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Home My WebLink AboutCO 510 BINDEX CONSERVATION ORDER NO. 510B Kenai Gas Field Kenai Unit Kenai Sterling Gas Pools 3, 4, 5.1, 5.2, and 6 Kenai Beluga/Upper Tyonek Gas Pool Kenai Tyonek Gas Pool 1 Kenai Deep Tyonek Gas Pool Kenai Peninsula Borough, Alaska 1. February 18, 2021 Hilcorp's request to amend CO 510 2. February 18, 2021 Notice of Public Hearing, Affidavit of Publication, email distribution, mailings ORDERS STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION 1 333 West 7" Avenue, Suite 100 Anchorage Alaska 99501 Re: THE APPLICATION OF Hilcorp Alaska, LLC, to amend Conservation Order No. 510A to allow commingling of production in the Kenai Unit 44-08 Well IT APPEARING THAT: Docket Numbers: CO-21-002 Conservation Order No. 510B Kenai Gas Field Kenai Unit Kenai Sterling Gas Pools 3, 4, 5.1, 5.2, and 6 Kenai Beluga/Upper Tyonek Gas Pool Kenai Tyonek Gas Pool 1 Kenai Deep Tyonek Gas Pool Kenai Peninsula Borough, Alaska June 17, 2021 1. By applications dated February 18, 2021, Hilcorp Alaska, LLC (Hilcorp) in its capacity as 100% working interest owner and operator of the Kenai Gas Field (KGF) requested the Alaska Oil and Gas Conservation Commission (AOGCC) authorize downhole commingling from Sterling Gas Pools 3, 4, and 5.1 in the Kenai Unit (KU) 44-08 well. 2. Pursuant to 20 AAC 25.540, the AOGCC tentatively scheduled a public hearing for March 23, 2021. On February 18, 2021, the AOGCC published notice of the opportunity for that hearing on the State of Alaska's Online Public Notice website and on the AOGCC's website, and electronically transmitted the notice to all persons on the AOGCC's email distribution list. On February 21, 2021, the notice was published in the Anchorage Daily News. On February 24, 2021, printed copies of the notice were mailed to all persons on the AOGCC's mailing distribution list. 3. No one requested that the tentatively scheduled hearing be held. 4. Hilcorp's application provides sufficient information upon which to make an informed decision. 5. This tentatively scheduled hearing was vacated on March 11, 2021. Findings: 1. Hilcorp is the operator for the leases within the affected area described below. 2. CO 510A set forth Pool Rules to govern development of the KGF. Conservation Order 510B June 17, 2021 Page 2 of 6 3. CO 510A defined, in descending stratigraphic order, five separate Kenai Sterling Gas Pools (Sterling Pools numbered 3, 4, 5.1, 5.2, and 6), the Beluga/Upper Tyonek Gas Pool, the Tyonek Pool 1, and the Kenai Deep Tyonek Gas Pool. CO 510A identified two reference wells — KU 21-6 and Kenai Deep Unit No. 1 (KDU I) --to define these pools and specified a measured depth (MD) for the top and base of each pool within one of those wells. 4. Hilcorp drilled the KU 44-08 well in November 2020 to target stratigraphically isolated sands in the Sterling formation on the far eastern side of the KGF. The well has tested gas but also produces water and is unable to sustain flow on an individual sand basis. 5. Hilcorp requests authorization to downhole commingle production in the KU 44-08 well in the hopes that bringing on production from multiple pools at the same time will allow the well to sustain flow. 6. Hilcorp has perforated and tested the Sterling B4B sand located in Sterling Gas Pool 5.1 and the Sterling Al sand located in Sterling Gas Pool 3.1 and found gas in both zones but neither zone produced to sustain flow on its own. As a result, single sand production in this area of the field is not economically viable. Hilcorp has identified four additional sands (one in Sterling Gas Pool 3.1, two in Sterling Gas Pool 4, and one in Sterling Gas Pool 5.1) and proposes to perforate all six sands and bring all three pools online at the same time utilizing downhole commingling in an effort to make production from the well economically viable, and thus increase ultimate recovery from this area of the field. . 7. Hilcorp proposes to run an initial production log to determine the flow from each sand and use that to allocate production between the pools, and on an annual basis thereafter run an additional production log and adjust the production allocation accordingly. Conclusions: 1. The KU 44-08 well has found gas on the far eastern portion of the KGF, but is unable to sustain production from individual sands so none of this gas would be recoverable. 2. Allowing downhole commingling might allow the well to be able to sustain production, making the well economically viable and allowing gas that would otherwise not be recovered to be produced. 3. Using an initial and annual thereafter production logging to determine how to allocate production from the well to the three pools that are proposed from commingling will provide an adequate methodology to properly allocate production. NOW, THEREFORE, IT IS ORDERED that: Conservation Order 510A is superseded by this order (CO 510B) and its record is incorporated by reference into this order's record. Development and operation of the KGF is subject to the following rules and the statewide requirements under 20 AAC 25 to the extent not superseded by these rules. Conservation Order 51OB June 17, 2021 Page 3 of 6 Affected Area: Seward Meridian Township, Range Description T4N, RI 1 W Section 3: Lot 4, SW 1/4 NW 1/4, W 1/2 SW 1/4 Sections 4, 5, 6, 7, and 8: All Section 9: N 1/2, SW 1/4, W 1/2 SE 1/4 Section 16:N 1/2NW 1/4, SW 1/4 NW 1/4, NW 1/4 SW 1/4 Sections 17 and 18: All Section 19: Lot 1, NE 1/4 NW 1/4, NE 1/4 Section 20: N 1/2 NW 1/4, SW 1/4 NW 1/4 T4N, R12W Section 1: All Section 2: E 1/2 E 1/2 Section 11: E 1/2 NE 1/4 - - Section 12: All Section 13: Lots 5 through 12, easterly 2.50 acres of Lots 13 through 16, E 1/2 NW 1/4 NE 1/4, E 1/2 E 1/2, E 1/2 W 1/2 SE 1/4 NE 1/4, E 1/2 W 1/2 NW 1/4 SE 1/4, E 1/2 SW 1/4 NE 1/4, E 1/2 NW 1/4 SE 1/4, All of W 1/2 NE 1/4, E 1/2 NW 1/4 lying westerly of coastline T5N, Rl 1 W Section 17: Lots 8 and 9, NW 1/4 SW I/4, S 1/2 SW 1/4, All of Kenai River Section 18- SE 1/4 SE 1/4 Section 19: Lots 2, 6 through 13, SE 1/4, E 1/2 E 1/2 SE 1/4 SW 1/4, NE 1/4, All SE 1/4 NW 1/4, NE 1/4 SW 1/4, S 1/2 SW 1/4 lying westerly of coastline Section 20: S 1/2, NW 1/4, SW 1/4 NE 1/4, NW 1/4 NE 1/4 Section 28: NW 1/4 WI/4, S 1/2 NW 1/4, SW 1/4, W ]/2 SE 1/4, SE 1/4 SE 1/4 Sections 29 and 30: All Section 31: Lots 3 through 10, E 1/2, All that portion lying westerly of coastline Sections 32 and 33: All Section 34: NW 1/4NW 1/4, S 1/2 NW 1/4, SW IA, W 1/2 SE 1/4 T5N, R12W Section 25: SE 1/4 NE 1/4, E 1/2 SE 1/4 Section 36: E 1/2 Rule 1. Definition of Pools (Revised from CO 510 and 510A) a. Kenai Sterling Gas Pool 3 is the accumulation of gas that is common to and correlates with the accumulation found in the interval from 4,175' to 4,412' MD in reference well KU 21-6. (Source: CO 510A) b. Kenai Sterling Gas Pool 4 is the accumulation of gas that is common to and correlates with the accumulation found in the interval from 4,412' to 4,576' MD in reference well KU 21-6. (Source: CO 510A) Conservation Order 510B June 17, 2021 Page 4 of 6 c. Kenai Sterling Gas Pool 5.1 is the accumulation of gas that is common to and correlates with the accumulation found in the interval from 4,576' to 4,880' MD in reference well KU 21-6. (Source: CO 510A) d. Kenai Sterling Gas Pool 5.2 is the accumulation of gas that is common to and correlates with the accumulation found in the interval from 4,880' to 5,250' MD in reference well KU 21-6. (Source: CO 510A) e. Kenai Sterling Gas Pool 6 is the accumulation of gas that is common to and correlates with the accumulation found in the interval from 5,250' to 5,520' MD in reference well KU 21-6. (Source: CO 510) f. Kenai Beluga/Upper Tyonek Gas Pool is the accumulation of gas that is common to and correlates with the accumulation found in the interval from 4,780' to 8,993' MD in reference well KU 41-18. (Source: CO 510) g. Kenai Tyonek Gas Pool I is the accumulation of gas that is common to and correlates with the accumulation found in the interval from 8,993' to 9,890' MD in reference well KU 41-18. (Source: CO 510) h. Kenai Deep Tyonek Gas Pool is the accumulation of gas that is common to and correlates with the accumulation found in the interval from 9,890' to 13,615' MD in reference well KU 41-18. (Source: CO 510A) Rule 2. Well Spacing (Restated from CO 510A) There shall be no restrictions as to well spacing except that no gas pay shall be opened in a well within 1,500' of an external property line of the affected area described above where the owners and landowners are not the same on both sides of the line. Rule 3. Casing and Cementing Requirements (Restated from CO 510) Surface casing shall be landed at not less than 1,200' or more than 2,000' and cement shall be circulated to the surface. Production casing shall be landed through the completion zone and cement shall cover and extend to at least 500' above each potentially productive sand interval. The use of multi -stage cementing procedures shall be permitted. Alternatively a casing string shall be adequately cemented at an intermediate point and a liner landed through the completion zone. If a liner is run, the annular space behind the liner shall be filled with cement to at least 100' above the casing shoe or the top of the liner shall be squeezed with sufficient cement to provide at least 100' of cement between the liner and casing annulus. Cement must cover all potentially productive intervals behind the liner. Casing and well head equipment shall be hydrostatically tested to not less than 2,000 pounds per square inch pressure. Conservation Order 510B June 17,2021 Page 5 of 6 Rule 4. Computed Bottomhole Pressure Survevs (Restated from CO 510 A key well bottomhole pressure survey shall be taken in each pool upon AOGCC request; however, such surveys shall not be required more often than twice in any calendar year. Bottomhole pressure may be computed from surface measurements taken with a dead weight tester provided, however, than an approved bottomhole measuring device shall be used when the accuracy of the computed bottomhole pressure is questionable. The time, length and kind of survey, number and location of the wells to be tested, datum and other details may be determined by the operator subject to AOGCC approval. Rule 5. Downhole Commin¢line (Restated from CO 510 and CO 510A and new this orderl a. Commingling of production from Kenai Sterling Gas Pool 4 and Kenai Sterling Gas Pool 5.1 in well KU 33-32 is allowed. (Source: CO 510) b. Commingling of production downhole from the Beluga/Upper Tyonek Pool, Tyonek Pool 1, and Kenai Deep Tyonek Pool is allowed with the following conditions (Source: CO 510A): Within 30 days of commencement of commingled production, and after production from the well has stabilized, the operator shall run a production log to determine the allocation of production between the Gas Pools. 2. Thereafter, the operator shall conduct production logging operations within each well at least once each calendar year, with no more than 13 months between operations, and adjust the allocation of production between the gas pools as appropriate. 3. Within 30 days of completion of production logging operations, electronic copies of all logs used for determining allocation of production shall be submitted to the AOGCC. c. Commingling of production from the Kenai Sterling Gas Pools 3.1, 4, and 5 in well KU 44-08 is allowed with the following conditions (Source: New this order): 1. Within 30 days of commencement of commingled production, and after production from the well has stabilized, the operator shall run a production log to determine the allocation of production between the Gas Pools. 2. Thereafter, the operator shall conduct production logging operations within each well at least once each calendar year, with no more than 13 months between operations, and adjust the allocation of production between the gas pools as appropriate. 3. Within 30 days of completion of production logging operations, electronic copies of all logs used for determining allocation of production shall be submitted to the AOGCC. Conservation Order 510B June 17, 2021 Page 6 of 6 Rule 6. Administrative Action (Restated from CO 510A) Unless notice and the opportunity for a public hearing are otherwise required, upon proper application the AOGCC may administratively waive the requirements of any rule stated herein or administratively amend this order as long as the change does not promote waste or jeopardize correlative rights, is based on sound engineering and geoscience principles, and will not result in an increased risk of fluid movement into freshwater. DONE at Anchorage, Alaska and dated June 17, 2021. Ugitally signed by Jeremy Dan Digitally si9nea by Dan Seamount Jessie L. Digitally signed by Jessie L. Chmlel.,kl Jeremy prise Price Dat`202106." Seamount D-09oo?031 g6' 711:4326 Chmielowski D 12021.800'r 11: 14i 32-oebg' Jeremy M. Price Daniel T. Seamount, Jr. Jessie L. Chmielowski Chair, Commissioner Commissioner Commissioner As provided in AS 31.05.080(a), within 20 days after written notice of the entry of this order or decision, or such further time as the AOGCC grants for good cause shown, a person affected by it may file with the AOGCC an application for reconsideration of the matter determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration must set out the respect in which the order or decision is believed to be ertoneous. The AOGCC shall grant or refuse the application for reconsideration in whole or in part within 10 days after it is filed. Failure to act on it within 10-days is a denial of reconsideration. If the AOGCC denies reconsideration, upon denial, this order or decision and the denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision denying reconsideration, UNLESS the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which the application for reconsideration was filed. If the AOGCC grants an application for reconsideration, this order or decision does not become final. Rather, the order or decision on reconsideration will be the FINAL order or decision of the AOGCC, and it may be appealed to superior court. That appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on reconsideration. In computing a period of time above, the date of the event or default after which the designated period begins to rim is not included in the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00 p.m. on the next day that does not fall on a weekend or state holiday. Salazar, Grace (CED) From: Salazar, Grace (CED) <grace.salazar@alaska.gov> Sent: Thursday, June 17, 2021 12:13 PM To: AOGCC Public Notices Subject: [AOGCC_Public_Notices] AOGCC Conservation Order 510E Attachments: C0510B.pdf Please see attached. Re: THE APPLICATION OF Hilcorp Alaska, LLC, to amend Conservation Order No. 510A to allow commingling of production in the Kenai Unit 44-08 Well Respectfully, M. Grace Salazar, Special Assistant Alaska Oil and Gas Conservation Commission 333 West 71^ Avenue Anchorage, AK 99501 Direct: (907) 793-1221 Email: grace.salazar@alaska.gov https://www.commerce.alaska.gov/web/aogcc/ Docket Numbers: CO-21-002 Conservation Order No. 510B Kenai Gas Field Kenai Unit Kenai Sterling Gas Pools 3, 4, 5.1, 5.2, and 6 Kenai Beluga/Upper Tyonek Gas Pool Kenai Tyonek Gas Pool 1 Kenai Deep Tyonek Gas Pool Kenai Peninsula Borough, Alaska June 17, 2021 List Name: AOGCC_Public_Notices@list.state.ak.us You subscribed as: grace.salazar@alaska.gov Unsubscribe at: http:Hlist.state.ak.us/mailman/options/aogcc_public_notices/grace.salazar%40alaska.gov Bernie Karl Gordon Severson Richard Wagner K&K Recycling Inc. 3201 Westmar Cir. P.O. Box 60868 P.O. Box Anchorage, AK 99508-4336 Fairbanks, AK 99706 AK Fairbanks,, AK 99711 George Vaught, Jr. Darwin Waldsmith P.O. Box 13557 P.O. Box 39309 Denver, CO 80201-3557 Ninilchik, AK 99639 INDEXES Notice of Public Hearing STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION Re: Docket # CO-21-022. The application of Hilcorp Alaska, LLC (Hilcorp) for an authorization under 20 AAC 25.215(b)(2) to commingle production downhole from three gas pools in the Kenai Gas Field KU 44-08 well (PTD 220-068). Hilcorp, by letter dated February 18, 2021, requests the Alaska Oil and Gas Conservation Commission (AOGCC) amend Conservation Order No. 510A to authorize the downhole commingling of production from the Kenai Sterling Gas Pools 3, 4, and 5.1, in the Kenai Gas Field. The AOGCC has tentatively scheduled a public hearing on this application for March 23, 2021 at 10:00 a.m. at 333 West 7d' Avenue, Anchorage, Alaska 99501. To request that the tentatively scheduled hearing be held, a written request must be filed with the AOGCC no later than 4:30 p.m. on March 10, 2021. If a request for a hearing is not timely filed, the AOGCC may consider the issuance of an order without a hearing. To learn if the AOGCC will hold the hearing, call (907) 793-1221 after March 11, 2021. If a hearing is requested, the Covid-19 virus may necessitate that the hearing be held telephonically. Those desiring to participate or be present at the hearing should check with AOGCC the day before the hearing to ascertain if the hearing will be telephonic. If the hearing is telephonic, on the day of the hearing, those desiring to be present or participate should call 1-800- 315-6338 and, when instructed to do so, enter the code 14331. Because the hearing will start at 10:00 a.m., the phone lines will be available starting at 9:45 a.m. Depending on call volume, those calling in may need to make repeated attempts before getting through. In addition, written comments regarding this application may be submitted to the Alaska Oil and Gas Conservation Commission, at 333 West 7s Avenue, Anchorage, Alaska 99501. Comments must be received no later than 4:30 p.m. on March 22, 2021, except that, if a hearing is held, comments must be received no later than the conclusion of the March 23, 2021 hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, contact the AOGCC's Special Assistant, Jody Colombie, at (907) 793-1221, no later than March 18, 2021. Jeremy Oele:A31.%IB M. Price Jeremy M. Price Chair, Commissioner Colombie, Jody J (CED) From: Colombie, Jody J (CED) <jody.colombie@alaska.gov> Sent: Thursday, February 18, 2021 1:44 PM To: AOGCC Public Notices Subject: [AOGCC_Public_Notices] Public Notice Attachments: CO-21-002 Public Hearing Notice KU 44-08.pdf Categories: Yellow Category Re: Docket # CO-21-022. The application of Hilcorp Alaska, LLC (Hilcorp) for an authorization under 20 AAC 25.215(b)(2) to commingle production downhole from three gas pools in the Kenai Gas Field KU 44-08 well (PTD 220-068). Jody J. Colombie AOGCC Special Assistant Alaska Oil and Gas Conservation Commission State of Alaska 333 West 7t' Avenue Anchorage, AK 99501 Phone Number: 907-793-1221 Email: jody.colombie@alaska.gov List Name: AOGCC_Public_Notices@list.state.ak.us You subscribed as: jody.colombie@alaska.gov Unsubscribe at: http:Hlist.state.ak.us/mailman/options/aogcc_public_notices/jody.colombie%40alaska.gov Bernie Karl Gordon Severson Richard Wagner K&K Recycling Inc. 3201 Westmar Cir. P.O. Box 60868 P.O. Box 58055 Anchorage, AK 99508-4336 Fairbanks, AK 99706 Fairbanks, AK 99711 George Vaught, Jr. Darwin Waldsmith P.O. Box 13557 P.O. Box 39309 Denver, CO 80201-3557 Ninilchik, AK 99639 IQ ffII l U" I CenteDrive Suite 1400 rage, K 9 anchorage, AK 99503 Anchorage, Phone: 907-777-8432 Fax: 907-777-8301 Hilcorp Alaska, LLC cterrell@hilcorp.com February 18, 2021 Jeremy Price, Chair Commissioner Alaska Oil and Gas Conservation Commission 333 West 7°i Avenue, Suite 100 Anchorage, Alaska 99501 RE: Request for a waiver to commingle production within the same wellbore from Sterling Gas Pools 3, 4, and 5.1 in the KU 44-08 Well located in the Kenai Unit Dear Commissioner Price: Hilcorp Alaska, LLC (Hilcorp), as Operator of the Kenai Unit ("KU") hereby requests that the Alaska Oil and Gas Conservation Commission ("AOGCC") grant a waiver for the requirement to provide complete separation of flow streams from different pools as specified in 20 AAC 25.210 for the KU 44-08 Well in the Kenai Gas Field ("KGF") for commingling of production within the same wellbore from Sterling Gas Pools 3, 4, and 5.1, pursuant to AS 31.05.030 and 20 AAC 25.215(b). Background Hilcorp drilled and completed the KU 44-08 Well in November 2020 in the KGF. The well was targeting stratigraphically isolated sands in the Sterling Formation on the far eastern side of KGF, correlating to a seismic amplitude event. The well has tested gas, however, these sands also produced water and the well was unable to sustain flow on an individual sand basis. The KU 44-08 Well is currently shut-in in hopes that bringing on production from individual Sterling Pools together (currently isolated) would be enough to add production in commercial quantities. To extend the productive life of this wellbore, Hilcorp now requests that the AOGCC grant a waiver of the requirement to provide complete separation of flow streams from different pools as specified in 20 AAC 25.2110 for commingling of production within the same wellbore from Sterling Gas Pools 3, 4, and 5.1. Hilcorp plans to produce from the Sterling Formation without isolating perforations between the Sterling Pools, in order to bring KU 44-08 into production. Discussion The KU 44-08 Well test shows gas present in Sterling Gas Pools 3, 4, and 5.1. The well was initially perforated and tested in the 134B Sand in the Sterling Gas Pool 5.1. This sand produced water and the well was unable to sustain flow. The B413 Sand was then isolated and the A 10 Sand was perforated and tested in the Sterling Gas Pool 3. This sand also produced water and the well was unable to sustain flow. Unfortunately, these sands produce too much water and the well is KU 44-08 Commingling Application Page 2 of 4 currently unable to sustain flow on an individual sand basis due to the 5.5" diameter of the wellbore and inability to lift the water with the gas. The well is currently shut-in in hopes that bringing on each of these pools together (currently isolated) would be enough to add production in commercial quantities. Hilcorp believes that the productive gas intervals in this wellbore are smaller, lower pressure intervals. While collectively, they may produce gas, they individually will not be able to overcome any hydrostatic column of liquid in the wellbore. There are a total of six (6) Sterling intervals being targeted in this well (see table below). Hilcorp proposes to commingle production from all six (6) sands, which would produce from Sterling Gas Pools 3, 4, and 5.1. If the well flows gas, Hilcorp will run a production log to determine which intervals are producing gas. On an annual basis thereafter, Hilcorp proposes to run a production log across all open perforations within the wellbore: Such data will be used to meet the requirements of 20 AAC 25.215(b)(1) [production from separate pools can be properly allocated). FORMATION SAND TOP MD BTM MD TOTAL FT D Top TV D Bottom TVD Sterling P3_AB 16,479' 16,524' 45' 13,83V t3,863' Sterling P3 A30 36,613' t6,695' 82' t3,913' t3,960' Sterling 1`4_111A 16,866' 16,897' 31' t4,067' t4,085' Sterling P4 82A 16,956 t7,089' 133' 14,126' 14,222' Sterling P5.1_94A t7,145' t7,174' 29' t4,260' 34,283' Sterling P5.1_94B t7,234' 17,270' 36' 34,323' 14,351' The proposed perforations in the Sterling formations are located within the boundaries of Sterling Gas Pools 3, 4, and 5.1, and the KU Sterling Participating Area ("Sterling PA"). During the initial testing phase, and thereafter, all production from KU 44-08 Well will be allocated and reported to the AOGCC in accordance with the annual production logs. For royalty reporting to the BLM, all production from the KU 44-08 Well will be reported and allocated to the Sterling PA. As detailed above, Hilcorp's proposal to commingle production from Sterling Gas Pools 3, 4, and 5.1 will not lead to a loss of reserves or less ultimate recovery. from the Sterling Formation. Moreover, waste will not occur and proper procedures will be in place to ensure that production from each of the Sterling Gas Pools are properly allocated, satisfying the requirements of 20 AAC 25.215(b)(1). Upon approval from the AOGCC and issuance of an order providing for commingling of production within the same wellbore from each of the Sterling Gas Pools, the requirements of 20 AAC 25.215(b)(2) will also be met. KU 44-08 Commingling Application Page 3 or4 Conclusion If the AOGCC does not grant a waiver of the requirement to provide complete separation of flow streams from different pools as specified in 20 AAC 25.210 for the KU 44-08 Well, Hilcorp will be unable to evaluate potential Sterling pay in the wellbore. Hilcorp would likely by-pass the potential Sterling pay and either convert the well into an injector, or plug and abandon the KU 44- 08 Well all together, thus reducing the ultimate recovery from the Kenai Gas Field. Hilcorp respectfully requests that the AOGCC grant a waiver of the requirement to provide complete separation of flow streams from different pools as specified in 20 AAC 25.210 for the KU 44-08 Well in the Kenai Gas Field for commingling of production within the same wellbore from Sterling Gas Pools 3, 4, and 5.1, pursuant to AS 31.05.030 and 20 AAC 25.215(b). Hilcorp believes that this application satisfies the requirements of 20 AAC 215(b). If you require additional information regarding this request, please contact Mr. Ben Siks, Sr. Geologist, at 907-777-8388 or bsiks@hilcorp.com, or the undersigned at 907-777-8432 or cterrell@hilcorp.com. Sincerely, Cody T. errell Landman Hilcorp Alaska, LLC Cc: Jody Colombie, AOGCC Special Assistant (via email) Samantha Carlisle, AOGCC Executive Secretary (via email) Attachments: • Attachment 1: SRU 14-15 Map Overview KU 44-05 Commingling Applicalum Pagc 4 of 4 13, 11 f , I � , I 1 1 1 I I 1 1 I 11• I , 4 I FEE A028142 � I 1 IK�t:�Ei BHL '9U alao7X ars t t t \ t yy/�l-ry �11 L`7.71't V.J tt FEE 022330 \t Xv aa.te aHt \ t t }� Kau •1.•-z EHI 12 1 f SHL ♦� AJ i'-094HL � hP411 [Z 6HI. soo4r4o11w ec. Legend FEA093656 K1 Jill, fill' -rs n111��.\� _ eyyOPa•''400C0/ FEE ADL460 v KU 44-OB_SHL Other Surface Hole La abw ON KU 44-08_TPH • Other Bottom Hole Location .� KU 44-08_BHL� —•j %%W Paths M. Oil and Gas Uro Boundary Attachment 1 KU 44-08 Well Overview Commingling Application 0 50u 1,160 1.740 2,320 Feet A Alaska S631c Pdnc Zane a, tND27 Idap Dale 211e:2021 � I � /I I KBU 42�1� /I 1 1KBU'4WRD / I I / I I / I I I 1 1 I I I I I I I FEE A028142 � I 1 BU JM7X BHlKU 43-07 BHL \\ �KBkt lj= YBHL • +KU 11-08 BHL H .` 131-11.` KBU 11-08Z BHL KBU 43-07Y BF I I I 1 1 / I / \ I / \ I / \ I/ �. \, •yCU 41-18X BHL f KBU 32-08 BHL I / / / / KBU 13-088HL / / / / KBU 14-W BHL KYA 1 (KU 41-18) BHL \ `II•k KIJ 44-08_SI IL KBU 11-17X BHL FEE 022330 \\\ \ KU 12-17 BHL KU 44.18 BHL • \ \ FEE AA093856 IKU 44-U8_HHL 'K1J44 KU 11-17 BHL _s.e bo4'ce b0.p.po o-bbpo b�„p.pcb\oW�- , S0041V011 W See. T7 Legend ® KU 44-08 SHL ;ti, KU 44-08_TPH FEE ADL460 Other Surface Hole Location • Other Bottom Hole Location 2. % KU 44-08_BHL — Well Paths Oil and Gas Unit Boundary Attachment 1 KU 44-08 Well Overview Hilamp Al.Kka, LLC Commingling Application 0 580 1,160 1,740 2,320 N Feet Alaska State Plane Zone 4, NAD27 Map Date: 2/18/2021