Department of Commerce, Community, and Economic Development
Alaska Oil and Gas Conservation Commission
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HomeMy WebLinkAboutCO 432 ECONSERVATION ORDER 432E
Kuparuk River Field
Kuparuk River Unit
Milne Point Unit
Kuparuk River Oil Pool
1. March 4, 2020 CPAI’s request to expand Kuparuk River Unit
2. April 9, 2020 Notice of hearing, affidavit of publication, email
distribution, mailings
3. September 16, 2022 Eni request to modify well testing and production
allocation conditions (CO 432E.001)
ORDERS
STATE OF ALASKA
ALASKA OIL AND GAS CONSERVATION
333 West 71h Avenue
Anchorage, Alaska 99501
Re: THE APPLICATION OF ) Conservation Order No. 432E
CONOCOPHILLIPS ALASKA, INC. )
to expand the areal extent of the ) Kuparuk River Field
Kuparuk River Oil Pool ) Kuparuk River Unit
Milne Point Unit
Kuparuk River Oil Pool
June 29, 2020
IT APPEARING THAT:
1. By application dated March 4, 2020, ConocoPhillips Alaska, Inc. (CPAI), as a working interest
owner and operator of the Kuparuk River Unit (KRU), requested the Alaska Oil and Gas
Conservation Commission (AOGCC) issue an amended order to expand the areal extent of the
Kuparuk River Oil Pool (KROP).
2. Pursuant to 20 AAC 25.540, the AOGCC tentatively scheduled a public hearing for May 12,
2020. On April 9, 2020, the AOGCC published notice of the hearing on the State of Alaska's
Online Public Notices website and on the AOGCC's website, and the AOGCC electronically
transmitted the notice to all persons on the AOGCC's email distribution list and mailed printed
copies of the notice to all persons on the AOGCC's mailing distribution list. On April 9, 2020,
the notice was published in the ANCHORAGE DAILY NEWS.
3. The AOGCC received no comments or request to hold the proposed hearing.
4. On May 4, 2020, the AOGCC cancelled the tentatively scheduled hearing.
FINDINGS:
1. Operators: The KROP encompasses the development areas within the KRU and the adjacent
Milne Point Unit (MPU). CPAI is the operator of the KRU, and Hilcorp Alaska, LLC (Hilcorp)
is the operator of the MPU.
2. Owners and Landowners: CPAI, ConocoPhillips Alaska I1 Inc., Chevron USA Inc., and
ExxonMobil Alaska Production Inc. are the owners of the KRU. Hilcorp, BP Exploration
(Alaska) Inc., Eni Petroleum US LLC, Herbaly Exploration LLC, and George Alan Joyce are
the owners of the MPU. The State of Alaska, Department of Natural Resources (DNR) is the
landowner.
3. Kuparuk River Oil Pool Designation: The KROP is currently defined by Conservation Order
No. 432D (CO 432D) as the accumulation of oil that is common to and correlates with the
accumulation found in the Atlantic Richfield Company West Sak River State No. I well
between the depths of 6,474 and 6,880 feet. CPAI requests to expand the KROP by adding
Township 13 North, Range 8 East, Section 22, Umiat Meridian to the affected area of the pool
Conservation Order 432E
June 29, 2020
Page 2
designated in CO 432D
4. While reviewing the Permit to Drill applications for CPAI's proposed well KRU 3M -23A
(PTD# 218-033) and associated laterals, the AOGCC determined that some of the laterals
would extend onto acreage outside of the KROP affected area. According to statewide
regulations, spacing exceptions would be required to drill these laterals. At that time, it was
discovered that well KRU 3M-27 (PTD# 195-214), its subsequent redrill well KRU 3M -27A
(PTD# 217-053), and lateral well branches drilled from KRU 3M -27A were also located
outside of the affected area of the KROP. CPAI applied for expedited consideration for spacing
exceptions for the KRU 3M -23A laterals, but this request was denied due to the regulatory
requirements to provide public notice and a 30 -day comment period for spacing exceptions. In
its application, CPAI indicated the ultimate solution would be to expand the KROP.
5. During 24 years of production from KRU 3M-27 and KRU 3M -27A, reservoir pressure has
fluctuated between approximately 3,250 and 4,000 psi, which agrees with other pressure
measurements recorded in this portion of the KROP field.
6. A geologic cross section extending from KRU 3M-27 to wells inside the defined KROP
affected area clearly demonstrates that the producing sands extend across the KROP boundary.
7. Seismic interpretation shows that KRU 3M -23A and KRU 3M -27A are in the same fault block
as KROP wells KRU 3M-12 and KRU 3M-20.
8. Fluid property data for KRU 3M-27 and KRU 3M -27A are aligned with the fluid properties
measured within other portions of the KROP.
CONCLUSION:
Geological, geophysical, production, and reservoir data clearly demonstrate that CPAI's proposed
expansion area is in communication with the KROP, and thus expanding the affected area is
appropriate.
NOW, THEREFORE, IT IS ORDERED:
This Conservation Order supersedes CO 432D, dated March 20, 2008. All administrative
approvals issued under CO 432D, except condition 4 of CO 432D.010, are hereby rescinded. The
findings, conclusions, and administrative record for CO 432D are incorporated in this order. In
addition to the requirements of 20 AAC 25, and to the extent such requirements are not superseded
by these rules or other conservation orders, the following rules shall apply to the Kuparuk River
Oil Pool within the affected area as described in Appendix A, attached hereto and made a part
hereof:
Rule 1. Name of Field (Restated From 432C)
The name of the field shall be the Kuparuk River Field. (Source CO 173)
Rule 2. Definition of Pool (Restated From 432C)
The name of the pool in the Kuparuk River Field shall be the Kuparuk River Oil Pool and is defined
as the accumulation of oil that is common to and correlates with the accumulation found in the
Conservation Order 432E
June 29, 2020
Page 3
Atlantic Richfield Company West Sak River State No. 1 well between the depths of 6,474 and
6,880 feet. (Source CO 173)
Rule 3 Well Spacing (Restated From 432C)
There shall be no restrictions as to well spacing except that no pay shall be opened in a well closer
than 500 feet to an external property line where ownership or landownership changes.
Rule 4. Casing and Cementing Requirements (Restated From 4320
a. Casing and cementing requirements are as specified in 20 AAC 25.030, CASING AND
CEMENTING, except as modified below. (Source CO 173)
b. For proper anchorage and to prevent an uncontrolled flow, a conductor casing shall be set at
least 75 feet below the surface and sufficient cement shall be used to fill the annulus behind
the pipe to the surface. (Source CO 173)
c. For proper anchorage, to prevent an uncontrolled flow, and to protect the well from the effects
of permafrost thaw -subsidence and freeze back, a string of surface casing shall be set at least
500 measured feet below the base of the permafrost section but not below 2700 feet true
vertical depth. Sufficient cement shall be used to fill the annulus behind the casing to the
surface. (Source CO 173, CO 193, 203, 209 & 229 — authorized depths of surface casing for
various Drill Sites are detailed in following table)
1) Drill Pad 2Z Kuparuk River oil pool wells may be drilled to a maximum depth of 3250
feet true vertical depth before surface casing is set so long as drilling fluid densities are
monitored and maintained at 10.0 pounds per gallon. (Source CO 190, modified by AA
190.01 - 190.15)
2) Drill Pad 2X and 2C Kuparuk River oil pool wells may be drilled to a maximum depth
of 2975 feet true vertical depth before surface casing is set. (Source CO 190, modified
by AA 190.01 - 190.15)
3) In the event that geologic conditions are not as anticipated, the Commission may
change the maximum depth for setting surface casing by administrative action,
provided a request, in writing, is timely submitted. (Source CO 190)
AA No.
Drill Sites
Authorized Surface Casing
Depth Pursuant to
Rule 4(c) CO 190
AA 190.1
1F
3350' TVD
AA 190.4
2Z
3450' TVD
AA 190.6
2K
3000' TVD
AA 190.7
2K
3452' TVD
AA 190.10
3G
3500' TVD
AA 190.11
IA
3900' TVD
AA 190.12
3R
4200' TVD
AA 190.13
1H
4100' TVD
AA 190.14
1H
4400' TVD
AA 190.15
IY
4400' TVD
Conservation Order 432E
June 29, 2020
Page 4
d. The surface casing, including connections, shall have minimum post -yield strain properties of
0.9% in tension and 1.26% in compression. (Source CO 173)
1) The only types and grades of casing, with threaded connections, that have been
shown to meet the requirements in (d) above and have been approved for use as
surface casing are the following:
(A) 13 3/8 inch, 72 pounds/foot, L-80, Buttress;
(B) 13-3/8 inch, 72 pounds/foot, N-80, Buttress;
(C) 10-3/4 inch, 45.5 pounds/foot, K-55, Buttress;
2) The Commission may approve other types and grades of surface casing upon a
showing that the proposed casing and connection can meet the post -yield strain
requirements in (d) above. This evidence shall consist of one of the following:
(A) Full scale tensile and compressive tests,
(B) Finite element model studies; or,
(C) Other types of axial strain data acceptable to the Commission.
e. Other means for protecting and maintaining the integrity of the well from the effects of
permafrost thaw -subsidence and freeze back may be approved by the Commission upon
application. (Source CO 173)
f. The Commission may approve alternative completion methods (to 20 AAC 25.030(b)(4) and
(5)) upon application and presentation of data that shows the alternatives are based on accepted
engineering principles. Such alternative designs may include: (Source CO 173)
1) Slotted liners, wire wrapped screen liners, or combinations thereof, landed inside
of open hole and may be gravel packed;
2) Open hole completions provided that the casing is set not more than 200 feet above
the productive zone.
Rule 5. Automatic Shut -In Equipment (Rescinded by Other Order No. 66)
Rule 6. Safety Flares (Restated From 4320
Repealed by 20 AAC 25.235.
Authorized Surface Casing
Conservation
Drill Sites
Depth Pursuant to CO 173
Order
Rule 4(c) and 20 AAC
25.035(b)
CO 193
2A, 2B, 2D, 2F, 2G, 2H, 2V
3200' TVD
CO 203
1L, IQ, 1R, 2E, 2U, 2W, 3B, 3C
3800' TVD
CO 209
1R, 2A, 2H, 2T, 3A, 3B, 3C, 3F,
4150' TVD
3J, 3K, 3M, 3N, 30,3Q
CO 229
2M, 3H
3700' TVD
d. The surface casing, including connections, shall have minimum post -yield strain properties of
0.9% in tension and 1.26% in compression. (Source CO 173)
1) The only types and grades of casing, with threaded connections, that have been
shown to meet the requirements in (d) above and have been approved for use as
surface casing are the following:
(A) 13 3/8 inch, 72 pounds/foot, L-80, Buttress;
(B) 13-3/8 inch, 72 pounds/foot, N-80, Buttress;
(C) 10-3/4 inch, 45.5 pounds/foot, K-55, Buttress;
2) The Commission may approve other types and grades of surface casing upon a
showing that the proposed casing and connection can meet the post -yield strain
requirements in (d) above. This evidence shall consist of one of the following:
(A) Full scale tensile and compressive tests,
(B) Finite element model studies; or,
(C) Other types of axial strain data acceptable to the Commission.
e. Other means for protecting and maintaining the integrity of the well from the effects of
permafrost thaw -subsidence and freeze back may be approved by the Commission upon
application. (Source CO 173)
f. The Commission may approve alternative completion methods (to 20 AAC 25.030(b)(4) and
(5)) upon application and presentation of data that shows the alternatives are based on accepted
engineering principles. Such alternative designs may include: (Source CO 173)
1) Slotted liners, wire wrapped screen liners, or combinations thereof, landed inside
of open hole and may be gravel packed;
2) Open hole completions provided that the casing is set not more than 200 feet above
the productive zone.
Rule 5. Automatic Shut -In Equipment (Rescinded by Other Order No. 66)
Rule 6. Safety Flares (Restated From 4320
Repealed by 20 AAC 25.235.
Conservation Order 432E
June 29, 2020
Page 5
Rule 7. Gas -Oil Ratio Tests (Restated From 432C)
Repealed by Conservation Order 262, dated October 23, 1990.
Rule 8. Pressure Surveys (Restated From 432C)
a. A bottom -hole pressure survey shall betaken on each well prior to initial sustained production.
(Source CO 230)
b. The operator shall obtain pressure surveys as needed to effectively manage hydrocarbon
recovery processes subject to an annual plan outlined in (d) of this rule. (Source CO 432)
c. Bottom -hole pressures obtained by a static buildup pressure survey, a 24-hour shut-in
instantaneous test, a multiple flow rate test or an injection fall-off test will be acceptable.
Calculation of bottom -hole pressures from surface data will be permitted for water injection
wells. (Source CO 230)
d. Data from the surveys required in this rule shall be filed with the Commission by April 1 of
the subsequent year in which the surveys are conducted. Along with the survey submittal, the
operator will provide a proposed survey plan for the upcoming year. Reservoir Pressure
Reports, Form 10-412, shall be utilized for all surveys with attachments for complete additional
data. Data submitted shall include, but are not limited to, rate, pressure, time, depths, fluid
gradient, temperature, and other well conditions necessary for complete analysis of each survey
being conducted. The pool pressure datum plane shall be 6,200 feet subsea. (Source CO 230,
432)
e. Results and data from any special reservoir pressure monitoring techniques, tests, or surveys
shall also be submitted as prescribed in (d) of this rule. (Source CO 230)
f. Upon application by the operator, the Commission in its discretion may administratively
approve exceptions to this rule. (Source CO 230)
Rule 9. Productivity Profiles (Restated From 432C)
a. During the first year of production, a production survey shall be run in each well that has
multiple sand intervals open to the well bore. (Source CO 173)
b. Subsequent surveys shall be run in wells that exhibit uncharacteristic changes in performance.
Subsequent surveys shall also be required in wells which have had remedial work performed
to change the production profile unless the remedial work results in only one sand interval
being open to the well bore. (Source CO 173, 276)
c. All completed production surveys taken during a calendar year shall be filed with the
Commission by April 1 of the subsequent year. The Commission may request data be provided
in advance of an annual submittal if required. (Source CO 173, 432)
d. By administrative order, the Commission shall specify additional surveys should it be
determined that the surveys submitted under (a) and (b) are inadequate. (Source CO 173)
Conservation Order 432E
June 29, 2020
Page 6
Rule 10. Production Well Tests (Restated From 4320
a. A well test must be performed on each active producing well at least once every 30 days
b. Twinned production wells commingled through the same surface flowline, must be tested at
least once every 30 days as a combined production stream and the individual wells must be
tested separately at least once every six months or more often if the combined well test
indicates uncharacteristic performance.
Rule 11. Sustained Casine Pressures (Restated From 4320
a. The operator shall conduct and document a pressure test of tubulars and completion equipment
in each development well at the time of installation or replacement that is sufficient to
demonstrate that planned well operations will not result in failure of well integrity,
uncontrolled release of fluid or pressure, or threat to human safety.
b. The operator shall monitor each development well daily to check for sustained pressure, except
if prevented by extreme weather conditions, emergency situations, or similar unavoidable
circumstances. Monitoring results shall be made available for AOGCC inspection.
c. The operator shall notify the AOGCC within three working days after the operator identifies a
well as having (1) sustained inner annulus pressure that exceeds 2000 psig or (2) sustained
outer annulus pressure that exceeds 1000 prig.
d. The AOGCC may require the operator to submit in an Application for Sundry Approvals (Form
10-403) a proposal for corrective action or increased surveillance for any development well
having sustained pressure that exceeds a limit set out in paragraph c of this rule. The AOGCC
may approve the operator's proposal or may require other corrective action or surveillance.
The AOGCC may require that corrective action be verified by mechanical integrity testing or
other AOGCC approved diagnostic tests. The operator shall give AOGCC sufficient notice of
the testing schedule to allow AOGCC to witness the tests.
e. If the operator identifies sustained pressure in the inner annulus of a development well that
exceeds 45% of the burst pressure rating of the well's production casing for inner annulus
pressure, or sustained pressure in the outer annulus that exceeds 45% of the burst pressure
rating of the well's surface casing for outer annulus pressure, the operator shall notify the
AOGCC within three working days and take corrective action. Unless well conditions require
the operator to take emergency corrective action before AOGCC approval can be obtained, the
operator shall submit in an Application for Sundry Approvals (Form 10-403) a proposal for
corrective action. The AOGCC may approve the operator's proposal or may require other
corrective action. The AOGCC may also require that corrective action be verified by
mechanical integrity testing or other AOGCC approved diagnostic tests. The operator shall
give AOGCC sufficient notice of the testing schedule to allow AOGCC to witness the tests.
f Except as otherwise approved by the AOGCC under paragraph (d) or (e) of these rules, before
a shut-in well is placed in service, any annulus pressure must be relieved to a sufficient degree
(1) that the inner annulus pressure at operating temperature will be below 2000 psig and (2)
Conservation Order 432E
June 29, 2020
Page 7
that the outer annulus pressure at operating temperature will be below 1000 psig. However, a
well that is subject to paragraph (c), but not paragraph (e), of these rules may reach an annulus
pressure at operating temperature that is described in the operator's notification to the AOGCC
under paragraph (c), unless the AOGCC prescribes a different limit.
g. For purposes of these rules,
"inner annulus" means the space in a well between tubing and production casing;
"outer annulus" means the space in a well between production casing and surface casing;
"sustained pressure" means pressure that (1) is measurable at the casing head of an annulus,
(2) is not caused solely by temperature fluctuations, and (3) is not pressure that has been
applied intentionally.
Rule 12 Administrative Actions (Restated From CO 432D)
Upon proper application, or its own motion, and unless notice and public hearing is otherwise
required, the Commission 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.
Rule 13 Allowable Gas Offtake (Restated From C0432D)
Gas offtake for the Kuparuk River Oil Pool is authorized with the following conditions:
a. The maximum annual average gas offtake rate is 5 million standard cubic feet of gas per day;
and
b. In the annual surveillance report, the volume of gas offtake, in units of standard cubic feet
and reservoir barrels, must be reported on a monthly basis.
Annual average gas offtake rate means the daily average rate, calculated by dividing the total
volume of gas delivered in a calendar year by the number of days in the year. However, in the
first year that gas offtake is initiated under this rule, the annual average gas offtake rate shall be
determined by dividing the total volume of gas delivered in the calendar year by the number of
days that remained in that year as of the initial delivery.
Rule 14 Surface Comminelin$ of Production with the Oooguruk Unit (OU) (Source CO
432D.007)
a. All KRU Oil Pools —the portion of the Kuparuk River Oil Pool within the KRU bound-
aries (CO 432D), West Sak Oil Pool (CO 406B), Tarn Oil Pool (CO 430A). Tabasco Oil
Pool (CO 435A), and Meltwater Oil Pool (CO 456A) — Production Commineline, Meas-
urement, and Allocation
Conservation Order 432E
June 29, 2020
Page 8
1) 20 AAC 25.228 is waived to allow the following: (1) OU oil production to be processed
in KRU facilities; (2) prior to custody transfer through the KRU LACT meters at the Ku-
paruk Pipeline inlet, OU oil production to be commingled with the production from the
portion of the Kuparuk River Oil Pool within the KRU boundaries and from all other KRU
oil pools; (3) measurement of the combined OU and KRU production through the KRU
LACT meter at the Kuparuk Pipeline inlet; and (4) the allocation of production between
units specified below:
(A) Determination of Total OU Production Sent to KRU
(i) Total OU Oil Production = (MPFM measured oil at OTP shrunk to sales con-
ditions and expressed at standard conditions) X (OU Loss Factor)*
* Loss factor is the allowance for proportionate oil lost in KRUfacilities, such as oil lost in injected water; it is expressed as a
ratio between 0 and I and is dimensionless.
(ii) Total OU Gas Production Sent to KRU = (MPFM measured gas at OTP) +
(Gas measured by Micro Motion ELITE Coriolis meter off OTP slugcatcher)*
* MPFM gas measurement includes gas evolved from shrinkage of liquid hydrocarbon in (a)(1)(A)(i) above; all measurements
are expressed at standard conditions.
(iii) Total OU Water Production sent to KRU = MPFM measured water at OTP
sent to KRU for processing.
(B) Determination of Total KRU Production
(i) KRU Oil Production = (Combined OU and KRU LACT meter volumes)* —
(OU Oil Production)**
* Determined in accordance with 20 AA 25.228.
**Determined under (a)(1)(A)(i) above.
(ii) Total KRU Gas Production = (Gas production measured at KRU facilities) —
(Total OU Gas Production Sent to KRU)*
* Determined under (a)(1)(A)(it) above, all volumes expressed at standard conditions.
(iii)Total KRU Water Production = (Water production measured at KRU facilities)
— (Total OU Water Production Sent to KRU)*
* Determined under (a)(1)(A)(iii) above; all measurements are expressed at standard conditions.
2) CPAI must submit to the Commission, DOG, and DOR monthly files containing the fol-
lowing: (1) daily allocation data for each pool; (2) all data necessary for, and the results
of, the calculations required by (a)(1-2) above; and (3) all other relevant information.
Conservation Order 432E
June 29, 2020
Page 9
3) Additional information requested by the Commission concerning production commin-
gling, measurement, and allocation must be provided in writing to the Commission, DOG,
and DOR within ten (10) working days of the Commission's request.
a) The conditions of the June 25, 2009, letter from CPAI (June 25 Letter) supporting permanent
approval of using multiphase metering for fiscal allocation purposes for the OU must be com-
plied with.
a. the AOGCC shall be given 30 days to review and approve any proposed changes to the Multi-
phase Metering Operations and Maintenance Guidelines, which is identified in Condition 1 of
the June 25 Letter, before such changes may take effect; non -action by the AOGCC within 30
days shall constitute approval of the proposed changes;
b. the logbook identified in Condition 5 of the June 25 Letter is made available to the AOGCC
upon request; and
c. the AOGCC must approve any changes to the 18 -month frequency of audits of the Multiphase
Flow Meters performance and accuracy, which is identified in Condition 7 of the June 25
Letter, before such changes may be implemented.
The MPM Multiphase Metering System is approved for well testing and production allocation
purposes with the following conditions.
a. This approval is for well testing and production allocation purposes only. The MPM Multi-
phase Metering System is NOT approved for custody transfer or fiscal allocation purposes.
b. Before a new MPM Multiphase Metering System can be put into service for well testing and
production allocation purposes CPAI must provide notification to the Commission of the lo-
cation of the new system (i.e. at which facility and/or drill site it was installed) and which
pool(s) it will be used to allocate production for.
c. The MPM Multiphase Metering Systems must be installed, operated, maintained, and cali-
brated in accordance with the manufacturer's requirements.
DONE at Anchorage, Alaska and dated June 29, 2020.
°We'.ItMP.M
Jeremy °iyimry s�snea by
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M. Price w,::,asses W Seamount, Jr.
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Jeremy M. Price Daniel T. Seamount, Jr.
Chair, Commissioner Commissioner
Conservation Order 432E
June 29, 2020
Page 10
AND APPEAL
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 inconsid-
eration 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 ran 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.
Conservation Order 432E
June 29, 2020
Page 11
Appendix A to Conservation Order 432E
Kuparuk River Oil Pool Affected Area (Revised this order)
Conservation Order 432E
June 29, 2020
Page 12
Umiat Meridian
T9N. R6E, U.M. TI IN, R10E, U.M.
SECS. 1,2,11,12,13, and 14. ALL
T9N, R7E, U.M.
Tl IN. RI IE U.M.
SECS. 1,2,3,4,5,6,7,8,9,10,11,12,13,
SECS. 5,6,7,8,16,17,18,19,20,21,22,23,26,27,28,
14,15,16,17 and 18.
29,30,31, 32,33,34,35 and 36.
T9N. R8E U.M.
T12N, R7E, U.M.
SECS. 1,2,3,4,5,6,7,8,9,10,11,12,13,
SECS. 1,2,11,12,13,14,15,16,21,22,23,24,25,26,35 and
14,15,16,17, and 18.
36.
T9N, R9E, U.M.
T12N, R8E, U.M.
SECS. 1,2,3,4,5,6,7,8,9,10,11,12,15,
ALL
16,17and 18.
31,32,33, and 34.
TI IN, R6E, U.M.
T12N R9E U.M.
T9N, R10E U.M.
ALL
SECS. 1,2,3,4,5,6,7,8,9,10,11 and 12.
SECS. 1,2,3,4,5,6,7,8,9,10,11,12,13,14,
TI IM R7E, U.M.
T12N. RIDE, U.M.
T10N, R6E. U.M.
SECS. 1,2,3,4,5,6,7,8,9,10,11,12,14,15,16,17,
SECS. 1,2,3,4,9,10,11,12,13,14,15,16,21,
18,19,20,21,22,23,25,26,27,28,29,30,31,32,33,
22,23,24,25,26,35 and 36.
34,35 and 36.
TION. R7E, U.M.
T12N, RI IE, U.M.
ALL.
SECS. 1,2,3,4,5,6,7,8,9,10,11,12 and 31.
T10N, R8E, U.M.
T13N, R8E, U.M.
ALL.
SECS. 13,14,22,23,24,25,26,27,28,33,34,35 and 36.
TION. R9E, U.M.
TI 3N, R9E, U.M.
ALL.
ALL
TION, R10E, U.M. TON, R10E, U.M.
ALL I ALL
TION, RI IE, U.M.
TON, RI IE, U.M.
SECS. 5,6,7,8,17,18,19 and 20.
SECS. 7,8,16,17,18,19,20,21,27, 28,29,30,
31,32,33, and 34.
TI IN, R6E, U.M.
SECS. 25,26,35 and 36.
T14N R9E U.M.
SECS. 1,2,3,4,5,6,7,8,9,10,11,12,13,14,
TI IM R7E, U.M.
15,16,17,18,20,21,22,23,24,25,26,27,
SECS. 1,2,3,4,9,10,11,12,13,14,15,16,
28,29,32,33,34,35 and 36.
17,18,19,20,21,22,23,24,25,26,27,28,29,
30,31,32,33,34,35 and 36.
T14N, R10E U.M.
SECS. 15,16,17,18,19,20,21,22,27,28,29,
Tl 1N, R8E, U.M.
30,31,32,33,34 and 35
ALL
T15N,R9E U.M.
TI 1N, R9E, U.M.
State lands within SECS. 25,26,27,3 1,
ALL
32,33,34,35, and 36.
Bernie Karl
K&K Recycling Inc. Gordon Severson Richard Wagner
P.O. Box 58055 3201 Westmar Cir. P.O. Box 60868
Fairbanks, AK 99711 Anchorage, AK 99508-4336 Fairbanks, AK 99706
George Vaught, Jr. Darwin Waldsmith
P.O. Box 13557 P.O. Box 39309
Denver, CO 80201-3557 Ninilchik, AK 99639
333 West Seventh Avenue
Anchorage, Alaska 99501-3572
Main: 907.279.1433
Fax: 907.276.7542
www.aogcc.alaska.gov
ADMINISTRATIVE APPROVAL CO 406C.003
ADMINISTRATIVE APPROVAL CO 430A.014
ADMINISTRATIVE APPROVAL CO 432E.001
ADMINISTRATIVE APPROVAL CO 435A.013
ADMINISTRATIVE APPROVAL CO 456A.013
ADMINISTRATIVE APPROVAL CO 596.010
ADMINISTRATIVE APPROVAL CO 597.010
Mr. Andrea Rimoldi
Technical Services Director
Eni US Operating Co Inc.
3700 Centerpoint Dr., Suite 500
Anchorage, AK 99503
Subject: Docket Number: CO-22-013
Multiphase Flow Meters (MPFM)
Revised Conditional Agreement
Oooguruk Unit
Dear Mr. Rimoldi:
By letter dated September 16, 2022, Eni US Operating Co Inc. (Eni) requested the Alaska Oil and
Gas Conservation Commission (AOGCC) revise the conditions of approval for using multiphase
metering for fiscal allocation of production from the Oooguruk Unit (OU) to be consistent with
revised conditions that Eni and ConocoPhillips Alaska Inc. (CPAI) had developed and that were
contained in a letter, which was included with Eni’s application, from CPAI to Eni dated August
25, 2022. The revised conditions are based on lessons learned over the more than a decade’s
experience with the fiscal allocation meters in use at the OU and operating and maintenance
practices.
The AOGCC hereby approves Eni’s request to revise the conditions of approval for using
multiphase metering for fiscal allocation purposes at OU.
The revised conditions of approval are:
1. The Measurement Metering Operations and Maintenance Guidelines set forth as Appendix 4
to the April 14, 2008, joint application to the AOGCC shall be the basis for all current and future
maintenance. Changes to the Guidelines must be mutually agreed upon between Eni and CPAI
and remain under a revision control procedure.
Administrative Approval CO 406C.003, CO 430A.014, CO 432E.001,
CO 435A.013, CO 456A.013, CO 596.010, CO 597.010
February 1, 2023
Page 2 of 4
2. Eni must perform a Fluid Point Reference (FPR) at least every 31 days. If the fluid properties
are known to have changed, Eni must perform a FPR using a representative combined fluid
sample from the onshore separator within four days of the change. Events that may trigger a
change in fluid properties include the introduction of a new well and shutting in, or bringing on,
one or more producing wells.
3. When an extraordinary event occurs, Eni must perform calibration checks on MPFM
secondary instrumentation and recalibrate them if necessary. Secondary instrumentation includes
line temperature transmitter (TL), line pressure transmitter (PL), and differential pressure cell
(DPV). CPAI continues to have sole but reasonable discretion to determine what constitutes an
extraordinary event. Non-exclusive examples of what might reasonably be deemed an
extraordinary events include spikes in differential pressure that put bias in the differential
pressure cell, excessive slugging, and meter over range.
4. The MPFM data acquisition flow computer (DAFC) configuration, as agreed upon by Eni,
CPAI and Schlumberger, will be checked every three months. No changes may be made to the
DAFC configuration file inputs, except for the parameters associated with the updates of the
Empty Pipe References and Fluid Point References, without prior agreement among all three
parties.
5. Eni must record all activity related to the MPFM that measures the Oooguruk total field
production in the electronic MPFM Compliance Log found in the Web-based Report Generator
(WRG). The compliance log must be available for inspection and copying by CPAI. Examples of
activity that must be recorded in the logbook include dates, times and notes pertaining to
calibrations, data validations, changes to the DAFC, audits, nuclear source tests/replacements,
and walk-around findings.
6. Eni is to log MPFM data (at the DAFC) at 1-second intervals. This data will be stored and
retained to allow for post-processing analysis at CPAI's request.
7. As provided for under Section 9.7 of Attachment 4 to the Production Processing and Services
Agreement (PPSA), an audit team that includes Eni, CPAI, and an Independent Party, recognized
as an expert and agreed by other members of the team, shall audit the MPFM performance and
accuracy on a 24-month frequency, or as otherwise agreed by CPAI. The Independent Party will
Chair the audit team.
8. Eni operators who perform unsupervised maintenance on the Schlumberger Vx meters must be
trained and evaluated on their use and maintenance. The Eni Measurement Operations Engineer,
their designee, or qualified testing personnel may train and evaluate personnel on the use and
maintenance of the Vx meters. These persons, as well as Eni Operators who have been trained
and evaluated, may supervise personnel who have not completed training. Training records
should be available upon request.
Administrative Approval CO 406C.003, CO 430A.014, CO 432E.001,
CO 435A.013, CO 456A.013, CO 596.010, CO 597.010
February 1, 2023
Page 3 of 4
Persons filling the role of the Eni Measurement Operations Engineer should be experienced in
the operation and maintenance of Schlumberger Vx meters or multiphase flow meters using
similar technology.
9. Eni must produce a monthly report relating the performance, sampling, and maintenance work
carried out on the MPFM's. The report format is subject to CPAI's approval.
10. Eni must perform metering maintenance activities according to the following frequency
schedule:
OTP MPFM Fiscal Metering Maintenance Procedures
Activity Frequency
Gas, Oil and Water Allocation Metering Daily Checks Daily
General Meter Walk Around and Inspection Daily
Transmitter Calibration Checks: DPV, PL and TL 31 Days
Fluid Point Reference (FPR) Update 31 Days
Nuclear source Wipe Tests 6 Mo
Ex and ExD Checks – Explosion-Proof DAFC Housing 1 Yr
Thermowell Inspections 1 Yr
Recalibrate Dedicated Test Equipment at NIST/Approved Lab 2 Yr
MPFM Venturi Inspection* 3 Yr
Nuclear Source Replacement** 5 Yr
* CPAI, with AOGCC approval, reserves the right to change the frequency of MPFM Venturi
Inspections back to the two-year interval specified in the June 25, 2009, letter to Pioneer that was
subsequently incorporated in the AOGCC's approval.
**CPAI, with AOGCC approval, reserves the right to grant up to five successive one-year
extensions to the replacement interval for the OTP nuclear sources. Eni shall request each one-
year extension, with CPAI approval based on an evaluation of nuclear source performance and
MPFM uncertainty. The maximum length of time between replacement of the OTP nuclear
sources shall not exceed 10 years.
Custody Gas Meter Maintenance Procedures
Activity Frequency
General Meter Walk Around and Inspection Daily
USM Temperature & Pressure Transmitter Calibration Checks 31 Days
USM Meterlink Maintenance/Diagnostics Log 31 Days
Coriolis Smart Meter Verification 31 Days
Coriolis Molecular Weight/Compressibility Update 31 Days
Recalibrate Dedicated Test Equipment at NIST/Approved Lab 2 Yr
Gas Meter Inspection and Cleaning Planned Plan SD
Administrative Approval CO 406C.003, CO 430A.014, CO 432E.001,
CO 435A.013, CO 456A.013, CO 596.010, CO 597.010
February 1, 2023
Page 4 of 4
DONE at Anchorage, Alaska and dated February 1, 2023.
Brett W. Huber, Sr. Jessie L. Chmielowski
Chair, Commissioner Commissioner
cc: Mr. Mike Timmcke
Manager, GKA Operations
ConocoPhillips Alaska
P.O. Box 100360
Anchorage, AK 99510-0360
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.
Jessie L.
Chmielowski
Digitally signed by
Jessie L. Chmielowski
Date: 2023.02.01
13:37:01 -09'00'
Brett W.
Huber. Sr.
Digitally signed by
Brett W. Huber. Sr.
Date: 2023.02.01
14:27:53 -09'00'
From:Carlisle, Samantha J (OGC)
To:AOGCC_Public_Notices
Subject:[AOGCC_Public_Notices] CO 406C.003, CO 430A.014, CO 432E.001, CO 435A.013, CO 456A.013, CO 596.010,
CO 597.010 (Oooguruk)
Date:Wednesday, February 1, 2023 3:02:52 PM
Attachments:MPFM Conditions of approval.pdf
Administrative Approval CO 406C.003, CO 430A.014, CO 432E.001, CO 435A.013, CO
456A.013, CO 596.010, CO 597.010.
Docket Number: CO-22-013
Multiphase Flow Meters (MPFM)
Revised Conditional Agreement
Oooguruk Unit.
Samantha Carlisle
AOGCC 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
Bernie Karl
K&K Recycling Inc.
P.O. Box 58055
Fairbanks, AK 99711
mailed 2/1/23
3
By Samantha Carlisle at 11:17 am, Sep 26, 2022
Page 1 of 3
August 25, 2022
Mr. David Hart
Eni US Operating Company
3700 Centerpoint Dr., Suite 500
Anchorage, AK 95503
RE: Conditional Letter of Approval to Alaska Oil and Gas Conservation Commission
Dear Mr. Hart:
The Alaska Oil and Gas Conservation Commission (AOGCC) granted final approval for use of
Schlumberger Vx Multiphase Flow Meters (MPFM) to measure Oooguruk Unit production for fiscal and
production allocation purposes on July 30, 2009. Permanent approval by the AOGCC required the
support of ConocoPhillips Alaska, Inc. (CPAI), as Operator of the Kuparuk River Unit. CPAI formally gave
their support in a letter to Pioneer Natural Resources Alaska, Inc. (Pioneer) dated June 25, 2009, subject
to 10 conditions outlined in the letter. Then on August 4, 2015, CPAI amended those 10 conditions based
on the operating and maintenance practices of Caelus Natural Resources, LLC (Caelus); the Operator of
the Oooguruk Unit at the time.
CPAI is willing to amend the 10 previously approved conditions based on current operating and
maintenance practices of Eni US Operating Co (Eni), Operator of the Oooguruk Unit and successor to
Caelus as set forth below, and subject to approval by the AOGCC. The revised conditions are as follows:
1. The Measurement Metering Operations and Maintenance Guidelines set forth as Appendix 4 to the
April 14, 2008 joint application to the AOGCC shall be the basis for all current and future
maintenance. Changes to the Guidelines must be mutually agreed upon between Caelus and CPAI
and remain under a revision control procedure.
2. Eni must perform a Fluid Point Reference (FPR) at least every 31 days. If the fluid properties are
known to have changed, Eni must perform a FPR using a representative combined fluid sample
from the onshore separator within four days of the change. Events that may trigger a change in
fluid properties include the introduction of a new well and shutting in, or bringing on, one or more
producing wells.
3. When an extraordinary event occurs, Eni must perform calibration checks on MPFM secondary
instrumentation and recalibrate them if necessary. Secondary instrumentation includes line
temperature transmitter (TL), line pressure transmitter (PL), and differential pressure cell (DPV).
CPAI continues to have sole but reasonable discretion to determine what constitutes an
extraordinary event. Non-exclusive examples of what might reasonably be deemed an
extraordinary event include: spikes in differential pressure that put bias in the differential pressure
cell, excessive slugging, and meter over range.
Mike Timmcke
Manager, GKA Operations
P. O. Box 100360
Anchorage, AK 99510-0360
Phone 907-659-7219
Page 2 of 3
4. The MPFM data acquisition flow computer (DAFC) configuration, as agreed upon by Eni, CPAI
and Schlumberger, will be checked every three months. No changes may be made to the DAFC
configuration file inputs, except for the parameters associated with the updates of the Empty Pipe
References and Fluid Point References, without prior agreement among all three parties.
5. Eni must record all activity related to the MPFM that measures the Oooguruk total field production in
the electronic MPFM Compliance Log found in the Web-based Report Generator (WRG). The
compliance log must be available for inspection and copying by CPAI. Examples of activity that must
be recorded in the logbook include dates, times and notes pertaining to calibrations, data validations,
changes to the DAFC, audits, nuclear source tests/replacements, and walk-around findings.
6. Eni is to log MPFM data (at the DAFC) at 1-second intervals. This data will be stored and retained
to allow for post-processing analysis at CPAI's request.
7. As provided for under Section 9.7 of Attachment 4 to the Production Processing and Services
Agreement (PPSA), an audit team that includes Eni, CPAI, and an Independent Party, recognized as
an expert and agreed by other members of the team, shall audit the MPFM performance and
accuracy on a 24-month frequency, or as otherwise agreed by CPAI. The Independent Party will
Chair the audit team.
8. Eni operators who perform unsupervised maintenance on the Schlumberger Vx meters must be
trained and evaluated on their use and maintenance. The Eni Measurement Operations Engineer,
their designee, or qualified testing personnel may train and evaluate personnel on the use and
maintenance of the Vx meters. These persons, as well as Eni Operators who have been trained
and evaluated, may supervise personnel who have not completed training. Training records
should be available upon request.
Persons filling the role of the Eni Measurement Operations Engineer should be experienced in the
operation and maintenance of Schlumberger Vx meters or multiphase flow meters using similar
technology.
9. Eni must produce a monthly report relating the performance, sampling, and maintenance work
carried out on the MPFM's. The report format is subject to CPAI's approval.
10. Eni must perform metering maintenance activities according to the following frequency schedule:
OTP MPFM Fiscal Metering Maintenance Procedures
Activity Frequency
Gas, Oil and Water Allocation Metering Daily Checks Daily
General Meter Walk Around and Inspection Daily
Transmitter Calibration Checks: DPV, PL and TL 31 Days
Fluid Point Reference (FPR) Update 31 Days
Nuclear Source Wipe Tests 6 Mo
Ex and ExD Checks – Explosion-Proof DAFC Housing 1 Yr
Thermowell Inspections 1 Yr
Recalibrate Dedicated Test Equipment at NIST/Approved Lab 2 Yr
MPFM Venturi Inspection * 3 Yr
Nuclear Source Replacement** 5 Yr
Page 3 of 3
* CPAI, with AOGCC approval, reserves the right to change the frequency of MPFM Venturi Inspections
back to the two-year interval specified in the June 25, 2009 letter to Pioneer that was subsequently
incorporated in the AOGCC's approval.
**CPAI, with AOGCC approval, reserves the right to grant up to five successive one-year extensions to the
replacement interval for the OTP nuclear sources. Eni shall request each one-year extension, with CPAI
approval based on an evaluation of nuclear source performance and MPFM uncertainty. The maximum
length of time between replacement of the OTP nuclear sources shall not exceed 10 years.
Custody Gas Meter Maintenance Procedures
Activity Frequency
General Meter Walk Around and Inspection Daily
USM Temperature & Pressure Transmitter Calibration Checks 31 Days
USM Meterlink Maintenance/Diagnostics Log 31 Days
Coriolis Smart Meter Verification 31 Days
Coriolis Molecular Weight/Compressibility Update 31 Days
Recalibrate Dedicated Test Equipment at NIST/Approved Lab 2 Yr
Gas Meter Inspection and Cleaning Planned Plant SD
Subject to these conditions, and AOGCC's approval, CPAI supports continued use of the MPFMs in their
current application at the Oooguruk Unit. If these conditions are not satisfied or the measurement appears
not to work as reasonably expected, CPAI may petition the AOGCC or take other action to ensure
accurate fiscal metering and otherwise protect the interests of the Kuparuk River Unit Working Interest
Owners. Nothing in this letter is intended to waive or modify any aspect of the Production Processing and
Services Agreement.
We look forward to continuing to work constructively with Eni for continued success of both the Kuparuk
River and the Oooguruk Units.
Sincerely,
Mike Timmcke
Manager, GKA Operations
STATE OF ALASKA
ADVERTISING
ORDER
NOTICE TO PUBLISHER
SUBMIT INVOICE SNOWING ADVERTISING ORDER NO., CERTIFIED
AFFIDAVIT OF PUBLICATION WITH ATTACKED COPY OFADVERTISMENT.
KE
ADVERTISrNG ORDER NUMBER
t
AO_08-20-022
FROM: AGENCY CONTACT:
Jody Colombie/Samantha Carlisle
Alaska Oil and Gas Conservation Commission DATE OF A.O. AGENCY PHONE:
333 West 7th Avenue 4/7/2020 907 279-1433
Anchorage, Alaska 99501
DATES ADVERTISEMENT REQUIRED:
COMPANY CONTACT NAME:
PHONE NUMBER: ASAP
FAX NUMBER:
907 276-7542
TO PUBLISHER:
Anchorage Daily News, LLC
SPECIAL INSTRUCTIONS:
PO Box 140147
Anchorage, Alaska 99514-0174
TYPE OF ADVERTISEMENT:
W LEGAL r DISPLAY i CLASSIFIED i OTHER (Specify below)
DESCRIPTION PRICE
CO -20-006
Initials of who prepared AO:
Alaska Non -Taxable 92-600185
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AOGCC
333 West 7th Avenue
Anchoralze, Alaska 99501
Pae 1 of 1
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All Pa es $
REF Type I Number
Amount Dale Comments
I PVN IVCO21795
2 AD AO -08-20-022
3
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FN AMOUNT Sy ACL Template PGM LCR Object I FY I DIST LIQ
1 20 AOGCC 3046 20
2
3
4
5
P acing uthori m, file:
Purchasing Authority's Signature Telephone Number
1. A.O.#and a Ni ge ust ap
2. The at gis r d f f
resale.
r l invoices and documents relating to this purchase.
u Chapter 32. IRS code. Registration number 92-73-0006 K. Items are for the exclusive use of the state and not for
pl o iseel/Onginal;el;9
:t'<opteF kiiblisher ({aafed)', piv. WI I Fiscal, Receiving
Form: 02-901
Revised: 4/7/2020
Notice of Public Hearing
STATE OF ALASKA
ALASKA OIL AND GAS CONSERVATION COMMISSION
Re: Docket Number: CO -20-006
The application of ConocoPhillips Alaska, Inc. (CPAI) for expansion of the affected area
of Conservation Order No. 432D (CO 432D), which governs the Kuparuk River Oil Pool,
Kuparuk River Field
CPAI, by letter dated March 4, 2020, requests the Alaska Oil and Gas Conservation Commission
(AOGCC) amend CO 432D to expand the affected area of the order.
The AOGCC has tentatively scheduled a public hearing on this application for May 12, 2020, at
10:00 a.m. at 333 West 7s' 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 April 27, 2020.
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 May 1,
2020.
In addition, written comments regarding this application may be submitted to the AOGCC, at 333
West 7v' Avenue, Anchorage, Alaska 99501. Comments must be received no later than 4:30 p.m.
on May 10, 2020, except that, if a hearing is held, comments must be received no later than the
conclusion of the May 12, 2020 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
May 10, 2020.
COVID-19 Notice: If a request for hearing is filed with the AOGCC and COVID-19 related social
distancing requirements will still be in effect at the time of the scheduled hearing the AOGCC will
make a determination on whether to conduct the hearing electronically or postpone the hearing
until after social distancing requirements are eased and will provide notice of its decision (and
ti ns on h participate electronically if that option is selected) via its mailing list.
Daniel T. Sea , Jr.
Commissioner
Notice of Public Hearing
STATE OF ALASKA
ALASKA OIL AND GAS CONSERVATION
Re: Docket Number: CO -20-006
The application of ConocoPhillips Alaska, Inc. (CPAI) for expansion of the affected area
of Conservation Order No. 432D (CO 432D), which governs the Kuparuk River Oil Pool,
Kuparuk River Field
CPAI, by letter dated March 4, 2020, requests the Alaska Oil and Gas Conservation Commission
(AOGCC) amend CO 432D to expand the affected area of the order.
The AOGCC has tentatively scheduled a public hearing on this application for May 12, 2020, at
10:00 a.m. at 333 West 7s' 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 April 27, 2020.
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 May 1,
2020.
In addition, written comments regarding this application may be submitted to the AOGCC, at 333
West 7a Avenue, Anchorage, Alaska 99501. Comments must be received no later than 4:30 p.m.
on May 10, 2020, except that, if a hearing is held, comments must be received no later than the
conclusion of the May 12, 2020 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
May 10, 2020.
COVID-19 Notice: If a request for hearing is filed with the AOGCC and COVID-19 related social
distancing requirements will still be in effect at the time of the scheduled hearing the AOGCC will
make a determination on whether to conduct the hearing electronically or postpone the hearing
until after social distancing requirements are eased and will provide notice of its decision (and
instructions on how to participate electronically if that option is selected) via its mailing list.
//signature on file//
Daniel T. Seamount, Jr.
Commissioner
Bernie Karl
K&K Recycling Inc. Gordon Severson Penny Vadla
P.O. Box 58055 3201 Westmar Cir. 399 W. Riverview Ave.
Fairbanks, AK 99711 Anchorage, AK 99508-4336 Soldotna, AK 99669-7714
George Vaught, Jr. Darwin Waldsmith Richard Wagner
P.O. Box 13557 P.O. Box 39309 P.O. Box 60868
Denver, CO 80201-3557 Ninilchik, AK 99639 Fairbanks, AK 99706
Colombie, Jody J (CED)
From: Colombie, Jody J (CED)
Sent: Tuesday, April 7, 2020 4:56 PM
To: Seamount, Dan T (DOA); Jessie Chmielowski; Jeremy Price; Tab Ballantine
Subject: FW: [EXTERNAL]RE: DRAFT: Kuparuk Oil Pool Expansion Application
Attachments: FINAL-Kuparuk Oil Pool Expansion Application.pdf
fyi
From: Kozak, Devin<Devin.Kozak@conocophillips.com>
Sent: Wednesday, March 4, 2020 12:53 PM
To: Roby, David S (CED) <dave.roby@alaska.gov>
Subject: RE: [EXTERNAL)RE: DRAFT: Kuparuk Oil Pool Expansion Application
Good afternoon Mr. Roby,
Attached is the Kuparuk Oil Pool Expansion application, updated to incorporate your notes below. Please, let me know if
any additional information, edits, or action is needed from me to complete this application process.
Thank you,
Devin
From: Roby, David S (CED) <dave.roby@alaska.gov>
Sent: Thursday, February 20, 2020 6:23 PM
To: Kozak, Devin<Devin.Kozak@conocophillips.com>
Subject: [EXTERNAL]RE: DRAFT: Kuparuk Oil Pool Expansion Application
Devin,
Just a couple of things.
1) Please add units for the y-axis of figures 4-6, either to the axis itself or in the title like was done on figure 7.
2) Please annotate figures 4-8 to indicate when the drilling of 27A and its laterals occurred.
Thanks,
Dave Roby
907-793-1232
CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, contains information from the Alaska Oil and Gas Conservation
Commission (AOGCC), State of Alaska and is for the sole use of the intended recipient(s). It may contain confidential and/or privileged information.
The unauthorized review, use or disclosure of such information may violate state or federal law. If you are an unintended recipient of this e-mail,
please delete it, without first saving or forwarding it, and, so that the AOGCC is aware of the mistake in sending it to you, contact Dave Roby at 907-
793-1232 or dave.robv@alaska.gov.
From: Kozak, Devin<Devin.Kozak@conocophillips.com>
Sent: Wednesday, February 5, 20204:15 PM
To: Roby, David S (CED) <dave.robv@alaska.gov>
Subject: DRAFT: Kuparuk Oil Pool Expansion Application
Good afternoon Mr. Roby,
Attached is a draft copy of the Kuparuk Oil Pool expansion application. Please review and let me know if any additional
information is needed to go forward with the process. If not, I will resubmit this copy to you as the 'Final' copy.
Thank you,
Devin Kozak
Drillsite Petroleum Engineer I ConocoPhillips
KRU I CPF3 NIMROQ
Office: 907-263-41211 Cell: 254-203-3564
ConocoPhillips
March 41h, 2020
Dave Roby
State of Alaska, Oil & Gas Conservation Commission
333 W. 7th Ave., Ste. 100
Anchorage, AK 99501-3539
Dear Commissioner:
Devin R. Kozak
Petroleum Engineer -3M
North Slope Operations and Development
ConocoPhillips Alaska, Inc.
ATO -1362
700 G Street
Anchorage, AK 99501-3448
Phone 907.263.4121
ConocoPhillips Alaska, Inc. ("ConocoPhillips") respectfully requests an expansion of the Kuparuk River
Oil Pool described in Conservation Order #432D (CO) to include T13N, R8E Section 22. The proposed
expansion area is within the Area Injection Order #2C (AID) boundaries and therefore no changes need
to be made to the AID. No rule changes to the CO or AID are being proposed by ConocoPhillips.
Approval of the application would permit these operations to continue to be conducted within the
existing Kuparuk River Field and Participating Area.
Basis for Request
On May 71h, 2018, the Commission Staff advised ConocoPhillips that the application for permit to drill
northern laterals from the 3M-23 (PTD# 193-187), located on T13N, R8E Section 27, crossed into the
northern area of T13N, R8E section 22, southeast quarter was outside of the affected area of the
Kuparuk River Oil Pool. During the same application process, it was discovered that an adjacent well in
the same section, 3M-27 (PTD# 195-214), is outside of the affected area of the Kuparuk River Oil Pool.
3M-27 was permitted in 1995 as a Kuparuk River Oil Pool well and has been on production since that
time. ConocoPhillips applied for a Spacing Exception Waiver of 20 AAC 25.055 for KRU 3M-23, in that
request ConocoPhillips stated that a remedial action to apply to expand the affected area of the
Kuparuk River Oil Pool to include T13N, R8E Section 22, where the existing well KRU 31VI-27 is located.
This application is in effort to fulfill the remedial action and operate within the Kuparuk River Oil Pool.
Please contact Devin Kozak (263-4121) if you have questions or require clarification of this request.
Sincerely,
Devin R. Kozak
Petroleum Engineer
ConocoPhillips Alaska, Inc.
I. Introduction
The proposed addition to the Kuparuk River Oil Pool (T13N, R8E Section 22), is located northwest of
existing Kuparuk River Unit drill site 3M (Figure 1) and is in pressure communication with the main
Kuparuk River Field. Detailed geological and engineering information describing the expansion area
associated with this application is provided below. ConocoPhillips is presenting this information on
behalf of the Greater Kuparuk Area (GKA) Working Interest Owners (WIGS). The information provided
will enable the Commission to issue a decision and finding to expand the CO and NO to include T13N,
R8E Section 22.
3M-27 (PTD# 195-214) was permitted in 1995 as a Kuparuk River Oil Pool well and has been on
production since that time. In April 2017, permits were approved to re -drill the existing 3M-27
development well as 3M -27A (PTD# 217-053). Furthermore, permits to drill additional laterals for new
wellbore segments of 3M -27A were also approved. The laterals include, 3M-27AL1 (PTD# 217-054),
3M-27AL2 (PTD# 217-055), 3M-27AL2-01 (PTD# 217-056), and 3M-27AL3 (PTD# 217-057) were drilled
outside of the existing Kuparuk River Oil Pool specifically in T13N, R8E Section 22.
On May 7th, 2018, the Commission Staff advised ConocoPhillips that the application for permit to drill
northern laterals from the 3M-23 (PTD# 193-187), located on T13N, R8E Section 27, crossed into the
northern area of T13N, R8E section 22, southeast quarter was outside of the affected area of the
Kuparuk River Oil Pool. During the same application process, it was discovered that an adjacent well in
the same section, 3M-27 (PTD# 195-214), is outside of the affected area of the Kuparuk River Oil Pool.
ConocoPhillips applied for a Spacing Exception Waiver of 20 AAC 25.055 for KRU 3M-23, in that request
ConocoPhillips stated that a remedial action to apply to expand the affected area of the Kuparuk River
Oil Pool to include T13N, R8E Section 22, where the existing well KRU 3M-27 is located. This application
is in effort to fulfill the remedial action and operate within the Kuparuk River Oil Pool.
II. Geology
Introduction
In this section, the geological data supporting the 3M expansion area application to the commission is
discussed.
Geological Interpretation of the 3M Expansion Area
Within the 3M pool expansion area, the 3M-27 deviated well was drilled in 1996 followed by the 3M-
27 coil tubing drilling (CTD) laterals (3M -27A, 3M-27AL1, 3M-27AL2, 3M-27AL2-01, 3M-27AL2PB1, 3M-
27AL3) in 2017. All wells penetrated the reservoir quality sands in the Kuparuk C4 and Kuparuk Al
intervals at a depth of approximately 6150-6275 feet TVD. As expected, the upper Kuparuk A reservoir
sands and B unit were absent being fully truncated by the Lower Cretaceous Unconformity (LCU) in this
area.
The 3M-27 and its associated CTD laterals are geologically connected with the main Kuparuk Oil Pool.
Structurally the 3M-27 well is located within the same fault block as the offset 3M-12, 3M-20, and 3M-
23 wells that are within the Kuparuk Oil Pool (Figure 2). Additionally, reservoir continuity can be seen
in Figure 3, a cross section showing the 3M-27 and wells within the Kuparuk Oil Pool to the east.
III. Reservoir
Introduction
In this section, the reservoir data supporting the 3M expansion area application to the commission is
discussed.
Rate and Pressure History
The measured pressure on 3M-27 has ranged between approximately 3250 —4000 psi at datum is
evidence that the well is in communication with the main Kuparuk Reservoir. The entire pressure
surveillance history can be seen in Figure 4. Production rates have confirmed the presence of
hydrocarbons in the proposed expansion area through the production of 3M-27. The oil production
rate and total liquid production rate history of 3M-27 can be seen in Figure 5 and Figure 6,
respectively.
Reservoir Fluid Properties
Reservoir fluid properties are provided from routine well testing of 3M-27. The API gravities from these
samples ranged from approximately 20-250 and the initial formation GOR ranged from approximately
400-700 SCF/STB. The API gravity and formation GOR sampling history can be seen in Figure 7 and
Figure 8, respectively. The samples from 3M -27A provide evidence that the fluid properties in the
proposed expansion area are in line with crude properties in the main Kuparuk River Field.
IV. Summary
ConocoPhillips request an expansion of the Kuparuk River Oil Pool described in Conservation Order
#432D to include T13N, R8E Section 22. ConocoPhillips has provided geologic and engineering evidence
to prove that the proposed expansion area is in communication with the existing Kuparuk River Oil
Pool. No rule changes to Conservation Order #432D are being proposed by ConocoPhillips. Approval of
the application would permit operations to continue to be conducted within the existing Kuparuk River
Field and Participating Area.
V. Figures
The figures that are referenced to in the Conservation Order expansion application are attached below.
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KUPawk Conservation order Oil Pool Boundary
O Kuparuk Area Injection Order Boundary
Kupuruk River Unit Kupauk Participating Area
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Kuparuk River Unit Tract
Figure 1— Proposed expansion area, T13NR8E Sec. 12
Figure 2 — Structure map of the proposed expansion area T13NRBE Sec.
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Well: 3M-27 Well: 3M-20
Well: 3M-12 Weil: 3M -OB
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--- Drilling of 3M -27A and Laterals Complete I Rig Release 2017-09-23
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Figure 4 — Pressure surveillance history of 3M-27
3M-27 Well Test Oil Rwts•e
--- Drilling of 3M -27A and Laterals Complete I Rig Release 2017-09-23
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Figure 5 — Oil production well test history of 3M-27
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--- Drilling of 3M -27A and Laterals Complete I Rig Release 2017-09-23
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Figure 6 — Liquid rate well test history of 3M-27
3M-27 Well Test Formation GOR
Drilling of 3M -27A and Laterals Complete I Rig Release 2017-09-23
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Figure 7 — Formation GOR sampling history of 3M-27
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3M-27 API Gravity
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--- Drilling of 3M -27A and Laterals Complete I Rig Release 2017-09-23 1
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Figure 8 — API gravity sampling history of 3M-27