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AOGCC clarifies 2 points in Alpine order
ConocoPhillips responded to June 28 investigative findings, notice of proposed enforcement, did not request review or hearing Kristen Nelson Petroleum News
The Alaska Oil and Gas Conservation Commission has issued a decision and order on the natural gas release at ConocoPhillips Alaska's Colville River unit in March 2022. This follows its June 28 investigation findings and notice of proposed enforcement action. The company had 15 days to respond to the findings and notice by concurring in whole or in part, requesting an informal review or requesting a hearing.
The commission said in its July 19 decision and order that ConocoPhillips responded to the finding and proposed action on July 13, addressing two factual findings which it said AOGCC "may wish to clarify."
The company did not request an informal review or a hearing. It did not dispute the findings -- other than the proposed clarifications -- "and did not dispute the proposed penalty," AOGCC said.
That penalty is a civil penalty of $913,796.80, which, the commission said, is to be paid within 10 days of the final decision.
ConocoPhillips made two requests for clarification of the commission's factual findings, both of which AOGCC accepted.
The company said that on page 5, the notice said "CPAI failed to confine the C10/Halo to the wellbore" for 66 days beginning Feb. 24, 2022, and ending May 1, 2022.
AOGCC said in its decision and order that the notice should have been more specific: the company failed to confine C10/Halo to the wellbore with cement, and said the relevant sentence on page 5 of the notice has been corrected to read:
"During this time, CPAI failed to confine the C10/Halo to the wellbore with cement, to prevent migration of fluids from one stratum to another and to protect significant hydrocarbon zones with is a violation of 20 AAC 25.030." The words "with cement" have been added.
On page 8 the notice included a reference to criterion related to well control until the next casing is set. The commission said that criterion should not have been included in the violation finding, and the relevant sentence has been corrected to eliminate that reference.
Subsurface blowout In its June 28 investigation findings the commission said the incident was initially described as a gas release "because the cause of the release and the source of the gas, was not immediately known," but said it has concluded upon investigation "that the CD1 gas release was in fact a shallow underground blowout of the WD-03 well due to the uncontrolled nature of the event and because gas breached the surface at multiple locations."
In its list of violations AOGCC said ConocoPhillips did not cement the C10/Halo interval because historically that interval "was not a significant hydrocarbon-bearing zone or abnormally geo-pressured." The company has refined its evaluation methods to provide more confidence "that significant hydrocarbon zones will be identified while planning and conducting future drilling operations."
The commission also said the company's drilling plan was not followed and freeze protection fluids were pumped into the well at a higher pressure than the not-to-be-exceeded pressure specified in the plan.
AOGCC said ConocoPhillips has revised its standard operating procedure for freeze protection "to include procedures, pressure limits, and contingent solutions, where pumping operations reach limits."
(See story on investigation findings in July 2 issue of Petroleum News.)
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