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Home My WebLink AboutAIO 024 CAREA INJECTION ORDER 24C Prudhoe Bay Unit Borealis Oil Pool North Slope, Alaska 1. July 24, 2018 BPXA’s request for amendment AIO24B to authorize downhole commingling of injection between two pools 2. November 18, 2018 Notice of public hearing, affidavit of publication, email distribution list, and mailings 3. November 22, 2022 Hilcorp request for administrative approval for continued WAG injection into Borealis well Z-25 with slow tubing by inner annulus (IA) communication. (AIO 24C.001) 4. January 23, 2024 Hilcorp request for Admin Approval to allow WAG injections for Well Z-103 (PTD 204-229) (AIO 24C.002) 5. February 20, 2024 Hilcorp request for Admin Approval to allow WAG Injections for Well Z-114 (PTD 213-065) (AIO 24C.003) STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West 71" Avenue Anchorage Alaska 99501 Re: THE APPLICATION OF BP Exploration ) Docket Number: AIO-18-034 (Alaska) Inc. for amendments to Area ) Area Injection Order No. 24C Injection Order 24B to authorize the ) downhole commingling of injection between ) Prudhoe Bay Unit the Prudhoe Oil Pool and the Borealis Oil ) Borealis Oil Pool Pool. ) North Slope Borough, Alaska CORRECTED April 8, 2019 Nunc pro tunc April 3, 2019 IT APPEARING THAT: By application received July 24, 2018, BP Exploration (Alaska) Inc. (BPXA) in its capacity of operator of the Prudhoe Bay Unit (PBU) requested that Area Injection Order (AIO) 24B be amended to allow downhole commingling of injection between the Prudhoe Oil Pool (POP) and the Borealis Oil Pool (BOP). Pursuant to 20 AAC 25.540, the Alaska Oil and Gas Conservation Commission (AOGCC) scheduled a public hearing for December 19, 2018. On November 16, 2018, the AOGCC published notice of that hearing on the State of Alaska's Online Public Notice website and on the AOGCC's website, electronically transmitted the notice to all persons on the AOGCC's email distribution list, and mailed printed copies of the Notice of Public Hearing to all persons on the AOGCC's mailing distribution list. On November 18, 2018, the notice was published in the Anchorage Daily News. No one requested that the hearing be held or submitted comments on BPXA's application. BPXA provided sufficient information to make a decision so the hearing was vacated. FINDINGS: Operator and Owners: BPXA is the operator of the leases in the portion of the PBU within the Affected Area of this order. BPXA, ExxonMobil, CPAI, and Chevron are the Working Interest Owners, and the State of Alaska, Department of Natural Resources (DNR) is the landowner of the Affected Area, which is located within the North Slope Borough, along Alaska's northern coastline. 2. Affected Area: The Affected Area is defined in AIO 24B, and it remains unchanged for this amended order. AOGCC Authority: The U.S. Environmental Protection Agency (EPA) has granted the AOGCC regulatory primacy limited to underground injection control (UIC) Class II wells. Borealis Oil Pool: The BOP is one of several oil pools in the Kuparuk formation that overlies the POP, it is present in the Drill Site L, V, and Z areas of the PBU. The BOP is authorized for lean and miscible gas injection as well was water injection for enhanced recovery purposes. Commingled injection between BOP and POP does not currently occur. Area Injection Order 24C April 8, 2019 Page 2 of 6 5. Prudhoe Oil Pool: The POP is a massive, highly productive reservoir that has multiple enhanced recovery injection projects occurring simultaneously in different portions of the pool. These recovery projects include lean and miscible gas injection, conventional water injection, gas cap water injection, and water -alternating -gas injection. The POP lies beneath several smaller pools in the Kuparuk and Schrader Bluff formations and it lies above the Lisburne Oil Pool. Many POP wells encounter two or more pools on the way to total depth. 6. Gas Source: The lean and miscible gas used for injection in the POP and BOP is sourced from the PBU Central Gas Facility and Central Compression Plant. Drill Sites L, V, and Z contain BOP and POP wells, so the gas available for enhanced recovery injection is the same for both the BOP and the POP. 7. Maximization of Ultimate Recovery: Several POP wells penetrate the BOP in a location that could be advantageous for providing enhanced recovery injection operations for that pool. Some of these locations have insufficient reserves to justify a standalone injection well, so commingling injection with the POP provides an opportunity to enhance recovery that otherwise would not be available. 8. Infection Conformance: Downhole chokes can be installed between the BOP and POP to ensure the proper amount of injection fluid for each pool. Additionally, a plug or tubing patch can be installed to shut off all injection to the POP or BOP respectively in the event one pool no longer needs injection support. 9. Prevention of Crossflow: During injection operations crossflow between the two pools will not be possible. During extended shut in periods crossflow could occur, but this can be prevented by setting a plug in the tubing between the BOP and POP. 10. Allocation of Injection Volumes: Injectivity profiles can be developed by obtaining injection rate and pressure data for at least one zone and differentially determining the injection rate in the other zone. Within 60 days of commencing commingled injection and within 60 days of the initial swap of injection fluid an injection survey or multi -rate injection profile would be run on each well to develop the injectivity profile. If deemed necessary, additional injection surveys or multi -rate injectivity tests would be conducted as injection performance dictates or upon AOGCC request. CONCLUSIONS: 1. Amendment of AIO 24B is necessary to authorize pool wide commingled injection between the BOP and POP. 2. Commingled injection will allow for improved recovery from the PBU by making enhanced recovery injection possible in portions of the BOP where it isn't currently economically feasible to drill a dedicated injection well. 3. Waste will be minimized by providing proper injection conformance and by setting plugs or patches to prevent crossflow on wells that are shut in for extended periods of time. 4. Injection volumes can be properly allocated by developing injectivity profiles for individual injection wells. Area Injection Order 24C April 8, 2019 Page 3 of 6 NOW, THEREFORE, IT IS ORDERED: In addition to statewide requirements under 20 AAC 25 (to the extent not superseded by these rules), the following rules govern Class II injection operations in the affected area described below and supersede and replace the rules adopted in Area Injection Order No. 24B dated January 30, 2008: Umiat Meridian T12N-R10E: ADL 25637 Sec 13, 24 T12N-R11E: ADL 47447 Sec 16 (SW/4 and W/2 NW/4 and W/2 SE/4), 21, 22 SWA and W/2 NW/4 and S/2 SEA ADL 47446 Sec 17, 18, 19, 20 ADL 28238 Sec 26 S/2 and W/2 NW/4 and SE/4 NW/4, 35, 36 ADL 28239 Sec 27, 28, 33, 34 ADL 47449 Sec 29, 30, 32 T11N-R11E: ADL 28240 Sec 1, 2, 11, 12 ADL 28241 Sec 3, 4, 9, 10 ADL 28245 Sec 13, 14, 24 ADL 28244 Sec 15 ADL 28246 Sec 25 T11N-R12E: ADL 28261 Sec 9 W/2 ADL 47450 Sec 5 S/2, 6 S/2 and NW/4 and W/2 NE/4, 7, 8 ADL 28263 Sec 16 W/2, 21 W/2 ADL 28262 Sec 17, 18, 19, 20 ADL 47452 Sec 28 W/2, 33 W/2 ADL 47453 Sec 29, 30, 31, 32 T12N-R12E: ADL 28259 Sec 31 W/2 and W/2 SE/4 Area Injection Order 24C April 8, 2019 Page 4 of 6 Rule 1 Authorized Infection Strata for Enhanced Recovery Injection of authorized fluids for purposes of pressure maintenance and enhanced recovery is permitted into strata that are common to, and correlate with, the interval between 6534' and 6952' MD in the West Kuparuk State #1 well in the Prudhoe Bay Field. Rule 2 Authorized Infection Fluids Fluids authorized for injection within the affected area are: a. produced water from Borealis Oil Pool or Prudhoe Bay Unit production facilities for the purposes of pressure maintenance and enhanced recovery; b. non -hazardous water collected from Borealis well house cellars and standing ponds; c. tracer survey fluid to monitor reservoir performance; d. source water from a seawater treatment plant; e. enriched hydrocarbon gas from the Prudhoe Bay Unit processing facilities, with the condition that the average Borealis Oil Pool reservoir pressure must be maintained above the minimum miscibility of the injectant; and f. source water from the Prince Creek Formation. Rule 3 Fluid Injection Wells The underground injection of fluids must be through a well that has been permitted for drilling as a service well for injection in conformance with 20 AAC 25.005, or through a well approved for conversion to a service well for injection in conformance with 20 AAC 25.280 and 20 AAC 25.412. The application to drill or convert a well for injection must be accompanied by sufficient information to verify the mechanical condition of wells within one-quarter mile radius. The information must include cementing records, cement quality log or formation integrity test records. Rule 4 Monitoring the Tubing -Casing Annulus Pressure Variations The tubing by casing annulus pressure and injection rate of each injection well must be checked at least weekly to confirm continued mechanical integrity. Rule 5 Demonstration of Tubing -Casing Annulus Mechanical Integrity The mechanical integrity of an injection well must be demonstrated before injection begins, and before returning a well to service following a workover affecting mechanical integrity. A Commission -witnessed mechanical integrity test must be performed after injection is commenced for the first time in a well, to be scheduled when injection conditions (temperature, pressure, rate, etc.) have stabilized. Subsequent tests must be performed at least once every four years thereafter (except at least once every two years in the case of a slurry injection well). The Commission must be notified at least 24 hours in advance to enable a representative to witness mechanical integrity tests. Unless an alternate means is approved by the Commission, mechanical integrity must be demonstrated by a tubing by casing annulus pressure test using a surface pressure of 1500 psi or Area Injection Order 24C April 8, 2019 Page 5 of 6 0.25 psi/ft multiplied by the vertical depth of the packer, whichever is greater, that shows stabilizing pressure and does not change more than 10 percent during a 30 -minute period. Results of mechanical integrity tests must be readily available for Commission inspection. Rule 6 Well Integrity Failure Whenever any pressure communication, leakage or lack of injection zone isolation is indicated by injection rate, operating pressure observation, test, survey, log, or other evidence, the Operator shall notify the Commission by the next business day and submit a plan of corrective action on a Form 10-403 for Commission approval. The Operator shall immediately shut in the well if continued operation would be unsafe or would threaten contamination of freshwater, or if so directed by the Commission. A monthly report of daily tubing and casing annuli pressures and injection rates must be provided to the Commission for all injection wells indicating well integrity failure or lack of injection zone isolation. Rule 7 Notification of Imnroner Class II Iniection Injection of fluids other than those listed in Rule 2 without prior authorization is considered improper Class II injection. Upon discovery of such an event, the operator must immediately notify the Commission, provide details of the operation, and propose actions to prevent recurrence. Additionally, notification requirements of any other State or Federal agency remain the operator's responsibility. Rule 8 Other conditions The Commission may immediately suspend, revoke, or modify this authorization if injected fluids fail to be confined within the designated injection strata. The operator must immediately notify the Commission of any out of zone injection. Rule 9 Wells Authorized for Downhole Commingled Iniection with the Prudhoe Oil Pool (New this order) Injection into the BOP and POP within the same wellbore is authorized for each well, subject to the following conditions. a. An Application for Sundry Approval (Form 10-403) must be approved by the AOGCC for each well prior to commencement of commingled injection. b. Within 60 days of commencement of commingled injection in a well, or upon initial switching from one injection fluid to the other, BPXA must conduct an injection survey or separate pool multi -rate injectivity test to determine the proper allocation of injected fluids. Thereafter as long as the well continues commingled injection allocation will be based on use of differential injectivity profiles or injection survey unless significant changes in total injectivity occur whereby an injection survey or separate pool injectivity test will be performed. c. Annual and total cumulative volumes injected by pool and results of logs, surveys, or separate pool multi -rate injectivity tests used for determining the allocation of injected fluids between pools must be supplied in the Annual Surveillance Report for the BOP. Area Injection Order 24C April 8, 2019 Page 6 of 6 Rule 10 Administrative Action (Renumbered this order) Unless notice and public hearing is otherwise required, the Commission may administratively waive the requirements of any rule stated above or administratively amend any rule as long as the change does not promote waste or jeopardize correlative rights, is based on sound engineering and geoscience principles, and will not result in an increased risk of fluid movement into freshwater. DONE at Anchorage, Alaska and dated April 8, 2019. iel T. Seamount, Jr. s�LCielowski T2s 5E' ommissioner Commissioner 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 itmay 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 Bernie Karl K&K Recycling Inc. P.O. Box 58055 Fairbanks, AK 99711 Gordon Severson 3201 Westmar Cir. Anchorage, AK 99508-4336 Penny Vadla 399 W. Riverview Ave. Soldotna, AK 99669-7714 George Vaught, Jr. Darwin Waldsmith Richard Wagner P.O. Box 13557 P.O. Box 39309 P.O. Box 60868 Denver, CO 80201-3557 Ninilchik, AK 99639 Fairbanks, AK 99706 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 ADMINISTRATIVE APPROVAL AREA INJECTION ORDER 24C.001 Mr. Stan Golis, PBW Operations Manager Hilcorp North Slope, LLC 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 Re: Docket Number: AIO-22-030 Request for Administrative Approval to Area Injection Order 24C: Water Alternating Gas Prudhoe Bay Unit (PBU) Z-25 (PTD 1881590), Borealis Oil Pool Dear Mr. Golis: By emailed letter dated November 22, 2022, Hilcorp North Slope, LLC (Hilcorp) requested administrative approval to continue water alternating gas (WAG) injection with a known tubing by inner annulus (TxIA) pressure communication. In accordance with 20 AAC 25.556(d), the Alaska Oil and Gas Conservation Commission (AOGCC) hereby GRANTS, subject to conditions, Hilcorp’s request for administrative approval to continue WAG injection in the subject well. Hilcorp reported a potential TxIA pressure communication to AOGCC on August 10, 2022, when the well was on miscible gas injection. Hilcorp performed diagnostics and extended monitoring which confirmed the TxIA. Hilcorp has performed additional diagnostics including a passing state-witnessed mechanical integrity test (MIT) of the inner annulus (to a test pressure of 3,534 psi) on November 22, 2022. This indicates that Z-25 exhibits at least two competent barriers to the release of well pressure. Hilcorp maintains live transmitters on the inner and outer annulus and alarm functions in the Supervisory Control and Data Acquisition (SCADA) system that create layers of protection from an over-pressure event. These inner and outer annulus alarms combined with the planned inner and outer annulus operating pressure limits enable AOGCC to continue to authorize gas injection. AOGCC believes Hilcorpcan safely manage the TxIA communication with periodic pressure bleeds by maintaining the IA to a pressure not to exceed 2,100 psi and OA to a pressure not to exceed 1,500 psi. Accordingly, the AOGCC believes that the well’s condition does not compromise overall well integrity so as to threaten human safety or the environment. AOGCC’s approval to continue WAG injection in PBU Z-25 is conditioned upon the following: 1) Hilcorp shall record wellhead pressures and injection rate daily; 2) Hilcorp shall submit to the AOGCC a monthly report of well pressures, injection rates, and pressure bleeds for all annuli. Bleeds to be flagged on the report; AIO 24C.001 December 5, 2022 Page 2 of 2 3) Hilcorp shall perform a MIT of the inner annulus every two years to the greater of the maximum anticipated injection pressure or 0.25 x packer TVD, but not less than 1,500 psi; 4) Hilcorp shall limit the well’s inner annulus operating pressure to 2,100 psi and the outer annulus operating pressure to 1,500 psi. Audible control room alarms shall be set at or below these limits; 5) Hilcorp shall monitor the inner and outer annulus pressures in real time with its SCADA system; 6) Hilcorp shall maintain the Production Control Center (PCC) remote shut down capability for Z-25 when on gas or miscible injectant (MI) operation. During gas/MI injection, the IA protocols will include a drill site operator and PCC alarm set at 2,100 psi, and a high alarm set at 3,000 psi that will prompt the PCC to remotely shut in the well; 7) Hilcorp shall immediately shut in the well and notify the AOGCC if there is any change in the well's mechanical condition; 8) After well shut in due to a change in the well's mechanical condition, AOGCC approval shall be required to restart injection; and 9) The next required MIT shall be completed before or during the month of November 2024. DONE at Anchorage, Alaska and dated December 5, 2022. Jessie L. Chmielowski Greg 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 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. Gregory Wilson Digitally signed by Gregory Wilson Date: 2022.12.05 14:14:18 -09'00' Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2022.12.05 14:17:30 -09'00' 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 ADMINISTRATIVE APPROVAL AREA INJECTION ORDER 24C.002 Mr. Torin Roschinger PBW Operations Manager Hilcorp North Slope, LLC 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 Re: Docket Number: AIO-24-007 Request for Administrative Approval to Area Injection Order 24C: Water Alternating Gas Prudhoe Bay Unit (PBU) Z-103 (PTD 2042290), Borealis Oil Pool Dear Mr. Roschinger: By emailed letter dated January 23, 2024, Hilcorp North Slope, LLC (Hilcorp) requested administrative approval to continuewater alternating gas (WAG) injection with a known tubing by inner annulus (TxIA) pressure communication. In accordance with 20 AAC 25.556(d), the Alaska Oil and Gas Conservation Commission (AOGCC) hereby GRANTS, subject to conditions, Hilcorp’s request for administrative approval to continue WAG injection in the subject well. Hilcorp reported a potential TxIA pressure communication to AOGCC on January 17, 2024, when the well was on miscible gas injection. Hilcorp performed diagnostics and extended monitoring which confirmed the TxIA. Hilcorp has performed additional diagnostics including a passing state-witnessed mechanical integrity test (MIT) of the inner annulus (to a test pressure of 3,160 psi) on January 22, 2024. This indicates that Z-103 exhibits at least two competent barriers to the release of well pressure. Hilcorp maintains live transmitters on the inner and outer annulus and alarm functions in the Supervisory Control and Data Acquisition (SCADA) system that create layers of protection from an over-pressure event. These inner and outer annulus alarms combined with the planned inner and outer annulus operating pressure limits enable AOGCC to continue to authorize gas injection. AOGCC believes Hilcorp can safely manage the TxIA communication with periodic pressure bleeds by maintaining the IA to a pressure not to exceed 2,100 psi and OA to a pressure not to exceed 1,000 psi. Accordingly, the AOGCC believes that the well’s condition does not compromise overall well integrity so as to threaten human safety or the environment. AOGCC’s approval to continue WAG injection in PBU Z-103 is conditioned upon the following: 1) Hilcorp shall record wellhead pressures and injection rate daily; AIO 24C.002 February 6, 2024 Page 2 of 2 2) Hilcorp shall submit to the AOGCC a monthly report of well pressures, injection rates, and pressure bleeds for all annuli. Bleeds to be flagged on the report; 3) Hilcorp shall perform a MIT of the inner annulus every two years to the greater of the maximum anticipated injection pressure or 0.25 x packer TVD, but not less than 1,500 psi; 4) Hilcorp shall limit the well’s inner annulus operating pressure to 2,100 psi and the outer annulus operating pressure to 1,000 psi. Audible control room alarms shall be set at or below these limits; 5) Hilcorp shall monitor the inner and outer annulus pressures in real time with its SCADA system; 6) Hilcorp shall maintain the Production Control Center (PCC) remote shut down capability for Z-103 when on gas or miscible injectant (MI) operation. During gas/MI injection, the IA protocols will include a drill site operator and PCC alarm set at 2,100 psi, and a high alarm set at a maximum of 3,000 psi that will prompt the PCC to remotely shut in the well; 7) Hilcorp shall immediately shut in the well and notify the AOGCC if there is any change in the well's mechanical condition; 8) After well shut in due to a change in the well's mechanical condition, AOGCC approval shall be required to restart injection; and 9) The next required MIT shall be completed before or during the month of January 2026. DONE at Anchorage, Alaska and dated February 6, 2024. Brett W. Huber, Sr. Jessie L. Chmielowski Chair, 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 reconsideration will be the FINAL order or decision of the AOGCC, and it may be appealed to superior court. That appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on reconsideration. In computing a period of time above, the date of the event or default after which the designated period begins to run is not included in the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00 p.m. on the next day that does not fall on a weekend or state holiday. Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2024.02.06 09:24:23 -09'00' Brett W. Huber, Sr. Digitally signed by Brett W. Huber, Sr. Date: 2024.02.06 10:21:09 -09'00' From:Carlisle, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Area Injection Order 24C.002 (Hilcorp) Date:Tuesday, February 6, 2024 10:41:41 AM Attachments:aio24C.002.pdf Docket Number: AIO-24-007 Request for Administrative Approval to Area Injection Order 24C: Water Alternating Gas Prudhoe Bay Unit (PBU) Z-103 (PTD 2042290), Borealis Oil Pool 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 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 ADMINISTRATIVE APPROVAL AREA INJECTION ORDER 24C.003 Mr. Torin Roschinger PBW Operations Manager Hilcorp North Slope, LLC 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 Re: Docket Number: AIO-24-008 Request for Administrative Approval to Area Injection Order 24C: Water Alternating Gas Prudhoe Bay Unit (PBU) Z-114 (PTD 2130650), Borealis Oil Pool Dear Mr. Roschinger: By emailed letter dated February 20, 2024, Hilcorp North Slope, LLC (Hilcorp) requested administrative approval to continue water alternating gas (WAG) injection with a known tubing by inner annulus (TxIA) pressure communication. In accordance with 20 AAC 25.556(d), the Alaska Oil and Gas Conservation Commission (AOGCC) hereby GRANTS, subject to conditions, Hilcorp’s request for administrative approval to continue WAG injection in the subject well. Hilcorp reported a potential TxIA pressure communication to AOGCC on January 24, 2024, when the well was on miscible gas injection. Hilcorp performed diagnostics and extended monitoring which confirmed the TxIA. Hilcorp has performed additional diagnostics including a passing state-witnessed mechanical integrity test (MIT) of the inner annulus (to a test pressure of 3,269 psi) on February 19, 2024. This indicates that Z-114 exhibits at least two competent barriers to the release of well pressure. Hilcorp maintains live transmitters on the inner and outer annulus and alarm functions in the Supervisory Control and Data Acquisition (SCADA) system that create layers of protection from an over-pressure event. These inner and outer annulus alarms combined with the planned inner and outer annulus operating pressure limits enable AOGCC to continue to authorize gas injection. AOGCC believes Hilcorp can safely manage the TxIA communication with periodic pressure bleeds by maintaining the IA to a pressure not to exceed 2,100 psi and OA to a pressure not to exceed 1,000 psi. Accordingly, the AOGCC believes that the well’s condition does not compromise overall well integrity so as to threaten human safety or the environment. AOGCC’s approval to continue WAG injection in PBU Z-114 is conditioned upon the following: 1) Hilcorp shall record wellhead pressures and injection rate daily; AIO 24C.003 February 26, 2024 Page 2 of 2 2) Hilcorp shall submit to the AOGCC a monthly report of well pressures, injection rates, and pressure bleeds for all annuli. Bleeds to be flagged on the report; 3) Hilcorp shall perform a MIT of the inner annulus every two years to the greater of the maximum anticipated injection pressure or 0.25 x packer TVD, but not less than 1,500 psi; 4) Hilcorp shall limit the well’s inner annulus operating pressure to 2,100 psi and the outer annulus operating pressure to 1,000 psi. Audible control room alarms shall be set at or below these limits; 5) Hilcorp shall monitor the inner and outer annulus pressures in real time with its SCADA system; 6) Hilcorp shall maintain the Production Control Center (PCC) remote shut down capability for Z-114 when on gas or miscible injectant (MI) operation. During gas/MI injection, the IA protocols will include a drill site operator and PCC alarm set at 2,100 psi, and a high alarm set at a maximum of 3,000 psi that will prompt the PCC to remotely shut in the well; 7) Hilcorp shall immediately shut in the well and notify the AOGCC if there is any change in the well's mechanical condition; 8) After well shut in due to a change in the well's mechanical condition, AOGCC approval shall be required to restart injection; and 9) The next required MIT shall be completed before or during the month of February 2026. DONE at Anchorage, Alaska and dated February 26, 2024. Brett W. Huber, Sr. Jessie L. Chmielowski Chair, Commissioner Commissioner GregRU\ C. Wilson 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 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. Brett W. Huber, Sr. Digitally signed by Brett W. Huber, Sr. Date: 2024.02.26 10:58:33 -09'00' Gregory Wilson Digitally signed by Gregory Wilson Date: 2024.02.26 15:41:02 -09'00' Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2024.02.26 15:51:15 -09'00' From:Coldiron, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Area Injection Order 24C.003 (Hilcorp) Date:Monday, February 26, 2024 4:03:55 PM Attachments:aio24C.003.pdf Docket Number: AIO-24-008 Request for Administrative Approval to Area Injection Order 24C: Water Alternating Gas Prudhoe Bay Unit (PBU) Z-114 (PTD 2130650), Borealis Oil Pool Samantha Coldiron 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 5 Hilcorp North Slope, LLC Torin Roschinger, PBW Operations Manager 3800 Centerpoint Dr, Suite 1400 Anchorage, Alaska 99503 02/20/2024 Chairman Brett Huber, Sr Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, Alaska 99501 Subject: Borealis Well Z-114 (PTD #213065). Request for Administrative Approval to allow WAG injection operations. Dear Chairman Huber, Hilcorp North Slope, LLC requests administrative approval to allow for WAG injection into Borealis well Z-114 with slow tubing x inner annulus (IA) communication. WAG injection well Z-114 was found to have slow IA re-pressurization on 01/24/2024 while on Miscible Gas Injection (MI). The well was immediately reported to the AOGCC and placed under evaluation for diagnostics and monitoring. The tubing hanger passed a pressure test to 5000 psi on 01/25/2024 and the three dummy gas lift valves (DGLVs) were replaced on 02/06/2024 in an effort to mitigate the slow TxIA communication. Additional monitoring after the DGLV replacement showed the IA continued to slowly repressurize. An AOGCC witness MIT- IA was conducted on 02/19/2024 and passed to 3,269 psi confirming the integrity of the primary and secondary well barriers. The maximum anticipated injection pressure for Z-114 would be the maximum MI header pressure for Z-pad which is approximately 3,000 psi. Hilcorp North Slope, LLC has determined that well Z-114 is safe to operate in its current condition and requests administrative approval based on the following conditions: x IA pressure can be maintained below MOASP by managing the IA repressurization with periodic annular bleeds. x Passing pressure test of the primary and secondary barriers. x IA and OA pressures will be monitored with wireless pressure gauges. If you have any questions, please call me at 406-570-9630 or Oliver Sternicki at 907-564-4891. Sincerely, Torin Roschinger PBW Operations Manager Attachments Technical Justification TIO/ Injection Plot Wellbore Schematic By Samantha Coldiron at 10:13 am, Feb 20, 2024 Digitally signed by Torin Roschinger (4662) DN: cn=Torin Roschinger (4662), ou=Users Date: 2024.02.20 09:45:11 -09'00' Torin Roschinger (4662) Borealis Well Z-114 Technical Justification for Administrative Approval Request 02/20/2024 Well History and Status Well Z-114 is a WAG injector that was originally drilled in 2013 and has operated without issue until recently. On 01/24/2024 the well was placed under evaluation for anomalous IA repressurization. Initial diagnostic testing was completed on 01/25/2024 with a passing pressure test of the tubing hanger seals to 5000 psi. The DGLVs were replaced on 02/06/2024 with extended packing stacks in the event that the GLMs were the cause of repressurization. Post DGLV replacement monitoring continued to show slow IA repressurization. The well passed an online AOGCC witnessed MIT-IA to 3,269 psi on 02/19/2024. Recent Well Events: 10/03/2021 AOGCC MIT-IA passed to 2910 psi 01/24/2024 AOGCC notified, Under Evaluation for suspected IA repressurization. 01/25/2024 PPPOT-T passed to 5000 psi 02/06/2024 Slickline set extended packing DGLVs. 02/19/2024 Online AOGCC witnessed MIT-IA passed to 3269 psi Barrier and Hazard Evaluation The primary and secondary barriers systems consist of the tubing and production casing and associated hardware. A passing online pressure test conducted on 02/19/2024, to 3,269 psi, which tested both barriers, demonstrates competent primary and secondary barrier systems. Due to the low IA repressurization rate, no logging or further repair attempt is planned at this time due to the low likelihood of locating the leak point. Proposed Operating and Monitoring Plan 1. Record wellhead pressures and injection rates daily; 2. Submit to the AOGCC a monthly report of well pressures, injection rates, and pressure bleeds for all annuli. Bleeds to be flagged on the report; 3. Perform a MITIA every two years to the greater of the maximum anticipated wellhead injection pressure or 0.25 x packer TVD, but not less than 1,500 psi; 4. Limit the well’s inner annulus operating pressure to 2,100 psi. Audible control room alarms shall be set at or below these limits; 5. Limit the well’s outer annulus operating pressure to 1,000 psi. Audible control room alarms shall be set at or below these limits; 6. Monitor the inner and outer annulus pressures in real time with SCADA system; 7. Maintain the PCC remote shut down capability for Z-114 when on gas or miscible injectant (MI) operation. 8. Immediately shut in the well and notify the AOGCC if there is any change in the well's mechanical condition; 9. After well shut in due to a change in the well's mechanical condition, AOGCC approval shall be required to restart injection; TIO/ Injection Plot Wellbore Schematic 4 Hilcorp North Slope, LLC Torin Roschinger, PBW Operations Manager 3800 Centerpoint Dr, Suite 1400 Anchorage, Alaska 99503 01/23/2024 Chairman Brett Huber, Sr Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, Alaska 99501 Subject: Borealis Well Z-103 (PTD #204229). Request for Administrative Approval to allow WAG injection operations. Dear Chairman Huber, Hilcorp North Slope, LLC requests administrative approval to allow for WAG injection into Borealis well Z-103 with slow tubing x inner annulus (IA) communication. WAG injection well Z-103 was found to have slow IA re-pressurization on 01/17/2024 while on Miscible Gas Injection (MI). The well was immediately reported to the AOGCC and placed under evaluation for diagnostics and monitoring. An AOGCC witness MIT-IA was conducted on 01/22/2024 and passed to 3,160 psi, confirming the integrity of the primary and secondary well barriers. The maximum anticipated injection pressure for Z-103 would be the maximum MI header pressure for Z-pad which is approximately 3,000 psi. Hilcorp North Slope, LLC has determined that well Z-103 is safe to operate in its current condition and requests administrative approval based on the following conditions: x IA pressure can be maintained below MOASP by managing the IA repressurization with periodic annular bleeds. x Passing pressure test of the primary and secondary barriers. x IA and OA pressures will be monitored with wireless pressure gauges. If you have any questions, please call me at 406-570-9630 or Oliver Sternicki at 907-564-4891. Sincerely, Torin Roschinger PBW Operations Manager Attachments Technical Justification TIO/ Injection Plot Wellbore Schematic Digitally signed by Torin Roschinger (4662) DN: cn=Torin Roschinger (4662), ou=Users Date: 2024.01.24 06:28:46 -09'00' Torin Roschinger (4662) Borealis Well Z-103 Technical Justification for Administrative Approval Request 01/23/2024 Well History and Status Well Z-103 is a WAG injector that was originally drilled in early 2005. The well had an under evaluation period in 2020 when suspected IA repressurization was being investigated. After diagnostics and a monitoring period no IA repressurization was seen and the well was returned to operable status on 11/30/2020. The well most recently went under evaluation on 01/17/2024 for IA repressurization and passed all diagnostics including an AOGCC witnessed MIT-IA to 3,160 psi with the well online on 01/22/2024. Recent Well Events: 07/03/2020 AOGCC MIT-IA passed to 2146 psi 11/03/2020 AOGCC notified, Under Evaluation for suspected IA repressurization. 11/03/2020 PPPOT-T passed to 5000 psi 11/30/2020 No IA repressurization seen post bleed and monitoring period. Well returned to Operable status. 01/17/2024 AOGCC notified, Under Evaluation for suspected IA repressurization. 01/19/2024 PPPOT-T passed to 5000 psi 01/22/2024 Online AOGCC witnessed MIT-IA passed to 3160 psi Barrier and Hazard Evaluation The primary and secondary barriers systems consist of the tubing and production casing and associated hardware. A passing online pressure test conducted on 01/22/2024, to 3,160 psi, which tested both barriers, demonstrates competent primary and secondary barrier systems. Due to the low IA repressurization rate, no logging or repair attempt is planned at this time due to the low likelihood of locating the leak point. Proposed Operating and Monitoring Plan 1. Record wellhead pressures and injection rates daily; 2. Submit to the AOGCC a monthly report of well pressures, injection rates, and pressure bleeds for all annuli. Bleeds to be flagged on the report; 3. Perform a MITIA every two years to the greater of the maximum anticipated wellhead injection pressure or 0.25 x packer TVD, but not less than 1,500 psi; 4. Limit the well’s inner annulus operating pressure to 2,100 psi. Audible control room alarms shall be set at or below these limits; 5. Limit the well’s outer annulus operating pressure to 1,000 psi. Audible control room alarms shall be set at or below these limits; 6. Monitor the inner and outer annulus pressures in real time with SCADA system; 7. Maintain the PCC remote shut down capability for Z-103 when on gas or miscible injectant (MI) operation. 8. Immediately shut in the well and notify the AOGCC if there is any change in the well's mechanical condition; 9. After well shut in due to a change in the well's mechanical condition, AOGCC approval shall be required to restart injection; TIO/ Injection Plot Wellbore Schematic 3 Hilcorp North Slope, LLC Stan Golis, PBW Operations Manager 3800 Centerpoint Dr, Suite 1400 Anchorage, Alaska 99503 11/22/2022 Commissioner Jessie Chmielowski and Commissioner Greg Wilson Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, Alaska 99501 Subject: Borealis well Z-25 (PTD# 188159). Request for continue WAG injection operations. Dear Commissioner Chmielowski and Commissioner Wilson, Hilcorp North Slope, LLC requests administrative approval for continued WAG injection into Borealis well Z-25 with slow tubing by inner annulus (IA) communication. WAG well Z-25 was reported to the AOGCC on 11/18/2022 for suspected slow tubing by IA pressure communication based on IA pressure trends while on MI service. The AOGCC was notified on 11/18/2022 and the well was placed under evaluation. A tubing hanger pack-off test (PPPOT-T) passed to 5000 psi on 8/13/2022. An online AOGCC witnessed MIT-IA passed to 3534 psi on 11/22/2022. The passing test confirms both the primary and secondary well barrier integrity. Hilcorp North Slope, LLC has determined that well Z-25 is safe to operate in its current condition and requests permission for continued WAG injection based on the following: x IA pressure can be maintained below MOASP by managing the IA repressurization with periodic annular bleeds. x Passing pressure test of the primary and secondary barriers. x IA and OA pressures will be monitored with wireless pressure gauges. If you have any questions, please call me at 907-777-8356 or Oliver Sternicki at 907-564-4891. Sincerely, Stan Golis PBW Operations Manager Attachments Technical Justification TIO/ Injection Plot Wellbore Schematic Digitally signed by Stan Golis (880) DN: cn=Stan Golis (880), ou=Users Date: 2022.11.22 16:42:22 -09'00' Stan Golis (880) Borealis Well Z-25 Technical Justification for Administrative Approval Request 11/22/2022 Well History and Status Borealis well Z-25 (PTD# 188159) is a WAG injector originally drilled and completed in March of 1989 as a development well and converted to a service well in October 2003. Beginning 02/26/2008, Z-25 operated under AIO 3.021 for slow TxIA communication while on MI and was limited to water injection only. On 11/16/2009 AIO 3.021 was canceled after a RWO replaced the tubing. Z-25 had previously been under evaluation for possible TxIA communication in August/ September 2022 due to anomalous IA pressure trends on MI and an IA bleed containing energized fluid on 8/9/2022. A tubing hanger pack-off test (PPPOT-T) passed to 5000 psi on 8/13/2022. During the extended evaluation period from 8/10-9/30/2022 the IA repressurization was not noted and no IA bleeds were conducted and the well was made operable. Z-25 was again noted as having increasing IA pressure trends on 11/18/2022 that cannot be correlated to injection rate or temperature increases and the well was reported to the AOGCC and place under evaluation. An online AOGCC witnessed MIT-IA passed to 3534 psi on 11/22/2022. Recent Well Events: 11/22/2022 Online AOGCC witnessed MIT-IA passed to 3534 psi. 11/18/2022 Notification sent to the AOGCC, well placed under evaluation. 09/30/2022 Well made operable after extended under evaluation period. 08/13/2022 PPPOT-T passed to 5000 psi. 08/10/2022 Notification sent to the AOGCC, well placed under evaluation. 08/09/2022 IA bleed with energized fluid, possible TxIA pressure communication noted. 12/08/2019 Passed online AOGCC witnessed MIT-IA to 3535 psi. Barrier and Hazard Evaluation The primary and secondary barriers systems consist of the tubing and production casing and associated hardware. A passing online pressure test conducted on 11/22/2022, which tested both barriers, demonstrates competent primary and secondary barrier systems. Due to the low IA repressurization rate no logging or repair attempt is planned at this time due to the low likelihood of locating the leak point. Proposed Operating and Monitoring Plan 1. Record wellhead pressures and injection rates daily; 2. Submit to the AOGCC a monthly report of well pressures, injection rates, and pressure bleeds for all annuli. Bleeds to be flagged on the report; 3. Perform a MITIA every two years to the greater of the maximum anticipated wellhead injection pressure or 0.25 x packer TVD, but not less than 1,500 psi; 4. Limit the well’s inner annulus operating pressure to 2,100 psi. Audible control room alarms shall be set at or below these limits; 5. Limit the well’s outer annulus operating pressure to 1,500 psi. Audible control room alarms shall be set at or below these limits; 6. Monitor the inner and outer annulus pressures in real time with its SCADA system; 7. Maintain the Production Control Center (PCC) remote shut down capability for Z-25 when on gas or miscible injectant (MI) operation; 8. Immediately shut in the well and notify the AOGCC if there is any change in the well's mechanical condition; 9. After well shut in due to a change in the well's mechanical condition, AOGCC approval shall be required to restart injection; TIO/ Injection Plot Wellbore Schematic z Notice of Public Hearing STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION Re: Docket Numbers: AIO 18-033, AIO 18-034, and AIO 18-035 Prudhoe Bay Unit, Aurora, Borealis, and Prudhoe Oil Pools The application of BP Exploration (Alaska) Inc (BPXA) for amendments to existing area injection orders in accordance with 20 AAC 25.215 authorizing the downhole commingling of injection between the Aurora and Prudhoe Oil Pools and the Borealis and Prudhoe Oil Pools. BPXA, by letter dated July 24, 2018, requests the Alaska Oil and Gas Conservation Commission (AOGCC) amend area injection orders no. 313, 22E, and 24B in accordance with 20 AAC 25.215 to authorize the downhole commingling of injection between the Aurora and Prudhoe Oil Pools and the Borealis and Prudhoe Oil Pools for all injection wells in those pools. The AOGCC has tentatively scheduled a public hearing on this application for December 19, 2018, at 10:00 a.m. at 333 West 7h Avenue, Anchorage, Alaska 99501. To request that the tentatively scheduled hearing be held, a written request must be filed with the AOGCC no later than 4:30 p.m. on December 2, 2018. If a request for a hearing is not timely filed, the AOGCC may consider the issuance of an order without a hearing. To learn if the AOGCC will hold the hearing, call (907) 793-1221 after December 4, 2018. In addition, written comments regarding this application may be submitted to the AOGCC, at 333 West 7' Avenue, Anchorage, Alaska 99501. Comments must be received no later than 4:30 p.m. on December 18, 2018, except that, if a hearing is held, comments must be received no later than the conclusion of the December 19, 2018 hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, contact the AOGCC's Special Assistant, Jody Colombie, at (907) 793-1221, no later than December 17, 2018. Hollis S. French Chair, Commissioner Notice of Public Hearing STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION Re: Docket Numbers: AIO 18-033, AIO 18-034, and AIO 18-035 Prudhoe Bay Unit, Aurora, Borealis, and Prudhoe Oil Pools The application of BP Exploration (Alaska) Inc (BPXA) for amendments to existing area injection orders in accordance with 20 AAC 25.215 authorizing the downhole commingling of injection between the Aurora and Prudhoe Oil Pools and the Borealis and Prudhoe Oil Pools. BPXA, by letter dated July 24, 2018, requests the Alaska Oil and Gas Conservation Commission (AOGCC) amend area injection orders no. 3B, 22E, and 24B in accordance with 20 AAC 25.215 to authorize the downhole commingling of injection between the Aurora and Prudhoe Oil Pools and the Borealis and Prudhoe Oil Pools for all injection wells in those pools. The AOGCC has tentatively scheduled a public hearing on this application for December 19, 2018, at 10:00 a.m. at 333 West 7a' Avenue, Anchorage, Alaska 99501. To request that the tentatively scheduled hearing be held, a written request must be filed with the AOGCC no later than 4:30 p.m. on December 2, 2018. If a request for a hearing is not timely filed, the AOGCC may consider the issuance of an order without a hearing. To learn if the AOGCC will hold the hearing, call (907) 793-1221 after December 4, 2018. In addition, written comments regarding this application may be submitted to the AOGCC, at 333 West 7s' Avenue, Anchorage, Alaska 99501. Comments must be received no later than 4:30 p.m. on December 18, 2018, except that, if a hearing is held, comments must be received no later than the conclusion of the December 19, 2018 hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, contact the AOGCC's Special Assistant, Jody Colombie, at (907) 793-1221, no later than December 17, 2018. //signature on file// Hollis S. French Chair, Commissioner STATE OF ALASKA ADVERTISING ORDER NOTICE TO PUBLISHER SUBMIT INVOICE SHOWING ADVERTISING ORDER NO, CERTIFTED AFFIDAVIT OF PUBLICATION WITH ATTACHED COPY OFADVERTISMENT. ADVERTISING ORDER NUMBER A AO-19-014 FROM: AGENCY CONTACT: Jody Colombie/Samantha Carlisle Alaska Oil and Gas Conservation Commission DATE OF A.O. AGENCY PHONE: 333 West 7th Avenue 11/162018 (907) 279-1433 Anchorage, Alaska 99501 DATES ADVERTISEMENT REQUIRED: COMPANY CONTACT NAME: PHONE NUMBER: ASAP FAX NUMBER: (907)276-7542 TO PUBLISHER: SPECIAL INSTRUCTIONS: Anchorage Daily News, LLC PO Box 140147 Anchorage, Alaska 99514-0174 TYPE OF ADVERTISEMENT: W LEGAL j DISPLAY :V CLASSIFIED r OTHER (Specify below) DESCRIPTION PRICE AIO 19-033, 034 and AIO 18-035 Initials of who prepared AO: Alaska Non -Taxable 92-600185 $U$p}IT INVQIGG 3ligwlfl66P�:CRiiSIN: ::.;gRDEB N(i,;lsR,'i'IFl$D A,PP,iuAS?40F.:;: :htl8ti(CAi1Qw:W11HA.T,.fACHEIsrP:�bF: ADvEN'ftsM£NPT[r:: AOGCC 333 West 7th Avenue Anchorage, Alaska 99501 Pae 1 of 1 Total of All Pa es $ REF Type Number Amount Date Comments I PvN VCO21795 2 AO AO-19-014 3 4 FIN AMOUNT SY Act. Template PCM LCR Object FY DIST LIQ I 19 A14100 3046 19 2 3 4 Purch A A ri a tl : Purchasing Authority's signature Telephone Number 1. ivi enoy name must aapp on all invoices and documents mlating to this purchase. Th state is registered for tax free human tItle under Chapter 32, IRS code. Registration number 92-73-0006 K. Items are for the exclusive use of the state and not tar sal Divls{on Frsepl/Qngmal.AO .,:;G6pleS. Puhliither (faxed);:DIVIBIbn Thar IAecelving:; Form: 02-901 Revised: 11/16/2018 Bernie Karl K&K Recycling Inc. Gordon Severson Penny Vadla P.O. Box 58055 3201 Westmar Cir. 399 W. Riverview Ave. Fairbanks, AK 99711 Anchorage, AK 99508-4336 Soldotna, AK 99669-7714 George Vaught, Jr. Darwin Waldsmith Richard Wagner P.O. Box 13557 P.O. Box 39309 P.O. Box 60868 Denver, CO 80201-3557 Ninilchik, AK 99639 Fairbanks, AK 99706 1 BP Exploration (Alaska), Inc. 900 East Benson Boulevard Post Office Box 196612 Anchorage, Alaska 99519-6612 Telephone (907) 564 581 ME# r July 24, 2018 Mr. Hollis French, Chair Alaska Oil and Gas Conservation Commission 333 West 7`s Avenue, Suite 100 Anchorage, AK 99501 JUL 8 0 2018 RE: Application for Amendment to Area Injection Orders 22E, 24B and 3B to authorize Downhole commingling of Injection between Two Pools Dear Chair French, In its capacity as Operator of the Aurora Oil Pool (AOP), Borealis Oil Pool (BOP) and the Prudhoe Oil Pool (POP), BP Exploration (Alaska) Inc. (`BP") hereby requests approval to commingle WAG injection between the AOP and POP, and between the BOP and POP, in the same wellbore of each injection well within these pools. BP respectfully submits that the requested commingling of injection will not cause waste or result in an increased risk of fluid movement into an underground source of drinking water, but rather will allow for recovery of a greater quantity of oil, and that such injection can be properly allocated. BP therefore requests administrative approval to amend Area Injection Orders 22E, 24B and 3B to authorize the referenced commingling of WAG injection within the same well -bore. Subject to commission approval, BP plans to commence commingling of WAG injection between the BOP and POP in Well Z-25 and between the AOP and POP in Well S -22B by the third quarter of 2018. Enclosed with this letter is additional information supporting this application, including BP's proposed allocation methodology and proposed amendments to the Injection Orders. ORIGINAL Application for Administrative Approval Amendment of AIO's 22E, 24B and 3B July 24, 2018 If the commission has questions or desires more information please contact Bill Bredar at 564-5348, william.bredar@bp.com. Sincerely, &'V '�C)v>-ej Diane Richmond Alaska Reservoir Development, BPXA Enclosure: Additional Information in Support of Application cc: Mr. Eric Reinbold, ConocoPhillips Alaska, Inc. Mr. Hank Jamieson, ExxonMobil Alaska, Production Inc. Mr. Jeffery Farr, ExxonMobil Alaska, Production Inc. Mr. Dave White, Chevron USA 2/14 Application for Administrative Approval Amendment of AIO's 22E, 24B and 3B July 24, 2018 Additional Information in Support of Application Introduction Area Injection Orders ("AIO") 313, 22E and 24B currently authorize commingling of WAG injection between AOP and POP, and BOP and POP, only for the specific wells identified in each AIO. However, each of the AIOs authorizes the commission to administratively amend the order as long as: the change does not promote waste or jeopardize correlative rights, is based on sound engineering and geoscience principles, and will not result in an increased risk of fluid movement into freshwater. BP respectfully submits that the information provided with this application satisfies the above requirements; and is requesting that the commission administratively approve BP's application and authorize commingling of WAG injection between the AOP and POP, and the BOP and POP, for each injection well within those pools. AOGCC would continue to retain the ability to approve individual wells via the 10-403 Application for Sundry Approval process. Supplemental information to support that waste will not occur and outline of surveillance and allocation measures are included in Appendices 1 (Aurora and Prudhoe Oil Pool commingling in WAG Injector S-2213) and 2 (Borealis and Prudhoe Oil Pool commingling in WAG injector Z-25). Proposed Alternative Allocation Methodology An alternative allocation methodology is also proposed to enable allocation of injection between zones using injection data based injectivity profiles. By obtaining injection pressure and rate data from at least one zone separately, differential injection rates between the pools 3/14 Application for Administrative Approval Amendment of AIO's 22E, 24B and 3B July 24, 2018 can be determined with knowledge of the injection pressure. Where injection rates are such that friction impacts the injectivity, the same methodology can be used with calculated bottom hole pressure. An example of this methodology is shown for S-31 A which had commingled WAG injection in 2010 between the Prudhoe (Sag) and Aurora Oil Pools. 4000 3800 5-31A Aurora -Prudhoe oil Pool Commingled MI Injection Splits per differential injectivity methodology (shown): 82% Aurora, 18% Prudhoe Splits per 3/6/101PROF with MI Inj @ 2975psi WHIP: 83% Aurora, 17% Prudhoe 2200 P10111 y = 0.2082x + 2638 4114 _ 'kbt E L- • • M —6i y = 0.1652x+ 2649 O Commingled MI Injection Mar -Jun 2010 L Aurora Only MI Injection Oct 2009 -- linear (Commingled MI Injection Mar -Jun 20l i, — Linear (Aurora Only MI Injection Oct 20071 0 500 1000 1500 2000 2500 3000 3500 4000 450 ..... MI Injection Rate (mscf/d) This proposed methodology allows for regular monitoring and allocation of splits between pools based on data obtained daily. Significant deviation in commingled injection slope trend over time are notable. It is also proposed that when major changes in commingled injectivity occur that are not explained by metering calibration checks or planned mechanical modification, an injection survey or an updated separate pool multi -rate injectivity test be obtained for purposes of injection allocation between pools. This would eliminate the annual necessity for entering the well to obtain a survey or isolate a zone for separate injection test unless triggered by a significant injectivity change. 4/14 3600 a 3400 N m 3200 c O 3000 V d 2900 M � i 2�tto o a 3 2400 O 2200 P10111 y = 0.2082x + 2638 4114 _ 'kbt E L- • • M —6i y = 0.1652x+ 2649 O Commingled MI Injection Mar -Jun 2010 L Aurora Only MI Injection Oct 2009 -- linear (Commingled MI Injection Mar -Jun 20l i, — Linear (Aurora Only MI Injection Oct 20071 0 500 1000 1500 2000 2500 3000 3500 4000 450 ..... MI Injection Rate (mscf/d) This proposed methodology allows for regular monitoring and allocation of splits between pools based on data obtained daily. Significant deviation in commingled injection slope trend over time are notable. It is also proposed that when major changes in commingled injectivity occur that are not explained by metering calibration checks or planned mechanical modification, an injection survey or an updated separate pool multi -rate injectivity test be obtained for purposes of injection allocation between pools. This would eliminate the annual necessity for entering the well to obtain a survey or isolate a zone for separate injection test unless triggered by a significant injectivity change. 4/14 Application for Administrative Approval Amendment of AIO's 22E, 24B and 313 July 24, 2018 Conclusion BP requests approval for well -bore commingling of WAG injection for AOP and POP commencing with Well S -22B and WAG injection for BOP and POP commencing with well Z-25. During the first 60 days of commingled injection an injection survey or separate pool multi -rate injectivity test will be obtained for purposes of allocation of injection by pool. An injection survey or separate pool multi -rate injectivity test will again be obtained within 60 days of the well injecting its other WAG phase. It is requested that differential injectivity profiles be approved as an allocation methodology for injection between pools. The proposed AIO amendments include the specific wells referenced in the Appendices. However, if the commission would consider poolwide commingling between the Aurora and Prudhoe Oil Pools and between the Borealis and Prudhoe Oil Pools, future opportunities could more efficiently be progressed though still require individual well approval through a 10-403 for perforating of a new pool and prior to commencing of commingled injection. Proposed Amendments to Area Injection Orders Note: Use of[ ]'s denotes the deletion of existing order text. Use of underline denotes proposed new text. Amendment to Prudhoe Bay Unit Western Operating Area AIO 3B Rule 9: Rule 9. Wells Authorized for Downhole Commingled Injection [with the Aurora Oil Pool] Injection into the AOP and POP within the same wellbore is authorized for each well[s PBU S-09 and S -31A] into the BOP and POP within the same wellbore, subject to the following conditions. 5/14 Application for Administrative Approval Amendment of AIO's 22E, 24B and 3B July 24, 2018 (a) An approved Application for Sundry Approval (Form 10-403) is required for each well prior to commencement of commingled injection. (b) Within 60 days of commencement of commingled injection in a well, or upon initial switching from one injection fluid to the other, BPXA must conduct an injection survey or separate pool multi -rate infectivity test to determine the proper allocation of injected fluids. [Additional injection surveys shall be conducted on each well at least once per year t] Thereafter as long as the well continues commingled injection, allocation will be based on use of differential iniectivity profiles or injection survey unless significant changes in total iniectivity occur whereby an injection survey or separate pool iniectivity test will be performed. (c) Annual and total cumulative volumes injected by pool and results of logs, [or ]surveys, or separate pool multi -rate iniectivity tests used for determining the allocation of injected fluids between pools must be supplied in the Annual Surveillance Report for the AOP and BOP. Amendment to Aurora Oil Pool AID 22E Rule 9: Rule 11. Wells Authorized for Downhole Commingled Injection with the Prudhoe Oil Pool Injection into the AOP and POP within the same wellbore is authorized for each well[s PBU S-09 and S-31 A], subject to the following conditions. a. An approved Application for Sundry Approval (Form 10 -403) is required for each well prior to commencement of commingled injection. b. Within 60 days of commencement of commingled injection in a well, or upon initial switching from one injection fluid to the other, BPXA must conduct an injection survey or separate pool multi -rate injectivity test to determine the proper allocation of injected fluids. [Additional injection surveys shall be conducted on each well at least 6/14 Application for Administrative Approval Amendment of AIO's 22E, 24B and 36 July 24, 2018 once per year t] Thereafter as long as the well continues commingled injection, allocation will be based on use of differential injectivity profiles or injection survey unless significant changes in total injectivity occur whereby an injection survey or separate pool injectivity test will be performed c. Annual and total cumulative volumes injected by pool and results of logs, [or ]surveys, or separate pool multi -rate injectivity tests used for determining the allocation of injected fluids between pools must be supplied in the Annual Surveillance Report for the AOP. Amendment to Borealis Oil Pool AIO 24B: Rule X. Wells Authorized for Downhole Commingled Injection with the Prudhoe Oil Pool Iniection into the BOP and POP within the same wellbore is authorized for each well subiect to the following conditions. a. An approved Application for Sundry Approval (Form 10 403) is required for each well prior to commencement of commingled injection b. Within 60 days of commencement of commingled injection in a well or upon initial switching from one iniection fluid to the other, BPXA must conduct an injection survey or separate pool multi -rate injectivity test to determine the proper allocation of infected fluids. Thereafter as long as the well continues commingled injection allocation will be based on use of differential injectivity profiles or injection survey unless significant changes in total injectivity occur whereby an injection survey or separateop of injectivity test will be performed c. Annual and total cumulative volumes injected by pool and results of logs surveys or separate pool multi -rate iniectivity tests used for determining the allocation of injected fluids between pools must be supplied in the Annual Surveillance Report for the BOP. 7/14 Application for Administrative Approval Amendment of AIO's 22E, 24B and 3B July 24, 2018 8/14 Application for Administrative Approval Amendment of AIO's 22E, 24B and 38 July 24, 2018 Appendix 1: Borealis and Prudhoe Oil Pool commingling in WAG Injectors Waste Will Not Occur 1. Injection Considerations Well Z-25 penetrates BOP in an ideal location for WAG injection due to its proximity to offset producers Z-100 and Z-113. Reservoir modeling indicates significant improvement in areal sweep to the offset producers as a result of placing an injection point at Z -25's Kuparuk penetration. While the size of the target does not justify a new well, the incremental benefits to the field are such that a workover for commingled injection in this well and potentially other wells is an attractive prospect. 2. Impacts on Current Well Utility Well Z-25 was drilled in 1989 and functioned as a Prudhoe Oil Pool producer from 1989 until 2003, at which time it was converted to an injector. Injection commenced in early 2005, and the well has been an active WAG injector ever since. One workover has taken place —the tubing was swapped out in 2009 due to a failed packer. Four slugs of MI have been injected to -date. When on water, the well injects approximately 7000 bwpd into POP. The forecasted injection rate into BOP is 1000-2000 bwpd, which will not adversely impact the ability to inject into POP. Injectivity into POP is anticipated to be higher than BOP, so an inline orifice choke is planned to be set below the BOP interval to allow for the desired injection splits between pools. This choke will be sized using best engineering practices, and the resulting injection splits will be confirmed via an injection profile log or separate pool multi rate Injectivity test. Due to the planned workover preserving the 4-1/2" tubing design, the POP and BOP can each be isolated in the future via a plug or a patch, respectively. This maximizes future utility and ensures the future injection needs in each pool from this well can be met. During periods of prolonged well downtime, a mechanical plug can be set 9/14 Application for Administrative Approval Amendment of AIO's 22E, 24B and 3B between zones to prevent crossflow. July 24, 2018 Appropriate Surveillance and Injection Allocation Will Be Assured Appropriate surveillance and injection allocation measures will be undertaken to meet reservoir management objectives and to provide an acceptable allocation methodology. 1. Injection Allocation Stand-alone injectivity data in the BOP will be obtained prior to commingling injection. This will allow for an initial pressure vs. rate relationship to be established for the BOP, to assist in allocating zonal splits once both pools are open to injection. Once commingled, injection into the POP will be regulated via a downhole choke and zonal splits will be confirmed via an injection profile or separate pool multi -rate injectivity test within the first 60 days. An injection profile or separate pool multi -rate injectivity test will also be obtained within 60 days of the well's first change of injection service to inform zonal splits of the other WAG phase. 2. Reservoir Surveillance Long-term development plans for BOP and POP pools include water -flood and Enhanced Oil Recovery using "Miscible Injectant" (or "MI") from the Prudhoe Bay Miscible Gas Project. Reservoir pressure and communication with offset producers will be determined by monitoring injection trends and WAG interactions in both pools. To aid in long-term reservoir management, static pressures from each pool can be measured with the use of down -hole plugs and pressure gauges. If it is determined that a completion in one pool is adversely affecting injection to the other pool, that completion can be isolated as necessary to ensure waste does not occur. 3. Zonal Isolation To confirm injected fluids are contained in the intended zone in the BOP, a cement log of the 10/14 Application for Administrative Approval Amendment of AIO's 22E, 24B and 3B July 24, 2018 casing is planned during the workover. If the log indicates cement quality that does not meet established minimums for zonal isolation, a remedial squeeze will be executed, and the log will be repeated prior to running the completion. Conclusion BP requests approval for well -bore commingling of WAG injection for BOP and POP, commencing with Well Z-25. During the first 60 days of commingled injection an injection survey log or separate pool multi rate injectivity test for purposes of allocation of injection by pool will be obtained. Thereafter, it is proposed that injection surveys or separate pool multi - rate injectivity test be taken on an as needed basis. 11/14 Application for Administrative Approval Amendment of AIO's 22E, 24B and 3B July 24, 2018 Appendix 2: Aurora and Prudhoe Oil Pool commingling in WAG Injectors Waste Will Not Occur 1. Injection Considerations Well S -22B penetrates AOP in an ideal location for WAG injection due to its proximity to offset producers S -42A and S-118. The Kuparuk penetration of S -22B is in an ideal location to provide WAG support to the toe of S -42A. A prior attempt to provide injection support to S -42A involved the unsuccessful coil tubing sidetrack of 5-112 in April 2016. Unfortunately, it was not possible to complete the S -I 12 sidetrack as planned due to unanticipated faults. Commingled injection into S -22B is a fallback alternative to the unsuccessful S-112 sidetrack. There is a large upside case if the S -22B Kuparuk injection re -complete provides injection support to S-118 to the south. S-118 is currently a non-operable producer with collapsed tubing and TxIA communication. A RWO to restore TxIA communication in 5-118 is also being worked. There are also potential incremental benefits to the field to a workover for commingled injection in other wells within these pools. 2. Impacts on Current Well Utility S -22B was sidetracked to its current location in 07/97 and initially brought on line as a pre - produced injector in 1998. S -22B failed an MIT prior to the well conversion from a producer to injector. A RWO to replace corroded tubing was performed in June 2001 and the well was subsequently converted to injection. There is remaining value in the POP injection location, so commingled injection in both zones is desirable. Five slugs of MI have been injected to - date. When on water, the well injects approximately 3500 bwpd into POP. The forecasted injection rate into AOP is 1250 bwpd, which will not adversely impact the ability to inject into POP. 12/14 Application for Administrative Approval Amendment of AIO's 22E, 24B and 313 July 24, 2018 Injectivity into POP is anticipated to be higher than AOP, so an inline orifice choke is planned to be set below the AOP interval to allow for the desired injection splits between pools. This choke will be sized using best engineering practices, and the resulting injection splits will be confirmed via an injection profile log or a separate pool multi -rate injectivity test. Due to the planned workover preserving the 4-1/2" tubing design, the POP and AOP can each be isolated in the future via a plug or a patch, respectively. This maximizes future utility and ensures the future injection needs in each pool from this well can be met. During periods of prolonged well downtime, a mechanical plug can be set between zones to prevent crossflow. Appropriate Surveillance and Injection Allocation Will Be Assured Appropriate surveillance and injection allocation measures will be undertaken to meet reservoir management objectives and to provide an acceptable allocation methodology. 1. Injection Allocation Stand-alone injectivity data in the AOP will be obtained prior to commingling injection. This will allow for an initial pressure vs. rate relationship to be established for the AOP, to assist in allocating zonal splits once both pools are open to injection. Once commingled, injection into the POP will be regulated via a downhole choke and zonal splits will be confirmed via an injection profile or separate pool multi -rate injectivity test within the first 60 days. An injection profile or separate pool multi -rate injectivity test will also be obtained within 60 days of the well's first change of injection service to inform zonal splits of the other WAG phase. 2. Reservoir Surveillance Long-term development plans for AOP and POP pools include water -flood and Enhanced Oil 13/14 Application for Administrative Approval Amendment of AIO's 22E, 24B and 3B July 24, 2018 Recovery using "Miscible Injectant" (or "MI") from the Prudhoe Bay Miscible Gas Project. Reservoir pressure and communication with offset producers will be determined by monitoring injection trends and WAG interactions in both pools. To aid in long-term reservoir management, static pressures from each pool can be measured on an as -needed basis with the use of down -hole plugs and pressure gauges. If it is determined that a completion in one pool is adversely affecting injection to the other pool, that completion can be isolated as necessary to ensure waste does not occur. 3. Zonal Isolation To confirm injected fluids are contained in the intended zone in the AOP, a cement log of the casing is planned during the workover. If the log indicates cement quality that does not meet established minimums for zonal isolation, a remedial squeeze will be executed and the log will be repeated prior to running the completion. Conclusion BP requests approval for well -bore commingling of WAG injection for AOP and POP, commencing with Well S -22B. During the first 60 days of commingled injection an injection survey or separate pool multi -rate injectivity test for purposes of allocation of injection by pool will be taken. An injection survey or separate pool multi -rate injectivity test will again be obtained within 60 days of the well injecting its other WAG phase. Thereafter, it is proposed that injection surveys or separate pool multi -rate injectivity test be taken on an as - needed basis. 14/14