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Home My WebLink AboutAIO 031 A INDEX Area Injection Order NO. 31A Raven Oil Pool Prudhoe Bay Field 1. July 27, 2023 Hilcorp Application for Expansion of Raven Oil Pool (Confidential items held in secure storage) Area Injection Order NO. 31A STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West 7th Avenue, Suite 100 Anchorage, Alaska 99501 Re: THE APPLICATION OF Hilcorp North Slope, LLC for the expansion of the area in which injection is authorized by Area Injection Order 31, in the Raven Oil Pool within the Prudhoe Bay Field, Prudhoe Bay Unit ) ) ) )) ) ) ) ) Docket Number: AIO-23-023 Area Injection Order 31A Prudhoe Bay Field Prudhoe Bay Unit Raven Oil Pool January 14, 2025 IT APPEARING THAT: 1. By application dated July 27, 2023, Hilcorp North Slope, LLC (Hilcorp), as operator of the Prudhoe Bay Unit (PBU) and on behalf of the Working Interest Owners (WIOs), requested the Alaska Oil and Gas Conservation Commission (AOGCC) grant an expansion to the affected area of Area Injection Order 31(AIO 31), which authorizes the underground injection of fluids for pressure maintenance and enhanced oil recovery in the Raven Oil Pool (ROP). The AOGCC, on its own motion, also proposes to rescind Rule 12 of AIO 31 because 20 AAC 25.556(d) now allows the AOGCC to administratively amend an order it has issued, thus making Rule 12 of AIO 31 extraneous. 2. Pursuant to 20 AAC 25.540, the AOGCC tentatively scheduled a public hearing for September 28, 2023, at 10:00 AM. The notice of that hearing was published on the State of Alaska’s Online Public Notice website, on the AOGCC’s website, and in the Anchorage Daily News on August 13, 2023. 3. No comments or requests that the hearing be held were received and the application provided sufficient information to make a decision. The tentatively scheduled hearing was vacated. 4. Hilcorp’s application, AOGCC’s records, and publicly available information provide sufficient information upon which to make an informed decision. FINDINGS: 1. Order History AIO 31, which authorized the underground injection of fluids for pressure maintenance and enhanced oil recovery in the ROP, was issued August 9, 2006. 2. Operatorship History of ROP The ROP was initially established by BP Exploration Alaska (BPXA), Hilcorp Energy Company purchased BPXA on July 1, 2020, and renamed it to Hilcorp North Slope, LLC. 3. Owners and Landowners The affected landowner is the State of Alaska. All lands within the development area are leased from the State of Alaska, lie within the PBU and have the same working interest Area Injection Order 31A January 14, 2025 Page 2 of 6 ownership: 36.40 percent ExxonMobil Alaska Production Inc., 36.08 percent ConocoPhillips Alaska, Inc., 26.36 percent Hilcorp North Slope, and 1.16 percent Chevron USA Inc. 4. Expansion of the Affected Area Hilcorp proposes to expand the affected area of AIO 31 to match their concurrently proposed expansion of the ROP. The current affected area and the proposed expanded affected area of the ROP are shown in Figure 1, below. Hilcorp proposes to greatly expand the ROP to the east, north, and west, staying within the boundaries of the PBU. Hilcorp provided a map showing the current and proposed boundaries of the ROP, along with a table of township/range values of the proposed final, total pool area. Hilcorp wishes to expand the ROP to pursue future development of the Sag River and Ivishak Formations from the Niakuk Drillsite. To support the geologic basis for the pool expansion, Hilcorp provided subsurface structure and net pay maps of the Sag River and Ivishak formations, a seismic cross-section, and a well log cross-section. The subsurface structure maps contained proposed development well locations. Hilcorp requested the geologic maps and cross-sections be held confidential. The Sag River Formation is Hilcorp’s primary target of interest. Development of this resource is expected to be accomplished via a combination of producing and injection wells. Also of interest is the Ivishak Formation. Hilcorp also believes expansion of the affected area and additional development drilling will allow further evaluation of sand quality and hydrocarbon presence of the Kuparuk River Formation of the overlying Niakuk Oil Pool. CONCLUSIONS: 1. AOGCC accepts Hilcorp’s request to keep the net pay and structure maps and seismic and well log cross-sections confidential, because all are based on interpreted data. 2. Information provided by Hilcorp demonstrates that the ROP extends beyond its current affected area, and thus expanding the affected area of the ROP is appropriate. 3. Having an administrative action rule in the Raven AIO is no longer necessary due to AOGCC regulations now allowing administrative action to be taken on any order issued by the AOGCC. NOW, THEREFORE, IT IS ORDERED: 1. This area injection order supersedes AIO 31, dated August 9, 2006, and the associated administrative approval to AIO 31. The record, findings, and conclusions of AIO 31 and its associated administrative approval are incorporated by reference into the record for this order. 2. The underground injection of fluids for pressure maintenance and enhanced oil recovery is authorized in the ROP within the affected area, subject to the following conditions, limitations, and requirements established in the rules set out below, in Conservation Order 570A, and in statewide requirements contained in 20 AAC 25 (to the extent not superseded by these rules). Area Injection Order 31A January 14, 2025 Page 3 of 6 Affected Area (Revised this order): Umiat Meridian Township/Range Sections 12N-15E N/2, SE/4, NE/4SW/4 Section 23 Section 24 N/2, SE/4, E/2SW/4 Section 25 N/2 Section 26 N/2NE/4 Section 36 12N-16E Section 19 S/2, NW/4, S/2NE/4 Section 20 S/2, S/2NW/4, SW/4NE/4 Section 21 S/2 Section 22 N/2 Section 28 N/2, N/2SW/4, SW/4SW/4 Section 29 Section 30 NW/4NW/4 Section 31 Figure 1. Existing Extent and Proposed Expansion of AIO 31 Affected Area (Source: Hilcorp North Slope, LLC) Rule 1: Authorized Injection Strata for Enhanced Recovery (Restated from AIO 31) Authorized fluids may be injected for purposes of pressure maintenance and enhanced recovery within the ROP into strata that are common to, and correlate with, the interval between the measured depths 10,628 feet and 11,165 feet within Well NK-05. Area Injection Order 31A January 14, 2025 Page 4 of 6 Rule 2: Fluid Injection Wells (Restated from AIO 31) The underground injection of fluids must be through a well that has been permitted for drilling as a service well for injection in conformance with 20 AAC 25.005, or through a well approved for conversion to a service well for injection in conformance with 20 AAC 25.280 and 20 AAC 25.412 (e). Rule 3: Authorized Fluids for Enhanced Recovery (Replaced by AIO 31.001) Fluids authorized for injection are: a) Produced water from Prudhoe Bay Unit processing facilities; b) Non-hazardous water and water-based fluids – (specifically seawater, source water, freshwater, domestic wastewater, equipment washwater, sump fluids, hydrotest fluids, firewater, and water with trace chemicals, and other water-based fluids with a pH greater than 2 and less than 12.5 and flashpoint greater than 140 degrees F); c) Fluids introduced to production facilities for the purpose of oil production, plant operations, plant/piping integrity or well maintenance that become entrained in the produced water stream after oil, gas, and water separation in the facility. Specifically: i. Freeze protection fluids; ii. Fluids in mixtures of oil sent for hydrocarbon recycle; iii. Corrosion/scale inhibitor fluids; iv. Anti-foams/emulsion breakers; v. Glycols d) Non-hazardous glycols and glycol mixtures; e) Fluids that are used for their intended purpose within the oil production process. Specifically: i. Scavengers; ii. Biocides f) Fluids to monitor or enhance reservoir performance. Specifically: i. Tracer survey fluids; ii. Well stimulation fluids; iii. Reservoir profile modification fluids. Rule 4: Authorized Injection Pressure for Enhanced Recovery (Restated from AIO 31) a. Normal injection pressures must be maintained below the parting pressure of the Sag River and Ivishak sandstones of the ROP. b. Injection pressures must be maintained so that injected fluids do not fracture the confining zone or migrate out of the approved injection stratum. c. If fluids are found to be fracturing the confining zone or migrating out of the approved injection stratum, the Operator must immediately shut in the injection wells. Injection may not be restarted unless approved by the AOGCC. Area Injection Order 31A January 14, 2025 Page 5 of 6 Rule 5: Monitoring Tubing-Casing Annulus Pressure (Restated from AIO 31) The tubing and casing annuli pressures of each injection well must be monitored at least daily, except if prevented by extreme weather condition, emergency situations, or similar unavoidable circumstances. Monitoring results shall be documented and made available for AOGCC inspection. Rule 6: Demonstration of Tubing/Casing Annulus Mechanical Integrity (Restated from AIO 31) 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 must be performed after injection is commenced for the first time in a well, to be scheduled when injection conditions (temperature, pressure, rate, etc.) have stabilized. Subsequent tests must be performed at least once every four years thereafter (except at least once every two years in the case of a slurry injection well). The AOGCC must be notified at least 24 hours in advance to enable a representative to witness mechanical integrity tests. Unless an alternate means is approved by the AOGCC, mechanical integrity must be demonstrated by a tubing/casing annulus pressure test using a surface pressure of 1500 psi or 0.25 psi/ft multiplied by the vertical depth of the packer, whichever is greater, that shows stabilizing pressure and does not change more than 10 percent during a 30-minute period. Results of mechanical integrity tests must be readily available for AOGCC inspection. Rule 7: Multiple Completion of Water Injection Wells (Restated from AIO 31) a. Water injectors may be completed to allow for injection in multiple pools within the same wellbore so long as mechanical isolation between pools is demonstrated and approved by the AOGCC. b. Prior to initiation of commingled injection, the AOGCC must approve methods for allocation of injection to the separate pools. c. Results of logs or surveys used for determining the allocation of water injection between pools, if applicable, must be supplied in the annual reservoir surveillance report. d. An approved injection order is required prior to commencement of injection in each pool. Rule 8: Well Integrity Failure and Confinement (Restated from AIO 31) Whenever any pressure communication, leakage or lack of injection zone isolation is indicated by injection rate, operating pressure observation, test, survey, log, or other evidence, the Operator shall notify the AOGCC by the next business day and submit a plan of corrective action on a Form 10-403 for AOGCC approval. The Operator shall immediately shut in the well if continued operation would be unsafe or would threaten contamination of freshwater, or if so directed by the AOGCC. A monthly report of daily tubing and casing annuli pressures and injection rates must be provided to the AOGCC for all injection wells indicating well integrity failure or lack of injection zone isolation. Rule 9: Notification of Improper Class II Injection (Restated from AIO 31) Injection of fluids other than those listed in Rule 3 without prior authorization is considered improper Class II injection. Upon discovery of such an event, the operator must immediately Area Injection Order 31A January 14, 2025 Page 6 of 6 notify the AOGCC, provide details of the operation, and propose actions to prevent recurrence. Additionally, notification requirements of any other State or Federal agency remain the operator’s responsibility. Rule 10: Plugging and Abandonment of Fluid Injection Wells (Restated from AIO 31) An injection well located within the affected area must not be plugged or abandoned unless approved by the AOGCC in accordance with 20 AAC 25. Rule 11: Other conditions (Restated from AIO 31) It is a condition of this authorization that the operator complies with all applicable AOGCC regulations. The AOGCC may suspend, revoke, or modify this authorization if injected fluids fail to be confined within the designated injection strata. Rule 12: Administrative Action (Superseded by regulation 20 AAC 25.556 (d)) DONE at Anchorage, Alaska and dated January 14, 2025. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner RECONSIDERATION AND APPEAL NOTICE As provided in AS 31.05.080(a), within 20 days after written notice of the entry of this order or decision, or such further time as the AOGCC grants for good cause shown, a person affected by it may file with the AOGCC an application for reconsideration of the matter determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration must set out the respect in which the order or decision is believed to be erroneous. The AOGCC shall grant or refuse the application for reconsideration in whole or in part within 10 days after it is filed. Failure to act on it within 10-days is a denial of reconsideration. If the AOGCC denies reconsideration, upon denial, this order or decision and the denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision denying reconsideration, UNLESS the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which the application for reconsideration was filed. If the AOGCC grants an application for reconsideration, this order or decision does not become final. Rather, the order or decision on reconsideration will be the FINAL order or decision of the AOGCC, and it may be appealed to superior court. That appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on reconsideration. In computing a period of time above, the date of the event or default after which the designated period begins to run is not included in the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00 p.m. on the next day that does not fall on a weekend or state holiday. Gregory C. Wilson Digitally signed by Gregory C. Wilson Date: 2025.01.14 13:53:34 -09'00' Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.01.14 14:44:41 -09'00' From:Coldiron, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Area Injection Order 31A and Conservation Order 570A (Hilcorp) Date:Tuesday, January 14, 2025 3:07:14 PM Attachments:aio31A.pdf co570A.pdf THE APPLICATION OF Hilcorp North Slope, LLC for the expansion of the area in which injection is authorized by Area Injection Order 31, in the Raven Oil Pool within the Prudhoe Bay Field, Prudhoe Bay Unit THE APPLICATION OF Hilcorp North Slope, LLC to amend Conservation Order No. 570 to expand the areal extent of the Raven Oil Pool within the Prudhoe Bay Field, Prudhoe Bay Unit 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 1