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AOGCC fines BlueCrest $20,000 on 2 wells
Kristen Nelson Petroleum News
The Alaska Oil and Gas Conservation Commission has fined BlueCrest Alaska Operating a $20,000 civil penalty for failure to complete a well safety valve system performance test on one well and failure to obtain approval for the alternative closure of the subsurface safety value on a second well.
The commission said in an April 26 order that both were violations of well safety valve systems requirements.
The first violation, at the Hansen 1A well, occurred April 5, 2016, when the company began production without obtaining approval for an alternate closure for the subsurface safety valve. The second violation occurred July 6, 2017, when BlueCrest failed to perform a safety valve system performance test on the Hansen H-16 well.
The commission’s proposed fine, $20,000, is $10,000 for each violation.
BlueCrest requested and received an informal review, held Jan. 9, at which the company presented a summary of well operations at Hansen, results of its internal review and a summary of implemented and intended solutions to prevent recurrence of violations.
The commission said the company sought clarification on the proposed enforcement but did not dispute the violations.
BlueCrest response In a January response to the commission’s Dec. 13 notice of violation, BlueCrest acknowledged failure to submit results of the performance test on the H-16 well and said, “A Safety Valve Test Record cannot be found for the performance test performed by an individual who is no longer employed, only an operator logbook entry for the function test performed July 2, 2017.”
The company said it did respond to the commission on that matter in October but acknowledged that it “failed to submit and cannot provide a record of a passing SVS test on H16 within 5 days of startup. All parties in BlueCrest believed this was completed after the witness was waived but we are unable to locate a record.”
The company said it does “dispute that we willfully or knowingly operated in non compliance in our Safety Valve System.” BlueCrest said it believed the system “met the intent of the regulations as our SVS tests have all passed since field start up. Having been told otherwise by the commission via Docket No OTH-17-055 we have already implemented the corrective action to actuate our SSSV on flowline pressure alarms.”
Among proposed action the company listed a training program for all operators and the identification of a single point of contact for Cosmopolitan facility operations.
Failure of valve to close In its April decision the commission said safety valve system testing of the Hansen 1A well on March 23, 2017, found that the subsurface safety valve failed to close in response to low pressure in the well’s flowline.
“BlueCrest confirmed that the subsurface safety valve in Hansen 1A is not linked to the low-pressure detection device as required by AOGCC regulations but instead closes only on a plant or site emergency shut down,” the commission said. The failure of the company to request a variance or waiver from the safety valve system regulations violated regulations, AOGCC said.
Testing of the Hansen H-16 was first scheduled for July 3, 2017, the commission said, but rescheduled by the company to July 6 because of operational issues. The commission said it deferred witnessing a pre-production safety valve system test July 5 to coincide with testing five days after production commenced.
The commission said BlueCrest’s operation log book shows the safety valve system was tested July 2.
“BlueCrest has not provided a record of a safety valve system performance test,” the commission said, and the Hansen H-16 produced without a properly tested safety valve system until the commission tested witnessed a test Nov. 9.
It cited BlueCrest for failure to perform the initial safety valve system performance test as required by regulations.
The commission said BlueCrest acknowledges that it failed to submit a record of Hansen H-16 passing a safety valve system performance test within five days of startup and cannot provide a record of that test.
BlueCrest has 30 days to appeal the order. If it chooses not to appeal, the fine must be paid within 30 days of the issuance of the order.
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