue due to the impact on the number of 25 appropriate valves that would need to be designed, fabricated R & R C O U R T R E P O R T E R S 811 G STREET (907)277- 0572 /Fax 274 -8982 ANCHORAGE, ALASKA 99501 12 1 and installed. 2 Considering the timing to design, order, fabricate, 3 transport, install and test necessary equipment to comply with 4 the new regulations, we request the Commission formally 5 document a one year transition period for operators to comply 6 with the regulations. 7 CHAIR SEAMOUNT: Commissioner Foerster, do you have any 8 questions 9 COMMISSIONER FOERSTER: No. 10 CHAIR SEAMOUNT: comments? Okay. I don't either. 11 MR. ENGEL: The next item I'd like to address relates to a 12 proposed industry guidance bulletin. It would be appreciated 13 if the Commission could provide an update on the effort to 14 prepare the bulletin related to testing, reporting, and 15 calculation of safety valve system pad failure rates and 16 potential consequences. 17 CHAIR SEAMOUNT: Any questions? 18 COMMISSIONER FOERSTER: By asking for an update, I'm 19 assuming that you're waiting for that information for some use? 20 MR. ENGEL: Yes. 21 COMMISSIONER FOERSTER: What would that use be? 22 MR. ENGEL: Pardon me? 23 COMMISSIONER FOERSTER: What is that use? What is not 24 giving you that information keeping you from doing right now? 25 MR. ENGEL: Well, during the last several hearings we've R & R C O U R T R E P O R T E R S 811 G STREET (907)277- 0572 /Fax 274 -8982 ANCHORAGE, ALASKA 99501 13 I 1 had, Commissioner Foerster, industry has expressed an interest 2 in gaining clarity around methods for calculating failure rates 3 for safety valve testing across the North Slope and Cook Inlet. 4 And also the method in which it is calculated and then the 5 consequences for enhanced testing would be beneficial to the 6 industry. 7 COMMISSIONER FOERSTER: Just curiosity? Okay. 8 CHAIR SEAMOUNT: Clarification. 9 MR. ENGEL: It would also provide the -- it would provide 10 the rules of how they're actually conducted. 11 COMMISSIONER FOERSTER: So that you can -- you would like. 12 MR. ENGEL: To better understand the way that the State 13 calculates the failure rates. 14 COMMISSIONER FOERSTER: So it's just for an understanding 15 of what we do. You're not going to do something different 16 based on what we give you? You're just asking for information 17 that will give you a better understanding of what we do? 18 MR. ENGEL: Right, we're asking for the clarity on that 19 topic. 20 COMMISSIONER FOERSTER: Uh -hum. No other questions. 21 CHAIR SEAMOUNT: Okay. 22 MR. ENGEL: Okay. Lastly, I would like to make a 23 recommendation for consideration for a future revision to the 24 safety valve system regulations. The regulations effectively 25 define a quote, safety valve system, unquote, in Sections 20 R & R C O U R T R E P O R T E R S 811 G STREET (907)277- 0572 /Fax 274 -8982 ANCHORAGE, ALASKA 99501 14 1 AAC 25.265(b) and (c). These sections reference surface safety 2 valves, actuators, low pressure detection devices and other 3 surface related components. Subsurface safety valves are 4 mentioned in section (d) yet not specifically referenced as 5 being included as part of the entire safety valve system. 6 Therefore, it appears one could interpret that subsurface 7 safety valves are not included in the definition of a, quote, 8 safety valve system. This could possibly impact the 9 applicability of section (c)(8) which provide a one year period 10 after December 3rd, 2010, to gain Commission approval to 11 operate components of a safety valve system that do not meet 12 the requirements of section (c) items 1 through 7. This 13 section applies to surface equipment only. It could also 14 possibly impact the calculation of safety valve system test 15 results depending upon if the subsurface safety valve is 16 included in the calculation. A clear definition of a safety 17 valve system would avoid potential confusion in the future. 18 That concludes my comments this afternoon. 19 COMMISSIONER FOERSTER: Could you give me an example of a 20 situation where this confusion would occur? 21 MR. ENGEL: The one that I see, Commissioner Foerster, 22 would be around the section C -7 provides a one year period for 23 an operator to gain Commission approval to operate a well 24 without the approved equipment in place at the moment, and it 25 applies to surface only, so if an operator had subsurface R & R C O U R T R E P O R T E R S 811 G STREET (907)277- 0572 /Fax 274 -8982 ANCHORAGE, ALASKA 99501 15 1 equipment that didn't meet the intent, the confusion arises is 2 it part of the system or not part of the system. 3 CHAIR SEAMOUNT: Okay. I have no questions. Mr. Engel, n in case we can think of other 4 please stick around questions or q 5 comments for you. 6 MR. ENGEL: Okay. I have one last comment for 7 Commissioner Foerster. Commissioner Foerster, I was sad to 8 learn recently that University of Texas is not bowl eligible 9 this year. 10 COMMISSIONER FOERSTER: Every cloud has a silver lining. 11 My Saturdays are now completely free to do other things besides 12 watch football. 13 CHAIR SEAMOUNT: Finally there's life beyond football, 14 huh? 15 Thank you for your comments, Mr. Engel. 16 MR. ENGEL: You're welcome. 17 CHAIR SEAMOUNT: Okay. It looks like next we have 18 ConocoPhillips. Okay. I can't remember, am I allowed to swear 19 them both in at the same time? 20 COMMISSIONER FOERSTER: Yeah. 21 CHAIR SEAMOUNT: Okay. Please raise your right hands? 22 (Oath administered) 23 MS. LOVELAND: I do so swear. 24 MR. KANADY: I do so swear. 25 CHAIR SEAMOUNT: Thank you. Okay. Who's first? R & R COURT REPORT E R S 811 G STREET (907)277-0572/Fax 274 -8982 ANCHORAGE, ALASKA 99501 16 1 MS. LOVELAND: I guess I am. 2 CHAIR SEAMOUNT: Okay. Please state your name, if you 3 want to be considered as an expert witness please give us your 4 qualifications and what discipline you're going to be -- you 5 want to be designated as an expert witness in. 6 M.J. LOVELAND 7 called as a witness on behalf of ConocoPhillips, testified as 8 follows on: 9 DIRECT EXAMINATION 10 MS. LOVELAND: My name is M.J. Loveland, and I do want to 11 be considered an expert witness. I am currently well integrity 12 project supervisor for ConocoPhillips Alaska. I have a 13 Bachelor of Science degree in Petroleum Engineering from the 14 University of Wyoming. I've 21 years of industry experience 15 and have been working with safety valve systems and the safety 16 valve regulations since 2003. At the time I was the supervisor 17 that gave work direction and training to the crews that perform 18 the actual safety valve performance tests. I've also been an 19 active member on the team working with the AOGCC on the safety 20 valve system regulation update since 2006. My current role is 21 acting as an advisor and a single point of contact that 22 addresses issues, questions, and projects regarding -- to well 23 integrity issues which -- including safety valve systems. 24 CHAIR SEAMOUNT: Commissioner Foerster, questions or 25 comments? R & R C O U R T R E P O R T E R S 811 G STREET (907)277- 0572 /Fax 274 -8982 ANCHORAGE, ALASKA 99501 17 1 COMMISSIONER FOERSTER: Nope 2 CHAIR SEAMOUNT: Okay. 3 COMMISSIONER FOERSTER: I'm very familiar with Ms. 4 Loveland's qualifications. Do you have any objections? 5 CHAIR SEAMOUNT: y y ections? ] 6 COMMISSIONER FOERSTER: None. 7 CHAIR SEAMOUNT: Okay. I don't either. Ms. Loveland, 8 you're designated as an expert witness. 9 MS. LOVELAND: Thank you. ConocoPhillips appreciates the 10 opportunity to give comment and testimony for this process 11 that's been going on for awhile. And we hope this is the last 12 one, but 13 CHAIR SEAMOUNT: So do I. 14 MS. LOVELAND: Specifically today I'm here to talk about 15 two Conservation orders, 406B.001 and 432D.009. They're both 16 on the list to be rescinded. And these Conservation orders 17 allow the low pressure pilots on West Sak wells and Kuparuk 18 injection wells that have low pressure -- low surface pressure 19 in- -- or have low surface pressure less than 500 or 700 psi 20 respectively, to be defeated until that pressure exceeds those 21 that I just said. 22 We understand that an allowance to defeat the low pressure 23 pilots in 20 AAC 25.265(j) (2) , however (j) (2) also states that 24 we have to have Commission authorization to not have 24 hour 25 man watch when these pilots are defeated. ConocoPhillips R & R C O U R T R E P O R T E R S 811 G STREET (907)277- 0572 /Fax 274 -8982 ANCHORAGE, ALASKA 99501 18 410 411 1 suggests leaving these two orders in place as that 2 authorization to have the pilots defeated with Commission 3 permission. 4 In West Sak operations it is very common for the surface 5 injection pressures to take several weeks to stabilize above 6 500 psi after a shut -in event that's even as short as 12 hours. 7 Most of the time it's not known until after the well is brought 8 online that the pressure will stabilize below 500 psi. 9 Therefore, advance notice for authorization isn't very 10 practical and a 24 hour man watch is a burden in our opinion 11 for a low risk practice. Roughly one well per month for up to 12 two weeks a month -- two weeks to a month would require a man 13 watch. There are four separate drill sites which have West Sak 14 injection wells that could have injection pressures less than 15 500 psi at any one time. The injection pressure can be so low 16 that they start out on a vacuum and they'll be at that for 17 several days and so actually get a low pressure pilot set point 18 is impossible or nearly impossible to manage. 19 The Kuparuk injectors have similar issues when the 20 injection wells have been pre - produced before swapping them to 21 injection. Rescinding 406B.001 and 432D.009 without replacing 22 them with equivalent authorization to defeat lower pressure 23 points on wells with low surface injection pressure will hamper 24 our ability to manage the West Sak flood and to a smaller 25 degree the Kuparuk flood in a cost efficient as well as in a R & R C O U R T R E P O R T E R S 811 G STREET (907)277- 0572 /Fax 274 -8982 ANCHORAGE, ALASKA 99501 19 1 1 pressure efficient manner. Therefore, ConocoPhillips requests 2 406B.001 and 432D.009 to be retained or replaced with like 3 authorization that allows the lower pressure pilots to be 4 defeated within pressure restrictions without the 24 hour man 5 watch. 6 CHAIR SEAMOUNT: Questions? 7 COMMISSIONER FOERSTER: Yes. So you're saying just leave 8 in the piece of the CO that relates to the low pressure pilots, 9 not the entire CO? 10 MS. LOVELAND: On one of them, on 406B the whole 11 Conservation order is being retained except .001. And on 432D 12 the Conservation order is being rescinded completely. 13 COMMISSIONER FOERSTER: So you want that, the LLP part 14 saved in both cases? 15 MS. LOVELAND: Yes. 16 COMMISSIONER FOERSTER: Okay. So have you thought about 17 this 24 hour man watch as a job stimulus? No, just kidding. 18 MS. LOVELAND: Good idea, but 19 COMMISSIONER FOERSTER: That was a joke. 20 CHAIR SEAMOUNT: It was? 21 COMMISSIONER FOERSTER: That was my only question, the 22 first one, the other one was just levity. No more questions. 23 CHAIR SEAMOUNT: Okay. Thank you. Thank you, Ms. 24 Loveland. And we may have further questions for you. Okay. 25 Okay. We've sworn you in so R & R C O U R T R E P O R T E R S 811 G STREET (907)277- 0572 /Fax 274 -8982 ANCHORAGE, ALASKA 99501 20 1 1 MR. KANADY: I -- we have -- Conoco has no further 2 comments. 3 CHAIR SEAMOUNT: Oh, you have no further 4 MR. KANADY: Yeah. 5 CHAIR SEAMOUNT: Oh, okay. At this point then did anybody 6 in the public or anybody at all have any questions or comments 7 to make? Mr. Engel? 8 MR. ENGEL: Yes, Commissioner Seamount. Could you provide 9 us with a rough estimate of the plan for it for answering or 10 addressing our questions this morning -- or this afternoon 11 regarding this topic? 12 COMMISSIONER FOERSTER: Not until we've talked to staff. 13 CHAIR SEAMOUNT: I think we need to talk to staff first 14 and probably the best way to go would be to contact which one? 15 Which one of you guys will be the contact? 16 DR. AUBERT: Either. 17 CHAIR SEAMOUNT: Okay. It'd be either Mr. Regg or Mr. 18 Aubert. 19 MR. ENGEL: Okay. Thank you. 20 CHAIR SEAMOUNT: We should have an answer -- we should 21 have that answered real shortly. 22 MR. ENGEL: Thank you. There's a consideration though of 23 potential compliance locations of this subject, a timely 24 response would be beneficial and really appreciated. 25 COMMISSIONER FOERSTER: We're not going to consider you R & R C O U R T R E P O R T E R S 811 G STREET (907)277- 0572 /Fax 274 -8982 ANCHORAGE, ALASKA 99501 21 1 out of compliance before we've made a decision. 2 MR. ENGEL: Thank you very much. 3 COMMISSIONER FOERSTER: But the second we do you better 4 watch out. 5 MR. ENGEL: Thank you very much. 6 CHAIR SEAMOUNT: Okay. You feel like adjourning? 7 COMMISSIONER FOERSTER: Yeah. 8 CHAIR SEAMOUNT: Okay. We are adjourned at the timely hour 9 of 2:29. 10 (Recessed - 2:29 p.m. 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 R & R C O U R T R E P O R T E R S 811 G STREET (907)277- 0572 /Fax 274 -8982 ANCHORAGE, ALASKA 99501 22 0 • 1 C E R T I F I C A T E 2 UNITED STATES OF AMERICA ) ) ss . 3 STATE OF ALASKA 4 I, Rebecca Nelms, Notary Public in and for the State of Alaska, residing at Anchorage, Alaska, and Reporter for R & R 5 Court Reporters, Inc., do hereby certify: 6 THAT the annexed and foregoing Public Hearing held on December 6th, 2010 was taken by William P. Rice, commencing at 7 the hour of 9:00 o'clock a.m, at the Alaska Oil and Gas Conservation Commission of Alaska in Anchorage, Alaska; 8 THAT this Public Hearing, as heretofore annexed, is a true 9 and correct transcription of the proceedings taken by William P. Rice and transcribed by myself. 10 IN WITNESS WHEREOF, I have hereunto set my hand and 11 affixed my seal this 10th day of December 2010. 12 (ik01 13 Notary Public in and for Alaska My Commission Expires:10 /18/14 14 15 16 17 18 19 20 21 22 23 24 25 R & R C O U R T R E P O R T E R S 811 G STREET (907)277- 0572 /Fax 274 -8982 ANCHORAGE, ALASKA 99501 • • STATE OF ALASKA OIL AND GAS CONSERVATION COMMISSION Rescinding Safety Valve System Rules in Existing Conservation Orders December 6, 2010 at 2:00 pm NAME AFFILIATION PHONE # TESTIFY (Yes or No) 9 4 1 R 2 aJ CL / ",' DEA_ C6 V I r-y &f L- � y At) Law, 6vevt4 Cu 0243 -2Cg / Ain fy 01/(r .2/0-2e PAS --tit . 1 opt Yr) 1 ACYLL )d\r no Aikto 44y . 4 1 ;. ‘,27.,--/4/e bp !° 4 1/ Z BP Exploration (Alaska) Inc. 900 East Benson Boulevard P.O. Box 196612 Anchorage, Alaska 99519 -6612 (907) 564 -5006 December 3, 2010 Mr. Daniel T. Seamount, Jr Alaska Oil & Gas Conservation Commission 333 West 7 Avenue, Suite 100 Anchorage, Alaska 99501 Reference: Proposed Changes to Safety Valve System Rules in Existing Conservation Orders Dear Commissioner Seamount, BP Exploration (Alaska) Inc. (BPXA) has reviewed the proposed changes to the various existing conservation orders concerning safety valve system (SVS) rules. BPXA operates in 20 of the 33 pools included in the November 03, 2010 Notice of Public Hearing. We agree with the intent to rescind language from conservation orders that is redundant to the recently adopted changes to the safety valve regulations, and we commend the AOGCC for taking this step to simplify and standardize the SVS requirements. We also agree with nearly all of the proposed specific changes, however, we question the proposed language in two of the conservation orders (CO) included in the notice. During the process leading up to the new SVS regulations there was extensive discussion related to the potential requirement for subsurface safety valves (SSSV) in water - alternating -gas (WAG) wells. The new SVS regulations specifically require SSSV in gas only injection wells but not in WAG wells. Miscible injection (MI) wells could be MI only or MI WAG wells. In the new SVS regulations, MI only injection wells are required to have a SSSV as "gas -only injection wells ", yet MI WAG wells do not require a SSSV. Maintaining the requirement for SSSV in WAG wells at Prudhoe Bay Borealis and Milne Point Schrader Bluff Oil Pools seems inconsistent with the intent of standardizing the SVS regulations. It is not apparent why these pools would have differential SSSV requirements compared to nearby pools. Milne Point Schrader Bluff Oil Pool Conservation Order 477, Rule 5c contains the following requirement: "SSSV or injection valves capable of preventing backflow to the surface must be installed at a depth below the permafrost on gas or miscible injection wells when in service." The proposed language for the revised pool rule is: "A SCSSV or subsurface- controlled subsurface safety valve capable of preventing backflow to the surface must be installed at a depth below the permafrost on miscible injection wells when in service." This requirement is inconsistent with those contained in the other Milne Point conservation orders. Specifically, there is no requirement for a SSSV in existing or the proposed conservation orders which apply to Milne Point Unit operations: Kuparuk River Oil Pool (CO 432D, Rule 5) or the Sag River Oil Pool (CO 423, Rule 7). Depending on the location, a SSSV may be required in wells under the new SVS regulations. • Prudhoe Bay Borealis Oil Pool Conservation Order 471, Rule 3c contains the following requirement: "Subsurface safety valves (SSSV) must installed y st be nstalled on gas or miscible (MI) injection wells when in service." The proposed language for the revised pool rule is: "A SCSSV or subsurface- controlled subsurface safety valve capable of preventing backflow to the surface must be installed at a depth below the permafrost on miscible injection wells when in service." This requirement is inconsistent with those contained in the other Prudhoe Bay Unit conservation r o ders. Specifically, there is no requirement for SSSV q SSV in existing or the proposed conservation orders which apply to the following Prudhoe Bay Unit (PBU) pools: Prudhoe (CO 341E, Rule 5), Midnight Sun (CO 452, Rule 6), Aurora (CO 457B, Rule 3), Orion (CO 505B, Rule 3), Polaris (CO 484A, Rule 3), Put River (CO 559, Rule 3), Raven (CO 570, Rule 5), North Prudhoe (CO 345, Rule 4), West Beach (CO 311B, Rule 6), or Lisburne (CO 207A). In addition, the current explicit requirement for SSSVs contained in several existing PBU conservation orders is proposed to be removed. Depending on the location, a SSSV will be required in some wells under the new regulation. We respectfully request the Commission rescind without replacement the existing language in the Milne Point Schrader Bluff and Prudhoe Bay Borealis Conservation Orders related to SSSV. If you have any questions, please call me at 564 -4194. Sincerely, 0---,4,(gcr,„„ Harold R. Engel Alaska Drilling & Wells Engineering Team Leader BP Exploration (Alaska) Inc. 2 BP Exploration (Alaska) and Alaska Oil & Gas Association Testimony regarding AOGCC's consideration to rescind part or all the Safety Valve System Rules in Existing Conservation Orders Public Hearing December 6, 2010 Harry Engel, BP Engineering Team Leader and Chairman of the Alaska Oil & Gas Association AOGCC Task Group Good afternoon Chairman Seamount and Commissioners Norman and Foerster. My name is Harry Engel. This afternoon I will be wearing 2 hats, first representing BP Exploration (Alaska) regarding the subject of this public hearing and then representing the Alaska Oil & Gas Association (AOGA) as Chairman of the AOGCC Task Group on several related topics. I am the Engineering Team Leader responsible for Integrity Management in BP's Alaska Wells organization. My responsibilities span all of BP's Well operations in Alaska. I hold undergraduate degrees in Civil and Environmental Engineering and have over 30 years experience in the oil & gas industry, primarily associated with drilling and well intervention activities. My assignments have included drilling engineering, well site leader roles and various Health, Safety and Environmental management positions. The majority of my experience has been in most of the operating areas in Alaska. I have also worked in the Rocky Mountains and have had several temporary international assignments. II ' Page 1 of 5 • I submitted written comments on December 3, 2010 to the AOGCC concerning the proposed changes to the safety valve system rules in existing Conservation Orders and have provided additional copies this afternoon. I request that my December 3, 2010 letter be included in the public record concerning this subject. We agree with the intent to rescind language from conservation orders that is redundant to the recently adopted changes to the safety valve regulations, and we commend the AOGCC for taking this step to simplify and standardize the SVS requirements. We also agree with nearly all of the proposed specific changes, however, we question the proposed language in two of the conservation orders included in the public notice, the Prudhoe Bay Borealis oil pool, CO 471 and Milne Point Schrader Bluff oil pool, CO 477. During the process leading up to the new SVS regulations there was extensive discussion related to the potential requirement for subsurface safety valves (SSSV) in water - alternating -gas or WAG wells. The new SVS regulations specifically require SSSV in gas only injection wells but not in WAG wells. Miscible injection (MI) wells referenced in the proposed changes to the two Conservation Orders could be MI only or MI WAG wells. Per the new SVS regulations, MI only injection wells are required to have a SSSV as "gas -only injection wells ", yet MI WAG wells do not require a SSSV. Maintaining the requirement for SSSV in WAG wells at Prudhoe Bay Borealis and Milne Point Schrader Bluff Oil Pools seems inconsistent with the intent of standardizing the SVS regulations. It is not apparent why these pools would have differential SSSV requirements Page2of5 compared to nearby pools. We respectfully request the Commission rescind, without replacement the existing language in the Milne Point Schrader Bluff and Prudhoe Bay Borealis Conservation Orders related to SSSV. At this point I would be happy to address any questions. Now I would like to represent the Alaska Oil & Gas Association (AOGA) as Chairman of the AOGCC Task Group on several related topics that are of interest to AOGA member companies. The main topic I would like to present is the transition period for operators to design, order, fabricate, transport, install and test necessary equipment to comply with the new SVS regulations that became effective December 3, 2010. The interpretation of 20 AAC 25.265 (f) could significantly impact the number of wells required to have a SSSV and the type of valve installed before the next tubing workover. Section (f) refers to wells completed before December 3, 2010 that are subject to section (d) and that are not equipped with functional hardware that would allow installation of a subsurface safety valve. These wells must comply with section (d) no later than the date of the next tubing workover. Section (d) requires a fail -safe automatic surface controlled subsurface safety valve. It's reasonable to interpret that if a well does not have the functional hardware necessary to install a surface controlled subsurface safety valve, the operator would be Page 3 of 5 11/ 110 required to install a surface controlled subsurface safety valve no later than the next tubing workover. It is not clear if the Commission would expect an operator to install non - surface controlled subsurface safety valves in wells that have a suitable profile for that type of SSSV in the tubing. We would appreciate clarity related to this issue due to the impact on the number of appropriate valves that would need to be designed, fabricated and installed. Considering the timing to design, order, fabricate, transport, install and test necessary the equipment to comply with the new regulations, we request the Commission formally document a one year transition period for operators to comply with the regulations. The next item I would like to address relates to a proposed Industry Guidance Bulletin. It would be appreciated if the Commission could provide an update on the effort to prepare the Bulletin related to testing, reporting, calculation of SVS pad failure rates and potential consequences. Page 4 of 5 4. Lastly I would like to make a recommendation for consideration for a future revision to the SVS regulations. The regulations effectively define a "safety valve system" in sections 20 AAC 25.265 (b) and (c). These sections reference surface safety valves, actuators, low pressure detection devices and other surface related components. Subsurface safety valves are mentioned in section (d) yet not specifically referenced as being included as part of the entire safety valve system. Therefore it appears one could interpret that subsurface safety valves are not included in the definition of a "safety valve system ". This could possibly impact the applicability of section (c)(8) which provide a one year period after December 3, 2010 to gain Commission approval to operate components of a safety valve system that do not meet the requirements of section (c) items 1 -7. This section applies to surface safety equipment only. It could also possibly impact the calculation of SVS test results depending upon if the SSSV is included in the calculation. A clear definition of a "safety valve system" would avoid potential confusion. Thank you for the opportunity to provide comments. Page 5 of 5 • SVS Testimony My name is MJ Loveland. I'm currently a Well Integrity Project Supervisor for ConocoPhillips Alaska. I have a Bachelor of Science degree in Petroleum Engineering from the University of Wyoming. I have 21 years of industry experience and have been working with safety valve systems and the safety valve regulations since 2003. At that time I was the Supervisor that gave work direction and training to the crews that perform the safety valve performance tests. I have also been an active member on the team working with the AOGCC on the Safety Valve system regulation update since 2006. My current role is acting as an advisor and a single point of contact that addresses questions and projects in regards to Well Integrity issues including safety valve systems. Conservation Orders 406B.001 and 432D.009 are on the list to be rescinded. These CO's allow LPP's to be defeated on West Sak and Kuparuk Injection wells that have low surface injection pressure, less than 500 psi and 700 psi respectively, until the injection pressure reaches or exceeds those injection pressures. ConocoPhillips understands that an allowance to defeat the LPP is covered under • 20AAC 25.265.j2 However, J2 also states we must have authorization from the Commission to not have 24 man watch when the pilots are defeated. ConocoPhillips suggests leaving these two orders in p lace as that authorization. In West Sak operations it is very common for the surface injection pressure to take several weeks to stabilize above 500 psi after a shut in event or well work that lasts even as short as 12 hours. Most of the time it is not known until after the well is brought online that the pressure will stabilize below 500 psi. Therefore advance notice for authorization is not practical and a 24 hour man watch is a large burden for in our opinion a low risk practice. Roughly one well per month for up to 2 weeks to a month would require a man watch. There are 4 separate drill sites which could have WS injectors with injection pressures less than 500 psi at any one time. The injection pressure can be so low as the wells actually start out on a vacuum for several days which makes a LPP set point impossible to set or manage. Kuparuk injectors have similar issues when injection wells are pre produced before swapping them to injection. • • Rescinding 406B.001 and 432D.009 with out replacing them with equivalent authorization to defeat LPP's on wells with low surface injection pressure will hamper our ability to manage the West Sak flood and to a smaller degree the Kuparuk flood in a cost efficient as well as ressure efficient manner. Therefore Conoco Phillips request P p q 406B.001 and 432D.009 be retained or replaced with like authorization that allows the LPP's to be defeated within pressure restrictions with out a 24 hour man watch. 41 1 STATE OF ALASKA • PUBLISHER S NOTICE TO PUBLIS ADVERTISING ORDER NO. ADVERTISING ON PA S OVE R ER NO., CERTIFIED A O_02114019 AFFIDAVIT MUST OF PUBLICAT ITRI ION LIC ( TE H 2 OF WING THIS AD FORM) WITH ATTACHED COPY ER OF / 1 ORDER ADVERTISEMENT MUST BE SUBMITTED WITH INVOICE SEE BOTTOM FORtINVOICE ADDRESVo F AOGCC AGENCY CONTACT DATE OF A.O. November 3, 2010 R 333 W 7th Ave, Ste 100 Jody Colombie 0 Anchorage, AK 99501 PHONE PCN M (9071 793 —1221 DATES ADVERTISEMENT REQUIRED: O T Anchorage Daily News November 4, 2010 PO Box 149001 Anchorage, AK 99514 THE MATERIAL BETWEEN THE DOUBLE LINES MUST BE PRINTED IN g ITS ENTIRETY ON THE DATES SHOWN. SPECIAL INSTRUCTIONS: Type of Advertisement Legal® ❑ Display Classified ❑Other (Specify) SEE ATTACHED SEND INVOIGEII1 -$ PL CE1 AOGCC, 333 W. 7th Ave., Suite 100 PAGE 1 OF TOTAL OF ; 'r i Anchorage, AK 99501 2 PAGES ALL PAGES$ r` ',i �4 u ' REF TYPE NUMBER AMOUNT DATE COMMENTS 1 VEN 2 ARD 02910 FIN AMOUNT SY CC PGM LC ACCT FY NMR DST LIQ 1 10 02140100 73451 2 _ REQUISITIONED B - DIVISION APPROVAL: \ t- . 02 -902 (Rev. 3/94) '' Publisher /Original Copies: Department Fiscal, Department, Receiving AO.FRM • • Y114/2010: Anchorage Daily News Affidavit of Publication 1001 Northway Drive, Anchorage, AK 99508 PRICE OTHER OTHER OTH IE t GRAND AD # DATE /AQ ACCOUNT PER DAY CHARGES CHARGES #2 CHARGES #3 TOTAL 831911 11/04/2010 AO -02114 STOF0330 $149.40 $149.40 $0.00 $0.00 80.00 $149A0 Nsdce et Public Hart SPATE OP 'ALASKA Alaska OE and Gas Conservation Csnonsbadon STATE OF ALASKA ▪ Rescinding Conservation Orders Safety save System Rules in THIRD JUDICIAL DISTRICT Pursuant to AS 31.05.030(b), the Alaska OH and Gas Conservation Commission (Commission) wilt Shane Drew, being rst duly sworn on oath deposes and says that convene a public hearing at 2:00 p.m. on December g Y P oses Y 6, 2010 to consider rescinds part or all of those he is an advertising representative of the Anchorage Daily News, rules within existing cal riders relating to a daily newspaper. well safety valve systems. See Commission weblike y news p p er. for a complete listing of affected Conservation That said newspaper has been approved by the Third Judicial • www•aogcc.aiaska.gov. Court, Anchorage, AIaska, and it now and has been published in The Commission has tentatively sch$duted a public 1 hearing on this matter for Decenter 6, 2010 at 2:00 the English language continually as a daily newspaper in p.m. To request that the hearing be held, a written Anchorage, Alaska, and it is now and during all said time was request must be filed by 4 :30 p.m. on November 19, printed in an office maintained at the aforesaid place of d a request is not time tiled, the Commission may publication of said newspaper. That the annexed is a copy of an consider the issuance an order without a hearing. , advertisement as it was published in regular issues (and not in To learn if the Commission will hold a hearing, caii 907 793 - 1221 after November 23, 2010. supplemental form) of said newspaper on the above dates and that such newspaper was regularly distributed to its subscribers s • comments Commission, the on, at 333 West Ziu Y submitted to the Commission, at 333 West 7th during all of said period. That the full amount of the fee charged Avenue, Suite 100, Anchorage, Alaska 99501. oin publication is not in excess of the rate charged onrDeie December must be received no th than e a r p.m. for the foregoing g p g on December 6, 2010, except that, if a hearsrrg is private individuals. Qn ofntts tI breceived no later than dm hearing. if, because of a disability, special accommodations may be needed to comment or attend the hearing, Gad 907- 793 -1221 by November 29, 2010. Signed .Ll. t&i 40f411 oasts., t : 3eeniount x. Chair, Commissioner Subscribed and sworn to me before this date: AO-02114019 Published: November 4, 2010 NOV 042010 Notary Public in and for the State of Alaska. Third Division. Anchorage, Alaska MY COMMISSION EXPIRES: .4 -----------_ RECEIVEiD' ' �OTAI I 4J $ ins & Sat Cans. COMI 3i0IR Aathorage ;__ �; • ,, 1 • • Notice of Public Hearing STATE OF ALASKA Alaska Oil and Gas Conservation Commission Re: Rescinding Safety Valve System Rules in Existing Conservation Orders Pursuant to AS 31.05.030(b), the Alaska Oil and Gas Conservation Commission (Commission) will convene a public hearing at 2:00 p.m. on December 6, 2010 to consider rescinding part or all of those rules within existing Conservation Orders relating to well safety valve systems. See Commission website for a complete listing of affected Conservation Orders. www.aogcc.alaska. gov. The Commission has tentatively scheduled a public hearing on this matter for December 6, 2010 at 2:00 p.m. To request that the hearing be held, a written request must be filed by 4:30 p.m. on November 19, 2010. If a request is not timely filed, the Commission may consider the issuance of an order without a hearing. To learn if the Commission will hold a hearing, call 907 - 793 -1221 after November 23, 2010. Written comments regarding the application may be submitted to the Commission, at 333 West 7th Avenue, Suite 100, Anchorage, Alaska 99501. Comments must be received no later than 4:30 p.m. on December 6, 2010, except that, if a hearing is held, comments must be received no later than the conclusion of the hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, call 907-793-1221 by November 29, 2010. Daniel T. Seamount, Jr. Chair, Commissioner • STATE OF ALASKA NOTICE TO PUBLISHER ADVERTISING ORDER NO. ADVERTISING INVOICE AFFIDAVIT MUST OF BEB IN PUBLICATION TRIPLICATE (PART SHOWING 2 OF THIS ADVERTISING FORM) WITH ATTACHED ORDER NO., COPY CERTIFIED OF M /t, O_02114019 ORDER ADVERTISEMENT MUST BE SUBMITTED WITH INVOICE SEE ,, BOTTOM FtR INVOICE ADDRESS, 0 ., a'IiIIIIPM rVN II I F AOGCC AGENCY CONTACT DATE OF A.O. R 333 West 7 Avenue. Suite 100 Jody Colombie November 3. 2010 ° Anchorage_ AK 99501 PHONE PCN M (9071 793 -1221 DATES ADVERTISEMENT REQUIRED: o Anchorage Daily News November 4, 2010 PO Box 149001 Anchorage, AK 99514 THE MATERIAL BETWEEN THE DOUBLE LINES MUST BE PRINTED IN g ITS ENTIRETY ON THE DATES SHOWN. SPECIAL INSTRUCTIONS: Account # STOF0330 AFFIDAVIT OF PUBLICATION United states of America REMINDER State of ss INVOICE MUST BE IN TRIPLICATE AND MUST REFERENCE THE ADVERTISING ORDER NUMBER. division. A CERTIFIED COPY OF THIS AFFIDAVIT OF PUBLICATION MUST BE SUBMITTED WITH THE INVOICE. Before me, the undersigned, a notary public this day personally appeared ATTACH PROOF OF PUBLICATION HERE. who, being first duly sworn, according to law, says that he /she is the of Published at in said division and state of and that the advertisement, of which the annexed is a true copy, was published in said publication on the day of 2010, and thereafter for consecutive days, the last publication appearing on the day of , 2010, and that the rate charged thereon is not in excess of the rate charged private individuals. Subscribed and sworn to before me This _ day of 2010, Notary public for state of My commission expires Orders Establishing Requirements for Well Safety Valve Systems AOGCC; 11/2/2010 Unit/Field Pool Conservation Rule Rescind Rule? Existing Order Requirement New Regulation Provisions Revised Rule - Well safety valve systems" (2) Comment Order 111 Addressing Regts from Order fall - are auto SSV and SCSSV; injection wells (except disposal) require "Injection web (evck ding disposal injectors) must be equipped wiM(i) a dou ble check valve Check valve requirements f« AE injectors are nBl covered by Colville River Unit Qannik 605 5 no (i) double check valve, o(11) single check valve and SSV; Injection valve 25. 285 (x);25.265(6);25.265(d)(2)(H): a nrangement or (11) ngle oneckvalve andassv. A SUbaurfaoecontrolled injection valve« satisfies single check valve requirement; test every 6 months 25.265)h)(5) scssv satisfies the requirements m a single check valve.' reatlopted regulation fail -safe auto SSV and SCSSV; injection wells (except disposal) require ' Injection wells (excluding disposal injectors) must be equipped wd h() a double check valve Oooguruk Oooguruk • Nuiqsut 597 6 no (ft double check valve, or (ii) single check valve and SSV; injection valve 25.265(x); 25.2659(6); 25.265(tl)(1); argen,mt or (ii) a single check valve and a SSV. A subsurface-controlled injection valve or cha k regrequirements for injectors are 6d covered subsurface-controlled satisfies single check valve requirement; test every 6 months 25.265(h)(5) scssv satisfies the requirements of a single check valve' aPt 9U ion fad -safe auto SSV and SCSSV; injection wells (except disposal) require 'Injection wells (excluding disposal injectors) must be equipped with(I) a double check valve Oooguruk Oooguruk - Kuparuk 596 6 no (i) double check v a l v e , single check valve and SSV; injection valve 25 .265(x);25.265(6);25.265(9)(1); arrangement or Oft a single check valve and aSSV. A subsurface-controlled injection valve or rhaked rev irements for Injectors are �owered by satisfies single check valve requirement; test every 6 months 25.265(h)(5) scssv satisfies the requirements or a single check valve.' fpl f rogs fail-safe auto SSV and SCSSV; maintain list of wells w removed or 25.265(a); 25.265(6); 25.265(tl)(2)(F); Requirement In maintain a wellhead sign and list of wells tom, Prudhoe Bay Unit Raven 570 5 yes wA le t SVS was with requirement to maintain a tag deactivated SVS; sign m wellness 25.265(m) Colville River Unit Fiord 569 5 no () check valve, or () single check valve 565; InjectNm�valve 25.265(a); 25.265(6); 25.265(tl)(2)(H); a rron B M� or (ii) a�sln9le m l valvvo and a ssv. ti unaurtacv lection w Ch7k valve requirements for injectors are not covered by satisfies single check valve requirement; test every 6 months 25.265(h)(5) sessysadsr time requirements m a single cheek valve." d0 d ` ati0 fail-safe auto SSV an; SCSSV; injection wells (except disposal) require " Inection wells ( exclutling disposal injeclars) must be equipped wnh(i) a double check valve equbemen injectors are yid covered by 25.265(a); 25.265(6); 25.265(d)(2)(H); cneckvalver isnor in • Colville River Unit Nanuq - Kuparuk 563 6 no (i) double check valve, or (Ii) single check valve and SSV; injection valve 50600 D ent «(ii) a single check valve antl a SSV. A subsurlace- cmlmlled injection valve a readopted regulation satisfies single check valve requirement; test every 6 months 25.2650)(5) SCSSV satisfies the requirements of a single check valve" • • fail -safe auto SSV and SCSSV; injection wells (except disposal) require ' Injection wells (excluding disposal injectors) must be equipped wthn) a double check valve 25.265(x); 25.265(6); 25.2650)(2)(H); a Check valve requirements for injectors are rwt covered by Colville River Unit Nanuq 562 6 no () double check valve, w (ii) single check valve and SSV; injection valve 25 h nangement w (ii) a single check valve and SSV. A subsurface-controlled injection valve « readopted regulator satisfies single check valve requirement; test every 6 months ()( ) SCSSV satisfies the requirements of a single a check valve." Prudhoe Ba Unit Put River 559 3 es fat-safe auto SSV; SSSV landing nipple belay permafrosC test as 25.265(a); 25.265(b); 25.265(d); Readopted 25.265(d) dictates which wells require sssv; Y y prescribed by Commission 25.265(h)(5) WA replaces SSSV nipple requirement for all wells Deep Creek Unit Happy Valley 553 3 yes SSV or SSSV 25.265(2) N/A Prudhoe Ba Unit Orion 5058 3 es fail -safe auto SSV; SSSV landing nipple below permafros test as 25.265(2); 25.265(b); 25.265(d); Readopted 25.265(9) dictates which wells require 0555; Y Y prescribed by Commission 25.265(11)(5) WA replaces SSSV nipple requirement for all wells Prudhoe Ba Unit Polaris 484A 3 yes fan -axle auto SSV; SSSV landing nipple below permafrost; test as 25.265(a); 25.265(b); 25.265(d); Readopted 25.265(d) dictates which wells require sssv; Y Y prescribed by commission 25.265(h)(5) WA replaces SSSV nipple requirement for all wens fail-safe auto SSV; SSSV larding nipple below permafrost; gas/M1 pre, requirement Milne Point Unit Milne Point • 477 5 no injection well require SSSV or injection valve below permafrost; test every 25.265(a); 25.265(b); 25.265(d); "A SCSSV w su�urtececontrolle9 injection valve capable m preventing beckflow to the surface Readopted 25.285(9)(5) does LxA Include SSSV r octet r« Schrader Bluff 6 months 25.265(h)(5) must be installed at a depth below the permafrost on miscible injection wells Mien In service." MI injectors Prudhoe Bay Unit Borealis 471 3 no fail -safe auto SSV; SSSV landing nipple below permafrost; 900/MI 25.265(a); 25.265(b); 25.265(d); "A SCSSV or subsurface-controlled injection valve capable of preventing backnow to the surface Readopted 25265(91(5) does N4 include SSSV regt for MI injection well require 565 below permafrost; test every 6 months 25.265(5)(5) must be installed at a depth below the permafrost on miscible injection Mods when in svelte" injectors Northstar Northstar 458A 4 no fail -safe auto SSV and SCSSV; test as prescribed by Commission; 500- 25 25.265(b); 25.265(d)(1) "The minimum setting depth far a tubing conveyed 0uteurface safety valve is 500 feet" Elating pod rule established a minimum sexing depth f« Me ft minimum setting depth 1« SSSV SSSV fail -safe auto SSV; SSSV landing nipple below permafrost; test every 6 25.265(a); 25.265(b); 25.265(d); Readopted 25.265(d) dictates which wells require SSSV; Prudhoe Bay Unit Aurora 4578 3 yes months 25.265(h)(5) N/A replaces SSSV nipple requirement for all wells fail-safe auto SSV; gas/N11 Injectors require 665 and single check valve "Injection wells (excluding disposal injectors) must be equipped with(i) a double check valve Check valve requirements f« injectors are nut covered by Kuparuk River Unit Meltwater 456A 5 no and SSSV landing nipple; water injection wells r a check 25.265(a); 25.265(6); 25.285(9); a (ii) valve subsurface-controlled injection valve « readopted valve, or (ii) single check valve a V; test every 6 months 25.265(h)(5) SCSSV satisfies the of single check vane. readopted for M injectors ec d)(5) does �t include ran -safe auto SSV (ad injectors and produces capable of unassisted 25.265(a); 25.265(b); 25.265(4); Readapted 25.265(d) dictates which wens require SSSV; Prudhoe Bay Unit Midnight Sun 452 6 y flow surface); test every s months 25.265(h)(5) N/A replaces SSSV nipple requirement for all wells fall -safe auto SSV and SCSSV; SSSV may be installed above or below "The setting depth of a required subsurface safety valve must be located In the tubing either Existing pod rule established alternate 550V setting depth; Duck Island Unit Eider 449 7 no permafrost; injection weds require double check valve, LPs trip pressure; 25.265(a); 25.265(6); 25.285(9)(1); above or below permafrost. Injection wens must be equipped with a double check valve check valve requirements for injectors are not covered by test every 6 months 25.265(h)(5) arrangement." readopted regulation lai1sa(e auto SSV and SCSSV (producers and gas injectors); water 'injection wells (excluding disposal injectors) must be equipped with() a double check valve Check valve requirements for injectors are not covered by • Colville River Unit Alpine 443B 5 no injection wells require (i) double check valve, Of (1i) single check valve 25.265(2); 25.265)b); 25.265(d)(2)(H) arrangement or (ii) a single check valve and a SSV. A subsurface-controlled injection valve Of readopted regulation and 5511 SCSSV satisfies the requirements of a single check valve." fan -safe auto SSV; gas/MI injectors require SSV and single check valve "Injection wells (excluding disposal injectors) must be equipped with() a double check valve Check valve requirements f« Injectors are IL covered by ng nipp injection squire () 2$265(x); 25 25.26$(4); heck valve and a 5511. A subsurrace-ccontrolled i valve or readopted r Nation; readopted 25.265(9)(5) does iwt include Kuparuk River Unit Tabasco 435A 6 no and SSSV landi le; water in tion wellsr 1 double check arrangement or(ii)a single check injection erg valve, or (ii) single check valve and SSV; test every 6 months 25.265(h)(5) SCSSV satisfies the requirements of a single check valve" SSSV requirement for MI injectors fail -safe auto SSV (5 /D well and artificial lift); sign on well if SVS Requirement to maintain a wellhead sign and list of wells with Kuparuk River Unit; Kuparuk 432D 5 yes deactivated; maintain list of wens wmeactieated SVS; test as prescribed 25.2fi5(a); 25.265(6); 25.265(h)(5); N/A deactivated SVS was replaced with requirement to maintain atag Milne Point Unit . Commission 25265(m) on well when not manned fail -safe auto SSV; gas/MI injectors require SSV and single check valve "Injection wells (excluding disposal injectors) must be equipped with(1) a double check valve Check valve requirements for injectors are rid covered by h 265 25.265(a); 25.285(6); 25.265(9); Kuparuk River Unit Tam 430A 6 no and SSSV landing arrangement w heck valve and a SSV. A subsurface-controlled injection readopted r lation, readopted 25 d .260 s Ixt include ng nipple; wafer injection w ells require (1) double check . ranger (ii) a single c lec ion va ve or egu pt ()( ) does valve, or (ii) single check valve and SSV; test every 6 months 25 ()( ) SCSSV satisfies the requirements of a single check valve" SSSV requirement for MI injectors Milne Point - Sag fail -safe auto 65V; injection wells requke double check valve; test every Check valve requirements for injectors are nut covered by Milne Point Unit 423 7 no 6 months 25.265(a); 25.265(6); 25 "Injection wells must be equipped with a double check valve arrangement." River readopted regulation Check valve requirements for injectors are nd covered by fail-safe auto SSV; gas/MI injectors require SSV and single check valve and SSSV landing nipple; water injection wells require (1) double check "Injection wells (excluding disposal injectors) must be equipped with() a double check valve readopted regulation; readapted 25.265(9)(5) does nd include valve, or (ii) Stigler check valve and SSV; test every 6 months; CO 25.265(a); 25.265(5); 25.265(d); arrangement or (ii) a single check valve and a SSV. A subsurface-controlled injection valve w SSSV requirement for MI injectors; CO 4066.001 is rescinded, Kuparuk River Unit Kuparuk - West Sak 406B 6 no 4066.001 modifies Rule 6(e) - LPP may be defeated on W. Sale injectors 25.265(h)(5) SCSSV satisfies the requirements of a single check valve. The Low Pressure Pilot may be replaced by language about defeating the LPS when surface w /surface 500 / notice when defeated and laced back in defeated on West Sak water injectors with surface Mjecti00 less than 500 injection pressure (« West Sak water injector is 2 'notice pressure < psi w p j ) pressure Psi" requirements are covered by readopted 20 AAC 25.265()(2) and service 25265(m)) fan -sale auto SSV and SCSSV; LPS trip pressure; readily accessible Badami Badami 402B 6 yes control unit; 5550 below permafrost; NTE 210days between tests; 25.265(a); 25.265(6); 25.265(11); N/A submit test reruns electronically within 14days; SVS defeated/removed 25.265(m) only if well SI or pad continuously manned Page 1 of 2 Orders Establishing Requirements for Well Safety Valve Systems AOGCC; 11/2/2010 Conservation New Regulation Provisions s Comment Unit/Field Pool Rule Rescind Rule? Existing Order Requirement Revised Rule - "Well safety valve systems'' ( 2 1 Order (11 Addressing Refits from Order fail -sate auto SSV (S/D well and artificial lilt); sign on well if sys 25.285(a); 25.265(5); 25 Requirement to maintain a wellhead sign and list of wells with Prudhoe Bay Unit North Prudhoe 345 4 yes deactvated; maintain list of wells w /deactivated sys; lest as prescribed (5)(5); NIA deactivated SVS was raced with requirement to maintain a tag by commission 25.265(m) on well when not manned fail-safe auto SSV (S/D well and artificial In); if SSSV installed a must be maintained and tested as part of SVS; sign on urea if SVS deactivated; 25.285(8); 25.265(5); 25.265(d); NIA Readopted 25.265(d) dictates which webs require SSSV; Prudhoe Bay Unit Prudhoe 341E 5 yes maintain list of wells wldeactiveted sys; test as prescribed by 25.265(h)(5) replaces SSSV nipple requirement for all wells Commission fa0.eafe auto SSV and sCSsV; maintain list of wells wI removed or 25.265(8); 25.265(5); 25.265(d); Readopted 25.265(d) dictates which weds require SSSV; N/A Bay Unit Niakuk 329A 5 yes deactivated SVS; sign on wellhead 25.265(h)(5); 25.265(m) replaces SSSV nipple requirement for all wells ail-safe auto SSV and SCSsV; SSSV may be rermoved as pad of 25.265(a); 25.265(5); 25.265(4); Readopted 25.265(d) dictates which wells require SSSV; Prudhoe Bay Unit Pt. McIntyre 3178 8 y routine well opts wre notice 25.285(1); 25.265(m) N/A replaces SSSV nipple requirement for all wells fall-safe auto SSV; sign on well if SVS deactivated; maintain list of wells 25.265(8); 25.265(5); 25.265(d); Readopted 25.265(d) dictates which wells require 5000; Prudhoe Bay Unit West Beach 311B 8 y wmeectivated SVS; test as prescribed by Commission 25.285(5)(5); 25.265(m) N/A replaces SSSV nipple requirement for all wells West Folk West Fork (Sterling 300 5 yes fail auto 5V5 on each production tubing 25.265(a); 25.265(5) NIA A&B) Requirement to maintain a wellhead sign and fist of wells with Prudhoe Bay Unit Lisburne 207A 7 yes fail -safe auto SSV; sign on well a SVS deactivated; maintain asl or was 25.265(0); 25.265(5); 25.265(h)(5); N/A deactivated SVS was replaces with requirement a maintain a tog w /deacbvated SVS; test as prescribed by commission 25.265(m) on well when not manned • Prudhoe Bay Unit Prudhoe - Kuparuk 98A 5 yes prwa uncontrolled valve installed below base or permafrost to 25.265(d) NIA Readopted 25.26 dictates which wens require sssv; spaces SSSV nipple requirement for all wells Commission policy dictating SVS performance testing AOGCC Policy - SVS (signed by by order of the Statewide N/A N/A N/A yes p y g 25.265(h); 25.265(1); 25.265(o) N/A commission 3/30/1994 (sgned by commission chairman Dave requirements Johnson) Footnotes (1) No SVS notes found in Injection Orders (2) New title for Revised Rule; "N /A" means entire pool rule to be rescinded • Page 2 of 2 • Mary Jones David McCaleb XTO Energy, Inc. IHS Energy Group George Vaught, Jr. Cartography GEPS P.O. Box 13557 810 Houston Street, Ste 200 5333 Westheimer, Suite 100 Denver, CO 80201 -3557 Ft. Worth, TX 76102 -6298 Houston, TX 77056 Jerry Hodgden Richard Neahring Mark Wedman Hodgden Oil Company NRG Associates Halliburton President 408 18 Street 6900 Arctic Blvd. Golden, CO 80401 -2433 P.O. Box 1655 Anchorage, AK 99502 Colorado Springs, CO 80901 Schlumberger CIRI Baker Tools Drilling and Measurements Land Department 795 E. Oil . 94 h Ct. 2525 Gambell St, #400 P.O. Box 93330 Anchorage, E Anchorage, AK 99503 Anchorage, AK 99503 Anchorage, AK 99515 -4295 Jill Schneider North Slope Borough Gordon Severson US Geological Survey P.O. Box 69 3201 Westmar Circle Barrow, AK 99723 4200 University Drive Anchorage, AK 99508 -4336 Anchorage, AK 99508 Jack Hakkila Darwin Waldsmith James Gibbs P.O. Box 190083 P.O. Box 39309 P.O. Box 1597 Anchorage, AK 99519 Ninilchick, AK 99639 Soldotna, AK 99669 Kenai National Wildlife Refuge Penny Vadla Cliff Burglin Refuge Manager 399 West Riverview Avenue 319 Charles Street P.O. Box 2139 Soldotna, AK 99669 -7714 Fairbanks, AK 99701 Soldotna, AK 99669 -2139 Richard Wagner Bernie Karl P.O. Box 60868 K &K Recycling Inc. Fairbanks, AK 99706 P.O. Box 58055 Fairbanks, AK 99711 \.\\ .,,,,.\.' ,,,,,71 • • Colombie, Jody J (DOA) From: Colombie, Jody J (DOA) Sent: Wednesday, November 03, 2010 1:43 PM To: Ballantine, Tab A (LAW); 'Aaron Gluzman'; Bettis, Patricia K (DNR); caunderwood @marathonoil.com; 'Dale Hoffman'; David Lenig; 'Gary Orr; 'Jason Bergerson'; 'Joe Longo'; Marc Kuck; 'Mary Aschoff; 'Matt Gill'; Maurizio Grandi; Ostrovsky, Larry Z (DNR); Richard Garrard; 'Sandra Lemke'; Talib Syed; 'Tiffany Stebbins'; 'Wayne Wooster; 'William Van Dyke'; Woolf, Wendy C (DNR); (foms2 @mtaonline.net); ( michael .j.nelson @conocophillips.com); ( Von. L.Hutchins @conocophillips.com); Alan Dennis; alaska @petrocalc.com; Anna Raff; Barbara F Fullmer; bbritch; Becky Bohrer; Bill Penrose; Bill Walker; Bowen Roberts; Brad McKim; Brady, Jerry L; Brandon Gagnon; Brandow, Cande (ASRC Energy Services); Brian Gillespie; Brian Havelock; Bruce Webb; carol smyth; Chris Gay; Cliff Posey; Crandall, Krissell; dapa; Daryl J. Kleppin; Dave Matthews; David Boelens; David House; David Steingreaber; 'ddonkel @cfl.rr.com'; Deborah J. Jones; Delbridge, Rena E (LAA); 'Dennis Steffy'; Elowe, Kristin; eyancy; Francis S. Sommer; Fred Steece; Garland Robinson; Gary Laughlin; Gary Rogers; Gary Schultz; ghammons; Gordon Pospisil; Gorney, David L.; 'Greg Duggin'; Gregg Nady; gspfoff; Harry Engel; Jdarlington (jarlington @gmail.com); 'Jeanne McPherren'; Jeff Jones; Jeffery B. Jones (jeff.jones @alaska.gov); Jerry McCutcheon; Jill Womack; 'Jim White'; 'Jim Winegarner; 'Joe Nicks'; 'John Garing'; 'John Katz'; 'John S. Haworth'; 'John Spain'; 'John Tower; 'Jon Goltz'; 'Judy Stanek'; 'Julie Houle'; 'Kari Moriarty'; 'Kaynell Zeman'; 'Keith Wiles'; 'Kim Cunningham'; 'Larry Ostrovsky'; 'Laura Silliphant'; 'Marilyn Crockett'; 'Mark Dalton'; 'Mark Hanley (mark.hanley @anadarko.com)'; 'Mark Kovac'; 'Mark P. Worcester; 'Marguerite kremer; 'Michael Dammeyer; 'Michael Jacobs'; 'Mike Bill'; 'Mike Mason'; 'Mike) Schultz'; 'Mindy Lewis'; 'MJ Loveland'; 'mjnelson'; 'mkm7200'; 'nelson'; 'Nick W. Glover; 'NSK Problem Well Supv'; 'Patty Alfaro'; 'Paul Decker (paul.decker @alaska.gov)'; 'Paul Figel'; 'PORHOLA, STAN T'; 'Randall Kanady'; 'Randy L. Skillern'; ' rob.g.dragnich @exxonmobil.com'; 'Robert Brelsford'; 'Robert Campbell'; 'Rudy Brueggeman'; 'Ryan Tunseth'; 'Scott Cranswick'; 'Scott Griffith'; Scott, David (LAA); 'Shannon Donnelly'; 'Sharmaine Copeland'; Shellenbaum, Diane P (DNR); Slemons, Jonne D (DNR); 'Sondra Stewman'; 'Steve Lambet; 'Steve Moothart'; 'Steven R. Rossberg'; 'Suzanne Gibson'; 'tablerk'; Tamera Sheffield; Taylor, Cammy 0 (DNR); Temple Davidson; Teresa Imm; Terrie Hubble; Thor Cutler; Tina Grovier; Todd Durkee; Tony Hopfinger; trmjrl; Vicki Irwin; Walter Featherly; Will Chinn; Williamson, Mary J (DNR); Yereth Rosen; Aubert, Winton G (DOA); Brooks, Phoebe; Davies, Stephen F (DOA); Fisher, Samantha J (DOA); Foerster, Catherine P (DOA); Johnson, Elaine M (DOA); Laasch, Linda K (DOA); Maunder, Thomas E (DOA); McIver, Bren (DOA); McMains, Stephen E (DOA); Norman, John K (DOA); Okland, Howard D (DOA); Paladijczuk, Tracie L (DOA); Pasqual, Maria (DOA); Regg, James B (DOA); Roby, David S (DOA); Saltmarsh, Arthur C (DOA); Scheve, Charles M (DOA); Schwartz, Guy L (DOA); Seamount, Dan T (DOA); Shartzer, Christine R (DOA) Subject: Public Notice SVS Rules.pdf - Adobe Acrobat Professional Attachments: Public Notice SVS Rules.pdf 1