AOGCC proposes changes to workover rules, reporting

Lists of planned workovers weren’t used by commission, will be eliminated, replaced with weekly reports of work done

Kristen Nelson

Petroleum News Editor-in-Chief

The Alaska Oil and Gas Conservation Commission is working on changes to its rules for reporting development well workovers.

Commission Chairman John Norman said at a Jan. 4 public hearing that the commission has been reviewing the reports it requires to “determine those reports that are necessary and to also determine if any reports or paperwork” required by the commission are “no longer useful to the commission” and to see about eliminating any that aren’t useful.

One area identified for review was workovers, and commission staff worked on this area with industry representatives.

The intent “was to update and revise orders that had been issued by the commission pertaining to operations generally known as workovers,” commission senior reservoir engineer Tom Maunder said at the hearing. Workovers, he said, include activities such as “a major entry into a well bore, or minor other activities that could be likened to changing the oil or checking the oil in an automobile.”

The commission waived requirements for pre-approvals for workovers in conservation orders for fields issued beginning in 1990, Maunder said, but those waivers were not extended as new pools were added at some fields, so there is inconsistency in requirements for pre-approvals for workovers.

Task force established

The task force developed two task matrices, he said, one for production wells and one for injection wells. The proposed changes in the commission’s conservation orders would apply the same standards to all fields in the state.

“By putting this task matrix out there, to be used by the operator, it literally puts everybody on the same page as to requirements of what activities they need to seek approval on and any follow-up reports that are necessary.”

There may be some increased paperwork, Maunder said, but the proposed changes provide “a consistent approach across the major oil fields in the state.”

Report also changed

The report required now is a list of workover operations planned for the following week. The new report will be a list of workovers done in the prior week. The planned work list wasn’t useful, he said, because plans often changed and some workover operations were deferred.

The new report, a list of completed work, would be useful to the commission in its compliance effort, he said, because it could be used to verify that required follow-up reports had been received.

Commissioner Dan Seamount asked Maunder about the potential for increased paperwork, and Maunder said there was mention in the task force that there would be some increase in paperwork. The goal, he said, “is to make sure we were getting the reports that were required and to grant the relief on the additional fields” where conservation orders do not grant waivers.

Seamount asked what the new weekly reports would include, and Maunder said samples he has seen include well identification, work performed, if a sundry approval was required prior to the work and what follow-up report was required.

Any paperwork increase hard to quantify in advance

On the potential for increase in paperwork, it is tough for industry to quantify any increase now, Engle said. Industry would like to see the process work for a while and then “evaluate any increases” that result from the changes, he said, and come back to the commission if there are problems.

Seamount also asked about required follow-up reports for workovers requiring approvals. As the commission looked at its records, he said, it found that required workover reports weren’t always received within 30 days as required, and asked Engle if he thought the proposed changes would solve the issue of late reports.

Engle said requirements for reports had evolved over the years and said the task force effort has clarified “what activities need reports to be filed” and when.

Will paperwork increase?

Engle said there may be more paperwork required for work in the field, but he didn’t think it would be significant. He suggested the task force continue on and evaluate any increases at a later date.

Norman asked Maunder if anything in the changes would lessen safety or protection against waste. Maunder said no. In fact, Maunder said, alteration of casing in a workover operation will require pre-approval from the commission under the proposed changes. This had been waived from pre-approvals in the conservation orders that are being amended, he said. “In looking at events that have happened in the last couple of years where casings have been compromised,” this type of workover was changed to require pre-approval. This will require more paperwork, he said, but he said this type of work isn’t a frequent occurrence.

Norman said the record will be left open for two weeks for any additional comments and said he anticipates that following closing of the record the commission will act on the proposal. He said the commission would revisit the issue if necessary, but said the commission would “expect full compliance” as soon as the changes are adopted.

“If for any reason full compliance proves to be impractical, then we will expect you to contact the commission immediately,” Norman said, and the commission will take another look at the requirements.