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Furie asks AOGCC to allow Cook Inlet wells to be P&A’d as they are
Kristen Nelson Petroleum News
When the current owners of the Kitchen Lights unit took over in July, they found a lot of things that needed to be cleaned up in the unit’s wells, John Hendrix, chief executive officer and president of Furie Operating Alaska, told the Alaska Oil and Gas Conservation Commission at a Dec. 23 hearing.
One of those things was three exploration wells which, although plugged and cemented, are classified as suspended, he said. Each still has 15 feet of 30-inch conductor pipe sticking up from the seafloor into the waters of Cook Inlet.
Hendrix petitioned the commission to change the status of the three wells to plugged and abandoned and AOGCC scheduled the hearing.
The three, KLU Nos. 1, 2A and 4, all have downhole barriers and surface plugs set per the commission’s regulations, Hendrix said. The wells have been rendered incapable of any production or flow, he said.
Furie is requesting a variance to AOGCC regulations for offshore location clearance to reclassify the three KLU wells as plugged and abandoned. The commission’s regulations for offshore wells (the relevant section is dated 1999) require removal of “wellhead equipment, casing, piling, and other obstructions to a depth at least five feet below the mudline before removing the drill rig, unless otherwise approved by the commission as adequate to protect public health and safety.”
Wells with casing stubs Hendrix said six offshore Cook Inlet wells close to the Kitchen Lights unit have previously been granted abandoned status with stubs of 6 to 12 feet above the seabed and are identified on National Oceanic and Atmospheric Administration navigational charts. Those wells, he said, have not posed a threat to navigation or commercial, subsistence or recreational activities in the area.
Rick Dusenbery, Furie’s chief operating officer, told the commission it is only the 30-inch conductor pipe that remains above the seafloor in the Furie wells. All three KRU wells were properly plugged in accordance with regulations, he said.
Commissioner Dan Seamount asked if the company knew why the previous operator didn’t P&A the wells.
Dusenbery said if you don’t P&A it generally means you plan to go back in, but Hendrix said all they can do is assume - they didn’t know why the previous operator didn’t P&A.
Other exploration wells Dusenbery said the exploration wells abandoned in the area in similar condition include the SRS State Nos. 1 and 2, drilled by Shell Oil Co. in 1965. Those wells, suspended after drilling operations ended, are cemented, but casing stubs remain. In 1967 Shell applied to change the status on the wells from suspended to abandonment, a change approved by Tom Marshall of the commission (this was the commission’s predecessor, the Alaska Oil and Gas Committee, when AOGCC, under an earlier name, was part of the Department of Natural Resources).
SRS State No. 1 has 30-inch casing reported 12 feet above the seafloor by NOAA on navigational charts and obstruction lists and there have been no issues reported in the 53 years since; the same is true for SRS State No. 2, which has 10 feet of 30-inch casing above seafloor, Dusenbery said.
There are also four Pan American wells with casing stubs above the seafloor near the Kitchen Lights unit, he said: Cook Inlet state Nos. 1-2, Middle Ground Shoal 18746 No. 1 and Forelands State Unit No. 1 - all with casing stubs 6 feet above the seafloor. (AOGCC records show the Pan American wells - all drilled in the 1960s - were plugged and abandoned within months of their spud dates.)
Furie wells not on NOAA charts Dusenbery said none of Furie’s wells are on NOAA charts and that would need to be remedied. He said the stubs don’t present navigational hazards because just the casing remains, no wellhead equipment that could snag.
All three Furie wells are in fairly deep water; two were suspended in 2012 and one in 2013, he said.
“Extreme tides in the Cook Inlet present unique challenges and high risks to any surface or subsea operation,” Furie said in slides presented at the hearing. Furie said “the human safety risk” associated with cutting off the remaining 15 feet of casing stub “is high and not commensurate with the operational outcome.”
Bathymetry surveys in the area have found boulders as tall or taller than the casing stubs in the area, the company said.
Furie presented casing cutoff cost estimates for three approaches: $3.7 million to mobilize a barge and divers and cut the casing off 5 feet below the mudline; $6.9 million to mobilize a jack-up rig and cut the casing off 5 feet below the mudline; and $2 million to mobilize a barge and divers and cut the casing off at mudline.
AOGCC records show 10 wells drilled by previous Kitchen Lights owners, three of which, two exploratory wells and one development well, are plugged and abandoned. All three of the currently suspended wells were exploratory.
Comments The commission heard from the U.S. Coast Guard on the issue of the remaining casing stubs.
“I’d be reluctant to call it a ‘hazard to navigation.’ On the other hand, a lack of awareness of said structures would be a concern,” Lt. Matt Lemanski, waterways management division chief for the U.S. Coast Guard Sector Anchorage, told AOGCC in a Dec. 17 email.
Lemanski said there would need to be a mechanism in place to communicate to NOAA to update the charts showing the protruding subsurface structures.
“After consulting with the Marine Pilots, I could see a situation where a vessel needs to drop an anchor in an emergency, to self-arrest or someone wants to install a new pipeline or subsea cable, or some other event (earthquake) that requires a response.” If information on the casing stubs was on the charts, “there will be documentation on file that is relatively easy to access,” Lemanski said.
Michael Munger, executive director of the Cook Inlet Regional Citizens Advisory Council, said in a Dec. 21 letter that CIRCAC believes “if this request for regulatory variance is granted, it may set a disturbing precedent for Cook Inlet and elsewhere in the state where drilling from a mobile drilling unit may occur.”
Munger said CIRCAC believes “that seafloor obstructions such as these wells add to navigational risk for large marine vessels in transit. Of particular concern is the potential of an anchor snag in the event of a vessel attempting self-arrest due to loss of steering or propulsion,” and said self-arrest has been utilized in the past in Cook Inlet.
CIRCAC also said large boulders move on the inlet seabed due to “extreme tidal fluctuations and associated high currents,” and noted the boulder strike on a subsea pipeline which had caused a natural gas leak and required repair.
Bob Shavelson, advocacy director for Cook Inletkeeper, said in a Dec. 22 letter that the commission’s regulations require removal of “wellhead equipment, casing, piling, and other obstructions to a depth at least five feet below the midline before removing the drilling rig, unless otherwise approved by the commission as adequate to protect public health and safety,” and said “Inletkeeper is unaware whether AOGCC made such findings prior to the removal of the drill rig from the wellheads in question.”
As for the historic wells cited by Furie, Inletkeeper said those wells predate the regulation requiring removal to 5 feet below the seafloor.
- KRISTEN NELSON
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