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Home My WebLink AboutO 100INDEX OTHER ORDER NO. 100 1. -------------------- 2. February 21, 2013 3. -------------------- 4 - -------------------- 5. August 19, 2014 6. October 23, 2014 7. October 29, 2014 8. October 31, 2014 9. November 20, 2014 10. January 25, 2015 Docket No. OTH-14-024 Redoubt Unit #3 PTD 2010640 Cook Inlet Energy, LLC's (CIE) Facility Reports of Produced Gas Disposition Sundry: 313-075 Confidential Penalty Calculation held in secure storage Emails between AOGCC and CIE re: Gas Flaring CIE's response to AOGCC's email re: Gas Flaring Notice of Proposed Enforcement Action CIE's response to Proposed Enforcement Action AOGCC's letter to CIE re: Informal Review CIE's response to AOGCC's October 31, 2014 letter CIE's letter to AOGCC re: Required Documentation by Other Order No. 100 INDEX OTHER ORDER NO. 100 STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 W. 71h Avenue Anchorage, Alaska 99501 Re: Cook Inlet Energy, LLC's Failure to ) Other Order No. 100 Minimize or Prevent Gas Flaring. ) Redoubt Unit #3 PTD 2010640 January 8, 2015 ERRATA NOTICE The Alaska Oil and Gas Conservation Commission (AOGCC) notes that Other Order No. 100 had an erroneous date of November 25, 2014 written on page two, the date is November 25, 2013. This correction will be reflected in a corrected Other Order No. 100 to be issued by the AOGCC. DONE at Anchorage, Alaska and dated January 8, 2015. f Cathy . Foerster Chair, Commissioner 11-4 avi J. Mayberry Commissioner STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Avenue Anchorage, Alaska 99501 Re: Failure to minimize or prevent gas flaring Other Order No. 100 Corrected Redoubt Unit #3 Docket No. OTH-14-024 PTD 2010640 January 7, 2015 DECISION AND ORDER On October 23, 2014 the Alaska Oil and Gas Conservation Commission (AOGCC) issued a Notice of Proposed Enforcement Action (Notice) to Cook Inlet Energy, LLC (CIE) regarding the Redoubt Unit #3 (RU-3). The Notice advised that CIE failed to shut-in RU-3 when the Kustatan Production Facility (KPF) was undergoing a major overhaul and flared 24,668 MCF of gas from November 25, 2013 through February 28, 2014. The Notice proposed specific corrective actions and a $294,834 civil penalty under AS 31.05.150(a). CIE requested an informal review. That review was held December 1, 2014. Summary of Proposed Enforcement Action: The Notice identified violations by CIE of 20 AAC25.235(c). Violations occurred on November 25, 2013 when CIE failed to shut-in RU-3 when the KPF was undergoing a major overhaul and when CIE flared from RU-3 from November 25, 2013 through February 28, 2014. The Notice proposed the following corrective actions be completed by CIE: 1) within two (2) weeks following the date of receipt of AOGCC's final decision, CIE shall provide AOGCC a detailed description and an example of its regulatory compliance tracking program and a copy of its written management -of -change procedures; 2) within two (2) weeks following the date of receipt of AOGCC's final decision, CIE shall provide AOGCC with a root cause analysis addressing the violations, and timeline for implementing identified corrective actions. 3) within two (2) weeks following the date of receipt of AOGCC final decision, CIE shall provide AOGCC evidence that personnel responsible for gas disposition management Other Order No. 100 Correcte January 7, 2015 Page 2 of 4 and staff involved with facility and well operations have been trained in AOGCC regulatory requirements, including the process for requesting approval for flaring activities from the AOGCC. A copy of the training program syllabus is to be included with other appropriate documentation. The notice proposed the penalties for violating 20 AAC 25.235(c) as follows: - $25,000 for the initial violation — failure to shut-in RU-3 when the KPF was undergoing a major overhaul. - $269,834 for flaring 24,668 MCF of gas from November 25, 2013 through February 28, 2014. Gas Disposition: Under AOGCC regulations, "The operator shall take action in accordance with good oil field engineering practices and conservation purposes to minimize the volume of gas released, burned, or permitted to escape into the air. " Beginning November 25, 2013 intermittent flaring occurred at the KPF as a result of gas production from RU-3 during a planned compressor overhaul. No approval was sought from the AOGCC for this flaring which continued through February 28, 2014. CIE had previously requested authorization to flare from RU-3 at start up after a rig workover in February 2013. This approval was granted and extended for 72 hours as indicated in correspondence dated August 18, 2013. CIE claims that AOGCC's flaring authorization was "unclear." CIE also claims that the AOGCC approval granted in February 2013 [flaring from RU-3 during workover operations] was valid nine to twelve months later for flaring during the planned extended compressor overhaul. These assertions find no support in the record. CIE's previous request for extended gas flaring as part of the February 2013 workover operations demonstrates CIE's knowledge that extended flaring warrants authorization from AOGCC. Approval for flaring from RU-3 should have been requested from the AOGCC prior to the commencement of the planned work on the compressor in November 2013. Further under AOGCC regulations, the AOGCC will authorize the flaring "if the flaring or venting is necessary to prevent loss of ultimate recovery " Other Order No. 100 Correcte_ January 7, 2015 Page 3 of 4 In its correspondence and during the informal meeting, CIE outlined the difficulty with choking back RU-3 to achieve lower flowrates because of water influx and low wellhead pressures. Also, CIE outlined the difficulty with restarting RU-3 once the well was shut in. Since the well is an extended reach deviated well, a rig or coiled tubing unit is usually necessary to restore the well's production. These difficulties are evident in a review of the well file. CIE's initial request for authorization to flare and its subsequent efforts to mitigate its flaring from RU-3 demonstrate that CIE understood the potential for a finding of waste due to flaring during the compressor overhaul. AOGCC has given CIE's mitigation efforts, as well as the condition of RU-3, due consideration in adjusting the final penalty imposed. Findings and Conclusions: The AOGCC finds that CIE violated 20 AAC 25.235(c) of the regulations. Consideration of the mitigating circumstances outlined above, however, results in the elimination of the monetary penalty that was proposed. The proposed corrective actions are deemed appropriate in this circumstance to address and prevent recurrence of the regulatory violation and are retained in the AOGCC's Final Decision. Now Therefore It Is Ordered That: Within 2 weeks after this Decision and Order becomes final, CIE shall provide AOGCC: 1) a detailed description and an example of its regulatory compliance tracking program and a copy of its written management -of -change procedures; 2) the full report of a root cause analysis addressing the violations, and timeline for implementing identified corrective actions. 3) evidence that CIE (and contract) personnel responsible for gas disposition oversight and field staff involved with facility and well operations have been trained in AOGCC regulatory requirements, including the process for requesting approval for flaring activities from the AOGCC. A copy of the training program syllabus is to be included with other appropriate documentation. As an Operator involved in an enforcement action, you are required to preserve documents concerning the above action until after resolution of the proceeding. Other Order No. 100 Correcte January 7, 2015 Page 4 of 4 Done at Anchorage, Alaska and dated nunc pro tunc January 7, 2015. Cathy . Foerster Chair, Commissioner avid J. ayberry Commissioner 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 AOGCC grants for good cause shown, a person affected by it may file with the AOGCC 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 AOGCC 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 AOGCC deniesreconsideration, 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 AOGCC mails, OR 30 days if the AOGCC 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 AOGCC 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 AOGCC, and it may be appealed to superior court. That appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on 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. Carlisle, Samantha J (DOA) From: Carlisle, Samantha J (DOA) Sent: Friday, January 09, 2015 8:19 AM To: 'AKDCWellIntegrityCoordinator'; 'Alexander Bridge'; 'Allen Huckabay'; 'Andrew VanderJack'; 'Anna Raff'; 'Barbara F Fullmer'; 'bbritch'; 'Becky Bohrer'; 'Bill Barron'; 'Bill Penrose'; 'Bill Walker'; 'Bob Shavelson'; 'Brian Havelock'; Burdick, John D (DNR); 'Carrie Wong'; 'Cliff Posey'; 'Colleen Miller'; 'Corey Cruse'; 'Crandall, Krissell'; 'D Lawrence'; 'Dave Harbour'; 'David Boelens'; 'David Duffy'; 'David Goade'; 'David House'; 'David McCaleb'; 'David Scott'; 'David Steingreaber'; 'David Tetta'; 'Davide Simeone'; 'ddonkel@cfl.rr.com'; 'Dean Gallego'; Delbridge, Rena E (LAA); 'Donna Ambruz'; 'Ed Jones'; 'Elowe, Kristin'; 'Evans, John R (LDZX)'; 'Francis S. Sommer'; 'Frank Molli'; 'Gary Oskolkosf'; 'George Pollock'; 'ghammons'; 'Gordon Pospisil'; 'Greg Duggin'; 'Gregg Nady'; 'gspfoff'; 'Jacki Rose'; 'Jdarlington Oarlington@gmail.com)'; 'Jeanne McPherren'; 'Jeffery B. Jones (Jeff Jones@alaska.gov)'; 'Jennifer Williams'; 'Jerry Hodgden'; 'Jerry McCutcheon'; 'Jessica Solnick'; 'Jim Watt'; 'Jim White'; 'Joe Lastufka'; 'Joe Nicks'; 'John Adams'; 'John Easton'; 'John Garing'; 'Jon Goltz'; 'Jones, Jeffrey L (GOV)'; 'Juanita Lovett'; 'Judy Stanek'; 'Julie Houle'; 'Julie Little'; 'Karl Moriarty'; 'Keith Wiles'; 'Kelly Sperback'; 'Klippmann'; 'Laura Silliphant (laura.gregersen@alaska.gov)'; 'Leslie Smith'; 'Lisa Parker'; 'Louisiana Cutler'; 'Luke Keller'; 'Marc Kovak'; 'Mark Dalton'; 'Mark Hanley (mark.hanley@anadarko.com)'; 'Mark Landt'; 'Mark Wedman'; 'Marguerite kremer (meg.kremer@alaska.gov)'; 'Michael Duncan'; 'Michael Jacobs'; 'Michael Moora'; 'Mike Bill'; 'Mike Mason'; 'Mike) Schultz'; 'MJ Loveland'; 'mjnelson'; 'mkm7200'; Morones, Mark P (DNR); 'nelson'; 'Nichole Saunders'; 'Nick W. Glover'; 'Nikki Martin'; 'NSK Problem Well Supv'; 'Oliver Sternicki'; 'Patty Alfaro'; 'Paul Craig'; 'Paul Decker (paul.decker@alaska.gov)'; 'Paul Mazzolini'; Pike, Kevin W (DNR); 'Randall Kanady'; 'Randy L. Skillern'; 'Randy Redmond'; 'Renan Yanish'; 'Robert Brelsford'; 'Ryan Tunseth'; 'Sara Leverette'; 'Scott Griffith'; 'Shannon Donnelly'; 'Sharmaine Copeland'; 'Sharon Yarawsky'; Shellenbaum, Diane P (DNR); Slemons, Jonne D (DNR); 'Smart Energy Universe'; Smith, Kyle S (DNR); 'Sondra Stewman'; 'Stephanie Klemmer'; 'Steve Moothart (steve.moothart@alaska.gov)'; 'Suzanne Gibson'; 'Tamers Sheffield'; 'Tania Ramos'; 'Ted Kramer'; 'Temple Davidson'; 'Terence Dalton'; 'Teresa Imm'; 'Thor Cutler'; 'Tim Mayers'; 'Tina Grovier'; 'Todd Durkee'; 'Tony Hopfinger'; 'trmjrl'; 'Tyler Senden'; 'Vicki Irwin'; 'Vinnie Catalano'; 'Walter Featherly'; 'Yereth Rosen'; 'Aaron Gluzman'; 'Aaron Sorrell'; 'Ajibola Adeyeye'; 'Alan Dennis'; 'Andrew Cater'; 'Anne Hillman'; 'Bruce Williams'; Bruno, Jeff J (DNR); 'Casey Sullivan'; 'David Lenig'; 'Diane Richmond'; Dickenson, Hak K (DNR); 'Donna Vukich'; 'Eric Lidji'; 'Erik Opstad'; 'Gary Orr'; 'Graham Smith'; 'Greg Mattson'; 'Hans Schlegel'; Heusser, Heather A (DNR); 'Holly Pearen'; 'James Rodgers'; 'Jason Bergerson'; 'Jennifer Starck'; 'Jill McLeod'; 'Jim Magill'; 'Joe Longo'; 'John Martineck'; 'Josh Kindred'; 'Kenneth Luckey'; King, Kathleen J (DNR); 'Laney Vazquez'; 'Lois Epstein'; Longan, Sara W (DNR); 'Marc Kuck'; 'Marcia Hobson'; 'Marie Steele'; 'Matt Armstrong'; 'Matt Gill'; 'Mike Franger'; 'Morgan, Kirk A (DNR)'; 'Pat Galvin'; 'Patricia Bettis'; 'Peter Contreras'; 'Richard Garrard'; 'Robert Province'; 'Ryan Daniel'; 'Sandra Lemke'; 'Scott Pexton'; 'Shaun Peterson'; 'Susan Pollard'; 'Talib Syed'; 'Terence Dalton'; Todd, Richard J (LAW); Tostevin, Breck C (LAW); 'Wayne Wooster'; 'William Hutto'; 'William Van Dyke'; 'Ballantine, Tab A (LAW) (tab.ballantine@alaska.gov)'; 'Bender, Makana K (DOA) (makana.bender@alaska.gov)'; 'Brooks, Phoebe L (DOA) (phoebe.brooks@alaska.gov)'; Carlisle, Samantha J (DOA); 'Colombie, Jody J (DOA) oody.colombie@alaska.gov)'; 'Crisp, John H (DOA) Oohn.crisp@alaska.gov)'; 'Davies, Stephen F (DOA) (steve.davies@alaska.gov)'; Eaton, Loraine E (DOA); Toerster, Catherine P (DOA) (cathy.foerster@alaska.gov)'; Trystacky, Michal (michal.frystacky@alaska.gov)'; 'Grimaldi, Louis R (DOA) (lou.grimaldi@alaska.gov)'; 'Guhl, Meredith (DOA sponsored) To: (..._, _dith.guhl@alaska.gov)'; Herrera, Matthew _ ►OA); 'Hill, Johnnie W (DOA)'; 'Hunt, Jennifer L (DOA)'; Kair, Michael N (DOA); Konkler, Stacey L (DOA); Loepp, Victoria T (DOA); Mayberry, David J (DOA); 'Mumm, Joseph (DOA sponsored) ooseph.mumm@alaska.gov)'; 'Noble, Robert C (DOA) (bob.noble@alaska.gov)'; 'Paladijczuk, Tracie L (DOA) (tracie.palad ijczuk@alaska.gov)'; 'Pasqual, Maria (DOA) (maria.pasqual@alaska.gov)'; 'Regg, James B (DOA) oim.regg@alaska.gov)'; 'Roby, David S (DOA) (dave.roby@alaska.gov)'; 'Scheve, Charles M (DOA) (chuck.scheve@alaska.gov)'; 'Schwartz, Guy L (DOA) (guy.schwartz@alaska.gov)'; 'Sea mount, Dan T (DOA) (dan.seamount@alaska.gov)'; 'Singh, Angela K (DOA) (angela.singh@alaska.gov)'; Skutca, Joseph E (DOA); 'Wallace, Chris D (DOA) (chris.waIlace@alaska.gov)' Subject: Other Order 100 Errata and Other Oder 100 Corrected Attachments: other100 errata.pdf; other100 corrected.pdf Please see attached. .,', jc„ Oil 11 lti i, CIS C_t)(i`r', P'G ctl lts t- t t;f�,i?'iI55S<7ii ;) 7{!'; ' 2"' ; (p11(,ra(.•, c-VI j) E-16 l5r:2 ,fax; CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, contains information from the Alaska Oil and Gas Conservation Commission (AOGCC), State of Alaska and is for the sole use of the intended recipient(s). It may contain confidential and/or privileged information. The unauthorized review, use or disclosure of such information may violate state or federal law. If you are an unintended recipient of this e-mail, please delete it, without first saving or forwarding it, and, so that the AOGCC is aware of the mistake in sending it to you, contact Samantha Carlisle at (907) 793-1223 or Samantha.Carlisle@alaska.gov. Er- r ..- No mestic Mail Only, Insurance Coverage Provided) rti For delivery information visit our website at www.usps.come r1J f co Postage $ Certified Fee cz] Return Receipt Fee Postmark Here O(Endorsement Required) Restricted Delivery Fee a (Endorsement Required) Lr1 C3Total Postage & Fees $ David Kumar Sent To Production Manager rU ri Cook Inlet Energy, LLC O N __________________ Street, Apt. No.; or PC Box No. 601 W. 5th Ave., Ste. 310 City, State, ZIP+4 Anchorage, AK 99501 PS Form :00 August 2006 See Reverse for Instructions ■ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ■ Print your name and address on the reverse so that we can return the card to you. ■ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: David Kumar Production Manager Cook Inlet Energy, LLC 601 W. 5th Ave., Ste. 310 Anchorage, AK 99501 2. Article Number (transfer from sal PS Form 3811, 1 ., A. Signature X n �t !�� ❑Agent UJ Uu! ❑ Addressee B.cReceived �%n /1 �,11 M A I C �a' I r, Delivery D. Is delivery addthss differenTrom item 1? ❑ Yes If YES, enter delivery address below: ❑ No 3. Service Type ❑ Certified Mail® ❑ Priority Mail Express- ❑ Registered ❑ Return Receipt for Merchandise ❑ Insured Mail ❑ Collect on Delivery 4. Restricted Delivery? (Extra Fee) ❑ Yes .+vmw ..cauu, n—W.i A James Gibbs Jack Hakkila Post Office Box 1597 Post Office Box 190083 Soldotna, AK 99669 Anchorage, AK 99519 Gordon Severson Penny Vadla 3201 Westmar Cir. 399 W. Riverview Ave. Anchorage, AK 99508-4336 Soldotna, AK 99669-7714 Richard Wagner Darwin Waldsmith Post Office Box 60868 Post Office Box 39309 Fairbanks, AK 99706 Ninilchik, AK 99639 Bernie Karl K&K Recycling Inc. Post Office Box 58055 Fairbanks, AK 99711 George Vaught, Jr. Post Office Box 13557 Denver, CO 80201-3557 rA-2'uCL - ��u2r� Angela K. Singh STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Avenue Anchorage, Alaska 99501 Re: Failure to minimize or prevent gas flaring Other Order No. 100 Redoubt Unit #3 Docket No. OTH-14-024 PTD 2010640 January 7, 2015 DECISION AND ORDER On October 23, 2014 the Alaska Oil and Gas Conservation Commission (AOGCC) issued a Notice of Proposed Enforcement Action (Notice) to Cook Inlet Energy, LLC (CIE) regarding the Redoubt Unit #3 (RU-3). The Notice advised that CIE failed to shut-in RU-3 when the Kustatan Production Facility (KPF) was undergoing a major overhaul and flared 24,668 MCF of gas from November 26, 2013 through February 28, 2014. The Notice proposed specific corrective actions and a $294,834 civil penalty under AS 31.05.150(a). CIE requested an informal review. That review was held December 1, 2014. Summary of Proposed Enforcement Action: The Notice identified violations by CIE of 20 AAC25.235(c). Violations occurred on November 26, 2013 when CIE failed to shut-in RU-3 when the KPF was undergoing a major overhaul and when CIE flared from RU-3 from November 26, 2013 through February 28, 2014. The Notice proposed the following corrective actions be completed by CIE: 1) within two (2) weeks following the date of receipt of AOGCC's final decision, CIE shall provide AOGCC a detailed description and an example of its regulatory compliance tracking program and a copy of its written management -of -change procedures; 2) within two (2) weeks following the date of receipt of AOGCC's final decision, CIE shall provide AOGCC with a root cause analysis addressing the violations, and timeline for implementing identified corrective actions. 3) within two (2) weeks following the date of receipt of AOGCC final decision, CIE shall provide AOGCC evidence that personnel responsible for gas disposition management Other Order No. 100 January 7, 2015 Page 2 of 4 and staff involved with facility and well operations have been trained in AOGCC regulatory requirements, including the process for requesting approval for flaring activities from the AOGCC. A copy of the training program syllabus is to be included with other appropriate documentation. The notice proposed the penalties for violating 20 AAC 25.235(c) as follows: - $25,000 for the initial violation — failure to shut-in RU-3 when the KPF was undergoing a major overhaul. - $269,834 for flaring 24,668 MCF of gas from November 26, 2013 through February 28, 2014. Gas Disposition: Under AOGCC regulations, "The operator shall take action in accordance with good oilfield engineering practices and conservation purposes to minimize the volume of gas released, burned, or permitted to escape into the air. " Beginning November 25, 2014 intermittent flaring occurred at the KPF as a result of gas production from RU-3 during a planned compressor overhaul. No approval was sought from the AOGCC for this flaring which continued through February 28, 2014. CIE had previously requested authorization to flare from RU-3 at start up after a rig workover in February 2013. This approval was granted and extended for 72 hours as indicated in correspondence dated August 18, 2013. CIE claims that AOGCC's flaring authorization was "unclear." CIE also claims that the AOGCC approval granted in February 2013 [flaring from RU-3 during workover operations] was valid nine to twelve months later for flaring during the planned extended compressor overhaul. These assertions find no support in the record. CIE's previous request for extended gas flaring as part of the February 2013 workover operations demonstrates CIE's knowledge that extended flaring warrants authorization from AOGCC. Approval for flaring from RU-3 should have been requested from the AOGCC prior to the commencement of the planned work on the compressor in November 2013. Further under AOGCC regulations, the AOGCC will authorize the flaring "if the flaring or venting is necessary to prevent loss of ultimate recovery " Other Order No. 100 January 7, 2015 Page 3 of 4 In its correspondence and during the informal meeting, CIE outlined the difficulty with choking back RU-3 to achieve lower flowrates because of water influx and low wellhead pressures. Also, CIE outlined the difficulty with restarting RU-3 once the well was shut in. Since the well is an extended reach deviated well, a rig or coiled tubing unit is usually necessary to restore the well's production. These difficulties are evident in a review of the well file. CIE's initial request for authorization to flare and its subsequent efforts to mitigate its flaring from RU-3 demonstrate that CIE understood the potential for a finding of waste due to flaring during the compressor overhaul. AOGCC has given CIE's mitigation efforts, as well as the condition of RU-3, due consideration in adjusting the final penalty imposed. Findings and Conclusions: The AOGCC finds that CIE violated 20 AAC 25.235(c) of the regulations. Consideration of the mitigating circumstances outlined above, however, results in the elimination of the monetary penalty that was proposed. The proposed corrective actions are deemed appropriate in this circumstance to address and prevent recurrence of the regulatory violation and are retained in the AOGCC's Final Decision. Now Therefore It Is Ordered That: Within 2 weeks after this Decision and Order becomes final, CIE shall provide AOGCC: 1) a detailed description and an example of its regulatory compliance tracking program and a copy of its written management -of -change procedures; 2) the full report of a root cause analysis addressing the violations, and timeline for implementing identified corrective actions. 3) evidence that CIE (and contract) personnel responsible for gas disposition oversight and field staff involved with facility and well operations have been trained in AOGCC regulatory requirements, including the process for requesting approval for flaring activities from the AOGCC. A copy of the training program syllabus is to be included with other appropriate documentation. As an Operator involved in an enforcement action, you are required to preserve documents concerning the above action until after resolution of the proceeding. Other Order No. 100 January 7, 2015 Page 4 of 4 Done at Anchorage, Alaska and dated January 7, 2015. Cathy f. Foerster Chair; Commissioner avid ayberry Commissioner 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 AOGCC grants for good cause shown, a person affected by it may file with the AOGCC 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 AOGCC 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 AOGCC 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 AOGCC mails, OR 30 days if the AOGCC 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 AOGCC 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 AOGCC, and it may be appealed to superior court. That appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on 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. Carlisle, Samantha J (DOA) From: Carlisle, Samantha J (DOA) Sent: Thursday, January 08, 2015 10:22 AM To: 'AKDCWeIIIntegrityCoordinator'; 'Alexander Bridge'; 'Allen Huckabay'; 'Andrew VanderJack'; 'Anna Raff'; 'Barbara F Fullmer'; 'bbritch'; 'Becky Bohrer'; 'Bill Barron'; 'Bill Penrose'; 'Bill Walker'; 'Bob Shavelson'; 'Brian Havelock'; Burdick, John D (DNR); 'Carrie Wong'; 'Cliff Posey'; 'Colleen Miller'; 'Corey Cruse'; 'Crandall, Krissell'; 'D Lawrence'; 'Dave Harbour'; 'David Boelens'; 'David Duffy'; 'David Goade'; 'David House'; 'David McCaleb'; 'David Scott'; 'David Steingreaber'; 'David Tetta'; 'Davide Simeone'; 'ddonkel@cfl.rr.com'; 'Dean Gallego'; Delbridge, Rena E (LAA); 'Donna Ambruz'; 'Ed Jones'; 'Elowe, Kristin'; 'Evans, John R (LDZX)'; 'Francis S. Sommer'; 'Frank Molli'; 'Gary Oskolkosf'; 'George Pollock'; 'ghammons'; 'Gordon Pospisil'; 'Greg Duggin'; 'Gregg Nady'; 'gspfoff'; 'Jacki Rose'; 'Jdarlington Oarlington@gmail.com)'; 'Jeanne McPherren'; 'Jeffery B. Jones (Jeff Jones@alaska.gov)'; 'Jennifer Williams'; 'Jerry Hodgden'; 'Jerry McCutcheon'; 'Jessica Solnick'; 'Jim Watt'; 'Jim White'; 'Joe Lastufka'; 'Joe Nicks'; 'John Adams'; 'John Easton'; 'John Garing'; 'Jon Goltz'; 'Jones, Jeffrey L (GOV)'; 'Juanita Lovett'; 'Judy Stanek'; 'Julie Houle'; 'Julie Little'; 'Karl Moriarty'; 'Keith Wiles'; 'Kelly Sperback'; 'Klippmann'; 'Laura Silliphant (laura.gregersen@alaska.gov)'; 'Leslie Smith'; 'Lisa Parker'; 'Louisiana Cutler'; 'Luke Keller'; 'Marc Kovak'; 'Mark Dalton'; 'Mark Hanley (mark.hanley@anadarko.com)'; 'Mark Landt'; 'Mark Wedman'; 'Marquerite kremer (meg.kremer@alaska.gov)'; 'Michael Duncan'; 'Michael Jacobs'; 'Michael Moora'; 'Mike Bill'; 'Mike Mason'; 'Mike) Schultz'; 'MJ Loveland'; 'mjnelson'; 'mkm7200'; Morones, Mark P (DNR); 'nelson'; 'Nichole Saunders'; 'Nick W. Glover'; 'Nikki Martin'; 'NSK Problem Well Supv'; 'Oliver Sternicki'; 'Patty Alfaro'; 'Paul Craig'; 'Paul Decker (paul.decker@alaska.gov)'; 'Paul Mazzolini'; Pike, Kevin W (DNR); 'Randall Kanady'; 'Randy L. Skillern'; 'Randy Redmond'; 'Renan Yanish'; 'Robert Brelsford'; 'Ryan Tunseth'; 'Sara Leverette'; 'Scott Griffith'; 'Shannon Donnelly'; 'Sharmaine Copeland'; 'Sharon Yarawsky'; Shellenbaum, Diane P (DNR); Slemons, Jonne D (DNR); 'Smart Energy Universe'; Smith, Kyle S (DNR); 'Sondra Stewman'; 'Stephanie Klemmer'; 'Steve Moothart (steve.moothart@alaska.gov)'; 'Suzanne Gibson'; 'Tamera Sheffield'; 'Tania Ramos'; 'Ted Kramer'; 'Temple Davidson'; 'Terence Dalton'; 'Teresa Imm'; 'Thor Cutler'; 'Tim Mayers'; 'Tina Grovier'; 'Todd Durkee'; 'Tony Hopfinger'; 'trmjrl'; 'Tyler Senden'; 'Vicki Irwin'; 'Vinnie Catalano'; 'Walter Featherly'; 'Yereth Rosen'; 'Aaron Gluzman'; 'Aaron Sorrell'; 'Ajibola Adeyeye'; 'Alan Dennis'; 'Andrew Cater'; 'Anne Hillman'; 'Bruce Williams'; Bruno, Jeff J (DNR); 'Casey Sullivan'; 'David Lenig'; 'Diane Richmond'; Dickenson, Hak K (DNR); 'Donna Vukich'; 'Eric Lidji'; 'Erik Opstad'; 'Gary Orr'; 'Graham Smith'; 'Greg Mattson'; 'Hans Schlegel'; Heusser, Heather A (DNR); 'Holly Pearen'; 'James Rodgers'; 'Jason Bergerson'; 'Jennifer Starck'; 'Jill McLeod'; 'Jim Magill'; 'Joe Longo'; 'John Martineck'; 'Josh Kindred'; 'Kenneth Luckey'; King, Kathleen J (DNR); 'Laney Vazquez'; 'Lois Epstein'; Longan, Sara W (DNR); 'Marc Kuck'; 'Marcia Hobson'; 'Marie Steele'; 'Matt Armstrong'; 'Matt Gill'; 'Mike Franger'; 'Morgan, Kirk A (DNR)'; 'Pat Galvin'; 'Patricia Bettis'; 'Peter Contreras'; 'Richard Garrard'; 'Robert Province'; 'Ryan Daniel'; 'Sandra Lemke'; 'Scott Pexton'; 'Shaun Peterson'; 'Susan Pollard'; 'Talib Syed'; 'Terence Dalton'; Todd, Richard J (LAW); Tostevin, Breck C (LAW); 'Wayne Wooster'; 'William Hutto'; 'William Van Dyke'; 'Ballantine, Tab A (LAW) (tab.ballantine@alaska.gov)'; 'Bender, Makana K (DOA) (makana.bender@alaska.gov)'; 'Brooks, Phoebe L (DOA) (phoebe.brooks@alaska.gov)'; Carlisle, Samantha J (DOA); 'Colombie, Jody J (DOA) Oody.colombie@alaska.gov)'; 'Crisp, John H (DOA) Oohn.crisp@alaska.gov)'; 'Davies, Stephen F (DOA) (steve.davies@alaska.gov)'; Eaton, Loraine E (DOA); 'Foerster, Catherine P (DOA) (cathy.foerster@alaska.gov)'; 'Frystacky, Michal (michal.frystacky@alaska.gov)'; 'Grimaldi, Louis R (DOA) (lou.grimaldi@alaska.gov)'; 'Guhl, Meredith (DOA sponsored) 1 To: (m-.edith.guhl@alaska.gov)'; Herrera, Matthew, -OA); 'Hill, Johnnie W (DOA)'; 'Hunt, Jennifer L (DOA)'; Kair, Michael N (DOA); Konkler, Stacey L (DOA); Loepp, Victoria T (DOA); Mayberry, David J (DOA); 'Mumm, Joseph (DOA sponsored) Ooseph.mumm@alaska.gov)'; 'Noble, Robert C (DOA) (bob.noble@alaska.gov)'; 'Paladijczuk, Tracie L (DOA)(tracie.palad ijczuk@alaska.gov)'; 'Pasqual, Maria (DOA) (maria.pasqual@alaska.gov)'; 'Regg, James B (DOA) Oim.regg@alaska.gov)'; 'Roby, David S (DOA) (dave.roby@alaska.gov)'; 'Scheve, Charles M (DOA) (chuck.scheve@alaska.gov)'; 'Schwartz, Guy L (DOA) (guy.schwartz@alaska.gov)'; 'Sea mount, Dan T (DOA) (dan.seamount@alaska.gov)'; 'Singh, Angela K (DOA) (angela.singh@alaska.gov)'; Skutca, Joseph E (DOA); 'Wallace, Chris D (DOA) (chris.wallace@alaska.gov)' Subject: Other Order No. 100 (Redoubt Unit, Kustatan Production Facility) Attachments: other100 Please see attached. .�r,rnow lla Car(ish, oll ,i'id Ga l.C)nse,vii;ion {,.comri;SSior AK 99501 L22.i (jJilOt1E'1 (901 ') 2 /G 75—`2 (fax} CONFIDENTIALITY NOTICE. This e-mail message, including any attachments, contains information from the Alaska Oil and Gas Conservation Commission (AOGCC), State of Alaska and is for the sole use of the intended recipient(s). It may contain confidential and/or privileged information. The unauthorized review, use or disclosure of such information may violate state or federal law. If you are an unintended recipient of this e-mail, please delete it, without first saving or forwarding it, and, so that the AOGCC is aware of the mistake in sending it to you, contact Samantha Carlisle at (907) 793-1223 or Samantha.Carlisle@alaska.gov. tal Service TM FFord11lPv111V FIED MAILTM RECEIPT Mall Only; No Insurance Coverage Provided) at www.usps.com® nformation visit our website r1J r-i co Postage $ Certified Fee Return Receipt Fee M (Endorsement Required) Restricted Delivery Fee O (Endorsement Required) Ln C3 Total Postage & Fees m David Kumar ru Sent To Production Manager r-i p 'si�eer,Apt. o.;"' "'" Cook Inlet Energy, LLC r . or PO Box No. 601 W. 5th Ave., Ste. 310 ------------------------ Ciry, State, ZIP+4 Anchorage, AK 99501 - SENDER: COMPLETE THIS SECTION ■ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ■ Print your name and address on the reverse so that we can return the card to you. ■ Attach this card to the back of the mailpiece, or on the front if space permits. Postmark Here 1. Article Addressed to: David Kumar Production Manager Cook Inlet Energy, LLC 601 W. 5th Ave., Ste. 310 Anchorage, AK 99501 A. Signature X All V ❑ Agent D. Is delivery a2 ress diffe4nt from item V Ye` If YES, enter delivery address below: ❑ No 3. Service Type ❑ Certified Mail® ❑ Priority Mail Express- 0 Registered ❑ Return Receipt for Merchandise ❑ Insured Mail ❑ Collect on Delivery 4. Restricted Delivery? (Extra Fee) n v 2. Article Numoer (Transfer from St PS Form 3811, Bernie Karl James Gibbs Jack Hakkila K&K Recycling Inc. Post Office Box 1597 Post Office Box 190083 8055 Soldotna, AK 99669 Anchorage, AK 99519 Post Office Box Fairbanks, AK 99711711 Gordon Severson 3201 Westmar Cir. Anchorage, AK 99508-4336 Richard Wagner Post Office Box 60868 Fairbanks, AK 99706 Penny Vadla 399 W. Riverview Ave. Soldotna, AK 99669-7714 Darwin Waldsmith Post Office Box 39309 Ninilchik, AK 99639 George Vaught, Jr. Post Office Box 13557 Denver, CO 80201-3557 �2.ti�2r� �rLo\S CLI-�s Angela K. Singh 10 Cook Inlet Energy_ January 25, 2015 Ms. Cathy P. Foerster Chair, Commissioner Alaska Oil and Gas Conservation Commission 333 West 71' Avenue Anchorage, Alaska 99501 Subject: Docket Number OTH-14-024 Other Order No. 100 Dear Chair Foerster, JAN 2 7 2015 Cook Inlet Energy (CIE) provides the Commission with the following information and documentation required by Order Number 100, issued on January 7, 2015. CIE has implemented the proposed corrective actions that will make Gas Disposition oversight more effective 1) Regulatory Compliance Tracking Program and Management of Change Procedure CIE is using Dakota Tracer software to keep track and assign responsibilities to various personnel for AOGCC production related practices. An AOGCC regulatory compliance -tracking module was added to the software and an example of how the program works is provided to the Commission (Please see attachment I). CIE carefully examined its Management of Change Procedure (MOC) and made necessary changes to include a regulatory review process to ensure ongoing compliance with AOGCC's regulations. A copy of the MOC procedure is provided to the Commission along with the flowchart depicting the sequence of steps involved in the process (Please see attachment II). 2) Root Cause Analysis and Associated Timelines Implementing Corrective Actions On November 20 2014, CIE provided the Commission with the root cause analysis of the incident and preventative steps to prevent such incidents in the future. CIE has further expanded on this matrix and has included the corrective actions and timelines associated with these actions. CIE presents the updated matrix to the Commission (Please see attachment III) 601 W, 5th Avenue, Suite 310, Anchorage, AK 99501. 907-334-6745(Main) I907-334-6735(Fax) Page 1 of 3 Cook Inlet Energy_ 3) Gas Disposition Oversight, Evidence of Training and Process for Requesting Approval for Venting/Flaring On November 20 2014, CIE previously provided the Commission with its training syllabus slides on Gas Disposition. Additionally, CIE has created a Gas Disposition Decision Matrix clearly outlining the necessary actions and the personnel responsible for overseeing compliance with regulations related to gas disposition. CIE also provides the Commission with signatures of key personnel involved in the Chain of Command as evidence of the above training (Please see attachment II) CIE understands the importance and the process involving timely request for approval related to any venting/flaring activities. CIE provides the Commission a recent copy of the correspondence which highlights the process in which flaring was requested and approved for a schedule maintenance activity on a compressor (Please see attachment I) We trust this letter adequately responds to Other Order No; 100. Please be assured that maintaining a close working relationship between CIE and the AOGCC is a high priority for us. Please do not hesitate to contact me at 433-3822 or at david.kumar@cookinlet.net if there is any further information you need on this or any other matter. Sincerely, 1 2� 1 D i umar P/oduction Manager Cook Inlet Energy 601 1rd. 51h Avenue, Su tc 310, Anchorage, AK 99501. 907-334-6745(1\4ain) I907-334-6735(Fax) Page 2 of 3 Cook Inlet Energy_ Attachments: I. Functioning of the Regulatory Compliance Tracking Program II. Management of Change Procedure with Flowchart III. Root Cause Analysis and Associated Timelines Implementing Corrective Actions IV. Copy of the training slides for Gas Disposition and Evidence of training V. Correspondence requesting approval from Commission for flaring 601 W. 51h Avenue, Suite 310, Anchorage, AK 99501. 907-334-6745(Mmin) I907-334-6735(Fax) Page 3 of 3 Attachment 1 Cook Inlet Energy_ Regulatory Compliance Tracking Program 1 INTRODUCTION Regulatory compliance is the awareness of and actions taken to maintain conformance with relevant laws and regulations. It is achieved through effective task management. Cook Inlet Energy (CIE) uses Dakota Tracer - a regulatory compliance software package to assign, alert, monitor progress, and update regulatory compliance tasks and corrective actions to ensure timely completion. Dakota Tracer is a web -based application that is accessed by our personnel both in the field and in the office. Compliance tasks are input into the system as action items which are organized into action groups by regulatory requirement. Each group of action items is displayed in a point and click action table where the compliance tasks can be viewed, sorted, and updated. CIE uses Dakota Tracer to provide automated email notification and task action reminders to required personnel consistent with our chain of command. Dakota Tracer users provide updates to compliance tasks via the event log which keeps a running history of all activity associated with each action item. Supporting documents are uploaded and attached to a compliance task when required. This allows for real-time task progress communication and monitoring. Dakota Tracer is a password accessed system which ensures confidentiality and provides data control. CIE uses Dakota Tracer to generate a quarterly status report to provide regulatory compliance task tracking and status to affected facilities and personnel. The reports are generated by the regulatory compliance software automatically per the CIE defined report schedule and emailed to the Production Manager, HSE Manager, Production Engineer, and Lead Operators. Dakota Tracer reports are browser - independent and can be viewed from mobile devices. Reporting can be generated as HTML, Microsoft Excel, or Microsoft Access files. 1 . Cook Inlet Energy_ 2 EXAMPLE CIE regulatory compliance tasks associated with 20 AAC 25.265(h) safety valve system performance testing are featured below for an example of the CIE Regulatory Compliance Tracking Program. The SVS testing tasks for existing producing wells at each CIE facility are input by the Production Engineer for the year in January. New wells are input into Dakota Tracer once stable production for the well has been reached. The SVS testing tasks are organized into an SVS testing action group. p _jr—.}reEPnasn —, — LW— —W {.,o— t r j t2p} ai lrrice aW it" 1 A11. Plm s— Ira. N" I 7hspueMk Msa I I— thMr tva-1 tias+.i 1 enoccctest mess non knmrro corriget toloanold7 NPULe opeala oin3•zo,s later Performaxe than A6 haus prio- to M test C.ndic( SVS rjt31}tmn r j tom, Kwaa e9FJ 5"WARM Rserad 7 CmpMed 11na/M1J 7 Nof�iion Mrgn 01113/M15 E r'..l t3f.-Hn!hie+tlb[-sratx*A�[ GPM _. rui`;aMn,:e-wr: Mi 13 Sdtli Ileai RdmnreeTesting tes8s NCA5hr4d m.rnllO15 1 Pmnxtim awsa3le +rust, ft+^ .imd-yS3 26MTestisg twin Ute ReM.3sMit SsS Pedmnrce TeslYig MSS hq ry jtAttitidPosps�ilnlC-16— aM ov*urrr W a,.Wa i.aMatm tb2 i31Po1 S45 CmipkOeAOGCC lest a'iRieID Mifi[aiim famro NdSbrted 0217672015 1 t'drR71LUd OperaAar F �{17)S&7e0eg pedtruatce =U 4 hour pin to StS test. CaductM r j {8}NdsaOP Wi r-1 �f=Z lu 3 +',et toMard falpkleAOCff test does nNfk-. i. iam ro W st. d 02106ws 1 1Aft; LeM Openln OWI MA c r:j{8)VIF Wd S,S SE+Ln>�pae Iasartlmrl Loren pin to Mt�.fnrdu[t StS T... �.ft. 4 (']{87)}iNFll rawp eADG...a... o,.eeo Ms4 PoJSi3 Qalplele aOGCC t14 YAbl8 aot{Rratim hmro MtlStarttd 02/06ROt5 1 ($iey L®d Cp �F rjto}ytrA � e + $spur to Mteifmdsct AS T... a, ♦. mrae «r� - d ses'YySYSM liWtll Poev�W*...._...,�+s *Pr.a Ai.Le 5ldrtitanPerfmraneTestiri reslMs ft6brhd 00/131.20157 P+PA[tim Weise 515Tntiq Iran the 5,U LbW M PMmlonceiIOn amr. man m. sw R5s9 SlArrrR last Iheeare aid retry SSS Pefom�rm TeYirs tesdts KYSprted ml131M15 7 PmdalionWNses FartadM Iranthe am. Sd.* SVS Pei— Testig .ron Ymak Ir. via snNmlaH Man NrrW. 94t M Sr2irk Poll S*S Miw nd vevify SLS PerlomnceTenalgraJ[s watSbrW 0111MIS I P i banWmje T.ft I-0, tram the field. SSMat M PerfanGlaY 7estYg m.,f ruti 1465 IiU AS a tcsappte OGCC le5i yAlrresi rartitkititn ormro ItolShrted W104I10151 till bndt{t rtar uw Caismd. tbm" Cdk Opetlass hop rGV7V—j V1W-i 3tatu (-,pWted ftt Dr: IW421314 L.M: WUSVS palwn Test Tank Dasr�s6Nrc Arliaa Phan CrnpleteAOGLLteg vAtsess n*bmtm tmm ro later than S hobs prior to SYS test Cmdct 515 t9Ttemute Test lar 148. 3Z A 3F25. At-35, 22-35. Ati«F Wr SVS Testing Rev.At,.._m,S to ssts:ms._�„xayer, :vent Log 1 ID.n01512:4k IOPN Christi Parkimon M PeW N Testing—c.&t ed is 1425, 32-35, RIC 41-35, and R-35 m 10:M2014. AOGU Yepecw p.— — WMt tkrsera. I-ItaN/F'anm: < ...... > ft*—Abla Anon: WU Lead Opeldn 2 Cook Inlet Energy_ An alert is added for each new SVS testing task which is set to notify the Production Manager, Production Engineer, and Lead Operator for the affected facility within 14 days of the task's due date. An alert is also added to provide notification of a change in the SVS testing due date in the event that the testing frequency is modified by the AOGCC as a result of testing performance. Q T alters Delete Cnedkea Clow Q L—a him Em W Delete Action ID From Trigger 2 T Fran �-* 194-2Ichristi.parkinson@cookiniet.net] Change in Date Due Cook Intet Energy>Produ Q 1a od.,sli.parlo—@Coolurdet.raci ©T To 4i 194.2 ! tdwW.parj*w r@m*n1eLr et] 14 &fl) Prior to Date Due Cock inlet Energy>Produ Q .I000durdel.rel ii1 T T,9w Q I J 1,1114 days) pia to Date Due ©'V {1)C1wW in Date We R T A&mnmd Akft -w pwF'jtf 1 says Undo DeIeW Prev a is Next ALERT FOR ACTION 194-2 FRDIk TD: KESSWjE Tlris is an automated alert generated by the CIE Regkiatory Compliarce ri Trakddng System. Please dreg aoy 9uestions regarding the Task or Action V'': NMFWATt0N v wnFV - Send erredi on dwW in ►' r Click Here to Set Advanced Alert Cord 3 Cook Inlet Energy_ Once SVS testing has been completed, the Lead Operator responsible for the compliance task will change the task status to "completed" and create a journal entry to record the testing date, a list of wells tested, and the AOGCC inspector present during the test. 113z 144-1 Statm Conoeted Date Due: 1014i2014 Label: NFU 515 Performance Test Task Description: Action Plan: Canplete AOGCC test �itness notification form ra later than 46 hours prior to SVS test. Conduct SVS Pertormance Test for 14-25, 32.35, 34-26, 41.35, 22-35. Attachments: '�. Event Loc 1.23i201512*40 PM Christi Parkinson M Pefornwu Testing vvs co kited for 14-25, 32.35, 34.26, 41.35, and 22.35 on 10?412014, AOGCC impector present was Matt Herrera. r Task Rale/Person: Responsible Person: NFU Lead Opwator Submittal of the SVS testing results to AOGCC is a compliance task delegated to the Production Manager. A journal entry will be created to record the submittal date and the SVS testing results will be added to the compliance task as an attachment. 4 Cook Inlet Energy_ ® & 14+7 Stahl: Cwoeted Date Due: 11 WIN Later: stoma wu us Testimt rtesft Talc Drttrfptian: Adige Nw: KNvwadvedN SUS erform a Testing remits from the field Udrd S5 Pert moo Teshrq resits to MaC vim emi w rater ttw 0* 1%ruder dap d the nroMh fdiw,* the test ��^ Sr5 Testing Rezcih ,c S?.'{ 5:�:ou_,: ems; FEM Event Log 1 T23OB 12yaW F% NO Parkin M"remits Yee sMitted to Amr"OM) via wa mn 1013WIM from DwW War. TOA WrIftoa: b*MSM Prrsoa: rlP&xtw Mahler A quarterly status report is automatically generated for the SVS testing action group to provide regulatory compliance task status tracking. The status reports are emailed to the Production Manager, HSE Manager, Production Engineer, and Lead Operators. AddNew Edli Nete We Help SCHEDULED REPORT REMINDER NOW: SVS Testing Status Report Template: Actions Grouped by 5tatus.rdlx Recipients:{chdsti.parkinsortL9rxd&iniet.net]; Report Sdwdlde: MwWy: Day 1 of every 3 mor*s) Start: 1/1/2015 URNrilcox];(HSE For the next year Advisor];david.kumr@tookinlet.net Aiessage: This is an automated report generated by the CIE Regulatory Compliance Tracking 4stem. Please direct any questions regarding the status of any task to David Kumar at 907 i33-3822 or Christi Parki tm at 907-433-3829. organization: Cook Inset EnKgV) Enable SVS Testing Status! c Nisti.paridtlson@cooldnlet.net; HSE Advisor, jrwilcox; davidAumar@cookinlet.net; !Day 1 of every 3 nTDnth(s) : 0 5 Attachment 2 Cook inlet Energy_ Quality Assurance Manual Management of Change QA-12.0 1.0 Purpose The purpose of the Management of Change (MOC) Procedure is to ensure that hazards associated with the introduction of changes are properly evaluated and addressed from the planning through implementation stages in a timely manner. A thorough review of the proposed change using a Facility Change Request (FCR) form should improve the operability and reliability of the change, control the introduction of hazards into the workplace, improve decision -making through collaboration, promote effective communications and teamwork, and ensure conformance with policy, standards, codes and regulations as they apply to production operations. 2.0 Scope / Applicability This MOC procedure must be followed prior to the introduction of a change to: • Cook Inlet Energy owned and operated oil and gas production facilities • Operating parameters that are beyond established safe limits • Maintenance activity other than replacement in kind • Control logic • Chemicals • Operation and maintenance procedures • Process safety equipment • Structures and equipment • Piping • Well design and testing equipment • Remediation, decommissioning or abandonment • Process technology • Defeat a safety valve system or perform any deviation in AOGCC regulatory matters Revision 0 UA-12.0 10/2014 Page 1 of 11 _ Cook Inlet Energy_ Quality Assurance Manual Management of Change QA-12.0 3.0 Management of Change Process 3.1 Definitions Facility Change Request (FCR) A Facility Change Request (FCR) is the form used for initiating consideration of a change or modification. It should be generated and approved prior to a modification or change, unless the change is due to emergency mitigation. Project complexity or the existence of an emergency situation determines the degree of offsite approval necessary prior to implementation of the proposed change. An FCR form must be utilized for all types of change; Like -In -Kind, MOC, Temporary, and Emergency Mitigation. An example FCR form is provided in Appendix A for reference. Like -In -Kind Change A Like -In -Kind change is a replacement which satisfies the original design specification of the device or material being replaced. Components and configuration of the change must be identical to that which was removed from service. Purchases of maintenance parts for use in PSM-covered processes must be in accordance with the Procurement section of the Quality Assurance Manual. This change does not require MOC review. MOC Change An MOC Change is any change, not determined to be a Like -In -Kind replacement, impacting scope listed above in Section 2.0. Temporary Change A Temporary Change is permitted within the MOC process as long as the conditions set form in the FCR form are returned to the original configuration by the estimated completion date. Temporary change criteria may be used for a time period of no more than six months. This must be strictly adhered to. After six months, CIE management will consider the change permanent and the Facility Engineer must complete a new Project Record Requirement and Closeout Checklist with the MOC Coordinator. Emergency Mitigation Change In the event of an emergency response as determined by the Production Manager, a facility modification may be undertaken without a pre -approved FCR, provided an FCR is generated within twenty-four hours of mitigating the emergency condition. An emergency response does not negate the requirement for a completed Pre -Startup Checklist. Hazard Analysis (HA) Revision 0 QA-12.0 10/2014 Page 1 of 11 Cook Inlet Energy_ Quality Assurance Manual Management of Change QA-12.0 A Hazard Analysis (HA) is the screening form for hazards analysis applicability. If one or more questions on the form is answered "Yes", then a hazards analysis must be completed as part of the MOC review process. 3.2 Examples Changes subject to MOC review include equipment changes, process changes and changes to approved facility operating and maintenance procedures. Examples are provided below: New Installations / Construction Activities • Installation of new process vessels and facilities • Installation of new buildings • Installation of new pumps Equipment Changes • Revising suction header piping on a pump • Increasing motor horsepower • Changing pump impeller size • Changing metallurgy on piping • Changing the set pressure, size/capacity, or placement of a safety valve • Changes in piping, valve or equipment specifications • Hoist capacity Process Change • Adding or deleting process or corrosion inhibitor chemicals • Raising an upper, safe operating limit • Changes to control computer (PLC, DCS) logic (cause & effect changes) • Adding or deleting a bypass on a trip circuit Regulatory Change • Changing the set pressure, size/capacity, or placement of a surface safety valve or subsurface safety valve • Defeating a surface safety valve or subsurface safety valve Procedural Change • Major change to an operating or maintenance procedure • Modifying a hazardous confined space entry procedure Revision 0 QA-12.0 10/2014 Page 2 of 11 _ Cook Inlet Energy_ Quality Assurance Manual Management of Change QA-12.0 3.3 MOC Review All process -related changes that are not due to a Like -In -Kind change require MOC review, complete project documentation and formal closeout. Both Like -In -Kind changes, and MOC changes must also follow procedures and documentation standards required by the Quality Assurance Manual. An MOC change can be field initiated, support staff initiated, or initiated in response to an emergency situation or temporary condition. The MOC review process is determined by the route it was initiated. A pre -startup checklist must be completed prior to startup for all MOC changes. All MOC reviews must be closed out within 180 days of implementation of the change. A monthly status report should be generated to provide MOC tracking and status to affected facilities and engineers. Steps — Field Initiated MOC Change 1. An Operator informs Production Foreman / Lead Operator and Facility Engineer of a proposed change. 2. The Facility Engineer determines the change is not a Like -In -Kind change and notifies the Production Manager and HSE Manager of the proposed change. 3. A completed FCR form is submitted to the MOC Coordinator by field personnel. All completed FCRs must have the Production Foreman / Lead Operator's signature and any necessary redline drawings or sketches to communicate the proposed change. 4. The MOC Coordinator assigns an FCR number and routes the FCR to the Production Manager for MOC determination. 5. Upon determination that an MOC review is required, the MOC Coordinator assigns the FCR an MOC number. The MOC documentation is routed to the Facility Engineer to begin the MOC review process. 6. The Facility Engineer reviews the MOC documents and determines the need for a hazards analysis using the HA form. The Facility Engineer also determines the need for any P&ID updates, procedural updates and specific personnel training. Project Record Requirements are selected and assigned using the Project Record Requirement and Closeout checklist. 7. The Facility Engineer forwards the MOC documentation to the HSE Manager for review and solicitation of regulatory compliance, health, safety, and environmental -related recommendations. 8. The HSE Manager routes the MOC documentation to the Safety Specialist and Environmental Professional as necessary for review and comment. 9. The HSE Manager forwards the MOC documentation to the Regulatory Professional for AOGCC regulatory compliance review. 10. The Regulatory Professional forwards the MOC documentation to the Landman for review and comment. 11. The Landman forwards the MOC documentation to the Quality Assurance Professional for review and solicitation of Quality Assurance/Quality Control recommendations. 12. The Quality Assurance Professional forwards the MOC documentation to the Production Foreman/Lead Operator for review and comment. Revision 0 QA-12.0 10/2014 Page 3 of 11 _ Cook Inlet Energy_ Quality Assurance Manual Management of Change QA-12.0 II The Production Foreman/Lead Operator forwards the MOC documentation to the MOC Coordinator who routes it to the Production Manager for final approval. 14. Upon final approval, the field may proceed with implementing the proposed change. 15. Upon completion of the work, the Production Foreman/Lead Operator notifies the Facility Engineer and the MOC Coordinator that MOC closeout may begin. The Production Foreman/Lead Operator submits all required documentation (indicated on the Project Record Requirements and Closeout checklist) to the MOC Coordinator. 16. The MOC Coordinator forwards the MOC closeout documentation to the Facility Engineer and the Quality Assurance Professional for review. The Production Manager provides final approval on the completion of closeout documentation for the MOC review. 17. The MOC Coordinator then establishes a permanent file for the MOC and its supporting documentation. Steps — Support Staff Initiated MOC Change 1. The Facility Engineer submits an FCR to the MOC Coordinator. The FCR must be accompanied by necessary design drawings to communicate the proposed change, a completed design -phase HA form and a Project Record Requirement and Closeout checklist. The design -phase HA form must be reviewed and approved by the Production Foreman/Lead Operator prior to submittal. 2. The MOC Coordinator assigns an FCR number and routes the FCR to the Production Manager for MOC determination. 3. Upon determination that an MOC review is required, the MOC Coordinator assigns the FCR an MOC number. The MOC documentation is routed to HSE Manager for review and solicitation of regulatory compliance, health, safety, and environmental -related recommendations. 4. The HSE Manager routes the MOC documentation to the Safety Specialist and Environmental Professional as necessary for review and comment. 5. The HSE Manager forwards the MOC documentation to the Regulatory Professional for AOGCC regulatory compliance review. 6. The Regulatory Professional forwards the MOC documentation to the Landman for review and comment. 7. The Landman forwards the MOC documentation to the Quality Assurance Professional for review and solicitation of Quality Assurance/Quality Control recommendations. 8. The Quality Assurance Professional forwards the MOC documentation to the Production Foreman/Lead Operator for review and comment. 9. The Production Foreman/Lead Operator forwards the MOC documentation to the MOC Coordinator who routes it to the Production Manager for final approval. 10. Upon final approval, the implementation of the proposed change may proceed. 11. Upon completion of the work, the Production Foreman/Lead Operator notifies the Facility Engineer and the MOC Coordinator that MOC closeout may begin. The Production Revision 0 QA-12.0 10/2014 Page 4 of 11 _ Cook Inlet Energy_ Quality Assurance Manual Management of Change QA-12.0 Foreman/Lead Operator submits all required documentation (indicated on the Project Record Requirements and Closeout checklist) to the MOC Coordinator. 12. The MOC Coordinator forwards the MOC closeout documentation to the Facility Engineer and the Quality Assurance Professional for review. The Production Manager provides final approval on the completion of closeout documentation for the MOC review. 13. The MOC Coordinator then establishes a permanent file for the MOC and its supporting documentation. Steps — Temporary Condition Initiated MOC Change Temporary changes are handled according to the appropriate processes above with the additional factor of a limited timeframe, as described in the Definitions section. Steps — Emergency Mitigation Initiated MOC Change Upon mitigation of a given emergency, FCR protocol will be initiated within twenty-four hours. MOC changes are then handled according to the field initiated change processes above. 4.0 Roles and Responsibilities 4.1 Production Manager 1. The Production Manager is responsible for coordinating the implementation of the Management of Change procedure within all Cook Inlet Energy facilities. 2. The Production Manager receives all FCR forms and is responsible for deciding if an MOC review is required for each proposed change. 3. The Production Manager and Production Foreman/Lead Operator are jointly responsible for ensuring that all personnel that could be affected by the change will be informed of the change and will be appropriately trained prior to startup. The training should include any potential health and safety impacts, changes in operating procedures and changes in process safety information. Training records will be archived with the MOC documentation at closeout and a copy will be provided to the Safety Specialist. 4. The Production Manager is responsible for final approval of each proposed change following completion of an MOC review. 5. The Production Manager and the Production Foreman/Lead Operator are responsible to ensure that all MOC approvals have been received prior to commencing construction or maintenance activities related to the change. Revision 0 QA-12.0 10/2014 Page 5 of 11 _ Cook Inlet Energy_ Quality Assurance Manual Management of Change QA-12.0 6. The Production Manager is responsible to ensure that all work is conducted in compliance with AOGCC regulations and that appropriate notification and/or authorization is obtain from AOGCC when required. 7. The Production Manager provides final approval on the completion of closeout documentation for the MOC review. 4.2 Production Foreman / Lead Operator 1. The Production Foreman/Lead Operator is responsible for submitting an FCR to the Production Manager for any facility change defined in Section 2.0, Scope/Applicability and which personnel under the Production Foreman/Lead Operator's direction will complete. 2. All FCR documents must be reviewed and approved by the Production Foreman/Lead Operator prior to submittal to the Production Manager for MOC determination. 3. The Production Foreman/Lead Operator will complete Section 1 of the FCR form including appropriate documentation to communicate the proposed change. Prior to startup of a facility modification, the Production Foreman/Lead Operator may be requested to participate in a Hazard Analysis exercise. 4. The Production Foreman/Lead Operator and the Production Manager are jointly responsible for ensuring that all personnel that could be affected by the change will be informed of the change and will be appropriately trained prior to startup. The training should include any potential health and safety impacts, changes in operating procedures and changes in process safety information. Training records will be archived with the MOC documentation at closeout and a copy will be provided to the Safety Specialist. 5. The Production Foreman/Lead Operator and the Facility Engineer are jointly responsible for implementation of the recommendations resulting from the Engineering, Safety and Environmental reviews as well as the Hazard Analysis conducted as part of the MOC process. 6. Along with the Production Manager, the Production Foreman/Lead Operator is responsible to ensure that all MOC approvals have been received prior to commencing construction or maintenance activities related to the change. 7. The Production Foreman/Lead Operator and the Production Manager are jointly responsible to ensure ongoing compliance with AOGCC regulations. 8. The Production Foreman/Lead Operator and the Facility Engineer are jointly responsible for all closeout documentation and updates required to facility information. Revision 0 QA-12.0 10/2014 Page 6 of 11 _Cook Inlet Energy_ Quality Assurance Manual Management of Change QA-12.0 a. The time frame for updating the facility information will be driven by the size of the change; larger changes impacting multiple drawings should be targeted for update within 120 days, not to exceed 180 days beyond the completion of the change. Smaller changes may be captured by hand drawn redlines on the facility "Master set" P&ID notebooks, with formal CAD updates scheduled to coincide with project -related updates on a basis not to exceed annually. b. The facility information might include, but not be limited to the following: deck plans or plot plans, piping, process, layouts, limits, classifications, electrical circuits, chemical hazards, SAFE/control logic and pressure relief. This information shall be shared with the appropriate individuals and posted in the CIE established locations. The established CIE locations for routinely updated facility information include P&ID notebooks for P&ID related hard copies and electronic drawing files. c. The same information is archived and managed offsite by the MOC Coordinator. 4.3 Facility Engineer 1. The Facility Engineer is responsible for submitting an FCR to the Production Manager for any support staff initiated facility change defined in Section 2.0, Scope/Applicability. The Facility Engineer will complete Section 1 of the FCR form including necessary design drawings to communicate the proposed change, a completed design -phase HA form and a Project Record Requirement and Closeout checklist. The design -phase HA form must be reviewed and approved by the Production Foreman/Lead Operator prior to submittal. 2. The Facility Engineer is responsible for conducting an engineering review of a proposed change where an MOC review is required as determined by the Production Manager. This review should include, but is not limited to impacts to mechanical integrity and corrosion programs. The Facility Engineer will complete Section 2 of the FCR with any recommendations and review comments. 3. The Facility Engineer is responsible to complete a Hazard Analysis form for each proposed change where an MOC review is required as determined by the Production Manager. 4. When hazard and operability reviews are conducted, the Facility Engineer is responsible for seeking and issuing management's response to any recommendations, as appropriate, and tracking those items selected for implementation. 5. The Production Foreman/Lead Operator and the Facility Engineer are jointly responsible for implementation of the recommendations resulting from the Engineering, Safety and Environmental reviews as well as the Hazard Analysis conducted as part of the MOC process. Revision 0 QA-12.0 10/2014 Page 7 of 11 _ _Cook Inlet Energy_ Quality Assurance Manual Management of Change QA-12.0 6. The Facility Engineer and the Production Foreman/Lead Operator are jointly responsible for all closeout documentation and updates required to facility information. a. The time frame for updating the facility information will be driven by the size of the change; larger changes impacting multiple drawings should be targeted for update within 120 days, not to exceed 180 days beyond the completion of the change. Smaller changes may be captured by hand drawn redlines on the facility "Master set" P&ID notebooks, with formal CAD updates scheduled to coincide with project - related updates on a basis not to exceed annually. b. The facility information might include, but not be limited to the following: deck plans or plot plans, piping, process, layouts, limits, classifications, electrical circuits, chemical hazards, SAFE/control logic and pressure relief. This information shall be shared with the appropriate individuals and posted in the CIE established locations. The established CIE locations for routinely updated facility information include P&ID notebooks for P&ID related hard copies and electronic drawing files. c. The same information is archived and managed offsite by the MOC Coordinator. 4.4 MOC Coordinator 1. The MOC Coordinator is responsible for assigning numbers to all FCRs and routing FCRs to the Production Manager for MOC determination. 2. The MOC Coordinator is responsible to assign an MOC number for all MOC required changes. The MOC Coordinator will review all MOC changes for compliance with the CIE MOC procedure and provide tracking for all MOCs through completion and closing. The tracking process will indicate the status of an MOC in the review process. Upon an MOC change approval, the tracking process will indicate a responsible party to contact for status on the implementation of the facility change. ;. The MOC Coordinator is responsible for distribution and routing of MOC documentation during the review process. Upon an MOC change approval, the MOC Coordinator is responsible for distribution of all MOC documentation to the Production Manager, Production Foreman/Lead Operator, Facility Engineer, and other individuals as appropriate. 4. The MOC Coordinator is responsible to review MOC closeout documentation to ensure completion. The MOC Coordinator is responsible for gathering and archiving all MOC closeout documentation. 4.5 HSE Manager 1. The HSE Manager is responsible for conducting a review of a proposed change where an Revision 0 QA-12.0 10/2014 Page 8 of 11 Cook Inlet Energy_ Quality Assurance Manual Management of Change QA-12.0 MOC review is required as determined by the Production Manager. This review should include, but is not limited to regulatory compliance, health, safety, and environmental impacts. The HSE Manager will determine if additional review and solicitation of recommendations are required from the Safety Specialist and Environmental Professional. The HSE Manager will complete Section 2 of the FCR with any recommendations and review comments. 4.6 Landman 1. The Landman is responsible for conducting a review of an MOC change. This review should include, but is not limited to impacts to lease agreements, land owner notification and state and federal notification. The Landman will complete Section 2 of the FCR with any recommendations and review comments. 4.7 Regulatory Professional The Regulatory Professional is responsible for conducting a review of an MOC change. This review should include, but is not limited to compliance with AOGCC regulations. 4.8 Quality Assurance Professional 1. The Quality Assurance Professional is responsible for conducting a review of an MOC change. This review should include, but is not limited to compliance with the CIE Quality Assurance program. 2. The Quality Assurance Professional is responsible to provide documentation and quality record requirements and recommendations to the Facility Engineer as needed. 3. The Quality Assurance Professional and the Production Foreman/Lead Operator are jointly responsible to ensure that all construction and maintenance activities are conducted in accordance with the CIE Quality Assurance program 4. The Quality Assurance Professional is responsible to review MOC closeout documentation to ensure compliance with the CIE Quality Assurance program. The Quality Assurance Professional is responsible for gathering and archiving all records and documentation required by the CIE Quality Assurance program prior to completion of MOC closeout. 4.9 Safety Specialist 1. The Safety Specialist is responsible for conducting a review of an MOC change when requested by the HSE Manager. This review should include, but is not limited to identification of safety hazards, gaps in personnel training, and recommendations for appropriate personal protective equipment. The Safety Specialist will complete Section 2 of Revision 0 QA-12.0 10/2014 Page 9 of 11 _ Cook Inlet Energy_ Quality Assurance Manual Management of Change QA-12.0 the FCR with any recommendations and review comments. 2. The Safety Specialist may be required to attend pre -startup audits and participate in a Hazards Analysis exercise. 4.10 Environmental Professional 1. The Environmental Professional is responsible for conducting a review of an MOC change when requested by the HSE Manager. This review should include, but is not limited to identification of environmental hazards, regulatory compliance, required updates to environmental reporting and permits. The Environmental Professional will complete Section 2 of the FCR with any recommendations and review comments. Revision 0 OA-12.0 10/2014 Page 10 of 11 Root Cause Analysis and r-reventative Steps Situation -1 • Rig/Coil intervention would be RU-3 Loaded up with required to get RU-3 to flow water and lost flow again • No guarantee of performing a successful workover due to cost Options [Shut ln constrains and high angle RU-3 extended reach operations • nu-i naa plenty or run ierr Keep • Simple swabbing using cheap wireline RU-3 operations was required to get it flowing to Flowing .__,__--- --- Low pressure gas was generated during swabbing operations • Over hI% or the total gas was usea during Nov, 13 — Feb, 14 • Out of the 96 days, there was either no flaring or flaring below SOMCF/D for 26 days Major overhaul was performed but was delayed Situation-2 West Foreland Unit due to long lead time for Compressor 5-530B some parts required went down and — needed major A booster compressor was overhaul simultaniously designed and installed in order to handle low Situation-3 West Mac Saturn Varying load turbines were run in changes caused order to use low changes in gas pressure gas consumption Keep RU-3 Flowing Permit to flare over Shr as per gas dispostion A previously issued temporary permit to flare for RU-3 was misinterpreted as permission to flare beyond an hr in event of swabbing operations AOGCC questions CIE about extended flaring Shutln Options RU 3 and RU-4 • Flare excess gas intermittently • RU-3 well had to flow at max rate in order to sustain continuous flow No correlative rights were violated There was no threat to public health or environment CIE also reported flared volumes on There were no safety concerns or uncontrolled the excess flare logs releases HO as requried by gas CIE was not profited by this action disposition Flaring was minimized to the greatest extent Dossibl • RU-3 was shut in once the error was noticed • The Production Manager in question was replaced • A similar situation with RU-4 was avoided and RU-4 was shut down — • Management of Change protocols were initiated and several layers of authority are required before flaring is authorized • Gas disposition training program is created and implement Corrective Actions Timeline of Implementation • Establish open line of communication with the Commission • Inform Commission of potential regulatory compliance issues and use advice on how to proceed • CIE has been effectively communicating with the Commission since this event • Examples are SVS matters for RU 9, SVS matters for NFU 24- 26, Flaring request for NFU 24-26, Advice on gas well potential testing of NFU 24-26 Timeline: Alreadv implemented and effective Requesting Flaring/Venting approval when necessary • Inform Commission of potential flaring/venting events beforehand • Apply with necessary paper work for flaring/venting approval • Fill in necessary paper work after approval and event • CIE has demonstrated ability to request permission for such events • Examples are Potential flaring/venting during flow back and testing of NFU 24-26, Flaring request during K-200 maintenance Timeline: Already implemented and effective Management of Change Protocols • Replacing key personnel responsible for AOGCC Compliance Timeline: Production Manager was replaced during Aug 2014, Production Foreman was dismissed during Oct 2014 Chain of Command • More personnel added to chain of command for added protection in compliance issues Timeline: Lead Operators implemented during Nov 2014, Production Engineer hired during Sep 2014 Regulatory Compliance Software • Regulatory compliance software (Dakota Tracer) used for tracking purposes Timeline: Already implemented and effective, Example provided to the Commision Training in Gas Disposition Regulations • Gas Disposition Training was conducted for key personnel Timeline: Already implemented and effective, Evidence presented to the Commission • Consultant hired for regulatory training Timeline: Since Nov 2014 Attachment 3 a, Attachment 4 w Cook Inlet Energy_ Introduction o All CIE Operators at all facilities must use good oil field engineering and conservation practices to minimize the volume of gas released, burned, or permitted to escape into the air o CIE is required to track all gas handled on a production facility by pool and report to AOGCC on a monthly basis according to 20 AAC 25.235 C � IL — Cook Inlet Energy_ 0 Definifiori-'- o Gas disposition is the tracking and reporting of all gas handled (produced, purchased, sold, transferred, reinjected, flared or vented, used for lease operations, and NGLs produced) on a production facility by pool o A pool, or unit, is a consolidation of leased lands that comprise a common underground geological reservoir Cook Inlet Energy_ AOGCC' Definition of Waste Gas released, burned, or permitted to escape into the air constitutes waste, except that Flaring or venting gas for a period not exceeding one hour as the result of an emergency or operational upset is authorized for safety; 2 Flaring or venting gas for a period not exceeding one hour as the result of a planned lease operation is authorized for safety; Flaring pilot or purge gas to test or fuel the safety flare system is authorized for safety; Minor venting of gas incidental to normal oil field operations is authorized; Cook Inlet Energy_ When is venting/flaring pre - authorized • Flaring or venting of gas for a period of less than 1 hour as the result of an emergency or operational upset is authorized for safety; o Flaring or venting of gas for a period of less than 1 hour as the result of a planned lease operation is authorized for safety; o Flaring pilot or purge gas to test or fuel the safety flare system is authorized for safety; Gas volumes flared or vented during these events must be recorded but do not require supplemental information since the duration was less than 1 hour. Cook Inlet Energy_ When is venting/flaring authorized by AOGCC AOGCC, in its discretion, will authorize flaring or venting of gas for periods exceeding 1 hour if: o the flaring or venting is necessary for facility operations, repairs, upgrades, or testing procedures; o an emergency that threatens life or property requires the flaring or venting, unless failure to operate in a safe and skillful manner causes the emergency; the flaring or venting is necessary to prevent loss of ultimate recovery; Authorization for these types of flaring or venting events is usually received within 90 days of submitting the Facility Report of Produced Gas Disposition (Form 10-422) Upon application, the AOGCC will, in its discretion, authorize the flaring or venting of gas for purposes of testing a well before regular production Aare Reporting - Information _ Cook Inlet Energy_ Supplement Flaring or venting incidents exceeding 1 hour require supplemental information: Explains why the gas was flared or vented, Lists the beginning and ending time of the flaring or venting o Reports the volume of gas flared or vented o Describes actions taken to minimize the volume of gas burned or released. CIE Operators internally report this information to the Production Manager using the CIE Excess Flare Log It- I - Cook Inlet Energy_ Gas Disposition Reporting: Form 10-422 The Production Manager is responsible for reporting gas disposition for each production facility using the Facility Report of Produced Gas Disposition (AOGCC Form 10-422) Gas acquisition or disposition includes the following categories Gas sold Gas re -injected s Gas flared or vented Gas used for lease operations other than flaring or venting; Natural gas liquids (NGLs) produced Gas purchased Gas transferred Other When a facility's gas production comes from multiple pools, production must be allocated between the pools as a percentage of the total volume of gas that the facility handled for the month. Cook Inlet Energy_ ME What to do when there is venting or flaring o Any release, burning, or escape into the air of gas other than minimal venting as authorized must be reported as flared or vented on the Facility Report of Produced Gas Disposition (Form 10-422) Follow the chain of command to comply with gas disposition rules It— Cook Inlet Energy_ uecision Matrix Flaring or Venting Event As per 20 AAC 25.235(b) Y Less than Does it comply with 20 Duration * . an hour AAC 25.235(d)(4) Z O Overan hour i Minimize or i i Inform '', stop Venting or Production Flaring Manager Is it Scheduled NO immediately ", through chain of unless required command for safety immediately N -- --.... Inform Production Scheduled Manager AAC 25.235(d) through chain of command document Yes ,Form 10-422 Production Manager notifies AOGCC Production Flaring or Manager Venting after notifies AOGCC approval from for approval AOGCC Form 10-422 and Written Supplement as per 20 AAC 25.235(b) Form 10-422 And Written Supplement as per 20 AAC 25.235(b) _ Cook Inlet Energy_ Chain of Command Flaring or Venting Event As per 20 AAC 25.235(b) Is it Scheduled Gas Disposition Decision Matrix Less than an hour Minimize or stop Venting or Flaring No immediately unless required for safety Does it comply with 20 AAC 25.235(d)(4)a 9 IUD,Ocument rm 10-422 Inform Production Manager Production through chain of Manager command notifies AOGCC immediately m v, Inform Production Production Scheduled AACManager + Manager notifies AOGCC through chain of for approval command Flaring or Venting after approval from AOGCC _ Cook Inlet Energy_ Name: Signature: Title: Date: f f / -�� ✓ _ _ _ Flaring or Venting Event As per 20 AAC 25.235(b) less than an hour Gas Disposition Decision Matrix _ cook Inlet Energy • Minimize or stop Venting or Flaring Is ----No- immediately unless required for safety Inform Production SchedUled Manager AAC 25,235(d) through chain of command Does it comply with 20 AAC 25.235(d)(4) Document Form 10-422 Inform Production Manager Production through chain of Manager command notifies AOGCC immediately Production Flaring or Manager Venting after notifies AOGCC approval from for approval AOGCC Name: ' Signature:: j� 2— Cr, Title: Bate: �� Flaring or Venting Event As per 20 AAC 25.235(b) Duration Is it Scheduled Gas Disposition Decision Matrix _ cook Inlet Energy_ an_h4u Minimize or stop Venting or Flaring No immediately unless required for safety Does it comply with 20 AAC 25.235(d)(4) Inform Production Manager through chain of command immediately Document ff orm 10-422 Production Manager notifies AOGCC Inform Production Production Flaring or -" Manager Manager Venting after AAC 25-235(d) through chain of notifies AOGCC approval from command for approval AOGCC Name: 1�AV (� kU ri� Signature: 0-- Title: PF-10 Date: �I 7 Flaring or Venting Event As per 2Q} AAG.2S 4 , Duration - o Overan hour - Is it Scheduled NO m LA Gas Disposition Decision Matrix Minimize or stop Venting or Flaring immediately unless required for safety Does it comply with 20 AAC 25.235(d)(4) ff ocument rm 10-422 Inform Production Manager Production through chain of Manager command notifies AOGCC immediately Inform Production Production Manager Manager through chain of notifies AOGCC command for approval Flaring or Venting after approval from AOGCC Cook Inlet Energy_ Name: 'A 4,.JSo,J Sign�iulre� f "` Title:Q�J ErJGt.Jbb� Date: _ Q/ / D7 / tot Gas Disposition Decision Matrix _ Cook Inlet Energy_ Flaring or Venting Event As per 20 AAC 25:235(b) Duration Does it comply with 20 AAC 25.235(d)(4) Yes Z 0 Minimize ]or inform stop VentinProduction Flaring Manager Production Is it Scheduled No immediately through chain of Manager unless required command notifies AOGCC for safety immediately LA Inform Production Production Flaring or Manager Manager Venting after through chain of notifies AOGCC approval from command for approval AOGCC Name: `--,.q.-ri c�� ✓t/%JCR So SignatureC50z., ,, Title:�� Date: Gas Disposition Decision Matrix cook Inlet Energy Flaring or;Vonting Event As per 20IAAC 25:235(b) Duration Does it comply with 20 AAC 25.235(d)(4) z 0 Inform 71-mpi imizeorVenting or Production Flaring Manager is it Scheduled No Immediately through chain of unless required command for safety Immediately N Inform Production Production Manager Manager through chain of notifies AOGCC command for approval Yes "0' 10412 prid Wr+ftt!n Su"ha runt Js pw 20 AAC Flaring or Venting after approval from AOGCC k Name: Signature: f / �--- Title: Le ©fps—� Date: 1 l 711 S Flaring or Venting Event As per 20 AAC 25.235(b) � � 1essthan an hour Is it Scheduled Gas Disposition Decision Matrix Does it comply with 20 AAC 25.235(d)(4) YeS---*^ 9 Minimize or Inform stop Venting or Production Flaring Manager No immediately through chain of unless required command for safety immediately Production Manager notifies AOGCC Inform Production Production Flaring or Manager Manager Venting after through chain of notifies AOGCC approval from command for approval AOGCC Cook Inlet Energy_ Name: Signature: l Title: d— Date: %- -7 - do ) �-- Gas Disposition Decision Matrix _ cook Inlet Energy Flaring or Venting Event As per 20 AAC 25.235(b) Duration Does it Comply with 20 i AAC 25.235(d)(4) Yes O Minimize or 71nformstop Venting or Flaring Production is it Scheduled No immediately Manager unless required mannotifies AOGCC for safety m A Production Flaring or Manager Venting after notifies AOGCC approval from for approval AOGCC Name: �os� 1441 Signatur�/- Title: G�r'or Date: Flaring or Venting Event As per 20 AAC 25.235(b) an h%il Over an Is it Scheduled Gas Disposition Decision Matrix Does It comply with 20 AAC 25.235(d)(4) z 0 Inform Production Manager through chain of command immediately Yes Production Manager notifies AOGCC Inform Produ7AOGC Flarin Production g or Manager ManVenting after saw [through chain of notifies approval fromcommand for apAOGCC Cook Inlet Energy Name: Signatur ------ / i Title: C e-4rlt c1t p� Date: Gas Disposition Decision Matrix _ cook Inlet Energy Flaring or Venting Event As per 20 AAC 25.235(b) Duration Minimize or stop Venting or Flaring Is it Scheduled No immediately unless required for safety m H Inform Production Manager through chain of command Does It comply with 20 AAC 25.235(d)(4) Z 0 Inform Production Manager through chain of command immediately Production Manager notifies AOGCC for approval Yes Production Manager notifies AOGCC Flaring or Venting after approval from AOGCC Name: 1 101 / �i'i 19✓ Signature:�Gy� GL/IGvL Title: Date: �— /S Attachment 5 _ Cook Inlet Energy_ JAN 2 2 2u,-, January 22, 2015 Ms. Cathy P. Foerster, Chair Alaska Oil and Gas Conservation Commission 333 West 7 h Ave., Suite 100 Anchorage, Alaska 99501 Re: WMRU Gas Flaring for Over 1 hr Approval Request Dear Chair Foerster, The purpose of this letter is to request AOGCC approval for Cook Inlet Energy (CIE) to flare gas for greater than one hour from West McArthur River Field (WMRU) while conducting non - routine maintenance activities on our sales gas compressor, K-200. The gas flared during this planned event will be solution gas from WMRU vapor recovery and process treaters. West Foreland (WF) gas may be included in the flaring as needed to maintain a pipeline pressure of 70 psi on the 6" LP gas pipeline between WF pad and WMRU. The K-200 gas compressor is used to compress processed solution gas up to 450 psig. The gas is used for fuel gas at WMRU and can also be used for fuel gas at WF and the Kustatan Production Facility (KPF) via the 6" CIGGS pipeline when necessary. Gas compressor maintenance activities are expected to occur for a duration of approximately 3 hours. The approximate quantity of gas expected during this flare event is 100 MCF. CIE will submit a written supplement to AOGCC Form 10-422 for this flaring event that includes a description of why the gas was flared, lists the beginning and ending times of the flaring, reports the volume of gas flared, and a description of actions taken to minimize the volume of gas flared during the event in accordance with 20 AAC 25.235(b). CIE will also inform the Commission via a follow-up email once the maintenance activity has been completed. CIE will proceed with this maintenance activity once gas flaring authorization from the Commission is received. We kindly look forward to your prompt reply providing approval for this planned gas flaring event over one hour. If necessary, you may contact me at 907-433-3822. Sincerely, D Kumar roduction Manager Cook Inlet Energy Copy: Jim Regg 601 W. 51h Avenue, Suite 310, Anchorage, AK 99501 907-334-6745 (Main) 1 907-334-6735 (fax) 0 THE STATE 01ALASKA GOVERNOR BILL WALKER January 23, 2015 David Kumar Production Manager Cook Inlet Energy 601 West 51h Avenue, Suite 310 Anchorage, AK 99501 Re: Docket No. OTH-15-002 WMRU Gas Flaring for Over 1hr Approval Request Dear Mr. Kumar: Alaska Oil and Gas Conservation Commission 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907.279.1433 Fax: 907.276.7542 www.aogcc.alaska.gov RECEWR ,JAN 2 3 2015 COOK INLET ENERGV Approval is granted to flare approximately 100 MCF of gas for approximately 3 hours while conducting non -routine maintenance activities on sales gas compressor, K-200. In the future, requests for approval to flare gas may be handled through email and telephone by contacting Victoria Loepp at (907)793-1247 or victoria.loeppCcDalaska.eov. Sincerely, Cathy P. Foerster Chair, Commissioner Cook Inlet Energy_ November 20, 2014 Mr. David J. Mayberry Commissioner Alaska Oil and Gas Conservation Commission 333 West 70' Avenue Anchorage, Alaska 99501 Re: Docket Number OTH-14-024 Notice of Proposed Enforcement Action Dear Commissioner Mayberry: I NOV 20 2014 A0GGG Thank you for providing Cook Inlet Energy (CIE) with an opportunity for an informal review process in regards to the flaring activity conducted on Redoubt Unit #3 (RU-3) gas well. CIE has carefully reviewed all of AOGCC's concerns and takes this matter seriously. In preparation for the informal review, allow me to summarize the facts as best I can. The Notice of Proposed Enforcement Action received October 24, 2014 alleged that the flaring of 24,668 MCF of natural gas produced from RU-3 between November 25, 2013 and February 28, 2014 constituted waste. Based upon the following facts, CIE does not believe that the flared gas from RU-3 during this period should be considered as waste: • Intermittent flaring was needed during the S-530B gas compressor major overhaul to keep sustained levels of gas production from RU-3. This was to prevent the well from loading up with fluids and preventing loss of ultimate recovery from the well according to 20 AAC 25.235(d)(5)(C). • Operation of the S-530B gas compressor was required to achieve pressures adequate to inject gas into the CIGGS sales gas line. Selling the gas from RU-3 was not an option during the gas compressor repair. Gas was flared at the Kustatan Production Facility (KPF) as part of the safety system on the fuel gas supply pipeline. • Overhaul and repair of the S-530B compressor took longer than planned due to the long lead times and availability of certain parts for the compressor. Additional turbines at the West McArthur River Unit Facility (WMRU) were fired up to use this low-pressure gas. Due to irregular loads it was not always possible to utilize the excess gas at all times. • Most of the RU-3 gas produced was used and flaring was minimized in accordance with good oil field engineering practices and conservation purposes as per 20 AAC 25.235 (c). The gas volume flared amounted to 12.6% of the total produced gas volume (excluding solution gas) from the Osprey Platform during the period. • The flaring of RU-3 gas was not continuous but intermittent. Out of the 96 day period there were over 26 days consisting of little to no gas flared. CIE made a conscious effort to put as much gas as possible to productive use during the time the compressor was down. • No gas was flared for 13 of the months the well was on production. CIE took every effort to minimize flaring during the life of the well. Along those lines in addition to performing an overhaul on 5-53013, a booster compressor was also designed and installed at the West Foreland Gas Pad to handle low-pressure gas to prevent such incidents in the future. • Production of both RU-3 and RU-4 is an all -or -nothing choice. The low wellhead pressures and the water influx into the wellbores do not allow for partial production. The wells have to flow at full rate or once they die they are difficult to restart. The extended reach deviated wells make these wells tough candidates for simple wire -line work. A Rig or CTU unit is almost always necessary to get these wells restarted once they are shut-in. • The extent and timeframe of approved flaring activities from RU-3 were unclear from the approved Sundry Notice and chain of emails, which led our Production Manager at the time to believe we were in compliance. Therefore, no additional approvals were requested. CIE never made any attempt to deceive or misreport its flaring activities to the Commission. Gas volumes flared were self -reported in accordance with AOGCC regulations as per 20 AAC 25.235(b) • In summary, during the flaring of RU-3: o No correlative rights were violated o There was no threat to public health or environment o There were no safety concerns or uncontrolled releases o CIE was not profited by this action o Flaring was minimized to the greatest extent possible o Continued operation of RU-3 was necessary to ensure ultimate recovery of gas CIE respectfully requests the Commission to consider the points discussed above and the background information provided below and not find CIE in violation of 20 AAC 25.235(c). While not admitting waste of RU-3 gas, CIE sincerely regrets the situation and offers to voluntarily pay royalties to the State of Alaska as if the gas had been produced. CIE recognizes that through better communication with AOGCC and requests for appropriate gas flaring approvals, the situation would have likely been avoided. CIE has prepared and implemented gas disposition training that follows AOGCC regulations and reiterates our internal chain of command for decision making and gas disposition reporting. Maintaining a close working relationship between CIE and the AOGCC is a high priority for me. Please do not hesitate to contact me at 433-3822 or david.kumarna,cookinlet.net there is any further information you need on this or any other matter. Sincerely, avid Kumar Production Manager Cook Inlet Energy Enclosed 1) Redoubt Gas Well Worksheet Indicating Produced and Flared Volumes 2) Root Cause Analysis and Steps taken to prevent re -occurrence 3) RU3 History and difficulty in restarting Osprey Gas Wells 4) Gas Disposition Decision Matrix 5) Chain of Command 6) Gas Disposition Training Slides xedoubt Gas Well Worksheet RU-3 Month MCF Total Gas Production from Osprey Total Gas Flared RU-4A (Excluding Solution Gas) (Over 1 hour) MCF MCF MCF Gas Flared Sep-14 0 63 63 Aug-14 0 1,8391 1,839 Jul-14� 0 6,530 6,530, Jun-14 1,018 13,84014,858 May-14 36,394 13,421 49,815 Apr-14', 28,778 13,521 42,29911 Mar-141 48,408 161184 1 64,592 li Feb-14' 51,789 14,672, 66,461, 6,699 10.08% Jan-14 37,812 13,939' 51,751 14,355 27.74% Dec-13 27,359 20,263 47,622 4,436 9.32% Nov-13', 32,044 20,001' 52,045: 1,875 3.60% Oct-131 42,641 18,858, 61,4991 Sep-13 47,375 13,8731 61,248' Aug-13' 53,390 19,177: 72,567 Jul-13 48,400 15,510 63,910 Jun-13 57,808 19,361 77,169 May-13' 35,692 27,046 62,738I Apr-13' 30,911 15,5481 46,459, Mar-131 33,618 8,143', 41,761, Feb-13 17,509 16,060 33,569 Jan-13 0 5,668 5,668 Total Percentage of Gas Flared (Nov-13 to Feb-14) 12.56% Root use Analysis and Preventaf Steps Situation -1 RU-3 Loaded up with water and lost flow • Rig/Coil intervention would be required to get RU-3 to Options Shut In flow again RU-3 • No guarantee of performing a successful workover due to • KU-3 naa plenty or tUK left Keep • Simple swabbing using cheap wireline RU-3 Flowinoperations was required to get it flowing to g...,�__a:.... __...- Low pressure gas was generated during swabbing operations • mover Tsixo or the total gas was usea during Nov, 13 — Feb, 14 . Out of the 96 days, there was either no flaring or flaring below 50MCF/D for 26 days Major overhaul was performed but was delayed Situation-2 West Foreland Unit due to long lead time for Compressor S-530B some parts required went down and needed major A booster compressor was overhaul simultaniously designed and Installed In order to handle low Situation-3 West Mac Saturn Varying load turbines were run In changes caused order to use low changes in gas pressure gas consumption Options Keep RU-3 Flowing Shut In RU-3 and RU-4 Permit to flare • Flare excess gas intermittently over 1hr as per • RU-3 well had to flow at max rate In gas dispostion order to sustain continuous flow A previously issued • No correlative rights were N iolated temporary permit to CIE also reported • There was no threat to public health or environment flare for RU-3 was flared volumes on • There were no safety concerns or uncontrolled releases misinterpreted as the excess flare logs permission to flare p • as requried by gas CIE was not profited by this action beyond an hr In event of swabbing disposition • Flaring was minimized to the greatest extent possible operations • RU-3 was shut In once the error was noticed • The Production Manager in question AOGCC questions was replaced CIE about extended . A similar situation with RU-4 was flaring avoided and RU-4 was shut down • Management of Change protocols were initiated and several layers of authority are required before flaring is authorized • Gas disposition training program is created and implement RU-3 History and Difficulty in Restarting Redoubt Unit #3 was completed on the southern flank of the Redoubt Shoal's Southern Fault Block into the Tyonek gas sands, which overlay the Redoubt Shoal structure. The well was first put on gas production May 28, 2003 and produced approximately 453 MMscf before the well was taken offline on December 6, 2003. After being shut in for an extended period of time, RU-3 was very difficult to bring back into production. Recompletion activities for RU-3 included pulling the existing gas completion, re -perforating the existing gas zone and installation of a new gas completion. This work was completed on December 16, 2012, however, it took several additional workover operations to bring the well online. During the RU-3 recompletion, the well was re -perforated at 11,410 ft TVD top perforations. The tubing was swabbed down to 2,660 ft but the well did not flow due to a hydrostatic head of 9000 ft of 8.7 ppg KCL brine. Further swabbing down to 3,150 ft had no effect and the wireline was damaged during the swabbing process. Fishing operations were successful to recover the swabbing BHA. Cook Inlet Energy then received approval to lift the well using nitrogen in an attempt to bring it online. Several days were spent with little success in lowering the fluid level in the tubing. Nitrogen coil lift from 13,000 ft was ineffective. It was suspected that the well design had too much volume (300 bbls) between the lower 9 5/8" packer and the perforations effectively killing the well on each nitrogen lift. Subsequent workover operations were planned to bring the well online using a nitrogen coil lift and an inflatable packer. Workover operations on RU-3 were successfully completed on February 19, 2013 and the well was brought online using nitrogen coil lift without an inflatable packer. The well produced approximately 631 MMscf before the well was shut-in on June 4, 2014 Currently, RU-3 is shut in with a wellhead pressure of 49 psi and loaded up with fluid. It is highly likely that intervention with a Rig/Coil unit would be required to bring it online. Flaring or Venting Event As per 20 AAC 25.235(b) Duration Over an hour it Schedu Scheduled AAC 25.235(d) Gas Disposition Decision Matrix Document Less than Does it comply with 20 an hour AAC 25.235(d)(4) j` Yes Form 10-422 Z 0 Minimize or Inform stop Venting or '. Production Production Flaring Manager immediately through chain of ` Manager unless required command notifies AOGCC for safety immediately Inform _ .._ g Production Flarin or ProductionF No Manager Manager Venting after through chain of ! notifies AOGCC I approval from r approval j AOGCC command C fo Form 10-422 and Written Supplement as per 20 AAC 25.235(b) 'Form 10-422 And Written Supplement as per 20 AAC 25.235(b) Chain of Command Lead Operator j Operator Production Foreman Production Engineer Chief [Production Regulatory , Operating Officer Manager Manager i AOGCC M Gas Disposition Training 20 AAC 25.235 Cook Inlet Energy M.-I I . Cook Inlet Energy_ Introduction All CIE Operators at all facilities must use good oil field engineering and conservation practices to minimize the volume of gas released, burned, or permitted to escape into the air CIE is required to track all gas handled on a production facility by pool and report to AOGCC on a monthly basis according to 20 AAC 25.235 _ Cook Inlet Energy_ Definitions o Gas disposition is the tracking and reporting of all gas handled (produced, purchased, sold, transferred, reinjected, flared or vented, used for lease operations, and NGLs produced) on a production facility by pool A pool, or unit, is a consolidation of leased lands that comprise a common underground geological reservoir Cook Inlet Energy_ AOGCC Definition of Waste Gas released, burned, or permitted to escape into the air constitutes waste, except that Flaring or venting gas for a period not exceeding one hour as the result of an emergency or operational upset is authorized for safety; Flaring or venting gas for a period not exceeding one hour as the result of a planned lease operation is authorized for safety; Flaring pilot or purge gas to test or fuel the safety flare system is authorized for safety; Minor venting of gas incidental to normal oil field operations is authorized; :a "s Iit— . Cook Inlet Energy_ When is venting/flaring pre authorized - Flaring or venting of gas for a period of less than 1 hour as the result of an emergency or operational upset is authorized for safety; Flaring or venting of gas for a period of less than 1 hour as the result of a planned lease operation is authorized for safety; Flaring pilot or purge gas to test or fuel the safety flare system is authorized for safety; Gas volumes flared or vented during these events must be recorded but do not require supplemental information since the duration was less than 1 hour. I[- Cook Inlet Energy_. When is venting/flaring authorized by AOGCC AOGCC, in its discretion, will authorize flaring or venting of gas for periods exceeding 1 hour if: * the flaring or venting is necessary for facility operations, repairs, upgrades, or testing procedures; an emergency that threatens life or property requires the flaring or venting, unless failure to operate in a safe and skillful manner causes the emergency; the flaring or venting is necessary to prevent loss of ultimate recovery; Authorization for these types of flaring or venting events is usually received within 90 days of submitting the Facility Report of Produced Gas Disposition (Form 10-422) Upon application, the AOGCC will, in its discretion, authorize the flaring or venting of gas for purposes of testing a well before regular } production Cook Inlet Energy_ It - Flare Reporting - Supplement Information Flaring or venting incidents exceeding 1 hour require supplemental information: o Explains why the gas was flared or vented, o Lists the beginning and ending time of the flaring or venting Reports the volume of gas flared or vented 0 Describes actions taken to minimize the volume of gas burned or released. CIE Operators internally report this information to the Production Manager using the CIE Excess Flare Log IL- Cook Inlet Energy_ N.-7 Disposition Reporting: Form 10-422 The Production Manager is responsible for reporting gas disposition for each production facility using the Facility Report of Produced Gas Disposition (AOGCC Form 10-422) o Gas acquisition or disposition includes the following categories Gas sold Gas re -injected Gas flared or vented Gas used for lease operations other than flaring or venting; Natural gas liquids (NGLs) produced Gas purchased Gas transferred Other When a facility's gas production comes from multiple pools, production must be allocated between the pools as a percentage of s 5 the total volume of gas that the facility handled for the month. Cook Inlet- L gy- :. What to do when there is venting or flaring Any release, burning, or escape into the air of gas other than minimal venting as authorized must be reported as flared or vented on the Facility Report of Produced Gas Disposition (Form 10-422) Follow the chain of command to comply with gas disposition rules Decision Matrix Flaring or Venting Event As per 20 AAC 25.235(b) Less than floes it comply with 20 Duration an hour AAC 25.235(d)(4) Z Over an O hour Minimize or inform stop Venting or Production Flaring Manager is it Scheduled NO immediately through chain of unless required: command for safety immediately r m Inform -- Production Scheduled, Production Manager AAC 25.235(d) Manager g er notifies AOGCC through chain of for approval command Cook Inlet Energy_ Document Yes r ,Form 10-422 Form 10-422 and Production Manager Written Supplement notifies AOGCC as per 20 AAC 25.23S(b) Form 10.422 Flaring or And Venting after ! approval from `Written Supplement AOGCC as per 20 AAC 25.235(b) 0 lu- - Cook Inlet Energy_ Chain of Command THE STATE E October 31, 2014 CERTIFIED MAIL — RETURN RECEIPT REQUESTED 7009 2250 0004 3911 3477 David Kumar Production Manager Cook Inlet Energy 601 West 5th Avenue, Suite 310 Anchorage, AK 99501 Re: Docket Number: OTH-14-024 Notice of Proposed Enforcement Action Failure to Minimize or Prevent Gas Flaring, Redoubt Unit #3 (PTD 201-064) Dear Mr. Kumar: As part of the informal review process, the Alaska Oil and Gas Conservation Commission (AOGCC) is providing Cook Inlet Energy an opportunity to submit documentary material and make written and oral statements regarding the above -referenced Notice of Proposed Enforcement Action for Failure to Minimize or Prevent Gas Flaring, Redoubt Unit #3. The informal review meeting is scheduled for December 1, 2014 at 9:00 a.m. in the AOGCC's Anchorage office at 333 West 7th Avenue. Copies of all written submissions and a summary of any oral statements planned by CIE should be provided to the AOGCC no later than November 20, 2014 so we can make best use of the informal review. Sincerely, w David J. Mayberry Commissioner L omestic Mail Only; No Insurance Coverage Provided) r delivery information visit our website at www.usps.com,. rl Ir Postage $ m Certified Fee O Return Receipt Fee O (Endorsement Required) C3 Restdcted Delivery Fee (Endorsement Required) C3 u'I ru Total Postage & Fees [$ nJ Sent To O 171 - Sfieef, Apt. o.; or PO Box No. --------------------- w ■ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ■ Print your name and address on the reverse so that we can return the card to you. ■ Attach this card to the back of the mailpiece, or on the front if space permits. Postmark Here 1. Article Addressed to: bX14 � 01� r plc A� kao)r �S ✓11��- C-Ae r�� (o O t v� wee Ay"CJA Q'4-c'kVyt Ip . 00 2. Article Number (rransfar from service label) Ll U 4 B. Received by (Printed Nam Die of Delivery D. Is delivery address different from item 1? ❑ Yes If YES, enter delivery address below: ❑ No 3. Service Type ❑ Certified Mail ❑ Express Mail ❑ Registered ❑ Return Receipt for Merchandise ❑ Insured Mail ❑ C.O.D. 4. Restricted Delivery? (Extra Fee) ❑ Yes 7009 2250 0004 3911 3477 PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 Cook Inlet Energy_ October 29, 2014 Ms. Cathy Foerster, Chair Alaska Oil and Gas Conservation Commission 333 West 7 h Ave., Suite 100 Anchorage, Alaska 99501 Re: Docket Number: OTH-14-024 OCT 2 9 2014 Response to AOGCC Proposed Enforcement Action Failure to Minimize or Prevent Gas Flaring, Redoubt Unit #3 (PTD 201-064) Dear Ms. Foerster, In response to your letter dated October 24, 2014 (attached) regarding Gas Flaring of RU-03, Cook Inlet Energy respectfully requests an informal review under 20 AAC 25.535(c) to discuss matters related to gas disposition and provide additional documentation of actions taken to prevent similar incidents in the future. We kindly look forward to your reply providing a date for this review. If necessary, you may contact me at 907-433-3822. Sincerely, a�� l 0� vid Kumar Production Manager Cook Inlet Energy Attachments: AOGCC Notice of Proposed Enforcement Action, Docket OTH-14-024 601 W. 511 Avenue, Suite 310, Anchorage, AK 99501 (907) 334-6745 * (907) 334-6735 fax THE STATr, 01 A LASTK,-,,�A�,, GOVERNOR SEAN PARNELL October 23, 2014 CERTIFIED MAIL — RETURN RECEIPT REQUESTED 7009 2250 0004 39113484 Mr. David Kumar Acting Production Manager Cook Inlet Energy, LLC 601 W 5th Avenue, Suite 310 Anchorage, AK 99501 Alaska Cu!1 amd Gaa CJau7Ilo-nm55 it 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907.279.1433 Fax: 907.276.7542 RECEIVED OCT 2 4 2014 COOK INLET ENERGY Re: Docket Number: OTH-14-024 Notice of Proposed Enforcement Action Failure to Minimize or Prevent Gas Flaring, Redoubt Unit 43 (PTD 201-064) Dear Mr. Kumar: Pursuant to 20 AAC 25.535, the Alaska Oil and Gas Conservation Commission (AOGCC) hereby notifies Cook Inlet Energy, LLC (CIE) of a proposed enforcement action. Nature of the Apparent Violation or Noncompliance (20 AAC 25 535(b)(1)) CIE has violated the provisions of 20 AAC 25.235 ("Gas disposition") in its operation of Redoubt Unit #3 (RU-3). Basis for Finding the Violation or Noncompliance (20 AAC 25 535(b)(2)) Under 20 AAC 25.235(c) an operator is required to act in accordance with good oil field engineering practices and conservation purposes to minimize the volume of gas released, burned, or permitted to escape into the air. Under 20 AAC 25.235(d) gas released, burned, or permitted to escape into the air constitutes waste, except for instances of safety, lease operation and conservation. On February 15, 2013, AOGCC authorized CIE to flare gas up to 72 hours for the purpose of unloading Well RU-3. No additional approvals were sought by CIE or granted by AOGCC. On July 10, 2014 AOGCC inquired about flaring beyond the 72 hours approved. CIE did not respond. On August 15, 2014 AOGCC sent a second inquiry about flaring beyond the 72 hours approved. CIE did not respond until August 19, 2014 with an acknowledgement that Notice of Proposed Enforcemen_ _ction October 23, 2014 Page 2 of 3 management controls were inadequate as were key personnel's understanding of AOGCC regulations. CIE obtained AOGCC approval for 72 hours of flaring during February, 2013. CIE commenced flaring, again, without AOGCC approval from Well RU-3 through the Kustatan facility on November 25, 2013, and continued through February 28, 2014. Facility Reports of Produced Gas Disposition, Form 10-422s for these months indicate a total of 24,668 MCF of produced gas from RU-3 was flared on 96 days at the Kustatan Production Facility between November 25, 2013 and February 28, 2014. This flaring constitutes waste. Proposed Action (20 AAC 25.535(b)(3)). The AOGCC proposes to order the following corrective actions by CIE: (1) Within two (2) weeks following the date of receipt of AOGCC's final decision, CIE shall provide AOGCC a detailed description and an example of its regulatory compliance tracking program and a copy of its written management -of -change procedures; (2) Within two (2) weeks following the date of receipt of AOGCC's final decision, CIE shall provide AOGCC with a root cause analysis addressing the violations, and timeline for implementing identified corrective actions. (3) Within two (2) weeks following the date of receipt of AOGCC final decision, CIE shall provide AOGCC evidence that personnel responsible for gas disposition management and staff involved with facility and well operations have been trained in AOGCC regulatory requirements, including the process for requesting approval for flaring activities from the AOGCC. A copy of the training program syllabus is to be included with other appropriate documentation. For violating 20 AAC 25.235(c), the AOGCC intends to impose civil penalties on CIE under AS 31.05.150 (a)' and AS 31.05.150 (d)2 as follows: - $25,000 for the initial violation — failure to shut-in RU-3 when the Kustatan production facility was undergoing a major overhaul. - $269,834 for flaring 24,668 MCF of gas continuously from November 26, 2013 through February 28, 2014. The total proposed civil penalty is $294,834. The serious nature of this disregard for the AOGCC's regulations and the wasteful nature of gas flaring warrant these penalties. CIE's inadequate management -of -change protocols, CIE's history of compliance issues and the need to deter are additional factors in the AOGCC's analysis. 1 AS 31.05.150(a) provides for a civil penalty of not more than $100,000 for the initial violation and not more than $10,000 for each day thereafter on which the violation continues. 2 AS 31.05.150(d) provides for a civil penalty for each 1,000 cubic feet of natural gas flared, vented, or otherwise determined to be waste as defined in AS 31.05.170. The penalty shall be twice the fair market value of the natural gas at the point of waste. Penalty calculation: 41h Q, 2013: 4,982 MSCF*5.710 $/MCF*2=$56,894, 1st Q, 2014: 19,686 MSCF*5.383 $/MCF*2=$211,940. Cook Inlet Gas Prevailing Value published by the Department of Revenue. Notice of Proposed Enforcemen tion October 23, 2014 Page 3 of 3 Rights and Liabilities (20 AAC 25.535(b)(4)) Within 15 days after receipt of this notification — unless the AOGCC, in its discretion, grants an extension for good cause shown — CIE may file with the AOGCC a written response that concurs in whole or in part with the proposed action described herein, requests informal review, or requests a hearing under 20 AAC 25.540. If a timely response is not filed, the proposed action will be deemed accepted by default. If informal review is requested, the AOGCC will provide CIE an opportunity to submit documentary material and make a written or oral statement. If CIE disagrees with the AOGCC's proposed decision or order after that review, it may file a written request for a hearing within 10 days after the proposed decision or order is issued. If such a request is not filed within that 10-day period, the proposed decision or order will become final on the IIth day after it was issued. If such a request is timely filed, the AOGCC will hold its decision in abeyance and schedule a hearing. If CIE does not concur in the proposed action described herein, and the AOGCC finds that CIE violated a provision of AS 31.05, 20 AAC 25, or an AOGCC order, permit or other approval, then the AOGCC may take any action authorized by the applicable law including ordering one or more of the following: (i) corrective action; (ii) suspension or revocation of a permit or other approval; and (iii) imposition of penalties under AS 31.05.150. In taking action after an informal review or hearing, the AOGCC is not limited to ordering the proposed action described herein, as long as CIE received reasonable notice and opportunity to be heard with respect to the AOGCC's action. Any action described herein or taken after an informal review or hearing does not limit the action the AOGCC may take under AS 31.05.160. Sincerely, Cathy . Foerster Chair, Commissioner October 23, 2014 CERTIFIED MAIL — RETURN RECEIPT REQUESTED 7009 2250 0004 3911 3484 Mr. David Kumar Acting Production Manager Cook Inlet Energy, LLC 601 W 5"' Avenue, Suite 310 Anchorage, AK 99501 I'r, c, r Lu `i9 'Si Re: Docket Number: OTH-14-024 Notice of Proposed Enforcement Action Failure to Minimize or Prevent Gas Flaring, Redoubt Unit 43 (PTD 201-064) Dear Mr. Kumar: Pursuant to 20 AAC 25.535, the Alaska Oil and Gas Conservation Commission (AOGCC) hereby notifies Cook Inlet Energy, LLC (CIE) of a proposed enforcement action. Nature of the Apparent Violation or Noncompliance (20 AAC 25.535(b)(1)). CIE has violated the provisions of 20 AAC 25.235 ("Gas disposition") in its operation of Redoubt Unit #3 (RU-3). Basis for Finding the Violation or Noncompliance (20 AAC 25.535(b)(2)). Under 20 AAC 25.235(c) an operator is required to act in accordance with good oil field engineering practices and conservation purposes to minimize the volume of gas released, burned, or permitted to escape into the air. Under 20 AAC 25.235(d) gas released, burned, or permitted to escape into the air constitutes waste, except for instances of safety, lease operation and conservation. On February 15, 2013, AOGCC authorized CIE to flare gas up to 72 hours for the purpose of unloading Well RU-3. No additional approvals were sought by CIE or granted by AOGCC. On July 10, 2014 AOGCC inquired about flaring beyond the 72 hours approved. CIE did not respond. On August 15, 2014 AOGCC sent a second inquiry about flaring beyond the 72 hours approved. CIE did not respond until August 19, 2014 with an acknowledgement that Notice of Proposed Enforcemen tion October 23, 2014 Page 2 of 3 management controls were inadequate as were key personnel's understanding of AOGCC regulations. CIE obtained AOGCC approval for 72 hours of flaring during February, 2013. CIE commenced flaring, again, without AOGCC approval from Well RU-3 through the Kustatan facility on November 25, 2013, and continued through February 28. 2014. Facility Reports of Produced Gas Disposition, Form 10-422s for these months indicate a total of 24,668 MCF of produced gas from RU-3 was flared on 96 days at the Kustatan Production Facility between November 25. 2013 and February 28, 2014. This flaring constitutes waste. Proposed Action (20 AAC 25.535(b)(3)). The AOGCC proposes to order the following corrective actions by CIE: (1) Within two (2) weeks following the date of receipt of AOGCC's final decision, CIE shall provide AOGCC a detailed description and an example of its regulatory compliance tracking program and a copy of its written management -of -change procedures; (2) Within two (2) weeks following the date of receipt of AOGCC's final decision, CIE shall provide AOGCC with a root cause analysis addressing the violations. and timeline for implementing identified corrective actions. (3) Within two (2) weeks following the date of receipt of AOGCC final decision, CIE shall provide AOGCC evidence that personnel responsible for gas disposition management and staff involved with facility and well operations have been trained in AOGCC regulatory requirements, including the process for requesting approval for flaring activities from the AOGCC. A copy of the training program syllabus is to be included with other appropriate documentation. For violating 20 AAC 25.235(c), the AOGCC intends to impose civil penalties on CIE under AS 31.05.150 (a)' and AS 31.05.150 (d)2 as follows: - $25,000 for the initial violation — failure to shut-in RU-3 when the Kustatan production facility was undergoing a major overhaul. - $269,834 for flaring 24,668 MCF of gas continuously from November 26, 2013 through February 28, 2014. The total proposed civil penalty is $294,834. The serious nature of this disregard for the AOGCC's regulations and the wasteful nature of gas flaring warrant these penalties. CIE's inadequate management -of -change protocols, CIE's history of compliance issues and the need to deter are additional factors in the AOGCC's analysis. AS 31.05.150(a) provides for a civil penalty of not more than $100,000 for the initial violation and not more than $10,000 for each day thereafter on which the violation continues. z AS 31.05.150(d) provides for a civil penalty for each 1,000 cubic feet of natural gas flared, vented, or otherwise determined to be waste as defined in AS 31.05.170. The penalty shall be twice the fair market value of the natural gas at the point of waste. Penalty calculation: 41h Q, 2013: 4,982 MSCF*5.710 $/MCF*2=$56,894, 1st Q, 2014: 19,686 MSCF*5.383 $/MCF*2=$211,940. Cook Inlet Gas Prevailing Value published by the Department of Revenue. Notice of Proposed Enforcemen ion October 23, 2014 Page 3 of 3 Rights and Liabilities (20 AAC 25.535(b)(4 Within 15 days after receipt of this notification — unless the AOGCC, in its discretion, grants an extension for good cause shown — CIE may file with the AOGCC a written response that concurs in whole or in part with the proposed action described herein, requests informal review, or requests a hearing under 20 AAC 25.540. If a timely response is not filed, the proposed action will be deemed accepted by default. If informal review is requested, the AOGCC will provide CIE an opportunity to submit documentary material and make a written or oral statement. If CIE disagrees with the AOGCC's proposed decision or order after that review, it may file a written request for a hearing within 10 days after the proposed decision or order is issued. If such a request is not filed within that 10-day period, the proposed decision or order will become final on the II"' day after it was issued. If such a request is timely filed, the AOGCC will hold its decision in abeyance and schedule a hearing. If CIE does not concur in the proposed action described herein, and the AOGCC finds that CIE violated a provision of AS 31.05, 20 AAC 25, or an AOGCC order, permit or other approval, then the AOGCC may take any action authorized by the applicable law including ordering one or more of the following: (i) corrective action; (ii) suspension or revocation of a permit or other approval; and (iii) imposition of penalties under AS 31.05.150. In taking action after an informal review or hearing, the AOGCC is not limited to ordering the proposed action described herein, as long as CIE received reasonable notice and opportunity to be heard with respect to the AOGCC's action. Any action described herein or taken after an informal review or hearing does not limit the action the AOGCC may take under AS 31.05.160. Sincerely, /-t-- Cathiv Foerster Chair, Commissioner Postal MAILT,, RECEIPT (DomesticCERTIFIED . • . CO m a 11- Postage $ M Certified Fee Postmark ❑ Return Receipt Fee Here E3 (Endorsement Required) C3 Restricted Delivery Fee (Endorsement Required) Q ul nj Total Postage & Fees 1 $ ru Mr. David Kumar Sent To a— Acting Production Manager O Cook Inlet Ener LLC ------ Street, Apt. No.; gy, or PO Box No. 601 W. 5th Ave., Ste. 310 f` ----------•------------ g ----- City, State, ZIP+4 Anchors e, AK 99501 PS Form :rr August 2D06 COMPLETE THIS SECTION COMPLETE THIS SECTIONZENDER: ■ Complete items 1, 2, and 3. Also complete A. S4atureitem ❑Agent 4 if Restricted Delivery is desired. I(�� ■ Print your name and address on the reverseX ❑ Addre P ' a N e) C; R to of Dell so that we can return the card to you. ■ Attach this card to the back of the mailpiece, t/ �,' G 1 !Vi or on the front if space permits. D. Is delivery ad ess differ t from item 1? If YES, enter delivery address below: 0 Yes ❑ No 1. Article Addressed to: Mr. David Kumar Acting Production Manager Cook Inlet Energy, LLC I 3. Se oeType 601 W. 5th Ave., Ste. 310 E3 Certified Mail ❑ Express Mail Anchorage, AK 99501 ❑ Registered ❑ Return Receipt for Merchandise ❑ insured Mail ❑ C.O.D. 4. Restricted Delivery? (Extra Fee) ❑ Yes 2. Article Number 7009 2250 ��04 3911, 3484 (Transfer from service label) PS Form 3811, February 2004 Domestic Return Receipt to25s52M-tsao I I Ferguson, Victoria L (DOA) From: David Kumar <David.Kumar@cookinlet.net> Sent: Tuesday, August 19, 2014 4:51 PM To: Ferguson, Victoria L (DOA) Cc: Courtney Rust; Conrad Perry; David Hall Subject: RE: CIE RU3 PTD 201-064 Gas Flaring Attachments: CIE Response to Flaring in RU-3.pdf Dear Ferguson, Please find CIE's response for flaring gas from RU-3. If you have any questions or concerns please don't hesitate to contact me. Thank you Regards D"ID KuMAR f 7. ,..r- David,Kumar@cookiNet.net 1 Cook Inlet Energy_ August 14, 2014 Ms. Victoria Ferguson Alaska Oil and Gas Conservation Commission 333 West 711, Ave., Suite 100 Anchorage, Alaska 99501 Re: Extended Flaring Cook Inlet Energy, LLC: Redoubt Unit #3 Permit to Drill No: 201-064 API No: 50-73320504-00 Dear Ms. Ferguson, Cook Inlet Energy recognizes the inadvertent flaring from RU-3 without prior approval from the AOGCC. The well was loading up with fluid and continued swabbing was necessary to keep it alive. This action kept the well unloaded and we were able to continue with success. There was no venting or flaring on the platform during this operation, and all gas was sent to the Kustatan production facility for processing. However, during this period one of the compressors at our Kustatan production facility was undergoing a major overhaul and this excess low-pressure gas was unable to be compressed or utilized and was consequent y __.flared. Our new Proauction Manager at that time was unfamiliar with Alaska regulations and protocols and had misinterpreted the prior approval for short duration flaring as an extended one. This incident brings to light how the management controls in -place were inadequate to deal with situations like this. This incident could have been prevented with proper senior oversight coupled with training/familiarization of AOGCC regulations for all personnel involved in the chain of command. The Production Manager in question is being replaced and we will correct any inadequacy in training and familiarization issues with subsequent personnel. We will not only conduct training in this aspect but also for other AOGCC regulatory issues such as the testing of safety valves, proper lock out and tag out of approved safety systems, notification to the AOGCC etc. to ensure continued compliance. Cook Inlet Energy strives to be fully compliant with all governmental rules and regulations. We feel by this additional training to all new and existing personnel in the chain of command, we will improve on our compliance record. We will continue to review regulatory responsibilities of all personnel and encourage all our personnel to stop activity and notify higher management if they are uncertain if an operation fully j complies with regulations, based on the training they receive. We also welcome any additional suggestions by the AOGCC to improve our program. If you have any questions, please contact me at (907)-433-3822. Sincerely, ;umar Ctindg,Production Manager Cook Inlet Energy 601 W. 5"' Avenue, Suite 310, Anchorage, AK 99501 (907) 334-6745 (907) 334-6735 fax Ferguson, Victoria L (DOA) From: Courtney Rust <Courtney.Rust@cookinlet.net> Sent: Monday, August 18, 2014 7:17 AM To: Ferguson, Victoria L (DOA) Subject: Re: CIE RU3 PTD 201-064 Gas Flaring 12/13-2/14 Victoria, I apologize (again). When I got back to the office I investigated the incident and drafted a letter that is going through management for approval. I am aware that you only gave approval for 72 hours of flaring in February 2013 and was unaware that we had done any flaring since. I understand the importance of this issue and am trying to get that letter approved and sent over today. Courtney On 8/15/14 11:39 AM, "Ferguson, Victoria L (DOA)" <victoria.ferguson@alaska.gov> wrote: >Shawn, Courtney, >Please explain or provide correspondence that explains this flaring. >Thanx, >Victoria >Victoria Ferguson >Senior Petroleum Engineer >State of Alaska >Oil & Gas Conservation Commission >333 W. 7th Ave, Ste 100 >Anchorage, AK 99501 >Work: (907)793-1247 >victoria.fereuson(@alaska.gov G >CONFIDENTIALIT( NOTICE: This e-mail message, including any attachments, >contains information from the Alaska Oil and Gas Conservation >Commission (AOGCC), State of Alaska and is for the sole use of the >intended recipient(s). It may contain confidential and/or privileged information. >The unauthorized review, use or disclosure of such information may >violate state or federal law. If you are an unintended recipient of >this e-mail, please delete it, without first saving or forwarding it, >and, so that the AOGCC is aware of the mistake in sending it to you, >contact Victoria Ferguson at (907)793-1247 or >Victoria.Ferguson@alaska.gov >----- Original Message----- >From: Ferguson, Victoria L (DOA) >Sent: Thursday, July 10, 2014 1:30 PM >To: 'Shawn Dillon' >Subject: RE: CIE RU3 PTD 201-064 Gas Flaring >Shawn, >Thanx for the correspondence from Feb 2013 regarding flaring of RU-3. >Do you have any correspondence that addresses the flaring of RU-3 for >the Dec, 2013 through Feb, 2014? >Thanx, >Victoria >Victoria Ferguson >Senior Petroleum Engineer >State of Alaska >Oil & Gas Conservation Commission >333 W. 7th Ave, Ste 100 >Anchorage, AK 99501 >Work: (907)793-1247 >victoria.ferguson@alaska.gov >CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, >contains information from the Alaska Oil and Gas Conservation >Commission (AOGCC), State of Alaska and is for the sole use of the >intended recipient(s). It may contain confidential and/or privileged information. >The unauthorized review, use or disclosure of such information may >violate state or federal law. If you are an unintended recipient of >this e-mail, please delete it, without first saving or forwarding it, >and, so that the AOGCC is aware of the mistake in sending it to you, >contact Victoria Ferguson at (907)793-1247 or >Victoria.Ferguson@alaska.gov >----- Original Message ----- >From: Shawn Dillon fmailto:Shawn.Dillon@cookinlet.net) >Sent: Tuesday, July 01, 201411:42 AM >To: Ferguson, Victoria L (DOA) >Cc: Dan Dickinson >Subject: FW: CIE RU3 PTD 201-064 >Victoria, > Here is the email trail for RU3. >Thanks, >Shawn Dillon >Production Manager >Cook Inlet Energy 2 >907-433-3829 >On 2/15/13 12:30 AM, "Ferguson, Victoria L (DOA)" ><victoria.ferguson(@alaska.gov> wrote: >>You have approval to flare as requested. >>Sent from my iPhone >>On Feb 14, 2013, at 7:09 PM, "Courtney Rust" >><courtney.rust@cookinlet. net> wrote: >>> Victoria, >>> Have you had a chance to review our request for a time extension on >>>flaring? >>> Thank you for your time on this. >>> Courtney 91 Ferguson, Victoria L (DOA) N From: Ferguson, Victoria L (DOA) Sent: Thursday, July 10, 2014 1.30 PM To: 'Shawn Dillon' Subject: RE: CIE RU3 PTD 201-064 Gas Flaring Shawn, Thanx for the correspondence from Feb 2013 regarding flaring of RU-3. Do you have any correspondence that addresses the flaring of RU-3 for the Dec, 2013 through Feb, 2014? Thanx, Victoria Victoria Ferguson Senior Petroleum Engineer State of Alaska Oil & Gas Conservation Commission 333 W. 7th Ave, Ste 100 Anchorage, AK 99501 Work: (907)793-1247 victoria.ferguson@alaska.�ov CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, contains information from the Alaska Oil and Gas Conservation Commission (AOGCC), State of Alaska and is for the sole use of the intended recipient(s). It may contain confidential and/or privileged information. The unauthorized review, use or disclosure of such information may violate state or federal law. If you are an unintended recipient of this e-mail, please delete it, without first saving or forwarding it, and, so that the AOGCC is aware of the mistake in sending it to you, contact Victoria Ferguson at (907)793- 1247 or Victoria.Ferguson@alaska.gov -----Original Message ----- From: Shawn Dillon[mailto:Shawn.Dillon@cookinlet.net] Sent: Tuesday, July 01, 2014 11:42 AM To: Ferguson, Victoria L (DOA) Cc: Dan Dickinson Subject: FW: CIE RU3 PTD 201-064 Victoria, Here is the email trail for RU3. Thanks, Shawn Dillon Production Manager Cook Inlet Energy 907-433-3829 1 On 2/15/13 12:30 AM, "Ferguson, Victoria L (DOA)" <victoria.ferguson@alaska.gov> wrote: >You have approval to flare as requested. >Sent from my Whone >On Feb 14, 2013, at 7:09 PM, "Courtney Rust" ><courtney.rust@cookinlet.net> wrote: >> Victoria, >> Have you had a chance to review our request for a time extension on >>flaring? >> Thank you for your time on this. >> Courtney _ Cook Inlet Energy February 13, 2013 Ms. Cathy Foerster, Chair Alaska Oil and Gas Conservation Commission 333 West 7th Ave., Suite 100 Anchorage, Alaska 99501 Re: Sundry Application Cook Inlet Energy, LLC: Redoubt Unit #3 Permit to Drill No: 201-064 API No: 50-73320504-00 Dear Ms. Foerster, Cook Inlet Energy (CIE) hereby submits a Sundry Application Redoubt Unit #3 well located in Redoubt Shoal, Cook Inlet. Workover operations under previous Sundry Application #312-358 successfully completed the well however, were insufficient to clear the tubing and perforations of completion brine. failed to bring the well ^^. CIE requests permission to flare test RU#3 to atmosphere for up to 48 hrs in order to increase the gas veloci and unload the water from the wellbore. If you have any questions, please contact me at (907)-433-3804. Sincerely, David Hall CEO - Cook Inlet Energy 601 W. Sth Avenue, Suite 310, Anchorage, AK 99501 (907) 334-6745 * (907) 334-6735 fax Schwartz, Guy L (DOA) From: Ferguson, Victoria L (DOA) Sent: Friday, February 15, 2013 9:03 AM To: Schwartz, Guy L (DOA) Subject: FW: CIE RU3 PTD 201-064 -----Original Message ----- From: courtney Rust(mailto:courtney.rust@cookinlet.net) Sent: Thursday, February 14, 2013 8:32 PM To: Ferguson, Victoria L (DOA) Subject: Re: CIE RU3 PTD 201-064 Thank you Victoria! On 2/14/13 8:30 PM, "Ferguson, Victoria L (DOA)" <victoria.ferguson@alaska.gov> wrote: >You have approval to flare as requested. >Sent from my iPhone >On Feb 14, 2013, at 7:09 ><courtney.rust@cookinlet >> Victoria, >> Have you had a chance >>flaring? PM, "Courtney Rust" net> wrote: to review our request for a time extension on >> Thank you for your time on this. >> Courtney i Page 1 of 1 Schwartz, Guy L (DOA' From: Ferguson, Victoria L (DOA) Sent: Tuesday, February 12, 2013 2:41 PM To: courtney.rust@cookinlet.net Cc: Schwartz, Guy L (DOA) Subject: FW: CIE RU3 PTD 201-064 Courtney, CIE must keep track of the flaring volumes and submit the flaring activity on form 10-422 at the end of the month. In the future if flaring activity is planned please include this in the Sundry request. Thanx, Victoria Victoria Ferguson Senior Petroleum Engineer State of Alaska Oil 8 Gas Conservation Commission. 333 W 7th Ave, Ste 100 Anchorage, AK 99501 Work: (907)793-1247 victoria.terguson@afaska.gov From: Sent: Tuesday, February 12, 2013 2:32 PM To: Ferguson, Victoria L (DOA) Cc: Schwartz, Guy L (DOA) Subject: CIE RU3 PTD 201-064 Victoria, Cook Inlet Energy requests a verbal approval for the flaring of gas on RU3 for 48 hours to finish unloading the water from the well. A sundry will be submitted immediately. Thank you, Courtney Must Cook Inlet Energy Project Engineer Office- 907-433-3809 cell-907-350-0091 2/19/2013 Confidential Penalty Calculation held in secure storage THE STATE of LASKA GOVERNOR SEAN PARNELL David Hall CEO Cook Inlet Energy, LLC 601 W. 51" Ave., Suite 310 Anchorage, AK 99501 Idaska 0gt annd Gas Conservation Commission Re: Redoubt Shoal Field, Undefined Pool, Redoubt Unit #3 Sundry Number: 313-075 Dear Mr. Hall: 333 West Seventh Avenue Anchorage. Alaska 99501-3572 Main. 907 279 1433 Fax. 907 276 7542 Enclosed is the approved Application for Sundry Approval relating to the above referenced well. Please note the conditions of approval set out in the enclosed form. As provided in AS 31.05.080, within 20 days after written notice of this 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. A request for reconsideration is considered timely if it is received by 4:30 PM on the 23rd day following the date of this letter, or the next working day if the 23rd day falls on a holiday or weekend. Sincerely, Cathy P. oerster Chair Sf DATED this day of February, 2013. Encl. L STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION APPLICATION FOR SUNDRY APPROVALS 20 AAC 25.280 FEB 13 2013 AOGCC 1. Type of Request: Abandon ❑ Plug for Redriil ❑ Perforate New Pool ❑ Repair Well ❑ Change Approved Program ❑ Suspend ❑ Plug Perforations ❑ Perforate ❑ Pull Tubing ❑ Time Extension ❑ Operations Shutdown ❑ Re-enter Susp. Well ❑ Stimulate ❑ Alter Casing ❑ Other: Flaring_ Q - 2. Operator Name: 4. Current Well Class: 5. Permit to Drill Number: COOK INLET ENERGY LLC Exploratory ❑ Development Q- Stratigraphic ❑ Service ❑ 201-064 3. Address: 6. API Number: 601 W. 5th AVE. SUITE 310, ANCHORAGE, AK 99501 50-733-20504-00 7 If perforating: 8. Well Name and Number: What Regulation or Conservation Order governs well spacing in this pool? 20 AAC 25.055 REDOUBT UNIT #3 f Will planned perforations require a spacing exception? Yes ❑ No Q 9. Property Designation (Lease Number): 10. Field/Pool(s): ADL-381203 (surface), ADL-374002 TD REDOUBT SHOAL UNDEFINED- 11. PRESENT WELL CONDITION SUMMARY Total Depth MD (ft): Total Depth TVD (ft): Effective Depth MD (ft): Effective Depth TVD (ft): Plugs (measured) Junk (measured): ' 16,940 13,016 8,990 7,122 8,990 & 14,450 8,930 Casing Length Size MD TVD Burst Collapse Structural 150, 30" 150, 150' NIA N/A Conductor Surface 3507' 13 318" 3,50T 3,024' 5,020 2,260 Intermediate 9,332 9 518" 9,332 7,416 6,870 4,750 Produc8on 6,512' 7 518" 15,615' 11,981' 6,890 4,790 Liner. 2,223' 51/2" 16,940' 13,016' 7,740 6,280 Perforation Depth MD (fl): Perforation Depth TVD (ft): Tubing Size: Tubing Grade: Tubing MD (ft): 7,780-7,818'/14,803-14,860' 6,203-6,232'/11,410-11,450' 2 7/8" L-80 EUE M 14,791' Packers and SSSV Type: 2 7/8" Halliburton SSSV Packers and SSSV MD (ft) and TVD (ft): SSSV @ 287' MD(rVD 9 5/8" Weatherford Hydrow I packer/7 5/8" Hydrow 1 Packer Y Packer @ 7,614' MD/6,075TVD and 14,700' MD/11,338' TVD 12. Attachments: ❑ Description Summary or Proposal � 13. Well Class after proposed work: Detailed Operations Program Q BOP Sketch Exploratory ❑ Development Q' Service ❑ 14, Estimated Date for 15. Well Status after proposed work: Commencing Operations: 2112/2013 Oil ❑ Gas Q. WDSPL ❑ Suspended ❑ WINJ ❑ GINJ ❑ WAG ❑ Abandoned ❑ 16. Verbal Approval: Date: 2/12/2013 Commission Representative: Victoria Ferguson GSTOR ❑ SPLUG 17. 1 hereby certify that the foregoing is true and correct to the best of my knowledge. Contact Courtney Rust 907-433-3809 Printed Name `)A 4 l� a4 �( Title I Signature I Phone Date COMMISSION USE ONLY Conditions of approval: Notify Commission so that a representative may witness Sundry Number: 3 f 3—V-7 Plug Integrity [� BOP Test Mechanical Integrity Test Location Clearance In Other. Subsequent Form Required: ❑ d !b i 2'�� APPROVED BY 4 G I UPAdl� /z t3 Form 10-403 (nevi 0 2 v Ilcation is valid for 12 months from the date of approval. Submit Form and 10 n /y kP ��9 Table of Contents BOPSketch......................................................... Wellhead Schematic ......................................... I ...................... s ..................................... 6 RU #3 Current Completion 1/3t2013 SSSV @ 303' MO 2 718" 6.5# L-80 EUE M Tubing TOIL 9,103' MD Top Tieback 14,71r" Cemerd Retainer @ 15f Lost fish 15768 MD to 16048 MD Navigator 2-7/8' Hallibunon SSSV at 2' 30' A-36 200 TVD 150 # Welded 200 MD 2-7/8' chemical injection mandrel at ±2,500' 13 318" L-80 3024 TVD 68 # OTC 3507 MO 2.718" WXO Sliding Sleeve @ 7,578' 95/8' x 2-7/8' Weatherford Hydrow I hydraulic -set packer @ 7,614' 2-719" Sidling Sleeve @ 7,754' Perforations 7780'-7800 & 78OV-7818' MD' MD 9518" L-80 7416TVD 47 # OTC 9332 MD 2.718" XN-nippto @ 14,751- 7-5/8' x 2-71W Weatherford Hydrow 1 hydraulic set packer @14,700' W L ReEntry Guide at 14.791' New 3 3!8" 6SPF Mlllenium TCP Perforations - 14.803' MD-14,860' MD Old Perforations 14,803 MD-14,860' MD Back to Toc 75/8' L-80 119811VD 29.7 # Hydril 521 15615 MD 5 117 L-80 13016 17 # Hydril 621 16940 MD . Well Name & Number. Redone urns 1Lease County or Parish: Peninsula Borough State/Prov. Alaska Coup . USA Perfora8ona: MD An Ie/Perfs Angle @KOP and Depth 0 KOP TVD F 2W BHP: 0 BHT: Completion Fluid: FWHP: FBHP: 0 FWHT: FBHT: Other Date Completed: RKB: P ed O : Rob Stinson Last Revision Date: 11/26102 Rig #35 Schematic (RAN DRILLING RIG ARPtANGEMENT APPINNAL W - EAST SIDE VGDRHLI'Sot�.o. OSPRLY ORILLNG RJU Wellhead Schematic I2 G➢:C +: 2Y: L(� jrj`!F 1t4! hF� glttl.c M "tr d--tlb FD% u 2Y, K/A(i. i y_,/r to .." cwem" Ikt *1-*X Wellhead Schematic 3-9/E rim v; 2x 1/7•IF '±YI 'h'JYU.L JJti ft �.d>r vox 3-1/8 'Mm, N: 4D A/F11.f pow RSG 3 1/o U7oo t 1 E49 ( ia.sJr �xt so. ( • wary Pray LSM NN sm a-Itz CD P14-6 Y-1/IE op 13. EMU Gw Dl t 4 Y4ie 1Y3i �. 71If 10 SO• i v-1,AY OD OREM 5--fY LU Tate-`P3 a Chwo ALL OWMM" ME AFOO SYSTSYIS IICGIl�@IIiG _ __ � 3- 3 X 4-5/A X 3-1 f9 :Hl Ci cthO h I�ULlfBSUt #`EY ;w=j ;.;. PRCDUMt WELL kgM < 2F 3w srpt t.N W1'i -- � xwo mt . � S�.�Ci84-8a 1 _ . Cook Inlet Energy_ February 13, 2013 Ms. Cathy Foerster, Chair Alaska Oil and Gas Conservation Commission 333 West 70, Ave., Suite 100 Anchorage, Alaska 99501 Re: Sundry Application Cook Inlet Energy, LLC: Redoubt Unit #3 Permit to Drill No: 201-064 API No: 50-73320504-00 Dear Ms. Foerster, RECEIVED FEB 13 2013 ApGCC Cook Inlet Energy (CIE) hereby submits a Sundry Application Redoubt Unit #3 well located in Redoubt Shoal, Cook Inlet. Workover operations under previous Sundry Application #312-358 failed to bring the well on. CIE requests permission to flare test RU#3 in order to unload the water from the wellbore followed by conducting a four -point well test If you have any questions, please contact me at (907)-433-3804. Sincerely, David Hall CEO — Cook Inlet Energy 601 W. 5t' Avenue, Suite 310, Anchorage, AK 99501 (907) 334-6745 * (907) 334-6735 fax STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION FACILITY REPORT OF PRODUCED GAS DISPOSITION 1. Facility Number 1330000029 2. Facility Name Kustatan 3. Field Redoubt Unit 4. Operator Cook Inlet Energy,LLC 5. MonthNear of Disposition I Revised Mar-14 Disposition Volume MCF 20. For production from multiple pools, list contribution of each pool as a percent of Total Volume. 6. Sold 32,759 Pool Name Pool Code Percent 7. Reinjected Redoubt Shoal 720100 100% 8. Flared or vented 1 hour or less 1,007 9. Flared or vented more than 1 hour (see instr.) 205 10. Pilot and Purge 109 11. Assist Gas 12. Fuel gas used in lease operations. 39,886 13. Other (see instructions) Authorization >1 hr: Safety ^� p(d MCF 14. TOTAL VOLUME (ITEMS 6-13) 73,966 Lease Use MCF 15. NGL Gas Equivalent Conservation MCF 16, Purchased gas Waste: MCF 17. Transferred from: West Foreland 9,099 1 6 18, Transferred to: (Express as a negative #) Commissioner Date 19. Remarks: Transferred gas: (25,238 mcf of gas to generate power for WRMU usage & 7,521 mcf sold to Chugach Electric Association) I hereby certify that th of s true and correct to the best of my knowledge. Note: All volumes must be corrected Signature Title Production Manager to pressure of 14.65 psia and to a temperature of 60o F. Authority 20 Printed Name Shawn Dillon Phone 334-6745 Date S p/-i AAC25.235. 68114 Form 10-422 Rev. 5/2009 INSTRUCTIONS ON REVERE SIDE Submit in Duplicate Cook Inlet Energy_ Excess Flare Log Facility Name Kustatan Production Facility Use (Military form for time logs Mar-14 Date & Time Begin End Event Gas MCF Planned I Description of Incident Category Reason Actions Taken I Steps Taken to Minimize Recurrence E Equipment 3-01-14 20:00 3-01-14 22:00 205 No 2 hour Power outage Liquid slug fuel gas scrubber. Re -start Dry out pipeline. Solar B Flare Total for Month 205 Flare_Log.As Page 1 STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION FACILITY REPORT OF PRODUCED GAS DISPOSITION 1. Facility Number 1330000029 2. Facility Name Kustatan 3. Field Redoubt Unit 4. Operator Cook Inlet Energy, LLC 5. MonthNear of Disposition Nov-13 Disposition Volume MCF 20. For production from multiple pools, list contribution of each pool as a percent of Total Volume. 6. Sold 18,661 Pool Name Pool Code Percent 7. Reinjected Redoubt Shoal 720100 100% 8. Flared or vented 1 hour or less 3,160 9. Flared or vented more than 1 hour (see instr.) 519 10. Pilot and Purge 106 11. Assist Gas 12. Fuel gas used in lease operations. 43,718 13. Other (see instructions) Official Use Onty Authorization >1 hr: Safety MCF 14. TOTAL VOLUME (ITEMS 6-13) 66,164 Lease Use MCF 15. NGL Gas Equivalent Conservation MCF 16. Purchased gas Waste: MCF Commissioner � Date 17. Transferred from: 18. Transferred to: (Express as a negative #) 19. Remarks: Transferred gas: (13,970 mcf of gas to generate power for WRMU usage & 4,691 mcf sold to Chugach Electric Association) I hereby certify that the foregoing is true and correct to the best of my knowledge. Note: All volumes must be corrected Signature d Title Chief Executive Officer to pressure of 14.65 psia and to a temperature of 60o F. Authority 20 Printed Name Davi all Phone 334-6745 Date l� AAC25.235. Form 10-422 Rev. 5/2009 INSTRUCTIONS ON REVERSE SIDE Submit in Duplicate Coak Inlet Energy_ Excess Flare Log Facility Name Kustatan Production Facility Use Militar f f]`._,F Nov-13 B DDate &Time End Event Gas MCF Planned Descri tion of Incident Cate o Reason Actions Taken Steps Taken to Minimize Recurrence Equipment 11-25-13 07:00 11-25-13 23:59 132 Yes Flaring gas that can't be used in order to swab RU-3. Excess gas. Gas line allowable pressure @ its maximum. Separator B & P V-168. 11-26-13 00:01 11-26-13 23:59 387 Yes Flaring gas that can't be used in order to swab RU-3. Excess gas. Gas line allowable pressure @its maximum. Separator B & P V-168. Flare Total for Month I519 Flare_Log.xls Page 1 STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION FACILITY REPORT OF PRODUCED GAS DISPOSITION 1. Facility Number 2. Facility Name 1330000029 Kustatan Disposition 3. Field Redoubt Unit Volume MCF 4. Operator 5. Month/Year of Disposition Cook Inlet Energy, LLC Dec-13 20. For production from multiple pools, list contribution of each pool as a percent of Total Volume. 6. Sold 16,627 Pool Name Pool Code Percent 7. Reinjected Redoubt Shoal 720100 100% 8. Flared or vented 1 hour or less 4-463 9. Flared or vented more than 1 hour (see instr.) / j ,' 1,013 10. Pilot and Purge 109 11. Assist Gas 12. Fuel gas used in lease operations. 38,310 13. Other (see instructions) Olflcial Use Only Authorization >1 hr Safety MCF 14. TOTAL VOLUME (ITEMS 6-13) 60,522 Lease Use MCF 15. NGL Gas Equivalent Conservation MCF 16. Purchased gas 2,596 Waste: MCF 17. Transferred from: Commissioner Uate 18. Transferred to: (Express as a negative #) 19. Remarks: Transferred gas: (16,627 mcf of gas to generate power for W RMU usage & -0- mcf sold to Chugach Electric Association) I hereby certify that the or oin true and correct to the best of my knowledge. // Note: All volumes must be corrected Signatur a/ l7 // Title Chief Executive Officer to pressure of 14.65 psia and to a temperature of 60o F. Authority 20 Printed Name David Hall Phone 334-6745 Date U / AAC25.235. Form 10-422 Rev. 5/2009 INSTRUCTIONS ON REVERSE SIDE Submit in Duplicate Cook inlet Energy Excess Flare Log Facility Name Kustatan Production Facility Use Military fc, rrn, ! ; ""'` Dec-13 Date & Time Be in End Event Gas MSCF Planned Description of Incident Category Reason Actions Taken Steps Taken to Minimize Recurrence E ui ment 11-30-13 12-01-13 Flaring gas that can't Begin selling g g Separator B & p 13:00 23:59 350 No be used in order to Excess gas. None excess gas V-168. swab RU-3. 12-02-13 12-02-13 Flaring gas that can't Begin selling g g Separator B & p 00:01 23:59 282 No be used in order to Excess gas. None excess gas V-168. unload RU-3. 12-03-13 12-03-13 Flaring gas that can't Begin selling Separator B & 00:01 23:59 185 No be used in order to Excess gas. None excess gas V-168. unload RU-3. 12-04-13 12-04-13 Flaring gas that can't Begin selling Separator B & 00:01 23:59 136 No be used in order to Excess gas. None excess gas V-168. unload RU-3. 12-05-13 12-05-13 Flaring gas that can't Begin selling Separator B & 00:01 23:59 77 No be used in order to Excess gas. None excess gas V-168. unload RU-3. 12-06-13 12-06-13 Flaring gas that can't Begin selling Separator B & 00:01 23:59 70 No be used in order to Excess gas. None excess gas V-168. unload RU-3. 12-07-13 12-07-13 Flaring gas that can't Begin selling Separator B & 111 No be used in order to Excess gas. None excess gas V-168. 00:01 23:59 swab RU-3. 12-08-13 12-08-13 Flaring gas that can't Begin selling Separator B & 52 No be used in order to Excess gas. None excess gas V-168. 00:01 23:59 unload RU-3. 12-09-13 12-09-13 Flaring gas that can't Begin selling Separator B & 32 No be used in order to Excess gas. None excess gas V-168. 00:01 23:59 unload RU-3. 12-10-13 12-10-13 Flaring gas that can't Begin selling Separator B & 57 No be used in order to Excess gas. None excess gas V-168. 00:01 23:59 unload RU-3. 12-11-13 12-11-13 Flaring gas that can't Begin selling Separator B & 27 No be used in order to Excess gas. None excess gas V-168. 00:01 23:59 unload RU-3. Flare_Log.xls Page 1 Date & Time Event Gas Steps Taken to Begin End MSCF Planned Description of Incident Category Reason Actions Taken Minimize Recurrence Equipment 12-12-13 12-12-13 Flaring gas that can't Be selling 9 9 Se arator B & Separator 00:01 23:59 10 No be used in order to Excess gas. None gas as V-168. unload RU-3. 12-13-13 12-13-13 Flaring gas that can't Be selling 9 9 Se arator B & Separator 00:01 23:59 3 No be used in order to Excess gas. None excess gas V-168. unload RU-3. 12-15-13 12-15-13 Flaring gas that can't In Be selling 9 9 Separator B & P 00:01 23:59 1 No be used in order to Excess gas. None excess gas V-168. unload RU-3. 12-16-13 12-16-13 Flaring gas that can't Be selling m g g Separator B & p 00:01 23:59 2 No be used in order to Excess gas. None gas as V-168. unload RU-3. 12-17-13 12-17-13 Flaring gas that can't Be selling m g g Separator B & p 00:01 23:59 4 No be used in order to Excess gas. None excess gas V-168. unload RU-3. 12-18-13 12-18-13 Flaring gas that can't Be selling Begin g g Separator B & P 00:01 23:59 4 No be used in order to Excess gas. None excess gas V-168. unload RU-3. 12-23-13 12-23-13 Flaring gas that can't Be selling m g g Separator B & 00:01 23:59 46 No be used in order to Excess gas. None excess gas V-168. unload 12-24-13 12-24-13 Flaring gas that can't Begin selling Separator B & 00:01 23:59 285 No be used in order to unload RU-3, Excess gas. None excess gas V-168. 12-25-13 12-25-13 Flaring gas that can't Be selling m g g Separator B & 00:01 23:59 414 No be used in order to Excess gas. None excess gas V-168. unload 12-26-13 12-26-13 Flaring gas that can't Begin selling g g Se arator B & P 00:01 23:59 349 No be used in order to Excess gas. None excess gas V-168. unload 12-27-13 12-27-13 Flaring gas that can't Begin selling Separator B & 00:01 23:59 402 No be used in order to Excess gas. None excess gas V-168. swab 12-28-13 12-28-13 Flaring gas that can't Begin selling Separator B & 00:01 23:59 456 No be used in order to Excess gas. None excess gas V-168. swab RU-3. 12-29-13 12-29-13 Flaring gas that can't Begin selling Separator B & 00:01 23:59 373 No be used in order to Excess gas. None excess gas V-168. w 12-30-13 12-30-13 Flaring gas that can't Begin selling Separator B & 00:01 23:59 352 No be used in order to Excess gas. None excess gas V-168. w -3. 12-31-13 12-31-13 Flaring gas that can't Begin selling Separator B & 00:01 23:59 383 No be used in order to Excess gas. None excess gas V-168. swab -I Flare_Log.xls Page 2 Date & Time Event Gas Steps Taken to Be in End I MSCF Planned Descri tion of Incident Category Reason Actions Taken Minimize Recurrence Equipment Flare Total for Month 1 4,463 Flare_Log.xls Page 3 STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION FACH ITY REPORT OF PRODUCED GAS DISPOSITION 1. Facility Number 2. Facility Name 1330000029 Kustatan Disposition 3. Field Redoubt Unit Volume MCF 4. Operator 5. Month/Year of Disposition Cook Inlet Energy, LLC Jan-14 20. For production from multiple pools, list contribution of each pool as a percent of Total Volume 6. Sold 17,841 Pool Name Pool Code Percent 7. Reinjected Redoubt Shoal 720100 100% 8. Flared or vented 1 hour or less 1,008 9. Flared or vented more than 1 hour (see instr.) 14,355 10. Pilot and Purge 109 11. Assist Gas 12. Fuel gas used in lease operations. 29,862 13. Other (see instructions) Official Use Only Authorization >1 hr: Safety MCF 14. TOTAL VOLUME (ITEMS 6-13) 63,175 Lease Use MCF 15. NGL Gas Equivalent Conservation - MCF 16. Purchased gas 393 Waste: MCF 17. Transferred from: � ...... ..,,,,,,.,, Date ' 18. Transferred to: (Express as a negative #) 19. Remarks: Transferred gas: (16,243 mcf of gas to generate power for WRMU usage & 1,598 mcf sold to Chugach Electric Association) I hereby certify that the foregoinq9l is truepnd correct to the best of my knowledge. /'7 / Note: All volumes must be corrected Signature Title Production Manager to pressure of 14.65 psia and to a temperature of 60o F. Authority 20 Printed Name Shawn Dillon Phone 334-6745 Date _ - AAC25.235. Form 10-422 Rev. 5/2009 INSTRUCTIONS ON REVERSE SIDE Submit in Duplicate Cook Inlet Energy_ Excess Flare Log Facility Name Kustatan Production Facility Use Military fon�-rr °� ��It' 2f f "�% Jan-14 Date & Time Event Gas Steps Taken to Be in End MSCF Planned Description of Incident Category Reason Actions Taken Minimize Recurrence E ui ment 1-1-14 Flaring gas that can't be Begin selling g 9 Separator B p 00:01 00:01 23:59 463 No used in order to Excess gas. None excess gas & V-168. blowdown RU-3. 1-2-14 Flaring gas that can't be Begin selling g 9 Separator B p 00:01 00:01 23:59 439 No used in order to Excess gas. None excess gas & V-168. blowdown RU-3. 1-3-14 Flaring gas that can't be Begin selling 9 9 Separator B p 00:01 00:01 23:59 467 No used in order to Excess gas. None excess gas &V-168. blowdown RU-3. 1-4- Flaring gas that can't be Begin selling 9 9 Separator B p 00:01 00:01 9 23:59 525 No used in order to Excess gas. None excess gas & V-168. blowdown RU-3. 1-5- Flaring gas that can't be Begin selling 9 9 Separator B p 00:01 00:01 9 23:59 511 No used in order to Excess gas. None excess gas 8 V-168. blowdown RU-3. 1-6-14 Flaring gas that can't be Begin selling 9 g Separator B p 00:01 00:01 23:59 515 No used in order to Excess gas. None excess gas & V-168. blowdown RU-3. 1-7- Flaring gas that can't be Begin selling 9 9 Separator B p 00:01 00:01 9 23:59 578 No used in order to Excess gas. None excess gas &V-168. blowdown RU-3. 1-8-14 1-8-14 Flaring gas that can't be Begin selling Separator B 00:01 23:59 396 No used in order to Excess gas. None excess gas &V-168. blowdown RU-3. 1-9- Flaring gas that can't be Begin selling 9 9 Separator B p 00:01 00:01 9 23:59 470 No used in order to Excess gas. None excess gas & V-168. blowdown RU-3. 1-10-14 1-1 Flaring gas that can't be in Be selling 9 9 Separator B p 00:01 23:5599 422 No used in order to Excess gas. None excess gas &V-168. blowdown RU-3. Flare_Log.xls Page 1 Date & Time Event Gas Steps Taken to Begin End MSCF Planned Description of Incident Category Reason Actions Taken Minimize Recurrence Equipment 1-11-14 1-11 Flaring gas that can't be m Be selling g g Separator B p 00:01 23:599 496 No used in order to Excess gas. None excess gas & V-168. blowdown RU-3. 1 1-1 Flaring gas that can't be Begin selling 9 g Separator B p 0:014 00:01 23:59 59 341 No used in order to Excess gas. None excess gas & V-168. blowdown RU-3. 1-1 123:59 Flaring gas that can't be Begin selling 9 9 Separator B p 014 00:01 23:59 377 No used in order to Excess gas. None excess gas & V-168. blowdown RU-3. 100: 14 1-1 Flaring gas that can't be Begin selling 9 9 Separator B p 00:01 59 23:59 404 No used in order to Excess gas. None excess gas & V-168. blowdown RU-3. 1-1 1-15 Flaring gas that can't be in Be selling g g Separator B p 00:0011 23:599 410 No used in order to Excess gas. None excess gas & V-168. blowdown RU-3. 1-16-14 1-16-14 Flaring gas that can't be Begin selling Separator B 00:01 23:59 434 No used in order to Excess gas. None excess gas & V-168. blowdown RU-3. 1-17-14 1-17-14 ng gas that can't be Flaring Be in sellin 9 9 Se arator B p 00:01 23:59 549 No used in order to Excess gas. None excess gas & V-168. blowdown RU-3. 100: 14 1-1 Flaring gas that can't be Begin selling 9 9 Separator B p 00:01 59 23:59 381 No used in order to Excess gas. None excess gas & V-168. blowdown RU-3. 1-1 123:59 Flaring gas that can't be Begin selling 9 9 Separator B p 014 00:01 23:59 316 No used in order to Excess gas. None excess gas & V-168. blowdown RU-3. 1-20-14 1-2 Flaring gas that can't be Begin selling 9 g Separator B p 00:01 23:59 59 347 No used in order to Excess gas. None excess gas & V-168. blowdown RU-3. 1-21-14 1-21-14 Flaring gas that can't be Begin selling Separator B 00:01 23:59 474 No used in order to Excess gas. None excess gas & V-168. blowdown RU-3. 1-22-14 1-22-14 Flaring gas that can't be Begin selling Separator B 00:01 23:59 534 No used in order to Excess gas. None excess gas & V-168. blowdown RU-3. 1-23-14 1-23-14 Flaring gas that can't be Begin selling Separator B 00:01 23:59 478 No used in order to Excess gas. None excess gas & V-168. blowdown RU-3. Flare_Log.xls Page 2 Date & Time Event Gas Steps Taken to Begin End MSCF Planned Description of Incident Category Reason Actions Taken Minimize Recurrence Equipment 1-24-14 1-24-14 Flaring gas that can't be Begin selling Separator B 475 No used in order to Excess gas. None 00:01 23:59 blowdown RU-3. excess gas & V-168. 1-25-14 1-25-14 Flaring gas that can't be Begin selling Separator B 493 No used in order to Excess gas. None 00:01 23:59 blowdown RU-3. excess gas & V-168. 1-26-14 1-26-14 Flaring gas that can't be Begin selling Separator B 463 No used in order to Excess gas. None 00:01 23:59 blowdown RU-3. excess gas & V-168. 1-27-14 1-27-14 Flaring gas that can't be Begin selling Separator B 485 No used in order to Excess gas. None 00:01 23:59 blowdown RU-3. excess gas & V-168. 1-28-14 1-28-14 Flaring gas that can't be Begin selling Separator B 593 No used in order to Excess gas. None 00:01 23:59 blowdown RU-3. excess gas & V-168. 1-29-14 1-29-14 Flaring gas that can't be Begin selling Separator B 524 No used in order to Excess gas. None 00:01 23:59 blowdown RU-3. excess gas & V-168. 1-30-14 1-30-14 Flaring gas that can't be Begin selling Separator B 524 No used in order to Excess gas. None 00:01 23:59 blowdown RU-3. excess gas & V-168. 1-31-14 1-31-14 Flaring gas that can't be Begin selling Separator B 00:01 23:59 471 No used in order to Excess gas. None excess gas & V-168. blowdown RU-3. Flare Total for Month I 14�355 Flare_Log.xls Page 3 STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION FACILITY REPORT OF PRODUCED GAS DISPOSITION 1. Facility Number 1330000029 Facility Name 2. Kustatan 3. Field Redoubt Unit 4. Operator Cook Inlet Energy, LLC 5. Month/Year of Disposition Feb-14 Disposition Volume MCF 20. For production from multiple pools, list contribution of each pool as a percent of Total Volume. 6. Sold 26,623 Pool Name Pool Code Percent 7. Reinjected Redoubt Shoal 720100 100% 8. Flared or vented 1 hour or less 909 9. Flared or vented more than 1 hour (see instr.) 10. Pilot and Purge 99 11. Assist Gas 12. Fuel gas used in lease operations. 41,364 13. Other (see instructions) Official Use Only Authorization >1 hr: Safety MCF + 14. TOTAL VOLUME (ITEMS 6-13) 75,694 Lease Use MCF 15. NGL Gas Equivalent Conservation MCF 16. Purchased gas Waste: MCF 17. Transferred from: _ Commissioner Dace 18. Transferred to: (Express as a negative #) 19. Remarks: Transferred gas: (23,308 mcf of gas to generate power for W RMU usage & 3,315 mcf sold to Chugach Electric Association) I hereby certify that the foregoing is nd correct to the best of my knowledge. Note: All volumes must be corrected Signature Title Production Manager to pressure of 14.65 psia and to a temperature of 60o F. Authority 20 Printed Name Shawn Dillon Phone 334-6745 Date AAC25.235. Form 10-422 Rev. 5/2009 INSTRUCTIONS ON REVERSE SIDE Submit in Duplicate Cook Inlet Energy_ Excess Flare Log Facility Name Kustatan Production Facility Use Military Feb-14 Date & Time Be in End Event Gas MSCF Planned Description of Incident Category Reason Actions Taken Steps Taken to Minimize Recurrence Equipment 2-1-14 2-1-14 Flaring gas that can't Begin selling Separator B 00:01 23:59 471 No be used in order to Excess gas. None excess gas & V-168. blowdown RU-3. 2-2-14 2-2-14 Flaring gas that can't Begin selling Separator B 00:01 23:59 499 No be used in order to Excess gas. None excess gas & V-168. blowdown RU-3. 2-3-14 2-3-14 Flaring gas that can't Begin selling Separator B 00:01 23:59 432 No be used in order to Excess gas. None excess gas & V-168. blowdown RU-3. 2-4-14 2-4-14 Flaring gas that can't Begin selling Separator B 00:01 23:59 45 No be used in order to Excess gas. None excess gas & V-168. blowdown RU-3. 2-5-14 2-5-14 Flaring gas that can't Begin selling Separator B 00:01 23:59 419 No be used in order to Excess gas. None excess gas & V-168. blowdown RU-3. 2-6-14 2-6-14 Flaring gas that can't Begin selling Separator B 00:01 23:59 39 No be used in order to Excess gas. None excess gas & V-168. blowdown RU-3. 2-7-14 2-7-14 Flaring gas that can't Begin selling Separator B 286 No be used in order to Excess gas. None excess gas & V-168. 00:01 23:59 blowdown RU-3. 2-8-14 2-8-14 Flaring gas that can't Begin selling Separator B 00:01 23:59 403 No be used in order to Excess gas. None excess gas & V-168. blowdown RU-3. 2-9-14 2-9-14 Flaring gas that can't Begin selling Separator B 00:01 23:59 249 No be used in order to Excess gas. None excess gas & V-168. blowdown RU-3. 2-10-14 2-10-14 Flaring gas that can't Begin selling Separator B 00:01 23:59 352 No be used in order to Excess gas. None excess gas & V-168. blowdown RU-3. Flare_Log.xls Page 1 Date & Time Begin End Event Gas MSCF Planned Description of Incident Cateaory Reason Actions Taken Steps Taken to Minimize Recurrence E ui ment Flaring gas that can't Begin selling Separator B 2-11-14 2-11-14 334 No be used in order to Excess gas. None excess gas & V-168. 00:01 23:59 blowdown RU-3. 2-12-14 2-12-14 Flaring gas that can't Begin selling Separator B 286 No be used in order to Excess gas. None excess gas & V-168. 00:01 23:59 blowdown RU-3. Flaring gas that can't Begin selling Separator B 2-13-14 2-13-14 282 No be used in order to Excess gas. None excess gas & V-168. 00:01 23:59 blowdown RU-3. Flaring gas that can't Begin selling Separator B 2-14-14 2-14-14 178 No be used in order to Excess gas. None excess gas & V-168. 00:01 23:59 blowdown RU-3. 2-15-14 2-15-14 Flaring gas that can't Begin selling Separator B 34 No be used in order to Excess gas. None excess gas & V-168. 00:01 23:59 blowdown RU-3. 2-16-14 2-16-14 Flaring gas that can't Begin selling Separator B 31 No be used in order to Excess gas. None excess gas & V-168. 00:01 23:59 blowdown RU-3. 2-17-14 2-17-14 Flaring gas that can't Begin selling Separator B 307 No be used in order to Excess gas. None excess gas & V-168. 00:01 23:59 blowdown RU-3. 2-18-14 2-18-14 Flaring gas that can't Begin selling Separator B 297 No be used in order to Excess gas. None excess gas & V-168. 00:01 23:59 blowdown RU-3. Flaring gas that can't Begin selling Separator B 2-19-14 2-19-14 198 No be used in order to Excess gas. None excess gas & V-168. 00:01 23:59 blowdown RU-3. Flaring gas that can't Begin selling Separator B 2-20-14 2-20-14 97 No be used in order to Excess gas. None excess gas & V-168. 00:01 23:59 blowdown RU-3. Flaring gas that can't Begin selling Separator B 2-21-14 2-21-14 15 No be used in order to Excess gas. None excess gas & V-168. 00:01 23:59 blowdown RU-3. Flaring gas that can't Begin selling Separator B 2-22-14 2-22-14 23 No be used in order to Excess gas. None excess gas & V-168. 00:01 23:59 blowdown RU-3. Flaring gas that can't Begin selling Separator B 2-23-14 2-23-14 17 No be used in order to Excess gas. None excess gas & V-168. 00:01 23:59 blowdown RU-3. Flare_Log.xls Page 2 Date &Time Begin End Event Gas MSCF Planned Description of Incident Cate o Reason Actions Taken Steps Taken to Minimize Recurrence Equipment 2-24-14 2-24-14 Flaring gas that can't Begin selling Separator B 00:01 23:59 12 No be used in order to Excess gas. None excess gas & V-168. blowdown RU-3. 2-25-14 2-25-14 Flaring gas that can't Begin selling Separator B 00:01 23:59 4 No be used in order to Excess gas. None excess gas & V-168. blowdown RU-3. 2-26-14 2-26-14 Flaring gas that can't Begin selling Separator B 00:01 23:59 5 No be used in order to Excess gas. None excess gas & V-168. blowdown RU-3. 2-27-14 2-27-14 Flaring gas that can't Begin selling Separator B 00:01 23:59 13 No be used in order to Excess gas. None excess gas & V-168. blowdown RU-3. 2-28-14 2-28-14 Flaring gas that can't Begin selling Separator B 00:01 23:59 3 No be used in order to Excess gas. None excess gas $ V-168. blowdown RU-3. Flare Total for Month 5,331 Flare_Log.xls Page 3