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Home My WebLink AboutCO 810CONSERVATION ORDER 810 Badami Unit 1. July 27, 2023 Savant Alaska application for downhole commingling Badami Unit B1-38 (Confidential exhibit held in secure storage) 2. August 10, 2023 Public Hearing Notice, Affidavit of Publication, Email list STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West 7th Avenue Anchorage Alaska 99501 Re: THE APPLICATION OF Cook Inlet Energy, LLC for an order authorizing downhole commingling of production in the Badami Unit B1-38 well (API No. 50- 029-23407-00-00). ) ) ) ) ) ) ) ) ) ) ) ) ) Docket Number: CO-23-013 Conservation Order 810 Badami Unit B1-38 Well Badami Oil Pool Undefined (Killian) Oil Pool North Slope Borough, Alaska September 22, 2023 IT APPEARING THAT: 1. By letter dated July 27, 2023, Cook Inlet Energy, LLC (CIE) requested authorization under 20 AAC 25.215(b) to commingle downhole production from the Badami Oil Pool (BOP) and Undefined Oil Pool unofficially named the Killian Oil Pool (KOP) in the Badami Unit (BU) B1-38 (API No. 50-029-23407-00-00) well. 2. Pursuant to 20 AAC 25.540, the Alaska Oil and Gas Conservation Commission (AOGCC) tentatively scheduled a public hearing for September 21, 2023. On August 19, 2023, 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, electronically transmitted the notice to all persons on the AOGCC’s email distribution list. On August 13, 2023, the AOGCC published the notice in the Anchorage Daily News. 3. No protest to the application or request for hearing was received. 4. Because CIE provided sufficient information upon which to make an informed decision, the request can be resolved without a hearing. 5. The tentatively scheduled hearing was vacated and the period for public comments closed on September 12, 2023. No public comments were received. FINDINGS: 1. CIE is the operator of the BU located along the Beaufort Sea coastline in the North Slope Borough, Alaska. 2. The B1-38 development oil well was spudded in 2009 and completed in the KOP in February 2010. The well came online at approximately 400 BOPD and has generally been in a long slow decline and is currently producing about 130 BOPD. Through July 2023, a little under 790 MBO has been recovered from the well. 3. The B1-38 penetrated the BOP approximately 1,100 feet TVD up hole from the KOP and CIE now proposes to add perforations in the BOP and commence commingled production from the well. 4. CIE expects the cross-flow potential between the pools to be negligible since the deeper KOP has been produced for several years which has partially depleted the pressure in the KOP such that the pressure differential between the KOP and the BOP will be negligible. Additionally, the well is a gas lifted producer which will work to lift the produced fluids to the surface as opposed to allowing it to flow between the pools. Conservation Order 810 September 22, 2023 Page 2 of 3 5. Allowing commingled production from the pools should result in an increase in the oil flow rate over its current rate, which would extend the economic life of the well and thus allow for increased production from the pools, which will increase ultimate recovery in the field and prevent waste. 6. Production trends from the KOP are well established, as such CIE proposes to base the initial production allocation on the difference between what the well was producing prior to adding the perfs in the BOP and the commingled flow. Thereafter, if significant changes are noted in the well’s production profile, such as would happen in the event the well is stimulated and/or perforations are added or removed, production logs can be run the reestablish the production allocation. CONCLUSIONS: 1. Commingling of production from the KOP and BOP in the B1-38 well should not cause waste and should maximize ultimate recovery from this well through extending the economic life of the well. 2. Basing the initial allocation on the difference between the current KOP only production and the combined rate after the BOP is brought online, then conducting production surveys as needed when the well’s production profile has a significant change will ensure adequate allocation of production between the KOP and the BOP. NOW THEREFORE IT IS ORDERED: Downhole commingling of production between the unofficially named Killian Oil Pool and the Badami Oil Pool in the B1-38 well is approved as follows: 1. After flow from the BOP has been established production from the well shall be allocated to the individual pools based on the difference between KOP only production and the commingled production. 2. Thereafter, a production log shall be run as necessary should the production profile of the well change. 3. A production log shall be run within 30 days of any work done to the well that could materially affect the production from either zone. Examples of this type of work includes but are not limited to: a. Adding perforations b. Plugging perforations c. Stimulating the well d. Changing the tubing 4. Copies of the production logs shall be submitted to the AOGCC within 30 days of being of being collected. DONE at Anchorage, Alaska, and dated September 22, 2023. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner Gregory Wilson Digitally signed by Gregory Wilson Date: 2023.09.22 10:50:13 -08'00' Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2023.09.22 11:50:11 -08'00' Conservation Order 810 September 22, 2023 Page 3 of 3 RECONSIDERATION AND APPEAL NOTICE 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 erroneous. 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 run 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. From:Carlisle, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Conservation Order 810 (Badami) Date:Friday, September 22, 2023 12:00:56 PM Attachments:co 810.pdf THE APPLICATION OF Cook Inlet Energy, LLC for an order authorizing downhole commingling of production in the Badami Unit B1-38 well (API No. 50-029-23407-00-00). Samantha Carlisle Special Assistant Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, AK 99501 (907) 793-1223 __________________________________ List Name: AOGCC_Public_Notices@list.state.ak.us You subscribed as: samantha.carlisle@alaska.gov Unsubscribe at: https://list.state.ak.us/mailman/options/aogcc_public_notices/samantha.carlisle%40alaska.gov 2 Notice of Public Hearing STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION RE: Docket Number: CO-23-013 By application dated July 27, 2023, Cook Inlet Energy, LLC (CIE) requests that the Alaska Oil and Gas Conservation Commission (AOGCC) authorize downhole commingling of production between the undefined Killian Oil Pool and the Badami Oil Pool in Badami Unit (BU) Well B1-38 (API No. 50-029-23407-00-00). Downhole commingling regulations (20 AAC 25.215) are in place to prevent waste and to protect correlative rights. Operators are prohibited from producing from, or injecting into, more than one pool (a rock formation where oil and/or gas has accumulated) in the same wellbore without the AOGCC approving the downhole commingling of two or more pools. It is not uncommon for a well to encounter multiple pools. In these situations, normally an operator will first produce from the deepest pool in the well until it is depleted, then plug off that pool and move up to the next pool and repeat the process until all the pools have been depleted. Sometimes one or more of these pools is not large enough to warrant production/injection operations on its own, or there are other reasons to allow commingled production/injection. In these instances, an operator will apply to the AOGCC for an order approving the downhole commingling of two or more pools. The AOGCC reviews the application to assure waste will not occur and all owners receive their share of the production. This notice does not contain all the information filed by CIE. To obtain more information, contact the AOGCC’s Special Assistant, Samantha Carlisle, at (907) 793-1223 or samantha.carlisle@alaska.gov. A public hearing on the matter has been tentatively scheduled for September 21, 2023, at 10:00 a.m. The hearing, which may be changed to full virtual, if necessary, will be held in the AOGCC hearing room located at 333 West 7th Avenue, Anchorage, AK 99501. The audio call-in information is (907) 202-7104 Conference ID: 834 417 044#. Anyone who wishes to participate remotely using MS Teams video conference should contact Ms. Carlisle at least two business days before the scheduled public hearing to request an invitation for the MS Teams. 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 August 28, 2023. If a request for a hearing is not timely filed, the AOGCC may issue an order without a hearing. To learn if the AOGCC will hold the hearing, call (907) 793-1223 after August 29, 2023. In addition, written comments regarding this application may be submitted to the AOGCC, at 333 west 7th Avenue, Anchorage, AK 99501 or samantha.carlisle@alaska.gov. Comments must be received no later than 4:30 p.m. on September 12, 2023, except that, if a hearing is held, comments must be received no later than the conclusion of the September 21, 2023, hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, contact Samantha Carlisle, at (907) 793-1223, no later than September 14, 2023. Brett W. Huber, Sr. Chair, Commissioner Brett W. Huber, Sr. Digitally signed by Brett W. Huber, Sr. Date: 2023.08.10 13:49:43 -08'00' From:Carlisle, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Public Hearing Notice CO-23-013 (CIE B1-38 Commingling) Date:Thursday, August 10, 2023 3:15:57 PM Attachments:CO-23-013 Public Hearing Notice CIE B1-38 Commingling.pdf Docket Number: CO-23-013 By application dated July 27, 2023, Cook Inlet Energy, LLC (CIE) requests that the Alaska Oil and Gas Conservation Commission (AOGCC) authorize downhole commingling of production between the undefined Killian Oil Pool and the Badami Oil Pool in Badami Unit (BU) Well B1-38 (API No. 50-029-23407-00-00). Samantha Carlisle Special Assistant Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, AK 99501 (907) 793-1223 __________________________________ List Name: AOGCC_Public_Notices@list.state.ak.us You subscribed as: samantha.carlisle@alaska.gov Unsubscribe at: https://list.state.ak.us/mailman/options/aogcc_public_notices/samantha.carlisle%40alaska.gov Lisi Misa being first duly sworn on oath deposes and says that she is a representative of the An- chorage Daily News, a daily newspaper. That said newspaper has been approved by the Third Judicial Court, Anchorage, Alaska, and it now and has been published in the English language continually as a daily newspaper in Anchorage, Alaska, and it is now and during all said time was printed in an office maintained at the afore- said place of publication of said newspaper. That the annexed is a copy of an advertisement as it was published in regular issues (and not in supplemental form) of said newspaper on AFFIDAVIT OF PUBLICATION ______________________________________ Notary Public in and for The State of Alaska. Third Division Anchorage, Alaska MY COMMISSION EXPIRES ______________________________________ 08/13/2023 and that such newspaper was regularly distrib- uted to its subscribers during all of said period. That the full amount of the fee charged for the foregoing publication is not in excess of the rate charged private individuals. Signed________________________________ Subscribed and sworn to before me this 14th day of August 2023. Account #: 100869 ST OF AK/AK OIL AND GAS CONSERVATION COMMISSION333 W. 7TH AVE STE 100, ANCHORAGE, AK 99501 Order #: W0039943 Cost: $356.8 Notice of Public HearingSTATE OF ALASKAALASKA OIL AND GAS CONSERVATION COMMISSION RE: Docket Number: CO-23-013By application dated July 27, 2023, Cook Inlet Energy, LLC (CIE) requests that the Alaska Oil and Gas Conservation Commission (AOGCC) authorize downhole commingling of production between the undefined Killian Oil Pool and the Badami Oil Pool in Badami Unit (BU) Well B1-38 (API No. 50-029-23407-00-00). Downhole commingling regulations (20 AAC 25.215) are in place to prevent waste and to protect correlative rights. Operators are prohibited from producing from, or injecting into, more than one pool (a rock formation where oil and/or gas has accumulated) in the same wellbore without the AOGCC approving the downhole commingling of two or more pools. It is not uncommon for a well to encounter multiple pools. In these situations, normally an operator will first produce from the deepest pool in the well until it is depleted, then plug off that pool and move up to the next pool and repeat the process until all the pools have been depleted. Sometimes one or more of these pools is not large enough to warrant production/injection operations on its own, or there are other reasons to allow commingled production/injection. In these instances, an operator will apply to the AOGCC for an order approving the downhole commingling of two or more pools. The AOGCC reviews the application to assure waste will not occur and all owners receive their share of the production. This notice does not contain all the information filed by CIE. To obtain more information, contact the AOGCC’s Special Assistant, Samantha Carlisle, at (907) 793-1223 or samantha.carlisle@alaska. gov. A public hearing on the matter has been tentatively scheduled for September 21, 2023, at 10:00 a.m. The hearing, which may be changed to full virtual, if necessary, will be held in the AOGCC hearing room located at 333 West 7th Avenue, Anchorage, AK 99501. The audio call-in information is (907) 202-7104 Conference ID: 834 417 044#. Anyone who wishes to participate remotely using MS Teams video conference should contact Ms. Carlisle at least two business days before the scheduled public hearing to request an invitation for the MS Teams. 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 August 28, 2023. If a request for a hearing is not timely filed, the AOGCC may issue an order without a hearing. To learn if the AOGCC will hold the hearing, call (907) 793-1223 after August 29, 2023. In addition, written comments regarding this application may be submitted to the AOGCC, at 333 west 7th Avenue, Anchorage, AK 99501 or samantha.carlisle@alaska.gov. Comments must be received no later than 4:30 p.m. on September 12, 2023, except that, if a hearing is held, comments must be received no later than the conclusion of the September 21, 2023, hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, contact Samantha Carlisle, at (907) 793-1223, no later than September 14, 2023. Brett W. Huber, Sr. Chair, Commissioner Pub: Aug. 13, 2023 STATE OF ALASKA THIRD JUDICIAL DISTRICT 2024-07-14 Document Ref: 79DHT-RHDXW-7GRAZ-NX7FW Page 46 of 57 1 188 W. Northern Lights Blvd., Suite 510, Anchorage, Alaska 99503. Main (907) 334-6745 | Fax (907) 334-6735 July 27, 2023 Alaska Oil and Gas Conservation Commission (AOGCC) 333 W 7th AVE Anchorage, AK 99501 (907) 279-1433 RE: Request for Administrative Approval to Downhole Commingle Production from the Killian and Badami Oil Pools in the Badami Unit B1-38 Wellbore at the Badami Field. Dear Commissioner, Glacier Oil and Gas (GLA), owner of Savant Alaska, operator of the Badami Field, hereby requests administrative approval be granted by the Alaska Oil and Gas Conservation Commission (AOGCC) to permit the downhole commingling of oil production from both the Killian oil pool and the Badami oil pool as defined in Conservation Order 402 A in the Badami Unit B1-38 wellbore (B1-38). Issuance of the requested Conservation Order requires an exception to 20 AAC 25.215(b)1 . Additionally, GLA requests waiver of the requirement to provide complete separation of flowstreams from separate pools as specified in 20 AAC 25.2102 The B1-38 well has been producing from the Killian oil pool since 2010 and steadily declining. The Badami oil pool lies approximately 1100 feet TVD up-hole from the current Killian perforated interval. GLA intends to perforate the Badami sands and commingle the production within the wellbore. In order to maximize recovery from the Badami Field in Both the Killian oil pool and the Badami oil pool, and to minimize any waste of resources, GLA is requesting administrative approval to downhole commingle production from the Killian and Badami in the B1-38 wellbore. 1 20 AAC 25.215(b) states: Commingling of production within the same wellbore from two or more pools is not permitted unless, after request, notice, and opportunity for public hearing in conformance with 20 AAC 25.540, the commission(1) ϐinds that waste will not occur, and that production from separate pools can be properly allocated; and(2) issues an order providing for commingling for wells completed from these pools within the ϐield. 2 20AAC25.210 states: A well may not be completed in more than one pool without approval of the commission. The commission will require evidence of complete separation of ϐlowstreams from separate pools, as ascertained by a pressure test or other acceptable test conducted at the time the packers are set. Subsequently, if packer leakage is suspected, the commission will require the operator to provide proof of complete separation of the pools involved in the completions or make a packer leakage test. At least 24 hours notice must be given so that the packer leakage test may be witnessed by a representative of the commission. 188 W. Northern Lights Blvd., Suite 510, Anchorage, Alaska 99503. Main (907) 334-6745 | Fax (907) 334-6735 Background BPA originally spudded B1-38 on March 20, 2009, drilling the intermediate hole to 12,874’ MD. Due to an unprecedented early breakup of the Sag River drainage, operations were shut-down in April and re-commenced the following winter on February 1, 2010. The well TD’d at 15,778’ MD to test the Kekiktuk formation. A review of the LWD logging suite determined that the primary Kekitktuk interval was composed of sandstones, shales and coals, and had an apparent Oil-Water Contact (OWC). Two sections were perforated within the Kekiktuk, 12 feet from 15,248’- 15,260’ MD and 4’ from 15,324’-15,328’ MD, the latter of which was directly above the OWC and later squeezed. Flow testing of the Kekiktuk resulted in zero pressure at surface and no flow. Despite negative results for the primary target, BPA serendipitously encountered an up-hole oil-bearing zone called the Killian. This newly discovered target lies within the greater offshore canning siltstones and shales and is distinct from the adjacent Badami sands. The Killian is encountered in the B1-38 well at 14,434’-14,497’ MD. BPA perforated 60’ of the Killian interval for production and achieved a maximum flow rate of 1,709 BOPD. In February 2011, a spinner survey determined that the lower 26’ of the Killian were not producing, which led to a re-stimulation in April 2013. To date, B1-38 has produced 744 MBO, 203 MMCFG, and essentially zero water from the Killian. The first producing year saw average daily production between 300- 400 BOPD, and latest production has hovered between 130-150 BOPD. Approximately 1,100’ up-hole from the Killian interval lies the Badami sand interval. Open hole logs indicate prospective Badami sands correlative with those in adjacent producing wells. To offset declining production in the Killian interval, GLA intends to perforate 80’ of the Badami sands and downhole commingle with the production from B1-38. GLA now requests administrative approval to complete and produce productive sands within the Badami oil pool without isolating existing Killian perforations. GLA believes that authorization to downhole commingle Killian and Badami oils will be in the best interest of the State of Alaska and the AOGCC because it will not lead to a loss of reserves or decrease ultimate recovery of either pool, ensuring that waste does not occur. This action will further the mission statement of the AOGCC “to enhance greater ultimate recovery, and protection of health, safety, fresh ground waters, and the rights of all owners to recover their share of the resource.” Geology In the Badami area, the Killian sands are some of the many small, complex, Late Cretaceous-aged Brookian reservoirs that occur within the Canning Formation. These reservoirs consist of sandstone and siltstone deposited as amalgamated turbidite channels and coeval discontinuous thin beds within a mudstone-dominated deep 188 W. Northern Lights Blvd., Suite 510, Anchorage, Alaska 99503. Main (907) 334-6745 | Fax (907) 334-6735 submarine slope and toe-of-slope environment. Drilling samples of this formation are described as: “very fine to fine grained, very calcareous, cemented sandstone that is hard to occasionally friable.” Average porosity is 22% and permeability is estimated at 100 millidarcies. Individual sand beds range from 1 inch in highly bedded facies to over 1 foot in amalgamated zones, with gross sand deposits thickening up to 120 feet. Lateral facies variability is high due to the ever-changing lobe and channel geometries of the basin floor fan. Net to gross reservoir ratios are dependent on the location within the distribution system, with higher ratios in the confined channel axis and lower in the unconfined distal regions. Several deep exploration wells have encountered the Killian sands, such as the East Mikkelsen Bay State No. 1, Mikkelsen Bay 13-9-19 and Badami Unit B1-36, but the B1- 38 was the first to produce from the reservoir, followed by Badami Unit B1-07, which targeted the interval with a lateral completion. The Killian interval as identified in the B1-38 open hole logs is 60’ thick and ranges in porosity from 12-22 percent. A map of key wells on the Badami Unit is included in Exhibit A. The slightly younger (Early Tertiary) Badami reservoir is similar to the Killian in that it comprises several separate turbidite sandstone packages within a mud-dominated basin floor fan complex near the base of slope within the Canning formation. Reservoir quality sands are thin and discontinuous over 30 square miles, and no wells to date have penetrated all identified fan systems, even though the Badami No. 1 well contains the most complete section. The reservoir sandstones are very fine to fine grained, moderately well sorted with porosity ranging from 15 to 21 percent and permeabilities ranging from 1 to 400 millidaries. Within the Badami sands, Amalgamated sand packages represent the best reservoir quality, in terms of porosity, permeability, and greater net to gross ratio. The gamma ray log of B1-38 indicates that the wellbore encountered at least two distinct Badami sand lobes. The lowermost sand lobe from 13,065’-13,124’ is interpreted to be the A5 Sand, which is an informal name used to identify the basal sand that is common to many Badami wells. This is characterized by a sharp base and fining upward succession, with a corresponding increase in resistivity indicating hydrocarbon charge. A shallower un-named lobe is also present from 12,825’-12,883’ which is interpreted as a distinct and disconnected from the A5 sand. It is characterized by a broad coarsening upward succession with a sharp base indicating a rapid return to Canning shale deposition. Exhibit B is a correlation section of the B1- 38 wellbore and offsets, with the Killian and Badami intervals depicted. 188 W. Northern Lights Blvd., Suite 510, Anchorage, Alaska 99503. Main (907) 334-6745 | Fax (907) 334-6735 Reservoir Pressures and Crossﬂow Waste PrevenƟon GLA anticipates negligible crossflow between Badami and Killian reservoirs. No abnormally pressured zones have been encountered in the Brookian sands, and observed downhole pore pressure gradients during drilling were .6 psi/ft, which is consistent with adjacent wells. The top of the Killian perforated zone is 11,061’ TVD and the bottom of the proposed Badami perforations is 10,014’ TVD, which is a difference of 1047’ TVD. The maximum original pressure differential for these intervals is inferred to be less than 630 psi. Since the Killian in this location is production depleted, the current pressure differential is very low, providing for nominal crossflow potential even at static well conditions. Furthermore, this well is produced by artificial gas lift, which introduces additional energy to ensure that fluid from both reservoirs arrives at the surface, minimizing waste in both reservoirs. Lease informaƟon and ProtecƟon of CorrelaƟve Rights The Badami Unit is composed of 9 ADL lease units comprising 17,437 acres. Adjacent to the unit, Savant Alaska, a GLA company, recently acquired 1,280 acres in the fall of 2021 (ADL-394094) and 2,987 (ADL-394163 and ADL-394160) acres in the fall of 2022. B1-38 is located within the Badami Unit and spans ADL-367011, ADL-367011, and ADL-365533. Savant Alaska holds 100% working interest rights in these leases at all depths, with no other working interest entities. Additionally, The State of Alaska is the only royalty recipient. There are no ownership differences across lease lines or across depth intervals, so correlative rights across lease lines will be protected. Scope of Commingling Plans GLA intends to conduct workover operations on B1-38 in Q3 and Q4 of 2023 wherein new penetrations will be added to the existing completion. Ideally, both Badami sands identified in B1-38 would be targets for perforations, however, the 7-5/8 inch intermediate casing shoe is 12,795’-12,835’, which is directly in the position of the upper un-named Badami sand lobe. In order to mitigate risk and preserve the integrity of the wellbore, GLA will bypass the upper lobe and only perforate from 13,044’-13,124’, which corresponds to the lower, A5 sand lobe. A wellbore diagram for B1-38 is included as Exhibit C. AllocaƟon Methods Production trends from the Killian oil pool in B1-38 are well established. Following the initial testing phase after adding perforations to the Badami interval, any incremental oil production will be attributed to the Badami oil pool. In addition, GLA will engage in suitable production logging across open perforations in the event that significant changes are observed concerning the productivity index. Such data will be used to meet the requirements of 20 AAC 25.215(b)(1) (requiring that production from separate pools can be properly allocated. 188 W. Northern Lights Blvd., Suite 510, Anchorage, Alaska 99503. Main (907) 334-6745 | Fax (907) 334-6735 Conclusion Glacier Oil and Gas (GLA), owner of Savant Alaska, operator of the Badami Field, hereby requests administrative approval be granted by the AOGCC to permit the downhole commingling in B1-38 of oil production from both the Killian oil pool and the Badami oil pool as defined in Conservation Order 402 A. Issuance of the requested Conservation Order requires an exception to 20 AAC 25.215(b). Additionally, GLA requests waiver of the requirement to provide complete separation of flowstreams from separate pools as specified in 20 AAC 25.210. GLA believes that authorization to downhole commingle Killian and Badami oils will be in the best interest of the State of Alaska and the AOGCC because it will not lead to a loss of reserves or decrease ultimate recovery of either pool, ensuring that waste does not occur. This action will further the mission statement of the AOGCC “to enhance greater ultimate recovery, and protection of health, safety, fresh ground waters, and the rights of all owners to recover their share of the resource.” Should you require additional information regarding this request, please contact myself at 907-433-3811 or David Pascal (COO) at 907-433-3822. Sincerely, Michael Fairbanks, Geologist and Exploration Manager Glacier Oil and Gas Enclosures: Exhibit 1 (map of Badami PA and area wells) Exhibit 2 (correlation section through key wells, depicting Killian and Badami reservoirs) Exhibit 3 (B1-38 wellbore diagram) Michael Fairbanks Digitally signed by Michael Fairbanks Date: 2023.07.27 09:18:41 -08'00' 188 W. Northern Lights Blvd., Suite 510, Anchorage, Alaska 99503. Main (907) 334-6745 | Fax (907) 334-6735 Map of Badami Unit and area wells Exhibit A 188 W. Northern Lights Blvd., Suite 510, Anchorage, Alaska 99503. Main (907) 334-6745 | Fax (907) 334-6735 Wellbore Diagram of Badami Unit B1-38