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HomeMy WebLinkAboutAIO 021 BAREA INJECTION ORDER 21B Meltwater Oil Pool Kuparuk River Field 1. May 5, 2015 Notice of public hearing, affidavit of publication, email distribution, mailings 2. April 14, 2015 CPAI’s request to amend AIO 21A 3. July 9, 2015 Transcript, exhibits, sign-in sheet 4. July 16, 2015 CPAI’s request to amend AIO 21A 5. October 21, 2015 KRU 2P-447 administrative approval (AIO 21B.001) 6. August 1, 2017 KRU 2P-429 administrative approval (AIO 21B.002) 7. September 26, 2017 CPAI’s injectivity test 8/22/17-9/5/17. 8. October 8, 2024 CPAI request cancellation of administrative approval of AIO 21B.001 (AIO 21B.001 Cancellation) ORDERS STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West 7th Avenue Anchorage Alaska 99501 Re: THE APPLICATION OF CONOCOPHILLIPS ALASKA, INC. for an amendment to the order authorizing underground injection of fluids for enhanced oil recovery in the Meltwater Oil Pool, in the Meltwater Participating Area, Kuparuk River Field, North Slope, Alaska IT APPEARING THAT: Area Injection Order No. 21B Docket No. AIO-15-015 Kuparuk River Field Kuparuk River Unit Meltwater Oil Pool October 8, 2015 1. Area Injection Order (AIO) 21 authorizing underground injection of fluids for enhanced oil recovery was issued for the Kuparuk River Unit (KRU) Meltwater Oil Pool (MOP) on August 1, 2001. Based upon additional information presented by ConocoPhillips Alaska, Inc. (CPAI), AIO 21 was revoked and replaced by AIO 21 A on May 16, 2013. 2. Recent geologic and production data analyses indicate AIO 21A does not accurately describe the MOP and confinement of injected fluids. 3. By application received on April 14, 2015 CPAI, as operator of the KRU, requested four amendments to existing rules of AIO 21A. 4. A notice of a public hearing was published on the State of Alaska Online Public Notice web site and on the Alaska Oil and Gas Conservation Commission (AOGCC) web site on May 4, 2015. On May 5, 2015, the notice was published in the Alaska Dispatch News. The hearing was scheduled for July 9, 2015. 5. The AOGCC received no comments or requests for a public hearing. 6. On July 9, 2015, the public hearing convened. 7. At the conclusion of the July 9, 2015 hearing, the AOGCC requested additional information from CPAI. The record was left open until July 16, 2015. CPAI submitted the requested information on July 16, 2015. FINDINGS: 1. The Environmental Protection Agency exempted all aquifers within the existing KRU. 40 CFR 147.102. 2. CO 456A defines the MOP as strata equivalent to those between 6,785 and 6,974 feet measured depth (MD) in well Meltwater North #2A. 3. Regular production from the MOP commenced in November 2001. Miscible gas Area Injection Order A B October 8, 2015 0 Page 2 injection began in January 2002, and water injection commenced in May 2003. Producing wells initially used miscible injectant (MI) for artificial lift. 4. The initial reservoir pressure for the MOP was approximately 2,400 psi. Injection activity increased reservoir pressure near injection wells to over 4,000 psi; reservoir pressure near shut-in producers reached nearly 3,000 psi. 5. CPAI encountered elevated gas pressures while drilling MOP well KRU 2P-441 in March 2002. 6. Beginning in April 2002, CPAI noted elevated outer annulus pressures in MOP development wells. Gas samples taken from outer annuli had chemical signatures consistent with MI. CPAI initially suspected MI gas used for artificial lift was migrating into the outer annuli, possibly through leaking, threaded casing connections. 7. After identifying elevated outer annulus pressures in MOP wells, CPAI initiated an annulus -monitoring program and attempted periodic annulus pressure bleeds. Since 2003, CPAI has provided periodic updates of monitoring and diagnostic efforts to AOGCC. 8. Water injection into the MOP ceased in October 2009 due to water supply line corrosion concerns. CPAI converted existing MOP water -injection wells to MI injection or shut them in. CPAI no longer uses water injection, other than for short term diagnostic purposes. 9. Using proprietary 4D seismic evaluation, CPAI identified a potential vertical migration mechanism from the MOP that allowed injected fluids to escape from the MOP and enter shallower strata. 10. During April 2012, CPAI reduced the injection -to -withdrawal ratio to ensure confinement of injected fluids to the MOP. Outer annuli pressures subsequently declined. In August 2012, CPAI restricted MI injection pressure to ensure that sand - face injection pressure remains less than 3,400 psi. 11. On October 4, 2012, AOGCC issued Administrative Approval AIO 21.001 allowing continued MI injection into the MOP subject to several conditions, including: daily recording of well pressures, monthly reporting of all MOP wells, and pressure restrictions on the outer annuli of all wells. 12. CPAI requests AOGCC revise AIO 21A to address numerous changes needed because CPAI believes injected gas is now being confined to the MOP as required by AOGCC regulations and AIO 21A. 13. Rule 2 of AIO 21A prohibits new wells and well conversions in the MOP. CPAI requests Rule 2 be modified to allow new wells (grassroots wells), development well sidetracks, and well conversions within the MOP. CPAI requests this change to allow for producer to injector conversions and the ability to drill new development wells and coil tubing sidetracks within the MOP. CPAI believes that by placing injectors and producers within the same lobe deposit, injected fluids will be contained within the MOP, the risk of further migration of injected fluids will be reduced, and ultimate hydrocarbon recovery will be improved. Area Injection Order AB October 8, 2015 0 Page 3 14. CPAI requests modification of Rule 8 of AIO 21A, to allow injection of Beaufort Sea water and KRU produced water for surveillance, logging near wellbore formation displacements, and well maintenance. 15. CPAI requests modification of Rule 9 of AIO 21A, Performance Reporting, to read "The Operator shall submit an annual synopsis of the surveillance, monitoring, and development initiatives completed during the previous year that pertain to the confinement of injected fluids within the Bermuda Interval together with the Meltwater Annual Surveillance Report." 16. CPAI requests removing Rule 11 of AIO 21 A, Expiration Date, which was extended on May 6, 2015 by AIO 21A.007 to November 16, 2015. CPAI states in its application "...surveillance and monitoring data suggest that the implementation of the new reservoir management strategy has prevented further migration of fluids out of the MOP. The existing rules in AIO 21A, together with the aforementioned proposed amendments, will ensure long term confinement of injected fluids and optimal hydrocarbon recovery." CPAI submitted additional information on July 16, 2015 stating "ConocoPhillips believes that a period of 10 years between Area Injection Order renewals is appropriate for AIO 21A. This recommended period of 10 years is predicated upon the cycle time to design and complete development initiatives and to evaluate the field performance data." CONCLUSIONS: 1. AIO 21A and associated administrative actions should be revoked and replaced with a time -limited injection order tailored to the circumstances in the MOP. 2. Injection activities at the MOP resulted in loss of confinement. Injected fluids migrated into shallower strata, entered uncemented portions of offset wells, and elevated pressures in the outer annuli of numerous MOP wells. Injection well reservoir pressures above 4,000 psi (Finding 4), exceeded the fracture initiation pressure of the Bermuda and confining strata (Finding 18 AIO 21A) establishing migration pathways. 3. CPAI estimates that 25-30 percent of the fluids injected into the MOP cannot be accounted for in the reservoir material balance and are suspected to have escaped reservoir containment. Annulus pressure bleeds cannot account for this full volume of escaped fluid. The possibility that gas charged sands overlying the MOP may exist is a significant drilling hazard. Grassroots wells should be treated like exploratory wells including requiring mud logs, gamma ray logs, porosity and resistivity logs, and a shallow hazards survey to identify potentially gas charged shallow sands. 4. CPAI has implemented reservoir management practices including reducing the injection -to -withdrawal ratio and restricting the MI injection pressure in response to the migration of MI out of the MOP. Indications are that these changes may be allowing migration pathways to close, however, continued measures are required to confirm the effectiveness of these mitigating practices. 5. Water injection for the purpose of surveillance, logging, near wellbore formation Area Injection Order N IB October 8, 2015 • Page 4 displacements, and well maintenance is a valuable tool to properly develop and manage the MOP. Since Beaufort Sea water was previously authorized by AIO 21 A.003 and AIO 21 A.005 for a limited time for video and fluid movement logging, this fluid should be authorized. 6. With the dissipating amounts of MI recovered during the annulus bleed operations and other information indicating migration pathways are closing, a monthly report is no longer necessary. A detailed annual report will provide sufficient information for the AOGCC to properly monitor this issue moving forward. NOW, THEREFORE, IT IS ORDERED THAT AIO 21 and AIO 2 1 A and all associated administrative approvals are hereby revoked and replaced by this order. All information related to AIO 21 and AIO 2 1 A is hereby incorporated by reference into the record for this order. The following rules, in addition to statewide requirements under 20 AAC 25 (to the extent not superseded by these rules), govern Class 11 enhanced oil recovery injection operations in the affected area described below: Umiat Meridian Township Range Section T8N R7E Sections 1 through 36: All State Lands Rule 1 Authorized Injection Strata for Enhanced Recovery (Source: AIO 21) Within the affected area, fluids appropriate for enhanced recovery may be injected for purposes of pressure maintenance and enhanced recovery into strata that are common to, and correlate with, the interval between 6,785' and 6,974' MD in well Meltwater North #2A. Rule 2 Meltwater Oil Pool Wells (Source: — Revised this Order) For any new well drilling surface hole in the affected area: a. A well site survey in accordance with 20 AAC 25.061(a) will be required; and b. Mud logs, gamma ray logs, porosity and resistivity logs will be required from the base of the conductor to total depth. Rule 3 Monitoring the Tubing -Casing Annulus Pressure Variations (Source: AIO 21, AIO 21.001) The tubing -casing annulus pressure and injection rate of each injection well must be checked at least weekly to confirm continued mechanical integrity. The operator shall record wellhead pressures and injection rates daily. The operator shall limit the outer annulus pressure to 1000 psi. Area Injection Order 1001 B October 8, 2015 • Page 5 Rule 4 Demonstration of Tubing -Casing Annulus Mechanical Integrity (Source: Revised this Order) 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. An AOGCC-witnessed mechanical integrity test (MIT) must be performed after injection is commenced for the first time in a well, to be scheduled when injection conditions (temperature, pressure, and rate) have stabilized and every 2 years thereafter. MIT's must be conducted in accordance with AOGCC Industry Guidance Bulletin No. 10-02A — "Mechanical Integrity Testing" and done to a test pressure equal to the maximum anticipated surface injection pressure. The AOGCC must be notified, following the procedures in AOGCC Industry Guidance Bulletin No. 10-OIA — "Test Witness Notification", at least 48 hours in advance to enable a representative to witness a MIT. The MIT report (AOGCC Form 10-426) must be provided to AOGCC no later than the 5t" calendar day of the month following the testing. Test results must be readily available for AOGCC inspection upon request. Rule 5 Notification of Improper Class II Infection (Source: Revised this order) Injection of fluids other than those listed in Rule 8 without prior authorization is improper Class II injection. Upon discovery of such an event, the operator must immediately notify the AOGCC, provide details of the operation, and propose actions to prevent recurrence. Notification to AOGCC does not relieve the operator of the notification requirements of any other State or Federal agency. Rule 6 Well Integrity and Confinement (Source: AIO 21A) 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 immediately notify the AOGCC and obtain permission for continued operation of the well. A corrective action plan shall be provided for AOGCC review and approval prior to further action being taken. The operator will also consult with the AOGCC about the need to shut in all wells in the MOP. Rule 7 Authorized Infection Pressure (Source: AIO 21A.004) Injection pressures must be maintained at or below 3,400 prig at the reservoir sand -face. Rule 8 Authorized Fluids for Injection (Source: Revised this order) Fluids authorized for injection are: a. Miscible injectant; b. Dry gas provided by the Kuparuk River Unit; c. Tracer survey fluid to monitor reservoir performance; d. Fluids injected for stimulation purposes per 20 AAC 25.280(a)(2); e. Glycol from hydro -tests and freeze protection; f. Diesel used for freeze protection; Area Injection Order Noll B October 8, 2015 • Page 6 g. Methanol used for freeze protection; h. Standard oilfield chemicals (corrosion and scale inhibitors, defoamers, emulsion breakers, etc.); i. Beaufort Sea water used for surveillance, logging, near wellbore formation displacements, and well maintenance; and j. KRU produced water used for surveillance, logging, near wellbore formation displacements, and well maintenance. Any other fluids, or uses for the above fluids, shall be approved in advance by separate action based upon proof of compatibility with the reservoir and formation fluids. Rule 9 Performance Reporting (Source: Revised this order) The operator shall submit to AOGCC an annual synopsis of the surveillance, monitoring, and development initiatives completed during the previous year that pertain to the confinement of the injected fluids within the MOP together with the Meltwater Annual Surveillance Report. The annual surveillance report will be required by April I of each year. The report shall include, but is not limited to, the following: a. progress of the enhanced recovery project and reservoir management summary including engineering and geological parameters; b. reservoir voidage balance by month of produced and injected fluids; c. analysis of reservoir pressure surveys within the pool; d. results and, where appropriate, analysis of production and injection log surveys, tracer surveys and observation well data or surveys; e. assessment of fracture propagation into adjacent confining intervals; f. summary of MIT results; g. summary of results of inner and outer annulus monitoring for all production wells, injection wells, and any wells that are not cemented across the Meltwater Oil Pool and are located within a'/4-mile radius of a Meltwater injector; h. results of any special monitoring; i. reservoir surveillance plans for the next year; and j. future development plans. Rule 10 Administrative Action (Source: AIO 21A) Upon proper application, or its own motion, and unless notice and public hearing are otherwise required, the AOGCC may administratively waive the requirements of any rule stated herein or administratively amend this order as long as the change does not promote waste or jeopardize correlative rights, is based on sound engineering and geoscience principles, and will not result in an increased risk of fluid movement into freshwater. Rule 11 Expiration Date (Source: Revised this order) This order shall expire if CPAI ceases to be the Designated Operator for the KRU. If CPAI continues as Designated Operator, this order shall expire five years after the effective date shown below unless prior to the expiration date CPAI requests the order be extended. Area Injection Order N9 B • Page 7 October 8, 2015 Any such request shall include: a. A review of the existing rules in the order and an analysis whether or not those rules should be retained, amended, or repealed; b. A review of, and discussion on, whether or not the affected area of the order should be revised; and c. A discussion of, and justification for, proposed new rules or revisions to existing rules. Done at Anchorage, Alaska and dated October 8, 2015. Cathy V Foerster Daniel T. Seamount, Jr. 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 @re AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on reconsideration. As provided in AS 31.05.080(b), "[t]he questions reviewed on appeal are limited to the questions presented to the AOGCC by the application for 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. Singh. Angela K (DOA) From: Colombie, Jody J (DOA) Sent: Thursday, October 08, 2015 4:09 PM To: Ballantine, Tab A (LAW); Bender, Makana K (DOA); Bettis, Patricia K (DOA); Bixby, Brian D (DOA); Brooks, Phoebe L (DOA); Carlisle, Samantha J (DOA); Colombie, Jody 1 (DOA); Cook, Guy D (DOA); Crisp, John H (DOA); Davies, Stephen F (DOA); Eaton, Loraine E (DOA); Foerster, Catherine P (DOA); Frystacky, Michal (DOA); Grimaldi, Louis R (DOA); Guhl, Meredith D (DOA); Herrera, Matthew F (DOA); Hill, Johnnie W (DOA); Jones, Jeffery B (DOA); Kair, Michael N (DOA); Loepp, Victoria T (DOA); Mumm, Joseph (DOA sponsored); Noble, Robert C (DOA); Paladijczuk, Tracie L (DOA); Pasqual, Maria (DOA); Regg, James B (DOA); Roby, David S (DOA); Scheve, Charles M (DOA); Schwartz, Guy L (DOA); Seamount, Dan T (DOA); Singh, Angela K (DOA); Wallace, Chris D (DOA); AKDCWellIntegrityCoordinator, Alex Demarban; Alexander Bridge; Allen Huckabay; Andrew VanderJack, Anna Raff; Barbara F Fullmer; bbritch; bbohrer@ap.org; Bob Shavelson; Brian Havelock, Bruce Webb; Burdick, John D (DNR); Carrie Wong; Cliff Posey; Colleen Miller, Crandall, Krissell; D Lawrence; Dave Harbour, David Boelens; David Duffy; David House; David McCaleb; David Steingreaber; David Tetta; Davide Simeone; ddonkel@cfl.rr.com; Dean Gallegos; Delbridge, Rena E (LAS); DNROG Units (DNR sponsored); Donna Ambruz; Ed Jones; Elowe, Kristin; Evans, John R (LDZX); Frank Molli; Gary Oskolkosf, George Pollock; ghammons; Gordon Pospisil; Gregg Nady; gspfoff, Jacki Rose; Jdarlington Oarlington@gmail.com); Jeanne McPherren; Williams, Jennifer L (LAW); Jerry Hodgden; Jerry McCutcheon; Solnick, Jessica D (LAW); Jim Watt; Jim White; Joe Lastufka; Joe Nicks; John Adams; Easton, John R (DNR); Jon Goltz; Juanita Lovett; Judy Stanek; Houle, Julie (DNR); Julie Little; Kari Moriarty, Kazeem Adegbola; Keith Wiles; Kelly Sperback; Gregersen, Laura S (DNR); Leslie Smith; Lisa Parker, Louisiana Cutler, Luke Keller; Marc Kovak; Dalton, Mark (DOT sponsored); Mark Hanley (mark.hanley@anadarko.com); Mark Landt; Mark Wedman; Kremer, Marguerite C (DNR); Mary Cocklan-Vendl; Michael Calkins; Michael Duncan; Michael Moora; Mike Bill; mike@kbbi.org; Mikel Schultz; MJ Loveland; mkm7200; Morones, Mark P (DNR); Munisteri, Islin W M (DNR); knelson@petroleumnews.com; Nichole Saunders; Nick W. Glover; Nikki Martin; NSK Problem Well Supv; Patty Alfaro; Paul Craig; Decker, Paul L (DNR); Paul Mazzolini; Pike, Kevin W (DNR); Randall Kanady; Randy L. Skillern; Renan Yanish; Robert Brelsford; Ryan Tunseth; Sara Leverette; Scott Griffith; Shannon Donnelly, Sharmaine Copeland; Sharon Yarawsky, Shellenbaum, Diane P (DNR); Smart Energy Universe; Smith, Kyle S (DNR); Sondra Stewman; Stephanie Klemmer; Sternicki, Oliver R; Moothart, Steve R (DNR); Suzanne Gibson; sheffield@aoga.org; Tania Ramos; Ted Kramer, Davidson, Temple (DNR); Terence Dalton; Teresa Imm; Terry Templeman; Thor Cutler, Tim Mayers; Todd Durkee; Tony Hopfinger; trmjrl; Tyler Senden; Vicki Irwin; Vinnie Catalano; Aaron Gluzman; Aaron Sorrell; Ajibola Adeyeye; Alan Dennis; Andrew Cater, Anne Hillman; Bajsarowicz, Caroline J; Brian Gross; Bruce Williams; Bruno, Jeff 1 (DNR); Casey Sullivan; Don Shaw; Donna Vukich; Eric Lidji; Erik Opstad; Gary Orr; Smith, Graham O (PCO); Greg Mattson; Dickenson, Hak K (DNR); Heusser, Heather A (DNR); Holly Pearen; Hyun, James 1 (DNR); Jason Bergerson; jill.a.mcleod@conocophillips.com; Jim Magill; Joe Longo; John Martineck; Josh Kindred; Kenneth Luckey; King, Kathleen J (DNR); Laney Vazquez, Lois Epstein; Longan, Sara W (DNR); Marc Kuck; Marcia Hobson; Steele, Marie C (DNR); Matt Armstrong; Matt Gill; Franger, James M (DNR); Morgan, Kirk A (DNR); Pat Galvin; Pete Dickinson; Peter Contreras; Richard Garrard; Richmond, Diane M; Robert Province; Ryan Daniel; Sandra Lemke; Sarah Baker, Peterson, Shaun (DNR); Pollard, Susan R (LAW); Talib Syed; Tina Grovier (tmgrovier@stoel.com); Todd, Richard J (LAW); Tostevin, Breck C (LAW); Wayne Wooster, William Hutto; William Van Dyke; jilt.a.mcleod@conocophillips.com Subject: A• 1B (CPA) (KRU) • Attachments: aio2lb.pdf • • James Gibbs P.O. Box 1597 Soldotna, AK 99669 Gordon Severson 3201 Westmar Cir. Anchorage, AK 99508-4336 Richard Wagner P.O. Box 60868 Fairbanks, AK 99706 Jack Hakkila P.O. Box 190083 Anchorage, AK 99519 Penny Vadla 399 W. Riverview Ave. Soldotna, AK 99669-7714 Bernie Karl K&K Recycling Inc. P.O. Box 58055 Fairbanks, AK 99711 George Vaught, Jr. P.O. Box 13557 Denver, CO 80201-3557 Kazeem A. Adegbola Manager, GKA Development Darwin Waldsmith North Slope Operations and Development P.O. Box 39309 ConocoPhillips Alaska, Inc. Ninilchik, AK 99639 Office: ATO-1326 700 G St. Anchorage, AK 99501 Angela K. Singh • THE STATE 'A.LASl\L`1 GOVERNOR BILL WALKER • Alaska Oil and Gas Conservation Commission ADMINISTRATIVE APPROVAL AREA INJECTION ORDER NO.21B.001 Ms. Kelly Lyons Problem Wells Supervisor ConocoPhillips Alaska, Inc. P.O. Box 100360 Anchorage, AK 99510-0360 Re: Docket Number: AIO-15-045 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907.279.1433 Fax: 907.276.7542 www.aogcc.alaska.gov Request for administrative approval allowing well 2P-447 (PTD 2031540) to continue to operate with increased outer annulus (OA) pressure not to exceed 1,800 psi to establish stabilized OA pressure and recharge rates. Kuparuk River Unit (KRU) 2P-447 (PTD 2031540) Kuparuk River Field Meltwater Oil Pool Dear Ms. Lyons: By letter dated October 10, 2015, ConocoPhillips Alaska, Inc. (CPAI) requested administrative approval to continue the increased annular pressure limit in the subject well. In accordance with Rule 10 of Area Injection Order (AIO) 021B.000, the Alaska Oil and Gas Conservation Commission (AOGCC) hereby GRANTS CPAI's request for administrative approval to continue to operate the well with the increased outer annular pressure limit specified in AIO 021B.000 Rule 3 from 1000 psi to a maximum of 1800 psi in the subject well. CPAI is continuing a program to determine fluid movement around the production casing shoes of the injection wells. CPAI is also pursuing a number of surveillance initiatives to aid in their efforts in characterization and understanding of the Meltwater shallow gas issue. This monitoring plan will further investigate reservoir and injection responses for the Meltwater oil pool. A key component of this plan is to allow the OA pressure in well 2P-447 to increase to equilibrium pressure without being restrained by the 1000 psi limit that is being maintained through the existing bleed program. The well exhibits at least two competent barriers to the release of well pressure. Accordingly, the AOGCC believes that the well's condition does not compromise overall well integrity so as to threaten human safety or the environment. AIO 21B.001 . October 21, 2015 Page 2 of 2 DONE at Anchorage, Alaska and dated October 21, 2015. a?41 Cathy V Foerster Daniel T. Seamount, Jr. Chair, Commissioner Commissioner 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. • 0 James Gibbs Jack Hakkila Bernie Karl P.O. Box 1597 P.O. Box 190083 K&K Recycling Inc. Soldotna, AK 99669 Anchorage, AK 99519 P.O. Box 58055 Fairbanks, AK 99711 Gordon Severson Penny Vadla George Vaught, Jr. 3201 Westmar Cir. 399 W. Riverview Ave. P.O. Box 13557 Anchorage, AK 99508-4336 Soldotna, AK 99669-7714 Denver, CO 80201-3557 Ms. Kelly Lyons Richard Wagner Darwin Waldsmith Problem Wells Supervisor P.O. Box 60868 P.O. Box 39309 ConocoPhillips Alaska, Inc. Fairbanks, AK 99706 Ninilchik, AK 99639 P.O. Box 100360 Anchorage, AK 99510-0360 y-&a,�-e Angela K. Singh Colombie, Jody J (DOA) From: Colombie, Jody J (DOA) Sent: Wednesday, October 21, 2015 12:37 PM To: 'AKDCWellIntegrityCoordinator'; 'Alex Demarban'; 'Alexander Bridge'; 'Allen Huckabay'; 'Andrew VanderJack'; 'Anna Raff'; 'Barbara F Fullmer'; 'bbritch'; 'Becky Bohrer'; 'Bob Shavelson'; 'Brian Havelock'; 'Bruce Webb'; Burdick, John D (DNR); 'Carrie Wong'; 'Cliff Posey'; 'Colleen Miller'; 'Crandall, Krissell'; 'D Lawrence'; 'Dave Harbour'; 'David Boelens'; 'David Duffy'; 'David House'; 'David McCaleb'; 'David Steingreaber'; 'David Tetta'; 'Davide Simeone'; 'ddonkel@cfl.rr.com'; 'Dean Gallegos'; Delbridge, Rena E (LAS); DNROG Units (DNR sponsored); 'Donna Ambruz'; 'Ed Jones'; 'Elowe, Kristin'; 'Evans, John R (LDZX)'; 'Frank Molli'; 'Gary Oskolkosf'; 'George Pollock'; 'ghammons'; 'Gordon Pospisil'; 'Gregg Nady'; 'gspfoff'; 'Jacki Rose'; 'Jdarlington oarlington@gmail.com)'; 'Jeanne McPherren'; 'Jennifer Williams'; 'Jerry Hodgden'; 'Jerry McCutcheon'; 'Jessica Solnick'; 'Jim Watt'; 'Jim White'; 'Joe Lastufka'; 'Joe Nicks'; 'John Adams'; 'John Easton'; 'Jon Goltz'; 'Juanita Lovett'; 'Judy Stanek'; 'Julie Houle'; 'Julie Little'; 'Karl Moriarty'; 'Kazeem Adegbola'; 'Keith Wiles'; 'Kelly Sperback'; 'Laura Silliphant (laura.gregersen@alaska.gov)'; 'Leslie Smith'; 'Lisa Parker'; 'Louisiana Cutler'; 'Luke Keller'; 'Marc Kovak'; 'Mark Dalton'; 'Mark Hanley (mark.hanley@anadarko.com)'; 'Mark Landt'; 'Mark Wedman'; 'Marquerite kremer (meg.kremer@alaska.gov)'; 'Mary Cocklan-Vendl'; 'Michael Calkins'; 'Michael Duncan'; 'Michael Moora'; 'Mike Bill'; 'Mike Mason'; 'Mike) Schultz'; 'MJ Loveland'; 'mkm7200'; Morones, Mark P (DNR); Munisteri, Islin W M (DNR); 'nelson'; 'Nichole Saunders'; 'Nick W. Glover'; 'Nikki Martin'; 'NSK Problem Well Supv'; Patty Alfaro; 'Paul Craig'; Paul Decker (paul.decker@alaska.gov); 'Paul Mazzolini'; Pike, Kevin W (DNR); Randall Kanady; Randy L. Skillern; 'Renan Yanish'; 'Robert Brelsford'; 'Ryan Tunseth'; Sara Leverette; 'Scott Griffith'; Shannon Donnelly; Sharmaine Copeland; 'Sharon Yarawsky'; Shellenbaum, Diane P (DNR); Smart Energy Universe; Smith, Kyle S (DNR); Sondra Stewman; 'Stephanie Klemmer'; Sternicki, Oliver R; Steve Moothart (steve.moothart@alaska.gov); 'Suzanne Gibson'; Tamera Sheffield; 'Tania Ramos'; 'Ted Kramer'; Temple Davidson; Terence Dalton; Teresa Imm; Thor Cutler; 'Tim Mayers'; Todd Durkee; trmjrl; 'Tyler Senden'; Vicki Irwin; Vinnie Catalano; 'Aaron Gluzman'; 'Aaron Sorrell'; Ajibola Adeyeye; Alan Dennis; Andrew Cater; Anne Hillman; Bajsarowicz, Caroline J; Brian Gross; 'Bruce Williams'; Bruno, Jeff J (DNR); Casey Sullivan; Don Shaw; 'Donna Vukich'; Eric Lidji; 'Gary Orr'; 'Graham Smith'; 'Greg Mattson'; Hak Dickenson; Heusser, Heather A (DNR); Holly Pearen; James Hyun; 'Jason Bergerson'; 'Jill McLeod'; 'Jim Magill'; Joe Longo; John Martineck; Josh Kindred; Kenneth Luckey; King, Kathleen J (DNR); Laney Vazquez; Lois Epstein; Longan, Sara W (DNR); Marc Kuck; Marcia Hobson; 'Marie Steele'; Matt Armstrong; 'Mike Franger'; Morgan, Kirk A (DNR); Pat Galvin; 'Patricia Bettis'; Pete Dickinson; Peter Contreras; Richard Garrard; Richmond, Diane M; Robert Province; 'Ryan Daniel'; 'Sandra Lemke'; Sarah Baker; Shaun Peterson; 'Susan Pollard'; Talib Syed; Tina Grovier (tmgrovier@stoel.com); Todd, Richard J (LAW); Tostevin, Breck C (LAW); 'Wayne Wooster'; 'William Van Dyke'; 'Ballantine, Tab A (LAW) (tab.ballantine@alaska.gov)'; 'Bender, Makana K (DOA) (makana.bender@alaska.gov)'; Bixby, Brian D (DOA); 'Brooks, Phoebe L (DOA) (phoebe.brooks@alaska.gov)'; Carlisle, Samantha J (DOA); 'Colombie, Jody J (DOA) Oody.colombie@alaska.gov)'; Cook, Guy D (DOA); 'Crisp, John H (DOA) Oohn.crisp@alaska.gov)'; 'Davies, Stephen F (DOA) (steve.davies@alaska.gov)'; Eaton, Loraine E (DOA); 'Foerster, Catherine P (DOA) (cathy.foerster@alaska.gov)'; Trystacky, Michal (michal.frystacky@alaska.gov)'; 'Grimaldi, Louis R (DOA) (lou.grimaldi@alaska.gov)'; 'Guhl, Meredith (DOA sponsored) (meredith.guhl@alaska.gov)'; Herrera, Matthew F (DOA); 'Hill, Johnnie W (DOA)'; 'Jones, Jeffery B (DOA) (Jeff Jones@alaska.gov)'; Kair, Michael N (DOA); Loepp, Victoria T (DOA); 'Mumm, Joseph (DOA sponsored) Ooseph.mumm@alaska.gov)'; 'Noble, Robert C (DOA) 1 To: (bo*ble@alaska.gov)'; 'Paladijczuk, Tracie L (LO (tracie.palad ijczuk@alaska.gov)'; 'Pasqual, Maria (DOA) (maria.pasqual@alaska.gov)'; 'Regg, James B (DOA) Oim.regg@alaska.gov)'; 'Roby, David S (DOA) (dave.roby@alaska.gov)'; 'Scheve, Charles M (DOA) (chuck.scheve@alaska.gov)'; 'Schwartz, Guy L (DOA) (guy.schwartz@alaska.gov)'; 'Seamount, Dan T (DOA) (dan.seamount@alaska.gov)'; 'Singh, Angela K (DOA) (angela.singh@alaska.gov)'; 'Wallace, Chris D (DOA) (chris.waIlace@alaska.gov)' Subject: aio2lb-001(KRU Meltwater) Attachments: aio2lb-001.pdf 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 NO. 21B.001 CANCELATION Ms. Jaime Bronga Well Integrity Specialist ConocoPhillips Alaska, Inc. P.O. Box 100360 Anchorage, AK 99510-0360 Re: Docket Number: AIO-24-029 Request to cancel Area Injection Order (AIO) 21B.001 Kuparuk River Unit (KRU) 2P-447 (PTD 2031540), Meltwater Oil Pool Dear Ms. Bronga: By letter dated October 8, 2024, ConocoPhillips Alaska, Inc. (CPAI) requested cancellation of administrative approval (AA) AIO 21B.001. In accordance with 20 AAC 25.556(d), the Alaska Oil and Gas Conservation Commission (AOGCC) hereby GRANTS CPAI’s request to cancel the AA. CPAI, by letter dated October 10, 2015, had requested an increase in the outer annulus operating pressure from 1,000 psi (AIO 21B.000) to 1,800 psi in continuing efforts to understand the Meltwater shallow gas issues. On October 21, 2015, AOGCC issued AIO 21B.001. AOGCC determined that water only injection could safely continue if CPAI complied with the restrictive conditions set out in the AA. CPAI has suspended the well under Sundry 323-609 and on August 9, 2024, completed a passing state-witnessed cement plug verification and mechanical integrity test of the tubing. AA AIO 21B.001 is hereby CANCELED. DONE at Anchorage, Alaska and dated October 9, 2024. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner Gregory Wilson Digitally signed by Gregory Wilson Date: 2024.10.09 13:31:59 -08'00' Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2024.10.09 15:26:27 -08'00' AIO 21B.001 Cancelation October 9, 2024 Page 2 of 2 RECONSIDERATION AND APPEAL NOTICE As provided in AS 31.05.080(a), within 20 days after written notice of the entry of this order or decision, or such further time as the AOGCC grants for good cause shown, a person affected by it may file with the AOGCC an application for reconsideration of the matter determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration must set out the respect in which the order or decision is believed to be erroneous. The AOGCC shall grant or refuse the application for reconsideration in whole or in part within 10 days after it is filed. Failure to act on it within 10 days is a denial of reconsideration. If the AOGCC denies reconsideration, upon denial, this order or decision and the denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision denying reconsideration, UNLESS the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which the application for reconsideration was filed. If the AOGCC grants an application for reconsideration, this order or decision does not become final. Rather, the order or decision on reconsideration will be the FINAL order or decision of the AOGCC, and it may be appealed to superior court. That appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on reconsideration. In computing a period of time above, the date of the event or default after which the designated period begins to run is not included in the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00 p.m. on the next day that does not fall on a weekend or state holiday. From:Coldiron, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Area Injection Order 21B.001 cancel (CPAI) Date:Thursday, October 10, 2024 7:45:43 AM Attachments:aio21B.001 cancel.pdf Docket Number: AIO-24-029 Request to cancel Area Injection Order (AIO) 21B.001 Kuparuk River Unit (KRU) 2P-447 (PTD 2031540), Meltwater Oil Pool Samantha Coldiron AOGCC Special Assistant Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, AK 99501 (907) 793-1223 __________________________________ List Name: AOGCC_Public_Notices@list.state.ak.us You subscribed as: samantha.coldiron@alaska.gov Unsubscribe at: https://list.state.ak.us/mailman/options/aogcc_public_notices/samantha.coldiron%40alaska.go v THE STATE °1AI.As� GOVERNOR BILL WALKER Ms. Vanessa Angel Alaska Oil and Gas Conservation Commission ADMINISTRATIVE APPROVAL AREA INJECTION ORDER NO.21B.002 Senior Petroleum Engineer ConocoPhillips Alaska, Inc. P.O. Box 100360 Anchorage, AK 99510 Re: Docket Number: AIO 17-025 Administrative Approval to allow for a water injectivity test Kuparuk River Unit 2P-429 well (PTD 201-102) Kuparuk River Unit Meltwater Oil Pool Dear Ms. Angel: 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907.279.1433 Fax: 907.276.7542 www.aogcc.alaska.gov On August 1, 2017, ConocoPhillips Alaska, Inc. (CPAI) submitted a sundry application (Sundry Number 317-358) to conduct an approximately two -week water injectivity test on the Kuparuk River Unit 2P-429 well (KRU 2P-429). On August 3, 2017, CPAI sent an email clarifying the maximum surface injection pressure expected during the proposed test. Area Injection Order 21B (AIO 21B) currently authorizes the injection of Beaufort Sea and Kuparuk River Unit (KRU) Produced water in the Meltwater Oil Pool (MOP) for surveillance, logging, near wellbore formation displacements, and well maintenance. The proposed injectivity test does not fall within the types of activities where water injection is already authorized. An administrative approval is necessary in order to carry out the proposed work. I In accordance with Rule 10 of AIO 21B, CPAI's proposed water injectivity test in the KRU 2P- 429 well is HEREBY AUTHORIZED subject to the conditions below. The MOP was originally developed with a water alternating gas (WAG) enhanced oil recovery (EOR) project, but has been exclusively injecting gas since 2009. Over time this has caused the gas oil ratio (GOR) for wells in the MOP to climb to the point where they are no longer consistently competitive producers. CPAI believes that converting the field to water injection will help make this pool more competitive and extend its economic life and thus increase ultimate recovery. Previously, water injection into the MOP was done at high pressures and this contributed to a loss of containment, which ultimately led to the issuance of AIO 21 A. AIO 21 A provides a specific list of fluids authorized for FOR injection in the MOP (the list does not include water) and establishes a maximum sand -face injection pressure limit of 3,400 psig for injection activities. AIO 21 B.002 August 9, 2017 Page 2 of 3 CPAI wants to test the viability of lower injection pressure, below the sand -face injection pressure limit, as an FOR process for the MOP to: determine whether to pursue this as a full field project. To that end, CPAI has requested authorization to conduct a two -week water injectivity test, utilizing produced water sourced from KRU Central Processing Facility 2, with a maximum surface injection pressure of 958 psi. Limiting the surface injection pressure to 958 psi during the water injectivity test will ensure that the sand -face injection pressure does not exceed the limit set by AIO 21B and thus should ensure containment of injected fluids during the test.] Bottomhole pressure will be monitored in offset wells before, during, and after the injectivity test. Nearby gas injection wells will be shut-in during the test so that any pressure response shown in the offset wells can be attributed to the water injectivity test instead of being related to the ongoing gas injection FOR project. The results of the test will be used to determine whether to pursue a full field low-pressure water injection project. In accordance with Rule 10 of AIO 21 B the AOGCC grants CPAI permission to conduct a produced water injectivity test subject to the following conditions: 1) This authorization is limited to the single well injectivity test described in sundry application number 317-358 and the additional information provided on August 3, 2017. Expansion of water injection beyond this single well project will require separate approval from the AOGCC; and 2) Within 30 days of completion of the injectivity test CPAI shall provide the AOGCC with a summary of the results of the injectivity test. This summary shall include information on the rates at which water was able to be injected and the corresponding surface injection pressure at that rate, any operational issues encountered during the injectivity test, and information on any pressure response in the offset wells. DONE at Anchorage, Alaska and dated August 9, 2017. Daniel T. Sea ount, Jr. Cathy P Foerster Commissioner Commissioner ' Surface injection pressure will exceed the 958 PSI limit for a short period of time after water injection begins due to the fact that the well's tubing will be filled with injection gas and the pressure at the surface will be approximately 2,200 PSI. The initial water pumping pressure will need to be in excess of 2,200 PSI in order to be able to inject water into the wellbore. As the gas in the tubing is displaced with water the surface injection pressure will decrease due to the increased hydrostatic head of the water compared to the gas and by the time the gas is completely displaced with water and the water reaches the sand -face, the surface injection pressure will be under the 958 PSI limit, AIO 21 B.002 August 9, 2017 Page 3 of 3 RECONSIDERATION AND APPEAL NOTICE As provided in AS 31.05.080(a), within 20 days after written notice of the entry of this order or decision, or such further time as the AOGCC grants for good cause shown, a person affected by it may file with the AOGCC an application for reconsideration of the matter determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration must set out the respect in which the order or decision is believed to be erroneous. The AOGCC shall grant or refuse the application for reconsideration in whole or in part within 10 days after it is filed. Failure to act on it within 10-days is a denial of reconsideration. If the AOGCC denies reconsideration, upon denial, this order or decision and the denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision denying reconsideration, UNLESS the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which the application for reconsideration was filed. If the AOGCC grants an application for reconsideration, this order or decision does not become final. Rather, the order or decision on reconsideration will be the FINAL order or decision of the AOGCC, and it may be appealed to superior court. That appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on reconsideration. In computing a period of time above, the date of the event or default after which the designated period begins to run is not included in the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00 p.m. on the next day that does not fall on a weekend or state holiday. T] I f: S'I :}1TF. A L A S K__A_ t.rttVFRN0 R BiLL \%"AlKFP Ms. Vanessa Angel Alaska Oil and Gas Conservation Commission ADMINISTRATIVE APPROVAL AREA INJECTION ORDER NO.21B.002 Senior Petroleum Engineer ConocoPhillips Alaska, Inc. P.O. Box 100360 Anchorage, AK 99510 Re: Docket Number: AIO 17-025 Administrative Approval to allow for a water injectivity test Kuparuk River Unit 2P-429 well (PTD 201-102) Kuparuk River Unit Meltwater Oil Pool Dear Ms. Angel: 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907.279.1433 Fax: 907.276.7542 aogcc.alaska.gov On August 1, 2017, ConocoPhillips Alaska, Inc. (CPAI) submitted a sundry application (Sundry Number 317-358) to conduct an approximately two -week water injectivity test on the Kuparuk River Unit 2P-429 well (KRU 2P-429). On August 3, 2017, CPAI sent an email clarifying the maximum surface injection pressure expected during the proposed test. Area Injection Order 21B (AIO 21B) currently authorizes the injection of Beaufort Sea and Kuparuk River Unit (KRU) Produced water in the Meltwater Oil Pool (MOP) for surveillance, logging, near wellbore formation displacements, and well maintenance. The proposed injectivity test does not fall within the types of activities where water injection is already authorized. An administrative approval is necessary in order to carry out the proposed work. I In accordance with Rule 10 of AIO 21B, CPAI's proposed water injectivity test in the KRU 2P- 429 well is HEREBY AUTHORIZED subject to the conditions below. The MOP was originally developed with a water alternating gas (WAG) enhanced oil recovery (EOR) project, but has been exclusively injecting gas since 2009. Over time this has caused the gas oil ratio (GOR) for wells in the MOP to climb to the point where they are no longer consistently competitive producers. CPAI believes that converting the field to water injection will help make this pool more competitive and extend its economic life and thus increase ultimate recovery. Previously, water injection into the MOP was done at high pressures and this contributed to a loss of containment, which ultimately led to the issuance of AIO 21 A. AIO 21 A provides a specific list of fluids authorized for FOR injection in the MOP (the list does not include water) and establishes a maximum sand -face injection pressure limit of 3,400 psig for injection activities. A10 21B.002 August 9, 2017 Page 2 of 3 CPAI wants to test the viability of lower injection pressure, below the sand -face injection pressure limit, as an FOR process for the MOP to determine whether to pursue this as a full field project. To that end, CPAI has requested authorization to conduct a two -week water injectivity test, utilizing produced water sourced from KRU Central Processing Facility 2, with a maximum surface injection pressure of 958 psi. Limiting the surface injection pressure to 958 psi during the water injectivity test will ensure that the sand -face injection pressure does not exceed the limit set by AIO 21B and thus should ensure containment of injected fluids during the test.' Bottomhole pressure will be monitored in offset wells before, during, and after the injectivity test. Nearby gas injection wells will be shut-in during the test so that any pressure response shown in the offset wells can be attributed to the water injectivity test instead of being related to the ongoing gas injection FOR project. The results of the test will be used to determine whether to pursue a full field low-pressure water injection project. In accordance with Rule 10 of AIO 21B the AOGCC grants CPAI permission to conduct a produced water injectivity test subject to the following conditions: 1) This authorization is limited to the single well injectivity test described in sundry application number 317-358 and the additional information provided on August 3, 2017. Expansion of water injection beyond this single well project will require separate approval from the AOGCC; and 2) Within 30 days of completion of the injectivity test CPAI shall provide the AOGCC with a summary of the results of the injectivity test. This summary shall include information on the rates at which water was able to be injected and the corresponding surface injection pressure at that rate, any operational issues encountered during the injectivity test, and information on any pressure response in the offset wells. DONE at Anchorage, Alaska and dated August 9, 2017. //signature on file// Daniel T. Seamount, Jr. Commissioner //signature on file// Cathy P. Foerster Commissioner Surface injection pressure will exceed the 958 PSI limit for a short period of time after water injection begins due to the fact that the well's tubing will be filled with injection gas and the pressure at the surface will be approximately 2,200 PSI. The initial water pumping pressure will need to be in excess of 2,200 PSI in order to be able to inject water into the wellbore. As the gas in the tubing is displaced with water the surface injection pressure will decrease due to the increased hydrostatic head of the water compared to the gas and by the time the gas is completely displaced with water and the water reaches the sand -face, the surface injection pressure will be under the 958 PSI limit, A10 21B.002 August 9, 2017 Page 3 of 3 RECONSIDERATION AND APPEAL NOTICE As provided in AS 31.05.080(a), within 20 days after written notice of the entry of this order or decision, or such further time as the AOGCC grants for good cause shown, a person affected by it may file with the AOGCC an application for reconsideration of the matter determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration must set out the respect in which the order or decision is believed to be erroneous. The AOGCC shall grant or refuse the application for reconsideration in whole or in part within 10 days after it is filed. Failure to act on it within 10-days is a denial of reconsideration. If the AOGCC denies reconsideration, upon denial, this order or decision and the denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision denying reconsideration, UNLESS the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which the application for reconsideration was filed. If the AOGCC grants an application for reconsideration, this order or decision does not become final. Rather, the order or decision on reconsideration will be the FINAL order or decision of the AOGCC, and it may be appealed to superior court. That appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on reconsideration. hi 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. Bernie Karl Gordon Severson Penny Vadla K&K Recycling Inc. 3201 Westmar Cir. 399 W. Riverview Ave. P.O. Box 58055 Anchorage, AK 99508-4336 Soldotna, AK 99669-7714 Fairbanks, AK 99711-0055 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 99639-0309 Fairbanks, AK 99706-0868 <C,\\-2C, \Z o- . a Colombie, Jody J (DOA) From: Colombie, Jody J (DOA) Sent: Wednesday, August 09, 2017 3:32 PM To: aogcc.inspectors@alaska.gov; Bender, Makana K (DOA) (makana.bender@alaska.gov); Bettis, Patricia K (DOA) (patricia.bettis@alaska.gov); Brooks, Phoebe L (DOA) (phoebe.brooks@alaska.gov); Carlisle, Samantha J (DOA); Colombie, Jody J (DOA) Oody.colombie@alaska.gov); Davies, Stephen F (DOA) (steve.davies@alaska.gov); Eaton, Loraine E (DOA); Foerster, Catherine P (DOA) (cathy.foerster@alaska.gov); French, Hollis (DOA); Frystacky, Michal (michal.frystacky@alaska.gov); Guhl, Meredith (DOA sponsored) (meredith.guhl@alaska.gov); Kair, Michael N (DOA); Link, Liz M (DOA); Loepp, Victoria T (DOA); Mumm, Joseph (DOA sponsored) Ooseph.mumm@alaska.gov); Paladijczuk, Tracie L (DOA) (tracie. pa lad ijczu k@a laska.gov); Pasqual, Maria (DOA) (maria.pasqual@alaska.gov); Quick, Michael (DOA sponsored); Regg, James B (DOA) Oim.regg@alaska.gov); Roby, David S (DOA) (dave.roby@alaska.gov); Schwartz, Guy L (DOA) (guy.schwartz@alaska.gov); Seamount, Dan T (DOA) (dan.seamount@alaska.gov); Singh, Angela K (DOA); Wallace, Chris D (DOA) (chris.waIlace@alaska.gov); AK, GWO Projects Well Integrity; AKDCWellIntegrityCoordinator, Alan Bailey; Alex Demarban; Alexander Bridge; Alicia Showalter, Allen Huckabay; Andrew VanderJack; Ann Danielson; Anna Raff; Barbara F Fullmer, bbritch; Becky Bohrer; Ben Boettger; Bill Bredar; Bob; Brandon Viator; Brian Havelock, Bruce Webb; Caleb Conrad; Candi English; Cocklan-Vendl, Mary E; Colleen Miller; Connie Downing; Crandall, Krissell; D Lawrence; Dale Hoffman; Darci Horner; Dave Harbour, David Boelens; David Duffy, David House; David McCaleb; David McCraine; ddonkel@cfl.rr.com; DNROG Units; Donna Ambruz; Ed Jones; Elizabeth Harball; Elowe, Kristin; Elwood Brehmer; Evan Osborne; Evans, John R (LDZX); Garrett Brown; George Pollock; Gordon Pospisil; Greeley, Destin M (DOR); Gretchen Stoddard; gspfoff, Hunter Cox; Hurst, Rona D (DNR); Hyun, James J (DNR); Jacki Rose; Jason Brune; Jdarlington oarlington@gmail.com); Jeanne McPherren; Jerry Hodgden; Jill Simek; Jim Watt; Jim White; Joe Lastufka; Joe Nicks; John Burdick; John Easton; John Larsen; John Stuart; Jon Goltz; Josef Chmielowski; Juanita Lovett; Judy Stanek, Kari Moriarty, Kasper Kowalewski; Kazeem Adegbola; Keith Torrance; Keith Wiles; Kelly Sperback; Kevin Frank; Kruse, Rebecca D (DNR); Kyla Choquette; Laura Silliphant (laura.gregersen@alaska.gov); Leslie Smith; Lori Nelson; Louisiana Cutler; Luke Keller, Marc Kovak; Mark Dalton; Mark Hanley (mark.hanley@anadarko.com); Mark Landt; Mark Wedman; Mealear Tauch; Michael Bill; Michael Calkins; Michael Moora; Mike Morgan; MJ Loveland; mkm7200; Motteram, Luke A; Mueller, Marta R (DNR); nelson; Nichole Saunders; Nick Ostrovsky; Nikki Martin; NSK Problem Well Supv; Patty Alfaro; Paul Craig; Paul Decker (paul.decker@alaska.gov); Paul Mazzolini; Pike, Kevin W (DNR); Randall Kanady; Renan Yanish; Richard Cool; Robert Brelsford; Robert Warthen; Sara Leverette; Scott Griffith; Shahla Farzan; Shannon Donnelly; Sharon Yarawsky; Skutca, Joseph E (DNR); Smart Energy Universe; Smith, Kyle S (DNR); Stephanie Klemmer; Stephen Hennigan; Sternicki, Oliver R; Steve Moothart (steve.moothart@alaska.gov); Steve Quinn; Suzanne Gibson; Tamera Sheffield; Ted Kramer; Teresa Imm; Tim Jones; Tim Mayers; Todd Durkee; Tom Maloney; trmjrl; Tyler Senden; Umekwe, Maduabuchi P (DNR); Vinnie Catalano; Well Integrity, Well Integrity; Weston Nash; Whitney Pettus; Aaron Gluzman; Aaron Sorrell; Ajibola Adeyeye; Alan Dennis; Andy Bond; Bajsarowicz, Caroline J; Bruce Williams; Bruno, Jeff J (DNR); Casey Sullivan; Corey Munk; Don Shaw; Eppie Hogan; Eric Lidji; Garrett Haag; Graham Smith; Heusser, Heather A (DNR); Holly Fair; Jamie M. Long; Jason Bergerson; Jesse Chielowski; Jim Magill; Jim Shine; Joe Longo; John Martineck; Josh Kindred; Keith Lopez; Laney Vazquez; Lois Epstein; Longan, Sara W (DNR); Marc Kuck; Marcia Hobson; Marie Steele; Matt Armstrong; Melonnie Amundson; Mike Franger; Morgan, Kirk A (DNR); Pascal Umekwe; Pat Galvin; Pete Dickinson; Peter Contreras; Rachel Davis; Richard Garrard; Richmond, Diane M; Robert Province; Ryan Daniel; Sandra Lemke; Susan Pollard; Talib Syed; Tina Grovier (tmgrovier@stoel.com); William Van Dyke Subject: AIO 21B.002 Attachments: aio21B.002.pdf Re: Docket Number: AIO 17-025 Administrative Approval to allow for a water injectivity test Kuparuk River Unit 2P-429 well (PTD 201-102) Kuparuk River Unit Meltwater Oil Pool Jody J. Colombie .AOGCC Special -Assistant .Alaska Oil and Gas Conservation Commission 333 West Tti .Avenue .Anchorage, .Alaska 99501 Office: (907) 793-1221 Fax: (907) 276-7542 CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, contains information from the Alaska Oil and Gas Conservation Commission (AOGCC), State of Alaska and is for the sole use of the intended recipient(s). It may contain confidential and/or privileged information. The unauthorized review, use or disclosure of such information may violate state or federal law. If you are an unintended recipient of this e-mail, please delete it, without first saving or forwarding it, and, so that the AOGCC is aware of the mistake in sending it to you, contact Jody Colombie at 907.793.1221 or jodv.colombie@alaska.aov. INDEXES 8 P.O. BOX 100360 ANCHORAGE, ALASKA 99510-0360 October 8, 2024 Commissioner Jessie Chmielowski Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, AK 99501 Commissioner Chmielowski, ConocoPhillips Alaska, Inc. requests the cancellation of Administrative Approval AIO 21B.001 for Kuparuk service well 2P-447 (PTD 203-154). AIO 21B.001 was approved December 15, 2015, allowing continued operation of the well with an increased OA pressure not to exceed of 1800 psi. KRU 2P-447 was recently suspended (sundry 323-609) which included setting a CIBP and dump bailing cement on top. The state witnessed tag of TOC and MIT-T to 1500 psi was completed on 8/9/2024. As such, AIO 21B.001 is no longer relevant and CPAI request that the AIO be cancelled. Please contact Jaime Bronga at 907-265-1053 if you have any questions. Sincerely, Jaime Bronga Well Integrity Specialist ConocoPhillips Alaska, Inc. Digitally signed by Jaime Bronga DN: OU=Conoco Phillips Alaska, CN=Jaime Bronga, E=jaime.bronga@conocophillips.com Reason: I am the author of this document Location: Date: 2024.10.08 14:16:05-08'00' Foxit PDF Editor Version: 13.0.0 Jaime Bronga By Samantha Coldiron at 2:25 pm, Oct 08, 2024 7 ConocoPhillips September 26, 2017 i-i'CEIVED OCT 0 2 2017 AXfJSI G4 Dan Seamount, Commissioner Cathy Foerster, Commissioner Alaska Oil and Gas Conservation Commission 333 West 7th Ave. Suite 100 Anchorage, Alaska 99501-3539 Re: Docket Number AIO 17-025 Administrative Approval to allow for a water injectivity test Kuparuk River Unit 2P-429 well (PTD 201-102) Kuparuk River Unit Meltwater Oil Pool Dear Commissioner Seamount and Commissioner Foerster, Marc Lemons Manager, GKA Base Production And Optimization Greater Kuparuk Area ConocoPhillips Alaska, Inc. ATO -1376 PO Box 100360 Anchorage AK 99510-0360 Phone (907) 265-6112 From August 22nd through September 51h a water injection test was performed at Meltwater on injector 2P- 429. CPA] wanted to test the viability of water injection at pressure below the sandface injection pressure limit. Area Injection Order 21B (AIO 21 B) currently authorizes the injection of Beaufort Sea and Kuparuk River Unit (KRU) produced water in the Meltwater Oil Pool (MOP) for surveillance, logging, near wellbore formation displacements, and well maintenance. The proposed injectivity test did not fall within the types of activity where water was already authorized so an administrative approval was necessary to carry out the work. The injectivity test was authorized by the AOGCC in accordance with Rule 10 of the AIO 21B. The following data was requested from the AOGCC within 30 days of the end of the test. 1. Injection rates and corresponding well head pressures 2. Any operational issues 3. Information on pressure responses in offset wells ConocoPhillips Marc Lemons Manager, GKA Base Production And Optimization Greater Kuparuk Area ConocoPhillips Alaska, Inc. ATO -1376 PO Box 100360 Anchorage AK 99510-0360 Phone(907)265-6112 1. Injection Rates and corresponding well head pressures The water injection test ran from 8/22/2017 through 9/5/2017. On 9/5/2017 a step rate test was performed from 7:30AM to 10:OOAM. No excursions above wellhead pressure limit set for this test (958 psi) were experienced. Overall data, colored by day Sw nv Pms m, pal, Inj.a Rm, BN D vs. Dm 900 600 700 4efe[t Gnsuv Osi i I 600 600 • • �� 6>• • C • Q O O 6 00 ( 0 O fl • C • O 300 200 ni.mo�nw. enaD 7,000 • 6,600 6,000 6,600 6,000 • 4,600 4,000 3,600 3,000 ¢Qa® C O • 0 as 20 Soo 16"�Qa O C O • • 6D as • 2.000... { • • �- • 0 • • Q 1,600 Ogg • • 1,000 p C 6/228011 6Q672017 6126/2017 6IW2017 913/!017 a.a p Ino nrw exp cme, h Dµ eIN'tNlDnt, �An � Nm • *w e, o� ConocoPhillips Step Rate test data on 9/5/2017 9urfx Pressure, psi, Opeotlon Rab, swan vs. sass 900 860 800 760 700 650 600 550 600 7,000 6,600 6,000 5,600 5,000 4,500 4,000 3,600 3,000 2,600 2,000 1,500 • Hopm 7:30 AM 7:60 AM 8:10 AM 2. Any operational issues Marc Lemons Manager, GKA Base Production And Optimization Greater Kuparuk Area ConocoPhillips Alaska, Inc. ATO -1376 PO Box 100360 Anchorage AK 99510-0360 Phone (907) 265-6112 s,mcsn.ss,rs. ssl ammonium In�lC4an R., BWW 8:30 AM 8:60 AM 9:10AM 9:60AM 9:30 AM Date Trxra ey mover M (RcrxwnMl D., oey arweexioxe) 4/ Tue There were no operational issues related to being able to inject water into the Meltwater reservoir below the maximum allowable surface pressure. Injection rate was varied at the beginning of the test while work was performed to confirm the accuracy of the injection rate metering. Five days after the start of the test, the pump unit was shut down for 17 hours to repair a mechanical failure. ConocoPhillips Marc Lemons Manager, GKA Base Production And Optimization Greater Kuparuk Area ConocoPhillips Alaska, Inc. ATO -1376 PO Box 100360 Anchorage AK 99510-0360 Phone (907) 265-6112 3. Information on pressure responses in offset wells Pressure gauges were hung in the injecting well 2P-429, an offset producer 2P -422A, and an offset injector 2P-434. The offset injector had been SI for two years prior to the gauge being set, the offset producer was SI when the gauge was set. Both offset wells remained SI until the test was complete and all gauges were pulled. The variation in the BHP data for 2P-429 is because the pump was shut down every 12 hours to check the oil on the pump driver. Data is collected in the gauges every 10 seconds. w.9 2.000 t 900 1 800 1.698 1 597 1496 +..396 1 295 1 194 1093 993 892 &82017 8798017 812/2017 81152017 8118/2017 8212017 8242017 8272017 81302017 922017 D.. If you have any questions concerning this data, please contact me at 265-6112. Marc Lemons Manager, GKA Base Production and Optimization Greater Kuparuk Area W�,tN 3.090 ua.6mw. 3.000 M,L �MV1 2.964 •res 2,9664 •mu. 2.927 2.927 2.891 2,891 2655 2.855 2.818 2.818 2,782 2.782 2.745 2 745 2.709 2 709 2.673 2.673 2636 2.636 2,600 2 600 Roby, David S (DOA) From: Angel, Vanessa M <Vanessa.M.Angel@conocophillips.com> Sent: Thursday, August 03, 2017 9:58 AM To: Roby, David S (DOA) Cc: Jolley, Liz C Subject: Meltwater water injection Hello Dave, Per our conversation I just wanted to note that for the 2P-429 WI test, the sundry says we will not exceed 958psi surface pressure with water. 1 just wanted to clarify that to take the well from gas injection to water injection we will need to pump 1 tubing volume of water at a higher pressure. 2P-429 is currently injecting gas at 2200 psi, so we need our pump rate to start at 2200 psi to overcome that pressure and get water into the well, then we can decrease over time. Once approximately 1 tubing volume is in place, we will stay at our expected pressure of 930 psi, within the do not exceed pressure of 958 psi. Thanks, Vanessa STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION APPLICATION FOR SUNDRY APPROVALS 20 AAC 25.280 AUG 01 2017 G oC 1. Type of Request: Abandon ❑ Plug Perforations ❑ Fracture Stimulate ❑ Repair Well ❑ Operations shutdown❑ Suspend ❑ Perforate ❑ Other Stimulate ❑ Pull Tubing ❑ Change Approved Program❑ Plug for Redrill ❑ Perforate New Pool ❑ Re-enter Susp Well ❑ Alter Casing ❑ Other: Water Inj Test 2. Operator Name: 4. Current Well Class: 5. Permit to Drill Number: COnocoPhilll sAlaska Inc. Exploratory ❑ Development C' Stratigraphic El Service 201-102 3. Address: 6. API Number: P. O. Box 100360, Anchorage, Alaska 99510 50-103-20378-00 7. If perforating: 8. Well Name and Number: What Regulation or Conservation Order governs well spacing in this pool? N/A KRU 2P-429 Will planned perforations require a spacing exception? Yes ❑ No El 9. Property Designation (Lease Number): 10. Field/Pool(s): ADL 389058 ftl Kuparuk River Field / Meltwater Oil Pool 11. PRESENT WELL CONDITION SUMMARY Total Depth MD (ft): Total Depth TVD (ft): Effective Depth MD: Effective Depth TVD: MPSP (psi): Plugs (MD): Junk (MD): 8,974' 6,002' 8505 5738 958 NONE 8900 Casing Length Size MD TVD Burst Collapse Conductor 82' 16" 110, 110, Surface 2,936' 9 5/8 2,965' 2,434' Production 8,941' 7" 8,966' 5,997' Liner Perforation Depth MD (ft): Perforation Depth TVD (ft): Tubing Size: Tubing Grade: Tubing MD (ft): 8176 - 8505 5549 - 5738 4.500" L-80 7,617' Packers and SSSV Type: Packers and SSSV MD (ft) and TVD (ft): PACKER - NONE N/A SSSV: - A-1 INJECTION VALVE on 3.875" DB Lock w.80 BEAN 517.5 MD and 517.3 TVD 12. Attachments: Proposal Summary ❑ Wellbore schematic ❑ 13. Well Class after proposed work: Detailed Operations Program ❑ BOP Sketch ❑ Exploratory ❑ Stratigraphic ❑ Development Service bCI 14. Estimated Date for 8/15/2017 15. Well Status after proposed work: Commencing Operations: OIL ❑ WINJ ❑ WDSPL ❑ Suspended ❑ GAS ❑ WAG ElGSTOR ElSPLUG ElCommission 16. Verbal Approval: Date: Representative: GINJ El Op Shutdown ❑ Abandoned El 17. 1 hereby certify that the foregoing is true and the procedure approved herein will not be deviated from without prior written approval. Authorized Name: Vanessa Angel Contact Name: Vanessa Angel Authorized Title: Senior Petroleum Engineer Contact Email: Vanessa.M.Angel@conocophillips.com Contact Phone: (907) 265-1018 Authorized Signature: Date: 26 COMMISSION USE ONLY Conditions of approval: Notify Commission so that a representative may witness Sundry Number: Plug Integrity ❑ BOP Test ❑ Mechanical Integrity Test ❑ Location Clearance ❑ Other: Post Initial Injection MIT Req'd? Yes ❑ No ❑ Spacing Exception Required? Yes ❑ No d Subsequent Form Required: APPROVED BY Approved by: COMMISSIONER THE COMMISSION Date: Submit Form and Form 10-403 Revised 4/2017 n t i PiP_icpA r a o F pp valid for 12 months from the date of approval. Attachments in Duplicate t ) 2P-429 Water Injection Test DATE: 07/25/17 ObiectiveBackground Meltwater (2P) area has been on gas injection only since 2009. A water injection test into 2P-429 will enable data to be gathered on the water injection capability at the low maximum surface injection pressure of 958 psi. Meltwater online producers will also be monitored for changes in performance which may occur during the injection test period. The results of the test will be used to analyze whether long term water injection at —950 psi maximum surface pressure is economically feasible at Meltwater. Downhole pressure will be gathered utilizing memory gauges from two wells with bottom hole locations near 2P-429, before, during, and after the injection testing. Memory gauges will be run approximately two weeks before the start of the injection test into injectors 2P-429 and 2P-434 (LTSI injector) and low rate producer 2P-422A. Producer 2P-422 (-50 BOPD) will be SI and a downhole memory gauge will be run into the well at least two weeks prior to the start of the injection test. Injectors 2P-427 and 2P-432 will also be shut in just prior to the beginning of the injection test and remain shut in for the duration of the test. The intended start date for beginning injection into 2P-429 is 08/15/17 and a 2-week duration is planned. CPF2 produced water as the injection fluid during the test; the produced will trucked to 2P and a pump truck will be used to inject the water. A drawing showing the approximate location of all equipment is attached to this procedure. Items to Note: The absolute surface pressure limit of 958 psi is based on a maximum reservoir sandface injection pressure of 3400 PSI at the top of the perfed sand in the 2P-429 well. Below that depth, the higher hydrostatic gradient will increase above 3400 psi. This is the current interpretation of the AIO injection pressure limit. 2P-429 MITIA to 3300 psi passed 8/20/2016. Expected Well Test Duration: • 2 weeks Anticipated Initial Injection Rate and pressure: • 4000 BWPD • 930 psi maximum wellhead injection pressure Annulus Monitoring: • DSO to Monitor Annulus Pressures: • 2400 psi on the IA • 1000 psi on the OA. Be aware of the potential for increase in pressure due to thermal expansion. • Well Integrity Status is NORMAL, no ANNCOMM issues. 115 aivzoi7 2P-429 Water Injection Test Safety: • Ensure that the on -tour pump operator can be reached by field radio at all times. • Follow all contractor company SOPS and the ASH handbook. • Keep non -intrinsically safe devices such as cell phones out of classified areas such as the wellhouse and modules on the 2P pad. • Ensure all equipment and tanks are electrically grounded. • Report any Accidents, Spills, or Near -Misses to supervisor immediately. • H2S should not be present but every worker must wear a H2S monitor within 9" of the mouth at all times when on the job site. • The pump operator will neither operate nor defeat wellhead safety systems except to shut in the well in an emergency situation via wellhead safety system(s). • A pre job safety walk through will be conducted after connection to the Kuparuk piping or live process prior to pumping operation being initiated. This pre job walkdown should include the DS Lead, DSO, CPA Safety Specialist, CPA Production Engineer, CPA DS Facility Engineer and the pump operator. • Any significant change in from this procedure during the execution of the job, including use of different metering or a different pump, during the job set up will be reviewed and approved by the 2P DSO (radio call number, 233) and the Production Engineer. Injection Procedure: 1) Prior to starting injection CPF2 Instrument Techs will install a Panemetrics flow meter and pressure gauge (with wireless transmitters) on the piping downstream of the pump discharge: 2) Prior to starting injection, the Production Engineer will verify that correct changes in IP21 to convert the well from GI to WI service for 2P-429 in IP21 have been completed and that the wireless transmitters for the Panemetrics flow meter and pressure gauge have been added to IP21. 3) Tanker trucks will take on water at the CPF2 PWI truck loading facility (or possibly a temporary truck loading station set up at 2N) and haul the water to a 4-tank battery on site in front of 2P-429. 4) Initiate water injection into 2P-429 ramping up to 4000 bwpd at a well head injection pressure of no more than 930 psi. DSO to verify the Panemetrics flow meter and pressure gauge and wireless transmitters are functioning properly. 5) Immediately notify the CPF2 PE should any significant changes to injection pressure and/or rate occur to the well during the injection test. 6) Objective is two weeks of continuous injection into 2P-429. Short term interruptions in injection into the well due to problems with truck delivery of water or pump maintenance, for example, will not cause the test to be ended prior to the planned two -week duration nor is it likely to be extended. 7) DSO and Production Engineer to obtain frequent well tests on producers most likely to interact directly with 2P-429. 8) DSO to monitor IA and OA pressures on all Meltwater wells while paying close attention to those most likely to interact with 2P-429. 2/5 sn/2017 *a.- 420 i9k$9Ca 2P-429 Water Injection Test . �i f f , QUA i fIS�dBs.SYA %n W3 ..:...,.max.......• -...a+:... f ..+... :.... �,...k.:...»»..+«.+:... �A .,�.......,..,....-. �i: 3/5 8/l/2017 2P-429 Water Injection Test CAUTION THIS DRILL SITE IS TO BE CONSIDERED AN H25 AREA. .:d FEATURE LOCATIONS LEGEND �- OLEAN SHOP! DUMP AREA, ALL EQUIPMENT; - ENMA0wCNTAL AREA -NO SHOW DUMP=l I — POKALINE—RtAICH MEARANCEIt, SLOWERS MAY NIT- LINES WITH OfSCRAINZ — SNOTS DLOWNS AREA OF&Y. NO Show DUNIPING AREA. ® RESCUE EQUIPMENT SODA LOCATIONS I'-1-1 DESIGNATED SM AREA (PRIMARY} LI DESIGNATED SAFE AREA (SEOMDARY) EYACUATYON ROUTES DEKNOINC ON INNO ti WINDSOCK DARRICADE/ESCAPE ROUTE FIRE EMINOUISNER NOTE: Nil SNOW IS TO BE PLACED IN ANY RESERVE PIT OR LINED PIT. Keep 5' clearance from all flowllnes due to high voltage electrical lines. If you need to get closer, contact R&P:7"6. LEGEND # DOSTRIG PRODUCER . EMSTM INJECTOR O NEW PRODUrm n NEW INJECTOR . Q OORYMIED FROM PAODUCEN TO IMECTER Ill EEISRNB ODDUGIOR ¢,! k7WNiD1?a!Y CNAume • wvo�n vpJ s®allosl� unoE hiltips AREA:2P MODULEXXXX UNIT: D2 3 5 1 Add Thermosi hens Per )C10002iACS R JEC �� O52P FACILITY EXPANSION I)aHatMA dlk—v I --A b P-+,I, Par I(ARNRQSAM .FC R �`� 02/20/02 LKS21GEt FEATURE LOCATION 4/5 8/1/2017 e • e." s sWIF ConocoPhillips ; KUP INJ 2P-429 Well Atir bates Max Angle AM TD Welihore APW WI Field Name Welibore Status ncl (°) MD (ftKB) Act Btm (ftKB) 501032037800 MELTWATER INJ 56.09 8,902.56 8,974.0 Comment H2S (ppm) Date Annotation End Date KB-Grd (ft) Rig Release Date SSSV: NIPPLE Last W0: 33.91 12/20/2001 Annotation Depth (ftKB) Entl Date Annotation Last Mod By Entl Date Last Tag: SLM 7,849.0 2I9/2015 Rev Reason: GLV C/O, Pull plug/catcher, Tag, INJ VLV, Fish hipshkf 5I7I2015 Set 96 Casing Description OD (in) ID 9n) Top (ftKB) Set Depth (ftKB) Set Depth (TVD)... WtlLen (1... Grade Top Thread CONDUCTOR 16 15.062 28.0 110.0 110.0 WELDED Casing Description OD (in) ID (in) Top (ftKB) Set Depth (ftKB) Set Depth (TVD)... Will... (I... Grade Top Thread SURFACE 9 5/8Will...8,835 28.6 2,965.0 2.434.3 40.00 L-80 BTCM Casing Description OD (in) ID (in) Top (ftKB) Set Depth (ftKB) Set Depth (TVD)... WtlLen (I... Grade Top Thread PRODUCTION 7"x4.5" 7 6.276 25.5 8,966.4 5,997.3 26.00 L-80 BTCM 01638' < Tiub�Dg ��s Tubing Description String Ma... ID (in) Top (ftKB) Set Depth (7f Set Depth (TVD) (.-.. Wt (Ibtft) G.de Top Connection TUBING 4112 3.958 23.2 7,617.0 5,219.2 12.60 L-80 IBTM Corr000n `Details:; Nominal ID Top (ftKB) Top (TVD) (ftKB) Top Intl (°) Item Des Core (in) 23.2 23.21 0.00 HANGER FMC TUBING HANGER 4,500 517.5 517.31 4.40 NIPPLE CAMCO DB LANDING NIPPLE 3.875 7,550.0 5,179.01 53.28 SLEEVE BAKER CMU SLIDING SLEEVE w1OTIS'X' PROFILE 3.812 7,570.6 5,191.41 53.15 NIPPLE CAMCO DB-6 NIPPLE 3,750 7,614.1 5,217.51 52.88 SEAL BAKER G-22 LOCATOR 8 SEAL ASSY 3.875 --OUIeTlq,HDle:.. !£171 'ie reti'ie3ai>>e Pa9ss Ya 11ii1175,.1Sti+;etG.) ' Top (ftKB) Top (TVD) Top (ftKB) (°) Intl Des Core Run Date to (in) 517.5 517.3 4.40 VALVE 4.5" A-1 INJECTION VALVE ON 3.875" DB LOCK 5/4/2015 0.800 1 w.80 BEAN (S/N: HRS-51) 8,900.0 5,960.31 56.09 FISH 17" x 1-11/16" ELINE SPINNER 4/27/2015 0.000 Shot" Dens Top(TVD) Btm(TVD) (shots/ Top (ftKB) Bt. (ftKB) (ftKB) (ftKB) Zone Date to Type Corn 8,176.0 8,240.0 5,549.5 5,586.3 T-3, 2P-429 1/1412002 6.0 IPERF 2.5" HSC, 2506 Power jet HMX Chgs, 60 deg phase 8,300.0 8,325.0 5,620.8 5,635.2 T-3, 2P-429 1/14/2002 6.0 IPERF 2.5" HSC, 2506 Power jet HMX Chgs, 60 deg phase 8,325.0 8,350.0 5,635.2 5,649.5 T-3, 2P-429 1/1312002 6.0 IPERF 2.5" HSC, 2506 Power . jet HMX Chgs, 60 deg phase 8,386.0 8,411.0 5,670.2 5,684.5 T-3, 2P429 1/1312002 6.0 IPERF 2.5" HSC, 2506 Power jet HMX Chgs, 60 deg phase 8,411.0 8,435.0 5,684.5 5,698.2 T-3, 2RA29 1/13/2002 6.0 IPERF 2.5" HSC, 2506 Power jet HMX Chgs, 60 deg phase 8,495.0 8,505.0 5,732.5 5,738.1 T-3, 2P-429 1113/2002 6.0 IPERF 2.5" HSC, 2506 Power jet HMX Chgs, 60 deg phase Mandrel inserts St all on (TVD) Valve Latch Port Size TRORun Top (fDCB) (ftKB) Make Model OD(in) -am Type Type (in) (psi) Run Date Co. 1 7,50 .21 5,149.3 1 CAMCO KBG-2 1 GAS LIFT DMY BTM 0.000 0.0 12t8r2015 Alotes; Genera] 8.5a%iy End Date Annotation 7/28/2009 NOTE: OBSTRUCTION (78417) IS 100T HIGHER THAN 1/1812007 TAG (8859') 11/2272010 NOTE: VIEW SCHEMATIC w/Alaska Schematic9.0 4/27/2015 NOTE: 17" x 1-11/16" ELINE SPINNER LEFT IN HOLE 0 0 • Wallace, Chris D (DOA) From: Wallace, Chris D (DOA) Sent: Saturday, October 10, 2015 10:52 PM To: NSK Problem Well Supv Subject: RE: Request to allow Meltwater injector 2P-447 (PTD 203-154 AIO 21A.006) and producer 2P-431 (PTD 202-053 AIO 21A.002 Amended) to remain online 10-10-15 Kelly, AIO 21 B did cancel the old orders but it was not our intent to change the current operation of the wells. Please get back with me within the mentioned 14 days with the criteria that you see in conflict and we will work this out. Thanks Chris -------- Original message -------- From: NSK Problem Well Supv <n I 617@conocophillips.com> Date: 10/10/2015 2:20 PM (GMT-09:00) To: "Wallace, Chris D (DOA)" <chris.wallace(&alaska.gov> Subject: Request to allow Meltwater injector 2P-447 (PTD 203-154 AIO 21A.006) and producer 2P-431 (PTD 202-053 AIO 21 A.002 Amended) to remain online 10-10-15 Chris, The AA's of two Meltwater wells, injector 213-447 (PTD 203-154 NO 21A.006) and producer 213-431 (PTD 202-053 NO 21A.002 Amended), expired when the new Meltwater Area Injection Order AIO 21B was issued on 10/08/15. CPAI requests that these wells be allowed to remain on line while new applications are assessed and submitted if deemed appropriate. The wells will be operated as set out in their expired AA's for a period not to exceed 14 days. Brent Rogers / Kelly Lyons Problem Wells Supervisor ConocoPhillips Alaska, Inc Desk Phone (907) 659-7224 Pager (907) 659-7000 pgr 909 • ONES lh Conocoillips Alaska July 16th, �Pw X0 I,S C Dt—J JUL 16 2015 I� Commissioners Cathy Foerster and Daniel Seamount Alaska Oil & Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, AK 99501 RE: Request to Amend Area Injection Order No. 21A, Meltwater Oil Pool Greater Kuparuk Area North Slope, Alaska Dear Commissioners: Kazeem Adegbola Manager, GKA Development Greater Kuparuk Area P. O. Box 100360 Anchorage, AK 99510-0360 Phone: 907-263-4027 On july 91h,.391-4fe Alaska Oil and Gas Conservation Commission ("Commission or AOGCC") held a public hearing concerning ConocoPhillips Alaska, Inc.'s ("ConocoPhillips") Request to Amend Area Injection Order No. 21A ("AIO 21A"). ConocoPhillips submits this letter to supplement the record presented to the Commissioners and provides the following responses to the Commissioners' questions asked during the public hearing. Source of Gas Present in the Overburden A Meltwater Field Outer Annulus Gas Analysis was performed in 2012 by the ConocoPhillips Technology Group in Houston. It was determined that the shallow intervals above the Bermuda reservoir at discovery contained dominantly dry biogenic gas (high C1 content and highly negative carbon isotopes) while the gasses associated with the Bermuda reservoir were dominantly thermogenic gas with a small volume of more negative biogenic gas (methane). The Meltwater N2 (discovery well) and Meltwater N1 and N2A (delineation wells) mud logs show that at discovery numerous gas shows were present in the overburden below the base of the Permafrost. These shallow gasses tended to have biogenic dry methane or a mix of biogenic methane and thermogenic gas. Based upon the mud logs from the Meltwater N2 discovery well and the N1 and N2A delineation wells, there was no presence of butanes (C4), pentanes (C5), hexanes (C6), or heptanes (C7) in the overburden 200' above the Bermuda reservoir. Miscible injectant (MI) contains measurable amounts of C4-C7. The MI contains gas from the Prudhoe Bay Field that is isotopically more positive (more mature) and thus distinguishable from the Meltwater gas • ! Commissioners Foerster and Seamount July 16, 2015 Page 2 accumulations. Therefore, gas composition analyses have been used at Meltwater to determine the presence of reservoir fluids in the outer annuli. Since 2012, no well has exhibited an increasing similarity to MI. No gas has been encountered from the surface to base Permafrost interval while drilling any Meltwater exploration, delineation, or development well. The Permafrost appears to act as a barrier to natural migration of gas from the overburden below. Vertical Extent of the Linear Features In response to the Commissions' questions regarding the vertical extent of the linear features, please see slides and transcript from the confidential presentation presented by Eric Bressler to the AOGCC on November 14t", 2012. See confidential transcript, line 22 on page 57 through line 1 on page 58 when referring to slide 3 of the confidential presentation. See line 14 on page 59 through line 11 on page 60 of the confidential transcript when referring to slides 6-7 of the confidential presentation. Seismic Resolution The resolution of the 1998 and 2008 seismic data sets varies with depth. This is primarily because fold and frequency are different with depth. Fold is a measure of the redundancy of common midpoint seismic data, equal to the number of offset receivers that record a given data point or in a given bin and are added during stacking to produce a single trace. Generally, higher fold produces better resolution and the Meltwater 3D fold varies from 3 fold around 1000 feet TVDSS to 57 fold around 6000 feet TVDSS. The dominant frequency of the Meltwater 3D datasets range from 34 Hz shallow to 29 Hz deeper. Tuning Thickness is the thinnest interval over which a correct measurement of the distance between two closely spaced reflectors can be made. At the Bermuda reservoir depth, tuning thickness is estimated to about 87 feet. Surface Faults ConocoPhillips Alaska is not aware of any surface or subsurface data that suggests the presence of faults at the surface. Commissioners Foerster and Seamount July 16, 2015 Page 3 Determination of Presence of Shallow Gas with Seismic Seismic evaluations are used to determine if shallow gas is present in a predictive manner and can be useful to qualitatively assess the presence of shallow gas. Seismic data was analyzed as part of the exploration drilling permit issued by AOGCC for well Meltwater N2. A review of that analysis shows seismic data did not indicate the presence of shallow hazards. If a rotary well was to be drilled at Meltwater in the future, ConocoPhillips would complete a shallow gas hazard assessment as part of the AOGCC drilling permitting process, an area review, and the ConocoPhillips Well Design and Delivery Process. Area Injection Order Sunset Clause ConocoPhillips believes that a period of 10 years between Area Injection Order renewals is appropriate for NO 21A. This recommended period of 10 years is predicated upon the cycle time to design and complete development initiatives and to evaluate the field performance data. Area Review as Part of the Drilling Permitting Process at Meltwater ConocoPhillips does not object to completing an area review as part of its Well Design and Delivery Process and ConocoPhillips would submit the results of such area review to the AOGCC with its application for a permit to drill. Meltwater Outer Annulus Pressure Review The charts within Attachment 1 depict the outer annulus (OA) pressure for each Meltwater well from January 15t, 2010 through July 13th, 2015. This range was chosen as it spans the time period before and after the sand face injection pressure limit was set for Meltwater injectors. As of July 13th, 2015, no well at Meltwater, shut-in or active, had an OA pressure above the 1,000 psig limit set forth in Rule 3 of AIO 21A. The trends of the individual wells over the time span specified can be classified into four categories: • Decrease in OA Pressure: 0 2P-406(p) 0 2P-417(p) 0 2P-420(i) 0 2P-431(p) 0 2P-432(p) 0 2P-438(p) • I—] Commissioners Foerster and Seamount July 16, 2015 Page 4 0 2P-441(p) 0 2P-448A(p) 0 2P-451(p) • No Appreciable Change in OA Pressure 0 2P-415A(p) 0 2P-422A(p) 0 2P-427(i) 0 2P-443(p) 0 2P-449(p) • Recent Increase in OA Pressure Attributable to Thermal Effects 0 2P-419(i) 0 2P-429(i) 0 2P-434(i) 0 2P-447(i) • Increase in OA Pressure o 2P-424A(p) From the time at which the sand face injection pressure limit was set in 2012 until 2014 only three injectors were active, 2P-420, 2P-427, and 2P-429. When the reservoir pressure decreased below the sand face injection pressure limit at 2P-419 and 213-447 in 2014, the two injectors were returned to service. Upon completion of well work and pressure transient analysis in 2014 injector 213-434 was returned to service. When these three injectors (213-419, 2P-434, and 2P-447) were returned to service they realized an increase in their outer annulus pressure that can be attributed to thermal effects from the increase in thermal energy input from the injection gas. In addition, injector 213-429, after a period of intermittent injection, was brought online at a higher rate as the reservoir pressure had decreased substantially. This increased injection rate resulted in an increase in OA pressure that can be attributed to thermal effects from the increase in injection rate. Charts for each of these four wells (213-419, 213-429, 2P-434, and 2P-447) with their associated injection rates are depicted in Attachment 2. Well 2P-424A, although below the 1,000 psi OA pressure limit, has seen a gradual increase in outer annulus pressure over the 2010-2015 time period. This increase in OA pressure cannot be attributed to thermal effects, nor can it be attributed to annular communication. Please refer to Attachment 3 for a chart of well 2P-424A's outer annulus pressure and production rates. Further investigation was done into well 213-424A to determine if there were signs of migration of injected fluids out of zone. The findings from this investigation are summarized below: • Biogenic gas is native to the Meltwater overburden. Miscible injectant, that has been injected into the Bermuda interval, has a significantly different isotopic signature for Commissioners Foerster and Seamount July 16, 2015 Page 5 methane and ethane. The isotopic analyses of the gas collected from the 2P-424A outer annulus in 2012 indicated it was entirely biogenic in nature. • Outer annulus gas composition analyses were conducted to determine if NGLs, that are combined with methane and ethane to create MI, were present. Biogenic gas in the Meltwater overburden does not contain appreciable quantities of NGLs. The results of these analyses do not indicate the presence of NGLs in the outer annulus gas. Please refer to Attachment 3 for a chart showing these outer annulus gas composition analyses. • The outer annulus pressure has been bled down to assess the recharge rate. It has been determined that the recharge rate is approximately 15 psi/day and that the pressure levels off and is currently stable at approximately 750 psig. This 750 psig pressure is well below the outer annulus pressure limit of 1,000 psig. From the further investigation summarized above, there is no evidence that well 2P-424A's outer annulus is in communication with fluids that were injected into the Bermuda interval. Well 2P- 424A's outer annulus pressure, gas composition, recharge rate, and annular integrity will continue to be monitored for signs of migration of injected fluids out of zone. Potential Meltwater Field Incremental Recovery By pursuing well conversions and Coiled Tubing Drilling sidetracks at Meltwater an estimated incremental 2-7 MMSTB of gross resource may be produced. Well Schematics ConocoPhillips has not yet begun the well design process for future development wells at Meltwater. ConocoPhillips would submit a schematic with any permit to drill application after completion of an area review and the Well Design and Delivery Process. Coiled Tubing Drilling (CTD) wells would be drilled and completed within the Bermuda reservoir. An example of a typical CTD well for the Kuparuk reservoir is attached within Attachment 4. Location of 2P Pad The location of the 2P pad was based upon Phillips Alaska's understanding of the Meltwater subsurface accumulation as well as surface topography, habitat value, and other factors. The pad was oriented to minimize snow accumulation on the site. Commissioners Foerster and Seamount July 16, 2015 Page 6 Conclusions ConocoPhillips is confident that the requested amendments are based on sound engineering and geoscience principles, will further mitigate the risk of the migration of injected fluids out of the Meltwater Oil Pool, will increase ultimate hydrocarbon recovery, will not promote waste or jeopardize correlative rights, and will not result in an increased risk of fluid movement into freshwater. We are confident that with these changes, ConocoPhillips can continue to operate in a safe and efficient manner at Meltwater. Sincerely, Kazeem Adegbola Manager, GKA Development Attachments 0 t • Commissioners Foerster and Seamount July 16, 2015 Page 7 Attachment 1: Meltwater OA Pressures 2 P-4Q6 taco zaoo � zaoc A uoo a too q EAo o ado zoo —2o.40s 2P-415A ISO I" B = iaoc Iv aco N N Vw 200 0 - 9 4 b P y —2lxdiiA Ol • Commissioners Foerster and Seamount July 16, 2015 Page 8 2 P-417 i®00 1400 3 1200 A 1000 a i00 Vi M d am 4W 200 Q 11 2P-4Y! 2P-419 1mi0 140D g um 1000 ■ am i GM 400 200 0 -- - �� ,titi 7� ,y'i .�A ♦y 1� 2P 419 Commissioners Foerster and Seamount July 16, 2015 Page 9 2P-420 IWO 1400 i20p A Iwo I o am NM 5M 4W 200 2 P-42p 2 P-422A Iwo 140p �UM low ;p am ew 40Ci 200 Lf 0 J,�ct ��r� y0tA �,,cr e Il �2P.422A 0 • Commissioners Foerster and Seamount July 16, 2015 Page 10 2P-424A Iwo troo 1200 g two a mo 6M ,00 ton 1/ 0'� 1 � 140' —2a-a2a 2P-427 teoo taoo .Wy tam tM0 3a a0 n Q am U 4W 2m rTrrT 0, 1 1 1 1 1 1 o ti ti s � u — 2;: 27 0 0 Commissioners Foerster and Seamount July 16, 2015 Page 11 2P-429 law 1400 Iwo g low mam h 4M 203 8 '14 i~ 1'i' 1^3 14' tih ,40 —2�t2D 2P-431 14W 1D0 i200 vlli MW L00 j� GM �+ 4W 2C0 0 ,y0 4� 41 ,ti3 ,�A 'ti'7 "rho -2P 491 0 • Commissioners Foerster and Seamount July 16, 2015 Page 12 2P-432 Iwo 1400 �MO 1000 am GM 200 0 —2P-432 2P-434 I-Aw 14M .W, 1100 vu' 1000 a �0 60D 400 200 0 —2?.4i4 Commissioners Foerster and Seamount July 16, 2015 Page 13 2P-438 Iwo I" I200 � IODD a a0 M 6w a4o 200 0 NO N ,�l� J il il il —2W4S8 2P-"I law 1400 I200 Iwo sow ew 20D 0 hit? —2PdA1 • • Commissioners Foerster and Seamount July 16, 2015 Page 14 2 P-"3 ,two 14M 1200 g 1000 a a0 a 600 400 200 0 10 ti� �N Nq —2P-A43 2P-"7 IWO MW 1200 IWD a �0 sao 4W 200 0 Jsc�' �cr o� ,1ci Jai s'c1 �ac� 2Ad47 • : * Commissioners Foerster and Seamount July 16, 2015 Page 15 2P-"SA Iwo 1400 1000 mas CL oo o. s 4W 2.W 0 1d 'f4 S'1' 'tip 'tit 1� ti�O ,y(i ySY CY ,�Ck � CS gCY 2P-"9 ieoo uoo laoo �nw. m aw M aw 400 200 0 ti4 NN yi 43 titr tih kb �3�z ace tiD� ,ace �aci �9tx ,gcK �2P.449 • • Commissioners Foerster and Seamount July 16, 2015 Page 16 2P-451 1600 1400 12W g 1000 m a0 a 60D 4M 200 0 ,�9 titi .ti'L .% -2P-d31 • • Commissioners Foerster and Seamount July 16, 2015 Page 17 Attachment 2: Recent Increase in OA Pressure Due to Thermal Effects 2P-419 3ROo 30000 1400 9fl00 _ s= 3200 ii 70DO 3000 b004 aw 5000 {i IL800 4dDO p 4O0 F 3000 ; 2000 C 200 30J0 0 0 ---2P.t3!-InjaKtion Rats 2P-429 3600 25000 1400 # _ p 1200 { 20000 i .� i000 i 3S000 O � am lam C� Q�GM SODO C 200 4d �'b tib 411 144 q13 y�� --2P•429 ---lnjectias Rate 0 • Commissioners Foerster and Seamount July 16, 2015 Page 18 2P-434 Iwo , ls= 1400 13000 .... 1200 , 13000 1000 soon a .r 7W a� 6W ` sago 40o 3000 G 200 100o i 0 1000 —2P.434 —Injection RAC! ZP-447 16001, IS= ' 3400 13000 +�+ 1200 } 13000 .a low 9000 am 7000 �1 670 ! S000 4� V 400 ! 3000 200 1000 0 _I 11 _ _. -lox ���2PA47—Ing4ctionW_ Commissioners Foerster and Seamount July 16, 2015 Page 19 Attachment 3: Review of Well with an Increase in OA Pressure 2P-424A ICU Ixr soya j 4M A a SM 300 Q. 20D 400 N Iao 200 3$so —i;'-MA —Ca RM —W,1!R e 3 2 I - 0 2P-424A OA Gas Compositon U C . z••ctar� �,+stuzou w 2*stcs. s?a�.'2033 z►.ss� sott�aoai _• 2src3c6 at/2�nOae � E'.�ye-.e 6ss Cd+epo sR:ad+ Commissioners Foerster and Seamount July 16, 2015 Page 20 Attachment 4: Typical Kuparuk Coiled Tubing Drilling Well Schematic Typical Kuparuk CTD Sidetrack In Blue conductor S�xface Gsir� of A3ands of A -sands This is a typical Kuparuk A -sand CTD Completion. Depending on the results of the Well Design and Delivery Process, a potential Meltwater CTD well schematic may be different 46 0 1 ALASKA OIL AND GAS CONSERVATION COMMISSION 2 3 Before Commissioners: Cathy Foerster, Chair 4 Daniel T. Seamount 5 6 In the matter of proposed modifications ) 7 to Area Injection Order AIO 21A. ) 8 ) 9 10 ALASKA OIL and GAS CONSERVATION COMMISSION 11 Anchorage, Alaska 12 13 July 9, 2015 14 9:00 o'clock a.m. 15 16 PUBLIC HEARING 17 18 BEFORE: Cathy Foerster, Chair 19 Daniel T. Seamount, Commissioner 0 0 1 TABLE OF CONTENTS 2 Opening remarks by Chair Foerster 03 3 Comments by Mr. Nenahlo 08 4 Comments by Mr. Wentz 24 5 Comments by Mr. Bressler 27 6 Comments by Mr. Kanady 65 7 Comments by Mr. Starck 82 Pj 1 P R O C E E D I N G S 2 (Anchorage, Alaska - July 9, 2015) 3 (On record - 9:01 a.m.) 4 CHAIR FOERSTER: I'll call this hearing to 5 order. Today is July 9th, 2015, it's 9:01 a.m. We're 6 in the offices of the Alaska Oil and Gas Conservation 7 Commission located at 333 West Seventh Avenue, 8 Anchorage, Alaska. To my left is Commissioner Dan 9 Seamount, I'm Cathy Foerster. 10 Today we're having a hearing regarding docket 11 number AIO 15-015, Kuparuk River field, Meltwater oil 12 pool amendment to area injection order 21A. 13 ConocoPhillips Alaska, Inc., has requested 14 modifications to the existing area injection order 21A 15 for the enhanced oil recovery operations in a letter 16 dated February -- I mean, April 14th, 2015. Also by 17 letter dated May 6, 2015 ConocoPhillips Alaska, Inc., 18 requested administrative approval to extend the 19 expiration date contained in rule 11 of area injection 20 order AIO 21A, amended by six months. In accordance 21 with rule 10 of AIO 21A amended, the AOGCC granted 22 Conoco's request for administrative approval to extend 23 the expiration date contained in rule 11 of AIO 21A 24 amended by six months. AIO 21A amended was scheduled 25 to expire on May 16th, 2015 and in order not to 3 1 interrupt operations before the AOGCC could hold the 2 scheduled hearing today we issued an order on Conoco's 3 request extending the expiration date contained in rule 4 11 of AIO 21A amended. That administrative approval 5 was granted on May 6 of 2015. 6 Sorry for all that, but I felt like background 7 was necessary for the record. 8 AOGCC is now taking this opportunity to update 9 the order and rules to reflect current operating 10 practices as well as latest regulatory requirements and 11 conditions. 12 Computer Matrix will be recording today's 13 proceedings. Anyone interested can get a copy of the 14 transcript from Computer Matrix Reporting. 15 We'd like to remind those testifying to speak 16 into the microphone. We've updated our microphones so 17 you don't have to try to speak into two separate 18 microphones simultaneously, either one will suffice, 19 but speaking into either is necessary so that the court 20 reporter can capture your testimony and so that people 21 in the back of the room can hear what you're saying. 22 We'll also ask you as you speak to slides reference the 23 slides, in other words instead of saying as you can see 24 this is a map of blab, blah, blah, we need you to say 4 1 whatever. And the reason we need you to do that is 2 because we're creating a permanent record and in the 3 future, you know, 10 years from now the people who take 4 your jobs may be wanting to look back on this and they 5 need to be able to reference the attachment which will 6 be the slides. So in order for it to make sense to 7 people in the future, you know, we want to look as 8 unstupid as possible in the future. 9 All right. Let me see if there's -- who is 10 going to testify today. Is there anyone besides Conoco 11 planning to testify today. Well, it looks like only 12 people from Conoco have signed up to testify so we'll 13 have -- we'll start with Conoco, but at the end of the 14 hearing if there's anyone else in the audience who 15 becomes compelled to testify such as Frank Brown, we'll 16 pull them up or ask them up. And so the way we'll do 17 this is -- are all four of you planning to testify? 18 MR. NENAHLO: Yes. 19 CHAIR FOERSTER: So what I'll do is I'll swear 20 you all in together, but when I ask you the question 21 we'll get separate I dos from you. And then as you 22 testify I'd like you to introduce yourself, who you -- 23 you know, who you represent, what your credentials are, 24 if you want to be recognized in an -- as an expert in a 25 particular area what that area is and what your 5 1 credentials for that are, then we will decide whether 2 to accept you as an expert or not. 3 So all four of you would you raise your right 4 hand. 5 (Oath administered) 6 MR. KANADY: I do. 7 MR. BRESSLER: I do. 8 MR. WENTZ: I do. 9 MR. NENAHLO: I do. 10 CHAIR FOERSTER: Great. All right. So whoever 11 wants to start, go for it. And in case -- it looked 12 like you were planning -- okay. Good. I was going to 13 ask, I'm peeking ahead, I'd really appreciate some 14 chronology to set a background for and we may have some 15 reporters in the room, we may have members of the 16 public who aren't as painfully familiar with Meltwater 17 as we are and I'd like to set a groundwork for 18 newcomers. 19 MR. NENAHLO: Absolutely. We have that 20 prepared on slide two. 21 CHAIR FOERSTER: Excellent. A plus. 22 MR. NENAHLO: Okay. All right. Slide one. 23 Good morning. My name is Thomas Nenahlo. I'm the 24 development engineer for the Meltwater field for 25 ConocoPhillips Alaska. I'm here today with my G 1 colleagues to represent ConocoPhillips as the operator 2 of the Kuparuk River unit and the Meltwater oil pool. 3 Given the individuals who know the details of the 4 history of the Meltwater field and the initiatives that 5 have been undertaken are with me today to present the 6 information and address your questions. In addition to 7 myself we have Bob Wentz, our staff geologist for the 8 area and he is prepared to describe the Meltwater oil 9 pool geology; Eric Bressler is a staff geophysicist and 10 is prepared to speak to you on matters regarding the 11 geophysical description of the field, Randy Kanady, our 12 staff drilling engineer, is also with us this morning 13 to provide an overview of our well design and delivery 14 process. Also joining us this morning is Patrick 15 Wolfe, our North Slope development manager and Kazeem 16 Adeglola, our greater Kuparuk area development manager. 17 Before I begin I would like to provide the 18 Commission with my educational and professional 19 background and experience. I graduated with a 20 bachelor's of science in chemical engineering with a 21 minor in economics in June of 2008 from the Colorado 22 Schools of mines and am currently near completion of my 23 master's degree in petroleum engineering at the 24 University of Alaska at Fairbanks. I have worked for 25 ConocoPhillips Alaska for the past seven years. K 1 Throughout this time I have worked in facilities, 2 production and reservoir engineering roles. I have 3 worked the Meltwater field from December, 2011 until 4 present. I would like to be recognized as an expert in 5 facilities production and reservoir engineering. 6 CHAIR FOERSTER: Commissioner Seamount, do you 7 have any questions? 8 COMMISSIONER SEAMOUNT: No questions and..... 9 CHAIR FOERSTER: Nor do I. 10 COMMISSIONER SEAMOUNT: .....no objections. 11 CHAIR FOERSTER: Nor I. And I have no 12 objections. We'll recognize you as an expert in..... 13 MR. NENAHLO: Facilities..... 14 CHAIR FOERSTER: .....facilities..... 15 MR. NENAHLO: .....production and reservoir 16 engineering. 17 CHAIR FOERSTER: Okay. Wow. A man for all 18 seasons. 19 MR. NENAHLO: Thank you. 20 THOMAS NENAHLO 21 previously sworn, called as a witness on behalf of 22 ConocoPhillips Alaska stated as follows on: 23 DIRECT EXAMINATION 24 MR. NENAHLO: For the chronologies slide two. 25 Today's hearing arises from ConocoPhillips' request 1 to..... 2 CHAIR FOERSTER: You want to switch to slide 3 two for the audience? 4 MR. NENAHLO: Right. Thank you. 5 CHAIR FOERSTER: Sorry. Multitasking. 6 MR. NENAHLO: Today's hearing arises from 7 ConocoPhillips' request to amend area injection order 8 21A. Prior to summarizing the amendment request I 9 would like to provide the Commission with a brief 10 summary of key events that have occurred to date with 11 respect to the Meltwater oil pool since the original 12 area injection order was issued in 2001. In August of 13 2001 the original area injection order 21 was issued, 14 five months later injection operations began. Shortly 15 thereafter an increase in the outer annulus pressures 16 of three wells was identified. Samples of the gas from 17 these outer annuli indicated the presence of miscible 18 injectant. An investigation was then initiated to 19 determine the source and migration mechanism for the 20 MI. Several hypotheses were proposed including a gas 21 lift casing thread leak, poor cement bonds on 22 injectors, tubing by inner annulus by outer annulus 23 leaks, producer fracture stimulation above the casing 24 cement job, poor cement job in the exploration, 25 delineation or plugged and abandoned wells, a pressure E 1 induced fault or fissure opening close to an injector 2 or natural faulting. In January of 2003 organic 3 tracers were injected into injection wells, but as of 4 May, 2003 no tracer had been detected in our outer 5 annuli gas or producer gas streams. Mechanical 6 integrity tests were performed on the inner annuli of 7 all producers and they all passed. A full field model 8 history match completed in May of 2003 indicated no 9 significant out of zone injection. 10 ConocoPhillips reviewed the well completions 11 and found no significant well design issues. Case 12 (indiscernible) logging indicated competent cement 13 bonds on injectors. Neutron density logging indicated 14 no elevated gas saturations at shallow depths on 15 injectors. Pressure pulse testing suggests that no 16 communication between injectors and the outer annuli. 17 In addition pressure response was not identified in 18 surrounding outer annuli during annular disposal 19 operations. Static noise and temperature logging was 20 conducted on wells 2P-431 and 2P-451 that indicated 21 fluid movement behind the production casing to C37, C40 22 and C50 depths. Although movement was identified in 23 the C37 to C50 interval investigation was unable to 24 identify a vertical migration mechanism from the 25 Bermuda interval to the outer annuli of wells with an 10 1 MI signature. 2 From 2003 to 2011 ConocoPhillips managed the 3 elevated outer annulus pressures through a number of 4 initiatives. These included internal waivers that 5 allowed outer annulus operating pressures up to 1,800 6 psig for those wells that exceeded 1,000 psig, our 7 normal maximum allowable operating pressure. These 8 waivers were reviewed and renewed on a semi annual 9 basis and distributed to the AOGCC to inform the 10 Commission of the ongoing surveillance. Meltwater 11 wells were equipped with inner annulus and outer 12 annulus pressure transmitters to alert operations of 13 detectable abnormal conditions. Operator well 14 integrity awareness training was conducted, periodic 15 extended outer annulus bleeds were performed as 16 necessary and outer annulus bleeds were performed as 17 necessary and outer annulus fluid levels were taken 18 monthly as part of an ongoing effort to monitor the 19 pressure at the surface casing shoe. Periodic status 20 updates were also delivered to the ConocoPhillips 21 Alaska management and the AOGCC through the history of 22 the Meltwater field. 23 In 2012 the linear features that had been 24 previously identified within the Bermuda formation were 25 mapped vertically into the overburden. The 2012 40 11 1 seismic features up to the C37 interval identified a 2 potential pathway for injected MI to reach the outer 3 annuli. With this new information the AOGCC was 4 notified and containment initiatives were developed. 5 ConocoPhillips requested amendments to the area 6 injection order in October, 2012 and after hearing the 7 AOGCC issued the current area injection order, 21A. In 8 2014 and 2015 ConocoPhillips prepared and submitted 9 interim progress reports detailing the ongoing 10 containment initiatives. 11 On April 14th, 2015 ConocoPhillips as operator 12 and on behalf of the working interest owners submitted 13 a request to amend area injection order 21A. These 14 amendments arise from geologic, engineering and 15 production data analyses that indicate there has been 16 no further migration of injected fluids out of the 17 Meltwater oil pool and that well conversions and 18 sidetracks utilizing coiled tubing drilling technology 19 may further reduce the risk of potential migration of 20 injected fluids out of the Meltwater oil pool while 21 optimizing the ultimate hydrocarbon recovery from the 22 field. 23 Slide three. The requested amendments to area 24 injection order 21A are as follows. An amendment to 25 rule 2 to allow for new wells and for producer to 12 1 injector conversions in the Meltwater oil pool. 2 Modification to Rule 8 to allow for the use of produced 3 water and sea water for well and surveillance work 4 only. The modification of the monthly reporting 5 requirements set out in rule 9. ConocoPhillips 6 requests these become annual reporting requirements. 7 And finally ConocoPhillips has requested that the 8 expiration date set forth in the area injection order 9 in rule 11 be removed. After expert testimony is 10 provided I will provide -- I will review these proposed 11 modifications in more detail prior to completing our 12 presentation. 13 Slide four. The Meltwater team and I will 14 begin this presentation with an overview of the 15 Meltwater field. We will the move into a summary of 16 the containment initiatives that have been pursued at 17 the field over the previous three years. Following 18 this we will discuss our development objectives at 19 Meltwater and how they pertain to containment and the 20 optimization of ultimate hydrocarbon recovery. We will 21 then conclude today's presentation with a summary of 22 our requested amendments to AIO 21A in our closing 23 remarks. 24 We do have quite a bit of material to cover 25 this morning so unless you have any questions for me at 13 1 this time I'll go ahead and begin. 2 CHAIR FOERSTER: Commissioner Seamount, do you 3 have any questions? 4 COMMISSIONER SEAMOUNT: I'll have some later, 5 not right now. 6 CHAIR FOERSTER: We'll probably both hold our 7 questions until we -- until you guys finish and we'll 8 take a recess and..... 9 MR. NENAHLO: Okay. That sounds good. 10 CHAIR FOERSTER: .....but that doesn't mean 11 that something won't pop up that we need to interrupt 12 and ask just for clarity in the moment. So it's not a 13 promise not to ask questions..... 14 COMMISSIONER SEAMOUNT: Okay. 15 CHAIR FOERSTER: .....it's just a hope. 16 COMMISSIONER SEAMOUNT: Okay. I just made you 17 a liar, I do have one question. 18 CHAIR FOERSTER: Okay. 19 MR. NENAHLO: Sure. 20 COMMISSIONER SEAMOUNT: How much work is 21 involved in these reports, you know, you want to change 22 from monthly to annual, is it because it's a lot of 23 work? 24 MR. NENAHLO: It requires, you know, about a 25 half day of work to complete that report. What we -- 14 1 when we provide the report we provide two month data 2 increments, the month that we're reporting for and then 3 the previous month to help establish trends for those 4 that are looking at the report. In annual report we 5 will be providing the same data, but we'll be looking 6 at 12 month trend. So the information will be the 7 same, just over a longer trend. And so in capturing 8 some of the activities on the field establishing a 9 longer trend we think would be beneficial to both us 10 and the Commission. 11 CHAIR FOERSTER: So I'm assuming that going 12 from monthly which is half a day to annual which would 13 be 12 months, you know, it's not going to require six 14 days of work? 15 MR. NENAHLO: Correct. It would require..... 16 CHAIR FOERSTER: Okay. 17 MR. NENAHLO: .....less. 18 CHAIR FOERSTER: Okay. All right. Any other 19 questions? 20 COMMISSIONER SEAMOUNT: No. 21 CHAIR FOERSTER: Okay. Proceed, please. 22 MR. NENAHLO: Slide five. So it has been some 23 time since we have discussed the particulars of the 24 Meltwater field and so we would like to begin with an 25 overview of the Meltwater field operations and surface 15 1 facilities. 2 Slide six. The operator of the Meltwater 3 development is ConocoPhillips Alaska, the surface owner 4 is the state of Alaska and the working interest owners 5 are ConocoPhillips Alaska, BP Exploration, Chevron USA 6 and ExxonMobil Alaska. 7 Slide seven. This slide shows the bottom hole 8 location and services of wells that have been drilled 9 within the Meltwater field. The blue outline indicates 10 the Meltwater participating area, the green circles 11 indicates wells in production service, the blue 12 triangles are those in injection service and the red 13 stars indicate wells that have been plugged and 14 abandoned. All wells are drilled from a single drill 15 site, 2P, the location of which is indicated by the 16 brown rectangle in the northwest corner of the 17 participating area. 18 CHAIR FOERSTER: What do the yellow circles 19 represent? 20 MR. NENAHLO: The yellow circles are the 21 exploration delineation wells. So the Meltwater North 22 2 well was the discovery well drilled in 2000, the 23 delineation wells, Meltwater North 2A and North 1 were 24 drilled later that year. So you have those three wells 25 I just mentioned there in the yellow circle. 1 CHAIR FOERSTER: And what's the status of those 2 three wells? 3 MR. NENAHLO: They are plugged and abandoned. 4 CHAIR FOERSTER: Okay. Thank you. 5 MR. NENAHLO: Development drilling began in 6 2011, currently there are 13 producers and 6 injectors. 7 Slide eight. Meltwater is a single gravel pad, 8 2P, that can be accessed by gravel road. Four bridges 9 were constructed to access the development. 10 Meltwater's wells, manifold system and testing 11 facilities are located on this gravel pad. Power is 12 supplied to Meltwater through an overhead powerline. 13 Meltwater's production flows into a 24 inch production 14 flowline and co -mingles with Tarn and Kuparuk 15 production before arriving at the central processing 16 facility, CPF 2 at which point the production is 17 processed into sales quality crude. Historically water 18 that was used for injection and artificial lift was 19 supplied to Meltwater in a 12 inch pipe line, however 20 in October of 2009 the Meltwater water injection line 21 was proactively removed from service due to internal 22 corrosion. At this point in time Meltwater's converted 23 to MI injection and MI lift only. By making this 24 conversion improved oil production rate and sweep 25 efficiency were realized. In July of 2014 the 17 1 importation of Prudhoe Bay NGLs into the Kuparuk River 2 unit were discontinued and the Meltwater field was then 3 converted to lean gas injection and lean gas lift only 4 service. 5 CHAIR FOERSTER: Before you leave this slide 6 just for orientation for the public, although it's kind 7 of a separate field, it's operated as just an extension 8 of the Kuparuk field, there are no living quarters, 9 there's no production facilities on site, it's just -- 10 it's just three production pads, correct? 11 MR. NENAHLO: It's just a single production 12 pad, 2P. 13 CHAIR FOERSTER: Single production pad, 14 the..... 15 MR. NENAHLO: Yes. 16 CHAIR FOERSTER: Okay. 17 MR. NENAHLO: The rest of that is correct. 18 CHAIR FOERSTER: Okay. Thank you. 19 MR. NENAHLO: Uh-huh. Slide nine. Meltwater 20 drill site 2P facilities were constructed using a trunk 21 and lateral design in which the wells tie into a 22 manifold system that extends east west across the south 23 side of the pad. Twenty foot wellhead spacing was used 24 as well as a conventional separator for well testing. 25 Remote capabilities include well test actuation, IV 1 control of well chokes and actuation of surface safety 2 valves. An emergency shutdown skid is part of the 3 safety and environmental protection at Meltwater. An 4 electrical control room is located on the east end of 5 the pad adjacent to the test facilities. 6 CHAIR FOERSTER: How often are people on this 7 pad? 8 MR. NENAHLO: Typically daily, however we do 9 encounter days' conditions especially during the 10 wintertime which may prevent people to get onto the 11 pad. And that's one of the reasons that we put in 12 place, you know, the remote well test actuation, 13 control of the well chokes and emergency shutdown skid. 14 CHAIR FOERSTER: Some of the questions I'm 15 asking may sound really stupid..... 16 MR. NENAHLO: Oh, no, it's..... 17 CHAIR FOERSTER: .....and some of them are 18 stupid, but some of them are more just to orient the 19 audience. 20 MR. NENAHLO: No, no problem. Ask away. 21 CHAIR FOERSTER: And I won't identify which is 22 which. 23 COMMISSIONER SEAMOUNT: We'll be able to figure 24 it out. 25 CHAIR FOERSTER: Okay. 19 • • 1 MR. NENAHLO: All right. Slide 10. The 2 reservoir management strategy for the Meltwater field 3 was adopted in 2012 in an effort to ensure containment 4 while optimizing ultimate hydrocarbon recovery. To 5 achieve these objectives a sand based injection 6 pressure limit of 3,400 psig was set. This pressure 7 limit is predicated upon the formation integrity test 8 data from production casing that was set near the top 9 of the Bermuda interval. The chart depicts the 10 formation integrity and leak off test data for the 11 Meltwater field. The three bars in red on the left are 12 the production casing formation integrity tests that 13 the sand face injection pressure limit is predicated 14 upon. In all three cases after the casing was set the 15 wells were drilled out to perform the FITS and drilled 16 into the upper part of the Bermuda interval. The red 17 line that crosses through the production casing data on 18 the left represents the sand face injection pressure 19 limit at the depth of the Bermuda interval in relation 20 to the FIT data. The blue bar, fourth from the left, 21 is the intermediate casing set at 4,696 feet measured 22 depth in 2P-441. The leak off test for this casing 23 point is 16 pounds per gallon. The remaining bars on 24 the graph in green are surface LOT or FIT data for the 25 development and exploration wells in the Meltwater 20 1 area. 2 CHAIR FOERSTER: LOT is leak off test, FIT is 3 formation integrity test? 4 MR. NENAHLO: That's correct. 5 CHAIR FOERSTER: Just for the record. 6 MR. NENAHLO: Thanks. The range for the LOT 7 and FIT tests are 14.6 to 18.1 pound per gallon for the 8 surface casing indicating a good strength throughout 9 this section. 10 Unless there are any further questions from the 11 Commission pertaining to Meltwater surface facilities 12 operations I'll pass the presentation over to Mr. Wentz 13 who'll be providing an overview of the geology at 14 Meltwater. 15 CHAIR FOERSTER: Commissioner Seamount, do you 16 have any questions at this time? 17 COMMISSIONER SEAMOUNT: The only one I have is 18 -- the only one I have is a question as to why you 19 placed the pad where you did when you drilled 20 exploration wells all over the area, I mean, why didn't 21 you put it in the middle? 22 MR. NENAHLO: I do not know the answer to that 23 question. I can get back with you guys. 24 COMMISSIONER SEAMOUNT: I assume it had 25 something to do with environment or topography or 21 1 something. 2 MR. NENAHLO: That would be my assumption as 3 well, I'm not sure about lakes in the area, but..... 4 CHAIR FOERSTER: So it's highly likely that one 5 or both of us will ask random questions that you don't 6 know the answer to. Rather than feeling compelled to 7 come up with an answer right now, write down -- have 8 somebody in your group write down the questions that 9 you don't have an answer to and we'll leave the record 10 open for whatever we determine is an appropriate amount 11 of time for you to get us answers to those questions. 12 So take the pressure off. 13 MR. NENAHLO: Okay. Thank you. 14 CHAIR FOERSTER: Okay. Any other question? 15 COMMISSIONER SEAMOUNT: No. 16 CHAIR FOERSTER: All right. Thank you for your 17 testimony and thank you for the thorough overview and 18 thank you for identifying each slide before you talked 19 about it. 20 All right. Whoever's next. 21 MR. WENTZ: Slide 11. 22 CHAIR FOERSTER: Before you start we need your 23 name, who you represent, what your expertise is, do you 24 want to be recognized as an expert, what your 25 credentials are and then you can carry forward. 22 1 MR. WENTZ: My name is Robert Wentz 2 (indiscernible - away from microphone)..... 3 CHAIR FOERSTER: Oh, wait. Turn the mic on. 4 The mic has to be on before -- okay. Thank you. Start 5 over again, please. 6 MR. WENTZ: Okay. My name is Robert Wentz, I 7 graduated with a bachelor's degree in geological 8 sciences in May of 1977 from Susquehanna University in 9 Pennsylvania. I've worked for ConocoPhillips primarily 10 as a development geologist for the past 35 years. 11 Throughout this time I've had numerous assignments both 12 domestically and internationally. Currently I'm the 13 staff geologist assigned to the Meltwater field, an 14 assignment which has been ongoing for the past two 15 years. I will be presented an overview of the 16 Meltwater field geology. I would like to be recognized 17 as an expert in geology. 18 CHAIR FOERSTER: Commissioner Seamount, do you 19 have any questions of this witness? 20 COMMISSIONER SEAMOUNT: No questions, no 21 objections. 22 CHAIR FOERSTER: All right. I have no 23 questions and I no objections either so please proceed, 24 Mr. Wentz. 25 MR. WENTZ: Thank you. 23 1 ROBERT WENTZ 2 previously sworn, called as a witness on behalf of 3 ConocoPhillips, stated as follows on: 4 DIRECT EXAMINATION 5 MR. WENTZ: Slide 12. The image on the left 6 side of this slide is a map showing the location of the 7 Meltwater field in relation to the nearby Kuparuk River 8 and Tarn fields. The Meltwater field is located 9 approximately eight miles to the southwest of the 10 Kuparuk field. The stratigraphic column at the right 11 of the slide which is representative of the central 12 North Slope depicts the Meltwater field which is 13 located within the Brookian sequence, Torok formation 14 locally known as the Bermuda sandstone. It is 15 interpreted that the Bermuda sandstones were deposited 16 as deep water, channelized, turbidite lobes. 17 Slide 13. This slide illustrates a structural 18 cross section which traverses the field from the 19 northwest to the southeast as depicted on the map to 20 the lower left by the cross section line A to A prime. 21 The cross section depicts the reservoir characteristics 22 of the gross Bermuda reservoir interval which is 23 highlighted in yellow shading. Four wells are 24 identified across the top, the 2P-434, 417, 422A and 25 422. The text boxes at the bottom of each of the first 24 1 three wells depict the key average reservoir properties 2 of each well. The 2P-422 well to the right is 3 interpreted to have possibly intersected the field 4 oil/water contact. Though the gross Bermuda reservoir 5 interval is generally continuous across the Meltwater 6 field the internal stratigraphy is quite complex as 7 individual sand units are difficult to correlate 8 between wells. This continuous nature is illustrated 9 by the changes in the gamma ray curve, the brown, 10 between each well as well as the green pay flags and 11 the permeability curves in pink calculated from 12 petrophysical analysis. The 2P-417 well exhibits the 13 best overall reservoir quality particularly in the 14 upper portion of the Bermuda as illustrated by the 15 permeability curve. The 422A well exhibits better 16 reservoir quality at the base of the gross interval. 17 Additional insight into the discontinuous or 18 compartmentalized nature of the Bermuda will be 19 discussed in the geophysics overview. 20 Unless there are any questions from the 21 Commission at this time I will hand over the 22 presentation to Eric Bressler who will be providing the 23 geophysical overview of the Meltwater field. 24 CHAIR FOERSTER: Commissioner Seamount, do you 25 have any questions at this time? 25 1 COMMISSIONER SEAMOUNT: No, I -- no, I don't. 2 CHAIR FOERSTER: Save them for the..... 3 COMMISSIONER SEAMOUNT: Save them up for the 4 geophysicist. 5 CHAIR FOERSTER: All right. Mr. Bressler, 6 please proceed and again start with who you are and all 7 that good stuff. 8 MR. BRESSLER: My name's Eric Bressler. I 9 graduated with a degree -- a bachelor's degree in 10 geology with minors in math and physics from Olivet 11 Nazarene University in 1998. I earned a master's 12 degree in geophysics from Wright State University in 13 2001. I've worked for ConocoPhillips or its 14 predecessors as a geophysicist for the last 15 years. 15 I joined our Alaska Business Unit three and a half 16 years ago and have worked Meltwater since that time. I 17 would like to be recognized as an expert in geophysics. 18 CHAIR FOERSTER: Thank you. Commissioner 19 Seamount, do you have any questions? 20 COMMISSIONER SEAMOUNT: No questions, no 21 objections. 22 CHAIR FOERSTER: I have no questions, I have no 23 objections. We recognize you as an expert so please 24 proceed. 25 ERIC BRESSLER 26 1 previously sworn, called as a witness on behalf of 2 ConocoPhillips, stated as follows on: 3 DIRECT EXAMINATION 4 MR. BRESSLER: So slide 14 up here. Much of 5 the material -- before I get going here much of the 6 material that I'm presenting here today was presented 7 in the non -confidential section of the hearing held in 8 November of 2012 and has been updated to reflect our 9 current understanding. We do not intend to present any 10 confidential information at today's hearing. 11 CHAIR FOERSTER: That's very good news. 12 MR. BRESSLER: So slide 15. This is a depth 13 structure map of the C35 surface which is just below or 14 is in some areas the base of the Bermuda sands in 15 Meltwater field. The depth range in this range is from 16 on west in the bright, hot colors about 4,300 feet 17 below sealevel. On the east side we reach down to 18 5,888 field below sealevel. All of the Meltwater wells 19 are shown on the map and green dashes on the wellbore 20 are the C35 penetrations in these wells. The solid 21 green outline is the participating area boundary. The 22 shelf edge is approximately where the green changes to 23 blue on the map, the arrows depict the location of 24 canyons interpreted on the shelf and upper slope where 25 erosion has occurred. Immediately down dip from these 27 1 erosional canyons we see the up dip extent of the 2 Bermuda sands which were fed from these channels. The 3 white dashed polygon outlines the Bermuda sands in the 4 field. Note that the area as a whole is lower, deeper 5 in the area of the Meltwater sands and this is where 6 the sands were deposited in a local depression on the 7 C35 surface. There are faults that have been mapped 8 west of the participating area through the C35 -- at 9 the C35 interval, but we do not image and interpret 10 faults within the Bermuda reservoir. it Slide 16, Bermuda stratigraphic complexity. 12 This slide illustrates the interpreted stratigraphic 13 complexity within the gross Bermuda reservoir interval 14 in the Meltwater field. The map is an interpretation 15 of the isolated channel levy system compartments or 16 lobes within the reservoir. The pay sands are 17 contained within the lobes and are characterized by 18 poor connectivity between individual sand bodies. The 19 isolation is a result of the chaotic nature of deep 20 water turbidite deposits. The deviated well 21 trajectories are depicted as gray lines and overlie the 22 lobe bound -- overlie the lobes. The map was primarily 23 based upon 3D seismic data and production performance 24 data. An analysis of the 4D seismic data was completed 25 at the Bermuda interval. This analysis identified %: 1 linear features at the reservoir level that align with 2 the asmath (ph) of the maximum principal stress. These 3 linear features are a time shift between the 1998 and 4 the 2008 seismic shoots and are indicative of a change 5 in gas saturation and/or pressure. The linear features 6 are depicted in this illustration as dashed black lines 7 trending north/northwest, south/southeast. 8 Slide 17, Meltwater field geoseismic section. 9 This slides depicts an interpreted geoseismic section 10 of the gross Bermuda interval. The traverse of the 11 cross section is shown by the red line from A to A 12 prime. These lobes have been interpreted from the 3D 13 seismic character and are consistent with the geologic 14 and production data for the field. The geoseismic 15 section illustrates the individual lobes within the 16 gross Bermuda reservoir interval. The gross Bermuda 17 reservoir interval is depicted as -- with the dashed 18 blue line. Production data from the field indicates 19 poor connectivity between the individual sand lobes 20 shown in yellow in that gross interval. 21 And unless there are any further questions -- any 22 questions from the Commission at this time I will hand 23 the presentation back to Tommy Nenahlo who'll be 24 providing a review of the containment initiatives that 25 were undertaken at Meltwater. 29 1 CHAIR FOERSTER: Commissioner Seamount, do you 2 have any questions at this time? 3 COMMISSIONER SEAMOUNT: How abruptly do these 4 sandstones pinch out, looks like they're -- looks like 5 it's pretty abrupt, right? 6 MR. WENTZ: Yes, seismically it's -- they're 7 fairly distinct boundaries. 8 COMMISSIONER SEAMOUNT: Okay. This is 9 outstanding displays I might add. 10 CHAIR FOERSTER: You just did. Any other 11 questions? 12 COMMISSIONER SEAMOUNT: No other questions. 13 CHAIR FOERSTER: I don't have any questions at 14 this time, but we will have questions later. 15 MR. NENAHLO: Slide 19. As discussed in the 16 introduction ConocoPhillips Alaska would like to 17 provide you with details on the Meltwater containment 18 initiatives that we have undertaken since 2012. 19 ConocoPhillips Alaska has implemented two primary 20 initiatives to ensure containment and is pursuing 21 (indiscernible). The first initiative undertaken to 22 mitigate the large pressure differential between 23 injectors and producers was to implement a sand face 24 injection pressure limit. To determine the 25 effectiveness of the strategy ConocoPhillips Alaska 30 1 developed a significant number of surveillance and 2 monitoring programs. These programs yielded valuable 3 data to which a large technical and professional 4 resource has been applied to evaluate the information. 5 Based upon evaluation of these data there's no 6 indication of further migration of injected fluids out 7 of the Bermuda interval. As average reservoir 8 pressures declined outer annulus pressures have 9 declined, the composition of the outer annuli gas has 10 become less similar to MI. Isotopic analyses have 11 indicated the outer annuli gas becoming more similar to 12 biogenic gas which is native to the Meltwater 13 overburden. And oxygen activation logging has 14 determined that injected fluids are not bypassing the 15 production casing cement of the injected wells at 16 Meltwater. All six injectors have been logged to date. 17 Surveillance and monitoring programs will continue to 18 ensure safe operations and containment of injected 19 fluids within the Bermuda interval. 20 The second initiative undertaken was a 21 reservoir containment assurance project designed to 22 ensure the containment of injected fluids within the 23 Meltwater oil pool. This initiative resulted in the 24 creation and evaluation of a subsurface containment 25 matrix that enabled the qualitative assessment of the 31 1 five key elements of containment. In addition 2 ConocoPhillips developed and implemented a wells fit 3 for service program called WellTrak to ensure 4 compliance of the wells within operating and 5 administrative guidelines. 6 The third initiative is in a planning stage and 7 would be designed to place injectors and producers 8 within the same reservoir body or lobe through the use 9 of coiled tubing drilling sidetracks and well 10 conversions. This will reduce the effect of the 11 aforementioned stratigraphic discontinuities between 12 individual lobes have on the differential pressure 13 between injectors and producers. This initiative is 14 designed to mitigate further migration of injected 15 fluids out of zone as well as provide for improved 16 reservoir connectivity and ultimate hydrocarbon 17 recovery. 18 The following slides will detail the specific 19 elements of the initiatives that have been implemented 20 thus far at Meltwater. 21 Slide 20. To ensure the safe operations and 22 the integrity of the wells at Meltwater ConocoPhillips 23 has completed the following. Continuous pressure 24 monitoring capabilities are available on the outer 25 annuli of each Meltwater well. In addition near 32 1 surface casing corrosion is a known problem across the 2 greater Kuparuk area. Mitigation of the process with 3 an annular dielectric sealant has shown effectiveness 4 by reduction in corrosion rates. All Meltwater wells 5 were treated with the sealant in 2006. An 6 investigation in 2013 to determine the extent of 7 surface casing corrosion at Meltwater determined that 8 the wells are effectively protected from corrosion by 9 sealant and the corrosion rate on the surface casing is 10 very low. Furthermore operator awareness training is a 11 large component of ensuring risks to personnel and 12 equipment are mitigated. The primary components of 13 this training are one, skills now computer based 14 training on a three year frequency and two, classroom 15 training with a well integrity engineer instructor on 16 an annual basis. 17 Slide 21. As previously discussed in August of 18 2012 the well had injection pressure limit of 3,400 psi 19 at the sand face was put in place at Meltwater. This 20 reservoir management strategy was designed to reduce 21 the pressure in the Bermuda formation to a pressure at 22 or below 3,400 psi to ensure confinement of injected 23 fluids. A number of management and monitoring 24 initiatives are ongoing. These include wellhead 25 injection pressure monitoring and alarm set points, 33 1 Bermuda formation pressure surveillance and injection 2 withdraw monitoring. The chart shown in this slide 3 shows the formation pressures over the life of the 4 Meltwater field with the date of the survey on the X 5 axis and pressure and psi on the Y axis. The green 6 circles are producers while the red triangles are 7 injectors. The black bar in 2012 illustrates the time 8 at which the sand face injection pressure limit was 9 set. As shown formation pressures continue to decline 10 with the current reservoir management strategy. After 11 converting to miscible injectant only in 2009 and 12 subsequently to lean gas injection only in 2014 13 injector and producer formation pressures are 14 converging with the exception being the western portion 15 of the field where producer formation pressures have 16 been falling. I'll provide more in depth analysis on 17 the western section later in the presentation. 18 The injectors that had historically supported 19 these producers were shut-in during the spring of 2012 20 due to formation pressures above the sand face pressure 21 limit. In the fall of 2014 these injectors were 22 successfully returned to service after the formation 23 pressures had decreased below the limit. As of 24 February, 2015 all injectors had been successfully 25 returned to service at Meltwater and are capable of 34 1 operating below the current sand face injection 2 pressure limit. 3 Slide 22. The surface casing by production 4 casing annuli commonly referred to as the outer annuli 5 are utilized extensively to monitor for potential 6 communication between the Bermuda formation and 7 shallower intervals. With the exception of wells 2P- 8 406 and 2P-447 which have cemented outer annuli the 9 outer annuli of all Meltwater wells have an open shoe 10 to the formation. This allows the monitoring of the 11 pressure and gas composition of the overburden between 12 the Bermuda and the C80 interval where the surface 13 casings are set. The diagram shown are the well 14 trajectories for Meltwater with the surface pad 15 location shown as the blue rectangle. A number of 16 ongoing surveillance initiatives are in place to 17 monitor the outer annuli and will be discussed in the 18 following slides. 19 Slide 23. Outer annulus surveillance 20 initiatives are designed to monitor the gas 21 composition, static pressure and pressure build up of 22 the formation at the C80 interval. The chart depicts 23 the average outer annulus pressure at Meltwater. 24 Pressures have exhibited an overall significant decline 25 since 2005. In 2012 following the setting of the sand 35 1 face injection pressure limit three of the six 2 injectors at Meltwater were shut-in as they were unable 3 to inject at a pressure below this limit. The 4 reservoir pressure has since decreased and these three 5 injectors were able to be returned to service in the 6 2013 to 2014 time frame. As noted on the chart the 7 recent increase in the average outer annulus pressure 8 can be attributed to thermal effects from these three 9 injectors being returned to service. 10 Slide 24. Prior to the conversion to lean gas 11 injection after NGL imports from Prudhoe Bay to the 12 Kuparuk River unit were discontinued samples of gas 13 from the outer annuli of Meltwater wells were taken on 14 a semi annual basis. The chart shows the analysis 15 technique for the samples collected for an example well 16 injector 2P-429. The blue bars on the left is the Mol 17 percentage for each component for miscible injectant. 18 The teal bars for each component that have a zero value 19 are the Mol percentages for each of the components over 20 the C4 to C7 range for biogenic gas. Essentially 21 biogenic gas does not have any Mol percent of C4 to C7. 22 The values in between are the individual samples that 23 have been taken specific to well 2P-429. As can be 24 seen the outer annulus gas samples have been taken 25 specifically to well 2P-429 -- I'm sorry. As can be 36 0 0 1 seen the outer annulus gas composition since 2012 has 2 never indicated a presence of miscible injectant. 3 These composition analyses demonstrate the 4 effectiveness of the sand face injection pressure limit 5 as it has shown no indication of further migration of 6 injected fluids out of the Bermuda interval. At this 7 time no Meltwater well with compositional analyses 8 completed has shown an increasing similarity to 9 miscible injectant since 2012 when these analyses 10 began. In an effort to confirm the results of the 11 compositional analyses of the outer annuli gas isotopic 12 analyzes were performed. Miscible injectant contains 13 Prudhoe Bay NGLs that are isotopically more positive 14 and thus distinguishable from other gases in the 15 Meltwater oil pool. In 2002 and 2005 isotopic analyses 16 were performed that indicated the outer annulus gas of 17 a number of wells was very similar to MI. In 2012 a 18 systematic analysis of outer annulus gasses showed less 19 miscible injectant and more biogenic gas than in 2002 20 and 2005. These isotopic analyses support the 21 conclusions from the compositional analyses. There's 22 no indication of further migration of injected fluids 23 out of the Bermuda interval. 24 Slide 25. Oxygen activation logging technology 25 is keeping of identifying fluid movement around the 37 0 1-1 1 production casing cement shoe by identifying the 2 presence of oxygen when injecting water. Sea water was 3 used to provide the oxygen in the injected fluid. The 4 schematic on the lower left shows the flow scenario for 5 the oxygen activation logging test tool. The tool 6 works by injecting water past the neutron generator 7 where the oxygen atom within the water molecules is 8 activated then the detection of water flow behind the 9 casing string is possible by measuring gamma rays 10 originating from the activated oxygen. As defined in 11 AIO 21A.004 and .005, to obtain the most information 12 from the logging campaign an attempt was made to step 13 up the sand face injection pressure in 250 psi 14 increments from 2,975 psi to 4,475 psi while performing 15 oxygen activation logging runs. These logging runs 16 were designed to one, confirm there's no fluid movement 17 around the production casing shoe when injecting within 18 the current sand face injection pressure limit and two, 19 to determine if the migration of miscible injectant was 20 possibly a result of historic sand face injection 21 pressures prior to the issuance of AIO 21A. 22 The chart in the lower right summarizes the 23 logging program. On the X axis is the injection rate 24 of water while the Y axis is the sand face injection 25 pressure psi. The red bar indicates the current sand 0 1 face injection pressure limit. The data points for 2 each well indicate the range of rate and pressure that 3 was able to be applied during the logging runs. All 4 injectors have been successfully logged, no leakage of 5 injected fluids above the Bermuda interval was 6 identified over the range of pressure supplies. 7 Slide 26. For AIO 21A.002 ConocoPhillips 8 Alaska completed construction of the facilities 9 necessary to perform an extended bleed on the outer 10 annulus of 2P-431. This effort was designed to it determine if the source providing pressure to the outer 12 annulus is trapped and if it can be depressured. Outer 13 annulus gas -- I'm sorry. The outer annulus began 14 being bled back to production on March 7th, 2015. The 15 chart on this slide details the duration during which 16 2P-431 outer annulus has been bled back. The maroon 17 line represents the OA gas bleed rate and has shown a 18 steady decline in rate since the bleed began. The 19 green light represents the cumulative gas production. 20 As of July 6th, 2015 the cumulative 19.5 million 21 standard cubic feet of gas has been bled to production 22 at an average rate of 112 standard cubic feet per 23 minute. The red line is the outer annulus pressure. 24 On June 18th the central processing facility was 25 shutdown for planned maintenance work. After returning 39 0 1 the well to service and opening the bleed line the 2 outer annuluses only flowed intermittently potentially 3 indicating that the source that had historically 4 charged the outer annulus was being depressured. It is 5 anticipated that a period of six to eight months will 6 be required to substantially reduce the pressure of 7 this source as the flow rate is relatively small and 8 the source is unable to support sustained flow in the 9 current surface operating pressures. 10 This concludes our review of the containment 11 initiatives. As previously mentioned based upon 12 evaluation of the data that has been collected and 13 evaluated to date there is no indication that further 14 migration of injected fluids out of the Bermuda 15 interval. 16 Unless there are any questions from the 17 Commission at this point in time I'll hand over the 18 presentation to Mr. Wentz to discuss the Meltwater 19 overburden characterization study. 20 CHAIR FOERSTER: Commissioner Seamount, do you 21 have any questions at this time? 22 COMMISSIONER SEAMOUNT: I've got one stupid 23 question..... 24 CHAIR FOERSTER: Go for it. 25 COMMISSIONER SEAMOUNT: .....that you were 40 1 referring to in the beginning. You get these gas 2 samples for analysis off the bleeds? 3 MR. NENAHLO: There's a -- where is the exact 4 physical location..... 5 COMMISSIONER SEAMOUNT: Yeah. 6 MR. NENAHLO: .....is that the question? So 7 there's a port on the outer annulus where you can 8 acquire a gas sample..... 9 COMMISSIONER SEAMOUNT: Okay. 10 MR. NENAHLO: .....for each individual well. it COMMISSIONER SEAMOUNT: And how much biogenic 12 gas is produced would you say, is -- do you have any 13 way to figure that out? 14 MR. NENAHLO: Well, that's -- it's on a well by 15 well basis and exactly quantifying how much of it is 16 biogenic versus how much of it is non-biogenic is 17 difficult to determine. When we evaluate the 18 composition of the gas what we're simply looking for is 19 the -- if there is presence of those NGL components 20 that we know are not native to the overburden. 21 COMMISSIONER SEAMOUNT: Do you have any idea 22 where the biogenic gas is coming from, is it the entire 23 section or a discrete interval or, I mean, what do the 24 mud logs say? 25 CHAIR FOERSTER: Is that going to be addressed 41 1 later in the presentation? 2 MR. NENAHLO: Yeah, I don't have the specific 3 answer to that at -- that question at this time, but we 4 can get that for you. 5 CHAIR FOERSTER: Okay. So that'll get written 6 down as the second question to be followed up with. 7 Okay. I don't have..... 8 COMMISSIONER SEAMOUNT: That's it. 9 CHAIR FOERSTER: .....I don't have any 10 questions at this time. I'm debating whether we should 11 take recess and ask questions or just solider on to the 12 end. I'm leaning towards soldiering on. What do you 13 think? 14 COMMISSIONER SEAMOUNT: I agree. 15 CHAIR FOERSTER: Okay. Please continue. And 16 identify yourself again before you start talking. You 17 don't need to give the whole speel, just your name. 18 MR. WENTZ: Slide 27. For the record this is 19 Robert Wentz and I'll be presenting the overburden 20 characterization study. 21 CHAIR FOERSTER: Thank you. 22 MR. WENTZ: Slide 28. An integrated overburden 23 characterization study was initiated by ConocoPhillips 24 Alaska in late 2012 and completed in January, 2015. 25 ConocoPhillips Alaska provided the AOGCC with an 42 1 interim report in 2014 and a final report in April, 2 2015. Primary goal of the study was to better 3 understand the containment system and explain the 4 process of fluid migration into the overburden which 5 occurred in the Meltwater field throughout an 6 integration of geological, petrophysical and 7 geomechanical descriptions and modeling of the 8 overburden. In addition a better understanding of the 9 observed north/northwest, south/southeast trending 10 linear features observed in the 4D seismic was desired. 11 The studies were largely performed by several Houston 12 technology groups and the Meltwater technical team. A 13 total of six different initiatives were pursued, one, a 14 static description of the overburden; two, critical 15 stress modeling; three, mechanistic overburden 16 modeling; four, a completions analysis; five, 17 geomechanical modeling; and six, seismic modeling. The 18 results and information that I will present are fully 19 represented in the Meltwater annual report submitted in 20 April. I will now provide the Commission with a 21 summary of the overall results in each of the 22 initiatives. 23 Slide 29. Numerous technologies were applied 24 and an exhaustive attempt was made to understand the 25 containment system and explain the processes of fluid 43 1 propagation into the overburden, however the overall 2 results of the overburden characterization study were 3 greatly hampered by data constraints on key parameters 4 necessary to accurately describe the overburden. As 5 the modeling inputs contained large uncertainties 6 interpretation of the results were unable to provide an 7 additional insight into the processes and actual 8 propagation mechanism. Although the results were 9 quantitatively inconclusive we were able to 10 qualitatively infer conclusions that aligned with our it understanding of field operations. It is important to 12 note that overall the modeling supported the 13 interpretation that the initial migration of injected 14 fluids out of the Bermuda interval was a result of a 15 larger pressure differential between injectors and 16 producers. This pressure differential was exacerbated 17 by the stratigraphic discontinuities within the Bermuda 18 interval. 19 I will now address each of the key initiatives 20 of the study. 21 Slide 30. The first initiative was a static 22 description of the overburden. The Meltwater field is 23 located on the central North Slope which has exhibited 24 a complex tectonic history. Several tectonic events 25 have produced multiple generations of faults and 1 fractures as evidenced on the chart to the lower right. 2 This chart represents a generalized geologic column of 3 the central North Slope with tectonic sequences, 4 stratigraphic units and major fault fracture events, 5 the solid arrows indicating the direction of maximum 6 horizontal stress. Some of these predate the Meltwater 7 reservoir and overburden, but still influence younger 8 episodes. The younger events pertain most directly to 9 the Meltwater reservoir and overburden. Multiple fault 10 sets and different stratigraphic intervals can be 11 interpreted using 3D seismic data. Below the lower 12 Cretaceous unconformity represented by LCU, Jurassic- 13 Cretaceous west, northwest striking normal faults are 14 present below the Bermuda reservoir interval. Early 15 Tertiary north/northwest striking faults are 16 interpreted in the overburden, exhibiting similar 17 strike to the observed 4D seismic lineaments. In an 18 attempt to better understand the faulting at Meltwater 19 field an automatic fault extraction process was 20 performed on the 3D seismic data on a fault enhanced 21 volume, FEV, in an attempt to identify potential fault 22 characteristics in the overburden. The automated 23 extraction process is a new ConocoPhillips technology 24 which may provide automated seismic detection for 25 potential faults by identifying seismic signal 45 • 1 disruptions. This interpreted technology is based upon 2 user specified thresholds. Due to the relatively poor 3 data quality available within the overburden the effort 4 yielded results that were inconclusive. 5 Slide 31. The modeling of critical stress can 6 provide an indicator of the potential for the slip 7 reactivation on existing faults and fracture. Faults 8 at or near critical stress may be more likely to 9 contribute to fluid flow. The modeling can also aid in 10 the identification of individual faults or fault 11 segments as well as fault sets and trends most prone to 12 being critically stressed. Critical stress models can 13 also offer insights into how much pressure if any would 14 be required to reduce the effective principal stresses 15 and thus reach a critical stress state. Critical 16 stress as a function of excess fluid pressure was 17 evaluated and modeled for the Meltwater field. 18 Under current geological conditions precise 19 subsurface stress directions and magnitudes for the 20 Meltwater field area are under constrained. The 21 regional maximum horizontal stress, HS max, is 22 interpreted to generally trend northwest/southeast with 23 local variations ranging from west/northwest to 24 east/southeast to north/northwest, south/southeast. 25 The Meltwater Ni well contains the borehole breakout .R 0 1 data with the image -- from an image log indicating a 2 northwest/southeast maximum horizontal stress which is 3 consistent with these regional trends. 4D seismic 4 lineaments appear to be aligned with the maximum 5 horizontal stress trending north/northwest to 6 south/southeast. This suggests the most likely 7 Meltwater field stress model with HS max oriented 8 north/northwest to south/southeast. However the 9 difficulty in knowing exact stress state and changes in 10 the stress state dynamically contributes to a large 11 uncertainty in critical stress analysis. Final 12 evaluation of the critical stress modeling is that the 13 uncertainty and stress magnitudes is large enough to 14 make interpretations of excess fluid pressure value 15 from this approach inconclusive. 16 Slide 32. Mechanistic overburden modeling was 17 performed with a focus on evaluating the overburden 18 material balance. The model was used to test whether 19 MI migration is possible through high perm fractures in 20 the overburden. These factors were intended to 21 correspond with the 4D seismic lineaments. Due to 22 limit data characterizing the overburden in full field 23 extended reservoir the modeling input was quite 24 subjective. The results of the modeling were 25 inconclusive. 47 1 A 3D planar fracture geometry model was used in 2 a completions analysis to simulate the estimated 3 surface pressure and injection profile for the 4 Meltwater field. The modeling indicating that 5 hydraulic fractures likely grew and penetrated the 6 overburden. This modeling was limited by the lack of 7 data characterizing both the overburden and a full 8 field reservoir. 9 It supports the interpretation that the initial 10 migration of injected fluids out of the Bermuda 11 interval was a result of a large pressure differential 12 between injectors and producers. 13 Slide 33. A geomechanical analysis was 14 performed to evaluate scenarios for hydraulic fractures 15 to be induced by field injection operations or through 16 reactivated regional faults or a combination of the two 17 in a geologically conditioned model. A discrete 18 fracture network model was constructed to test this 19 range of scenarios. The tool allows for 3 dimensional 20 propagation of a hydraulic fracture in a geocellular 21 model containing any population of layers, cell 22 properties or discrete planar faults or fractures. 23 Hydraulic fracture propagation was simulated in the 24 model which considered general fluid injection 25 conditions as well as rule based calculations that N 1 govern geomechanical interactions. These modeling 2 results were hindered by the limited characterizing the 3 overburden and the full field extended reservoir and 4 the results of the modeling were inconclusive. 5 At this point I will hand over the presentation 6 to Eric Bressler to discuss the sixth initiative, the 7 seismic modeling portion of the Meltwater overburden 8 characterization. 9 CHAIR FOERSTER: Before you proceed, are you 10 going to talk about more than slide 34? it MR. BRESSLER: No, ma'am. Just..... 12 CHAIR FOERSTER: Okay. 13 MR. BRESSLER: .....slide 34. 14 CHAIR FOERSTER: Okay. Well, go ahead and do 15 that and then there might be some questions. 16 MR. BRESSLER: For the record this is Eric 17 Bressler. Seismic modeling was performed to better 18 understand the cause of the observed 4D time shifts at 19 Meltwater. Also for assessing the ability of seismic 20 to detect a reduction in gas or a related mitigating 21 change in the overburden. Though the rock physics 22 model used for the modeling is sub -optimally 23 constrained several conclusions can be drawn with a 24 fair amount of certainty. One outcome of this study is 25 that gas alone does not account for the observed time 1 shifts. When fractures are included modeled time 2 shifts are consistent with the time shifts observed in 3 the 4D seismic. Another result of this study is the 4 confirmation that seismic would be poorly suited for 5 confirming a reduction in overburden gas. This is 6 because p-wave velocity is not sensitive to changes in 7 gas concentration once gas is present at or in excess 8 of about 3 to 5 percent. 9 And at this point I will hand the presentation 10 back to Tommy Nenahlo to discuss the development 11 initiatives at Meltwater if you have no questions. 12 CHAIR FOERSTER: Okay. Before we proceed, 13 Commissioner Seamount do you have any questions at this 14 point? 15 COMMISSIONER SEAMOUNT: Just one. Are any of 16 these lineaments or faults or fractures expressed at 17 the surface? 18 MR. BRESSLER: Not that -- this is Eric 19 Bressler. There's certainly no information on the 20 seismic that would suggest that or any other data that 21 I'm familiar with. 22 COMMISSIONER SEAMOUNT: There's no topographic 23 expressions that may be..... 24 CHAIR FOERSTER: Okay. Any other questions? 25 COMMISSIONER SEAMOUNT: Go ahead. 50 • 1 CHAIR FOERSTER: Okay. I've heard of lot of 2 quantitatively inconclusive and insufficient data and 3 subject to blah, blah, blah, I've heard of lot of 4 (indiscernible), so can you say that you know where the 5 gas has gone and how it got there? And identify 6 yourself, whoever chooses to take this one. 7 MR. NENAHLO: This is -- this is Thomas 8 Nenahlo. So we believe is that essentially there's a 9 -- due to the stratigraphic discontinuities and the 10 operations there's a large pressure differential 11 between injector and producer and along these linear 12 features it migrated vertically and likely charged up 13 shallower zones. We can't..... 14 CHAIR FOERSTER: How did the migration occur, 15 you didn't have a good seal, you created fractures, how 16 did the migration occur? 17 MR. WENTZ: I would say that the excess 18 ejection pressures may have forced the gas up through a 19 fracture network into shallower intervals at least then 20 into the little outer -- open outer annulus where there 21 it may have charged up shallower zones. 22 CHAIR FOERSTER: Okay. So correct me if I'm 23 wrong, but what I'm hearing is that existing fractures 24 that -- in the absence of the increased pressure were 25 sealing, became open due to the increased pressure and 51 1 then provided a conduit for upward movement, is that 2 accurate? 3 MR. NENAHLO: That is correct. 4 CHAIR FOERSTER: Okay. And that's what you 5 believe happened, but because of all those 6 inconclusives and not enough data I heard you said 7 you're still not for sure that that's your mechanism, 8 is that -- is that also accurate? 9 MR. NENAHLO: The modeling that was done 10 supports that interpretation. 11 CHAIR FOERSTER: But modeling can support a lot 12 of interpretation that later become -- are dismissed, 13 right, in my history of using models the only thing you 14 can say about a model is you're going to change it, is 15 that -- are you okay with what I just said? 16 MR. NENAHLO: (Inaudible response)..... 17 CHAIR FOERSTER: Do you have any questions now 18 that I've..... 19 COMMISSIONER SEAMOUNT: Do you know how high 20 these fractures go or how high the open part of the 21 fracture goes? 22 MR. BRESSLER: This is Eric Bressler. 23 Seismically we don't see a signal beyond about 1,700 24 feet above the reservoir. 25 COMMISSIONER SEAMOUNT: Above the reservoir? 52 0 • 1 MR. BRESSLER: Above the reservoir. 2 CHAIR FOERSTER: What would that depth be 3 subsea? 4 MR. BRESSLER: Just below -- oh..... 5 CHAIR FOERSTER: You don't see anything above X 6 feet subsea? 7 MR. BRESSLER: Yeah, I would need to..... 8 CHAIR FOERSTER: Get a calculator and subtract? 9 MR. BRESSLER: Yeah. Yeah. 10 CHAIR FOERSTER: It's okay to do that. 11 COMMISSIONER SEAMOUNT: Sounds like it would be 12 around 4,000 feet in parts of the field. 13 MR. BRESSLER: I would add that the fractures 14 are not identifiable on the seismic. Usually with a 15 fracture there's no offset of formation, that they're 16 just cracks in the rock. So they're not able to be 17 identified on the seismic. We do not identify faulting 18 within the Bermuda reservoir interval on the seismic. 19 CHAIR FOERSTER: So this is a hypothesis? 20 MR. BRESSLER: So it's a hypothesis. 21 CHAIR FOERSTER: Okay. And do you have a depth 22 above which you don't see anything? 23 MR. BRESSLER: I'm just going to have to 24 roughly subtract..... 25 CHAIR FOERSTER: We can put that in the list of 53 1 questions that..... 2 MR. BRESSLER: Okay. 3 CHAIR FOERSTER: .....somebody writes down and 4 you get back to us on. 5 MR. BRESSLER: Okay. 6 CHAIR FOERSTER: Okay. All right. Any other 7 questions? 8 COMMISSIONER SEAMOUNT: No. 9 CHAIR FOERSTER: All right. Please proceed. 10 MR. NENAHLO: Slide 35. And for the record 11 this is Thomas Nenahlo and I'll be presenting 12 initiative three, development objectives. 13 So these development objectives are predicated 14 upon recent geologic, engineering and production data 15 analyses that indicate that well conversions and 16 sidetracks utilizing coiled tubing drilling technology 17 may further reduce the risk of potential migration of 18 injected fluids out of the Meltwater oil pool while 19 optimizing the ultimate hydrocarbon recovery from the 20 field. 21 Slide 36. By placing a producer and an 22 injector in the same turbidite lobe deposit significant 23 improvements in producer performance can be realized. 24 This map on the lower right depicts the individual 25 lobes from the Meltwater field as discussed and 54 0 0 1 illustrated in the Meltwater geology overview section. 2 The well trajectories and bottom hole locations are 3 shown in relation to the individual turbidite lobe 4 boundaries. These individual channelized lobes 5 demonstrate the reservoir compartmentalization. The 6 green circles indicates the bottom hole locations of 7 the producers while the blue triangles indicate the 8 bottom hole locations of the injectors. In addition 9 due to the depositional nature of the turbidite 10 deposits the sands within each lobe can have 11 significant vertical and lateral heterogeneities 12 especially near the periphery of the lobe. As can be 13 seen on the map there are a number of examples in which 14 injectors and producers are not in the optimum location 15 to account for the lobate nature of the reservoir. To 16 overcome the stratigraphic barriers between the lobes 17 ConocoPhillips would like to progress well conversions 18 and coiled tubing drilling sidetrack opportunities. 19 This initiative is designed to mitigate further 20 migration of injected fluids out of zone as well as 21 provide for improved reservoir connectivity and 22 ultimate hydrocarbon recovery. 23 Slide 37. Shown on this slide is a cross 24 section within an individual turbidite lobe from A to A 25 prime. The picture on the right is a depiction of the 55 0 • 1 reservoir interpretation from seismic and well 2 interaction data between the injector 2P-434, producer 3 2P-417, and injector 2P-420. These wells exhibit 4 superior inter -well communication that correlates with 5 the seismic interpretation. The interaction between 6 injector 2P-434 and producer 2P-417, will be discussed 7 further on the next slide. 8 Slide 38. This slide demonstrates the superior 9 hydrocarbon production performance when an injector and 10 a producer are located within the same turbidite 11 deposit. The interaction depicted here is between 12 injector 2P-434 and producer 2P-417. The orange line 13 on the chart shows the injection rate, 1,000 standard 14 cubic feet per day, within the date of injection on the 15 X axis. The green area indicates the oil production 16 rate from 2P-417. Prior to restoring 2P-434 to 17 injection service well 2P-417 was producing 18 approximately 150 barrels of oil per day. After 19 restoring injection capabilities producer 2P-417 20 reached a peak oil rate of over 1,200 barrels of oil 21 per day. As can be seen a significant improvement in 22 the oil rate from this well was achieved by taking 23 advantage of the lobate nature of the reservoir and 24 returning this injector to service. There are a number 25 of other opportunities to further improve the 56 1 hydrocarbon recovery at Meltwater by pursuing well 2 conversions and coiled tubing drilling sidetracks. 3 Slide 39. Shown on this slide is a cross 4 section that crosses through multiple lobe boundaries 5 from B in the south to B prime in the north. The 6 picture on the right is a depiction of the reservoir 7 interpretation from seismic data between producer 2P- 8 449, injector 2P-447, producer 2P-448A and producer 2P- 9 451. As can be seen there are numerous stratigraphic 10 boundaries that need to be overcome between the 11 injector 2P-447 and the adjacent producers. These 12 barriers appear to negatively impact the ability to 13 provide pressure support and reservoir sweep to the 14 producers. 15 Slide 40. This slide shows the injection and 16 production rates in the southwest portion of the field 17 where there are significant reservoir heterogeneities 18 along the turbidite lobe boundaries that can be 19 attributed to the deposition environment. Prior to 20 setting the sand face injection pressure limit the 21 injectors in this area were capable of injecting 22 approximately eight million standard cubic feet per 23 day. After the sand face injection pressure limit was 24 set the injectors were shut-in to allow the reservoir 25 pressure to decline. When the injectors were returned 57 1 to service in late 2014 they were unable to inject at 2 historic rates. Rather than using the higher injection 3 pressure to support the producers in the area 4 ConocoPhillips is evaluating opportunities to relocate 5 the bottom hole location of existing wells to better 6 sweep individual lobes by not requiring injection 7 across the turbidite lobe boundary. 8 Slide 41. This slide illustrates the effects 9 of reservoir compartmentalization on Meltwater's total 10 oil production. The chart at the left is the oil 11 production in the western and eastern sections in 12 barrels of oil per day. Within the chart the green 13 represents the western section of the reservoir while 14 the red represents the eastern section. The primary 15 difference between the two is that the well 16 interactions within the western section are more 17 hindered by compartmentalization. On setting of the 18 sand face injection pressure limit the injection rate 19 into the western section of Meltwater experienced a 20 significant decline resulting in a decline in the oil 21 production rate. The eastern section production 22 injection remained relatively stable. This 23 compartmentalization hinders the ability to establish 24 an optimal sweep of the reservoir with the current well 25 locations. This is the primary driver for 1 ConocoPhillips to pursue well conversions and coiled 2 tubing drilling sidetrack opportunities as the 3 evaluations completed to date indicate that an 4 improvement in the ultimate recovery of the field can 5 be achieved by converting and/or relocating bottom hole 6 locations of a number of wells. 7 CHAIR FOERSTER: Okay. Go back to that slide 8 just for a sec. So are those cumulative production 9 rates, combined production rates or are they separate? 10 MR. NENAHLO: Those are stacked production 11 rates. 12 CHAIR FOERSTER: Stacked. Okay. That's what I 13 was -- that's a good word. 14 MR. NENAHLO: Yeah, and barrels of oil per day. 15 CHAIR FOERSTER: And when the dip occurred 16 that's when you stopped injecting, when the initial dip 17 occurred..... 18 MR. NENAHLO: This dip? 19 CHAIR FOERSTER: No. No, the first dip. 20 MR. NENAHLO: So that dip is attributable to 21 the 2012 CPF 2 shutdown, we were doing..... 22 CHAIR FOERSTER: Okay. 23 MR. NENAHLO: .....planned maintenance so we 24 actually shut-in the field. 25 CHAIR FOERSTER: Okay. So that was a field 59 1 shut-in. 2 MR. NENAHLO: Field shut-in. 3 CHAIR FOERSTER: And then when you brought the 4 field back on..... 5 MR. NENAHLO: And at that time we had a sand 6 face injection pressure limit set..... 7 CHAIR FOERSTER: Okay. 8 MR. NENAHLO: .....and then we experienced a 9 decline. This recent increase here is that interaction 10 between 2P-434 and 417. And this increase here is we 11 had a producer shut-in for some time in the field due 12 to low reservoir pressure and so by returning the 13 injectors to service -- so this -- we coincided 14 returning injectors to service with that single 15 producer 2P-449. 16 CHAIR FOERSTER: And you're pointing now to 17 which slide? 18 MR. NENAHLO: Oh, I'm sorry. Slide 40..... 19 CHAIR FOERSTER: Okay. 20 MR. NENAHLO: .....looking at the lower right 21 of the chart. 22 CHAIR FOERSTER: Okay. 23 MR. NENAHLO: So we -- when we brought online 24 the injectors we also brought online that additional 25 producer. I 1 CHAIR FOERSTER: Okay. Thank you. All right. 2 And now you're back on slide 41. 3 MR. NENAHLO: Back on slide..... 4 CHAIR FOERSTER: Thank you. That gave it more 5 of a complete context for me. 6 MR. NENAHLO: Yeah. 7 CHAIR FOERSTER: Thank you. Okay. Continue. 8 MR. NENAHLO: Okay. 9 CHAIR FOERSTER: Oh, unless..... 10 MR. NENAHLO: Unless there any further..... 11 CHAIR FOERSTER: Do you have any questions 12 right now? 13 COMMISSIONER SEAMOUNT: No. 14 CHAIR FOERSTER: Okay. Nor do I. 15 MR. NENAHLO: Slide 42, requested amendments to 16 AIO 21A. 17 Slide 43. ConocoPhillips Alaska requests that 18 the Oil and Gas Conservation Commission 19 administratively amend area injection order 21A, the 20 Meltwater oil pool in the Kuparuk River field. 21 ConocoPhillips Alaska submitted the request in its 22 capacity as operator of the Meltwater oil pool and as 23 unit operator for an on behalf of the working interest 24 owners of the Meltwater participating area in the 25 Kuparuk River unit. The requested amendments to AIO 61 1 21A are designed to one, further mitigate the potential 2 for the migration of injected fluids out of the 3 Meltwater oil pool while improving flood efficiency and 4 ultimate hydrocarbon recovery in a safe and 5 environmentally friendly manner; two, to enable 6 ConocoPhillips Alaska to safely and successfully 7 conduct surveillance initiatives to ensure confinement 8 of injected fluids within the MOP; three, to ensure 9 continued performance reporting by providing an annual 10 synopsis on ConocoPhillips Alaska's surveillance and 11 monitoring and development initiatives that are 12 designed to ensure the containment of injected fluids 13 within the Meltwater oil pool and; four, to remove the 14 expiration date associated with AIO 21A. 15 Slide 44. In light of the new information 16 gathered and analyzed over the past three years 17 ConocoPhillips Alaska seeks to administratively amend 18 four rules within AIO 21A. The rationale in support of 19 each proposed amendments follows. Rule 2, fluid 20 injection wells. In an effort to mitigate the effect 21 of stratigraphic discontinuities between injectors and 22 producers within the Meltwater oil pool ConocoPhillips 23 originally requested that AIO 21A rule 2 be revised to 24 read as follows. Development well sidetracks are 25 permissible when drilled within the MOP and well 62 1 conversions are permissible in the MOP. This proposed 2 amendment is designed to improve reservoir connectivity 3 between producers and injectors thus mitigating the 4 effects of compartmentalization and improving ultimate 5 hydrocarbon recovery. Further by placing injectors and 6 producers within the same lobe deposit the risk of 7 injected fluids migrating out of the MOP can be 8 reduced. An alternative option to the original request 9 would be to replace the existing language with the 10 original AIO 21 rule 2 language. The proposed language 11 for either alternative is reflected on the slide above. 12 ConocoPhillips' operating philosophy and core values 13 emphasize safety and environmental stewardship. We are 14 committed to ensuring that the wells at Meltwater are 15 drilled and operated safely. To ensure this in 16 addition to the existing regulations that require the 17 AOGCC's approval through the drilling permitting 18 process to drill any new well as well as the AOGCC's 19 approval for all well conversions through the sundry 20 process, ConocoPhillips has internally developed a 21 thorough well design and delivery process. 22 And, Randy Kanady, our staff drilling engineer 23 will now provide an overview of our well design 24 delivery process for the Commission. 25 MR. KANADY: Good morning. My name is Randall 63 1 Kanady and I'm a staff drilling engineer with 2 ConocoPhillips Alaska Drilling and Wells Group. And 3 I'd like to be recognized as an expert in drilling 4 engineering. I have over 25 years experience in Alaska 5 oil fields with ARCO, Phillips and ConocoPhillips. My 6 responsibilities over the years have included 7 production engineering, drilling engineering, HSC and 8 currently I manage ConocoPhillips' drilling and wells 9 compliance and regulatory activities. I have a 10 bachelor's in petroleum engineering and a master's in 11 environmental engineering. My bachelor's is from 12 Montana College of Mineral Science and Technology and a 13 master's in environmental engineering from the 14 University of Alaska. Finally I'm a registered 15 professional engineer in the state of Alaska. 16 CHAIR FOERSTER: Do you have any questions for 17 this witness? 18 COMMISSIONER SEAMOUNT: I have no questions, I 19 have no objections. 20 (Off record comments) 21 CHAIR FOERSTER: Mr. Kanady, I have no 22 questions, I have no objections. 23 (Off record comments) 24 CHAIR FOERSTER: You may proceed. 25 RANDALL KANADY 64 1 previously sworn, called as a witness on behalf of 2 ConocoPhillips stated as follows on: 3 DIRECT EXAMINATION 4 MR. KANADY: ConocoPhillips Alaska would like 5 the Commission to consider that rule number 2 of AIO 6 21A revert back to the original AIO rule 2 which is 7 restated in his slide 36. I'm sorry, we're on slide 8 35. 9 CHAIR FOERSTER: Forty-five. 10 MR. KANADY: Forty-five. And that rule is 11 restated on the top of slide 45. CPA would like to 12 rely on AOGCC permit to drill process 20 AAC 25.005 to 13 review future Meltwater drilling opportunities to 14 address potential drilling risk. Before CPAI would 15 submit a permit to drill a proposed well would go 16 through ConocoPhillips' well design and delivery 17 process. I would like to briefly review the well 18 design and delivery process for the Commission to give 19 you an appreciation of the detailed work that would be 20 required. The well design and delivery process or 21 WDDP, establishes a set of standards and guidelines for 22 the delivery and operation of all ConocoPhillips wells. 23 The WDDP is managed -- is intended to manage and 24 identify operational risk as a structured process which 25 leverages multi discipline teams and continuous 65 1 improvement in an organized way to deliver safe, 2 efficient planning of well work across ConocoPhillips. 3 Implementation of the WDDP encourages collaboration by 4 soliciting and capturing the key issues and inputs from 5 each discipline. It guides a multi discipline team 6 through the well planning process, it documents well 7 design and delivery decisions, encourages timely 8 decision making on well design and provides early 9 feedback to other disciplines on the feasibility and 10 cost of proposed development alternatives. 11 The WDDP is a front end loading process that is 12 structured in a stage gate process that ensures robust 13 planning and design early in the project's lifestyle at 14 a time when the ability to influence changes in design 15 is relatively high and the cost to make those changes 16 is relatively low. It encourages the appropriate level 17 of specialist and leadership to be involved at the 18 appropriate stage of the project planning process to 19 ensure critical criterion options are considered at the 20 right time. And it enables the development of 21 sufficient strategic information with which owners can 22 address risk and make decisions to commit resources in 23 order to maximize the potential for success. 24 So the six phases of the WDDP as you can see on 25 slide 45 is front end loading or FEL-1 is explore I 1 phase, FEL-2 is the appraise phase, FEL -- FEL-1 is the 2 appraise phase, FEL-2 is the select phase and FEL-3 is 3 the define phase. And ConocoPhillips would not be 4 bringing a well to the Commission until it has passed 5 the FEL-3 stage gate. And then the remaining stages of 6 the WDDP is execute phase or the well construction 7 phase and then operate phase. For each FEL phase it 8 has multiple requirements that must be completed before 9 getting approval to progress to the next phase. These 10 phases are implemented differently depending on whether 11 the project is an individual well or a program and its 12 associated program wells. 13 The WDDP utilizes Max Book which is a web base 14 software tool designed to support the WDDP by providing 15 a chronological tool to implement and document the WDDP 16 by enabling a multi discipline team to move a project 17 through the process of designing and delivering a well. 18 So unless the Commission has any questions 19 regarding our well design and delivery process I will 20 hand the presentation back to Tommy Nenahlo. 21 CHAIR FOERSTER: Do you have any questions? 22 COMMISSIONER SEAMOUNT: I just have one. I 23 hear a lot of talk about sidetracking existing wells, 24 put them in better locations and stuff, are you also 25 saying that you want to drill grassroot wells too, I 67 1 mean, can you reach the entire field by sidetracking 2 existing wells and do what you want to do? 3 CHAIR FOERSTER: And whoever answers identify 4 yourself. 5 MR. NENAHLO: I'll answer that one. This is 6 Thomas Nenahlo. Currently we are pursuing well 7 conversions and coiled tubing drilling sidetracks. 8 There are opportunities that we believe are to the 9 south -- the southeast of the field primarily that 10 would be inaccessible to CTD sidetracks and well it conversions in terms of optimizing the ultimate 12 recovery. In addition CTD opportunities may be 13 challenged in the future due to the vertical 14 perm/horizonal perm relationship. The channelized 15 nature of Meltwater field provides us benefits in a 16 number of areas in the Meltwater field because we have 17 a better KVKH than sand -- a similar field like Tarn 18 would have. Tarn is a much more laminated system 19 because we're higher up on the slope and we have a much 20 more channelized nature deposition environment which 21 you'd think would be conducive for CTD sidetracks. 22 But, yes, there are opportunities that we would not be 23 able to reach with CTD and we need to evaluate the 24 deliverability of the CTD well once a pilot is drilled 25 before we assess anything further on the lower east is 1 side. 2 CHAIR FOERSTER: Any other question? 3 COMMISSIONER SEAMOUNT: Not at this time. 4 CHAIR FOERSTER: I have a couple questions 5 about the WDDP. Is the WDDP something that everybody 6 -- I mean, is it like an ASME code or, you know, is it 7 something that everybody that drills wells follows or 8 is it -- is this something ConocoPhillips does? 9 MR. NENAHLO: I know for a fact it's something 10 ConocoPhillips does, but I couldn't say for sure which 11 of the companies follows it, the VDDT curriculum. 12 CHAIR FOERSTER: So it's not something that you 13 learned in college that everybody automatically does 14 like the laws of physics? 15 MR. NENAHLO: No. 16 CHAIR FOERSTER: Okay. So has Conoco's WDDP 17 changed during the time that you've been with Conoco or 18 is it something that -- I mean, it's like a law of 19 physics, you let go of it, it always drops, is the WDDP 20 like that, nothing ever changes in it? 21 MR. NENAHLO: The -- this WDD -- the current 22 well design and delivery process was implemented last 23 year and but the pieces that we talked about were 24 primarily there I think for the last several years, but 25 it has been formalized into a manual of standards here 69 1 in 2014. 2 CHAIR FOERSTER: So if Conoco were to pull a BP 3 on us and sell Meltwater to Hilcorp or somebody would 4 Hilcorp have this same WDDP? 5 MR. NENAHLO: Yeah, I would have to check with 6 Hilcorp. 7 CHAIR FOERSTER: So there's no guarantee that a 8 new operator -- and it could be -- it could be Pioneer 9 or somebody else, there's -- so there's no guarantee 10 that should Conoco relinquish operatorship of Meltwater 11 to a different operator that that operator would still 12 -- would have this same WDDP? 13 MR. NENAHLO: There's no way, yeah, without 14 checking with the operator to find out if they..... 15 CHAIR FOERSTER: So there's no guarantee? 16 MR. NENAHLO: .....without checking with the 17 operator. 18 CHAIR FOERSTER: So not knowing who the 19 operator is could you check with that operator? 20 MR. NENAHLO: We..... 21 CHAIR FOERSTER: I think that's a no. So 22 there's no guarantee. Never mind, it's a rhetorical 23 question. All right. I don't have any questions at 24 this time. 25 MR. NENAHLO: And so for the record this is 70 1 Thomas Nenahlo. Slide 46. I just have a few more 2 slides and we'll be complete with the presentation. 3 Rule 8. So slide 46, rule 8, authorized fluids 4 for injection. AIO 21A, rule 8 specifies that the 5 authorized fluids for injection into the Meltwater oil 6 pool. Water is not currently listed. Water was 7 previously authorized and used as an underground 8 injection fluid in the Meltwater oil pool, but was not 9 identified in AIO 21A. This was because there are no 10 plans to revert to a waterflood or water alternating 11 gas flood at the MOP at this time due to the superior 12 performance of the field in utilizing a gas and/or 13 miscible injectant flooding agent. However Beaufort 14 Sea water in the Kuparuk River unit produced water is 15 necessary to conduct surveillance, logging, near 16 wellbore displacements and well maintenance. 17 Specifically the use of injected water allows for 18 displacement of gas in the wellbore prior to well 19 interventions to mitigate hazards to personnel and is 20 required for oxygen activation logging as a method to 21 ensure the integrity of the production casing cement 22 shoe on injectors. The Meltwater field fluid 23 sensitivity study was completed in March of 2001. This 24 study utilized core samples from the Meltwater North 25 number 1 and number 2 wells that included an 71 1 investigation into the sensitivity of preserved 2 reservoir samples to the proposed floodwaters. These 3 proposed floodwaters included a Kuparuk River unit 4 produced water blend and a 75 percent Kuparuk River 5 unit produced water, 25 percent Beaufort Sea water 6 blend. The investigation into the sensitivity of the 7 Meltwater North number 1 and number 2 core samples to 8 the proposed floodwaters concluded that there were no 9 adverse reactions to the produced water/sea water 10 blend. 11 As discussed in the application for permission 12 to inject produced water and sea water in the Meltwater 13 oil pool and which application resulted in AIO 21A.005, 14 although ConocoPhillips Alaska does not have fluid 15 sensitivity studies completed with 100 percent Beaufort 16 Sea water, the salinities of the KRU or Kuparuk River 17 unit produced water and the Beaufort Sea water are 18 similar and no appreciable compatibility problems for 19 either the Meltwater formation or its confining zones 20 are expected. If injectors do incur damage from sea 21 water injection the damage will be contained with a 22 small radius of the wellbore due to the small volume of 23 fluid required to complete the surveillance, logging, 24 displacements and well maintenance initiatives. Any 25 damage to the near wellbore formation that may arise 72 0 1 can be reversed by employing remedial treatments. The 2 AOGCC authorized the injection of Beaufort Sea water in 3 AIO 21A.005 on November 21, 2014 for a period of six 4 months to allow us to complete a number of surveillance 5 initiatives. Therefore ConocoPhillips requests that 6 AIO 21A rule 8 be modified to allow for the continued 7 injection of Beaufort Sea water and injection of KRU 8 produced water for surveillance, logging, near wellbore 9 formation displacements and well maintenance purposes. 10 Slide 47. Rule 9, performance reporting. Rule 11 9 of AIO 21A currently requires a monthly report 12 detailing the daily monitoring of all Meltwater oil 13 pool wells. ConocoPhillips Alaska respectfully 14 requests that the Commission modify AIO 21A, rule 9, to 15 read the operator shall submit an annual synopsis of 16 the surveillance, monitoring and development 17 initiatives completed during the previous year that 18 pertain to the confinement of injected fluids within 19 the Bermuda interval together with the Meltwater annual 20 surveillance report. This proposed modification to 21 rule 9 will ensure the Commission receives an annual 22 synopsis of surveillance, monitoring and development 23 initiatives as they pertain to the containment of 24 injected fluids at the same time ConocoPhillips Alaska 25 submits the Meltwater annual surveillance report that 73 1 is required by conservation order 456, rule 10. This 2 modification to AIO 21A, rule 9, will eliminate the 3 monthly reporting requirement yet ensure that the 4 Commission is regularly informed of the status and 5 results of containment and development initiatives. 6 Rule 11, expiration date. Currently AIO 21A 7 has an expiration date of November 16, 2015. 8 ConocoPhillips requests that the Commission remove the 9 expiration date as surveillance and monitoring data 10 suggest that the implementation of the new reservoir 11 management strategy has prevented further migration of 12 injected fluids out of the Meltwater oil pool. The 13 existing rules together with the aforementioned 14 requested amendments will ensure confinement of 15 injected fluids while optimizing ultimate hydrocarbon 16 recovery. 17 CHAIR FOERSTER: Mr. Nenahlo, before you go to 18 your next slide, are you aware that the AOGCC is 19 considering adding sunset clauses to all of its 20 conservation orders and AIOs? 21 MR. NENAHLO: That actually was discussed with 22 the AOGCC technical staff. 23 CHAIR FOERSTER: Okay. So the fact that we're 24 going to -- we are likely to put sunset clauses on all 25 of AIOs doesn't impact your desire to have us not do 74 1 one for this one? 2 MR. NENAHLO: What kind of time frame -- I'm 3 just out of curiosity what are the time frames for the 4 sunset clauses? 5 CHAIR FOERSTER: We haven't nailed it yet. 6 MR. NENAHLO: Okay. Yeah, we're -- essentially 7 we had a two year original AIO 21. 8 CHAIR FOERSTER: Do you have a recommendation 9 for -- you know, and one of the reasons we're 10 considering the sunset clause is just, you know, 11 mechanical conditions of wells change, operating 12 parameters change, knowledge of fields change, 13 operators change and the ability of different operators 14 to perform at the same level changes. So do you have a 15 suggestion on a sunset clause timing for this AIO given 16 that we're not likely to give you eternity? 17 MR. NENAHLO: I'd like to discuss that with the 18 technical team. 19 CHAIR FOERSTER: Okay. Well, maybe that's a 20 question you can answer and..... 21 MR. NENAHLO: Yeah, certainly. We'd be..... 22 CHAIR FOERSTER: .....we'll leave the record 23 open. 24 MR. NENAHLO: .....more than happy to. 25 CHAIR FOERSTER: Okay. Commissioner Seamount, 75 1 do you have any questions at this time? 2 COMMISSIONER SEAMOUNT: No, I don't. I might 3 after the break though. 4 CHAIR FOERSTER: Okay. Please proceed. 5 MR. NENAHLO: Thank you. Slide 48, closing 6 remarks. So in conclusion the requested amendments to 7 AIO 21A arise from geologic, engineering and production 8 data analyses that indicate there has been no further 9 migration of injected fluids out of the Meltwater oil 10 pool. Furthermore recent geologic and production data 11 analyses indicate that well conversions and sidetracks 12 utilizing coiled tubing drilling technology overcomes 13 stratigraphic barriers within the compartmentalized 14 reservoir may further reduce the risk of potential 15 migration of injected fluids out of the Meltwater oil 16 pool while optimizing ultimate hydrocarbon recovery. 17 ConocoPhillips believes the requested amendments are 18 based on sound engineering and geoscience principles 19 and they will further mitigate the risk of migration of 20 injected fluids, it will increase ultimate hydrocarbon 21 recovery, it will not promote waste or jeopardize 22 correlative rights and will not result in an increased 23 risk of fluid movement into freshwater. We are 24 confident that even with these changes ConocoPhillips 25 can continue to operate in a safe and efficient manner 76 1 at Meltwater therefore ConocoPhillips Alaska seeks 2 AOGCC approval of the amendments presented today. 3 And thank you for your attention during this 4 presentation. 5 CHAIR FOERSTER: Okay. Before we take a break 6 do you have any questions? 7 COMMISSIONER SEAMOUNT: No. 8 CHAIR FOERSTER: Neither do I. It is 10:40, 9 let's take a -- I'd say we'll need at least 20 minutes. 10 We'll tentatively plan on resuming at 11:00, but if 11 we're not back up here don't start without us. So 12 we're recessed at 10:40. 13 (Off record - 10:40 a.m.) 14 (On record - 11:04 a.m.) 15 CHAIR FOERSTER: All right. We have several 16 questions for Conoco and we'll start with Mr. Seamount. 17 (Off record comments) 18 COMMISSIONER SEAMOUNT: All right. I have a 19 few questions. Do these fractures or lineaments or 20 pathways, temporary pathways, do they propagate through 21 the C37? 22 MR. BRESSLER: They appear to die out about 200 23 feet below the C37. 24 COMMISSIONER SEAMOUNT: Okay. 25 MR. BRESSLER: And I can answer your earlier 77 1 question..... 2 COMMISSIONER SEAMOUNT: Okay. 3 MR. BRESSLER: .....like about the height. 4 Because the field itself has variable depth, right, and 5 these linear features have variable height, about 3,600 6 feet below sea level would be about the shallowest you 7 would expect that to reach. 8 COMMISSIONER SEAMOUNT: So 3,600 feet below sea 9 level? 10 MR. BRESSLER: Yeah. 11 COMMISSIONER SEAMOUNT: And it looks like there 12 are at least -- there's a C50, C40 and a C37 sand in 13 that interval, correct? 14 MR. BRESSLER: Correct. 15 COMMISSIONER SEAMOUNT: Do you see any shallow 16 gas, I think I may have asked this question, but do you 17 see any shallow gas above the C80? 18 MR. BRESSLER: No, sir. Of course the quality 19 of the seismic diminishes as you, you know, the amount 20 of fold, the amount of data you have in any seismic 21 survey's diminished up there, but we don't see 22 anything. 23 COMMISSIONER SEAMOUNT: So, is there a possible 24 way to get seismic that would work at those shallow 25 depths like these shallow hazard surveys that we do on W. 1 exploration wells? 2 MR. BRESSLER: It's conceivable. I guess I 3 don't know enough about the limitations and issues with 4 acquisition up there on the Slope in terms of shallow 5 -- shallow seismic, but..... 6 CHAIR FOERSTER: Well, that would be a good 7 question to write down for your list and get back to us 8 on. 9 COMMISSIONER SEAMOUNT: And also I'd like to 10 know what the resolution of the seismic is. I assume 11 that these plumes have been mapped out with the aid of 12 seismic? 13 MR. BRESSLER: Yes. 14 COMMISSIONER SEAMOUNT: And are you able to get 15 a footage on them or just see them? 16 MR. BRESSLER: A footage for all dimensions, 17 height? 18 COMMISSIONER SEAMOUNT: Yeah, what..... 19 MR. BRESSLER: Yeah. 20 COMMISSIONER SEAMOUNT: .....what's the minimum 21 height that you can see? 22 MR. BRESSLER: Yeah, so the minimum depth is 23 3,600 below sea level. And they can be deeper than 24 that. 25 COMMISSIONER SEAMOUNT: Okay. But I'm talking 79 1 about the sand, the Bermuda sand, what thickness can 2 you identify off the seismic on the sand? 3 MR. BRESSLER: Oh, I see. Tuning thickness on 4 the newer data set is about 87 feet. That's 5 artificially precise, but that's the math, it's 87.5 6 feet when I use my, you know, rough interval velocity 7 and dominant frequency of about 30 hertz on the full 8 stack seismic. 9 CHAIR FOERSTER: And that's good to one 10 significant digit. 11 COMMISSIONER SEAMOUNT: Okay. 12 (Off record comments) 13 COMMISSIONER SEAMOUNT: So when you map out 14 these plumes your tuning thickness is 87 feet, but you 15 can see the edges of them anyway 16 correct, and that's how you -- how you map the aerial 17 extent? 18 MR. BRESSLER: Yeah, of the lobes. 19 COMMISSIONER SEAMOUNT: Okay. Has your seismic 20 analysis of the pathways changed since the last time we 21 looked at them..... 22 MR. BRESSLER: No. 23 COMMISSIONER SEAMOUNT: .....you came in and 24 gave a presentation? 25 MR. BRESSLER: No. 1 COMMISSIONER SEAMOUNT: Okay. What formation 2 is the C80 in, it's below the base of the West Sak? 3 MR. BRESSLER: I'll defer to my colleague here. 4 MR. WENTZ: This is Robert Wentz. We have it 5 within the Campainian (ph). The C80 is normally 6 markers and..... 7 COMMISSIONER SEAMOUNT: Okay. 8 MR. WENTZ: .....it's within the Campainian. 9 COMMISSIONER SEAMOUNT: Okay. Is that what the 10 C stands for? 11 MR. WENTZ: No, I don't believe so. It may be 12 the Cretaceous, but I'm not sure. 13 COMMISSIONER SEAMOUNT: Oh, okay. All right. 14 If you're going to sidetrack a well where would you set 15 the whipstock, do you have any idea? 16 CHAIR FOERSTER: Identify yourself please. 17 MR. NENAHLO: I'm sorry. For the record this 18 is Thomas Nenahlo. We have a CTD development engineer 19 with us today, maybe he would be able to answer that 20 question specifically. 21 CHAIR FOERSTER: Come on up and swear yourself 22 in if you're going to answer a question. Identify 23 yourself, who you're with, what you do and then let me 24 swear you in. And talk into one of the mics. Have a 25 seat. 1 MR. STARCK: Yes, my names Kai Starck, I've 2 worked for ConocoPhillips since 2005 in the 3 (indiscernible) drilling group and I -- since 2012 I've 4 been working as a (indiscernible) drilling engineer. 5 In that regard I guess I'd like to be considered an 6 expert witness on (indiscernible) drilling. 7 CHAIR FOERSTER: Okay. Do you have any 8 questions? 9 COMMISSIONER SEAMOUNT: Where did you qo to 10 school? 11 MR. STARCK: I do not have a degree. 12 COMMISSIONER SEAMOUNT: Oh. Okay. I've seen 13 those bumper stickers that say no college. Okay. I 14 have no questions other than that. 15 CHAIR FOERSTER: Nor do I. Please..... 16 COMMISSIONER SEAMOUNT: And no objections. 17 CHAIR FOERSTER: And no objections. 18 MR. STARCK: Thank you. 19 KAI STARCK 20 called as a witness on behalf of ConocoPhillips stated 21 as follows on: 22 DIRECT EXAMINATION 23 MR. STARCK: The placement of the whipstock 24 would be highly dependent on the original geometry of 25 the well. In general when we decide on placement of E-IM 1 whipstock we want to have competent rock above us to 2 contain the wellbore to the actual formation we're 3 drilling. In general in Kuparuk area we don't do any 4 cementing of our liners, we use a slotted liner 5 completion so that requires having a good, competent 6 barrier above us. So we would place the whipstock 7 below whatever that competent barrier would be. 8 COMMISSIONER SEAMOUNT: Okay. So it's possible 9 that if you did have a problem lineament or temporary 10 fracture or whatever we call them that you would -- 11 could set the whipstock above it, right, I mean, it -- 12 I mean, you could drill through it? 13 MR. STARCK: Yes. 14 COMMISSIONER SEAMOUNT: Okay. That's all I 15 have. Thank you. 16 MR. STARCK: Thank you. 17 CHAIR FOERSTER: I have several questions and 18 they're in a variety of -- I wrote them down, kind of a 19 stream of consciousness approach and so they may be all 20 over the place. I'm going to try to make them as 21 logical as I can. 22 Can you account for all of the MI that was 23 injected? 24 MR. NENAHLO: This is Thomas Nenahlo. So on 25 reservoir material balance it would be approximately -- 1 in terms of a material balance we have approximately 25 2 to 30 percent of MI that potentially leak off either 3 shallow or deep -- or deeper. CHAIR FOERSTER: And so 4 you can't account for 25 to 30 percent of the MI? 5 MR. NENAHLO: In the reservoir material 6 balance. And that's not necessarily MI, but accum 7 injected fluid including water. 8 CHAIR FOERSTER: Okay. Okay. You said that 9 you needed the rules lifted to allow you, you know, new 10 wells and conversions so that you can maximize recovery it from the field. How will the field reserves and 12 recovery change if we lift this, are you going to -- 13 are you going to add reserves, are you going to book 14 new reserves, are you just going to be able to get the 15 reserves you've already booked and after you answer 16 that question what's the quantity that you expect. 17 MR. NENAHLO: Okay. Well, currently we have -- 18 we have two initiatives we're presenting, one would be 19 a pilot CTD well and one would be a well conversion and 20 that would be used to verify the work that we've done 21 so far in terms of linking up an injector and a 22 producer within a channel levy of turbidite lobe 23 complex. So making predictions on all of the 24 development opportunities would be difficult to say at 25 this time in terms of the actual additional reserves we �1. 1 might get before the end of the field life, however we 2 do believe them to be substantial in terms of -- order 3 of magnitude would be thousands of barrels a day. 4 CHAIR FOERSTER: That's rate, not reserves? 5 MR. NENAHLO: Things of rates, yeah, 6 incremental rate. Now what the -- the end of field 7 life would then be extended if we -- if we did pursue 8 this opportunities because currently the wells or a 9 number of the producers are not receiving adequate 10 injection support and we believe that's attributable to 11 the stratigraphic discontinuities that we'd like to 12 overcome. 13 CHAIR FOERSTER: So put that down as a question 14 that we'd like an answer on is what do you -- do you 15 have a projection of incremental recovery, not rate, 16 but recovery, based on changing the rules. 17 MR. NENAHLO: Are you looking for a specific 18 estimate like a number? 19 CHAIR FOERSTER: Yeah, I'm looking for a 20 number. 21 MR. NENAHLO: Okay. 22 CHAIR FOERSTER: Yeah. And would that allow 23 you just to get what's already booked or would you be 24 booking additional reserves as part of that question 25 also. E, 1 I'm trying to keep this in some sort of a 2 logical order, but -- okay, that's good. I'll go in a 3 different direction now. In earlier conversations with 4 Mr. Kanady there had been some concerns expressed about 5 increased potential for shallow gas hazards caused by 6 the earlier injection problems. What is your feeling 7 on the potential for increased shallow gas hazards at 8 this time? 9 MR. KANADY: This is Randy Kanady. At this 10 time we haven't done -- completed a detailed analysis 11 of those hazards and the -- that analysis would be 12 conducted in our well design and delivery process in 13 the FEL one in two phases. 14 CHAIR FOERSTER: Okay. And so when you do that 15 analysis would you include all of the inconclusive 16 results that you presented today? 17 MR. KANADY: Those risks would be taken into 18 account if we were to progress the project forward. 19 CHAIR FOERSTER: What's the worst thing that 20 could happen if you were to drill a new well and you 21 hadn't adequately planned for those -- you hadn't 22 adequately identified the shallow gas hazards? 23 MR. KANADY: Well, you know, the worst thing 24 that would happen is your mud weight would not be 25 adequate to control the pressure of that gas and you M 1 would -- you would take a kick and have to shut-in the 2 BOPs and circulate in a higher mud weight. 3 CHAIR FOERSTER: Well, what would happen if you 4 didn't -- if you did that during the surface hole 5 drilling and you didn't have a BOP? 6 MR. KANADY: Again you would have to address 7 those risks in the well design and delivery process 8 before you..... 9 CHAIR FOERSTER: What if you didn't adequately 10 address them in the design process? 11 MR. KANADY: Well, I think, you know, the 12 Commission knows what the answer would be and..... 13 CHAIR FOERSTER: Well, the record doesn't. 14 MR. KANADY: The -- if you took an unpredicted 15 kick on your surface hole and couldn't control it with 16 mud weight you would have to take that kick through 17 your diverter and potentially lose the well. 18 CHAIR FOERSTER: So you'd have a well control 19 problem, you'd have loss of well control and what we 20 call a blowout? 21 MR. KANADY: Potentially, yeah. 22 CHAIR FOERSTER: Right. Okay. So I just want 23 the record to reflect that that risk is real and it 24 exists. Okay. Let's see. I'll go back to a question 25 that I think is for Mr. Nenahlo. And what is the RE 1 economic limit on production rates for wells in Tarn? 2 MR. NENAHLO: The economic limit? 3 CHAIR FOERSTER: Yes. 4 MR. NENAHLO: The economic limit for Meltwater 5 wells in particular is usually constrained by gas to 6 oil ratio. And so the -- as we increase the gas/oil 7 ratio it becomes less competitive because we have 8 limited space in our facilities for handling that gas 9 and depending on the time of year, you know, in colder 10 months we have more compression capacity so..... 11 CHAIR FOERSTER: So a well that was producing 12 50 barrels a day but had a low GOR could still be 13 competitive? 14 MR. NENAHLO: Would very much be competitive, 15 yes. 16 CHAIR FOERSTER: Okay. So you don't have a -- 17 so the fact that those wells weren't getting pressure 18 support and they were dropping down to 100 barrels a 19 day, that didn't by itself make them non-competitive? 20 MR. NENAHLO: That in itself..... 21 CHAIR FOERSTER: Okay. 22 MR. NENAHLO: .....however there is one point I 23 would like to make for the record is we do have a 24 24 inch PO line and so how we currently have been 25 operating is have seasonal producers. So we bring 1 online -- we shut it in in the summer to bring and 2 build our reservoir pressure on the producers such that 3 we can flush -- provide flush production to the 2P PO 4 line as it needs to cross it miles to reach Tarn 5 production. So those cold ambients, you know, can pose 6 freezing problems if we don't have sufficient rate. 7 And so there could theoretically be situations if we 8 aren't -- we do not pursue the developmental objectives 9 in which we need to shut-in the field during the winter 10 months due to that reason. 11 CHAIR FOERSTER: Okay. 12 MR. NENAHLO: So that would be another economic 13 limited source, but on a higher level. 14 CHAIR FOERSTER: Have you looked into the 15 possibility of gaining connectivity by hydraulically 16 fracturing your existing wells to interconnect the 17 different lenses or would that be just reopening 18 Pandora's Box on exceeding the pressure limits that 19 caused the earlier flows? 20 MR. NENAHLO: Our existing injector completions 21 were not fracture stimulated when they were originally 22 completed. And, you know, we have injectors -- we have 23 an injector, 2P-427 that is outside of the linear 24 feature and so we can model the rates in an unfractured 25 scenario. And we believe that that would be sufficient :' 1 for providing the necessary support to the producers if 2 the stratigraphic barriers are overcome. 3 CHAIR FOERSTER: Okay. I probably didn't ask 4 my question properly. 5 MR. NENAHLO: Oh. 6 CHAIR FOERSTER: Rather than drill new wells to 7 gain communication among the different lobes that 8 aren't currently in communication could that 9 interconnectivity and that communication be gained 10 through hydraulic fractures? 11 MR. NENAHLO: In most cases the fractures would 12 need to be much larger than would be -- in terms of 13 laterally much larger than we'd be willing to pursue to 14 overcome distances that we need to cover to overcome 15 the..... 16 CHAIR FOERSTER: Okay. 17 MR. NENAHLO: .....stratigraphic 18 discontinuities. 19 CHAIR FOERSTER: Okay. So the answer is no? 20 MR. NENAHLO: Correct. 21 CHAIR FOERSTER: That's fine. You talk about 22 feeder channels. Can you map the feeder channels? 23 Identify yourself when you answer the question. 24 MR. BRESSLER: I believe you're speaking to me. 25 This is Eric Bressler. So you're talking about a dip 90 1 on the shelf where we were discussing the source for 2 the sediment? 3 CHAIR FOERSTER: And the channels that go down 4 and create the..... 5 MR. BRESSLER: Yes, those can be mapped in the 6 upper most portions -- up dip portions of the field and 7 then beyond up onto the shelf, outside of the reservoir 8 area. 9 CHAIR FOERSTER: So when you inject into the 10 lobes will the injection stay in the lobes or will it 11 -- does it have potential to move up into the feeder 12 channel and go other places? 13 MR. BRESSLER: Well, presumably, I mean, 14 outside the reservoir area the permeability would be 15 much less and I guess it's not my area of expertise to 16 answer that, but I..... 17 CHAIR FOERSTER: So you're thinking a 18 permeability decrease would be the barrier for..... 19 MR. BRESSLER: I believe so. 20 CHAIR FOERSTER: Are all the inconclusives that 21 you mentioned due to a lack of data or poor data or a 22 combination thereof? Identify yourself. 23 MR. WENTZ: This is Robert Wentz, I'll answer 24 that. And I'm assuming you're referring to the 25 overburden characterization studies? 91 1 CHAIR FOERSTER: I'm referring to every time 2 you said well, we looked at this, but we got 3 inconclusive data. So anybody who made that statement 4 might want to chime in with their own answer. 5 MR. WENTZ: The lack of data pertains primarily 6 to the overburden characterization. Traditionally in 7 the petroleum industry data acquisitions focus 8 primarily on the producing reservoirs or in the field 9 development. In he Meltwater development a full suite 10 of open hole logs covers the Bermuda section along with 11 conventional core which is actual rock data. The 12 portions of the borehole outside of the reservoir, 13 particularly the overburden above, normally contain 14 less than a full suite of a logs. There's -- there is 15 a full suite in some wells and in the case of the 16 Meltwater field there is no conventional core outside 17 of the reservoir. Currently well logging devices can 18 indirectly measure geomechanical properties of the 19 rock, but actual rock sample measurements are needed to 20 fully calibrate the data in order to fully understand 21 the geomechanical processes. 22 CHAIR FOERSTER: So given what you know now if 23 you had it to do again would you do it differently, 24 would you gather different data or more data? And this 25 is a question for our learning so that as we move into 92 1 development of fields we know what kinds of 2 requirements to make, put upon operators. 3 MR. WENTZ: I believe in the industry that is a 4 trend that the overburden sampling is done now to 5 forego problems like this based on what the industry 6 has learned. 7 CHAIR FOERSTER: So you would -- you would do 8 it differently now going with what you've learned. 9 Okay. 10 MR. WENTZ: That's hard to say for every field 11 case, but generally, yes. 12 CHAIR FOERSTER: Okay. Does anybody else want 13 to weigh in on this? 14 (No comments) 15 CHAIR FOERSTER: Okay. What's the source of 16 the biogenic gas that you -- to which you refer? 17 MR. WENTZ: Earlier you were asking where that 18 gas had come from. During the drilling of the well mud 19 logs were run and we saw indications of gas throughout 20 multiple levels of the overburden and varied from well 21 to well in differing amounts. I'm not sure exactly 22 where that gas has come from other than those multiple 23 layers throughout the overburden. 24 CHAIR FOERSTER: So these were in the initial 25 wells you identified, that's not in subsequent wells? 93 1 MR. WENTZ: The -- all the wells as they were 2 drilled. 3 CHAIR FOERSTER: Okay. Starting from the very 4 first -- those three that are now plugged and 5 abandoned, those three discovery wells? 6 MR. WENTZ: I believe so. I'd have to go back 7 and..... 8 CHAIR FOERSTER: Okay. That would be a 9 question I'd love to get the answer to so write that 10 one down. And as you move into lean gas injection how 11 will you identify the biogenic gas versus the injected 12 gas, I mean, since you won't have those heavy markers? 13 MR. NENAHLO: Correct. So working with..... 14 CHAIR FOERSTER: This is? 15 MR. NENAHLO: I'm sorry. This is Thomas 16 Nenahlo. Tracers, gas tracers are a viable option to 17 use for that scenario. And..... 18 CHAIR FOERSTER: Are you planning on putting 19 tracers into your injection? 20 MR. NENAHLO: We have not solidified plans at 21 this moment. I have worked with a contracting company 22 to ensure the feasibility of that and we do have -- it 23 is feasible to use gas tracers for the outer annulus 24 gas analysis as well as producer to injector 25 interactions. I 1 CHAIR FOERSTER: Okay. Okay. You mentioned 2 that two wells still have increased pressure, which two 3 wells are those? 4 MR. NENAHLO: Those are well 2P-447 and 2P-431 5 as we're currently, you know, performing that extended 6 bleed as I had shown in the presentation and I can go 7 back to that slide if you like, we haven't..... 8 CHAIR FOERSTER: Go ahead. 9 MR. NENAHLO: .....let since -- would you like 10 me to go back to that slide? 11 CHAIR FOERSTER: No, no, no. 12 MR. NENAHLO: Okay. So I'll start with 2P-431. 13 We began bleeding it back March 7th of 2015 and we had 14 a short shut-in duration. During the CPF 2 shutdown it 15 rose to around eight to 900 psi, but then we returned 16 it to the -- to the bleed after we brought the facility 17 back online. So we don't know its true stabilized 18 pressure anymore. Historically it had been about 1,500 19 psi at surface. The gas composition we were monitoring 20 on a weekly basis and the gas composition is staying 21 steady and it's not showing influence from our lean gas 22 injection operations which indicates -- you know, 23 preliminarily indicates we're not being -- that source 24 that's charging the 2P-431 outer annulus is not being 25 supplied by the reservoir interval..... 95 1 CHAIR FOERSTER: The pressure increased 2 occurred..... 3 MR. NENAHLO: .....we're injecting in. 4 CHAIR FOERSTER: .....during the shut-in? 5 MR. NENAHLO: Right. Just due to the -- if you 6 wouldn't mind I can go to the..... 7 CHAIR FOERSTER: Oh, go back to the slide, 8 that's fine. 9 MR. NENAHLO: Okay. We're on slide 26 and the 10 maroon is the bleed rate and the red is the outer 11 annulus pressure. So you can see that we -- when we 12 shut-in the well it started to rise and we also, you 13 know, shut-in the bleeder cores as the facility was 14 shutdown and then when we restarted it it's been 15 producing intermittently since then indicating that the 16 source is starting to die out, but we still need more 17 time to evaluate this. 18 CHAIR FOERSTER: So what makes you think it's a 19 thermal effect? 20 MR. NENAHLO: 2P-431? 21 CHAIR FOERSTER: Yes. You said that you had 22 two wells that had higher pressure and you said that 23 the increase was just thermal. So what makes you think 24 that's thermal? 25 MR. NENAHLO: Oh, sorry. Not this well, this -- M 1 are you referring to the interim progress report or 2 you're referring..... 3 CHAIR FOERSTER: Earlier in your presentation 4 one of you said that there were two wells that had -- 5 still had increased pressure, but it was simply 6 thermal. And so those are the two wells I wanted you 7 to identify and explain why you thought they were just 8 thermal. 9 MR. NENAHLO: On our injection wells we 10 believe..... 11 CHAIR FOERSTER: I don't recall which wells. 12 Well, you didn't identify them, you said that there 13 were two wells that had increased pressure that you 14 felt that the increase was thermal. So I'd like you'd 15 to tell me which two wells those are and why you think 16 it's thermal. 17 MR. NENAHLO: So 2P-429 and 2P-434 would be the 18 thermally affected wells. 19 CHAIR FOERSTER: Okay. So what were the 20 numbers of the wells again? 21 MR. NENAHLO: 2P-429, 2P-434. 22 CHAIR FOERSTER: And so you actually have four 23 wells that have increased pressure? 24 MR. NENAHLO: Well, I guess I need to make sure 25 of the question. So are you referring to above the 97 1 thousand psi limit or below the thousand psi limit? 2 CHAIR FOERSTER: I'm just referring to what you 3 said in your testimony. 4 MR. NENAHLO: Okay. 5 COMMISSIONER SEAMOUNT: It's slide 23. 6 MR. NENAHLO: Oh, okay. Those specific wells 7 and so the context of that..... 8 CHAIR FOERSTER: Which two wells are those? 9 MR. NENAHLO: So that is well 2P-424 and I have 10 to take a look at the -- I don't have that information 11 on the second well with me. 12 CHAIR FOERSTER: Oh, so now we've got five 13 wells or maybe six. 14 MR. NENAHLO: Sorry. Let me..... 15 CHAIR FOERSTER: You've got 2P-447, 431..... 16 MR. NENAHLO: .....let me refer to the..... 17 CHAIR FOERSTER: .....429, 434, 424 and 18 possibly a sixth well. 19 MR. NENAHLO: So I can -- let me work through 20 each well individually if you don't -- I can get 21 through the interim progress report. 22 CHAIR FOERSTER: Okay. I think so that I allow 23 you the time to do this with clarity and no pressure, 24 what I would like to hear form you is for the five 25 wells that you have named today and the potential sixth 0 1 well that this slide refers to I would like to know -- 2 get a characterization of the pressure and if you still 3 have increased pressure an explanation of why you think 4 that is so and if you think it is thermal the 5 justification for why you think it is thermal. So 6 that's something that we'll get from you, but not right 7 now because I don't think you want to do that technical 8 analysis while everybody's staring at you. MR. 9 NENAHLO: Okay. 10 CHAIR FOERSTER: Is that fair? 11 MR. NENAHLO: Yes, that's fair. 12 CHAIR FOERSTER: Okay. We'll move on. Another 13 thing that we'd like to have submitted that we don't 14 need right now, but with the answers to all the other 15 questions please submit a well schematic for what a 16 typical completion would look like in a grassroots 17 well, in a coiled tubing sidetrack well and in a 18 conversion and in any other configuration that you 19 might deem possible. 20 When we do AIOs we often do -- okay, areas of 21 review. How would ConocoPhillips feel about a rule 22 requiring an area of review for any new wells in the 23 Meltwater pool. Now I'm asking for your feelings, but 24 to the degree that you feel comfortable answering that 25 questions I'd appreciate an answer. • 01 1 MR. NENAHLO: I'm not familiar with an area 2 review. Like what would be the specifics of that? 3 CHAIR FOERSTER: It would be looking for 4 shallow gas hazards, it would be looking for mechanical 5 integrity of all wells within an affected area, that 6 sort of thing. 7 MR. NENAHLO: Yeah, I believe certainly that 8 would be included with our well design and delivery 9 process review. 10 CHAIR FOERSTER: So if we were to make that a 11 requirement that wouldn't be something that would be 12 unduly burdensome to ConocoPhillips? 13 MR. NENAHLO: No. 14 CHAIR FOERSTER: Okay. I think we're nearing 15 the end. Just -- I'd like to close out with one more 16 opportunity for ConocoPhillips to characterize in 17 laymen's terms an explanation of the mechanism that 18 caused the initial concerns, just something that the 19 Petroleum News reporter could understand because if he 20 understands it I have a reasonable amount of confidence 21 that I'll understand it too. So whoever wants to take 22 that one. 23 MR. NENAHLO: Okay. So this is Thomas Nenahlo, 24 I can take that question. So what we believe was the 25 ultimate reason for fluid migration out of zone was we 100 1 had injectors and producers and between them we had 2 stratigraphic barriers we were seeing in field 3 operations, you know, before my time. We had producers 4 out running injection support and we injected at a 5 pressure well above our current sand face injection 6 pressure limit. And likely this broke down the 7 reservoir or broke down the seal and we had leakage of 8 injected fluids vertically. 9 CHAIR FOERSTER: Thank you. Commissioner 10 Seamount, did I inspire any additional questions from 11 you? 12 COMMISSIONER SEAMOUNT: No, you certainly did 13 not. 14 CHAIR FOERSTER: Okay. Well, thank you for 15 your patience with all of our questions, thank you for 16 a thorough presentation, thank you for identifying 17 every one of your slides. 18 And at this point I'll ask if there is any 19 other person in the audience who would like to testify? 20 (No comments) 21 CHAIR FOERSTER: Okay. We've given you a 22 number of questions that we -- and we'll need an answer 23 from before we can proceed with your request. Will one 24 week of leaving the record open be sufficient, did you 25 need two weeks, how much time does ConocoPhillips need 101 1 -- think you'll need to answer the questions that 2 remain unanswered? 3 MR. NENAHLO: I think one week will be 4 sufficient. 5 CHAIR FOERSTER: Okay. Well, we will leave the 6 record open for seven calendar days from today and 7 expect answers to all of the questions that we've asked 8 by then. And should ConocoPhillips need additional 9 time we'll need a request in writing to keep the record 10 open longer and so that we can do that. it All right. Then if there's nothing else for 12 the good of the order then at 11:38 this hearing's 13 adjourned. 14 (Recessed - 11:38 a.m.) 15 (END OF PROCEEDINGS) 102 • • 1 TRANSCRIBER'S CERTIFICATE 2 I, Salena A. Hile, hereby certify that the 3 foregoing pages numbered 02 through 103 are a true, 4 accurate, and complete transcript of proceedings in re: 5 Area Injection Order AIO 21A public hearing, 6 transcribed under my direction from a copy of an 7 electronic sound recording to the best of our knowledge 8 and ability. 9 10 Date Salena A. Hile, Transcriber 11 103 Iv-.1" ConocoPh*1111*PS • Meltwater Area Injection Order 21A Amendment Hearing ConocoPhillips Alaska Meltwater Team 0 Thursday, July 9th, 2015 Meltwater A10 Chronology w August 2001: Original A10 21 Issued w January 2002: Injection Operations begin w April 2002: Increase in OA pressures w 2003: Completed investigation into the source of the increase in OA pressures w 2003 — 2011: ■ ConocoPhillips managed OA pressures through a number of initiatives ■ Provided periodic updates to the AOGCC w Spring 2012: Identified likely migration of fluid out of zone with 4D seismic w Summer 2012: Containment Initiatives Kicked Off w October 2012: CPAI requested Amendment to A10 21 ■► May 2013: Amended A10 21 Issued w April 2014: Interim Progress Report Submitted w April 2015: Interim Progress Report Submitted w April 2015: NO 21A Request for Amendment Submitted ConocoPhillips Summary of Requested Amendments to A10 21A 10 CPAI requests the following amendments to A1021A ■ The allowance for Producer -to -Injector conversions (Rule 2) ■ The allowance to drill wells within the Meltwater Oil Pool (Rule 2) ■ The allowance to use PW and SW for well and surveillance work only (Rule 8) • ■ To change the monthly reporting requirement to annual reporting (Rule 9) ■ To eliminate the expiration date on the A10 (Rule 11) 0 3 w.wu•..uu..u.o. ConocoPhillips Presentation Outline w Meltwater Field Overview ■ Facilities ■ Operations ■ Geoscience w Meltwater Containment Initiatives ■ Operations ■ Well Integrity ■ Reservoir Management Strategy ■ Surveillance ■ Overburden Characterization m Development Objectives • w Requested Amendments to AIO 21A w Closing Remarks • ConocoPhillips 0 Meltwater Operations Operator and Surface Owners within One Quarter Mile of Injection Operations ow Operator: ConocoPhillips Alaska, Inc. m Surface Owner: State of Alaska �► Working Interest Owners ■ ConocoPhillips Alaska, Inc. ■ BP Exploration (Alaska) Inc. ■ Chevron U.S.A. Inc. ■ ExxonMobil Alaska Production, Inc. "'•"""' ConocoPhillips • Meltwater Field Wells Meltwater 2P Pad Location 2P-451 • 2P-448 + 2 P-448A 2P-434 0 2P-443 O MWN 2A 2P 417 2P-420 ♦ 2P-406 • OMWN 2 2P415A 2P-432 � • + 2P-415 2P-422A 2P-447 0 2P-441 + 2P-422 2P-449 2P-438 ♦ 2P-429 2P-424 OMWN 1 2P-427 ♦ 2P-41902P-431 ♦ : P-424A LEGEND 2.4001.200 0 2.400 Feet • PRODUCER ♦ INJECTOR N + PLUG & ABANDON MELTWATER PARTICIPATING AREA Discovery Well: ■ Meltwater North 2 (2000) Delineation Wells: ■ Meltwater North 2A ■ Meltwater North 1 Meltwater Field ■ 13 Producers ■ 6Injectors ■ 4 Abandoned Bore Holes ConocoPhillips • Meltwater Operations Meltwater Facilities ow 8" Miscible Injectant/Lean Gas Injection Line w 12" Water Injection Line (SI) w 24" Production Flowline w Gravel Road and Pad .,eo 24� Po Ti •••► 24" PO w 4 Bridges _12" WI.10" Wi w 1 Drill Site -•' �, _..--.. __.. m Overhead Powerline •••• 2L `4-Corners" Intersection O CL � I Meltwater 12" WI line proactively shut in 000000 . 4 • • . "Tam DS's" • — .. — lam Pipelines • C4 r . Meltwater Pipelines a • • a • a • • ` "Meltwater" CPF ConocoPhillips 0 • Meltwater Operations Drill Site Facilities m Trunk and Lateral Well Manifold ■ Production ■ Test ■ Water Injection (WI line to Meltwater currently shut-in) • Miscible Injectant ■► 20' Wellhead Spacing w Conventional Well Test Separator w Remote Well Test Actuation° t d� a w Remote Control of Well Chokes w Emergency Shutdown (ESD) Skid Electrical/Control Room �7_ 0 Meltwater Operations Sand Face Injection Pressure Limit Set at 3,400 psig M Designed to ensure containment of injected fluids M Predicated upon FIT data Meltwater FIT/LOT Data - Sorted Deep to Shallow - 20 Production■ 19 .Surface Casing FIT FIT 18 — = Sand Face Injection Pressure Limit j FIT 0. 17 a FIT FIT 16 fA L 15 a H u, 14 H Q 13 FIT FIT FIT 12 11 10 Qi°a Qc°a Qt°a Q`°a a,$ °yy °a"b ,115 tiQ tiQ tiQ tiQ°tiQ tiQ tiQ tiQ tiQ tiQ tiQ tiQ tiQ tiQ tiQ tiQ tiQ tiQ ��a ,�QA�,�� tiQ tiQ tiQ tiQ ConocoPhillips is is U. ConocoPhillips iiiwiw.o..• Meltwater Field Meltwater Field CI Kuparuk River Unit N Meltwater Participating Area 2 Miles SW NE o M Key Fields 2 N O Q V U 50 Y Z 65 o W Co Gp. West Sak o� o O 96Nanush P _Tabasco Tarn / Meltwater otF vd wHRZ HueSh.Q Kuparuk River 144 Alpine a U oLL u> N Nechelik W Kingak Fm m 20 Shublik Fm. River Ss TRIASSIC �— ' Sa lererochit G Prudhoe Bay Z Q W 245 . ¢ c) W Z PERMIAN 2 � w O PENNSYLVANIAN 2e6 j N 320 Lisburne GP. Endicott w ISSISSIPPIAN 360 • • Meltwater Field Structural Cross -Section A NW 2P-434 2P-417 2P-422A 2P-422 4eoo . 5500 s6ao . 51ro � f 5800 s9oo 5200 net pay 50' av porosity 20.7% av perm 7.9 and Sw 48% 4800 4800 5100 6300 � � r 4900 4900 5200 T4.2 64W T4.1 ,s 5000 5300 6500 sloo �.; T3.1 T3 520U - 5300 5600 5400 + 131 i 5200 6700 1 i E�111 net pay 85' o „W . av porosity 20.7 /o av perm 7.3 and pay ay 4$' o Sw 48 /o av porosity 19.60/ ­ 1 1 av Perm 4.0 and A' SE 486.. 7400 1. 7500 r` 49W 7600 5000 7700 7M Gross Bermuda Reservoir 8100 5300 8200 s3o0 r ,. p ESon ,� Fos ible f It U 55Q R600 �. 5600 8700 :. 9800 5700 13 .......H : .......... :� 0.. ConocoPhillips ....ON • - Geophysics - • q.,., Cono4hillips AL............. 4300 4400 4500 4600 4700 4800 4900 5000 5100 5200 5300 5400 5500 5600 5700 9800 Conoco -Phillips ........ •iiiiiuwuu.. Bermuda Stratigraphic Complexity w Bermuda reservoir compartmentalized by turbidite lobe deposits 2P�A4i 1:20000 4 1 K;LOMETRES U y 2 MILES • • Meltwater Field Geoseismic Section Cono4hillips • 0 E Containment lnlktifrv, ......... ConocoPhillips Summary of Meltwater Containment Initiatives w CPAI has implemented two primary initiatives and is pursuing a third ■ Initiative 1: Sand face injection pressure limit started in 2012 ■ No indication of further MI migration, predicated upon: ■ Average reservoir pressure decline ■ Decline in Meltwater outer annulus pressures ■ The composition of the outer annuli gas becoming less similar to MI ■ Isotopic analyses indicating the outer annuli gas becoming more similar to biogenic gas ■ Surveillance logging verification of the integrity of the completion in all six injectors ■ Initiative 2: Reservoir Containment Assurance Project ■ Created and evaluated a Subsurface Containment Matrix that enabled the qualitative assessment of the five key elements of containment ■ Wells ■ Reservoir and Overburden Characterization ■ Field Management/Surveillance ■ Operations ■ Action/Mitigation Planning E ■ WellTrak Program ■ Initiative 3: Place injectors and producers within the same turbidite lobe deposit through is Coiled Tubing Drilling sidetracks and well conversions ■ This will reduce the effect that stratigraphic discontinuities between individual lobes have on the differential pressure between injectors and producers ■ Will require approval of WIOs and the AOGCC ... . ..... . 19 ConocoPhillips :............. Ensuring Safe Operations & Well Integrity m Continuous Outer Annuli (OA) Pressure Monitoring ■ Advisory and critical alarms set to alert Operations of changing conditions m Surface Casing (SC) Integrity Investigation in 2013 ■ Objective: ■ To determine the extent of the SC corrosion at Meltwater ■ Conclusions: ■ The 2012 213-406 SC leak was attributable to a thread leak, not corrosion ■ Meltwater wells are effectively protected from corrosion by sealant ■ The corrosion rate on the SC is very low ■ The safety risks associated with excavation are greater than any potential benefits ■ Future inspections will be conducted to continue to monitor the corrosion rate w In 2006 a corrosion inhibiting sealant was installed in all 2P conductor casings w Operator Awareness Training • RG-2401 CorrosionInhibiting ..;;......... ..; 20 ....::::.. ,,,�.g;;;;;;;;;;;;; ConocoPhillips Reservoir Management Strategy Strategy: ■ Sand face injection pressure limit of 3,400 psig put in place in 2012 ■ Based on FIT/LOT data from wells in which the production casing was set at the top of the Bermuda interval Monitoring Plan: ■ WHIP monitoring with advisory and critical alarms set to alert Operations of changing conditions ■ Injection -withdrawal monitoring ■ Cum I/W has decreased —6.5% from 2012 to 2015 ■ Bermuda formation pressure surveillance 5000 00 4500 $pOg r 4000 ♦ ♦♦� 3 3500 a` 3000 • ♦� • M • • ♦ • 2500 : • j •• • ♦ c M • E 2oo0 �� • • • • • • • • 9 o U- 1500 • • • ♦ • • M: • • • • • • d • • • • • •� •• • • 1000 •� • • e f N •• • • 6 op 500 • ,'� • 0 CPy CPS CQ� C�y {� O' 00� OHO Oti1 Oti1 Oti3 Otib Otih Orb 1. Me� `OQ'�, `Oe� �� �� '6¢� `d✓� `C�� .�F` `(� .peg .peg ,p¢� `�� O OQ O O O O O O O O O O O O O O O • Producers ♦ injectors —Bermuda Formation Pressure Limit Bermuda FormationPressure U 21 "'::::: ConocoPhiliips • Monitoring Program for Shallow Intervals �► Un-cemented production casing annuli and open surface casing shoes ■ Allows for the monitoring of pressure and gas composition changes in shallow intervals Meltwater 2P-Pad 434 443 1 mile N-2A 448Pg417 406 :;""' -----a 451�✓::; 420 N-2 •_. 415A 415 448 ' • ' 448A fl i 422k 441 ref 4, `.422 447 449 0 J b429,`: 438 424 N-1 431 419 427 0 424A • Monitoring Program for Shallow Intervals �► Outer Annulus (OA) Monitoring Program • Continuous monitoring of pressures ■ Quarterly fluid levels ■ Semi-annual pressure bleeds ■ Semi-annual gas composition analyses (through July 2014) ■ Isotopic gas analyses w Outer Annulus Pressures ■ Decrease in OA Pressure: 11 of 19 wells ■ No Change in OA Pressure: 6 of 19 wells ■ Increase in OA Pressure: 2 of 19 wells Injectors returned to service 0 +d° iA� AO O°j 10 11 11 1� 1p Sh —Mel twater Average OA Pressure Meltwater Average Outer Annulus Pressures """ ConocoPhillips • • Monitoring Program for Shallow Intervals m CIA Gas Composition Analyses ■ No wells have shown an increasing similarity to MI m CIA Gas Isotopic Analyses ■ Isotopic analyses performed in 2002, 2005, and 2012 • ■ Analyses in 2012 shows less MI and more biogenic gas than in 2002 and 2005 2Q-429 oA Gas Compositon is �° Rar tCP �o� Meltwater CIA Gas Composition Analysis 24 ............� Verification of Production Casing Cement Shoe Integrity ft Utilized surveillance logging to verify the integrity of the production casing cement shoe w Tested the shoe over a range of sand face injection pressures and rates w No indication of fluid movement above the perforations detected ■ All injectors have been tested • 11 4,000 Ib a 3,500 43 3,000 a+ 2' c i 2P 419� 2' o 2P-420 A 2P-427 c O 2P-429 1,500 • 2P-434 i 2P-447 1,000 —Sandface Pressure limit nI v7 L IX 0 Flow Scenario for TDM3D Impulse Test Tool 1 1,000 2,000 3,000 4,000 5,000 6,000111 8,000110 Rate (STBD) Water Activation Logging Summary • 2P-431 OA Extended Bleed m 213-431 has historically had the highest outer annulus pressure (N1,500 psig) w Began extended bleed on March 7t", 2015 CPF2 Shutdown Begins w Bleed rate has shown a declining trend • • Yll r7" Overburden Characterization Study m Initiated in late 2012, completed in January 2015 m Goal was to better understand the containment system and explain the processes of fluid propagation into the overburden m Additional goal of understanding the 4D seismic linear features • m Studies largely performed by Houston Technology groups and Meltwater technical team w Specific Initiatives ■ Static Description of the Overburden ■ Critical Stress Modeling ■ Mechanistic Overburden Modeling ■ Completions Analysis ■ Geomechanical Analysis ■ Seismic modeling Overburden Characterization Study — Results w Numerous technologies applied w Initiatives were highly data -constrained which provided quantitatively inconclusive results ■ Model construction required key input parameters having large uncertainties • ■ Uncertainties resulted in inability to provide a conclusive determination as to the mechanism that allowed propagation of fluids into the overburden w Modeling supported interpretation of out -of -zone injection ■ Unable to provide additional insight into processes of fluid propagation into the overburden """""" ConocoPhillips 0 Static Description of the Overburden w Meltwater Field located on the Central North Slope w Complex tectonic history w Multiple normal fault sets in stratigraphic column N ■ Jurassic -Cretaceous WNW -striking (deep) ■ Early Tertiary NNW -striking (shallow) 40 ■ Similar trend to 4D seismic lineaments �� 1w Fault Enhanced Volume (FEV) MA SW NE Late Tertiary(?)Extension �0 interpretation v N j�r—� Eocene Extension 'o — Early Tertiary Stress //•.---,►� v � -. J-K Rift Extension Kingek Fmk_ TWASSIC - Sidiirocl�it Cp gas wi PERIAIAN 1 PEWRYWAN J W 3?J /� OP. J 9) Ellesmerian Extension Critical Stress Modeling w Critical Stress Modeling ■ Possible indicator of potential for slip reactivation on existing faults and fractures ■ Faults at or near critical stress may be more likely to contribute to fluid flow ■ Models can aid in the identification of faults most prone to be critically stressed ® Can offer insights into how much pressure would be required to reach a critical stress state • w Results ■ Principal stress directions and magnitudes are under -constrained ■ Regional maximum horizontal stress (SHmax) ranges from WNW -ESE to NNW -SSE ■ 4D seismic lineaments appear aligned with SHmax trending NNW -SSE ■ Difficulty in knowing static stress state and changes in stress state dynamically contributes to a large uncertainty in the critical stress analysis ■ Large uncertainty in stress magnitudes make interpretations of excess fluid pressure values inconclusive 0 ......:::::::: "" ConocoPhillips Mechanistic Overburden Modeling & Completions Analysis w Mechanistic Overburden Modeling ■ Focused on evaluating overburden material balance ■ Model tested whether MI migration was possible through high permeability fractures in the overburden ■ Limited data characterizing the overburden and full -field extended reservoir made results S inconclusive m Completions Analysis ■ 3D planar fracture geometry model used to simulate estimated surface pressure and injection profiles ■ Modeling indicated hydraulic fractures likely grew into overburden ■ Limited by lack of data characterizing the overburden and full -field extended reservoir ■ Supports interpretation that initial migration of injected fluids out of Bermuda interval was a result of large pressure differential between injectors and producers Geomechanical Analysis w Geomechanical Analysis ■ Evaluated scenarios where hydraulic fractures could be induced by field injection operations or through reactivated regional faults, or combination of both ■ Discrete fracture network model constructed ■ Tool allows for 3D propagation of hydraulic fracture in a geocellular model i ■ Simulation considered general fluid and injection conditions within framework of geomechanical interactions ■ Limited data characterizing the overburden and full -field extended reservoir made results inconclusive • ................ ConocoPhillips ................ Seismic Modeling w Seismic Modeling ■ Performed to better understand the cause of the observed 4D time -shifts at Meltwater ■ Also used to assess the ability of seismic to detect a reduction in gas or a related mitigating change in the overburden w Conclusions ■ Gas alone does not account for the observed time shifts ■ Fractures are required to match the modeled time shifts to the 4D seismic ■ Seismic would be poorly suited for confirming a reduction in overburden gas ■ P-wave velocity is not sensitive to gas concentrations when gas is present in excess of 3-5% of pore volume 0 • E Inter -well Communication m Meltwater reservoir compartmentalized by channelized turbidite lobe deposits To overcome stratigraphic barriers, CPAI is considering/studying well conversions and CTD sidetrack opportunities 1:20000 q t KILOMETRES 0 1 MILL E 5 36 ..:.............. ConocoPhillips r� • Inter -well Communication w Example of effective inter -well communication .ACKE."'M UWAW VON r iFVW 60'M OW M s:2aooa ¢ C .44VCIN(1i � r 4at'1 wxa �as.ea ww � fRrAti +�,�� anon ?+�t m*cw sraieainw 0 —'� 2P-azo ��. .. 9.9-9999P ConocoPhillips 0 Inter -well Communication 1,600 1,400 1,200 �0p y 1,000 SW W 600 a 400 200 By having an injector and a producer within the same turbidite deposit, a significant improvement° in reservoir performance can be achieved. , ' X. O~p Otih �V-4170iIRate—2P-4341nj*a1onRaft ;N 16,000 14,000 12,000 d 8,000 `o 6,000 w d C c 4,000 2,000 ,mom AL = 2P-434 Injector • = 2P-417 Producer ....... 38 .... ;;;;;,,;g;;g;;;;;' ConocoPhillips • • Inter -well Communication w Example of less effective inter -well communication 2P-d 2P-44 iR-447 I t. 1-44946, .: t,A ,. `Y5 as '�.i'�1� ✓�� , w u� • 11 • [ 2:wiFt Y rim. iWL W .- WiflYwy�• 1PW-RLIB 4i�6GU 39 am_ ConocoPhillips ............ Inter -well Communication Stratigraphic heterogeneities negatively impact production rate 4,000 3,500 Wo 3,000 s 2.500 p 2AW it 1,500 8 1,000 62Z 14.000 12,OW 4,000 2,000 o o otiti p�ti otiti �ti otiti o{L oti�. .,ti o�^, ati^, oti^r ti^, otis 0�► otia �s o�h a.�h otih •Oil Production Rate OGas Injection Rate A = Injectors 40 = Producers C, Meltwater Production History w Significant production decline in Western Meltwater attributed to compartmentalization ■ May be possible to overcome with well conversions and CTD sidetracks 0 0 Meltwater Reservoir Boundary Map • • ConocoPhillip Requested Amendments to A10 21A w CPAI requests the following amendments to A1021A ■ The allowance for Producer -to -Injector conversions ■ The allowance to drill wells within the Meltwater Oil Pool ■ The allowance to use PW and SW for well and surveillance work only • ■ To change the monthly reporting requirement to annual reporting ■ To eliminate the expiration date on the AlO 0 ConocoPhillips :::........ Requested Amendments to A10 21A w Existing Rule 2 - Fluid Injection Wells: New wells and production -to - injection conversions are prohibited in the MOP. ■ Proposed Rule 2: ■ "Development well sidetracks are permissible when drilled within the MOP. Well conversions is are permissible in the MOP." ■ Alternative Option: Modify Rule 2 to Original A10 21 Rule 2 Language ■ "The underground injection of fluids must be through a well 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. " • r..oru..uu.. •r....u.u.urr.r �- Cono4hillips Alternative to Proposed Modification of Rule 2 m Replace existing Rule 2 by reverting back to original A10 21 Rule 2: ■ The underground injection of fluids must be through a well 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. Any proposed well at Meltwater would go through the CPA's Well Design and Delivery Process w The Well Design and Delivery Process (WDDP) establishes a set of standards and guidelines for the delivery and operation of all ConocoPhillips wells. It is a structured process which leverages multi -discipline expertise and continuous improvement in an organized way to deliver safe, efficient planning and delivery of well work across ConocoPhillips w The six phases in the WDDP are: ■ FEL-0: Explore ■ FEL-1: Appraise • ■ FEL-2: Select ■ FEL-3: Define - Permit to Drill ■ Execute: Well Construction ■ Operate: Post Well Reviews ow MaxBook is a Drilling and Wells project management tool used to track the WDDP '�• ,;;;;; ConocoPhillips Requested Amendments to A1O 21A w Existing Rule 8 — Authorized Fluids for Injection: Fluids authorized for injection are: ■ Miscible injectant ■ Dry gas provided by the Kuparuk River Unit • ■ Tracer survey fluid to monitor reservoir performance ■ Fluids injected for stimulation purposes per 20 AAC 25.280 (a)(2) ■ Glycol from hydro -tests and freeze protection ■ Diesel used for freeze protection ■ Methanol used for freeze protection ■ Standard oilfield chemicals (corrosion and scale inhibitors, defoamers, emulsion breakers, etc.) ■ Proposed modification to Rule 8 is to add the following fluids to the list of authorized fluids: ■ "Beaufort seawater for surveillance, logging, near-wellbore formation displacements, and well maintenance; and 0 ■ Kuparuk River Unit produced water for surveillance, logging, near-wellbore formation displacements, and well maintenance." Requested Amendments to A10 21A w Existing Rule 9 — Performance Reporting: The Operator shall submit to the AOGCC a monthly report detailing the daily monitoring of all Meltwater Oil pool wells. Included in the monthly report, the Operator shall submit OA fluid levels, well pressures, injection and/or production rates, and pressure bleeds for all annuli. Trends shall be evaluated and detailed. In addition to the conditions listed in the above rules the Operator shall provide by April 15t of each year an interim progress report that provides an update on the status of the overburden characterization study, a synopsis of the monitoring data collected during the previous year, and a detailed analysis of the effects on ultimate recovery of switching from an MWAG project, as authorized by AIO 21, to the current MI injection only project. ■ Proposed Rule 9: ■ "The Operator shall submit an annual synopsis of the surveillance, monitoring, and development initiatives completed during the previous year that pertain to the confinement of injected fluids within the Meltwater Oil Pool together with the Meltwater Annual Surveillance Report:' 0 Existing Rule 11— Expiration Date: This order shall expire 24 months after the effective date shown below (May 16, 2013) ■ CPAI requests that Rule 11 be removed and that A10 21A have no expiration date. .....:.: 47 'ii"""""" ConocoPhillips iii..i.i..... Closing Remarks Containment initiatives in conjunction with geologic and production data analyses indicate there has been no further migration of injected fluids out of the Meltwater Oil Pool. 0 ■► Well conversions and sidetracks utilizing coiled tubing drilling may further reduce the risk of migration of injected fluids while optimizing hydrocarbon recovery. The requested amendments are based on sound engineering and geoscience principles, will further mitigate the risk of the migration of injected fluids out of the MOP will increase g J ultimate hydrocarbon recovery, will not promote waste or jeopardize correlative rights, and will not result in an increased risk of fluid movement into freshwater. • • .......::Hal 49 ............M. 'e n.rr.ar.wuur J • 0 STATE OF ALASKA OIL AND GAS CONSERVATION COMMISSION Public Hearing Docket Number: AIO 15-015 Kuparuk River Field, Meltwater Oil Pool Amendment to AIO 21 A July 9, 2015 at 9:00 a.m. NAME AFFILIATION Testify (yes or no) 52 n�2 2 Ca&c -- � -FAQ cC c Q C'kris Lj"ace A-o c.cc n o VuMp % AVVAA,_ Cb10Q-0 pA�V10 Cjl &Nc,Lc-c \�,Ra 0<-Wy LF£ n "o iTOV OU 1A)EN7� ityr 5 YOI�Y it NO A�o.r' -3 p6raktu w. �)c" K)-,-, 0 • Continuation Page NAME AFFILIATION TESTIFY (Please Print) (Yes or No) G: S cAn CZ cc ho 9 0 • ConocoP *I ips Alaska April 14, 2015 Cathy Foerster, Commissioner Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, AK 99501 i • APR 14 2015 Kazeem A. Adegbola Manager, GKA Development North Slope Operations and Development Office: ATO-1326 700 G. ST. Anchorage, Alaska 99501 Telephone: 907-263-4027 E-mail: Kazeem.A.Adegbola@ConocoPhillips.com RE: Meltwater Oil Pool Area Injection Order 21A Request for Amendment Kuparuk River Field North Slope, Alaska Dear Commissioner Foerster: ConocoPhillips Alaska, Inc. (CPA[) requests that the Alaska Oil and Gas Conservation Commission administratively amend Area Injection Order 21A (AIO 21A) for the Meltwater Oil Pool (MOP) within the Kuparuk River Field. CPAI submits this request in its capacity as operator of the MOP, and as Unit Operator for and on behalf of the working interest owners of the Meltwater Participating Area and the Kuparuk River Unit. Please refer to the attached Request to Amend Meltwater Oil Pool Area Injection Order 21A for the specific details of the proposed modifications to AIO 21A. Please do not hesitate to contact me at (907) 263-4027 or Tommy Nenahlo at (907) 265-6934 should you have any questions about this request. Kazeem A. Adegbola Manager, GKA Development Request to Amend Area Injectia'�fOrder No. 21A • April 14, 2015 Request to Amend Meltwater Oil Pool Area Injection Order 21A ConocoPhillips Alaska, Inc. (CPAI) requests that the Alaska Oil and Gas Conservation Commission (Commission) administratively amend Area Injection Order 21A (AIO 21A) for the Meltwater Oil Pool (MOP) within the Kuparuk River Field (see Attachment 1, Proposed AIO 21A Amendments). The requested amendments to AIO 21A arise from geologic and production data analyses that indicate there has been no further migration of injected fluids out of the MOP. Furthermore, recent geologic and production data analyses indicate that well conversions and sidetracks utilizing coiled tubing drilling technology may further reduce the risk of potential migration of injected fluids out of the MOP. The requested amendments to AIO 21A are designed to: Further mitigate the potential for the migration of injected fluids out of the MOP, while improving flood efficiency and ultimate hydrocarbon recovery in a safe and environmentally friendly manner. Enable CPAI to safely and successfully conduct surveillance initiatives to ensure confinement of injected fluids within the MOP. 3. Ensure continued performance reporting by providing a synopsis of CPAI's surveillance, monitoring, and development initiatives that are designed to ensure the containment of injected fluids within the MOP. 4. Remove the expiration date associated with AIO 21A. Technical Background The MOP is defined as the Bermuda Interval that occurs between 6,785 ft. and 6,974 ft. measured depth (MD) in the Meltwater North #2A well (see Attachment 2, Type Log). These units are late Cretaceous -age (Cenomanian-Turonian) and are overlain by 2,600 ft. of marine mudstone, siltstones, and shales. The top of the Cairn Interval to the C37 Interval represent deep marine mudstones and siltstones and occasional sandstones, and are of late Cretaceous age. The Bermuda Interval itself is a complex shelf -slope turbidite deposit. The deposition environment was of an intermittent nature, in which pulses of reservoir quality sand were deposited in discrete intervals over a period of time. These deposition episodes were likely triggered by storm and/or seismic events. Therefore, the reservoir is compartmentalized into turbidite lobes, which are individual bodies of reservoir quality sandstone. Within the MOP, these individual lobes are often separated by stratigraphic and/or structural discontinuities that can cause significant baffling of flow. Based upon the information gathered, and technical analyses completed to -date, it is likely the initial migration of injected fluids out of the Bermuda interval was a result of a large pressure differential between injectors and producers. (See the Meltwater Oil Pool Area Injection Oder 21A 2014 and 2015 Interim Progress Reports submitted to the Commission on April 1, 2014, and April 1, 2015, respectively). This pressure differential was exacerbated by stratigraphic and/or structural discontinuities within the Bermuda interval. To mitigate this issue and ensure the containment of Page 1 Request to Amend Area Injection Order No. 21A 0 April 14, 2015 injected fluids within the Bermuda interval, CPAI has implemented two primary initiatives and is pursuing a third. The first initiative undertaken to mitigate the large pressure differential between injectors and producers was to implement a sand face injection pressure limit. This sand face injection pressure was incorporated into AIO 21A as Rule 7. To determine the effectiveness of this strategy CPAI developed a significant number of surveillance and monitoring programs. These programs yielded valuable data, to which a large technical and professional resource has been applied to evaluate the information. Based upon evaluation of these data, there is no indication of further migration of injected fluids out of the Bermuda interval. This is predicated upon the following information: o Average reservoir pressure has declined (see Attachment 3, Meltwater Reservoir Pressures). o The composition of the outer annuli gas has become less similar to MI (see Attachment 4, Meltwater Outer Annulus Gas Compositions). o Isotopic analyses have indicated the outer annuli gas becoming more similar to biogenic gas (see Attachment 5, Meltwater Outer Annulus Gas Isotopic Analyses). o Oxygen activation logging (Spectra -Flow®) has determined that injected fluids are not bypassing the production casing cement in the wells tested to date (see Attachment 6, Meltwater Oxygen -Activation Logging of Production Casing Cement Shoes). Surveillance and monitoring programs will continue to ensure safe operations and containment of injected fluids within the Bermuda interval. To safely and successfully complete these programs, the injection of water for surveillance, logging, and near-wellbore formation displacement will be required. The second initiative undertaken was a Reservoir Containment Assurance Project designed to ensure the containment of injected fluids within the MOP. This initiative resulted in the creation and evaluation of a Subsurface Containment Matrix (SCM) that enabled the qualitative assessment of the five key elements of containment: 1) Wells 2) Reservoir and Overburden Characterization 3) Field Management/Surveillance 4) Operations 5) Action/Mitigation Planning In each category, the detailed elements of containment were assessed with a series of statements related to details in the containment elements. The Meltwater SCM will continue to be reviewed on a bi-annual basis. The third initiative is in a planning stage and would be designed to place injectors and producers within the same reservoir body, or lobe, through the use of coiled tubing drilling (CTD) sidetracks and well conversions. This will reduce the effect that structural and/or stratigraphic discontinuities between individual lobes have on the differential pressure between injectors and producers. This initiative is designed to mitigate further migration of Page 2 Request to Amend Area Injection• Order No. 21A is April 14, 2015 injected fluids out of zone, as well as provide for improved reservoir connectivity and ultimate hydrocarbon recovery. It is CPAI's conclusion that the historic migration of injected fluids out of the Bermuda reservoir was likely related to compartmentalization of the reservoir into turbidite lobes and the bottomhole locations of the existing development wells. In the case in which an injector and producer are located within the same lobe, reservoir connectivity is considered excellent. In the case in which injectors and producers are located in different lobes, reservoir connectivity is deemed poor, resulting in lower hydrocarbon production rates and recovery factors. Discussion of Requested Amendments In light of the new information gathered and analyzed over the past two years, CPAI seeks to administratively amend four rules in AIO 21A. The rational in support of each proposed amendment follows. 1. Fluid Injection Wells: New wells and production -to -injection conversions are prohibited in the MOP. (AIO 21A Rule 2) In an effort to mitigate the effect of structural and/or stratigraphic discontinuities between injectors and producers within the MOP, CPAI requests that AIO 21A Rule 2 to be revised to read as follows: "Development well sidetracks are permissible when drilled within the MOP. Well conversions are permissible in the MOP." This proposed amendment to Rule 2 would allow for producer -to -injector conversions and the ability to drill development well sidetracks within the MOP using coiled tubing drilling technology. This would improve reservoir connectivity between producers and injectors, thus mitigating the effects of compartmentalization and improving ultimate hydrocarbon recovery. Further, by placing injectors and producers within the same lobe deposit, the risk of injected fluids migrating out of the MOP can be reduced. CPAI believes that by placing injectors and producers within the same lobe deposit injected fluids will be contained within the MOP and CPAI will reduce the risk of further migration of injected fluids and improve the ultimate hydrocarbon recovery. 2. Authorized Fluids for Injection (A10 21A Rule 8) AIO 21A Rule 8 specifies the authorized fluids for injection into the MOP. Water is not currently listed. Water was previously authorized and used as an underground injection fluid in the MOP (see Area Injection Order No. 21 dated August 1, 2001) but was not identified in AIO 21A as an authorized fluid. This was because there are no plans to revert to a water flood or water - alternating -gas flood at the MOP due to the superior performance of the field when utilizing a gas and/or miscible injectant flooding agent. However, Beaufort Sea water and Kuparuk River Unit (KRU) produced water is necessary to conduct surveillance, logging, near-wellbore displacements, and well maintenance. Specifically, the use of injected water allows for displacement of gas in the wellbore prior to well interventions to mitigate hazards to personnel Page 3 Request to Amend Area Injectioder No. 21A • April 14, 2015 and is required for oxygen -activation logging as a method to ensure the integrity of the production casing cement shoe on injectors. A Meltwater field fluid sensitivity study was completed in March of 2001. This study utilized core samples from the Meltwater North #1 and Meltwater North #2 wells that included an investigation into the sensitivity of preserved reservoir samples to the proposed flood waters. These proposed flood waters included a KRU produced water blend and a 75% KRU produced water/25% Beaufort Sea water blend. The investigation into the sensitivity of the Meltwater North #1 and Meltwater North #2 core samples to the proposed flood waters concluded that there were no adverse reactions to the 75% KRU produced water/25% Beaufort Sea water blend identified. As discussed in AIO 21A.005, although CPAI does not have fluid sensitivity studies completed with 100% Beaufort Sea water, the salinities of the KRU produced water and the Beaufort Sea water are similar, and no appreciable compatibility problems for either the Meltwater formation or its confining zones are expected. If injectors do incur damage from sea water injection, the damage will be contained within a small radius of the wellbore due to the small volume of fluid required to complete the surveillance, logging, near-wellbore formation displacements, and well maintenance initiatives. Any damage to the near-wellbore formation that may arise can be reversed by employing remedial treatments. Therefore, CPAI requests that AIO 21A Rule 8 be modified to read as follows, to allow for the injection of Beaufort Sea water and KRU produced water for surveillance, logging, near-wellbore formation displacements, and well maintenance purposes. Fluids Authorized for Injection are: a. Miscible injectant; b. Dry gas provided by the Kuparuk River Unit; c. Tracer survey fluid to monitor reservoir performance; d. Fluids injected for stimulation purposes per 20 AAC 25.280 (a)(2); e. Glycol from hydro -tests and freeze protection; f. Diesel used for freeze protection; g. Methanol used for freeze protection; h. Standard oilfield chemicals (corrosion and scale inhibitors, defoamers, emulsion breakers, etc.); i. Beaufort Sea water for surveillance, logging, near-wellbore formation displacements, and well maintenance; and j. Kuparuk River Unit produced water for surveillance, logging, near-wellbore formation displacements, and well maintenance All fluids injected must be compatible with the injection zone. Any other fluids shall be approved in advance by separate administrative action based upon proof of compatibility with the reservoir and formation fluids. Long-term injection of water provided by the Kuparuk River Unit water injection system is currently not authorized and shall be approved by a separate administrative action. Page 4 Request to Amend Area Injecttorder No. 21A • April 14, 2015 All of the proposed injection fluids have been authorized by the Commission for injection on the North Slope. All of the injection fluids are non -hazardous, Class II approved fluids, E & P exempt, or products being used for their intended purpose in the wells (and not waste), and therefore have been approved by the Commission for injection in Class II wells. 3. Performance Reporting (AIO 21A Rule 9) Rule 9 of AIO 21A currently states: "The Operator shall submit to the AOGCC a monthly report detailing the daily monitoring of all Meltwater Oil Pool wells. Included in the monthly report, the Operator shall submit OA fluid levels, well pressures, injection and/or production rates, and pressure bleeds for all annuli. Trends shall be evaluated and detailed. In addition to the conditions listed in the above rules the Operator shall provide by April 1" of each year an interim progress report that provides an update on the status of the overburden characterization study, a synopsis of the monitoring data collected during the previous year, and a detailed analysis of the effects on ultimate recovery of switching from an MWAG project, as authorized by AIO 21, to the current MI injection only project." CPAI requests modifying AIO 21A Rule 9 to read: "The Operator shall submit an annual synopsis of the surveillance, monitoring, and development initiatives completed during the previous year that pertain to the confinement of injected fluids within the Bermuda Interval together with the Meltwater Annual Surveillance Report." This proposed modification to Rule 9 will ensure the Commission receives an annual synopsis of surveillance, monitoring, and development initiatives as they pertain to the containment of injected fluids at the same time CPAI submits the Meltwater Annual Surveillance Report that is required by Conservation Order 456, Rule 10. This modification to AIO 21A Rule 9 would eliminate the monthly reporting requirement, yet ensure that the Commission is regularly informed of the status and results of containment and development initiatives being pursued at Meltwater. 4. Expiration Date (AIO 21A Rule 11) The current AIO 21A Rule 11 states: "This order shall expire 24 months after the effective date shown below." The expiration date for AIO 21A is May 16, 2015. CPAI requests that the Commission remove Rule 11 from AIO 21A as surveillance and monitoring data suggest that the implementation of the new reservoir management strategy has prevented further migration of injected fluids out of the MOP. The existing rules in AIO 21A, together with the aforementioned proposed amendments, will ensure long term confinement of injected fluids and optimal hydrocarbon recovery. Page 5 0 0 Request to Amend Area Injection Order No. 21A April 14, 2015 Conclusions CPAI believes the requested amendment approvals are based on sound engineering and geoscience principles, will further mitigate the risk of the migration of injected fluids out of the MOP, will increase ultimate hydrocarbon recovery, will not promote waste or jeopardize correlative rights, and will not result in an increased risk of fluid movement into freshwater. Please do not hesitate to contact me at (907) 263-4027 or Tommy Nenahlo at (907) 265-6934 should you have any questions about this request. Kazeem A. Adegbola Manager, GKA Development Page 6 Request to Amend Area InjectiaTf'order No. 21A April 14, 2015 Attachment 1: Proposed AIO 21A Amendments A10 21A Rule 2 (Fluid Injection Wells) Current: "New wells and production -to -injection conversions are prohibited in the MOP." Requested: "Development well sidetracks are permissible when drilled within the MOP. Well conversions are permissible in the MOP." A10 21A Rule 8 (Authorized Fluids for Injection) Current: "Fluids Authorized for Injection are: a. Miscible injectant; b. Dry gas provided by the Kuparuk River Unit; c. Tracer survey fluid to monitor reservoir performance; d. Fluids injected for stimulation purposes per 20 AAC 25.280 (a)(2); e. Glycol from hydro -tests and freeze protection; f. Diesel used for freeze protection; g. Methanol used for freeze protection; h. Standard oilfield chemicals (corrosion and scale inhibitors, defoamers, emulsion breakers, etc.); All fluids injected must be compatible with the injection zone. Any other fluids shall be approved in advance by separate administrative action based upon proof of compatibility with the reservoir and formation fluids. Water provided by the Kuparuk River Unit water injection system is currently not available and not planned for injection. The water is not authorized for injection and shall be approved by a separate administrative action." Requested: "Fluids Authorized for Injection are: a. Miscible injectant; b. Dry gas provided by the Kuparuk River Unit; c. Tracer survey fluid to monitor reservoir performance; d. Fluids injected for stimulation purposes per 20 AAC 25.280 (a)(2); e. Glycol from hydro -tests and freeze protection; f. Diesel used for freeze protection; g. Methanol used for freeze protection; h. Standard oilfield chemicals (corrosion and scale inhibitors, defoamers, emulsion breakers, etc.); i. Beaufort Sea water for surveillance, logging, near-wellbore formation displacements, and well maintenance; and j. Kuparuk River Unit produced water for surveillance, logging, near-wellbore formation displacements, and well maintenance Page 7 Request to Amend Area Injection Order No. 21A April 14, 2015 All fluids injected must be compatible with the injection zone. Any other fluids shall be approved in advance by separate administrative action based upon proof of compatibility with the reservoir and formation fluids. Long-term injection of water provided by the Kuparuk River Unit water injection system is currently not authorized and shall be approved by a separate administrative action." A10 21A Rule 9 (Performance Reporting) Current: "The Operator shall submit to the AOGCC a monthly report detailing the daily monitoring of all Meltwater Oil Pool wells. Included in the monthly report, the Operator shall submit OA fluid levels, well pressures, injection and/or production rates, and pressure bleeds for all annuli. Trends shall be evaluated and detailed. In addition to the conditions listed in the above rules the Operator shall provide by April 15` of each year an interim progress report that provides an update on the status of the overburden characterization study, a synopsis of the monitoring data collected during the previous year, and a detailed analysis of the effects on ultimate recovery of switching from an MWAG project, as authorized by AIO 21, to the current MI injection only project. Requested: "The Operator shall submit an annual synopsis of the surveillance, monitoring, and development initiatives completed during the previous year that pertain to the confinement of injected fluids within the Meltwater Oil Pool together with the Meltwater Annual Surveillance Report." A10 21A Rule 11 (Expiration Date) Current: "This order shall expire 24 months after the effective date shown below (May 16, 2013)." Requested: It is requested that Rule 11 be removed and that AIO 21A have no expiration date. Page 8 Request to Amend Area Injection Order No. 21A • April 14, 2015 Attachment 2: Current MOP Type Log — Meltwater North 2/2A Well Meltwater Oil Pool AET �(.� LZfnn MELTWATER TYPE LOG oll�. Ugnu C - Ugnu A '- — Top W. Bak pwmwftt YO aaw Lw IMY: 4�. so" W. Sak C riiq "n4 J.n C -40 Ci-3 WVL i „oo- uaz w>, awa 'f +;x wx srao T-7 ++ao Cairn .Benbuda ,.,, • _..lf C-3 , z L P, Page 9 • Request to Amend Area Injection Order No. 21A April 14, 2015 Attachment 3: Meltwater Reservoir Pressures 5000 'i 4500 CL 4000 7 3500 d3000 2500 E 2000 LL • 1500 V E 1000 m 500 0 e �4. V IN ♦!!♦ • ♦ 11%11 00 ��` • • • •• • f • • f H ;E s P 'ti I1.le *,p tie tie tie ��O 1� a L0 Le:, Le L0 Le �0 �Q,yro F eF '0 eF eF eF 6 'de eF ec° eF e,P eF eF eF Oec Oec Oec Oec Oec O� 'd Oes OeC Oec OeC 1j s5 Oe- Qec • Producers ♦ Iryectars "Bermuda formation Pressure omit 0� Page 10 Request to Amend Area Injeco. Order No. 21A Is April 14, 2015 Attachment 4 (Page 1 of 2): Meltwater Outer Annulus Gas Compositions 2P-406 CIA Gas Compositon, 2P-415A CIA Gas Compositon m2PA064!28/2012 92P4I3A4/30=12 M 2P.409 IV12023 a aR 6041mloppoa n2P.4062126/2M4 as NVN41SA411312014 k2P40641INM 24 BI.I.ft G. c-p-ti- - --------- ----------- • oe Polo L�L 104P - ----------------- ----- - ------- - ------------ 2P-417 OA Gas Compositon 2P-420 OA Gas Compositon 92P-4174IM2012 -.2P4I79/ICV20I2 12P<174113V2024 lop' 2P-424A OA Gas Compositon • 2P-024A 4/30/2012 2Fi24A 3/30J2011 02P424A911712013 s 42� "/712021 'PA24A4/3D/2014 2Ps2aA 11/26/2014 I-e Ile 2P-429 OA Gas Compositon . M I C—POO.n .2P429$12%12013 UIF429 10/912011 0 ,GIs 2P-427 OA Gas Compositon • . 2P-427 SA212023 0 2PA27 7PV2013 2P427 IW12MR 2PA27 61712014 eft cwp..i LL- ---------------- - -- L - 0--e me 0-le '10-11 Ile oe : t- 0� 2P-431 OA Gas Compositon Page 11 Request to Amend Area InjectionZ)rder No. 21A 0 April 14, 2015 Attachment 4 (Page 2 of 2): Meltwater Outer Annulus Gas Compositions 2P-432 OA Gas Compositon s� mpoiuon .-., 4/10/2012._........�.....�._.9/1f/2012 EW2P-4329/1IV2M2 S%24'20131a3/20132 S/2y2014ko:c.mP tA0 ole ole a+ 2P-441 OA Gas Composkon S � •IP4a29J19/2012 j S y^. .-----...__. .._.__.._. _._..._-- •2P�sl s/2N7013 ''. I . iP..i ia�m3 02P.4415/142014 f ■91ppn4 NCkmpeakren I . 1 2P-449A OA Gas Compositon �T . Mi cornpr�,wn • 2F 44M 4/Pi2D12 .... ..------ _..._.....___.—.-_....—.._._.._.__._._,.'- •1PJ4M9119/2012 •2h41M4/1412023 S k IP• MS/1/2013 1 s 2P-44M 7/2S/2011 S � 4 IP44M 30h/2025 1 +' e 2P.44MS/27/2014 • tbpnk BktCorryoWar f i 0 41#1Ile 2P-451 OA Gas Compositon ���-^ �—����-� - _...... kMitcmpotticn 1 ■ 2F4514/30,'2037 it S ■ 2P•4515/1/2023 t � 92F�517/2y2013 - 1 P 2P.51 20)9/2013 1 — €2F4524/16/2034 _ - 2P-434 OA Gas Composkon .111 Canpos6on 1 yam— ■7P•s3a 9/lq'7012 s a 2P-t13 c/2a�xma at a1Pi3430,'9/101D 1 • tft-k Or C—m ,ki.n 1 ! . . IL 2P-40 OA Gas Cmuposkon ` _ . Mi compunen ,. .• .. .1P-4•174/3Q'2M2 ■2P•4479/29J2M2 !,.. S t' _.., .... • 2PA47 S/27/2014 x IPM7IIW2M4 �S ■9igaN10r L6nN0411kM` s � i .._ 0 Ole 4r Page 12 Request to Amend Area Inje,*Order No. 21A April 14, 2015 Attachment 5: Meltwater Outer Annulus Gas Isotopic Analyses • -42 Tarn 2N-339 - MI Gas 2P-431, OA MI 2002 Misc Inj 2M-03 2P-432, OA 2P-431, C37-C80, OA 2P-434, CA 2P-438. C37-C80. OA 2P-438, OA 2P-451, C37-C80, OA 2P-441, OA 2PAA7, OA 2P-451, OA " -46 2P-451, A 22P-43P-43143 18 OA L y -48 2P-432, OA 2P-441. OA r D2P-434, OA a2P-427, ! ■� OA% > 2P-449, OA 0 -50 �2Pf 448, OA in 2P-447, OA c 2P-429, OA O L m -52 C 2P 417, OA U _J -54 Increasing O Biog Gass 2P-424, OA -56 .45 .40 -35 -30 -50 Carbon Isotopes Ethane 813Cz ■ MWN-1 ,-2A * MWN mud gas 2P production • 212-415 Cairn sst MI i T4 -T7 mud gas \ C37-C80 mud gas + Outer Annulus 2002 X Outer Annulus 2005 D Outer Annulus 2012 Page 13 1 0 Request to Amend Area Injection Order No. 21A April 14, 2015 • Attachment 6: Meltwater Oxygen -Activation Logging of Production Casing Cement Shoes 4,500 ILV LIQ a 3,500 a� N 3,000 %M a) a 2,500 0 is 2,000 y 1,500 500 0 M k E 2P-419 2P-434 2P-447 Sandface Pres::g]... - ............. - 1,000 2,000 3,000 4,000 5,000 6,000 7,000 8,000 9,000 Rate (STBD) Page 14 Revised Public Hearing STATE OF ALASKA Alaska Oil and Gas Conservation Commission Re: Docket Number: AIO 15-015 Kuparuk River Field, Meltwater Oil Pool Amendment to AIO 21 A The Alaska Oil and Gas Conservation Commission (AOGCC) acting pursuant to AS 31.05.030(b), hereby gives notice of a Public Hearing concerning proposed modifications to existing Area Injection Order (AIO) 21A.000 for the Enhanced Oil Recovery Operations. ConocoPhillips Alaska, Inc. (CPAI) sent to AOGCC on April 1, 2015 an Interim Progress Report "Meltwater Oil Pool Area Injection Order 21A (AIO 21A)" and held a presentation with AOGCC Senior Staff on April 30, 2015. CPAI, by letter dated April 14, 2015 requests to amend AIO 21 A. AOGCC will take this opportunity to update the order and rules to reflect current operating practices and latest regulatory requirements and conditions. CPA as operator of the Kuparuk River Field, Meltwater Oil Pool should be prepared to offer evidence on these matters at this hearing. Accordingly, the AOGCC hereby gives notice that it will hold a public hearing on this inquiry on July 9, 2015 at 9:00 a.m. in the hearing room of the AOGCC, 333 West 71h Avenue, Anchorage, Alaska 99501. Written comments regarding this inquiry may also be submitted to the Alaska Oil and Gas Conservation Commission, at 333 West 7`h Avenue, Suite 100, Anchorage, Alaska 99501. Written comments must be received no later than 5:00 p.m. Alaska time June 10, 2015. 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 793-1221, no later than June 20, 2015. Cathy P. Foerster Chair, Commissioner 0 STATE OF ALAS" ADVERTISING ORDER ADVERTISEQG ORDER NUMBER AO-15-020 FROM: Alaska Oil and Gas Conservation Commission AGENCY CONTACT: Jody Colombie/Samantha Carlisle DATE OF A.O. 05/04/15 AGENCY PHONE: �(907) 793-1221 333 West 7th Avenue Anchorage, Alaska 99501 DATES ADVERTISEMENT REQUIRED: COMPANY CONTACT NAME: PHONE NUMBER: Publish 5/5/15 FAX NUMBER: (907)276-7542 TO PUBLISHER: Alaska Dispatch News SPECIAL INSTRUCTIONS: PO Box 149001 Anchorage, Alaska 99514 �1 ��ltlll9 tiE �Ifl DESCRIPTION .. PRICE AIO 15-015 Initials of who prepared AO: Alaska Non -Taxable 92-600185 SUBMIT INVOICE SHOWING ADVERTISING ORDER NO., CERTIFIED AFFIDAVIT OF PUBLICATION WITH ATTACHED COPY OF ADVERTISMIENT To; Department of Administration Division of AOGCC 333 West 7th Avenue Anchorage, Alaska 99501 Page 1 of 1 Total of All Pa es $ REF Type Number Amount Date Comments I PvN ADN84501 2 Ao AO-15-020 3 4 FIN AMOUNT SY CC PGM LGR ACCT FY I DIST LIQ I 15 02140100 73451 15 2 3 4 5 Purcha ing N Title: 44 Purchasing Authority's Signature Telephone Number 1) TRIBUTION: Division Fiscal/Original AO Copies: Publisher (faxed), Division Fiscal, Receiving Form: 02-901 Revised: 5/4/2015 270227 RECEIVE® 0001364080 S MAY 0 8 2015 $ 234.08 " AFFIDAVIT OF PUBLICATION STATE OF ALASKA THIRD JUDICIAL DISTRICT Leesa Little being first duly sworn on oath deposes and says that he/she is a representative of the Alaska Dispatch 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 aforesaid 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 May 05, 2015 and that such newspaper was regularly distributed 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 this 5th day of May, 2015 Notary Ieylblic in and for The State of Alaska. Third Division Anchorage, Alaska MY COMMISSION EXPIRES Revised Public Hearing STATE OF ALASKA Alaska oil and Gas Conservation Commission Re: Docket Number: AID 15-015 Kuparuk River Field, Meltwater Oil Pool Amendment to AIO 21A The Alaska Oil and Gas Conservation Commission (AOGCC) acting pursuant to AS 31.05.030(b), hereby gives notice of a Public Hearing concerning proposed modifications to existing Area Injection Order (AID) 21A.000 for the Enhanced Oil Recovery Operations. ConocoPhillips Alaska, Inc. (CPAI) sent to AOGCC on April 1, 2015 an Interim Progress Report "Meltwater Oil Pool Area Injection Order 21A (AID 21A)" and held a presentation with AOGCC Senior Staff on April 30, 2015. CPA[, by letter dated April 14, 2015 requests to amend AIO 21A. AOGCC will take this opportunity to update the order and rules to reflect current operating practices and latest regulatory requirements and conditions. CPA as operator of the Kuparuk River Field, Meltwater Oil Pool should be prepared to offer evidence on these matters at this hearing. Accordingly, the AOGCC hereby gives notice that it will hold a public hearing on this inquiry on July 9, 2015 at 9:00 a.m. in the hearing room of the AOGCC, 333 West 7th Avenue, Anchorage, Alaska 99501. Written comments regarding this inquiry may also be submitted to the Alaska Oil and Gas Conservation Commission, at 333 West 7th Avenue, Suite 100, Anchorage, Alaska 99501. Written comments must be received no later than 5:00 P.M. Alaska time June 10, 2015. 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 793-1221, no later than June 20, 2015. AO-15-020 Published: April 16, 2015 Cathy P. Foerster Chair, Commissioner 0 Singh, Angela K (DOA) From: Colombie, Jody J (DOA) Sent: Monday, May 04, 2015 3:09 PM To: Bender, Makana K (DOA); Bettis, Patricia K (DOA); Brooks, Phoebe L (DOA); Carlisle, Samantha J (DOA); Colombie, Jody J (DOA); Davies, Stephen F (DOA); Eaton, Loraine E (DOA); Foerster, Catherine P (DOA); Frystacky, Michal (DOA); Guhl, Meredith D (DOA); Hunt, Jennifer L (DOA); Kair, Michael N (DOA); Loepp, Victoria T (DOA); Mumm, Joseph (DOA sponsored); Paladijczuk, Tracie L (DOA); Pasqual, Maria (DOA); Regg, James B (DOA); Roby, David S (DOA); Schwartz, Guy L (DOA); Seamount, Dan T (DOA); Singh, Angela K (DOA); Wallace, Chris D (DOA); AKDCWellIntegrityCoordinator; Alexander Bridge; Allen Huckabay; Andrew VanderJack, Anna Raff; Barbara F Fullmer, bbritch; bbohrer@ap.org; Bob Shavelson; Brian Havelock; Burdick, John D (DNR); Carrie Wong; Cliff Posey, Colleen Miller; Crandall, Krissell; D Lawrence; Dave Harbour, David Boelens; David Duffy; David House; David McCaleb; David Steingreaber; David Tetta; Davide Simeone; ddonkel@cfl.rr.com; Dean Gallegos; Delbridge, Rena E (LAS); Donna Ambruz; Ed Jones; Elowe, Kristin; Evans, John R (LDZX); Frank Molli; Gary Oskolkosf, George Pollock, ghammons; Gordon Pospisil; Greg Duggin; Gregg Nady; gspfoff, Hulme, Rebecca E (DNR); Jacki Rose; Jdarlington oarlington@gmail.com); Jeanne McPherren; Williams, Jennifer L (LAW); Jerry Hodgden; Jerry McCutcheon; Solnick, Jessica D (LAW); Jim Watt; Jim White; Joe Lastufka; news@radiokenai.com; John Adams; Easton, John R (DNR); Jon Goltz; Juanita Lovett; Judy Stanek; Houle, Julie (DNR); Julie Little; Kari Moriarty; Kazeem Adegbola; Keith Wiles; Kelly Sperback; Gregersen, Laura S (DNR); Leslie Smith; Lisa Parker; Louisiana Cutler, Luke Keller, Marc Kovak; Dalton, Mark (DOT sponsored); Mark Hanley (mark.hanley@anadarko.com); Mark Landt; Mark Wedman; Kremer, Marguerite C (DNR); Mary Cocklan-Vendl; Michael Calkins; Michael Duncan; Michael Moora; Mike Bill; mike@kbbi.org; Mikel Schultz; MJ Loveland; mkm7200; Morones, Mark P (DNR); Munisteri, Islin W M (DNR); knelson@petroleumnews.com; Nichole Saunders; Nick W. Glover; Nikki Martin; NSK Problem Well Supv; Patty Alfaro; Paul Craig; Decker, Paul L (DNR); Paul Mazzolini; Pike, Kevin W (DNR); Randall Kanady; Randy L. Skillern; Renan Yanish; Robert Brelsford; Ryan Tunseth; Sara Leverette; Scott Griffith; Shannon Donnelly, Sharmaine Copeland; Sharon Yarawsky; Shellenbaum, Diane P (DNR); Smart Energy Universe; Smith, Kyle S (DNR); Sondra Stewman; Stephanie Klemmer; Sternicki, Oliver R; Moothart, Steve R (DNR); Suzanne Gibson; Sheffield@aoga.org; Tania Ramos; Ted Kramer, Davidson, Temple (DNR); Terence Dalton; Teresa Imm; Thor Cutler, Tim Mayers; Todd Durkee; Tony Hopfinger; trmjrl; Tyler Senden; Vicki Irwin; Vinnie Catalano; Walter Featherly; Aaron Gluzman; Aaron Sorrell; Ajibola Adeyeye; Alan Dennis; Andrew Cater, Anne Hillman; Bajsarowicz, Caroline J; Bruce Williams; Bruno, Jeff J (DNR); Casey Sullivan; Donna Vukich; Eric Lidji; Erik Opstad; Gary Orr; Smith, Graham O (PCO); Greg Mattson; Dickenson, Hak K (DNR); Heusser, Heather A (DNR); Holly Pearen; Jason Bergerson; jill.a.mcleod@conocophillips.com; Jim Magill; Joe Longo; John Martineck; Josh Kindred; Kenneth Luckey; King, Kathleen J (DNR); Laney Vazquez; Lois Epstein; Longan, Sara W (DNR); Marc Kuck; Marcia Hobson; Steele, Marie C (DNR); Matt Armstrong; Matt Gill; Franger, James M (DNR); Morgan, Kirk A (DNR); Pat Galvin; Peter Contreras; Richard Garrard; Richmond, Diane M; Robert Province; Ryan Daniel; Sandra Lemke; Peterson, Shaun (DNR); Pollard, Susan R (LAW); Talib Syed; Todd, Richard J (LAW); Tostevin, Breck C (LAW); Wayne Wooster, William Hutto; William Van Dyke Subject: Revised Notice of Public Hearing, AIO-15-015 Attachments: Revised Notice of Public Hearing, AIO-15-015.pdf Amended Docket Number a added the time of the hearing. 0 James Gibbs Jack Hakkila Bernie Karl P.O. Box 1597 P.O. Box 190083 K&K Recycling Inc. Soldotna, AK 99669 Anchorage, AK 99519 P.O. Box 58055 Fairbanks, AK 99711 Gordon Severson Penny Vadla George Vaught, Jr. 3201 Westmar Cir. 399 W. Riverview Ave. P.O. Box 13557 Anchorage, AK 99508-4336 Soldotna, AK 99669-7714 Denver, CO 80201-3557 Kazeem A. Adegbola Manager, GKA Development Richard Wagner Darwin Waldsmith North Slope Operations and Development P.O. Box 60868 P.O. Box 39309 ConocoPhillips Alaska, Inc. Fairbanks, AK 99706 Ninilchik, AK 99639 Office: ATO-1326 700 G St. Anchorage, AK 99501 vou-4 : Le NIaY �{ � 20 t5 Angela K. Singh Public Hearing STATE OF ALASKA h Alaska Oil and Gas Conservation Commission \ Re: Docket Number: AIO 15 005� Kuparuk River Field, Meltwater Oil Pool ^ n Amendment to AIO 21 A l' The Alaska Oil and Gas Conservation Commission (AOGCC) acting p suAt to AS 31.05.030(b), hereby gives notice of a Public Hearing concerning propo d modifications to existing Area Injection Order (AIO) 21 A.000 for the Enha ed Oil Recovery Operations. ConocoPhillips Alaska, Inc. (CPAI) sent to AOGCC on Apr , 2015 an Interim Progress Report "Meltwater Oil Pool Area Inj/aend A (AIO 21A)" and held a presentation with AOGCC Senior Staff o CPAI, by letter dated April 14, 2015 requAIO 21A. AOGCC will take this opportunity to rder and rules to reflect current operating practices and latest regulatory rnd conditions. CPA as operator of the Kuparuk Riy6r Field, Meltwater Oil Pool should be prepared to offer evidence on these matters at Ofis hearing. Accordingly, the AOGCC he by gives notice that it will hold a public hearing on this inquiry on July 9, 2015 at in the hearing room of the AOGCC, 333 West 7th Avenue, Anchorage, Alaska 99 Written comments garding this inquiry may also be submitted to the Alaska Oil and Gas Conservation ommission, at 333 West 7th Avenue, Suite 100, Anchorage, Alaska 99501. Writte omments must be received no later than 5:00 p.m. Alaska time June 10, 2015. If, beca e of a disability, special accommodations may be needed to comment or attend the ring, contact the AOGCC's Special Assistant, Jody Colombie, at 793-1221, no lat,ef than June 20, 2015. /—Zqe� Cathy . Foerster Chair, Commissioner STATE OF ALASKA ADVERTISING ORDER NUMBER ADVERTISING ORDER AO-15-019 FROM: AGENCY CONTACT: Jody Colombie/Samantha Carlisle Alaska Oil and Gas Conservation Commission DATE OF A.O. AGENCY PHONE: 333 West7th Avenue 04/30/15 1(907) 793-1221 Anchorage, Alaska 99501 DATES ADVERTISEMENT REQUIRED: COMPANY CONTACT NAME: PHONE NUMBER: Publish 5/4/15 FAX NUMBER: (907)276-7542 TO PUBLISHER: SPECIAL INSTRUCTIONS: Alaska Dispatch News PO Box149001 Anchorage, Alaska 99514 qm "Pi 1� DESCRIPTION PRICE AIO 15-005 Initials of who prepared AO: Alaska Non -Taxable 92-600185 Department of Administration SUBMIT INVOICE SHOWING ADVERTISING. Division AOGCC ORDER NO., CERTIFIED AFFIDAVIT OF of PUBLICATION WITH ATTACHED COPY OF 333 West 7th Avenue Total of ADVERTISMENT TO: Anchorage, Alaska 99501 Page 1 of 1 All Pa es $ REF Type Number Amount Date Comments 1 PvN ADN84501 2 Ao AO-15-019 3 4 FIN AMOUNT SY CC PGM LGR ACCT FY DIST LIQ I 15 02140100 73451 15 2 3 4 Purc a ine: T le: as' g thority's Signature Telephone Number DISTRIBUTION: Division Fiscal/Original AO Copies:Publisher (faxed), Division Fiscal, Receiving Form:02-901 Revised: 4/30/2015 270227 0001363950 RECEIVED $ 229.10 MAY 0 8 2015 AFFIDAVIT OF PUBLICATIONAOGCC STATE OF ALASKA THIRD JUDICIAL DISTRICT Leesa Little being first duly sworn on oath deposes and says that he/she is a representative of the Alaska Dispatch 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 aforesaid 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 May 04, 2015 and that such newspaper was regularly distributed 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 this 4th day of May, 2015 Notary Publ1d in and for The State of Alaska. Third Division Anchorage, Alaska MY COMMISSION EXPIRES Public Hearing STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION Re: Docket Number: CO-14-OAIO 15-005 Kuparuk River Field, Meltwater Oil Pool Amendment to AID 21A The Alaska Oil and Gas Conservation Commission (AOGCC) acting purscconcerning nt to propos d modificationhereby towexisting es A eace of aPublic injeccton Order (AID) 21A.000 for the Enhanced Oil Recovery Operations. ConocoPhillipS Alaska, Inc. (CPAI) sent to AOGCC on April 1, 2015 an Interim Progress Report "Meltwater oil Pool Area Injection Order 21A (AIO 21A)" and held a presentation with AOGCC Senior Staff on April 30, 2015. CPAI, by letter dated April 14, 2015 requests to amend AID 21A. AOGCC will take this opportunity to update the order and rules to reflect current operating practices and latest regulatory requirements and conditions. CPA as operator of the Kuparuk River Field, Meltwater Oil Pool should be prepared to offer evidence on these matters at this hearing. Accordingly, the AOGCC hereby gives notice that it will hold a public hearing on this inquiry on July 9, 2015 at a.m. in the hearing room of the AOGCC, 333 West 7th Avenue, Anchorage, Alaska 99501. Written comments regarding this inquiry may also be submitted to the Alaska Oil and Gas Conservation Commission, at 333 West 7th Avenue, Suite 100, Anchorage, Alaska 99501. Written comments must be received no later than 5:00 P.M. Alaska time June 10, 2015. 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 793-1221, no later than June 20, 2015, AO-15-019 Published: May 4, 2015 f- Cathy P. Foerster Chair, Commissioner Singh, Angela K (DOA) From: Colombie, Jody J (DOA) Sent: Monday, May 04, 2015 1:03 PM To: Bender, Makana K (DOA); Bettis, Patricia K (DOA); Brooks, Phoebe L (DOA); Carlisle, Samantha 1 (DOA); Colombie, Jody J (DOA); Davies, Stephen F (DOA); Eaton, Loraine E (DOA); Foerster, Catherine P (DOA); Frystacky, Michal (DOA); Guhl, Meredith D (DOA); Hunt, Jennifer L (DOA); Kair, Michael N (DOA); Loepp, Victoria T (DOA); Mumm, Joseph (DOA sponsored); Paladijczuk, Tracie L (DOA); Pasqua[, Maria (DOA); Regg, James B (DOA); Roby, David S (DOA); Schwartz, Guy L (DOA); Seamount, Dan T (DOA); Singh, Angela K (DOA); Wallace, Chris D (DOA); AKDCWe[[IntegrityCoordinator; Alexander Bridge; Allen Huckabay; Andrew VanderJack; Anna Raff; Barbara F Fullmer, bbritch; bbohrer@ap.org; Bob Shavelson; Brian Havelock; Burdick, John D (DNR); Carrie Wong; Cliff Posey; Colleen Miller, Crandall, Krissell; D Lawrence; Dave Harbour; David Boelens; David Duffy; David House; David McCaleb; David Steingreaber; David Tetta; Davide Simeone; ddonkel@cfl.rr.com; Dean Gallegos; Delbridge, Rena E (LAS); Donna Ambruz; Ed Jones; Elowe, Kristin; Evans, John R (LDZX); Frank Molli; Gary Oskolkosf; George Pollock; ghammons; Gordon Pospisil; Greg Duggin; Gregg Nady; gspfoff, Hulme, Rebecca E (DNR); Jacki Rose; Jdarlington oarlington@gmail.com); Jeanne McPherren; Williams, Jennifer L (LAW); Jerry Hodgden; Jerry McCutcheon; Solnick, Jessica D (LAW); Jim Watt; Jim White; Joe Lastufka; news@radiokenai.com; John Adams; Easton, John R (DNR); Jon Goltz; Juanita Lovett; Judy Stanek; Houle, Julie (DNR); Julie Little; Kari Moriarty; Kazeem Adegbola; Keith Wiles; Kelly Sperback; Gregersen, Laura S (DNR); Leslie Smith; Lisa Parker, Louisiana Cutler, Luke Keller; Marc Kovak; Dalton, Mark (DOT sponsored); Mark Hanley (mark.hanley@anadarko.com); Mark Landt, Mark Wedman; Kremer, Marguerite C (DNR); Mary Cocklan-Vendl; Michael Calkins; Michael Duncan; Michael Moora; Mike Bill; mike@kbbi.org; Mikel Schultz; MJ Loveland; mkm7200; Morones, Mark P (DNR); Munisteri, Islin W M (DNR); knelson@petroleumnews.com; Nichole Saunders; Nick W. Glover; Nikki Martin; NSK Problem Well Supv; Patty Alfaro; Paul Craig; Decker, Paul L (DNR); Paul Mazzolini; Pike, Kevin W (DNR); Randall Kanady; Randy L. Skillern; Renan Yanish; Robert Brelsford; Ryan Tunseth; Sara Leverette; Scott Griffith; Shannon Donnelly; Sharmaine Copeland; Sharon Yarawsky; Shellenbaum, Diane P (DNR); Smart Energy Universe; Smith, Kyle S (DNR); Sondra Stewman; Stephanie Klemmer; Sternicki, Oliver R, Moothart, Steve R (DNR); Suzanne Gibson; Sheffield@aoga.org; Tania Ramos; Ted Kramer, Davidson, Temple (DNR); Terence Dalton; Teresa Imm; Thor Cutler; Tim Mayers; Todd Durkee; Tony Hopfinger; trmjrl; Tyler Senden; Vicki Irwin; Vinnie Catalano; Walter Featherly; Aaron Gluzman; Aaron Sorrell; Ajibola Adeyeye; Alan Dennis; Andrew Cater, Anne Hillman; Bajsarowicz, Caroline J; Bruce Williams; Bruno, Jeff J (DNR); Casey Sullivan; Donna Vukich; Eric Lidji; Erik Opstad; Gary Orr, Smith, Graham O (PCO); Greg Mattson; Dickenson, Hak K (DNR); Heusser, Heather A (DNR); Holly Pearen; Jason Bergerson; jill.a.mcleod@conocophillips.com; Jim Magill; Joe Longo; John Martineck; Josh Kindred; Kenneth Luckey; King, Kathleen J (DNR); Laney Vazquez, Lois Epstein; Longan, Sara W (DNR); Marc Kuck; Marcia Hobson; Steele, Marie C (DNR); Matt Armstrong; Matt Gill; Franger, James M (DNR); Morgan, Kirk A (DNR); Pat Galvin; Peter Contreras; Richard Garrard; Richmond, Diane M; Robert Province; Ryan Daniel; Sandra Lemke; Peterson, Shaun (DNR); Pollard, Susan R (LAW); Talib Syed; Todd, Richard J (LAW); Tostevin, Breck C (LAW); Wayne Wooster; William Hutto; William Van Dyke Subject: Public Hearing Notice KRU, Meltwater Amendment AIO 21A Attachments: Notice of Public Hearing AIO-15-005.pdf 0 0 James Gibbs Jack Hakkila Bernie Karl P.O. Box 1597 P.O. Box 190083 K&K Recycling Inc. Soldotna, AK 99669 Anchorage, AK 99519 P.O. Box 58055 Fairbanks, AK 99711 Gordon Severson Penny Vadla George Vaught, Jr. 3201 Westmar Cir. 399 W. Riverview Ave. P.O. Box 13557 Anchorage, AK 99508-4336 Soldotna, AK 99669-7714 Denver, CO 80201-3557 Kazeem A. Adegbola Manager, GKA Development Richard Wagner Darwin Waldsmith North Slope Operations and Development P.O. Box 60868 P.O. Box 39309 ConocoPhillips Alaska, Inc. Fairbanks, AK 99706 Ninilchik, AK 99639 Office: ATO-1326 700 G St. Anchorage, AK 99501 ,-A-",�'eCL IAl2,( A-1 t 2O 15 Angela K. Singh.