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HomeMy WebLinkAboutO 212Other Order 212 Docket Number: OTH-24-019 1. October 30, 2023 OSA operational changes (PTD 223-087) 2. April 19, 2024 AOGCC notice of proposed enforcement action 3. May 6, 2024 OSA informal review request and scheduling 4. May 6, 2024 OSA operability question 5. May 20, 2024 OSA response to proposed enforcement 6. June 26, 2024 OSA civil penalty payment (Confidential items held in secure storage) STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Avenue Anchorage Alaska 99501 Re: Compliance with PTD 223-087, Pikka Unit, NDBi-044 well ) ) ) ) ) ) Other Order 212 Docket Number: OTH-24-019 Oil Search (Alaska), LLC June 12, 2024 DECISION AND ORDER On April 19, 2024, the Alaska Oil and Gas Conservation Commission (AOGCC) issued a Notice of Proposed Enforcement Action (Notice) to Oil Search (Alaska), LLC (OSA) regarding the NDBi-044 well. The Notice proposed a $30,000 civil penalty under AS 31.05.150(a). OSA acknowledged receipt of the Notice and requested an informal review of the matter. The informal review was held on May 9, 2024. OSA also submitted a written response dated May 20, 2024, which AOGCC has considered as part of its informal review process. Summary of Proposed Enforcement Action: The Notice identified the violation by OSA for failing to follow an approved permit to drill while performing drilling operations at NDBi-044 per 20 AAC 25.015(b)(2) and proposed a civil penalty of $30,000. The Notice also required that OSA provide a detailed written explanation that describes how OSA intends to prevent recurrence of this violation. Violation - Failure to Follow an Approved Permit to Drill: On October 17, 2023, the AOGCC conditionally approved Permit to Drill (PTD) 223-087, authorizing OSA to drill well NDBi-044. Drilling operations were completed by OSA on December 22, 2023. The AOGCC investigation indicates OSA failed to follow the procedure in the approved permit to drill in violation of 20 AAC 25.015(b)(2). Mitigating Circumstances: The factors in AS 31.05.150(g) were considered in determining the appropriate penalty.1 The benefits derived from the violation and need to deter similar behavior are the factors which most heavily influence AOGCC’s decision, and the penalty being assessed in this matter. 1 AS 31.05.150 includes the following nine factors for consideration in determination of a penalty assessed under this section. (1) the extent to which the person committing the violation was acting in good faith in attempting to comply; (2) the extent to which the person committing the violation acted in a willful or knowing manner; (3) the extent and seriousness of the violation and the actual or potential threat to public health or the environment; (4) the injury to the public resulting from the violation; (5) the benefits derived by the person committing the violation from the violation; Other Order 212 June 12, 2024 Page 2 of 3 Mitigating circumstances considered in the assessment of the proposed civil penalty include OSA’s lack of previous enforcement actions and no injury to the public beyond failure to comply. Further, AOGCC has not imposed per-day assessments for the violations, which has significantly reduced the penalty. Findings and Conclusions: The AOGCC finds that OSA violated the provisions of 20 AAC 25.015(b)(2) (“Changes to a program in a permit to drill”) while performing drilling operations at NDBi-044. Mitigating circumstances outlined above were considered in the Notice and the AOGCC assessment as to the appropriate civil penalty. Now Therefore It Is Ordered That: OSA is assessed a civil penalty in the amount of $30,000 for failing to comply with the approved permit to drill. OSA’s response to the Notice included specific corrective actions to prevent recurrence of this violation. As an Operator involved in an enforcement action, OSA is required to preserve documents concerning the above action until after resolution of the proceeding. DONE at Anchorage, Alaska and Dated June 12, 2024. Brett W. Huber, Sr. Jessie L. Chmielowski Gregory C. Wilson Chair, Commissioner Commissioner Commissioner cc: Phoebe Brooks (AOGCC) AOGCC Inspectors (6) 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; (7) 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; (8) the effort made by the person committing the violation to correct the violation and prevent future violations; and (9) other factors considered relevant to the assessment that are adopted by the commission in regulation. Gregory Wilson Digitally signed by Gregory Wilson Date: 2024.06.12 10:19:10 -08'00'Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2024.06.12 10:25:52 -08'00' Brett W. Huber, Sr. Digitally signed by Brett W. Huber, Sr. Date: 2024.06.12 17:05:24 -05'00' Other Order 212 June 12, 2024 Page 3 of 3 RECONSIDERATION AND APPEAL NOTICE As provided in AS 31.05.080(a), within 20 days after written notice of the entry of this order or decision, or such further time as the AOGCC grants for good cause shown, a person affected by it may file with the AOGCC an application for reconsideration of the matter determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration must set out the respect in which the order or decision is believed to be erroneous. The AOGCC shall grant or refuse the application for reconsideration in whole or in part within 10 days after it is filed. Failure to act on it within 10-days is a denial of reconsideration. If the AOGCC denies reconsideration, upon denial, this order or decision and the denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision denying reconsideration, UNLESS the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which the application for reconsideration was filed. If the AOGCC grants an application for reconsideration, this order or decision does not become final. Rather, the order or decision on reconsideration will be the FINAL order or decision of the AOGCC, and it may be appealed to superior court. That appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on reconsideration. In computing a period of time above, the date of the event or default after which the designated period begins to run is not included in the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00 p.m. on the next day that does not fall on a weekend or state holiday. From:Coldiron, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Other Order 212 (Oil Search (Alaska), LLC) Date:Wednesday, June 12, 2024 2:32:32 PM Attachments:other 212.pdf Compliance with PTD 223-087, Pikka Unit, NDBi-044 well Samantha Coldiron 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.coldiron@alaska.gov Unsubscribe at: https://list.state.ak.us/mailman/options/aogcc_public_notices/samantha.coldiron%40alaska.go v 6 T1 O m l W 0 M10 v< m1 mO 0-4 n 2 N � p� G 5 Oil Search (Alaska), LLC a subsidiary of Santos Limited 900 E. Benson Blvd Anchorage, Alaska 99508 PO Box 240927 Anchorage, Alaska 99524 (T) +1 907 375 4642 —santos.com 1/2 May 20, 2024 Brett Huber, Sr. Commission Alaska Oil and Gas Conservation Commission 333 West Seventh Avenue Anchorage, AK 99501-3572 Dear Commissioner Huber, As discussed at the informal hearing May 9th, 2024, Oil Search (Alaska) (OSA) takes the Alaska Oil and Gas Conservation Commission’s (AOGCC) Notice of Proposed Enforcement Action dated April 19, 2024, (Notice) very seriously. OSA is committed to making systematic improvements to ensure compliance with AOGCC requirements. OSA appreciated the opportunity to discuss the issues outlined in the Notice. We look forward to working together to improve communication and operate in a safe and compliant manner to develop Alaska’s resources. OSA proposes the following actions in response to the Notice: 1. OSA will direct all requests for changes to approved permits to drill or sundry applications (Change Requests) solely to the AOGCC-assigned petroleum engineer (AOGCC Petroleum Engineer). This individual will be the single point of contact for approving such requests. 2. To avoid ambiguity, Change Requests will specifically request approval from the AOGCC Petroleum Engineer. OSA Drilling Engineers will include their best estimates of the timeframe in which approvals are needed from the AOGCC Petroleum Engineer. This will notify the AOGCC Petroleum Engineer of any urgency related to the requests so that they can prioritize responses and workload. Operations will not proceed unless clear written approvals are received from the AOGCC Petroleum Engineer. 3. All communications regarding Change Requests will include the relevant OSA manager. (Ty) Robert Senden (Ty.Senden@Santos.com) will be copied on non-rig interventions and well integrity communications; Robert Tirpack (Rob.Tirpack@Santos.com) will be copied on all drilling-related communications. Once production begins, one of our production managers will be included on relevant communications with the agency. Including these managers on such communications will drive consistency between Change Requests within drilling and completions teams, improve compliance, and foster cooperation moving forward. 4. OSA will immediately roll out the above actions to the drilling and completions teams. By Samantha Coldiron at 1:38 pm, May 20, 2024 2/2 OSA welcomes your feedback on the actions proposed above. We look forward to working together on future wells. Given the above, OSA’s good faith efforts at clear and transparent communications, and OSA’s excellent record of compliance in the past, we respectfully request that AOGCC issue a Warning regarding the alleged infractions rather than a Notice of Violation. Best Regards, Robert Tirpack Senior Engineering Manager, Drilling Oil Search Alaska, LLC 4 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. From:Thompson, Jacob (Jacob) To:McLellan, Bryan J (OGC) Cc:Coldiron, Samantha J (OGC); Dewhurst, Andrew D (OGC) Subject:RE: NDBi-044 (PTD 223-087) operability question Date:Monday, May 6, 2024 2:22:59 PM Attachments:image003.png image004.png image005.png Thank you. Jacob Thompson – Senior Drilling EngineerOil Search (Alaska), LLC a subsidiary of Santos Limited P.O. Box 240927 Anchorage, Alaska 99524-0927 o: +1 (907) 646-7079| m: +1 (907) 854-4377 Jacob.Thompson@santos.com https://www.santos.com/ From: McLellan, Bryan J (OGC) <bryan.mclellan@alaska.gov> Sent: Monday, May 6, 2024 2:20 PM To: Thompson, Jacob (Jacob) <Jacob.Thompson@santos.com> Cc: Coldiron, Samantha J (OGC) <samantha.coldiron@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: ![EXT]: NDBi-044 (PTD 223-087) operability question Jake, In response to the question in your text message regarding the Proposed Enforcement action affecting the operability of the well… The outcome of the proposed enforcement action is not expected to impact the well’s operability. Regards Bryan McLellan Senior Petroleum Engineer Alaska Oil & Gas Conservation Commission Bryan.mclellan@alaska.gov +1 (907) 250-919 Santos Ltd A.B.N. 80 007 550 923 Disclaimer: The information contained in this email is intended only for the use of the person(s) to whom it is addressed and may be confidential orcontain privileged information. If you are not the intended recipient you are hereby notified that any perusal, use, distribution, copying or disclosure is strictly prohibited. If you have received this email in error please immediately advise us by return email and delete the email without making a copy.Please consider the environment before printing this email 3 From:Thompson, Jacob (Jacob) To:Coldiron, Samantha J (OGC); Tirpack, Robert (Robert) Subject:RE: OSA informal review request.pdf Date:Monday, May 6, 2024 9:32:19 AM Attachments:image002.png image003.png image004.png image005.png Thursday May 9th at 1:30 PM works good for me. Jacob Thompson – Senior Drilling EngineerOil Search (Alaska), LLC a subsidiary of Santos Limited P.O. Box 240927 Anchorage, Alaska 99524-0927 o: +1 (907) 646-7079| m: +1 (907) 854-4377 Jacob.Thompson@santos.com https://www.santos.com/ From: Coldiron, Samantha J (OGC) <samantha.coldiron@alaska.gov> Sent: Monday, May 6, 2024 9:30 AM To: Thompson, Jacob (Jacob) <Jacob.Thompson@santos.com>; Tirpack, Robert (Robert) <Robert.Tirpack@santos.com> Subject: ![EXT]: RE: OSA informal review request.pdf How does Thursday at 1:30pm look? From: Thompson, Jacob (Jacob) <Jacob.Thompson@santos.com> Sent: Monday, May 6, 2024 9:28 AM To: Coldiron, Samantha J (OGC) <samantha.coldiron@alaska.gov>; Tirpack, Robert (Robert) <Robert.Tirpack@santos.com> Subject: RE: OSA informal review request.pdf Samantha, I’m free Wednesday and Thursday afternoon this week, and all day Monday and Tuesday next week. If none of those dates work for you I can try to move things around in my schedule to accommodate. Thanks, Jacob Thompson – Senior Drilling EngineerOil Search (Alaska), LLC a subsidiary of Santos Limited P.O. Box 240927 Anchorage, Alaska 99524-0927 o: +1 (907) 646-7079| m: +1 (907) 854-4377 Jacob.Thompson@santos.com https://www.santos.com/ From: Coldiron, Samantha J (OGC) <samantha.coldiron@alaska.gov> Sent: Monday, May 6, 2024 8:24 AM To: Tirpack, Robert (Robert) <Robert.Tirpack@santos.com>; Thompson, Jacob (Jacob) 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. <Jacob.Thompson@santos.com> Subject: ![EXT]: RE: OSA informal review request.pdf Yes, please schedule the informal review through me. Thank you, Samantha Coldiron AOGCC Special Assistant (907) 793-1223 From: Tirpack, Robert (Robert) <Robert.Tirpack@santos.com> Sent: Friday, May 3, 2024 1:23 PM To: Coldiron, Samantha J (OGC) <samantha.coldiron@alaska.gov>; Thompson, Jacob (Jacob) <Jacob.Thompson@santos.com> Subject: RE: OSA informal review request.pdf Samantha – thank you for the note. Jacob Thompson has reached out to Brian McLellan to start coordinating a time to meet for the informal review. If Jacob should be working with you, please advise. Regards, Rob Robert Tirpack Senior Drilling and Completions Engineering Manager m: (907) 903-9454 | e: robert.tirpack@santos.com Santos.com | Follow us on LinkedIn, Facebook and Twitter From: Coldiron, Samantha J (OGC) <samantha.coldiron@alaska.gov> Sent: Friday, May 3, 2024 1:18 PM To: Tirpack, Robert (Robert) <Robert.Tirpack@santos.com> Subject: ![EXT]: OSA informal review request.pdf Mr. Tirpak, Is there is date and time Oil Search has available for informal review request? Also, please send letters and correspondence via email and you can choose to deliver a paper copy as well. Email to myself is acceptable for docket related matters. Thank you, Samantha Coldiron AOGCC Special Assistant Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, AK 99501 (907) 793-1223 Santos Ltd A.B.N. 80 007 550 923Disclaimer: The information contained in this email is intended only for the use of the person(s) to whom it is addressed and may be confidential or contain privileged information. If you are not the intended recipient you are hereby notified that any perusal, use, distribution, copying or disclosure isstrictly prohibited. If you have received this email in error please immediately advise us by return email and delete the email without making a copy.Please consider the environment before printing this email 2 Alaska Oil and Gas Conservation Commission 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907.279.1433 Fax: 907.276.7542 www.aogcc.alaska.gov April 19, 2024 CERTIFIED MAIL – RETURN RECEIPT REQUESTED 7018 0680 0002 2049 1211 Mr. Rob Tirpack Oil Search Alaska, LLC 900 E. Benson Blvd Anchorage, AK 99508 Re: Docket Number: OTH-24-019 Notice of Proposed Enforcement Action Compliance with PTD 223-087 NDBi-044 Dear Mr. Tirpack: Pursuant to 20 AAC 25.535, the Alaska Oil and Gas Conservation Commission (AOGCC) hereby notifies Oil Search Alaska, LLC (OSA) of a proposed enforcement action. Nature of the Apparent Violation or Noncompliance (20 AAC 25.535(b)(1)). OSA has violated the provisions of 20 AAC 25.015(b)(2) (“Changes to a program in a permit to drill”) while performing drilling operations at NDBi-044. Basis for Finding the Violation or Noncompliance (20 AAC 25.535(b)(2)). On October 17, 2023, the AOGCC approved Permit to Drill (PTD) 223-087, authorizing OSA to drill the well. Drilling operations were completed by OSA on December 22, 2023. Per 20 AAC 25.015(b)(2), an operator may not undertake a change to an approved program or activity without AOGCC Sundry approval. To make a change, the well’s current condition and proposed change must be provided to the AOGCC for review and approval. The AOGCC investigation indicates OSA failed to follow the procedure in the approved permit to drill as described below: 1) The PTD approved the stage collar for the 2 nd stage cement of the 9-5/8” liner to be set at 6750’ MD. This depth was intended to cover the Tuluvak formation, as required in Pool Rule #6 of Conservation Order 807. Docket Number: OTH-24-019 Notice of Proposed Enforcement April 19, 2024 Page 2 of 3 2) On October 30, 2023, OSA sent an email to the AOGCC titled “Permit 223-087 NDBi-044 Operational Changes”. This email informed AOGCC of OSA’s plans to: a. Make minor changes to the directional plan. b. Install a 9-5/8” tieback casing string. c. Move the 2nd stage cement job collar from 6,750’ MD to 4,126’ MD, based on a re- interpretation of the Tuluvak’s “productive interval.” 3) On November 1, 2023, the AOGCC replied to the October 30th email with the following questions: “Regarding Item 3 in your email below [item 2c above], what criteria are now used to determine the Tuluvak productive interval? How have they changed? Please provide a cross-section displaying correlation of the expected Tuluvak productive interval in NDB-044 with nearby wells DW-02, NDB-032, and NDB-043/043A.” 4) On November 6, 2023, OSA replied to the November 1 email with an attachment that included a cross section of nearby wells showing a shallower proposed depth for the 2nd stage cement job collar based upon an interpreted gas-oil-contact but did not provide justification for why oil-bearing sands should be left uncemented. 5) On November 21, 2023, OSA ran the 9-5/8” liner and installed the 2nd stage cement collar at 4,158’ MD, which is 2,592’ shallower than approved in the PTD and does not comply with Rule 6 of Conservation Order 807. 6) On December 1, 2023, OSA ran the 9-5/8” tieback casing string, which was not included in the approved PTD. The proposed change in 2a above did not require Sundry approval because the bottomhole location did not change by more than 500 feet. The proposed changes in 2b and 2c above did require sundry approval. The AOGCC has no record of receiving an Application for Sundry Approvals (Form 10- 403) nor any verbal or written approval for these changes. Proposed Action (20 AAC 25.535(b)(3)). For violating 20 AAC 25.015(b)(2) and Rule 6 of Conservation Order 807, the AOGCC intends to impose a civil penalty on OSA under AS 31.05.150(a) in the amount of $30,000 for failing to follow an approved permit to drill.1 In addition to the imposed civil penalty, AOGCC intends to require OSA to provide a detailed written explanation that describes how OSA intends to prevent recurrence of this violation. As an operator involved in an enforcement action you are required to preserve documents concerning the above actions until after resolution of the proceeding. 1 AS 31.05.150(a) provides for not more than $100,000 for the initial violation and not more than $10,000 for each day thereafter on which the violation continues. The proposed amount is a $30,000 initial penalty. AS 31.05.150(g) requires the AOGCC to consider nine criteria in setting the amount of a civil penalty. Docket Number: OTH-24-019 Notice of Proposed Enforcement April 19, 2024 Page 3 of 3 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 – OSA 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 OSA an opportunity to submit documentary material and make a written or oral statement. If OSA 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. If OSA does not concur in the proposed action described herein, and the AOGCC finds that OSA 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 OSA 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. Chair, Commissioner Brett W. Huber, Sr. Digitally signed by Brett W. Huber, Sr. Date: 2024.04.21 10:11:18 -05'00' 1 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. From:Thompson, Jacob (Jacob) To:McLellan, Bryan J (OGC) Subject:Permit 223-087 NDBi-044 Operational Changes Date:Monday, October 30, 2023 4:08:36 PM Attachments:image007.png image008.png image009.png Visio-NDBi-044 Rev G.0 Schematic Tieback_Stage Collar Update.pdf Bryan, Based on our fast moving continuous improvement process we have made several changes to the NDBi-044 well design. Below is a list of the changes to the planned well along with a justification for them. 1. Directional path has been altered to put a tangent section from 990’ – 1,140’ TVD, and the shallow section has a lower build rate. There has been a consistent and corrilatable hard streak seen on each development well. This hard streak is suspected to have played a roll in the surface casing being parted on NDB-024. This change does not inhibit our ability to reach our bottom hole targets or affect our area of review. 2. We are electing to run a 9-5/8” tieback to surface. The original plan was to leave the tieback out, but after further evaluation it was determined to be prudent to mitigate the risk associated with lower annular velocities while drilling the production hole and higher mechanical loads on the surface casing during pressure testing. This change affects the well program in the following ways: a. The proposed variance request to pressure test the 13-3/8” surface casing to above 70% of its internal yield pressure is no longer required. b. The 13-3/8” surface casing will be pressure tested to 2,600 psi which allow MASP + a Safety Factor. c. 9-5/8” tieback and liner will be pressure tested to 3,000 psi after installation. d. The MIT-IA will be testing the 4-1/2” x 9-5/8” to 4,000 psi after completion is landed. 3. A more detailed petrophysical analysis was conducted to determine the base of the Tuluvak’s productive zone based on offset wells. The base of the Tuluvak’s productive interval was determined to be 2,725’ TVD / 3,626’ MD (originally prognosed at 3,181’ TVD/ 6,750’ MD and covered the entirety of the Tuluvak). We’ll be placing the stage collar at 4,126’ MD or 500’ below the productive portion of the Tuluvak. This will allow for 15.3 ppg tail slurry to be pumped from the stage collar depth to the top of the liner, thus improving cement quality across the productive interval. This concludes the changes to the NDBi-044 Plan. Feel free to reach out with any questions, and thank you for your time. Jacob Thompson – Senior Drilling EngineerOil Search (Alaska), LLC a subsidiary of Santos Limited P.O. Box 240927 Anchorage, Alaska 99524-0927 o: +1 (907) 646-7079| m: +1 (907) 854-4377 Jacob.Thompson@santos.com https://www.santos.com/ Santos Ltd A.B.N. 80 007 550 923Disclaimer: The information contained in this email is intended only for the use of the person(s) to whom it is addressed and may be confidential orcontain privileged information. If you are not the intended recipient you are hereby notified that any perusal, use, distribution, copying or disclosure is NDBi-044 GL 20" Insulated Conductor128' MD 9-5/8" Liner Hanger and Liner Top Packer2,376' MD 13-3/8" 68 ppf L-80 Surface Casing2,526' MD 1-½” GLM Shear Valve~1,600' MD / ~1,540' TVD 4-½” X-Nipple~1,500' MD 4-½” X-Nipple~10,708 MD 9-5/8", 47ppf L-80 Intermediate Liner11,118' MD 4-½”, 12.6ppf P-110S Production Liner 17,837' MD 4-½” Liner Hanger and Liner Top Packer10,968' MD / 4,033' TVD 4-½” 12.6ppf P-110S Completion w/ Tieback Seals~10,988' MD 4-½” X-Nipple~10,812' MD 4-½” Openhole Packers one every 500' -700' with Frac Ports Toe Sleeve Shutoff Collar *Quantity of openhole packer and frac sleeve may change Archer C-Flex Two-Stage Cementing Tool~4,126' MD TOC First Stage Cement Job - 250' TVD above Nanushuk~8,350' MD 16" Hole Size 12-1/4" Hole Size 8-1/2" Hole Size 4-½” Downhole Psi/Temp Gauge~10,760' MD / ~4,003 TVD 4-½” X-Nipple~1,700' MD 9-5/8" Tieback and Seal Assembly2,370' MD