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Alaska Oil and Gas Conservation Commission
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HomeMy WebLinkAboutCO 817CONSERVATION ORDER 816
Milne Point Unit
Kuparuk River Oil Pool
Schrader Bluff Oil Pool
Sag River Oil Pool
Ugnu Undefined Oil Pool
1. May 17, 2024 Hilcorp gas offtake allowable application
2. May 23, 2024 Notice of public hearing and affidavit of publication
STATE OF ALASKA
ALASKA OIL AND GAS CONSERVATION COMMISSION
333 West 7th Avenue
Anchorage, Alaska 99501
Re: THE APPLICATION OF HILCORP
ALASKA, LLC. to establish an
allowable gas offtake for the Milne
Point Unit
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Conservation Order 817
Docket Number CO-24-007
Milne Point Unit
Kuparuk River Oil Pool
Schrader Bluff Oil Pool
Sag River Oil Pool
Ugnu Undefined Oil Pool
July 23, 2024
IT APPEARING THAT:
By application dated May 17, 2024, Hilcorp Alaska, LLC. (Hilcorp), as the operator of the
Milne Point Unit (MPU), requested the Alaska Oil and Gas Conservation Commission
(AOGCC) issue an order establishing an allowable gas offtake for the MPU to allow the MPU
to sell compressed natural gas (CNG) to a third party.
Pursuant to 20 AAC 25.540, the AOGCC tentatively scheduled a public hearing for June 27,
204. On May 23, 2024, 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. On May 27, 2024,
the notice was published in the ANCHORAGE DAILY NEWS.
The AOGCC received no comments or request to hold the proposed hearing.
The tentatively scheduled hearing was vacated.
FINDINGS:
1. Operators: Hilcorp is the operator of the MPU.
2. Owners and Landowners: Hilcorp, 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. Proposed CNG Sales: Hilcorp is negotiating to sell CNG produced from the MPU to Alaska
CNG, LLC (AK CNG) who in turn will sell the CNG to other customers.
4. MPU Oil Pools: There are three defined and one undefined oil pools in the MPU, these are
from shallowest to deepest: the Ugnu Undefined Oil Pool, the Schrader Bluff Oil Pool, the
Kuparuk River Oil Pool, and the Sag River Oil Pool. Production from these pools are
commingled on the surface and processed in the MPU’s processing facilities.
5. Proposed CNG Sales Daily Volume: Hilcorp proposes selling up to 1,500 MSCFPD, on an
annualized average basis, of produced gas in the form of CNG to AK CNG.
6. Potential Impacts on Ultimate Recovery: The MPU currently process approximately 40
MMSCF of gas and reinjects 15 MMSCF of gas for enhanced oil recovery (EOR) purposes on
a daily basis. The 1.5 MMSCFPD of gas that Hilcorp proposes to sell would amount to
Conservation Order 817
July 23, 2024
Page 2
approximately 10% of the volume of gas available for EOR injection in the MPU. The MPU
injects approximately 120 MBW per day, with some going to EOR and some going to disposal.
The main fluid injected for EOR purposes at the MPU is water. On a reservoir barrel basis,
water injection accounts for approximately 80% of the EOR fluid injected in the MPU.
Therefore the 10% loss of EOR gas injection that would occur through sales of CNG accounts
for only 2% of the total volume of fluids injected for EOR purposes. This small of a decrease
in the amount of fluids injected for EOR purposes would not have a significant impact on
ultimate recovery from the field. Additionally, the decrease in EOR injection as a result of gas
sales can easily be made up for by taking some water that is going to disposal injection and
using it for EOR injection instead.
CONCLUSION:
1. Sales of CNG from the MPU to AK CNG will not have a meaningful impact on the ultimate
recovery from the MPU, and any impacts could be mitigated by increase water injection for
EOR purposes.
NOW, THEREFORE, IT IS ORDERED:
The maximum annual average gas offtake rate for the MPU is 1,500 MSCFPD. This is a
cumulative amount for all oil pools in the MPU. This applies to production from all defined and
undefined oil pools in the MPU and to both known and any as yet to be discovered oil pools in the
MPU.
DONE at Anchorage, Alaska and dated July 23, 2024.
Jessie L. Chmielowski Gregory C. Wilson
Commissioner Commissioner
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 reconsider-
ation 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.
Gregory Wilson Digitally signed by Gregory Wilson
Date: 2024.07.23 14:07:47 -08'00'
Jessie L.
Chmielowski
Digitally signed by
Jessie L. Chmielowski
Date: 2024.07.23
14:45:41 -08'00'
2
Notice of Public Hearing
STATE OF ALASKA
ALASKA OIL AND GAS CONSERVATION COMMISSION
RE: Docket Number: CO-24-007
Hilcorp Alaska, LLC (Hilcorp), by letter dated May 17, 2024, filed an application to the Alaska
Oil and Gas Conservation Commission (AOGCC) to establish an allowable gas offtake rate of
1,500 MCF/D for the Milne Point Unit (MPU) to allow sales of compressed natural gas (CNG) to
third parties. AS 31.05.030(e)(1)(F) allows the AOGCC to regulate the rate at which oil or gas is
withdrawn from a well or field for the purpose of conservation.
Hilcorp is negotiating with Alaska CNG, LLC (AKCNG) to sell CNG from the MPU to AKCNG
and possibly additional parties in the future. Selling natural gas from the MPU will reduce the
amount of gas available for re-injection into the pools in the MPU for pressure maintenance and
enhanced oil recovery (EOR) purposes, which has the potential for reducing ultimate recovery
from the field. Hilcorp states the gas reinjection loss can easily be made up by increased water
injection, which is the main fluid injected for pressure maintenance and EOR purposes.
This notice does not contain all the information filed by Hilcorp. To obtain more information,
contact the AOGCC’s Special Assistant, Samantha Coldiron, at (907) 793-1223 or
samantha.coldiron@alaska.gov.
A public hearing on the matter has been tentatively scheduled for June 27, 2024, at 10:00 a.m. The
hearing, which may be changed to full virtual, if necessary, will be held in the AOGCC hearing
room located at 333 West 7th Avenue, Anchorage, AK 99501. The audio call-in information is
(907) 202-7104 Conference ID: 433 773 304#. Anyone who wishes to participate remotely using
MS Teams video conference should contact Ms. Coldiron at least two business days before the
scheduled public hearing to request an invitation for the MS Teams. To request that the tentatively
scheduled hearing be held, a written request must be filed with the AOGCC no later than 4:30 p.m.
on June 10, 2024.
If a request for a hearing is not timely filed, the AOGCC may issue an order without a hearing. To
learn if the AOGCC will hold the hearing, call (907) 793-1223 after June 12, 2024.
In addition, written comments regarding this application may be submitted to the AOGCC, at 333
west 7th Avenue, Anchorage, AK 99501 or samantha.coldiron@alaska.gov. Comments must be
received no later than 4:30 p.m. on June 24, 2024, except that, if a hearing is held, comments must
be received no later than the conclusion of the June 27, 2024, hearing.
If, because of a disability, special accommodations may be needed to comment or attend the
hearing, contact Samantha Coldiron, at (907) 793-1223, no later than June 20, 2024.
Brett W. Huber, Sr.
Chair, Commissioner
Brett W. Huber,
Sr.
Digitally signed by Brett W.
Huber, Sr.
Date: 2024.05.23 07:44:59 -08'00'
Lisi Misa being first duly sworn on oath deposes
and says that she is a representative of the An-
chorage Daily News, a daily newspaper. That
said newspaper has been approved by the Third
Judicial Court, Anchorage, Alaska, and it now
and has been published in the English language
continually as a daily newspaper in Anchorage,
Alaska, and it is now and during all said time
was printed in an office maintained at the afore-
said place of publication of said newspaper.
That the annexed is a copy of an advertisement
as it was published in regular issues (and not in
supplemental form) of said newspaper on
AFFIDAVIT OF PUBLICATION
______________________________________
Notary Public in and for
The State of Alaska.
Third Division
Anchorage, Alaska
MY COMMISSION EXPIRES
______________________________________
05/27/2024
and that such newspaper was regularly distrib-
uted to its subscribers during all of said period.
That the full amount of the fee charged for the
foregoing publication is not in excess of the rate
charged private individuals.
Signed________________________________
Subscribed and sworn to before me
Account #: 100869 ST OF AK/AK OIL AND GAS CONSERVATION COMMISSION333 W. 7TH AVE STE 100, ANCHORAGE, AK 99501
Order #: W0045966 Cost: $335.94
Notice of Public Hearing
STATE OF ALASKAALASKA OIL AND GAS CONSERVATION COMMISSION
RE: Docket Number: CO-24-007
Hilcorp Alaska, LLC (Hilcorp), by letter dated May 17, 2024, filed an
application to the Alaska Oil and Gas Conservation Commission (AOGCC) to establish an allowable gas offtake rate of 1,500 MCF/D
for the Milne Point Unit (MPU) to allow sales of compressed natural gas (CNG) to third parties. AS 31.05.030(e)(1)(F) allows the AOGCC to
regulate the rate at which oil or gas is withdrawn from a well or field for the purpose of conservation.
Hilcorp is negotiating with Alaska CNG, LLC (AKCNG) to sell CNG from
the MPU to AKCNG and possibly additional parties in the future. Selling natural gas from the MPU will reduce the amount of gas available
for re-injection into the pools in the MPU for pressure maintenance and enhanced oil recovery (EOR) purposes, which has the potential
for reducing ultimate recovery from the field. Hilcorp states the gas reinjection loss can easily be made up by increased water injection,
which is the main fluid injected for pressure maintenance and EOR purposes.
This notice does not contain all the information filed by Hilcorp. To
obtain more information, contact the AOGCC’s Special Assistant, Samantha Coldiron, at (907) 793-1223 or samantha.coldiron@alaska.
gov.
A public hearing on the matter has been tentatively scheduled for June 27, 2024, at 10:00 a.m. The hearing, which may be changed
to full virtual, if necessary, will be held in the AOGCC hearing room located at 333 West 7th Avenue, Anchorage, AK 99501. The audio
call-in information is (907) 202-7104 Conference ID: 433 773 304#. Anyone who wishes to participate remotely using MS Teams video
conference should contact Ms. Coldiron at least two business days before the scheduled public hearing to request an invitation for the
MS Teams. To request that the tentatively scheduled hearing be held, a written request must be filed with the AOGCC no later than 4:30
p.m. on June 10, 2024.
If a request for a hearing is not timely filed, the AOGCC may issue an order without a hearing. To learn if the AOGCC will hold the hearing,
call (907) 793-1223 after June 12, 2024.
In addition, written comments regarding this application may be submitted to the AOGCC, at 333 west 7th Avenue, Anchorage, AK
99501 or samantha.coldiron@alaska.gov. Comments must be received no later than 4:30 p.m. on June 24, 2024, except that, if
a hearing is held, comments must be received no later than the conclusion of the June 27, 2024, hearing.
If, because of a disability, special accommodations may be needed to
comment or attend the hearing, contact Samantha Coldiron, at (907) 793-1223, no later than June 20, 2024.
Brett W. Huber, Sr.
Chair, Commissioner
Pub: May 27, 2024
STATE OF ALASKA
THIRD JUDICIAL DISTRICT
______________________________________2024-05-28
2024-07-14
Document Ref: EEONI-9VMFV-P5CSL-OCECR Page 3 of 31
From:Coldiron, Samantha J (OGC)
To:AOGCC_Public_Notices
Subject:[AOGCC_Public_Notices] Public Hearing Notice (Hilcorp)
Date:Thursday, May 23, 2024 8:23:30 AM
Attachments:CO-24-007 Public Hearing Notice MPU gas offtake allowable.pdf
Docket Number: CO-24-007
Hilcorp Alaska, LLC (Hilcorp), by letter dated May 17, 2024, filed an application to the
Alaska Oil and Gas Conservation Commission (AOGCC) to establish an allowable gas
offtake rate of 1,500 MCF/D for the Milne Point Unit (MPU) to allow sales of compressed
natural gas (CNG) to third parties. AS 31.05.030(e)(1)(F) allows the AOGCC to regulate the
rate at which oil or gas is withdrawn from a well or field for the purpose of conservation.
Samantha Coldiron
AOGCC Special Assistant
Alaska Oil and Gas Conservation Commission
333 West 7th Avenue
Anchorage, AK 99501
(907) 793-1223
__________________________________
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May 17, 2024
ATTN: Dave Roby
Alaska Oil and Gas Conservation Commission
333 W 7th Ave, STE 100
Anchorage, AK 99501
Dave.Roby@alaska.gov
RE: Gas Offtake Allowable Application
Milne Point Field
Kuparuk River Oil Pool, Schrader Bluff Oil Pool,
Sag River Oil Pool and Ugnu Undefined Oil Pool
Dear Mr. Roby:
Hilcorp Alaska, LLC (“Hilcorp”) is negotiating an agreement to provide Alaska CNG, LLC with
natural gas from the Milne Point Field. This natural gas is to be delivered at the custody transfer
meter at the Milne Point Facility (“MPF”). The natural gas will then be transported to customers
across the North Slope. Initial deliveries are expected to commence in July 2024. Hilcorp may also
enter into additional gas sales contracts with other entities for the same or similar purposes. Alaska
CNG, LLC and other purchasers will hereafter be referred to as “Purchasers.”
The regulations promulgated by the Alaska Oil and Cas Conservation Commission (“AOGCC”)
do not expressly address gas allowables or specify procedures for AOGCC approval of natural gas
production from an oil field, and most existing pool rules do not address the issue. However, we
recognize the authority of the AOGCC under AS 31.05.030(e)(1)(F) to regulate for conservation
proposesthe quantity and rate of production of gas from a property. For the reasons set forth below,
Hilcorp, as operator and on behalf of the working interest owners of the Milne Point Unit, seeks
AOGCC approval of the above-referenced gas delivery to Purchasers on the grounds that this
offtake is consistent with good oilfield engineering practices and conservation purposes.
The Milne Point Field is comprised of the Kuparuk River Oil Pool, Schrader Bluff Oil Pool, Sag
River Oil Pool, and Ugnu Undefined Oil Pool which are processed through the MPF. The gas
produced from these oil pools are separated from the oil and water at the MPF and is used for fuel
gas for power generation, gas lift, and compressed natural gas for in-field fuel for trucks. The
remaining gas is reinjected back into the Kuparuk River Oil Pool for pressure support and
additional oil recovery. The total volume of processed gas at the MPF is approximately 40,000
mscfd, and approximately 15,000 mscfd is reinjected.
The overwhelming majority of pressure support is supplied by water injection with the injection
of approximately 120,000 bbls of water per day. The loss of reservoir voidage from gas sales can
be made with increased water injection which is readily available. Thus, diverting up to 1,500
mscfd of gas from injection to gas sales will not have a measurable impact on production or
ultimate recovery of oil from the Milne Point Field oil pools.
P.O. Box 244027
Anchorage, AK 99524-4027
3800 Centerpoint Drive, Ste. 1400
Anchorage, AK 99503
Phone: 907-777-8341
Fax: 907-777-8301
Email: jamie.wilson@hilcorp.com
By Samantha Coldiron at 9:09 am, May 20, 2024
AOCGG Gas Offtake Allowable
Milne Point Field
Page 2 of 2
Hilcorp is requesting an approval of one million five hundred standard cubic feet per day (1,500
mscfd) of natural gas offtake allowables to Purchasers.
In conclusion, pursuant to Rule 12 of Conservation Order No. 432 E (Kuparuk River Oil Pool),
Rule 11 of Conservation Order No. 477 (Schrader Bluff Oil Pool), Rule 14 of Conservation Order
No. 423 (Sag River Oil Pool), Hilcorp asks the AOGCC to administratively approve additional
third party gas deliveries of up to one million five hundred standard cubic feet per day (1,500
mscfd) from the Milne Point Field beginning July 2024.
Please contact the undersigned should you have any questions.
Sincerely,
Hilcorp Alaska, LLC
Jamie Wilson
Sr. Landman
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From:Jamie Wilson
To:Roby, David S (OGC)
Cc:Coldiron, Samantha J (OGC); Bradley Simpson; Aaron O"Quinn
Subject:RE: [EXTERNAL] MPU gas offtake application
Date:Thursday, May 23, 2024 8:48:43 AM
Dave,
Thanks for reaching out! Our answers are below in red.
Let us know if you have any additional questions.
Thanks,
Jamie
From: Roby, David S (OGC) <dave.roby@alaska.gov>
Sent: Monday, May 20, 2024 10:34 AM
To: Jamie Wilson <jamie.wilson@hilcorp.com>
Cc: Coldiron, Samantha J (OGC) <samantha.coldiron@alaska.gov>
Subject: [EXTERNAL] MPU gas offtake application
Hi Jamie,
I’m reviewing your application for the MPU gas offtake and preparing the public notice and have a
question for you. In the application it states “[t]he loss of reservoir voidage from gas sales can be
made with increased water injection which is readily available.” How much additional water
injection would it take to replace the 1,500 MCF/D proposed?
The gas used for CNG would normally be injected into the Kuparuk formation. The Kuparuk
formation volume factor (Bg) for gas in the Kuparuk is 0.88 rb/Mscf and the formation volume factor
for water in the Kuparuk (Bw) is 1.02 rb/stb. Therefore, 1,500 Mscf/d *Bg / Bw = 1,294 stb/d of
water injection required to make up the loss in gas injection.
We currently dispose of ~20,000 bwpd in the MPU B-50. Any loss of gas injection voidage could be
made up by decreasing the disposal at B-50 and putting it back into the surface system. In addition,
we have an approved project that will re-distribute gas injection on F-pad and L-pad. Once
completed we will also have additional source water capacity on F-pad and L-pad to make up
additional voidage requirements from CNG sales.
Also, do you want the 1,500 MCF/D to be a hard limit (you couldn’t sell more than 1,500 MCF in any
given day) or do you want the 1,500 MCF/D to be a max average daily volume (as long as the
average daily rate for the year is less than 1,500 MCF/D you’re OK even if you exceed the 1,500 MCF
on some days)it to be a nominal value)? We would like the 1,500 mcfd to be a max daily average
over a year timeframe for operational flexibility.
Regards,
Dave Roby
Senior Reservoir Engineer
Alaska Oil and Gas Conservation Commission
(907)793-1232
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