STATE OF ALASKA

ALASKA OIL AND GAS CONSERVATION COMMISSION

333 West Seventh Avenue, Suite 100

Anchorage Alaska 99501

Re:

Rule Establishing a Blow Out Prevention Equipment Pressure Test Interval of Fourteen Days Applicable to Drilling and Completion Operations within the Lisburne Oil Pool

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Conservation Order No. 517.000

Prudhoe Bay Field: Lisburne Oil Pool

April 7, 2004

IT APPEARING THAT:

1. On its own motion, the Alaska Oil and Gas Conservation Commission (“Commission” or “AOGCC”) proposed to establish a blow out prevention equipment (“BOPE”) test interval of fourteen days applicable to drilling and completion operations within the Lisburne Oil Pool (“LOP”).

2. Notice of opportunity for a public hearing on the proposal was published in the Anchorage Daily News on February 24, 2004 and was provided to the pool operator, BP Exploration (Alaska) Inc. (“BPXA”).

3. The Commission received no request for a hearing.

4. The Commission received no written comments on the proposal.

FINDINGS:

1. AOGCC regulations 20 AAC 25.035 (e) (10) (A) and 20 AAC 25.036 (d) (1) require that BOPE in use during drilling and completion operations be function pressure tested at least once per week.

2. Information obtained during drilling of more than 2000 wells within the Prudhoe Bay Field provides the operator with a high level of geologic control. This knowledge allows the LOP operator to predict subsurface pressures with a high degree of certainty.

3. Commission inspectors witness a sufficient number of the subject pool’s BOPE tests to confirm that the Commission’s test data is reasonably representative of actual BOPE operating performance.

4. Based on testing records on file in the Commission offices, BOPE on typical drilling rigs in use within the LOP is highly reliable.

5. U.S. Bureau of Land Management (“BLM”) regulations (43 CFR 3160) require BOPE pressure testing on thirty day time intervals, and weekly BOPE function testing of annular components.

6. U.S. Minerals Management Service (“MMS”) regulations (30 CFR 250) require BOPE pressure testing on fourteen day time intervals, and weekly BOPE function testing of ram and annular components.

7. Norwegian Petroleum Safety Authority (“PSA”) regulations (Chapter II, Section 48) require BOPE pressure testing on fourteen day time intervals, and weekly BOPE function testing.

8. Information recorded by the LOP operator on their daily drilling operations reports indicates that the operator typically spends approximately four to eight hours performing each BOPE test.

CONCLUSIONS:

1. There is a relatively low probability of subsurface pressure related well control events during drilling and completion operations in the LOP.

2. BOPE performance in the LOP will not be degraded by a fourteen day pressure test interval and a weekly function test interval.

3. Well control during drilling and completion operations within the LOP can be maintained if BOPE is pressure tested on fourteen day time intervals and function tested weekly.

4. A fourteen day BOPE pressure test interval and weekly function testing will improve LOP drilling and completion operating efficiency, and may enhance LOP resource development.

5. A fourteen day BOPE pressure test interval, with a weekly BOPE function test, is consistent with similar requirements of other regulatory agencies.

NOW, THEREFORE, IT IS ORDERED: that Conservation Order No. 207 is amended to add the following rule:

Blow out prevention equipment (“BOPE”) in use during drilling and completion operations must be pressure tested when installed, repaired, or changed, and at time intervals not to exceed fourteen days thereafter, unless the Commission determines that weekly BOPE pressure test interval is indicated by a particular drilling rig’s BOPE test performance. Weekly BOPE function tests must be performed on ram and annular components, except blind rams which must be function tested at least every thirty days.

By Order of the Commission at Anchorage, Alaska, this 7th day April 2004.

John K. Norman, Chair
Alaska Oil and Gas Conservation Commission

Daniel T. Seamount, Jr., Commissioner
Alaska Oil and Gas Conservation Commission


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