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Home My WebLink AboutO 159�':7L CF L SM DEPARTMENT OF LAW OFFICE OF THE ATTORNEY 6ENERAI April 3, 1978 Howard A. Slack, Vice President & Resident Manager Atlantic Richfield Company P.O. Box 360 Anchorage, Alaska 99510 Dear Mr. Slack: / 14 r S. HAMMOND, GOVERNOR 360 N START — SUITE 105 ANCNORARE 99501 The Department of Natural Resources, Division of Oil and Gas Conservation, has reported that there has been a violation of 11 AAC 22.005 which requires that an opera- tor of an oil and gas well secure a drilling permit prior to drilling or deepening of any well. Atlantic Richfield Company spudded and started drilling on Well DS4, Number 13� in the Prudhoe Bay field without a permit. The operator commenced drilling approximately three days before a permit was issued by the Oil and Gas Conservation Committee. Al- though we are convinced that the infraction was not inten- tional, this is the second time that ARCO has violated 11 AAC 22.005 and the Oil and Gas Conservation Committee has recommended that action be initiated to collect a fine from ARCO pursuant to AS 31.05.150. That provision pro- vides that a person who willfully violates a provision of AS 31.05 is subject to a penalty of not more than $1,000.00 for each act of violation and for each day that the viola- tion continues. The oil and Gas Conservation Committee has recom- mended that efforts be made to collect the penalty from you equivalent to about 258 of the maximum penalty -to which ARCO could be subjected for willful violation. In this case, the well operations were carried on for approximately two days and 17 hours. A $1,000.00 per day penalty rate would equal approximately $2,710.00. A 258 penalty would amount to $678.00 which the Committee has rounded off to $700.00. The Oil and Gas Conservation Committee is willing to accept $700.00 from ARCO in this matter as full penalty payment if ARCO gives assurance that they will inaugurate. -:..E-,;,>,•, procedures to prevent similar occurrences from happenin again. A "JIJ 4 'J _,%'d 0`nsiea C1 U; s::o e_, _J;M'rv.:UUl! Mr. Howard A. Slack -2- April 3, 1978 Although the Oil and Gas Conservation Committee is convinced that the infraction was not intentional, this is the second time that it has happened despite a March 10, 1976 communication from you indicating that necessary steps were taken to revamp ARCO's procedure to assure that simi- lar occurrences would not happen again. If i may be of any assistance in this matter please do not hesitate to contact me. Should you decide to pay the penalty of $700.00, payment should be made through this office and any checks submitted should be made out to the State of Alaska. Once again, please do not hesitate to contact me if you have any questions about this matter. Very truly yours, AVRUM U+. GRASS ATTORNEY GENERAL. % By: Jeffrey B. Lowenfels Assistant Attorney General is L JBL:tb cc: O. K. Gilbreath, Jr., Director Alaska State Division of Oil and Gas 3001 Porcupine Anchorage, Alaska 99501 Fred Boness, Deputy Commissioner Department of Natural Resources Pouch M Juneau, Alaska 99811 FIDS I 'lie H. Hamilton -10V Chef Petroleum EMineer March 30, 1978 ARCA Well DS4-13 Srmdded Without. Pernii t, Ben. Le Nonan called from Prudhoe Bay at 9:15AM today. He reported that well DS 4-13 was spudded at 4:30 PM Sunday 03/26/78. The drilling permit was approved for the well at 9:30 AM Wednesday 03/29/78. Calculation of possible malty for drilling without a permit. 4:30 PM 03/26/78 to 9:30 AM 03/29/78 = 2 days 17 hours or 2.71 days. Max Penalty = 2.71 days X $1,000.00/day = $2,710.00. .25 X $2,710.00 = $678.00 or approximately $ 700.00. Conservation March 29, 1978 Be: prudhos Bay unit Ds 4-13 Atlantic Richfield Company permit No. 79-31 Frank M. Brown District Drilling &Kjineer Atlantic Richfield Cosy p. O. Box 360 Anchorage, Alaska 99510 Dear Sirc Enclosed is the approved application for permit to drill the above- referenced bovereferenced well at a location in Sectio 34, T06mship 11^], Rmwe 15F, TTI. %all samples, core chips and a nail log are not recused. A directional survey is required. "may rivers in Alaska and their drainage systems have been classified as irportant for the spamming or migration of anadremus fish. aerations in these areas are subject to AS 16.50.870 and the regulations Pmrulgatexl thereunder (Title 5, Alaska Administrative Code). Prior to arrencing operations yoti may be contacted by the 71abitat Coordinator's office, Departmzt of Fish and fame. Pollution of any waters of the State is prohibited by AS ,,6, cJapter 03, Article 7 arca the regulations promulgated thereunder (Title 18, Alaska Xldnistrative Code, Chapter 70) and by the Federal Water pollution Control Act, as amn3ed. prior to arrencing operations you may to contacted by a representative Of the Department of, IInriramental Conservation. pursuant to AS 38.40, Local Elise tlncler State Leases, the Alaska Depart2!ent of Labor is being notified of the issuance of this permit to drill. To aid us in scheduling field work, wn would appreciate your notifying this office within 48 hours after the viell is spudded. We could also like to i -e notified so that a representative of the Division may be present to Tdtness testing of bloout prev,enter ecpAprent before mnface casing sloe is drilled.