AOGCC wants industry-wide work group on technical safety issues

Commission accepts safety valve management system, quarterly reports, as plan to resolve BP’s safety valve testing problems at Prudhoe

Kristen Nelson

PNA Editor-in-Chief

The Alaska Oil and Gas Conservation Commission has accepted BP Exploration (Alaska) Inc.’s safety valve management system and quarterly reports as a plan to resolve safety valve testing problems the company has been having at Prudhoe Bay.

But the commission also wants a technical working group including other operators to look at these issues and report back to the commission.

BP responded March 1 to a Feb. 14 review by the commission of safety valve system problems in the western operating area. (See story in Feb. 24 issue of PNA.) Representatives of the company answered questions from the commission March 6.

The commission issued BP a performance enforcement action on Prudhoe Bay safety valve system performance March 8, saying it believes BP’s proposed safety valve management system “is an effective plan to ensure compliance with AOGCC conservation orders and regulations associated with safety valve system performance.”

The commission said that BP’s safety valve management system provides safety valve system performance monitoring; roles and responsibilities of personnel involved with safety valve system testing and maintenance; a means to inform field personnel and management about safety valve system performance; and a decision tree for implementing correction action when safety valve system failures occur.

March 6 the commission said it wants to establish a technical working group with representatives from all Alaska operators which would follow up on technical issues.

Commission Chair Cammy Taylor told BP that she would like to have the Alaska Oil and Gas Association involved in the technical working group.

Taylor told PNA that the commission has used AOGA in the past to coordinate meeting with oil and gas operators.

“What we’d like to have is a working group of all the interested parties, everybody who’s going to be affected, so that they can review all the old standards and policies to make sure that we’re responding appropriately. Not just building on things that have been done in the past,” she said.

The commission is looking at the situation on the North Slope right now, “but it’s fair to look at general standards statewide,” Taylor said.

“And that’s something that should be done at a working group level and then when there are recommendations the commission can take them up either as regulations or as specific rules for conservation orders.”

BP told the commission March 6 that the safety valve management system will address communications problems which kept the company’s management unaware of problems with testing. Prior to early last year said Chris Phillips, vice president and operations integrity manager, the company’s reporting system did not flag to more senior levels of management that there was a problem. Today, he said, the Prudhoe Bay field manager knows the failure rates.

BP said the safety valve management system was developed last year in response to concerns about safety valve system failure rates, and is designed to ensure that Greater Prudhoe Bay safety valve systems are functioning properly.

Three areas have been enhanced in the last half year, BP said: Work orders are generated for all safety valve system repairs, producing more complete documentation; there is increased vigilance to understand root cause failures; and test results are entered into a new field-wide safety valve system database.

Recent F pad testing results illustrate how the management system works, the company said. There was a 12 percent component failure rate at tests at F pad in December. Field management was informed. Field instrument technicians were sent to troubleshoot the problem. BP management received a report. Testing and investigation continued.

In February there was 19 percent component failure rate. An electrical technician identified what appeared to be hydrates in several electrical switches. An engineer was assigned to further assess the root cause of the failures.

The solution? Small blankets were installed on top of insulation boxes to cover the entire electrical switch, the wells were retested and all passed.

BP told the commission the blankets were needed because the company had previously — in response to another safety valve system problem — installed the insulation boxes.