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Home My WebLink AboutO 202Other Order 202 Docket Number: OTH-23-017 1. June 1, 2023 Notice of investigation and Request for information to Eni 2. June 7, 2023 Email requesting additional time and AGOCC response 3. June 23, 2023 Eni response to Notice of investigation and Request for information 4. August 10, 2023 Notice of proposed enforcement action to Eni 5. August 24, 2023 Eni response and request for informal review 6. October 24, 2023 Eni civil penalty payment STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Avenue Anchorage Alaska 99501 Re: Failure to Obtain Sundry Approval for Rigless Workovers, Nikaitchuq and Oooguruk Units ) ) ) ) ) Other Order 202 Docket Number: OTH-23-017 October 3, 2023 DECISION AND ORDER On August 10, 2023, the Alaska Oil and Gas Conservation Commission (AOGCC) issued a Notice of Proposed Enforcement Action (Notice) to Eni Petroleum US LLC (Eni) for failing to obtain approval for rigless workovers. The Notice proposed a specific corrective action and a $60,000 civil penalty under AS 31.05.150(a). Eni timely requested informal review and submitted a written response which the AOGCC has considered as part of its informal review process. This decision and order now follows. Summary of Proposed Enforcement Action: The Notice proposed a $60,000 civil penalty for failing to obtain prior approval for certain rigless workovers. The Notice also proposed that Eni develop a Sundry Matrix for AOGCC approval that clearly delineates routine well workover operations that can be excluded from certain application, pre-approval, and reporting requirements for oil pools within the Nikaitchuq and Oooguruk Units. Violation - Failure to Obtain Approval for Rigless Workovers: On May 4, 2023, an AOGCC Inspector witnessed a mechanical integrity test at Nikaitchuq water injection well SI06-NE1 (PTD 2191650) after Eni completed a rigless workover to install a tubing patch.1 The Inspector requested a copy of the approved sundry application from Eni’s field representative to verify the required test pressure; Eni was unable to provide a copy of the sundry approval. Nikaitchuq SI06-NE1 passed the witnessed mechanical integrity test. A review of AOGCC records found no sundry approval for the SI06-NE1 tubing patch. On May 11, 2023, the AOGCC sent a notice of investigation to Eni, requesting a list of wells where rigless interventions were performed from January 1, 2020, to April 30, 2023. Eni responded with the requested list of wells on June 23, 2023. The AOGCC investigation identified numerous rigless well interventions done by Eni without prior approval as required by 20 AAC 25.280 (“Workover operations”). Specifically, the AOGCC determined that Eni completed 12 rigless workovers without first obtaining the required sundry approval per 20 AAC 25.280(a)(5) for the following wells located within the Nikaitchuq Unit: OI15-S4, OI13-03, OI06-05, OI20- 1 The tubing patch was installed on April 24, 2023, and the well placed on injection April 26, 2023. Other Order 202 October 3, 2023 Page 2 of 4 07, SI26-NW2, SI29-S2, OP26-DSP02, SP30-W1, SI07-SE4, OI20-07, SI11-FN6, SI06-NE1. The Notice proposed a $5000 fine for each incident for a total of $60,000. Informal Review: Eni met with AOGCC staff on July 24, 2023, to discuss the information submitted in response to AOGCC’s investigation, and to begin discussions about developing a Sundry Matrix for AOGCC approval that clearly delineates routine well workover operations that can be excluded from certain application, pre-approval, and reporting requirements for oil pools within the Nikaitchuq and Oooguruk Units. On August 24, 2023, Eni responded to the Notice, requesting the AOGCC “conduct an informal review of its proposed action under 20 AAC 25.535(c) and reassess the proposed civil penalty.” Eni’s letter constitutes a request for informal review of the AOGCC’s decision, and the AOGCC has reviewed the evidence and arguments contained in the Eni’s August 24, 2023, letter as its “documentary material and … written or oral statement” under 20 AAC 25.535(d). 20 AAC 25.280(a)(5) requires that “Application for Sundry Approvals … must be approved…in order to…conduct…repairs to the well.” Eni suggests its misunderstanding of the type of operations requiring a sundry application was in part based on the regulation referencing “repairs to the well” instead of explicitly referencing repairs to tubing or casing in the well like the tubing patches at issue here. Eni’s exceptionally narrow interpretation of what constitutes “repairs to the well” is not persuasive, particularly when considering the AOGCC’s own regulatory definition of “well.” The definition of a “well” in 20 AAC 25.990(74) includes “a hole penetrating the earth, usually cased with steel pipe…” Moreover, as Eni would be aware, every Permit to Drill a well and every Application for Sundry Approval to work over a well requires details of the casing and tubing used in that well. Simply put, Eni’s argument that somehow repairs to the well tubing or casing does not constitute “repairs to the well” is not reasonable when 20 AAC 25.280(a)(5) is considered within the context of AOGCC’s definition of a well and its permitting forms. Moreover, it is unclear why Eni would choose to proceed on numerous workover operations based on its narrow interpretation of the AOGCC regulations instead of first confirming its understanding with the AOGCC.2 Likewise, Eni’s argument that the SI06-NE1 well was the “first time it was suggested to Eni that a sundry application might be required for a tubing patch” is justification for eliminating or significantly reducing the penalty amount assumes that the AOGCC is somehow responsible for preemptively ensuring an operator’s activities are compliant with the requirements – an inaccurate assumption. The AOGCC notes that there have been 4 civil penalty actions imposed on Eni – including repeat violations for failing to perform required mechanical integrity tests on injection wells. There have also been 3 Notice of Violation (NOV) enforcement actions where a civil penalty was not imposed. Eni argues that there is no need to deter similar behavior because of its full cooperation with the 2 Eni’s Written Response to Notice of Proposed Enforcement repeatedly references its misunderstanding as support for reducing the penalty. On page 2, Eni states that it “did not understand a sundry was required for a tubing patch installation”; also on page 2, Eni refers to its good faith interpretation of the regulation. On page 3 Eni states “this violation was the result of good faith misinterpretation”; also on page 3, Eni states “it was a good faith misunderstanding”. Other Order 202 October 3, 2023 Page 3 of 4 investigation and transparency. While that cooperation is expected and appreciated, Eni should recognize that AS 31.05.150(g)(7) includes deterring similar behavior of others similarly situated – in other words, other operators with injection and producing wells that require repairs within the life cycle of the well. The factors in AS 31.05.150(g) were considered in determining the appropriate penalty. Eni’s failure to make a good faith effort in its attempts to comply with the workover regulation, track record of regulatory non-compliance, and need to deter similar behavior in future operations are the factors which most heavily influenced the AOGCC’s decision, and the penalty being assessed. The proposed civil penalty had already accounted for Eni’s efforts to commence work on the Sundry Matrix and commence submitting sundry applications for planned rigless workovers – work that was initiated after being informed that the AOGCC was investigating but prior to the Notice. The AOGCC notes that the civil penalty amount is also mitigated by considering only 12 injector tubing patches as non-compliant instead of 34 rigless operations that should have been pre-approved by the AOGCC. In addition, the civil penalty is mitigated by limiting the timeframe of our investigation and by not considering per-day penalties for each well that was out of compliance. The effort made by Eni to correct the violation and prevent future violations, Eni’s cooperation with the investigation, and lack of injury to the public and the environment were also factored in mitigating the proposed penalty amount. Findings and Conclusions: The AOGCC finds that Eni failed to comply with 20 AAC 25.280. Eni has not provided any information that would warrant changing the proposed penalty amount. Now Therefore It Is Ordered That: Eni is assessed a civil penalty in the amount of $60,000 for failing to obtain approval prior to commencing rigless workovers where tubing patches were installed. If this Order is not appealed, the fine must be paid within 30 days of its issuance. If appealed, the fine will be held in abeyance until the appeal process is complete. In addition to the civil penalty, Eni is to develop a Sundry Matrix for AOGCC approval that clearly delineates routine well workover operations that can be excluded from certain application, pre-approval, and reporting requirements for oil pools within the Nikaitchuq and Oooguruk Units. As an Operator involved in an enforcement action, Eni is required to preserve documents concerning the above action until after resolution of the proceeding. Done at Anchorage, Alaska and Dated October 3, 2023. Brett W. Huber, Sr. Jessie L. Chmielowski Gregory C. Wilson Chair, Commissioner Commissioner Commissioner Brett W. Huber, Sr. Digitally signed by Brett W. Huber, Sr. Date: 2023.10.03 12:59:40 -08'00' Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2023.10.03 13:07:00 -08'00' Gregory Wilson Digitally signed by Gregory Wilson Date: 2023.10.03 13:17:57 -08'00' Other Order 202 October 3, 2023 Page 4 of 4 cc: AOGCC Inspectors Phoebe Brooks (AOGCC) RECONSIDERATION AND APPEAL NOTICE Pursuant to 20 AAC 25.535(d), this order becomes final 11 days after it is issued unless within 10 days after it is issued the person files a written request for a hearing, in which case the proposed decision or order is of no effect. If the person requests a hearing, the commission will schedule a hearing under 20 AAC 25.540. As provided in AS 31.05.080(a), within 20 days after this order becomes final as discussed above, 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] Other Order 202 (Eni) Date:Tuesday, October 3, 2023 1:45:22 PM Attachments:other 202.pdf Re: Failure to Obtain Sundry Approval for Rigless Workovers, Nikaitchuq and Oooguruk Units 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 6 ENI US OPERATING CO. INC. 1200 Smith, Suite 1700 Houston, TX 77002 us operating 713-393-6100 00001 7619 CKS NE 23252 - 0002093761 NNNNNNNNNNNN 2925100005210 K619A1 C ALASKA OIL AND GAS CONSERVATION COMMISSION AOGCC 333 WEST 7TH AVENUE ANCHORAGE AK 99501 VENDOR NO: 0000457972 2093761 PAGE: 1 of 1 DATE: October 19, 2023 CHECK NUMBER: 2093761 AMOUNT PAID: $60,000.00 ACCOUNT NUMBER: 113344023 En! US OperatingCo.lnc.05 DIRECT INQUIRIES TO: 713-393-6100 DATE INVOICE NUMBER DESCRIPTION GROSSAMOUNT DISCOUNT NET AMOUNT 10/06/23 CHKRE010062023 CIVIL PENALTY DOCKET NUMBER OT $60,000.00 $000 $600D000 TOTALS $60,000.00 $0.00 $60,000.00 RECFW OCT ? 4 2923 AOCCC us operating ENI US OPERATING CO. INC. 1200 Smith, Suite 1700 Houston, TX 77002 713-393-6100 PAY ALASKA OIL AND GAS CONSERVATION TO THE COMMISSION AOGCC ORDER OF: 333 WEST 7TH AVENUE ANCHORAGE, AK 99501 CHECK 32-61 NUMBER 2093761 1110 October 19, 2023 "` VOID AFTER 180 DAYS "` CHECKAMOUNT $60r000.00 EXACTLY ""*'°*"*'60,000 DOLLARS AND 00 CENTS JPMorTX Chase Bank, N.A. Dallas,, TX Authorized Sipahve 11*2093761,18 t:&i1,0006&1tt: L1,3344023110 STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Avenue Anchorage Alaska 99501 Re: Failure to Obtain Sundry Approval for ) Other Order 202 Rigless Workovers, Nikaitchuq and ) Oooguruk Units ) Docket Number: OTH-23-017 October 3, 2023 DECISION AND ORDER On August 10, 2023, the Alaska Oil and Gas Conservation Commission (AOGCC) issued a Notice of Proposed Enforcement Action (Notice) to Eni Petroleum US LLC (Eni) for failing to obtain approval for rigless workovers. The Notice proposed a specific corrective action and a $60,000 civil penalty under AS 31.05.150(a). Eni timely requested informal review and submitted a written response which the AOGCC has considered as part of its informal review process. This decision and order now follows. Summary of Proposed Enforcement Action: The Notice proposed a $60,000 civil penalty for failing to obtain prior approval for certain rigless workovers. The Notice also proposed that Eni develop a Sundry Matrix for AOGCC approval that clearly delineates routine well workover operations that can be excluded from certain application, pre -approval, and reporting requirements for oil pools within the Nikaitchuq and Oooguruk Units. Violation - Failure to Obtain Approval for Rigless Workovers: On May 4, 2023, an AOGCC Inspector witnessed a mechanical integrity test at Nikaitchuq water injection well SI06-NE 1 (PTD 2191650) after Eni completed a rigless workover to install a tubing patch.' The Inspector requested a copy of the approved sundry application from Eni's field representative to verify the required test pressure; Eni was unable to provide a copy of the sundry approval. Nikaitchuq SI06-NEI passed the witnessed mechanical integrity test. A review of AOGCC records found no sundry approval for the SI06-NE 1 tubing patch. On May 11, 2023, the AOGCC sent a notice of investigation to Eni, requesting a list of wells where rigless interventions were performed from January 1, 2020, to April 30, 2023. Eni responded with the requested list of wells on June 23, 2023. The AOGCC investigation identified numerous rigless well interventions done by Eni without prior approval as required by 20 AAC 25.280 ("Workover operations"). Specifically, the AOGCC determined that Eni completed 12 rigless workovers without first obtaining the required sundry approval per 20 AAC 25.280(a)(5) for the following wells located within the Nikaitchuq Unit: OI15-S4, 0I13-03, 0I06-05, 0I20- ' The tubing patch was installed on April 24, 2023, and the well placed on injection April 26, 2023 Other Order 202 October 3, 2023 Page 2 of 4 07, SI26-NW2, SI29-S2, OP26-DSP02, SP30-WI, SI07-SE4, OI20-07, SI11-FN6, SI06-NEI. The Notice proposed a $5000 fine for each incident for a total of $60,000. Informal Review: Eni met with AOGCC staff on July 24, 2023, to discuss the information submitted in response to AOGCC's investigation, and to begin discussions about developing a Sundry Matrix for AOGCC approval that clearly delineates routine well workover operations that can be excluded from certain application, pre -approval, and reporting requirements for oil pools within the Nikaitchuq and Oooguruk Units. On August 24, 2023, Eni responded to the Notice, requesting the AOGCC "conduct an informal review of its proposed action under 20 AAC 25.535(c) and reassess the proposed civil penalty." Eni's letter constitutes a request for informal review of the AOGCC's decision, and the AOGCC has reviewed the evidence and arguments contained in the Eni's August 24, 2023, letter as its "documentary material and ... written or oral statement" under 20 AAC 25.535(d). 20 AAC 25.280(a)(5) requires that "Application for Sundry Approvals ... must be approved... in order to ... conduct ... repairs to the well. " Eni suggests its misunderstanding of the type of operations requiring a sundry application was in part based on the regulation referencing "repairs to the well" instead of explicitly referencing repairs to tubing or casing in the well like the tubing patches at issue here. Eni's exceptionally narrow interpretation of what constitutes "repairs to the well" is not persuasive, particularly when considering the AOGCC's own regulatory definition of "well." The definition of a "well" in 20 AAC 25.990(74) includes "a hole penetrating the earth, usually cased with steel pipe..." Moreover, as Eni would be aware, every Permit to Drill a well and every Application for Sundry Approval to work over a well requires details of the casing and tubing used in that well. Simply put, Eni's argument that somehow repairs to the well tubing or casing does not constitute "repairs to the well" is not reasonable when 20 AAC 25.280(a)(5) is considered within the context of AOGCC's definition of a well and its permitting forms. Moreover, it is unclear why Eni would choose to proceed on numerous workover operations based on its narrow interpretation of the AOGCC regulations instead of first confirming its understanding with the AOGCC.2 Likewise, Eni's argument that the SI06-NE 1 well was the "first time it was suggested to Eni that a sundry application might be required for a tubing patch" is justification for eliminating or significantly reducing the penalty amount assumes that the AOGCC is somehow responsible for preemptively ensuring an operator's activities are compliant with the requirements — an inaccurate assumption. The AOGCC notes that there have been 4 civil penalty actions imposed on Eni — including repeat violations for failing to perform required mechanical integrity tests on injection wells. There have also been 3 Notice of Violation (NOV) enforcement actions where a civil penalty was not imposed. Eni argues that there is no need to deter similar behavior because of its full cooperation with the z Eni's Written Response to Notice of Proposed Enforcement repeatedly references its misunderstanding as support for reducing the penalty. On page 2, Eni states that it "did not understand a sundry was required for a tubing patch installation"; also on page 2, Eni refers to its good faith interpretation of the regulation. On page 3 Eni states "this violation was the result of good faith misinterpretation"; also on page 3, Eni states "it was a good faith misunderstanding". Other Order 202 October 3, 2023 Page 3 of 4 investigation and transparency. While that cooperation is expected and appreciated, Eni should recognize that AS 31.05.150(g)(7) includes deterring similar behavior of others similarly situated — in other words, other operators with injection and producing wells that require repairs within the life cycle of the well. The factors in AS 31.05.150(g) were considered in determining the appropriate penalty. Em's failure to make a good faith effort in its attempts to comply with the workover regulation, track record of regulatory non-compliance, and need to deter similar behavior in future operations are the factors which most heavily influenced the AOGCC's decision, and the penalty being assessed. The proposed civil penalty had already accounted for Eni's efforts to commence work on the Sundry Matrix and commence submitting sundry applications for planned rigless workovers — work that was initiated after being informed that the AOGCC was investigating but prior to the Notice. The AOGCC notes that the civil penalty amount is also mitigated by considering only 12 injector tubing patches as non -compliant instead of 34 rigless operations that should have been pre -approved by the AOGCC. In addition, the civil penalty is mitigated by limiting the timeframe of our investigation and by not considering per -day penalties for each well that was out of compliance. The effort made by Eni to correct the violation and prevent future violations, Eni's cooperation with the investigation, and lack of injury to the public and the environment were also factored in mitigating the proposed penalty amount. Findings and Conclusions: The AOGCC finds that Eni failed to comply with 20 AAC 25.280. Eni has not provided any information that would warrant changing the proposed penalty amount. Now Therefore It Is Ordered That: Eni is assessed a civil penalty in the amount of $60,000 for failing to obtain approval prior to commencing rigless workovers where tubing patches were installed. If this Order is not appealed, the fine must be paid within 30 days of its issuance. If appealed, the fine will be held in abeyance until the appeal process is complete. In addition to the civil penalty, Eni is to develop a Sundry Matrix for AOGCC approval that clearly delineates routine well workover operations that can be excluded from certain application, pre -approval, and reporting requirements for oil pools within the Nikaitchuq and Oooguruk Units. As an Operator involved in an enforcement action, Eni is required to preserve documents concerning the above action until after resolution of the proceeding. Done at Anchorage, Alaska and Dated October 3, 2023. Brett W Digitally signed by J2551f LDigitally signed by Gregory Digitally signed L. Brett W. Huber, Sr. Jessie L. Chmielowski by Gregory Wilson Date: 2023.10.03 Chmielowski Date:2023.10.03 Date: 2023.10.03 Huber, Sr. 12:59:40-08'00' 13071i0-08'00' Wilson 13:17:57-08'00' Brett W. Huber, Sr. Jessie L. Chmielowski Gregory C. Wilson Chair, Commissioner Commissioner Commissioner Other Order 202 October 3, 2023 Page 4 of 4 cc: AOGCC Inspectors Phoebe Brooks (AOGCC) AND APPEAL Pursuant to 20 AAC 25.535(d), this order becomes final 1 I days after it is issued unless within 10 days after it is issued the person files a written request for a hearing, in which case the proposed decision or order is of no effect. If the person requests a hearing, the commission will schedule a hearing under 20 AAC 25.540. As provided in AS 31.05.080(a), within 20 days after this order becomes final as discussed above, 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. 5 August 24, 2023 Mr. Brett W. Huber, Sr. Chair, Commissioner Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, Alaska 99501 ens petrrdeum eni petroleum us Ilc 3700 Centerpoint Dr., Suite 500 Anchorage, AK 99503 - U.S.A. Tel. 907-865-3300 Fax 907-865-3380 RECEIVED AUG 2 4 2023 AOGCC Re: Docket Number OTH-23-017 Written Response to Notice of Proposed Enforcement Action & Request for Informal Review Rigless Well Workovers Nikaitchuq Unit Oooguruk Unit Dear Chair Huber: Eni US Operating Co. Inc. ("Eni") received your letter notifying us of the proposed enforcement action related to 20 AAC 25.280. Eni submits this written response and respectfully requests the Commission conduct an informal review of its proposed action under 20 AAC 25.535(c) and reassess the proposed civil penalty. In making this submission and request, Eni agrees that: • Eni completed installation of a tubing patch on Nikaitchuq injection well SI06-NE1 on April 24, 2023. • The tubing patch was installed without the use of a rig. • The AOGCC witnessed a mechanical integrity test ("MIT") after the well was returned to injection. • Eni was unable to provide evidence of AOGCC approval for the rigless well workover and a review of AOGCC well records confirmed there was no prior approval for the Nikaitchuq SI06- NE 1 tubing patch. • Eni was notified by letter dated May 11, 2023, of an AOGCC investigation "to determine if there are other rigless workovers that were completed without an approved sundry application." • On June 23, 2023, Eni responded to the investigation notice with a list of wells within the Nikaitchuq and Oooguruk Units where rigless well interventions were performed. Although it was not Eni's understanding at the time the tubing patches were completed, Eni has learned that the Commission interprets 20 AAC 25.280 to require an operator to request a sundry for any tubing 1 cn� p0rr© eum 2ni patch. Eni requests that the Commission also consider the additional facts presented below in determining its proposed enforcement action and decline to impose or significantly reduce the proposed civil penalties. Under 20 AAC 25.535(c), even if the AOGCC finds that a person has violated or failed to comply with a provision of its regulations, the Commission has discretion whether to impose a penalty under AS 31.05.150 by considering certain factors. Eni respectfully requests that the Commission consider the following factors discussed below: The extent to which the person committing the violation was acting in good faith in attempting to comply and the extent to which the person committing the violation acted in a wilful or knowing manner Eni did not wilfully or knowingly violate 20 AAC 25.280 in performing the tubing patches. At the time Eni performed the tubing patches, it did not understand a sundry was required for a tubing patch installation because, while the regulation expressly requires a sundry for "the pulling of tubing" and "repairs to the well" (as opposed to tubing or casing), it doesn't expressly require a sundry for tubing repair. Eni's good faith interpretation of the regulation is evidenced in part by the fact that Eni actively communicates with the AOGCC concerning its well operations, including the ones under investigation here. AOGCC representatives were notified to attend several of the MITs conducted post -tubing patch installation, and AOGCC staff attended six of the MITs. Eni would not do this if it were trying to avoid AOGCC scrutiny or knowingly/wilfully violating the regulation. Moreover, the incident with the Nikaitchuq injection well S106-NE 1 was the first time it was suggested to Eni that a sundry application might be required for a tubing patch. Since that time, and even though this investigation has not concluded, Eni implemented a procedure to request a sundry prior to performing a tubing patch, which it did for the 0I11-01 patch installation job ( Sundry #323-369, granted on July 12, 2023). It always has been and remains Eni's intention to always comply with all AOGCC statutes and regulations. Eni's good faith (and lack of any wilful or knowing intent) is evident and weighs against imposing a penalty. The extent and seriousness of the violation and the actual or potential threat to public health or the environment and the injury to the public resulting from the violation Although Eni did not file sundries for the noted tubing patches, this omission did not pose an actual or potential threat to the public health or the environment. Nor is Eni aware of any injury to the public that resulted. These factors also suggest the Commission should not assess a penalty here. 2 eno pctrrdeum 2no The benefits derived by the person committing the violation from the violation Eni did not derive any benefit from its omissions. There are no fees that accompany the filing of a sundry and thus Eni did not avoid the imposition of any costs. Eni asked AOGCC staff to witness several of the MITs, which shows it was not trying to hide that it had completed the tubing patches. This also demonstrates that Eni was not trying to avoid and in fact welcomed AOGCC scrutiny of the effectiveness of the tubing patch. Eni's lack of benefit (financially or otherwise) indicates a penalty is inappropriate here. The history of compliance or noncompliance by the person committing the violation with the provisions of this chapter, the regulations adopted under this chapter, and the orders, stipulations, or terms of permits issued by the commission As stated above, Eni's intent is always to comply with all AOGCC statutes and regulations as well as all other regulations, permit stipulations and conditions required to operate within Alaska and throughout the world. Given that Eni operates more than 100 wells in Alaska, that this violation was the result of a good faith misinterpretation, and that Eni's recent record of compliance was clean, this factor mitigates against imposing the proposed civil penalty. The need to deter similar behavior by the person committing the violation and others similarly situated at the time of the violation or in the future Eni's response to the AOGCC's initial notification of possible violation shows there is no need to deter similar behavior from Eni. Eni has fully cooperated in the Commission's investigation. In the spirit of full transparency, Eni included all types of rigless interventions it performed rather than just the categories listed under "well workover operations" in 20 AAC 25.280. (Eni wanted to ensure the Commission was able to review all of Eni's rigless interventions, since it appeared some of the categories in 20 AAC 25.280 were susceptible to different interpretations.) Eni's violation of 20 AAC 25.280 was not wilful or knowing; it was a good faith misunderstanding, which means there is no need to deter Eni from further violations. Likewise, when informed of the investigation, Eni requested a meeting and met with Commission Staff to ensure it had an accurate understanding of the Commission's interpretation of the regulation. Eni also proactively submitted proposed matrices setting out the sundry approval and reporting requirements for frequently performed well operations on the Nikaitchuq and Oooguruk oil pools.' As Eni learned during this investigation, and as the ' The Commission indicated in its proposed action that, in addition to the proposed civil penalty, it "intends to require Eni to develop a Sundry Matrix for AOGCC approval that clearly delineates routine well workover operations that can be excluded from certain application, pre -approval, and reporting requirements for oil pools within the Nikaitchuq and Oooguruk Units." Eni has already been working with Commission Staff and has submitted two proposed matrices for review. Eni thus would not object to this portion of the AOGCC's proposed action. la cni p0rdeum 2ni Commission points out in its letter, several other operators already have sundry matrices for their pools. Evaluation of the deterrence factor does not support the imposing a civil penalty here. The effort made by the person committing the violation to correct the violation and prevent future violations As described in greater detail above, Eni fully cooperated with the Commission as it investigated this matter. In its initial response to the Commission, Eni not only committed to instituting procedures to ensure sundry applications are properly submitted if it was determined adjustments to Eni's current processes were needed, but Eni then carried through on its commitment and already submitted two proposed sundry matrices to the AOGCC for the Nikaitchuq and Oooguruk pools.2 Eni has already implemented the processes proposed in the matrices with respect to tubing patches to ensure a sundry is submitted before any tubing patch. This factor also weighs against the imposition of any civil penalty. Given the additional facts Eni presents in this letter, the analysis of the factors relevant to determining the amount of a civil penalty, and Eni's lack of objection to the Commission's other proposed action in this matter (in fact as noted above Eni has already submitted a Sundry Matrix for the Nikaitchuq and Oooguruk oil pools), Eni respectfully requests that the AOGCC decline to impose or significantly reduce the proposed civil penalties for this matter. Should you have any questions, please do not hesitate to contact me. Sincerely, Giorgio Iaimucci Well Operations Project Manager CC: David Hart, Operations Manager Alaska Andrea Rimoldi, Technical Services Director Massimo Insulla, President and CEO James Regg, Supervisor, Inspection, AOGCC z See also note 1. 0 4 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907.279.1433 Fax: 907.276.7542 www.aogcc.alaska.gov August 10, 2023 CERTIFIED MAIL – RETURN RECEIPT REQUESTED 7018 0680 0002 2052 9600 Mr. Giorgio Iannucci Well Operations Project Manager Eni US Operating Company, Inc. 3800 Centerpoint Drive, Suite 300 Anchorage, AK 99503 Re: Docket Number: OTH-23-017 Notice of Proposed Enforcement Action Rigless Well Workovers Nikaitchuq Unit Oooguruk Unit Dear Mr. Iannucci: Pursuant to 20 AAC 25.535, the Alaska Oil and Gas Conservation Commission (AOGCC) hereby notifies Eni US Operating Company Inc. (Eni) of a proposed enforcement action. Nature of the Apparent Violation or Noncompliance (20 AAC 25.535(b)(1)). Eni has violated the provisions of 20 AAC 25.280 (“Workover operations”) while performing workover operations at Nikaitchuq Unit. Basis for Finding the Violation or Noncompliance (20 AAC 25.535(b)(2)). Eni completed installation of a tubing patch on Nikaitchuq injection well SI06-NE1 on April 24, 2023. The tubing patch was installed without the use of a rig. The AOGCC witnessed a mechanical integrity test after the well was returned to injection. Eni was unable to provide evidence of AOGCC approval for the rigless well workover and a review of AOGCC well records confirmed there was no prior approval for the Nikaitchuq SI06-NE1 tubing patch.1 1 20 AAC 25.280(a)(5) requires the submittal and approval of an Application for Sundry Approvals (Form 10-403) to enter and conduct repairs to a well. Docket Number: OTH-23-017 Notice of Proposed Enforcement August 10, 2023 Page 2 of 3 Eni was notified by letter dated May 11, 2023 of an AOGCC investigation “to determine if there are other rigless workovers that were completed without an approved sundry application”.2 Included in the AOGCC’s investigation was a search for an approved application that would exempt Eni from certain application, pre-approval, and reporting requirements at Nikaitchuq and Oooguruk Units.3 On June 23, 2023, Eni responded to the investigation notice with a list of wells within the Nikaitchuq and Oooguruk Units where rigless well interventions were performed. AOGCC concludes that there have been no approvals granted to Eni that exempt certain workover operations from sundry applications and reporting obligations, and that Eni failed to submit and receive sundry approval for rigless workovers on Nikaitchuq Unit wells between January 1, 2020, and April 30, 2023, as required by 20 AAC 25.280. Proposed Action (20 AAC 25.535(b)(3)). For violating 20 AAC 25.280 the AOGCC intends to impose a civil penalty pursuant to AS 31.05.150(a) in the amount of $60,000 for failing to obtain approval of rigless workovers.4 In addition to the imposed civil penalty, AOGCC intends to require Eni to develop a Sundry Matrix for AOGCC approval that clearly delineates routine well workover operations that can be excluded from certain application, pre-approval, and reporting requirements for oil pools within the Nikaitchuq and Oooguruk Units. Rights and Liabilities (20 AAC 25.535(b)(4)) Within 15 days after receipt of this notification – unless the AOGCC, in its discretion, grants an extension for good cause shown – Eni may file with the AOGCC a written response that concurs in whole or in part with the proposed action described herein, requests informal review, or requests a hearing under 20 AAC 25.540. If a timely response is not filed, the proposed action will be deemed accepted by default. If informal review is requested, the AOGCC will provide Eni an opportunity to submit documentary material and make a written or oral statement. If Eni disagrees with the AOGCC’s proposed decision or order after that review, it may file a written request for a hearing within 10 days after the proposed decision or order is issued. If such a request is not filed within that 10-day period, the proposed decision or order will become final on the 11th day after it was issued. If such a request is timely filed, the AOGCC will hold its decision in abeyance and schedule a hearing. 2 The AOGCC imposed a January 1, 2020, to April 30, 2023, time period for its investigation into Eni’s rigless workovers. 3 The AOGCC has upon application by other operators approved a “Sundry Matrix” that sets out the sundry approval and reporting requirements for frequently performed well operations on specific oil pools. There is no record of such approval for the Eni operated pools within the Nikaitchuq and Oooguruk Units. 4 AS 31.05.150(g) requires AOGCC to consider nine criteria in setting the amount of a civil penalty. The AOGCC determined that 12 of the 88 rigless workovers ENI listed required a sundry per 20 AAC 25.280(a)(5), all located within the Nikaitchuq Unit: OI15-S4, OI13-03, OI06-05, OI20-07, SI26-NW2, SI29-S2, OP26-DSP02, SP30-W1, SI07-SE4, OI20-07, SI11-FN6, SI06-NE1. The $60,000 proposed civil penalty is derived from 12 wells at $5000 per well. Docket Number: OTH-23-017 Notice of Proposed Enforcement August 10, 2023 Page 3 of 3 If Eni does not concur in the proposed action described herein, and the AOGCC finds that Eni violated a provision of AS 31.05, 20 AAC 25, or an AOGCC order, permit or other approval, then the AOGCC may take any action authorized by the applicable law including ordering one or more of the following: (i) corrective action; (ii) suspension or revocation of a permit or other approval; and (iii) imposition of penalties under AS 31.05.150. In taking action after an informal review or hearing, the AOGCC is not limited to ordering the proposed action described herein, as long as Eni received reasonable notice and opportunity to be heard with respect to the AOGCC’s action. Any action described herein or taken after an informal review or hearing does not limit the action the AOGCC may take under AS 31.05.160. Sincerely, Brett W. Huber, Sr. Jessie L. Chmielowski Gregory C. Wilson Chair, Commissioner Commissioner Commissioner cc: Phoebe Brooks AOGCC Inspectors Jessie L. Chmielowsk i Digitally signed by Jessie L. Chmielowski Date: 2023.08.10 11:59:09 -08'00' Gregory Wilson Digitally signed by Gregory Wilson Date: 2023.08.10 12:01:07 -08'00' Brett W. Huber, Sr. Digitally signed by Brett W. Huber, Sr. Date: 2023.08.10 13:50:31 -08'00' 3 eni us operating co. inc. 3700 Centerpoint Dr., Suite 500 Anchorage, AK 99503 – U.S.A. Tel. 907-865-3300 Fax 907-865-3380 1 June 23, 2023 VIA HAND DELIVERY Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, Alaska 99501 Mr. Brett W. Huber, Sr. Chair, Commissioner Re: Docket Number OTH-23-017 Notice of Investigation and Request for Information Rigless Well Workovers Nikaitchuq Unit Oooguruk Unit Dear Chair Huber, With reference to your Notice of Investigation and Request for Information dated May 11, 2023, please find the attached list of wells Eni US Operating Co. Inc. (“Eni”) operates where rigless interventions were performed from January 1, 2020, to April 30, 2023, with descriptions of the work that was completed (the “List”). Please note that, in the spirit of full transparency, Eni has included all types of rigless interventions performed rather than just the categories listed under “well workover operations” in 20 AAC 25.280, as it appears those categories are susceptible to different interpretations. With reference to the mentioned “rigless well workover” of water injection well Nikaitchuq SI06-NE1, Eni’s interpretation is that a sundry application was not required for a tubing patch installation because this type of operation is not listed in 20 AAC 25.280. Eni did not prepare sundry applications for the other interventions included in the List for similar reasons and, if it turns out sundry applications were required for any of those interventions, then the regulation is unclear. Eni’s good faith interpretation of the regulation is evidenced in part by the fact that Eni actively communicates with the AOGCC concerning its well operations, including the ones under investigation here. In addition, although AOGCC representatives have attended previous MIT post-tubing patch installations during the time period under investigation, this was the first time it was suggested to Eni that a sundry application might be required. 2 Despite any ambiguity in the regulation, it remains Eni’s commitment to comply with all AOGCC statutes and regulations. Because the AOGCC and Eni may interpret portions of 20 AAC 25.280 differently, Eni would appreciate meeting with the AOGCC Staff to discuss which type of rigless operations fall within the categories listed in 20 AAC 25.280 and thus require a sundry application or report. Eni will separately submit a meeting request for this purpose to AOGCC Staff. If adjustments to Eni’s current processes are needed, Eni is committed to instituting procedures to ensure sundry applications are properly submitted. Should you have any questions, please do not hesitate to contact me. Sincerely, Giorgio Iannucci Well Operations Project Manager Attachment CC: David Hart, Operations Manager Alaska Andrea Rimoldi, Technical Services Director Massimo Insulla, President and CEO James Regg, Supervisor, Inspection, AOGCC Well Name Unit Type Site SoW Start Date End Date ODSN‐48i CTU ODS Hydrate thawing 27‐Jul‐20 8‐Aug‐20 ODSK‐35Ai E‐Line/Slickline ODS Tubing leak Diagnostics 5‐Aug‐20 18‐Aug‐20 ODSN‐02 E‐Line/Slickline ODS TRSV Brush and Flush 16‐Aug‐20 18‐Aug‐20 SP27‐N1 E‐Line/Slickline SID Tubing leak diagnostics 25‐Aug‐20 7‐Sep‐20 SP05‐FN7 E‐Line/Slickline SID Tubing leak diagnostics 28‐Aug‐20 11‐Sep‐20 SP18‐N5 E‐Line/Slickline SID Tubing leak diagnostics, Patch install 1‐Sep‐20 4‐Sep‐20 OP26‐DSP02 E‐Line/Slickline OPP EPA MIT‐IA, Tubing leak diagnostics 21‐Oct‐20 30‐Oct‐20 OP‐I2 E‐Line/Slickline OPP Swap downhole memory gauges 24‐Oct‐20 26‐Oct‐20 OP17‐02 E‐Line/Slickline OPP Tubing leak diagnostics 5‐Nov‐20 8‐Nov‐20 SP27‐N1 E‐Line/Slickline SID Tubing Punch 7‐Dec‐20 9‐Dec‐20 SP23‐N3 E‐Line/Slickline SID Tubing Punch 9‐Dec‐20 10‐Dec‐20 SD37‐DSP01 E‐Line/Slickline SID Post RWO rigless program 16‐Dec‐20 25‐Dec‐20 ODST‐45A E‐Line/Slickline ODS Greased and function wellhead, Install TWC 23‐Dec‐20 23‐Dec‐20 ODSN‐31 E‐Line/Slickline ODS TRSV Brush and Flush 9‐Mar‐21 14‐Mar‐21 ODSN‐02 E‐Line/Slickline ODS TRSV Brush and Flush 12‐Mar‐21 12‐Mar‐21 OI15‐S4 E‐Line/Slickline OPP Tubing leak diagnostics, Install patch 24‐Mar‐21 4‐Jun‐21 OI13‐03 E‐Line/Slickline OPP Tubing leak diagnostics, Install patch 25‐Mar‐21 2‐May‐21 SP03‐NE2 E‐Line/Slickline SID Run tractor to ESP to check for obstructions 25‐Mar‐21 25‐Mar‐21 OI06‐05 E‐Line/Slickline OPP Tubing leak diagnostics, Install patch 28‐Mar‐21 7‐Jul‐21 OI20‐07 E‐Line/Slickline OPP Tubing leak diagnostics, Install patch 28‐Mar‐21 5‐Jun‐21 SI26‐NW2 E‐Line/Slickline SID MITIA, Tubing leak diagnostics, Install Patch 7‐Apr‐21 7‐May‐21 SI29‐S2 E‐Line/Slickline SID MITIA, Tubing leak diagnostics, Install Patch 10‐Apr‐21 16‐May‐21 SI34‐W6 E‐Line/Slickline SID MITIA, Tubing leak diagnostics 15‐May‐21 5‐Jun‐21 ODSN‐31 E‐Line/Slickline ODS TRSV Brush and Flush 18‐Jun‐21 12‐Jul‐21 ODSN‐17 E‐Line/Slickline ODS OV Replacement 20‐Jun‐21 25‐Jun‐21 ODSK‐38i E‐Line/Slickline ODS E line / Blue Spark for TRSSSV 24‐Jun‐21 24‐Jun‐21 ODSN‐40 E‐Line/Slickline ODS Replace BPV w/ TWC 9‐Jul‐21 10‐Jul‐21 ODSK‐38i E‐Line/Slickline ODS Remove BPV 9‐Jul‐21 10‐Jul‐21 ODSK‐14 E‐Line/Slickline ODS TRSV Brush and Flush 12‐Jul‐21 13‐Jul‐21 ODSN‐40 E‐Line/Slickline ODS Replace TWC 17‐Jul‐21 18‐Jul‐21 ODSN‐48i E‐Line/Slickline ODS WRSSV Replacement 18‐Jul‐21 18‐Jul‐21 ODSN‐04 E‐Line/Slickline ODS OV Replacement 19‐Jul‐21 1‐Aug‐21 ODSN‐02 E‐Line/Slickline ODS TRSV Brush and Flush 2‐Aug‐21 10‐Aug‐21 ODSN‐06i E‐Line/Slickline ODS OV Replacement 3‐Aug‐21 7‐Aug‐21 OP09‐S1 E‐Line/Slickline OPP SOV replacement 11‐Sep‐21 14‐Sep‐21 ODSN‐19i CTU ODS Hydrate thawing 15‐Sep‐21 26‐Sep‐21 ODSN‐31 CTU ODS TRSV Chem soak 17‐Sep‐21 22‐Sep‐21 ODSN‐31 CTU ODS TRSV Lockout 6‐Oct‐21 28‐Oct‐21 ODSN‐02 CTU ODS TRSV Chem soak, Fluff & Stuff 21‐Sep‐21 29‐Sep‐21 ODSN‐24 CTU ODS Fluff & Stuff 27‐Sep‐21 9‐Oct‐21 ODSN‐01A CTU ODS Fluff & Stuff 29‐Sep‐21 3‐Oct‐21 SD37‐DSP01 E‐Line/Slickline SID Pressure Test Tubing 21‐Oct‐21 23‐Oct‐21 ODSDW1‐44 E‐Line/Slickline ODS Tubing caliper, Waterflow log, MITIA 19‐Nov‐21 4‐Dec‐21 OI15‐S4 E‐Line/Slickline OPP Water Flow Log of lateral 22‐Nov‐21 29‐Nov‐21 OP26‐DSP02 E‐Line/Slickline OPP Tubing caliper, Waterflow log, MITIA, Install patch 29‐Nov‐21 25‐Jan‐22 OP‐I2 E‐Line/Slickline OPP Swap downhole memory gauges 2‐Dec‐21 3‐Dec‐21 ODSW1‐44 CTU ODS EPA logging 3‐Dec‐21 4‐Dec‐21 SP30‐W1 E‐Line/Slickline SID MITIA, Tubing leak diagnostics, install Patch 11‐Dec‐21 26‐Dec‐21 ODSN‐01A CTU ODS Fluff & Stuff 19‐Dec‐21 21‐Jan‐21 SI07‐SE4 E‐Line/Slickline SID Tubing leak, Diagnose and set patch in TBG. 27‐Jan‐22 16‐Feb‐22 OP21‐WW01 E‐Line/Slickline OPP TRSV Brush and Flush 3‐Feb‐22 6‐Feb‐22 Attachment - Docket No. OTH-23-017 Well Name Unit Type Site SoW Start Date End Date OP23‐WW02 E‐Line/Slickline OPP TRSV Brush and Flush 6‐Feb‐22 19‐Feb‐22 ODSN‐29 CTU ODS Tubing leak diagnostics 5‐Apr‐22 4‐May‐22 OI07‐04 E‐Line/Slickline OPP Leak Detect for TBG x Annulus A communication with patch installation.11‐May‐22 20‐May‐22 ODSN‐29 E‐Line/Slickline ODS Selective Single Nuiqsut Isolation 21‐May‐22 30‐May‐22 ODSN‐24 CTU / Pumping Unit ODS Hydrate thawing 21‐May‐22 25‐May‐22 ODSN‐17 E‐Line/Slickline ODS E line / Blue Spark for TRSSSV 29‐May‐22 29‐Jun‐22 ODSN‐02 CTU ODS Fluff & Stuff 11‐Jun‐22 17‐Jun‐22 ODST‐39 CTU ODS Fluff & Stuff 14‐Jun‐22 23‐Jun‐22 ODST‐45A CTU ODS Fluff & Stuff 15‐Jun‐22 28‐Jun‐22 OP21‐WW01 E‐Line/Slickline OPP E line / Blue Spark for TRSSSV 16‐Jun‐22 18‐Jun‐22 OP22‐WW03 E‐Line/Slickline OPP E line / Blue Spark for TRSSSV 19‐Jun‐22 20‐Jun‐22 OP23‐WW02 E‐Line/Slickline OPP E line / Blue Spark for TRSSSV 21‐Jun‐22 23‐Jun‐22 OI20‐07 E‐Line/Slickline OPP Hole in TBG diagnostics, Install Patch 24‐Jun‐22 5‐Jul‐22 ODSK‐33 E‐Line/Slickline ODS E line / Blue Spark for TRSSSV 6‐Jul‐22 7‐Jul‐22 SI11‐FN6 E‐Line/Slickline SID TBG x Annulus A Communication. E line Diagnostics and repairs. , Install patch 7‐Jul‐22 22‐Jul‐22 ODSK‐41 E‐Line/Slickline ODS Pre RWO rigless program 14‐Jul‐22 16‐Jul‐22 ODSN‐31 E‐Line/Slickline ODS Pre RWO rigless program 29‐Jul‐22 29‐Jul‐22 ODSN‐18 E‐Line/Slickline ODS Slickline OV Replacemnt. 6‐Aug‐22 9‐Aug‐22 ODSN‐25 E‐Line/Slickline ODS Pre RWO rigless program 10‐Aug‐22 12‐Aug‐22 OI07‐04 E‐Line/Slickline OPP TBG x Annulus A Communication. E line and Slickline Diagnostics and repairs. 13‐Aug‐22 16‐Aug‐22 SP03‐NE2 E‐Line/Slickline SID Thru‐Tubing ESP install 26‐Aug‐22 18‐Sep‐22 OP22‐WW03 E‐Line/Slickline OPP TRSV Brush and Flush 11‐Oct‐22 12‐Oct‐22 SP03‐NE2 E‐Line/Slickline SID Thru‐Tubing ESP install 26‐Oct‐22 6‐Nov‐22 ODSN‐24 E‐Line/Slickline ODS Slickline WLRSSSV replacement. 19‐Nov‐22 27‐Nov‐22 ODSN‐17 E‐Line/Slickline ODS Slickline Pressure/Temp survey 28‐Nov‐22 29‐Nov‐22 ODSN‐10i E‐Line/Slickline ODS Slickline WLRSSSV replacement. 29‐Nov‐22 22‐Dec‐22 ODSK‐14 E‐Line/Slickline ODS TRSV Brush and Flush 1‐Dec‐22 5‐Dec‐22 SD37‐DSP01 E‐Line/Slickline SID EPA logging 11‐Dec‐22 15‐Dec‐22 SD37‐DSP01 E‐Line/Slickline SID Test Tubing, Eline logging 9‐Jan‐23 12‐Jan‐23 OP‐I2 Slickline OPP OP‐I2 RL M. Gauge removal 31‐Jan‐23 2‐Feb‐23 ODSN‐10i E‐Line/Slickline ODS Orfice Valve Swap 2‐Mar‐23 12‐Mar‐23 ODSN‐31 E‐Line/Slickline ODS Tubing Punch 12‐Mar‐23 9‐Apr‐23 OP‐I2 E‐Line/Slickline OPP Caliper & ACX logs 16‐Mar‐23 17‐Mar‐23 OP‐I2 E‐Line/Slickline OPP Set Patch in TBG. 9‐Apr‐23 17‐Apr‐23 SI34‐W6 E‐Line/Slickline SID MITIA 13‐Apr‐23 16‐Apr‐23 SI06‐NE1 E‐Line/Slickline SID Hole in TBG diagnostics, Install Patch 14‐Apr‐23 27‐Apr‐23 ODSN‐31 E‐Line/Slickline ODS Tubing Punch 29‐Apr‐23 14‐May‐23 2 1 Carlisle, Samantha J (OGC) From:Regg, James B (OGC) Sent:Wednesday, June 7, 2023 3:08 PM To:Iannucci Giorgio Cc:Hart David; Carlisle, Samantha J (OGC) Subject:RE: [EXTERNAL] OTH-23-017, Notice of Investigation Your request for an additional 2 weeks to provide the requested information is approved. New due date is June 23, 2023. Jim Regg Supervisor, Inspections AOGCC 333 W. 7th Ave, Suite 100 Anchorage, AK 99501 907‐793‐1236 From: Iannucci Giorgio <Giorgio.Iannucci@eni.com> Sent: Wednesday, June 7, 2023 2:35 PM To: Regg, James B (OGC) <jim.regg@alaska.gov> Cc: Hart David <David.Hart@eni.com> Subject: RE: [EXTERNAL] OTH‐23‐017, Notice of Investigation Mr. Regg, I meant June 23rd as new proposed deadline, two weeks past the 30 days notice. Thanks, Giorgio From: Iannucci Giorgio Sent: Wednesday, June 7, 2023 2:20 PM To: 'Regg, James B (CED)' <jim.regg@alaska.gov> Cc: Hart David <David.Hart@eni.com> Subject: RE: [EXTERNAL] OTH‐23‐017, Notice of Investigation Dear Mr. Regg, With reference to the attached letter and as per your conversation with Mr. Hart cc’d here, Eni would like to ask for a two‐week extension to the 30 days deadline, i.e. until June 16th, in order to provide an accurate response with the list of well works requested and get management approval prior to that. Best regards, Giorgio Iannucci Well Operations Project Manager ‐ Alaska You don't often get email from giorgio.iannucci@eni.com. Learn why this is important CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. 2 eni US Operating Co., Inc. 3700 Centerpoint Drive Suite 500 Anchorage, Alaska 99503 Cell +1‐907‐223‐6576 From: Carlisle, Samantha J (OGC) <samantha.carlisle@alaska.gov> Sent: Thursday, May 11, 2023 1:39 PM To: Iannucci Giorgio <Giorgio.Iannucci@eni.com> Subject: [EXTERNAL] OTH‐23‐017, Notice of Investigation Please see attached. Hard copy is being sent via USPS certified mail. Thank you, Samantha Carlisle Special Assistant Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, AK 99501 (907) 793-1223 ---------------------------------------------------------------------------------------------------------------------------------------------------- -------------------- Message for the recipient only, if received in error, please notify the sender and read http://www.eni.com/disclaimer/ Security Warning: This email originated from outside of the organization. Do not click links or open attachments unless you have verified the sender’s email address and know the content is safe. 1 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907.279.1433 Fax: 907.276.7542 www.aogcc.alaska.gov June 1, 2023 Certified Mail Return Receipt Requested 7018 0680 0002 2052 9648 Mr. Giorgio Iannucci Well Operations Project Manager Eni US Operating Company, Inc. 3700 Centerpoint Drive, Suite 500 Anchorage, Alaska 99503 Re: Docket Number: OTH-23-017 Notice of Investigation and Request for Information Rigless Well Workovers Nikaitchuq Unit Oooguruk Unit Dear Mr. Iannucci: ENI US Operating Company Inc. (Eni) recently completed a rigless well workover at water injection well Nikaitchuq SI06-NE1 (PTD 2191650). Work involved installation of a tubing patch with a wireline unit to regain integrity of the injection tubing. An Alaska Oil and Gas Conservation Commission (AOGCC) Inspector witnessed a mechanical integrity test on the well on May 4, 2023, after receiving 48-hour advance notice of the test from Eni. The AOGCC Inspector requested a copy of the approved sundry application from Eni’s field representative to verify the required test pressure; he was told there was no sundry approval. The tubing patch was installed on April 24, 2023, and Nikaitchuq SI06-NE1 was placed back on injection on April 26. The witnessed mechanical integrity test passed, and the well was allowed to remain on injection. An AOGCC representative contacted Eni’s Anchorage office personnel on May 4, 2023, and the Eni personnel confirmed that they were unable to locate a sundry for the Nikaitchuq SI06-NE1 tubing patch. A review of AOGCC field files also revealed no approved sundry application for the subject well work. A Report of Sundry Well Operations for the rigless well workover was provided by Eni on May 5, 2023, at the AOGCC’s request. The AOGCC has initiated an investigation to determine if there are other rigless workovers that were completed without an approved sundry application as required by 20 AAC 25.280. Within 30 days of receipt of this letter, Eni is requested to provide a list of wells it operates where rigless Docket Number: OTH-23-017 Rigless Workovers Investigation June 1, 2023 Page 2 of 2 workovers have been performed, what work was completed, and if there was prior AOGCC approval. The time period for this request is January 1, 2020, to April 30, 2023. This request is made pursuant to 20 AAC 25.300. Failure to comply with this request is itself a regulatory violation. The AOGCC reserves the right to purse an enforcement action in this matter according to 20 AAC 25.535. Should you have any questions about the information request, please contact Jim Regg at (907) 793-1236. Sincerely, Brett W. Huber, Sr. Chair, Commissioner cc: AOGCC Inspectors Phoebe Brooks Samantha Carlisle Brett W. Huber, Sr. Digitally signed by Brett W. Huber, Sr. Date: 2023.06.01 09:57:46 -08'00'