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Home My WebLink AboutAEO 018Aquifer Exemption Order 18 1. May 15, 2024 Hilcorp Susan Dionne Well 8 Aquifer Exemption Request 2. May 30 , 2024 Notice of Hearing, Affidavit of publication, and email 3. ------------------- Correspondence Emails STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West 7th Avenue, Suite 100 Anchorage Alaska 99501 Re: THE APPLICATION OF Hilcorp Alaska, LLC for an Aquifer Exemption Order for the Beluga 135 aquifer within a one-quarter mile radius of that same aquifer open to the Susan Dionne 8 well within the Ninilchik Unit in Sections 25, 26, 35, and 36, Township 4 South, Range 14 West, Seward Meridian, in conformance with 20 AAC 25.440. ) ) ) ) ) ) ) ) ) ) Docket Number: AEO-24-001 Aquifer Exemption Order 18 Ninilchik Unit Well Susan Dionne 8 PTD 213-051 Kenai Peninsula Kenai Peninsula Borough December 10, 2024 IT APPEARING THAT: 1. By application received May 15, 2024, (Application), Hilcorp Alaska, LLC (Hilcorp), operator of the Ninilchik Unit (NU), requested an order from the Alaska Oil and Gas Conservation Commission (AOGCC) exempting the Beluga 135 aquifer within a one-quarter mile radius of that aquifer in existing well Susan Dionne 8 within the Ninilchik Unit, Sections 6 and 7, Township 1 South, Range 13 West, Seward Meridian (SM), Kenai Peninsula Borough, Alaska. 2. The AOGCC has authority to issue an aquifer exemption. Review by the U.S. Environmental Protection Agency (EPA) is also required by 20 AAC 25.440(d). 3. Pursuant to 20 AAC 25.540, the Alaska Oil and Gas Conservation Commission (AOGCC) tentatively scheduled a public hearing for July 16, 2024. On May 30, 2024, the AOGCC published notice of that hearing on the State of Alaska’s Online Public Notice website, the AOGCC’s website, and electronically transmitted the notice to all persons on the AOGCC’s email distribution list. On June 2, 2024, the notice was published in the Anchorage Daily News. On June 5, 2024, the notice was published in the Peninsula Clarion. 4. The AOGCC did not receive any requests to hold the hearing, public comments, or protests. 5. The public hearing tentatively scheduled for July 16, 2024 was vacated. 6. Hilcorp’s application, supplemental information, and AOGCC’s public records provide sufficient information to make an informed decision. FINDINGS: 1. Operator: Hilcorp operates the NU, which is located within the Kenai Peninsula Borough, Alaska. 2. Description of Well and Aquifer: Susan Dionne 8 (SD8; API Number 50-133-20611-00-00) is a directionally drilled, idle gas development well located on the Susan Dionne Drill Site within the NU. The surface location for the well is 390 feet from the south line and 954 feet from the east line of Section 6, Township 1S, Range 13W, Seward Meridian (SM). The bottomhole location for the well is 482 feet from the north line and 682 feet from the west line of Section Aquifer Exemption Order 18 December 10, 2024 Page 2 of 12 7, Township 1S, Range 13W, SM. Geographic location for the proposed exempted interval within well SD8 is 60.112353 North latitude and -151.575897 West latitude (NAD83). Hilcorp’s application requests a Class II Aquifer Exemption (AE) for the Beluga 135 sand interval that lies between approximately 3,700’ and 3,900’ true vertical depth (TVD) in SD8 for the purposes of Class II disposal injection. 3. Extent of Requested Aquifer Exemption Area and Nearby Wells within that Area: Hilcorp’s requested area for aquifer exemption consists of those portions of Sections 6 and 7 of Township 1 South, Range 13 West, SM that lie within the NU and within a one-quarter mile radius of the Beluga 135 disposal interval within well SD8. Figure 1. SD8 Area — Index Map The green dashed line represents the SD8 boundary; the red dashed circle represents a radius of one-quarter mile from the planned disposal zone. (Source: Hilcorp Alaska, LLC’s application) Only one nearby well, Susan Dionne 1A (SD1A; API Number 50-133-10002-01-00), penetrates Hilcorp’s informally named Beluga 135 zone within a ¼-mile radius of the proposed injection disposal interval in SD8 (see Figure 1). SD1A was completed in the Beluga 135 zone at a location approximately 140 feet to the southeast of the Beluga 135 zone in SD8 to gather data about the reservoir and its suitability for disposal injection operations. Well records and Aquifer Exemption Order 18 December 10, 2024 Page 3 of 12 cement evaluation logs demonstrate that both SD8 and SD1A are cased and cemented sufficiently to isolate the proposed exempted aquifer and its associated confining layers. 4. Notification of Affected Owners: Hilcorp is the only operator within a ¼-mile radius of the proposed disposal well. Hilcorp identified and notified 13 surface owners within a ¼-mile radius of SD8. AOGCC’s public notification process for Hilcorp’s requested AE is described above. This process conforms to the requirements of Alaska Regulations 20 AAC 25.440 and 20 AAC 25.540. 5. Affected Strata: Hilcorp’s proposed disposal injection zone lies within the Beluga Formation (Beluga). The interval requested for exemption is a portion of Hilcorp’s informally named 135 zone (Beluga 135). AOGCC’s associated Disposal Injection Order No. 47 (DIO 47) specifies the proposed Beluga 135 disposal zone as the zone that is common to and correlates with the interval between 3,896’ and 3,945’ measured depth (MD), which are equivalent to 3,754’ and 3,799’ true vertical depth (TVD) in SD8. See Figure 2, below. 6. Geology and Confinement: The proposed Beluga 135 disposal zone consists of very fine- to fine-grained, moderately to well-sorted sandstone that was deposited as part of a vertical sequence of stacked fluvial channels that are separated by interlaminated mudstones and siltstones with occasional thin coal seams. Beluga 135 sand porosity ranges from 19 to 30% and permeability ranges from 3 to 139 millidarcies. The top of the Beluga 135 zone is marked by a thin coal seam that can be correlated across the local geologic structure. Upper confinement is provided by an aggregate of more than 115 true vertical feet of laterally continuous, interlaminated mudstones and siltstones with occasional thin coal seams that constitute Hilcorp’s informally named Beluga 131 to upper Beluga 135 intervals. The proposed disposal zone is directly overlain by 13 true vertical feet of tuffaceous claystone, which is capped by 14-1/2 feet of interbedded tuffaceous claystone and siltstone, and then 3 feet of overlying coal, for an aggregate total of 30-1/2 true vertical feet. Lower confinement is provided by more than 75 true vertical feet of laterally continuous mudstone and siltstone layers with occasional thin coal seams within the lower Beluga 135 and the underlying Beluga 136 and Tyonek Formation (Tyonek) T-2 intervals. The effectiveness of the confining zones – both upper and lower – has been demonstrated by an injectivity test performed in the Beluga 135 disposal zone in close by well SD1A. Analysis of these results is provided in Hilcorp’s application for DIO 47. A map provided within Hilcorp’s application (reproduced as Figure 3, below) depicts the structure atop the proposed exempted aquifer, which is a four-way anticlinal closure. There are no known faults that affect the Beluga 135 zone in the vicinity of the Susan Dionne Drill Site or within the requested Affected Area. Aquifer Exemption Order 18 December 10, 2024 Page 4 of 12 Figure 1. Stratigraphic Correlation between SD8 (left) and Nearby Well SD1A (right). Proposed disposal zone identified by light yellow fill within the central vertical bar. (Source: Hilcorp Alaska, LLC’s AE application) 7. Requested Affected Area: Hilcorprequests the AOGCC grant an Aquifer Exemption to include those portions of Sections 6 and 7 in Township 1 S, Range 13 West, SM that lie within a one- quarter mile radius of the Beluga 135 aquifer as it is transected by well SD8, an area encompassing about 126 acres, that is depicted on Figure 3, below. Aquifer Exemption Order 18 December 10, 2024 Page 5 of 12 Figure 3. SD8 Area — Beluga 135 Structure Map Red circle represents the requested aquifer exemption area (one-quarter-mile radius). (Source: Hilcorp Alaska, LLC AE Application) 8. Nearby Drinking Water Wells: The tables below capture general information about the 13 registered water wells and the 5 subsurface water rights authorizations that are recorded within Sections 5, 6, 7, and 8 of T1S, R13W, SM, which lie within about 1.4 miles of the proposed injection interval. This well data is taken from the Alaska Department of Natural Resources (AK DNR), Division of Mining, Land and Water’s Well Log Tracking System (WELTS) and AK DNR’s Land Administration System (LAS) that were accessed on July 18 and July 22, 2024. From these tables it is evident that the deepest drinking-water well in this area (257 feet MD, or about -122’ true vertical depth subsea (TVDSS), and located nearby on the operator’s Aquifer Exemption Order 18 December 10, 2024 Page 6 of 12 drilling pad) lies about 3,447 vertical feet shallower than the top of the planned injection zone in SD8 at 3,869’ MD (equivalent to 3,729’ TVD and -3,569’ TVDSS). The acronym LAS refers to the AK DNR’s Land Administration System, and the associated numbers are the LAS case-file index numbers. The acronym TWUA refers to a State of Alaska Subsurface Temporary Water Use Authorization. The second closest registered drinking water well is Well No. 8259, which is 127’ deep and lies slightly more than one-half mile from the proposed injection interval. (See Figure 4, below.) In addition, Hilcorp identified two public water system sources wells in the area: a 200-foot deep well at Scenic View RV Park located 1.8 miles northeast of Susan Dionne 8, and a 45- foot deep well at Ninilchik 132.6 Cabins and RV Park is located three miles southwest of Susan Dionne 8. Well No. Owner Case ID No. Depth (ft) 1293 Carolyn Issermoyer Not Listed 50 2282 John Mollette Not Listed 200 8259 Bob Wallis Not Listed 127 19164 Leo Thornton Not Listed 58 19165 Foster Leng Not Listed 58 19190 Albert Jones Not Listed 55 21474 Darrell Jones Not Listed 101 25804 Marathon Oil Co. TWUA A2017-16 257 26930 J. Inman Not Listed 98 42933 Lawrence Baker Not Listed 120 47475 Robert Frost Not Listed Not Listed 75656 Ron Kingsley LAS 32051 109 84070 Hilcorp TWUA A2019-154 111 Table 1. List of the 13 Registered Domestic and Commercial Water Wells within Surrounding Governmental Sections 5, 6, 7, and 8 of T1S, R13W, SM (Source: Alaska DNR’s Alaska Mapper - WELTS Map) Case File No. Owner Case Type / Code Description Depth (ft) LAS 3436 Richard E. Person Water Rights - Subsurface 115 ADL 44511 W. Lee McKinley Water Rights - Subsurface Not Listed ADL 213078 Carolyn Reifsnyder Water Rights - Subsurface Not Listed LAS 32051 Laurie J. Lincoln Water Rights - Subsurface 109 TWUA A2021-149 Hilcorp Alaska, LLC. Temporary Water Use Authorization - Subsurface 257 Table 2. List of the 5 Subsurface Water Rights and Authorizations within Surrounding Governmental Sections 5, 6, 7, and 8 of T1S, R13W, SM (Source: Alaska DNR’s Alaska Mapper - Water Estate Map) Aquifer Exemption Order 18 December 10, 2024 Page 7 of 12 Figure 4. SD8 Area — Drinking Water Wells and Water Use Authorizations Registered drinking water wells (blue), subsurface water-use and temporary water-use authorization information (red) with associated well depths when available. (Sources: AKDNR’s WELTS and Water Estate databases) 9. Formation Water Salinity: Hilcorp provided laboratory analyses for two water samples obtained from the Beluga 135 interval in SD1A. Total Dissolved Solids for these samples measured 1,700 and 1,920 mg/l. However, it is important to note that the concentrations of six metals and 15 organic compounds measured in these samples exceed—and in many cases far exceed—the Groundwater Human Health Cleanup Levels specified in Alaska Regulation 18 AAC 75.345, which is titled “Groundwater and surface water cleanup levels.” (See Table 3, below.) Aquifer Exemption Order 18 December 10, 2024 Page 8 of 12 10. No. Detectable Parameter Sample Analysis Results (μg/l) GW Clean Up Level (μg/l)* 1 Lead 1080, 4450 15 2 Copper 2310, 10700 800 3 Chromium 463, 627 91 4 Selenium 360, 402 100 5 Barium 7600, 10400 3800 6 Manganese 333, 645 430 1 Naphthalene 3860, 4410 2 2 1,2,4-Trimethylbenzene 4080, 4710 56 3 Ethylbenzene 651, 731 15 4 Phenanthrene 6980, 6630 170 5 1,3,5-Trimethylbenzene 1420, 1630 60 6 Xylenes (total) 4510, 5050 190 7 Fluorene 2780, 2680 200 8 o-Xylene 1600, 1780 190 9 Benzene 23.6, 24.6 4.6 10 Diesel Range Organics 5310, 5710 1500 11 Chrysene 4.7, 4.5 2 12 1-Methylnaphthalene 4.6, 36 11 13 n-Propyl benzene 928, 1070 660 14 Acenaphthene 400, 387 260 15 1-Methylnaphthalene 5.8, 48.1 36 Total Dissolved Solids (mg/l) 1700, 1920 *Per 18 AAC 75.345 Table 3. SD1A — Beluga 135 Water Samples Detectable Results Summary 10. Suitability of Sediments as Drinking Water Aquifers: Pursuant to 20 AAC 25.440(a)(1), Hilcorp’s request for an aquifer exemption is supported by the following: a. The area surrounding SD8 is rural, sparsely populated, has plentiful subsurface groundwater, and the number of shallow water wells in this area is low. The deepest of the 13 water wells within about 1.4 miles of the proposed disposal zone is 257 feet, which is about 3,450 vertical feet shallower than the proposed disposal zone. The second deepest well in this area is 200 feet. Given the somewhat remote location of this rural area, the likelihood for future large-scale industrial, agricultural, or commercial development that could significantly impact aquifer usage appears to be low. b. Open-hole well logs recorded in SD8 and SD1A from 250’ to about 500’ MD indicate the interval contains well-developed, sand-rich aquifers that display elevated resistivity levels suggestive of fresh water or mildly brackish water that can be rendered potable through treatment. c. The Kenai Peninsula has abundant surface water that could provide a secondary source. According to the City of Kenai, the average annual precipitation for the Kenai Peninsula is about 20 inches. By example, the City of Homer, located about 35 miles to the south, utilizes the dammed Bridge Creek Reservoir as the sole municipal water source. Aquifer Exemption Order 18 December 10, 2024 Page 9 of 12 d. Although the Total Dissolved Solids content of the Beluga 135 formation water samples is low (measuring 1,700 and 1,920 mg/l), utilizing the Beluga 135 aquifer as a drinking water source is economically impractical. The Beluga 135 aquifer within the proposed exempted interval lies about 3,450 vertical feet below ground level. A detailed cost analysis presented in the operator’s application estimates that the cost to drill and equip a 3,500-foot-deep water well, which requires specialized drilling and pumping equipment, would be about $4,200,000 (drilling $3,000,000; Electrical Submersible Pump (ESP) $1,200,000), with yearly operating costs of about $138,000 to power the ESP. Reportedly there are no commercially available ESPs that are ANSI/NSF Standard 61 certified for use in a potable water system. In comparison, the cost to drill and equip a 250-foot-deep water well is about $26,250 (drilling costs $21,2501; $5,000 for a pump). e. The Beluga 135 zone contains hydrocarbons. a. In well SD8, the Beluga 135 was perforated and tested jointly with the underlying Tyonek T-140 sand. The initial, 24-hour flow test of the combined Beluga 135 and Tyonek T-140 intervals produced 656,000 cubic feet of gas and 260 barrels of water as shown on the Well Completion Report. Regular, commingled production from the Beluga 135 and Tyonek T-140 intervals occurred from February to April 2014, then the well was shut in. The operator determined that the T-140 interval was non-productive, and the Beluga 135 interval produced gas with large amounts of water. b. As it was drilled in SD8, the Beluga 135 zone yielded gas measurements of up to 200 units of methane gas (equivalent to 40,000 ppm or 4% in air) while using 10.6 pounds per gallon mud. c. The open-hole well log recorded across the Beluga 135 zone displays elevated resistivity measurements in association with obvious cross-over of the density and neutron curves, which are indicators of the presence of gas. d. A limited-duration flow test of the Beluga 135 in nearby well SD1A conducted during 1962 reportedly produced water and unmeasured amounts of gas. e. The Beluga 135 planned injection zone is currently producing gas in three wells within the Ninilchik Unit: Kalotsa 2 (API 50-133-20659-00-00), Kalotsa 3 (API 50-133-20661-00-00), and Paxton 10 (API 50-133-20691-00- 00. In the past, this reservoir zone has also produced gas in nearby wells Susan Dionne 5 (API 50-133-20562-00-00) and Susan Dionne 6 (API 50-133-20582- 00-00). f. Although the Beluga 135 zone formation water samples were fresh, they were contaminated. Using a procedure intended to minimize the chance of any fluid contamination 2, two 4-1/2-gallon water samples were recovered from the Beluga 135 in 1 Per Hilcorp’s application, according to Kraxberger Drilling, 2021, drilling cost is $85 per foot. 2 The procedure followed for nearby well SD-1A to gather water samples that are representative of the Beluga 135 interval was: Pressured up the well with nitrogen and pushed fluid level down to 4,926’. Aquifer Exemption Order 18 December 10, 2024 Page 10 of 12 nearby well SD1A—from a location about 140’ to the southeast of the Beluga 135 in SD8—and analyzed for the purpose of Hilcorp’s AE request. These samples are believed to be representative of the native formation fluids. Laboratory analyses by SGS North America Inc. of these samples demonstrate that the natural formation waters within the proposed exempted interval and within the proposed exemption area contain concentrations of six metals and 15 organic compounds that exceed the Groundwater (GW) Human Health Cleanup Levels specified in Alaska Regulation 18 AAC 75.345. Laboratory measurements and specified cleanup levels for these contaminants are listed in Table 3, above. 11. Protection of Aquifers by Existing Wells: Casing across the proposed exempted zone in SD8 is 7-5/8” 29.7# L-80. Cement across the disposal zone and confining layers consists of 352 barrels (bbls) of 14.5 pounds per gallon (ppg) Class G lead and 62 bbls of 15.5 ppg Class G tail. A subsequent Cement Bond Log (CBL) run on September 20, 2013, showed top of cement at 1,550’ MD and cement across the Beluga 135 disposal zone and associated confining layers that is sufficient for isolation. Only one well, SD1A, penetrates the Beluga 135 disposal zone within a 1/4-mile radius of the existing SD8 well. Intermediate casing is set in SD1A at 7,430’ MD, and the casing across the proposed disposal zone (from about 3,770’ to 3,813’ MD in SD1A) is 9-5/8” 40# and 47# N- 80. Cement across this interval and the associated confining layers consists of 2,800 sacks of cement of unspecified type. An Ultra Sonic Imaging Tool (USIT) log run on December 17, 2001 shows cement to the top of the USIT log at about 3,000’ MD, which is sufficient for isolation. 12. Injection Operations Will Not Impact Shallow Aquifers: Stimulation model results for the proposed Beluga 135 disposal zone, using a third-party model, were submitted as part of Hilcorp’s application for associated DIO 47. This modeling found that the planned disposal operations into the proposed disposal zone, as outlined in the application, will not propagate fractures through the confining zones. Injected fluids will remain confined to the intended zone as supported by injectivity results from correlative sands within the nearby SD1A well. Waste fluids will be contained within the Beluga 135 disposal zone by the confining lithologies based on the SD1A modeled injection rates, volumes, fluid densities, and pressures, which exceed expected SD8 operating conditions. Cement isolation of the injection zone in the well bore and operating conditions further support the AOGCC’s conclusion about confinement. (Sources: DIO 47 Finding 8, DIO 47 Conclusions 4 and 5, and Finding 10, above.) In addition, DIO 47 Rule 3 specifies: “Injection rates and pressures must be maintained such that the injected fluids will not initiate or propagate fractures through the confining zones or migrate out of the approved injection stratum.” Set a Cast Iron Bridge Plug at 4,890’ to seal off the deeper perfs. Perforated the Beluga 135 interval from 3790-3810’. Initial pressures were ~1300 psi. Reduced the surface pressure to allow for some inflow. Returned a couple days later with a slickline bailer. Fluid level was at 1950’. Ran in to 2050’ and pulled water sample into the bailer. Returned with 4.5 gallons of water. RIH a second time, fluid was at 1950’ again. Pulled a second sample from 2050’. Returned with 4.5 gallons of water in the bailer. Aquifer Exemption Order 18 December 10, 2024 Page 11 of 12 13. Area Affected by Disposal Injection Operations: SD8 is planned as a backup injector to existing disposal well NNA-1. The average volumes pumped into NNA-1 for the past year were approximately 300 bpd. Assuming 20-year project life with 300 barrels per day average daily injection rate, a 45-foot-thick disposal interval, average porosity of 25%, and piston-like displacement of native reservoir fluids, the expected impacted radius from the SD8 Beluga 135 perforations is 590 feet, which lies well inside the requested one-quarter-mile radius Affected Area. 14. Concurrence of the U.S. Environmental Protection Agency (EPA): Pursuant to 20 AAC 25.440 (d) (1), the EPA will be provided the opportunity to review and approve this order. CONCLUSIONS: 1. Beluga 135 aquifer within the proposed exemption area does not currently serve as source of drinking water. Known ground water consumption from the vicinity is consistent with plentiful groundwater resources occurring above a depth of 260 feet below ground surface. 2. The Beluga 135 aquifer occurring in the proposed exempted interval within the proposed exemption area cannot reasonably be expected to serve as an underground source of drinking water because methane gas is present, it is situated at a location and depth that makes the recovery of formation waters for drinking water purposes economically impractical, and it is contaminated with metals and organic compounds. 3. Casing, cement evaluation, and cementing records and logs indicate shallow aquifers will be protected by well SD8 and nearby well SD1A and that those wells will not provide conduits for injected fluids to migrate from the injection zones. 4. Confining intervals bracketing the injection zone have sufficient thickness and lateral continuity to prevent out-of-zone migration of injected fluids. There are no known faults that might provide migration pathways from the injection zones into other strata or freshwater aquifers. 5. The aquifers occurring in the proposed exempted interval within the proposed exemption area qualify as exempt freshwater aquifers under 20 AAC 25.440 (a)(1)(B) and 20 AAC 25.440 (a)(1)(C). 6. Hilcorp’s request for the specified one-quarter-mile radius Affected Area is warranted. NOW, THEREFORE, IT IS ORDERED THAT the aquifer occurring in the Beluga 135 interval that is stratigraphically equivalent to the interval from 3,896 to 3,945 feet MD in well SD8 (API Number 50-133-20611-00-00) and located within a radius of one-quarter-mile (1,320 feet) of the Beluga 135 interval in that well is designated as an exempt freshwater aquifer for the purposes of Class II waste disposal operations as provided by 20 AAC 25.440. This order is not effective until the United States Environmental Protection Agency has been provided the opportunity to review and approve the order pursuant to 20 AAC 25.440(d)(1).3 3 20 AAC 25.440.(d): “A commission order designating a freshwater aquifer or a portion of it as an exempt freshwater aquifer is not effective with respect to underground disposal or storage operations subject to 20 AAC 25.252 or injection operations Aquifer Exemption Order 18 December 10, 2024 Page 12 of 12 This Order does not authorize the injection of any fluids or gas within the exemption area. Disposal Injection Order No. 47 governs injection operations within the Affected Area described above. DONE at Anchorage, Alaska and dated December 10, 2024. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner RECONSIDERATION AND APPEAL NOTICE As provided in AS 31.05.080(a), within 20 days after written notice of the entry of this order or decision, or such further time as the AOGCC grants for good cause shown, a person affected by it may file with the AOGCC an application for reconsideration of the matter determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration must set out the respect in which the order or decision is believed to be erroneous. The AOGCC shall grant or refuse the application for reconsideration in whole or in part within 10 days after it is filed. Failure to act on it within 10-days is a denial of reconsideration. If the AOGCC denies reconsideration, upon denial, this order or decision and the denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision denying reconsideration, UNLESS the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which the application for reconsideration was filed. If the AOGCC grants an application for reconsideration, this order or decision does not become final. Rather, the order or decision on 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. subject to 20 AAC 25.402 until the United States Environmental Protection Agency has been provided the opportunity to review the order under 40 C.F.R. 144.7(b)(3) and has (1) approved the order, if it was issued under (a)(1) of this section; or (2) has allowed the applicable time period within which to disapprove the order to expire without acting on it, if the order was issued under (a)(2) of this section.” Gregory C. Wilson Digitally signed by Gregory C. Wilson Date: 2024.12.10 15:52:32 -09'00' Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2024.12.10 15:57:22 -09'00' From:Coldiron, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Aquifer Exemption Order 18 (Hilcorp) Date:Tuesday, December 10, 2024 4:09:05 PM Attachments:aeo18.pdf THE APPLICATION OF Hilcorp Alaska, LLC for an Aquifer Exemption Order for the Beluga 135 aquifer within a one-quarter mile radius of that same aquifer open to the Susan Dionne 8 well within the Ninilchik Unit in Sections 25, 26, 35, and 36, Township 4 South, Range 14 West, Seward Meridian, in conformance with 20 AAC 25.440. 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 3 From:Davies, Stephen F (OGC) To:Casey Morse Subject:Susan Dionne 8 (213-051) Aquifer Exemption Application - Question Date:Monday, July 22, 2024 2:17:00 PM Casey, I’m reviewing Hilcorp’s application for an Aquifer Exemption for Susan Dionne 8. Hilcorp’s companion application to convert this well to Class II disposal states “…there are no known transmissive faults at those depths [3400’ to 4000’ TVDSS] in the vicinity of Susan Dionne pad.” [Emphasis is mine.] This is not the same as saying “…there are no known faults in vicinity of Susan Dionne pad.” So, to clarify for the Beluga 135 proposed injection interval: Has Hilcorp identified any faults within a one-mile radius of the proposed injection interval? If so, please provide a detailed structure map depicting those faults at Beluga 135-level, how they were identified (seismic data, well log correlations), the vertical displacement range for each fault, whether or not each fault penetrates into or through the upper or confining zones for the injection interval, and Hilcorp’s interpretation as to whether or not each fault will affect confinement of wastes or fluids injected into the Beluga 135. Thanks and Be Well, Steve Davies AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. From:Casey Morse To:Davies, Stephen F (OGC) Cc:Donna Ambruz Subject:RE: [EXTERNAL] Susan Dionne 8 (213-051) Aquifer Exemption Application - Question Date:Tuesday, July 23, 2024 4:02:04 PM Steve, Thanks for reaching out. The word “transmissive” is misleading in that sentence as you pointed out below. Hilcorp has not identified any faults within a one-mile radius of the proposed injection interval. Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Monday, July 22, 2024 2:17 PM To: Casey Morse <casey.morse@hilcorp.com> Subject: [EXTERNAL] Susan Dionne 8 (213-051) Aquifer Exemption Application - Question Casey, I’m reviewing Hilcorp’s application for an Aquifer Exemption for Susan Dionne 8. Hilcorp’s companion application to convert this well to Class II disposal states “…there are no known transmissive faults at those depths [3400’ to 4000’ TVDSS] in the vicinity of Susan Dionne pad.” [Emphasis is mine.] This is not the same as saying “…there are no known faults in vicinity of Susan Dionne pad.” So, to clarify for the Beluga 135 proposed injection interval: Has Hilcorp identified any faults within a one-mile radius of the proposed injection interval? If so, please provide a detailed structure map depicting those faults at Beluga 135-level, how they were identified (seismic data, well log correlations), the vertical displacement range for each fault, whether or not each fault penetrates into or through the upper or confining zones for the injection interval, and Hilcorp’s interpretation as to whether or not each fault will affect confinement of wastes or fluids injected into the Beluga 135. Thanks and Be Well, Steve Davies AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov The information contained in this email message is confidential and may be legally privileged and is intended only for the use of theindividual or entity named above. If you are not an intended recipient or if you have received this message in error, you are herebynotified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, pleaseimmediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently deletethis message. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that theonward transmission, opening, or use of this message and any attachments will not adversely affect its systems or data. No responsibilityis accepted by the company in this regard and the recipient should carry out such virus and other checks as it considers appropriate. CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. From:Casey Morse To:Davies, Stephen F (OGC) Cc:Donna Ambruz Subject:RE: [EXTERNAL] Susan Dionne 8 (213-051) Aquifer Exemption Application - Question Date:Tuesday, July 23, 2024 4:02:04 PM Steve, Thanks for reaching out. The word “transmissive” is misleading in that sentence as you pointed out below. Hilcorp has not identified any faults within a one-mile radius of the proposed injection interval. Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Monday, July 22, 2024 2:17 PM To: Casey Morse <casey.morse@hilcorp.com> Subject: [EXTERNAL] Susan Dionne 8 (213-051) Aquifer Exemption Application - Question Casey, I’m reviewing Hilcorp’s application for an Aquifer Exemption for Susan Dionne 8. Hilcorp’s companion application to convert this well to Class II disposal states “…there are no known transmissive faults at those depths [3400’ to 4000’ TVDSS] in the vicinity of Susan Dionne pad.” [Emphasis is mine.] This is not the same as saying “…there are no known faults in vicinity of Susan Dionne pad.” So, to clarify for the Beluga 135 proposed injection interval: Has Hilcorp identified any faults within a one-mile radius of the proposed injection interval? If so, please provide a detailed structure map depicting those faults at Beluga 135-level, how they were identified (seismic data, well log correlations), the vertical displacement range for each fault, whether or not each fault penetrates into or through the upper or confining zones for the injection interval, and Hilcorp’s interpretation as to whether or not each fault will affect confinement of wastes or fluids injected into the Beluga 135. Thanks and Be Well, Steve Davies AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov The information contained in this email message is confidential and may be legally privileged and is intended only for the use of theindividual or entity named above. If you are not an intended recipient or if you have received this message in error, you are herebynotified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, pleaseimmediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently deletethis message. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that theonward transmission, opening, or use of this message and any attachments will not adversely affect its systems or data. No responsibilityis accepted by the company in this regard and the recipient should carry out such virus and other checks as it considers appropriate. Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. From:Gross, Ryan (he/him/his) To:Davies, Stephen F (OGC) Cc:Wallace, Chris D (OGC) Subject:RE: Aquifer Exemption for Susan Dionne 8 Date:Thursday, August 15, 2024 4:34:53 PM Attachments:image002.png Hi Steve, Good to hear from you. I don’t work in the UIC program anymore, but I see that Chris forwarded your message to James, Evan and Tim. Have a great day! Ryan J. Gross, P.E.Regional Coordinator for Infrastructure Technical Assistance Water Div. - Infrastructure and Technical Assistance Section EPA Region 10 Seattle Office – 206-553-6293 The Bipartisan Infrastructure Law – A Historic Investment in Water! From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Thursday, August 15, 2024 8:21 AM To: Gross, Ryan (he/him/his) <Gross.Ryan@epa.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov> Subject: Aquifer Exemption for Susan Dionne 8 Ryan, Steve Davies of the Alaska Oil and Gas Conservation Commission here. We last corresponded in August 2022 concerning an aquifer exemption for the North Fork Unit on the Kenai Peninsula, Cook Inlet Basin, Alaska. Are you still part of Region 10’s team that reviews aquifer exemption applications for Alaska? If not, could you please point me to the proper contact within Region 10? The proposed exemption that I am working on is conversion of an existing, shut in gas well into a back-up Class II disposal injection well located onshore along the western coastline of the Kenai Peninsula. I have completed a draft version of the EPA’s Aquifer Exemption Checklist form that was used for the North Fork Unit exemption. To expedite review, I’d like to discuss this with you and, if possible, submit my draft of EPA’s checklist to you for a quick preliminary review to ensure that I haven’t overlooked anything. Please let me know if this works for you. Thanks and Be Well, Steve Davies Senior Petroleum Geologist AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov. From:Davies, Stephen F (OGC) To:Robinson, James; Osborne, Evan; Mayers, Timothy Cc:Wallace, Chris D (OGC) Subject:RE: Aquifer Exemption for Susan Dionne 8 Date:Tuesday, August 20, 2024 4:51:00 PM Evan, James, and Tim: Steve Davies of the Alaska Oil and Gas Conservation Commission here. Are any of you part of Region 10’s team that reviews aquifer exemption applications for Alaska? If not, could you please point me to the proper contact within Region 10? I’d like to get this application review started with EPA. Please let me know when you are available to discuss this. Thanks and Be Well, Steve Davies Senior Petroleum Geologist AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov. From: Wallace, Chris D (OGC) <chris.wallace@alaska.gov> Sent: Thursday, August 15, 2024 4:20 PM To: Robinson, James <Robinson.James@epa.gov> Cc: Osborne, Evan <Osborne.Evan@epa.gov>; Mayers, Timothy <Mayers.Timothy@epa.gov>; Gross, Ryan <Gross.Ryan@epa.gov>; Davies, Stephen F (OGC) <steve.davies@alaska.gov> Subject: FW: Aquifer Exemption for Susan Dionne 8 James, Please see below from Steve on a new aquifer exemption we are progressing. Thanks and Regards, Chris Wallace, Sr. Petroleum Engineer, Alaska Oil and Gas Conservation Commission, 333 West 7th Avenue, Anchorage, AK 99501, (907) 793-1250 (phone), (907) 276-7542 (fax), chris.wallace@alaska.gov 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 Chris Wallace at 907-793-1250 or chris.wallace@alaska.gov. From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Thursday, August 15, 2024 7:21 AM To: Gross, Ryan <Gross.Ryan@epa.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov> Subject: Aquifer Exemption for Susan Dionne 8 Ryan, Steve Davies of the Alaska Oil and Gas Conservation Commission here. We last corresponded in August 2022 concerning an aquifer exemption for the North Fork Unit on the Kenai Peninsula, Cook Inlet Basin, Alaska. Are you still part of Region 10’s team that reviews aquifer exemption applications for Alaska? If not, could you please point me to the proper contact within Region 10? The proposed exemption that I am working on is conversion of an existing, shut in gas well into a back-up Class II disposal injection well located onshore along the western coastline of the Kenai Peninsula. I have completed a draft version of the EPA’s Aquifer Exemption Checklist form that was used for the North Fork Unit exemption. To expedite review, I’d like to discuss this with you and, if possible, submit my draft of EPA’s checklist to you for a quick preliminary review to ensure that I haven’t overlooked anything. Please let me know if this works for you. Thanks and Be Well, Steve Davies Senior Petroleum Geologist AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov. Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. From:Osborne, Evan To:Davies, Stephen F (OGC); Robinson, James; Mayers, Timothy Cc:Wallace, Chris D (OGC) Subject:RE: Aquifer Exemption for Susan Dionne 8 Date:Wednesday, August 21, 2024 7:11:42 AM Steve, Thank you for contacting us and raising this issue. Answer: Yes, we are the team that will be reviewing this request. I suggest we set up a meeting to discuss the proposed aquifer exemption. Does that work with your timeline for issuance? How about tomorrow at 10AM AK time? Or Friday at 9AM AK time? Best, Evan From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Tuesday, August 20, 2024 5:51 PM To: Robinson, James <Robinson.James@epa.gov>; Osborne, Evan <Osborne.Evan@epa.gov>; Mayers, Timothy <Mayers.Timothy@epa.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov> Subject: RE: Aquifer Exemption for Susan Dionne 8 Evan, James, and Tim: Steve Davies of the Alaska Oil and Gas Conservation Commission here. Are any of you part of Region 10’s team that reviews aquifer exemption applications for Alaska? If not, could you please point me to the proper contact within Region 10? I’d like to get this application review started with EPA. Please let me know when you are available to discuss this. Thanks and Be Well, Steve Davies Senior Petroleum Geologist AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov. From: Wallace, Chris D (OGC) <chris.wallace@alaska.gov> Sent: Thursday, August 15, 2024 4:20 PM To: Robinson, James <Robinson.James@epa.gov> Cc: Osborne, Evan <Osborne.Evan@epa.gov>; Mayers, Timothy <Mayers.Timothy@epa.gov>; Gross, Ryan <Gross.Ryan@epa.gov>; Davies, Stephen F (OGC) <steve.davies@alaska.gov> Subject: FW: Aquifer Exemption for Susan Dionne 8 James, Please see below from Steve on a new aquifer exemption we are progressing. Thanks and Regards, Chris Wallace, Sr. Petroleum Engineer, Alaska Oil and Gas Conservation Commission, 333 West 7th Avenue, Anchorage, AK 99501, (907) 793-1250 (phone), (907) 276-7542 (fax), chris.wallace@alaska.gov 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 Chris Wallace at 907-793-1250 or chris.wallace@alaska.gov. From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Thursday, August 15, 2024 7:21 AM To: Gross, Ryan <Gross.Ryan@epa.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov> Subject: Aquifer Exemption for Susan Dionne 8 Ryan, Steve Davies of the Alaska Oil and Gas Conservation Commission here. We last corresponded in August 2022 concerning an aquifer exemption for the North Fork Unit on the Kenai Peninsula, Cook Inlet Basin, Alaska. Are you still part of Region 10’s team that reviews aquifer exemption applications for Alaska? If not, could you please point me to the proper contact within Region 10? The proposed exemption that I am working on is conversion of an existing, shut in gas well into a back-up Class II disposal injection well located onshore along the western coastline of the Kenai Peninsula. I have completed a draft version of the EPA’s Aquifer Exemption Checklist form that was used for the North Fork Unit exemption. To expedite review, I’d like to discuss this with you and, if possible, submit my draft of EPA’s checklist to you for a quick preliminary review to ensure that I haven’t overlooked anything. Please let me know if this works for you. Thanks and Be Well, Steve Davies Senior Petroleum Geologist AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov. Caution: This email originated from outside EPA, please exercise additional caution when CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. From:Davies, Stephen F (OGC) To:Osborne, Evan; Robinson, James; Mayers, Timothy Cc:Wallace, Chris D (OGC) Subject:RE: Aquifer Exemption for Susan Dionne 8 Date:Wednesday, August 21, 2024 8:38:49 AM Evan, Friday at 9 AM would be best for me. I’m unavailable this morning. Thanks, Steve Davies AOGCC From: Osborne, Evan <Osborne.Evan@epa.gov> Sent: Wednesday, August 21, 2024 7:12 AM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov>; Robinson, James <Robinson.James@epa.gov>; Mayers, Timothy <Mayers.Timothy@epa.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov> Subject: RE: Aquifer Exemption for Susan Dionne 8 Steve, Thank you for contacting us and raising this issue. Answer: Yes, we are the team that will be reviewing this request. I suggest we set up a meeting to discuss the proposed aquifer exemption. Does that work with your timeline for issuance? How about tomorrow at 10AM AK time? Or Friday at 9AM AK time? Best, Evan From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Tuesday, August 20, 2024 5:51 PM To: Robinson, James <Robinson.James@epa.gov>; Osborne, Evan <Osborne.Evan@epa.gov>; Mayers, Timothy <Mayers.Timothy@epa.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov> Subject: RE: Aquifer Exemption for Susan Dionne 8 deciding whether to open attachments or click on provided links. Evan, James, and Tim: Steve Davies of the Alaska Oil and Gas Conservation Commission here. Are any of you part of Region 10’s team that reviews aquifer exemption applications for Alaska? If not, could you please point me to the proper contact within Region 10? I’d like to get this application review started with EPA. Please let me know when you are available to discuss this. Thanks and Be Well, Steve Davies Senior Petroleum Geologist AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov. From: Wallace, Chris D (OGC) <chris.wallace@alaska.gov> Sent: Thursday, August 15, 2024 4:20 PM To: Robinson, James <Robinson.James@epa.gov> Cc: Osborne, Evan <Osborne.Evan@epa.gov>; Mayers, Timothy <Mayers.Timothy@epa.gov>; Gross, Ryan <Gross.Ryan@epa.gov>; Davies, Stephen F (OGC) <steve.davies@alaska.gov> Subject: FW: Aquifer Exemption for Susan Dionne 8 James, Please see below from Steve on a new aquifer exemption we are progressing. Thanks and Regards, Chris Wallace, Sr. Petroleum Engineer, Alaska Oil and Gas Conservation Commission, 333 West 7th Avenue, Anchorage, AK 99501, (907) 793-1250 (phone), (907) 276-7542 (fax), chris.wallace@alaska.gov 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 Chris Wallace at 907-793-1250 or chris.wallace@alaska.gov. From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Thursday, August 15, 2024 7:21 AM To: Gross, Ryan <Gross.Ryan@epa.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov> Subject: Aquifer Exemption for Susan Dionne 8 Ryan, Steve Davies of the Alaska Oil and Gas Conservation Commission here. We last corresponded in August 2022 concerning an aquifer exemption for the North Fork Unit on the Kenai Peninsula, Cook Inlet Basin, Alaska. Are you still part of Region 10’s team that reviews aquifer exemption applications for Alaska? If not, could you please point me to the proper contact within Region 10? The proposed exemption that I am working on is conversion of an existing, shut in gas well into a back-up Class II disposal injection well located onshore along the western coastline of the Kenai Peninsula. I have completed a draft version of the EPA’s Aquifer Exemption Checklist form that was used for the North Fork Unit exemption. To expedite review, I’d like to discuss this with you and, if possible, submit my draft of EPA’s checklist to you for a quick preliminary review to ensure that I haven’t overlooked anything. Please let me know if this works for you. Thanks and Be Well, Steve Davies Senior Petroleum Geologist AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov. CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. From:Davies, Stephen F (OGC) To:Osborne, Evan Subject:RE: Aquifer Exemption for Susan Dionne 8 Date:Friday, August 23, 2024 9:04:00 AM Hi Evan, I’ve been looking through my emails to find your phone number. Are you available for a quick phone call? Thanks, Steve Davies AOGCC From: Osborne, Evan <Osborne.Evan@epa.gov> Sent: Wednesday, August 21, 2024 7:12 AM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov>; Robinson, James <Robinson.James@epa.gov>; Mayers, Timothy <Mayers.Timothy@epa.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov> Subject: RE: Aquifer Exemption for Susan Dionne 8 Steve, Thank you for contacting us and raising this issue. Answer: Yes, we are the team that will be reviewing this request. I suggest we set up a meeting to discuss the proposed aquifer exemption. Does that work with your timeline for issuance? How about tomorrow at 10AM AK time? Or Friday at 9AM AK time? Best, Evan From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Tuesday, August 20, 2024 5:51 PM To: Robinson, James <Robinson.James@epa.gov>; Osborne, Evan <Osborne.Evan@epa.gov>; Mayers, Timothy <Mayers.Timothy@epa.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov> Subject: RE: Aquifer Exemption for Susan Dionne 8 Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. Evan, James, and Tim: Steve Davies of the Alaska Oil and Gas Conservation Commission here. Are any of you part of Region 10’s team that reviews aquifer exemption applications for Alaska? If not, could you please point me to the proper contact within Region 10? I’d like to get this application review started with EPA. Please let me know when you are available to discuss this. Thanks and Be Well, Steve Davies Senior Petroleum Geologist AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov. From: Wallace, Chris D (OGC) <chris.wallace@alaska.gov> Sent: Thursday, August 15, 2024 4:20 PM To: Robinson, James <Robinson.James@epa.gov> Cc: Osborne, Evan <Osborne.Evan@epa.gov>; Mayers, Timothy <Mayers.Timothy@epa.gov>; Gross, Ryan <Gross.Ryan@epa.gov>; Davies, Stephen F (OGC) <steve.davies@alaska.gov> Subject: FW: Aquifer Exemption for Susan Dionne 8 James, Please see below from Steve on a new aquifer exemption we are progressing. Thanks and Regards, Chris Wallace, Sr. Petroleum Engineer, Alaska Oil and Gas Conservation Commission, 333 West 7th Avenue, Anchorage, AK 99501, (907) 793-1250 (phone), (907) 276-7542 (fax), chris.wallace@alaska.gov 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 Chris Wallace at 907-793-1250 or chris.wallace@alaska.gov. From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Thursday, August 15, 2024 7:21 AM To: Gross, Ryan <Gross.Ryan@epa.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov> Subject: Aquifer Exemption for Susan Dionne 8 Ryan, Steve Davies of the Alaska Oil and Gas Conservation Commission here. We last corresponded in August 2022 concerning an aquifer exemption for the North Fork Unit on the Kenai Peninsula, Cook Inlet Basin, Alaska. Are you still part of Region 10’s team that reviews aquifer exemption applications for Alaska? If not, could you please point me to the proper contact within Region 10? The proposed exemption that I am working on is conversion of an existing, shut in gas well into a back-up Class II disposal injection well located onshore along the western coastline of the Kenai Peninsula. I have completed a draft version of the EPA’s Aquifer Exemption Checklist form that was used for the North Fork Unit exemption. To expedite review, I’d like to discuss this with you and, if possible, submit my draft of EPA’s checklist to you for a quick preliminary review to ensure that I haven’t overlooked anything. Please let me know if this works for you. Thanks and Be Well, Steve Davies Senior Petroleum Geologist AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov. CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. From:Osborne, Evan To:Davies, Stephen F (OGC) Subject:RE: Aquifer Exemption for Susan Dionne 8 Date:Friday, August 23, 2024 9:16:34 AM I am – I also can’t find your number in your signature. I can be reached at 206-553-1747! From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Friday, August 23, 2024 10:04 AM To: Osborne, Evan <Osborne.Evan@epa.gov> Subject: RE: Aquifer Exemption for Susan Dionne 8 Hi Evan, I’ve been looking through my emails to find your phone number. Are you available for a quick phone call? Thanks, Steve Davies AOGCC From: Osborne, Evan <Osborne.Evan@epa.gov> Sent: Wednesday, August 21, 2024 7:12 AM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov>; Robinson, James <Robinson.James@epa.gov>; Mayers, Timothy <Mayers.Timothy@epa.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov> Subject: RE: Aquifer Exemption for Susan Dionne 8 Steve, Thank you for contacting us and raising this issue. Answer: Yes, we are the team that will be reviewing this request. I suggest we set up a meeting to discuss the proposed aquifer exemption. Does that work with your timeline for issuance? How about tomorrow at 10AM AK time? Or Friday at 9AM AK time? Best, Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. Evan From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Tuesday, August 20, 2024 5:51 PM To: Robinson, James <Robinson.James@epa.gov>; Osborne, Evan <Osborne.Evan@epa.gov>; Mayers, Timothy <Mayers.Timothy@epa.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov> Subject: RE: Aquifer Exemption for Susan Dionne 8 Evan, James, and Tim: Steve Davies of the Alaska Oil and Gas Conservation Commission here. Are any of you part of Region 10’s team that reviews aquifer exemption applications for Alaska? If not, could you please point me to the proper contact within Region 10? I’d like to get this application review started with EPA. Please let me know when you are available to discuss this. Thanks and Be Well, Steve Davies Senior Petroleum Geologist AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov. From: Wallace, Chris D (OGC) <chris.wallace@alaska.gov> Sent: Thursday, August 15, 2024 4:20 PM To: Robinson, James <Robinson.James@epa.gov> Cc: Osborne, Evan <Osborne.Evan@epa.gov>; Mayers, Timothy <Mayers.Timothy@epa.gov>; Gross, Ryan <Gross.Ryan@epa.gov>; Davies, Stephen F (OGC) <steve.davies@alaska.gov> Subject: FW: Aquifer Exemption for Susan Dionne 8 James, Please see below from Steve on a new aquifer exemption we are progressing. Thanks and Regards, Chris Wallace, Sr. Petroleum Engineer, Alaska Oil and Gas Conservation Commission, 333 West 7th Avenue, Anchorage, AK 99501, (907) 793-1250 (phone), (907) 276-7542 (fax), chris.wallace@alaska.gov 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 Chris Wallace at 907-793-1250 or chris.wallace@alaska.gov. From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Thursday, August 15, 2024 7:21 AM To: Gross, Ryan <Gross.Ryan@epa.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov> Subject: Aquifer Exemption for Susan Dionne 8 Ryan, Steve Davies of the Alaska Oil and Gas Conservation Commission here. We last corresponded in August 2022 concerning an aquifer exemption for the North Fork Unit on the Kenai Peninsula, Cook Inlet Basin, Alaska. Are you still part of Region 10’s team that reviews aquifer exemption applications for Alaska? If not, could you please point me to the proper contact within Region 10? The proposed exemption that I am working on is conversion of an existing, shut in gas well into a back-up Class II disposal injection well located onshore along the western coastline of the Kenai Peninsula. I have completed a draft version of the EPA’s Aquifer Exemption Checklist form that was used for the North Fork Unit exemption. To expedite review, I’d like to discuss this with you and, if possible, submit my draft of EPA’s checklist to you for a quick preliminary review to ensure that I haven’t overlooked anything. Please let me know if this works for you. Thanks and Be Well, Steve Davies Senior Petroleum Geologist AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov. Draft Aquifer Exemption Checklist for Susan Dionne 8, Kenai Peninsula, Alaska Page 1 of Aquifer Exemption Checklist – Susan Dionne No. 8, Kenai Peninsula, Alaska DRAFT Reviewed by:____________________________ Date: ___________ A- Regulatory Background and Purpose An aquifer or a portion thereof which meets the criteria for an "underground source of drinking water" in § 146.3 may be determined to be an "exempted aquifer". The aquifer exemption criteria at 146.4 must be met as follows: Class 1-V wells must meet criteria 146.4(a) and 146.4(b)(l); or 146.4(a) and 146.4(b)(2); or 146.4(a) and 146.4(b)(3); or 146.4(a) and 146.4(b)(4); or 146.4(a) and 146.4(c). Class VI wells must meet the criteria 146.4(d)1. Regardless of the AE request or the type of injection activity, in all cases, first and foremost a demonstration that the aquifer or portion thereof does not currently serve as a source of drinking water is the required first step in the process. EPA must evaluate each AE request to ensure the criteria are met prior to approval. EPA should also document its rationale for approving or disapproving each AE request in its statement of basis and, in case of exemptions that are substantial program revisions, EPA must provide public notice and an opportunity for the public to comment and request a public hearing. The purpose of this checklist is to ensure that appropriate and adequate information is collected to facilitate review of AE requests, and documentation of AE decisions. Some information described here may not apply to all AE requests. B- General Information AE request received by EPA on: Hilcorp Is the aquifer exemption Substantial or Non-Substantial? Non-substantial Describe basis for substantial/non-substantial determination. The proposed action is not a state program revision. This proposed AE is a minor exemption because it is associated with the issuance of a site-specific UIC permit action for existing well Susan Dionne (SD) No. 8 (SD8), not a state-wide programmatic change or a revision with implications for the state-wide or national UIC program. Is the aquifer exemption Complex? (Existence of drinking water wells, populated area ...) Yes, it is Complex due to drinking water wells within the general vicinity. Did the state or tribe provide public notice and opportunity for public hearing on the aquifer exemption request? (144.7 (b1) Yes, the public notice was published in the Anchorage Daily News on May 30, 2024, with the public hearing tentatively scheduled for July 16, 2024. Since no public comments or request for hearing were received, AOGCC vacated the public hearing. Were there any public comments? No. Draft Aquifer Exemption Checklist for Susan Dionne 8, Kenai Peninsula, Alaska Page 2 of If yes, identify, where they may be located. None received. Date(s) of notice(s) published: May 30, 2024 Public meeting(s) held: None. Hearing held: Public Hearing vacated. Any notable findings or pending litigation: None Describe the notice and comment process and the final decision: On May 30, 2024, the AOGCC published notice of the public hearing on the State of Alaska’s Online Public Notice website and on the AOGCC’s website, electronically transmitted the notice to all persons on the AOGCC’s email distribution list and mailed printed copies of the Notice of Public Hearing to all persons on the AOGCC’s mailing distribution list. On June 2, 2024, the notice was published in the Anchorage Daily News. The 15-day public comment period required under Alaska Administrative Code Regulation 20 AAC 25.440 ended at the July 3, 2024. No comments were received. A draft copy of the text for the AOGCC’s final decision (in progress) will be attached. Describe the basis for the decision to exempt the aquifer or the basis for the decision to withhold or deny approval of the exemptions request. The basis for the decision to exempt the Beluga Formation (Beluga), Beluga 135 sand aquifer for disposal injection purposes in the existing well SD8 (API Number 50-133-20611-00-00) between 3,869’ MD (equivalent to 3,729’ TVD and -3,569’ TVDSS)1 and 4,004’ MD (equivalent to 3,854’ TVD and -3,694’ TVDSS) are: 1. The Beluga 135 sand aquifer within Hilcorp’s proposed exemption area between the above listed depths does not currently serve as sources of drinking water. 2. The proposed exempted interval within the proposed exemption area cannot reasonably be expected to serve as an underground source of drinking water because: a. All known and foreseeable ground water consumption from the vicinity is consistent with plentiful surface water and groundwater resources occurring above a depth of 200 feet below ground surface. b. Groundwater within the Beluga 135 sand aquifer within Hilcorp’s proposed exemption area is so contaminated and is situated at depths that make recovery for drinking water purposes economically impractical. Any anticipated issues associated with EPA approval or disapproval of the AE request? Yes. AOGCC’s Disposal Injection Order No. 47 (DIO 47) states in part: “Injection operations are prohibited until AOGCC issues—and the U.S. EPA approves or does not act on — the 1 Measured depths used herein to describe various confining layers and injection zones are taken from the Susan Dionne 8 reference well log presented in Hilcorp’s application. All true vertical depth (TVD) and true vertical depth below sea level (true vertical depth “subsea”, or TVDSS) values presented herein were calculated using the minimum curvature method from the lithologic boundaries and measured depths annotated on the reference well log. To avoid confusion, for equivalent depths presented herein that represent true vertical depth, the footage will be a positive integer followed by the acronym TVD (e.g., 3,729’ TVD). For equivalent depths that represent true vertical depth subsea, the footage will be preceded by a negative sign and followed by the acronym TVDSS (e.g., 3,569’ true vertical depth subsea will be depicted as -3,569’ TVDSS). Draft Aquifer Exemption Checklist for Susan Dionne 8, Kenai Peninsula, Alaska Page 3 of decision regarding Hilcorp’s requested Aquifer Exemption Order for the Susan Dionne No. 8.” If disapproved by EPA, the AOGCC will re-evaluate Hilcorp’s planned disposal injection project and DIO 47. Any meetings between EPA/ States/ Tribes/Operator to discuss issues? No List: A teleconference call between EPA and Alaska Oil and Gas Conservation Commission (AOGCC) representatives occurred on ________, 2024. Is the request submitted by a primacy state or tribe? Yes If yes, name the State/Tribe/ Agency: AOGCC Contacts: UIC Coordinator: Chris Wallace, AOGCC, 907-793-1250 Senior Geologist: Steve Davies, AOGCC, 907-793-1224 AE identified by the Primacy State or tribe and submitted for EPA review and final determination on: ________, 2024 Name of the Owner/Operator: Hilcorp Alaska Operating, LLC (Hilcorp) Well/ Project Name: SD8, Alaska, Aquifer Exemption Well Class: II Purpose of injection: (mineral mining/oil and gas/other) Hilcorp requests approval to dispose by injection solids-free produced water from Hilcorp's Ninilchik Unit operations, and other fluids eligible for injection into a Class II disposal wells. Where is the proposed aquifer exemption located? Southern portion of the Kenai Peninsula, Alaska, about 5-1/4 miles northeast of the City of Ninilchik. Township, Section, Range, Quarter Section or other method used to identify the area: Hilcorp requested an aquifer exemption for those portions of Sections 6 and 7, Township 1 South, Range 13 West, Seward Meridian, Kenai Peninsula Borough, Alaska that lie within one- quarter mile radius of the proposed Beluga 135 sand injection interval within well SD8. Latitude and longitude information: (NAD 83) SD8 Well Location Latitude (NAD83) Longitude (NAD83) Wellhead 60.112353 -151.575897 County: Kenai Peninsula Borough City: 5-1/4 miles northeast of the City of Ninilchik State: Alaska Add information about distance to nearest Town, County: 5-1/4 miles southwest of the City of Ninilchik Draft Aquifer Exemption Checklist for Susan Dionne 8, Kenai Peninsula, Alaska Page 4 of Name of aquifer or portion of aquifer to be exempted: Beluga 135. Areal extent of the area proposed for exemption: Requested exempted area constitutes those portions of Sections 6 and 7, Township 1 South, Range 13 West, Seward Meridian, Kenai Peninsula Borough, Alaska that lie within a one- quarter mile radius of the proposed Beluga 135 sand disposal interval within SD8. Depth and thickness of the aquifer: Those portions of the Beluga Formation stratigraphically equivalent to the interval from 3,869’ to 4,004’ MD in well SD8 (API Number 50-133-20611-00-00). These measured depths are equivalent to 3,729’ and 3,854’ TVD and -3,570’ and -3,694’ TVDSS, respectively, for an overall vertical thickness of about 125’. The inclination of the wellbore through the proposed injection interval is about 22.7 degrees. The elevation of the ground surface at SD8 is 135’ above mean sea level. Discuss the total dissolved solid (TDS) content of the aquifer, including the TDS at the top and bottom of the exempted zone, and the locations and depths of all fluids samples taken. Hilcorp acquired water samples from the Beluga 135 sand in nearby well Susan Dionne 1A (API Number 50-133-10002-01-00). In Susan Dionne 1A, the Beluga 135 interval lies only about 140’ from that same interval in SD8, so the water samples obtained from Susan Dionne 1A are considered representative of the formation waters in SD8. Hilcorp provided laboratory analyses for two water samples obtained from the Beluga 135 interval in Susan Dionne 1A. Total Dissolved Solids for these samples measured 1,700 and 1,920 mg/l. However, it is important to note that the concentrations of six metals and 16 organic compounds measured in these samples exceed—and in many cases far exceed—the Groundwater Human Health Cleanup Levels specified in Alaska Regulation 18 AAC 75.345, which is titled “Groundwater and surface water cleanup levels.” C- Regulatory Criteria 146.4: An aquifer or a portion thereof may be determined to be an exempted aquifer for Class 1-V wells if it meets the criteria in paragraphs (a) -{c) below. Other than EPA approved aquifer exemption expansions that meet the criteria set forth in 146.4(d), new aquifer exemptions for Class VI wells shall not be issued. (a) Not currently used as a drinking water source and: (b)(l) It is mineral, hydrocarbon, or geothermal energy producing, or can be demonstrated by a permit applicant as part of a permit application for a Class II or Class II operation to contain minerals or hydrocarbons that considering their quantity and location are expected to be commercially producible; or (b)(2) It is situated at a depth or location which makes recovery of water for drinking water purposes economically or technologically impractical; or (b)(3) It is so contaminated that it would be economically or technologically impractical to render that water fit for human consumption; or (b)(4) It is located over a Class Ill well mining area subject to subsidence or catastrophic collapse; Draft Aquifer Exemption Checklist for Susan Dionne 8, Kenai Peninsula, Alaska Page 5 of Or (c) TDS is more than 3,000 and less than 10,000 mg/I and it is not reasonably expected to supply a public water system. (d) The areal extent of an aquifer exemption for Class II enhanced oil recovery or enhanced gas recovery well may be expanded for the exclusive purpose of Class VI injection for geologic sequestration under§ 144.l(d) if  it does not currently serve as a source of drinking water; and  the TDS is more than 3,000 mg/I and less than 10,000 mg/I; and  it is not reasonably expected to supply to public water system. Criteria Applies? (a) Not currently used as a drinking water source and: Yes (b)(l) It is mineral, hydrocarbon, or geothermal energy producing, or can be demonstrated by a permit applicant as part of a permit application for a Class II or Class II operation to contain minerals or hydrocarbons that considering their quantity and location are expected to be commercially producible; or Yes (b)(2) It is situated at a depth or location which makes recovery of water for drinking water purposes economically or technologically impractical; or Yes (b)(3) It is so contaminated that it would be economically or technologically impractical to render that water fit for human consumption; or Yes (b)(4) It is located over a Class Ill well mining area subject to subsidence or catastrophic collapse; N/A Or (c) TDS is more than 3,000 and less than 10,000 mg/I and it is not reasonably expected to supply a public water system. No (d) The areal extent of an aquifer exemption for Class II enhanced oil recovery or enhanced gas recovery well may be expanded for the exclusive purpose of Class VI injection for geologic sequestration under§ 144.l(d) if N/A it does not currently serve as a source of drinking water; and N/A the TDS is more than 3,000 mg/I and less than 10,000 mg/I; and N/A it is not reasonably expected to supply a public water system. N/A 1 - Demonstration that the aquifer or portion thereof does not currently serve as a source of drinking water: Describe the proposed exempted area and how it was determined: Hilcorp’s requested area for freshwater aquifer exemption consists of those portions of Sections 6 and 7 of Township 1 South, Range 13 West, Seward Meridian that lie within the Ninilchik Unit (Figure A-1, below). The operator’s requested exemption area encompasses the southern portion of the Ninilchik Unit and extends one-quarter mile from the proposed Beluga 135 injection interval in SD8. TDS: Hilcorp’s laboratory results indicate TDS concentrations for the native formation waters in the Draft Aquifer Exemption Checklist for Susan Dionne 8, Kenai Peninsula, Alaska Page 6 of sands the proposed injection zone, range from 1,700 to 1,920 mg/l. However, these analytical results demonstrate that 6 metals and 16 organic compounds exceed—and in most cases far exceed—the Groundwater Human Health Cleanup Levels specified in Alaska Regulation 18 AAC 75.345 Requested Top: Approximately 3,862’ MD (equivalent to 3,723’ TVD and -3,563’ TVDSS). Requested Bottom: Approximately 4,055’ MD (equivalent to 3,901’ TVD and -3,741’ TVDSS). Figure 1. Index Map – SD8 Area (Source: Hilcorp Alaska, Inc.) The green dashed line represents the SD8 landowner-notification boundary; the red dashed circle represents a radius of one-quarter mile from the planned disposal interval. Lithology: Hilcorp’s injection targets the Beluga 135 reservoir which consists of very fine- to fine-grained sandstone deposited in stacked fluvial channels. Permeability: 61 millidarcies (from core analysis) Porosity: 23.5 percent (from core analysis) 0 1 mile Draft Aquifer Exemption Checklist for Susan Dionne 8, Kenai Peninsula, Alaska Page 7 of Groundwater flow direction: Near-surface aquifers will likely flow west to northwest toward the adjacent Cook Inlet in conformance with the topographic gradient of the local ground surface and stream beds. Upper and lower confining zone(s) and description of vertical confinement from USDWs: Upper confinement is provided by about 115 true vertical feet of laterally continuous, interlaminated mudstones, siltstones, and thin coal seams (Beluga 131 through Beluga 134 intervals). Lower confinement provided by about 75 true vertical feet of laterally continuous siltstone layers and thin coal seams (Beluga 136 and Tyonek Formation T-2 intervals). Oil, gas, or mineral production history: SD8 is an unsuccessful oil exploration well drilled in 2013 to 12,130’ MD (11,556’ TVD) along the western coastline of the Cook Inlet that targeted the West Foreland and Hemlock Formations. Flow tests determined that these prospective oil zones were non-commercial, and the well was subsequently recompleted up-hole as a dual-string (2-3/8”) gas producer in the Tyonek T-140 and overlying Beluga 135 intervals. The well did not produce as expected. The T-140 interval was deemed non-productive, and the Beluga 135 produced large amounts of water with some sand. It was subsequently shut-in during May of 2014. Figure 2. Production History -- SD8 (Source: AOGCC’s RBDMS Production database) Production record for the Beluga 135 sand and several underlying Tyonek Formation sands. Draft Aquifer Exemption Checklist for Susan Dionne 8, Kenai Peninsula, Alaska Page 8 of In June of 2014, the T-140 perforations were isolated with a cast-iron bridge plug topped with cement, perforations in the Beluga 135 were squeezed. The dual completion strings were replaced by a single, 4-1/2” completion string, two additional Tyonek reservoirs—T-90 and T- 83—were perforated, and the well was put back on production. Pressure and temperature surveys in June and August 2014 indicated the T-90 is wet, so that interval was isolated using a through-tubing bridge plug topped with cement. In August 2018, an additional sand—T-2— was perforated, but production did not improve and in September 2018 the well was shut in with no future up-hole gas development opportunities. Are there any public or private drinking water wells within and nearby the proposed exempted area for which the proposed exempted portion of the aquifer might be a source of drinking water? No. The proposed exempted portion of the aquifer does not now, nor will it in the foreseeable future, serve as a source of drinking water due to:  plentiful near-surface freshwater aquifers (less than 400’ below ground level, or BGL),  the roughly 3,000-foot vertical separation of the base of those aquifers from the proposed, exempted aquifer, and  water-sample laboratory analytical results demonstrating that 6 metals and 16 organic compounds exceed the levels specified in Alaska Regulation 18 AAC 75.345. Figure 3, below, depicts the water wells registered with the State of Alaska that lie the governmental sections surrounding the proposed injection interval within SD8. If yes, list all those wells: The tables below capture general information about the 13 registered water wells and the 5 subsurface water rights authorizations that are recorded within Sections 5, 6, 7, and 8 of T1S, R13W, SM, which lie within about 1.4 miles of the proposed injection interval. These data are taken from the Alaska Department of Natural Resources (AK DNR), Division of Mining, Land and Water’s Well Log Tracking System (WELTS)2 and AK DNR’s Land Administration System (LAS) that were accessed for this checklist on July 18 and July 22, 2024. From these tables it is evident that the deepest drinking-water well in this area (257 feet BGL, or about -122’ TVDSS, and located nearby on the operator’s drilling pad) lies about 3,447 vertical feet shallower than the top of the planned injection zone in SD8 at 3,869’ MD (equivalent to 3,729’ TVD and -3,569’ TVDSS). The acronym LAS refers to the AK DNR’s Land Administration System, and the associated numbers are the LAS case-file index numbers. The acronym TWUA refers to a State of Alaska Subsurface Temporary Water Use Authorization. In addition, Hilcorp identified two public water system sources wells in the area: a 200-foot deep well at Scenic View RV Park located 1.8 miles northeast of Susan Dionne 8, and a 45- foot deep well at Ninilchik 132.6 Cabins and RV Park is located three miles southwest of Susan Dionne 8. 2 The WELTS database contains water well construction and lithologic information submitted to the Division of Mining, Land and Water by water well contractors as required per Alaska State Statute 41.08.020(b4). See https://gis.data.alaska.gov/datasets/SOA-DNR::dnr-well-log-welts/about. Draft Aquifer Exemption Checklist for Susan Dionne 8, Kenai Peninsula, Alaska Page 9 of Well No. Owner Case ID No. Depth (ft) 1293 Carolyn Issermoyer Not Listed 50 2282 John Mollette Not Listed 200 8259 Bob Wallis Not Listed 127 19164 Leo Thornton Not Listed 58 19165 Foster Leng Not Listed 58 19190 Albert Jones Not Listed 55 21474 Darrell Jones Not Listed 101 25804 Marathon Oil Co. TWUA A2017-16 257 26930 J. Inman Not Listed 98 42933 Lawrence Baker Not Listed 120 47475 Robert Frost Not Listed Not Listed 75656 Ron Kingsley LAS 32051 109 84070 Hilcorp TWUA A2019-154 111 Table 1. List of the 13 Registered Domestic and Commercial Water Wells within Surrounding Governmental Sections 5, 6, 7, and 8 of T1S, R13W, SM (Source: Alaska DNR’s Alaska Mapper - WELTS Map) Draft Aquifer Exemption Checklist for Susan Dionne 8, Kenai Peninsula, Alaska Page 10 of Figure 3. Drinking Water Wells and Water Use Authorizations – SD8 Area Registered drinking water wells (blue), subsurface water-use and temporary water-use authorization information (red) with associated well depths when available. (Source: AKDNR’s WELTS and Water Estate databases) Case File No. Owner Case Type / Code Description Depth (ft) LAS 3436 Richard E. Person Water Rights - Subsurface 115 ADL 44511 W. Lee McKinley Water Rights - Subsurface Not Listed ADL 213078 Carolyn Reifsnyder Water Rights - Subsurface Not Listed LAS 32051 Laurie J. Lincoln Water Rights - Subsurface 109 TWUA A2021-149 Hilcorp Alaska, LLC. Temporary Water Use Authorization - Subsurface 257 Table 2. List of the 5 Subsurface Water Rights and Authorizations within Surrounding Governmental Sections 5, 6, 7, and 8 of T1S, R13W, SM (Source: Alaska DNR’s Alaska Mapper - Water Estate Map) Draft Aquifer Exemption Checklist for Susan Dionne 8, Kenai Peninsula, Alaska Page 11 of Include:  pertinent map(s) visually showing the areal extent of exemption boundary, Figure 4, below, depicts the proposed Beluga 135 exemption boundary for SD8 and registered water wells and water-use authorizations that lie within one-quarter and one-half mile radii. Hilcorp’s requested exemption area extends one-quarter mile from the Beluga 135 interval in SD8 (represented by the smaller, dashed red circle).  depth and thickness of the aquifer proposed for exemption, Top: 3,869’ MD (equivalent to 3,729’ TVD and -3,569’ TVDSS) Bottom: 4,004’ MD (equivalent to 3,854’ TVD and -3,694’ TVDSS) Total Vertical Thickness: 125 feet.  all known subsurface structures such as faults affecting the aquifer, Figure 5, below, from Hilcorp’s application, shows the structure atop the proposed injection zone. The structure is a simple, four-way anticlinal closure with an apex about one mile southwest of the injection interval. Hilcorp has not identified any faults within a one-mile radius of the proposed Beluga 135 interval within SD8.3  and each of the inventoried water well locations by well # or owner name. Include: Table of all inventoried water wells showing:  Well Name/#,  Owner, (Private/Public),  Contact information,  Purpose of well (Domestic, Irrigation, Livestock, etc.),  depth of source water,  name of aquifer,  well completion data,  age of well (if known), and  primary source of well data (Applicant/State/Tribe/EPA). 3 Morse, Casey, 2024, Hilcorp Email Correspondence with S. Davies of AOGCC, July 23, 2024 Draft Aquifer Exemption Checklist for Susan Dionne 8, Kenai Peninsula, Alaska Page 12 of Figure 4. Requested Exempted Area Surrounding Proposed Injection Interval in SD8 Red dashed circles represent one-quarter mile (inner circle representing requested exempted area) and one-half mile (outer circle representing Area of Review) from the proposed injection interval. (Source: AKDNR’s WELTS and Water Estate databases) See data tables, above, for Well and Case-File Numbers, Owner names, well depths, and subsurface water rights authorizations. Owner contact information can be provided upon request. The Ak DNR Division of Mining, Land and Water’s Well Log Tracking System (WELTS) does not provide information regarding purpose of well, name of aquifer, or completion data. Three aquifers exist in this portion of the Kenai Peninsula: Alluvial Channel Aquifer (gravel and sand deposited as channel fillings) to a depth of roughly 40 feet below ground level, Moraine Aquifer (glacial deposits of mixed sand, gravel, silt and clay) to a depth of about 120 feet below ground, and the underlying Bedrock Aquifer, which in the Ninilchik Draft Aquifer Exemption Checklist for Susan Dionne 8, Kenai Peninsula, Alaska Page 13 of Figure 5. Beluga 135 Structure Map –SD8 Area Red circle represents a one-quarter radius from the proposed injection interval. (Source: Hilcorp Alaska, LLC) Unit area is Tertiary-aged Sterling Formation (sandstone, claystone, and thin coals formed as channel, overbank and flood-plain deposits associated with meandering rivers and streams).4 4 Petrik, W.A., 1993, Aquifers and Hydrogeology at Anchor Point, Alaska, Alaska Department of Natural Resources, Division of Geological & Geophysical Surveys, Division of Water, Public-Data File 93-50a Reger, R.D. and Petrik, 1993, Surficial Geology of the Anchor Point Area, Alaska, Alaska Department of Natural Resources, Division of Geological & Geophysical Surveys, Division of Water, Public-Data File 93-50B Arctic GeoScience Inc., 2002, Review of Regional Hydrogeologic Conditions, Cosmo Prospect, Hansen #1 Well Site, Anchor Point, Alaska, in AOGCC Well History File 2011570, p. 232 – 239 Draft Aquifer Exemption Checklist for Susan Dionne 8, Kenai Peninsula, Alaska Page 14 of Include:  Map showing the areal extent of exemption boundary, The areal extent of Hilcorp’s requested exempted area is presented on Figures 4 and 5, above.  all domestic water wells considered potentially down-gradient of the exemption and hydraulically connected to the exemption. None. Registered water wells within and near Hilcorp’s requested exemption area are not hydraulically connected to the proposed injection zone. The deepest of these water wells (257 feet below ground) is separated from the top of the planned injection zones by intervals of sandstone and thinly interbedded tuffaceous claystone, tuffaceous siltstone, coal, and carbonaceous shale within the Sterling Formation and about 2,785 true vertical feet of thinly interbedded siltstone, tuffaceous siltstone, claystone, coal, carbonaceous shale, and discontinuous sands assigned to the underlying Beluga Formation. If wells are deemed horizontally and/or vertically isolated from the exemption, this should be foot noted on the Table as well. As noted above, the registered water wells within and near Hilcorp’s requested exemption area are vertically isolated from the proposed injection zone. Use arrow(s) to indicate the direction and speed of GW in the aquifer proposed for exemption. Describe the evidence presented in the application and/or methodology used to conclude GW direction and speed when relevant. Direction and speed of groundwater within the proposed exemption interval is unknown, but the direction of flow is likely controlled by the east- to northeast-dipping local structural gradient. Include: any source water assessment and/or protection areas and designated sole source aquifers located within the delineated area. None. What is the appropriate area to examine for drinking water wells? Although guidance 34 says it should be a minimum of 1/4 mile, the determination of the appropriate area is on a case-by-case basis. Describe area and give a rationale. Hilcorp requested an exemption area encompassing a one-quarter mile radius around the Beluga 135 injection interval. Information for all registered water wells and subsurface water rights and authorizations within the governmental sections surrounding the injection interval have been compiled and examined. The only registered water well and authorizations within a one-half mile radius of the proposed injection interval are the operator’s 257-foot-deep Wilson, F.H., Hults, C.P., and Others, 2009, Preliminary Geologic Map of the Cook Inlet Region, Alaska, USGS Open File Report 2009-1108, Sheet 2 Draft Aquifer Exemption Checklist for Susan Dionne 8, Kenai Peninsula, Alaska Page 15 of commercial water well, which is located at the same Susan Dionne drill site. Otherwise, the nearest registered water well is WELTS Well No. 8259, which is located slightly more than one-half mile from the injection interval and is 127’ deep. Are there any public or private drinking water wells or springs capturing (or that will be capturing) or producing drinking water from the aquifer or portion thereof within the proposed exemption area? No. Evaluate the capture zone of the well (s) in the area near the proposed project (i.e., the volume of the aquifer(s) or portion(s) thereof from within which groundwater is expected to be captured by that well). Not applicable. A drinking water well's current source of water is the volume (or portion) of an aquifer which contains water that will be produced by a well in its lifetime. What parameters were considered to determine the lifetime of the well? (*) If the answer to this question is Yes, therefore the aquifer currently serves as a source of drinking water. Not applicable. 2 - Demonstration that the aquifer or portion thereof is mineral, hydrocarbon or geothermal energy producing per 146.4(b)(l) Did the permit applicant for a Class II or Ill operation demonstrate as part of the permit application that the aquifer or portion thereof contains minerals or hydrocarbons that, considering their quantity and location are expected to be commercially producible? Not commercially producible. SD8 is an unsuccessful oil exploration well that targeted the deeper West Foreland and Hemlock formations, which were both found non-commercial. The well was subsequently completed up-hole as a dual-string gas producer in the Tyonek T-140 and overlying Beluga 135 intervals. Combined, T-140 and Beluga 135 produced a total of 37,558,000 cubic feet of gas and 18,965 barrels of water over a total of 41 producing days. T- 140 was determined to be non-productive. Beluga 135 produced large amounts of water with some sand and was shut in. In June 2014, the Beluga 135 perforations were cement squeezed. Did the permit applicant furnish the data necessary to make the demonstration as required by 40 C.F.R. 144.7(c)(1) and (2)? Summarize this demonstration and data Include:  narrative statement,  logs,  maps,  data and  state-issued permit. Draft Aquifer Exemption Checklist for Susan Dionne 8, Kenai Peninsula, Alaska Page 16 of C.F.R. 144.7(c)(1) does not apply because this proposal does not involve a Class III well. C.F.R. 144.7(c)(2) applies to this proposed Class II operation, but as noted above, SD8 was produced 37,558,000 cubic feet of gas and 18,965 barrels of water between February and April of 2014, mostly from the proposed Beluga 135 injection interval. Perforations within the Beluga 135 were cement-squeezed in June 2014. If the proposed exemption is to allow a Class II enhanced oil recovery well operation in a field or project containing aquifers from which hydrocarbon were previously produced, commercial producibility shall be presumed by the Director upon a demonstration of historical production having occurred in the project area or field. Many times it may be necessary to slightly expand an existing Class II operation to recover hydrocarbons and an aquifer exemption for the expanded area may be needed. If the expanded exemption for the Class II EOR well is for a well field or project area where hydrocarbons were previously produced, commercial producibility would be presumed. SD8 is a gas development well that has been shut in since September 2018. For new or existing Class II wells not located in a field or project containing aquifers from which hydrocarbons were previously produced, information such as logs, core data, formation description, formation depth, formation thickness and formation parameters such as permeability or porosity shall be considered by the Director, to the extent available. SD8 produced gas at non-commercial rates from the lower Tyonek. Scanned images of the complete well history file are available online at http://aogweb.state.ak.us/weblink/0/doc/74471/Page1.aspx Electronic images of well logs, the mud log, and other digital data for SD8 are available upon request from the AOGCC by contacting Meredith Guhl, Petroleum Geology Assistant, at meredith.guhl@alaska.gov. Many Class II injection well permit applicants may consider much information concerning production potential to be proprietary. As a matter of policy, some states/tribes do not allow any information submitted as part of a permit application to be confidential. In those cases where potential production information is not being submitted, EPA would need some record basis for concluding that the permit application demonstrates that the aquifer contains commercially producible minerals or hydrocarbons. For example, the permit application may include the results of any R & D pilot project. In this case, the applicant should state the reasons for believing that there are commercially producible quantities of minerals within the expanded area. Also, exemptions relating to new or existing Class II wells not located in a field or project containing aquifers from which hydrocarbons were previously produced should include the following types of information: Regular production and injection information are not confidential for wells drilled in the State of Alaska. Such information is available online through the “Production” tab in AOGCC’s Data Miner web application at http://aogweb.state.ak.us/DataMiner4/Forms/Home.aspx. The SD8 data can be viewed or downloaded using the index Permit Number of 213051 or by typing Draft Aquifer Exemption Checklist for Susan Dionne 8, Kenai Peninsula, Alaska Page 17 of “S Dionne 8” (without the quotation marks) into the Well Name column. (NOTE: Clicking on the green-colored “radio button” open summary data for the well including blue-colored latitude/longitude coordinate values which are hyperlinks that display the wellhead and bottom-hole locations on Google Earth’s satellite photos. The blue-colored 213051 Permit Number next to the green radio button is a hyperlink that opens the scanned images of the SD8 well history file in AOGCC’s WebLink data management application.) a- Production history of the well if it is a former production well which is being converted. Table 3. SD8 - Production History - Beluga 135 and Tyonek T-140 Intervals (Source: AOGCC’s RBDMS Production Database) Commingled production from the Tyonek T-140 and Beluga 135 intervals was limed to three months from February to April 2014 and then the well was shut in. The T-140 interval was determined to be non-productive, and the Beluga 135 interval produced gas with large amounts of water. In June 2014, the T-140 perforations were isolated with a CIBP topped with cement, and the Beluga 135 perforations were squeezed. The chart shown above in Figure 2 presents the entire production history for SD8. b- Description of any drill stem tests run on the horizon in question. This should include information on the amount of oil and water produced during the test For SD8, the initial, 24-hour flow test of the combined Beluga 135 and Tyonek T-140 intervals produced 656,000 cubic feet of gas and 260 barrels of water as shown on the Well Completion Report, below.5 Table 4. SD8 – 24-Hour Production Test - Beluga 135 and Tyonek T-140 Intervals (Source: AOGCC’s RBDMS Laserfiche Weblink Document Management System) c- Production history of other wells in the vicinity which produce from the horizon in question. Thirteen wells penetrate the Beluga 135 interval within a one-mile radius of the proposed injection interval within SD8. Beluga 135 has been perforated in wells Susan Dionne 1A, Susan Dionne 5, Susan Dionne 6, SD8, and in nearby wells Kalotsa 2 and Kalotsa 3, all of which lie within that one-mile radius. Beluga 135 perforations are currently open for production in wells 5 AOGCC Well History File 213-051, p. 77 Draft Aquifer Exemption Checklist for Susan Dionne 8, Kenai Peninsula, Alaska Page 18 of Susan Dionne 1A, Susan Dionne 5, Kalotsa 2, and Kalotsa 3. However, the amount of gas recovered from Beluga 135 cannot be accurately estimated because production from Beluga 135 has been commingled that from various other Beluga and Tyonek sands within the Beluga/Tyonek Gas Pool. But the production test results shown in Table 4, above, and the production history discussed above demonstrate that the Beluga 135 interval in the vicinity of the Susan Dionne Pad is hydrocarbon bearing. d- Description of the project, if it is an enhanced recovery operation including the number of wells and their location. The Ninilchik Unit gas field is not an enhanced recovery project. For Class Ill wells, the Director must require an applicant to furnish data necessary to demonstrate that the aquifer is expected to be mineral or hydrocarbon producing and the Director must consider information contained in the mining plan for the proposed project, such as a map and general description of the mining zone, general information on the mineralogy and geochemistry of the mining zone, analysis of the amenability of the mining zone to the proposed mining method, and a time-table of planned development of the mining zone. Information to be provided may also include: a summary of logging which indicates that commercially producible quantities of minerals or hydrocarbons are present. The current Ninilchik Unit project does not involve Class III wells. 3- Demonstration that the aquifer or portion thereof is situated at a depth or location which makes recovery of water for drinking water purposes economically or technologically impractical per 146.4(b)(2) Is the aquifer or portion thereof situated at a depth or location which makes recovery of water for drinking water purposes economically or technologically impractical? Yes, as discussed above. List evidence in the application showing how this demonstration was made. The SD8 is in an area of the southern Kenai Peninsula that has plentiful, very shallow freshwater aquifers. The deepest water well within Hilcorp’s requested aquifer exemption area is 257 feet below ground level, and all nearby water wells are hydraulically isolated from the planned injection zones by thick intervals of thinly interbedded tuffaceous claystone, tuffaceous siltstone, coal, and carbonaceous shale within the Sterling Formation and about 2,785 true vertical feet of thinly interbedded siltstone, tuffaceous siltstone, claystone, coal, carbonaceous shale, and discontinuous sands assigned to the underlying Beluga Formation. All future drinking water needs will be met by the very shallow freshwater aquifers. With plentiful near-surface water supplies, it will not—in the foreseeable future—be economic or necessary to drill a 3,700-foot freshwater well. The operator’s application presents a detailed discussion of the estimated costs associated with drilling, equipping, and operating such an ultra-deep freshwater well, which are quite high (very roughly $315,000, $3,000,000, and $138,000 per year, respectively). Draft Aquifer Exemption Checklist for Susan Dionne 8, Kenai Peninsula, Alaska Page 19 of EPA consideration of an aquifer exemption request under this provision would include information related to:  The availability of less costly and more readily available alternative supplies,  the adequacy of alternatives to meet present and future needs, and  costs for treatment (including cost of disposal of treatment residuals) and or development associated with the use of the aquifer. The economic evaluation, submitted by the applicant, should consider the above factors, and these that follow: 1. Distance from the proposed exempted aquifer to public water supplies. 2. Current sources of water supply for potential users of the proposed exempted aquifer. 3. Availability, quantity and quality of alternative water supply sources. 4. Analysis of future water supply needs within the general area. 5. Depth of proposed exempted aquifer. 6. Quality of the water in the proposed exempted aquifer. Not applicable due to existing plentiful sources of near-surface freshwater. 4- Demonstration that the aquifer or portion thereof is too contaminated per 146.4(b)(3). Is the aquifer or portion thereof proposed for exemption so contaminated that it would be economically or technologically impractical to render that water fit for human consumption List evidence in the application showing that the area to be exempted is so contaminated that it would be economically or technologically impractical to render that water fit for human consumption. The production test and production history discussions above demonstrate that the Beluga 135 interval in the vicinity of the SD8 well is hydrocarbon bearing. The water-sample analytical data presented above indicate that extensive processing would be required to remove the metals and contaminants from the formation water to render it safe for human consumption. Economic considerations would also weigh heavily in EPA's decision on aquifer exemption requests under this section. Unlike the previous section, the economics involved are controlled by the cost of technology to render water fit for human consumption. Treatment methods can usually be found to render water potable. However, costs of that treatment may often be prohibitive either in absolute terms or compared to the cost to develop alternative water supplies. EPA's evaluation of aquifer exemption requests under this section will consider the following information submitted by the applicant: (a) Concentrations, types, and source of contaminants in the aquifer. (b) If contamination is a result of a release, whether contamination source has been abated. (c) Extent of contaminated area. (d) Probability that the contaminant plume will pass through the proposed exempted area. Draft Aquifer Exemption Checklist for Susan Dionne 8, Kenai Peninsula, Alaska Page 20 of (e) Ability of treatment to remove contaminants from ground water. (f) Current and alternative water supplies in the area. (g) Costs to develop current and future water supplies, cost to develop water supply from proposed exempted aquifer. This should include well construction costs, transportation costs, water treatment costs, etc. (h) Projections on future use of the proposed aquifer. Water-sample, production test, production history, and well drilling, construction, equipping and operating information provided in the operator’s application along with existing plentiful sources of surface and near-surface freshwater demonstrate that the Beluga 135 interval aquifer will not be used to supply drinking water. 5- Demonstration that the aquifer or portion thereof is located over a Class Ill well mining area subject to subsidence or catastrophic collapse per 146.4(b)(4) Not applicable. Is the aquifer or portion thereof proposed for exemption located aver a Class Ill well mining area subject to subsidence or catastrophic collapse? List evidence in the application showing that the area to be exempted is located over a Class Ill well mining area subject to subsidence or catastrophic collapse: Discuss the mining method and why that method necessarily causes subsidence or catastrophic collapse. The possibility that non-exempted underground sources of drinking would be contaminated due to the collapse should also be addressed in the application. 6- Demonstration that the aquifer or portion thereof has TDS more than 3,000 and less than 10,000 mg/I and it is not reasonably expected to supply a public water system per 146.4(c) Is the TDS of the aquifer or portion thereof proposed for exemption more than 3,000 and less than 10,000 mg/l? No. Hilcorp’s application estimates the TDS concentration for native formation fluids within the two proposed injection zones in the Tyonek range from 1,700 to 1,900 mg/l in the proposed Beluga 135 injection zone. Is the aquifer proposed for exemption or portion thereof not reasonably expected to supply a public water system? Yes. The SD8 is in an area of the southern Kenai Peninsula that has plentiful, very shallow freshwater. The deepest water well within Hilcorp’s requested exemption area is 257 feet below ground level, and the proposed exempted interval lies more than one-half mile deeper and is separated and hydraulically isolated by thick intervals of thinly interbedded tuffaceous claystone, tuffaceous siltstone, coal, and carbonaceous shale. All future drinking water needs will be met by shallow freshwater aquifers and, if necessary, surface waters or treated water from the upper portion of the Sterling Formation that lies above sea level. With plentiful near- surface water supplies, it will not—in the foreseeable future—be economic or necessary to drill a 3,700-foot well for freshwater. Draft Aquifer Exemption Checklist for Susan Dionne 8, Kenai Peninsula, Alaska Page 21 of Identify and discuss the information on which the determination that the total dissolved solids content of the ground water in the proposed exemption is more than 3,000 and less than 10,000 mg/I and the aquifer is not reasonably expected to supply a public water system. Include information about the quality and availability of water from the aquifer proposed for exemption. Also, the exemption request must analyze the potential for public water supply use of the aquifer. This may include:  A description of current sources of public water supply in the area,  a discussion of the adequacy of current water supply sources to supply future needs,  population projections,  economy, The Kenai Peninsula has a reported 2020 population of 58,799 and a land area of 16,075 square miles, for a population density of about 3.7 persons per square mile. The Ninilchik Unit is located inland, about 8 road-miles from the main highway in a relatively undeveloped rural area. Satellite photos available through Google Earth demonstrate the area surrounding the Ninilchik Unit is sparsely populated and will likely remain very lightly inhabited for the foreseeable future with little potential for agricultural, industrial, or commercial growth as it is located well away from the coastal corridor and main highway system in an area of brushy and forested rolling hills. The very shallow Alluvial Channel and Moraine Aquifers currently serve as the main sources for drinking water in the Anchor Point–Ninilchik area.  future technology, and Even with future technological advances, it is highly unlikely—in an area of plentiful surface and near-surface freshwater—that the Beluga 135 within the Susan Dionne Pad area will become economic as a public water supply.  a discussion of other available water supply sources within the area. Estimates and well-log calculations by AOGCC and other operating companies in this area suggest that upper portions of the Sterling Formation between roughly 10 feet depth and sea level, have TDS concentrations below 5,000 mg/l, which—with treatment—may provide a secondary water-supply source. 7- Demonstration that a Class II aquifer exemption may be expanded to Class VI per 146.4(d) (Refer to additional requirements in EPA's regulations for Class VI aquifer exemptions for this demonstration) Not applicable May the areal extent of an aquifer exemption for a Class II enhanced oil recovery or enhanced gas recovery well be expanded for the exclusive purpose of Class VI injection for geologic sequestration under§ 144. l(d)? Not applicable List evidence in the application showing an existing Class II operation associated with AE that is being converted into Class VI Not applicable CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. From:Davies, Stephen F (OGC) To:Osborne, Evan Cc:Wallace, Chris D (OGC) Subject:RE: Aquifer Exemption for Susan Dionne 8 Date:Friday, August 23, 2024 9:43:00 AM Attachments:AEO_SD-08_Aquifer_Exemption_Checklist_EPA_20240813.docx Evan, Thank you for taking my call this morning. Attached is my initial draft of EPA’s Aquifer Exemption Checklist for the Susan Dionne 8 well on the Kenai Peninsula of Alaska. Your comments and questions are much appreciated. Thanks again for your help, Steve Davies AOGCC From: Osborne, Evan <Osborne.Evan@epa.gov> Sent: Wednesday, August 21, 2024 7:12 AM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov>; Robinson, James <Robinson.James@epa.gov>; Mayers, Timothy <Mayers.Timothy@epa.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov> Subject: RE: Aquifer Exemption for Susan Dionne 8 Steve, Thank you for contacting us and raising this issue. Answer: Yes, we are the team that will be reviewing this request. I suggest we set up a meeting to discuss the proposed aquifer exemption. Does that work with your timeline for issuance? How about tomorrow at 10AM AK time? Or Friday at 9AM AK time? Best, Evan From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Tuesday, August 20, 2024 5:51 PM To: Robinson, James <Robinson.James@epa.gov>; Osborne, Evan <Osborne.Evan@epa.gov>; Mayers, Timothy <Mayers.Timothy@epa.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov> Subject: RE: Aquifer Exemption for Susan Dionne 8 Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. Evan, James, and Tim: Steve Davies of the Alaska Oil and Gas Conservation Commission here. Are any of you part of Region 10’s team that reviews aquifer exemption applications for Alaska? If not, could you please point me to the proper contact within Region 10? I’d like to get this application review started with EPA. Please let me know when you are available to discuss this. Thanks and Be Well, Steve Davies Senior Petroleum Geologist AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov. From: Wallace, Chris D (OGC) <chris.wallace@alaska.gov> Sent: Thursday, August 15, 2024 4:20 PM To: Robinson, James <Robinson.James@epa.gov> Cc: Osborne, Evan <Osborne.Evan@epa.gov>; Mayers, Timothy <Mayers.Timothy@epa.gov>; Gross, Ryan <Gross.Ryan@epa.gov>; Davies, Stephen F (OGC) <steve.davies@alaska.gov> Subject: FW: Aquifer Exemption for Susan Dionne 8 James, Please see below from Steve on a new aquifer exemption we are progressing. Thanks and Regards, Chris Wallace, Sr. Petroleum Engineer, Alaska Oil and Gas Conservation Commission, 333 West 7th Avenue, Anchorage, AK 99501, (907) 793-1250 (phone), (907) 276-7542 (fax), chris.wallace@alaska.gov 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 Chris Wallace at 907-793-1250 or chris.wallace@alaska.gov. From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Thursday, August 15, 2024 7:21 AM To: Gross, Ryan <Gross.Ryan@epa.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov> Subject: Aquifer Exemption for Susan Dionne 8 Ryan, Steve Davies of the Alaska Oil and Gas Conservation Commission here. We last corresponded in August 2022 concerning an aquifer exemption for the North Fork Unit on the Kenai Peninsula, Cook Inlet Basin, Alaska. Are you still part of Region 10’s team that reviews aquifer exemption applications for Alaska? If not, could you please point me to the proper contact within Region 10? The proposed exemption that I am working on is conversion of an existing, shut in gas well into a back-up Class II disposal injection well located onshore along the western coastline of the Kenai Peninsula. I have completed a draft version of the EPA’s Aquifer Exemption Checklist form that was used for the North Fork Unit exemption. To expedite review, I’d like to discuss this with you and, if possible, submit my draft of EPA’s checklist to you for a quick preliminary review to ensure that I haven’t overlooked anything. Please let me know if this works for you. Thanks and Be Well, Steve Davies Senior Petroleum Geologist AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov. From:Davies, Stephen F (OGC) To:Casey Morse Cc:Wallace, Chris D (OGC); Dewhurst, Andrew D (OGC) Subject:AEO for Susan Dionne 8 Date:Wednesday, August 28, 2024 12:43:00 PM Casey, I’m working on the Aquifer Exemption Order for the Susan Dionne 8 well. We’re making good progress, but I have a few questions for you. As I recall from the companion Disposal Injection Order NO. 47, this well will be used as a back up for the NNA 1 primary disposal well. If so, could Hilcorp please provide estimates for the volume of fluids expected to be disposed in Susan Dionne 8 over the life of the project in this backup capacity? Should NNA 1 fail and Susan Dionne 8 be used as the primary disposal well, could Hilcorp please provide estimates of the daily disposal volumes, the total estimated volume, and the radius of the affected area surrounding the well? Please provide the parameters used to calculate these volumes (thickness, average porosity, native-fluid displacement effectiveness, expected affected radius, etc.). Thanks and Be Well, Steve Davies AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. From:Osborne, Evan To:Davies, Stephen F (OGC) Subject:AE review Date:Wednesday, September 4, 2024 1:21:08 PM Steve, Didn’t want to leave you in the dark re: EPA’s review of the AE checklist decision draft. I’ve finished comments and they are under review. Shouldn’t be more than a week from here. Feel free to call with any questions. Evan Evan Osborne U.S. EPA Region 10 Underground Injection Control Program ph. 206-553-1747 CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. From:Davies, Stephen F (OGC) To:Osborne, Evan Cc:Wallace, Chris D (OGC); Dewhurst, Andrew D (OGC) Subject:RE: AE review Date:Wednesday, September 4, 2024 1:22:00 PM Thanks for the update, Evan. We appreciate your help with this. Thanks Again and Be Well, Steve Davies Senior Petroleum Geologist AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov. From: Osborne, Evan <Osborne.Evan@epa.gov> Sent: Wednesday, September 4, 2024 1:21 PM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Subject: AE review Steve, Didn’t want to leave you in the dark re: EPA’s review of the AE checklist decision draft. I’ve finished comments and they are under review. Shouldn’t be more than a week from here. Feel free to call with any questions. Evan Evan Osborne U.S. EPA Region 10 Underground Injection Control Program ph. 206-553-1747 CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. From:Casey Morse To:Davies, Stephen F (OGC) Cc:Wallace, Chris D (OGC); Dewhurst, Andrew D (OGC) Subject:RE: [EXTERNAL] AEO for Susan Dionne 8 Date:Friday, September 6, 2024 10:14:05 AM Steve, The average volumes we pumped into NNA-1 for the past year were approximately 300 bpd. The average porosity for the disposal interval in the SD-8 well is estimated at 25%. The disposal interval is 45 ft thick, and we will likely perforate across most (or all) of that interval. Here are the assumptions I used to calculate a radius of impact: 20-year project life with 300 bpd average daily rate Disposal zone height of 45 ft Average porosity of disposal zone is 25% Injected fluids remain vertically confined within the disposal zone Injection is proportionally distributed amongst the perforations There is piston-like displacement of native reservoir fluids Based on these assumptions, the impacted radius would be 590 ft. Thank you, Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Wednesday, August 28, 2024 12:44 PM To: Casey Morse <casey.morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: [EXTERNAL] AEO for Susan Dionne 8 Casey, I’m working on the Aquifer Exemption Order for the Susan Dionne 8 well. We’re making good progress, but I have a few questions for you. As I recall from the companion Disposal Injection Order NO. 47, this well will be used as a back up for the NNA 1 primary disposal well. If so, could Hilcorp please provide estimates for the volume of fluids expected to be disposed in Susan Dionne 8 over the life of the project in this backup capacity? Should NNA 1 fail and Susan Dionne 8 be used as the primary disposal well, could Hilcorp please provide estimates of the daily disposal volumes, the total estimated volume, and the radius of the affected area surrounding the well? Please provide the parameters used to calculate these volumes (thickness, average porosity, native-fluid displacement effectiveness, expected affected radius, etc.). Thanks and Be Well, Steve Davies AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov The information contained in this email message is confidential and may be legally privileged and is intended only for the use of theindividual or entity named above. If you are not an intended recipient or if you have received this message in error, you are herebynotified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, pleaseimmediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently deletethis message. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that theonward transmission, opening, or use of this message and any attachments will not adversely affect its systems or data. No responsibilityis accepted by the company in this regard and the recipient should carry out such virus and other checks as it considers appropriate. From:Davies, Stephen F (OGC) To:Osborne, Evan Subject:RE: AE review Date:Thursday, September 12, 2024 9:39:00 AM Hi Evan, Thought I’d check to see if there are any additional updates regarding AOGCC’s draft EPA Aquifer Exemption Checklist for Susan Dionne 8? Thanks Again and Be Well, Steve Davies Senior Petroleum Geologist AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov. From: Davies, Stephen F (OGC) Sent: Wednesday, September 4, 2024 1:23 PM To: Osborne, Evan <Osborne.Evan@epa.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: AE review Thanks for the update, Evan. We appreciate your help with this. Thanks Again and Be Well, Steve Davies Senior Petroleum Geologist AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov. From: Osborne, Evan <Osborne.Evan@epa.gov> Sent: Wednesday, September 4, 2024 1:21 PM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Subject: AE review CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. Steve, Didn’t want to leave you in the dark re: EPA’s review of the AE checklist decision draft. I’ve finished comments and they are under review. Shouldn’t be more than a week from here. Feel free to call with any questions. Evan Evan Osborne U.S. EPA Region 10 Underground Injection Control Program ph. 206-553-1747 Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. From:Osborne, Evan To:Davies, Stephen F (OGC) Subject:RE: AE review Date:Thursday, September 12, 2024 10:33:58 AM Hi Steve, It’s under review at a leadership level – let me give it another bump From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Thursday, September 12, 2024 10:40 AM To: Osborne, Evan <Osborne.Evan@epa.gov> Subject: RE: AE review Hi Evan, Thought I’d check to see if there are any additional updates regarding AOGCC’s draft EPA Aquifer Exemption Checklist for Susan Dionne 8? Thanks Again and Be Well, Steve Davies Senior Petroleum Geologist AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov. From: Davies, Stephen F (OGC) Sent: Wednesday, September 4, 2024 1:23 PM To: Osborne, Evan <Osborne.Evan@epa.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: AE review Thanks for the update, Evan. We appreciate your help with this. Thanks Again and Be Well, Steve Davies Senior Petroleum Geologist AOGCC CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov. From: Osborne, Evan <Osborne.Evan@epa.gov> Sent: Wednesday, September 4, 2024 1:21 PM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Subject: AE review Steve, Didn’t want to leave you in the dark re: EPA’s review of the AE checklist decision draft. I’ve finished comments and they are under review. Shouldn’t be more than a week from here. Feel free to call with any questions. Evan Evan Osborne U.S. EPA Region 10 Underground Injection Control Program ph. 206-553-1747 Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. From:Davies, Stephen F (OGC) To:Osborne, Evan Subject:RE: AE review Date:Thursday, September 12, 2024 11:58:00 AM Thank you. I appreciate it. Thanks Again, Steve Davies AOGCC From: Osborne, Evan <Osborne.Evan@epa.gov> Sent: Thursday, September 12, 2024 10:34 AM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Subject: RE: AE review Hi Steve, It’s under review at a leadership level – let me give it another bump From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Thursday, September 12, 2024 10:40 AM To: Osborne, Evan <Osborne.Evan@epa.gov> Subject: RE: AE review Hi Evan, Thought I’d check to see if there are any additional updates regarding AOGCC’s draft EPA Aquifer Exemption Checklist for Susan Dionne 8? Thanks Again and Be Well, Steve Davies Senior Petroleum Geologist AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov. From: Davies, Stephen F (OGC) Sent: Wednesday, September 4, 2024 1:23 PM To: Osborne, Evan <Osborne.Evan@epa.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. <andrew.dewhurst@alaska.gov> Subject: RE: AE review Thanks for the update, Evan. We appreciate your help with this. Thanks Again and Be Well, Steve Davies Senior Petroleum Geologist AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov. From: Osborne, Evan <Osborne.Evan@epa.gov> Sent: Wednesday, September 4, 2024 1:21 PM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Subject: AE review Steve, Didn’t want to leave you in the dark re: EPA’s review of the AE checklist decision draft. I’ve finished comments and they are under review. Shouldn’t be more than a week from here. Feel free to call with any questions. Evan Evan Osborne U.S. EPA Region 10 Underground Injection Control Program ph. 206-553-1747 Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. From:Osborne, Evan To:Davies, Stephen F (OGC) Subject:RE: AE review Date:Friday, September 13, 2024 12:22:43 PM Steve, can you send me your desk number? Evan From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Thursday, September 12, 2024 12:58 PM To: Osborne, Evan <Osborne.Evan@epa.gov> Subject: RE: AE review Thank you. I appreciate it. Thanks Again, Steve Davies AOGCC From: Osborne, Evan <Osborne.Evan@epa.gov> Sent: Thursday, September 12, 2024 10:34 AM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Subject: RE: AE review Hi Steve, It’s under review at a leadership level – let me give it another bump From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Thursday, September 12, 2024 10:40 AM To: Osborne, Evan <Osborne.Evan@epa.gov> Subject: RE: AE review Hi Evan, Thought I’d check to see if there are any additional updates regarding AOGCC’s draft EPA Aquifer Exemption Checklist for Susan Dionne 8? CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. Thanks Again and Be Well, Steve Davies Senior Petroleum Geologist AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov. From: Davies, Stephen F (OGC) Sent: Wednesday, September 4, 2024 1:23 PM To: Osborne, Evan <Osborne.Evan@epa.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: AE review Thanks for the update, Evan. We appreciate your help with this. Thanks Again and Be Well, Steve Davies Senior Petroleum Geologist AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov. From: Osborne, Evan <Osborne.Evan@epa.gov> Sent: Wednesday, September 4, 2024 1:21 PM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Subject: AE review Steve, Didn’t want to leave you in the dark re: EPA’s review of the AE checklist decision draft. I’ve finished comments and they are under review. Shouldn’t be more than a week from here. Feel free to call with any questions. Evan Evan Osborne U.S. EPA Region 10 Underground Injection Control Program ph. 206-553-1747 Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. From:Davies, Stephen F (OGC) To:Osborne, Evan Subject:RE: AE review Date:Monday, September 16, 2024 5:27:00 AM Hi Evan, My office phone is 907-793-1224. My cell phone number is 907-717-8229. I’ll be in my office after 8 AM. Thanks, Steve D. AOGCC From: Osborne, Evan <Osborne.Evan@epa.gov> Sent: Friday, September 13, 2024 12:23 PM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Subject: RE: AE review Steve, can you send me your desk number? Evan From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Thursday, September 12, 2024 12:58 PM To: Osborne, Evan <Osborne.Evan@epa.gov> Subject: RE: AE review Thank you. I appreciate it. Thanks Again, Steve Davies AOGCC From: Osborne, Evan <Osborne.Evan@epa.gov> Sent: Thursday, September 12, 2024 10:34 AM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Subject: RE: AE review Hi Steve, Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. It’s under review at a leadership level – let me give it another bump From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Thursday, September 12, 2024 10:40 AM To: Osborne, Evan <Osborne.Evan@epa.gov> Subject: RE: AE review Hi Evan, Thought I’d check to see if there are any additional updates regarding AOGCC’s draft EPA Aquifer Exemption Checklist for Susan Dionne 8? Thanks Again and Be Well, Steve Davies Senior Petroleum Geologist AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov. From: Davies, Stephen F (OGC) Sent: Wednesday, September 4, 2024 1:23 PM To: Osborne, Evan <Osborne.Evan@epa.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: AE review Thanks for the update, Evan. We appreciate your help with this. Thanks Again and Be Well, Steve Davies Senior Petroleum Geologist AOGCC 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 CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. in sending it to you, contact Steve Davies at 907-793-1224 or steve.davies@alaska.gov. From: Osborne, Evan <Osborne.Evan@epa.gov> Sent: Wednesday, September 4, 2024 1:21 PM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Subject: AE review Steve, Didn’t want to leave you in the dark re: EPA’s review of the AE checklist decision draft. I’ve finished comments and they are under review. Shouldn’t be more than a week from here. Feel free to call with any questions. Evan Evan Osborne U.S. EPA Region 10 Underground Injection Control Program ph. 206-553-1747 Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. From:Osborne, Evan To:Davies, Stephen F (OGC) Subject:RE: AE review Date:Monday, September 16, 2024 9:35:56 AM Steve, Here are the regulations I was referencing: 1. This citation in reference to procedures for state AEs: https://www.ecfr.gov/current/title- 40/part-144#p-144.7(b)(3) 2. Since the TDS is below 3,000, AOGCC wishes to rely on a determination based on the depth/contamination (i.e., 146.4(b), not 146.4(c)): https://www.ecfr.gov/current/title- 40/part-146#p-146.4(b) 3. Because of 1) and 2), above, AOGCC may need to go through this process: https://www.ecfr.gov/current/title-40/chapter-I/subchapter-D/part-145/subpart- D/section-145.32 I will make some calls and be in touch later this week. I am on leave next week. Evan From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Monday, September 16, 2024 6:27 AM To: Osborne, Evan <Osborne.Evan@epa.gov> Subject: RE: AE review Hi Evan, My office phone is 907-793-1224. My cell phone number is 907-717-8229. I’ll be in my office after 8 AM. Thanks, Steve D. AOGCC From: Osborne, Evan <Osborne.Evan@epa.gov> Sent: Friday, September 13, 2024 12:23 PM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. Subject: RE: AE review Steve, can you send me your desk number? Evan From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Thursday, September 12, 2024 12:58 PM To: Osborne, Evan <Osborne.Evan@epa.gov> Subject: RE: AE review Thank you. I appreciate it. Thanks Again, Steve Davies AOGCC From: Osborne, Evan <Osborne.Evan@epa.gov> Sent: Thursday, September 12, 2024 10:34 AM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Subject: RE: AE review Hi Steve, It’s under review at a leadership level – let me give it another bump From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Thursday, September 12, 2024 10:40 AM To: Osborne, Evan <Osborne.Evan@epa.gov> Subject: RE: AE review Hi Evan, Thought I’d check to see if there are any additional updates regarding AOGCC’s draft EPA Aquifer Exemption Checklist for Susan Dionne 8? Thanks Again and Be Well, CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. Steve Davies Senior Petroleum Geologist AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov. From: Davies, Stephen F (OGC) Sent: Wednesday, September 4, 2024 1:23 PM To: Osborne, Evan <Osborne.Evan@epa.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: AE review Thanks for the update, Evan. We appreciate your help with this. Thanks Again and Be Well, Steve Davies Senior Petroleum Geologist AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov. From: Osborne, Evan <Osborne.Evan@epa.gov> Sent: Wednesday, September 4, 2024 1:21 PM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Subject: AE review Steve, Didn’t want to leave you in the dark re: EPA’s review of the AE checklist decision draft. I’ve finished comments and they are under review. Shouldn’t be more than a week from here. Feel free to call with any questions. Evan Evan Osborne U.S. EPA Region 10 Underground Injection Control Program ph. 206-553-1747 Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. From:Davies, Stephen F (OGC) To:Osborne, Evan Subject:RE: AE review Date:Monday, September 16, 2024 9:36:00 AM Thank you, Evan. I appreciate your help with this. Cheers and Be Well, Steve Davies AOGCC From: Osborne, Evan <Osborne.Evan@epa.gov> Sent: Monday, September 16, 2024 9:36 AM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Subject: RE: AE review Steve, Here are the regulations I was referencing: 1. This citation in reference to procedures for state AEs: https://www.ecfr.gov/current/title- 40/part-144#p-144.7(b)(3) 2. Since the TDS is below 3,000, AOGCC wishes to rely on a determination based on the depth/contamination (i.e., 146.4(b), not 146.4(c)): https://www.ecfr.gov/current/title- 40/part-146#p-146.4(b) 3. Because of 1) and 2), above, AOGCC may need to go through this process: https://www.ecfr.gov/current/title-40/chapter-I/subchapter-D/part-145/subpart- D/section-145.32 I will make some calls and be in touch later this week. I am on leave next week. Evan From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Monday, September 16, 2024 6:27 AM To: Osborne, Evan <Osborne.Evan@epa.gov> Subject: RE: AE review Hi Evan, Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. My office phone is 907-793-1224. My cell phone number is 907-717-8229. I’ll be in my office after 8 AM. Thanks, Steve D. AOGCC From: Osborne, Evan <Osborne.Evan@epa.gov> Sent: Friday, September 13, 2024 12:23 PM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Subject: RE: AE review Steve, can you send me your desk number? Evan From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Thursday, September 12, 2024 12:58 PM To: Osborne, Evan <Osborne.Evan@epa.gov> Subject: RE: AE review Thank you. I appreciate it. Thanks Again, Steve Davies AOGCC From: Osborne, Evan <Osborne.Evan@epa.gov> Sent: Thursday, September 12, 2024 10:34 AM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Subject: RE: AE review Hi Steve, It’s under review at a leadership level – let me give it another bump From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Thursday, September 12, 2024 10:40 AM To: Osborne, Evan <Osborne.Evan@epa.gov> Subject: RE: AE review Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. Hi Evan, Thought I’d check to see if there are any additional updates regarding AOGCC’s draft EPA Aquifer Exemption Checklist for Susan Dionne 8? Thanks Again and Be Well, Steve Davies Senior Petroleum Geologist AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov. From: Davies, Stephen F (OGC) Sent: Wednesday, September 4, 2024 1:23 PM To: Osborne, Evan <Osborne.Evan@epa.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: AE review Thanks for the update, Evan. We appreciate your help with this. Thanks Again and Be Well, Steve Davies Senior Petroleum Geologist AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov. From: Osborne, Evan <Osborne.Evan@epa.gov> Sent: Wednesday, September 4, 2024 1:21 PM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Subject: AE review CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. Steve, Didn’t want to leave you in the dark re: EPA’s review of the AE checklist decision draft. I’ve finished comments and they are under review. Shouldn’t be more than a week from here. Feel free to call with any questions. Evan Evan Osborne U.S. EPA Region 10 Underground Injection Control Program ph. 206-553-1747 CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. From:Affeldt, Chris To:Davies, Stephen F (OGC) Cc:Osborne, Evan Subject:Request for Response - EPA comments on draft Aquifer Exemption Checklist for the proposed Susan Dionne No. 8 Class II injection well Date:Friday, September 20, 2024 1:41:44 PM Attachments:EPA_comments_beluga_aeapp.pdf You don't often get email from affeldt.christopher@epa.gov. Learn why this is important Dear Mr. Davies, Please see the attached letter with a request for response to the enclosed comments regarding the Aquifer Exemption Checklist submitted by the Alaska Oil and Gas Conservation Commission for the proposed Susan Dionne No. 8 Class II injection well. Please let me and Evan Osborne know if you have any questions. Thank you, Chris Affeldt (he/him) Acting Section Manager Groundwater and Drinking Water Section | Water Division U.S. EPA Region 10 (206) 553-6068 affeldt.chris@epa.gov CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. From:Osborne, Evan To:Davies, Stephen F (OGC) Subject:AE comments Date:Wednesday, October 9, 2024 2:52:47 PM Hi Steve, I’m following-up on the comments our team sent to you regarding the proposed AE. Would you like to have a call to discuss? I am free much of next week – feel free to propose a time or two that work for you. Best, Evan Osborne U.S. EPA Region 10 Underground Injection Control Program ph. 206-553-1747 September 20, 2024 Mr. Steve Davies Senior Petroleum Geologist Alaska Oil and Gas Conservation Commission 333 W 7th AVE Anchorage, AK 99501 Dear Mr. Davies: The United States Environmental Protection Agency Region 10 has completed its review of the draft Aquifer Exemption Checklist submitted by the Alaska Oil and Gas Conservation Commission for the proposed Susan Dionne No. 8 Class II injection well, Kenai Peninsula, Alaska. AOGCC submitted this draft document along with a request for comments on the proposed action. The EPA evaluated the materials under the Underground Injection Control program requirements, including applicable regulations and policy. The EPA’s comments, enclosed with this letter, are intended to solicit additional information regarding the adequacy of the original Aquifer Exemption request submitted by Hilcorp Alaska, LLC and subsequent evaluation by AOGCC. The EPA recommends that AOGCC consider the enclosed comments and respond with additional information before submitting an Aquifer Exemption decision. If you have any questions or comments, please feel free to contact Evan Osborne at osborne.evan@epa.gov or 206-553-1747. Sincerely, Chris Affeldt Acting Manager Groundwater and Drinking Water Section ENCLOSURES 1.Comments on DRAFT Aquifer Exemption Checklist – Susan Dionne No. 8, Kenai Peninsula, Alaska 2 Enclosure 1: Comments on DRAFT Aquifer Exemption Checklist – Susan Dionne No. 8, Kenai Peninsula, Alaska 1)What evidence is there to show that, “Groundwater within the Beluga 135 sand aquifer within Hilcorp’s proposed exemption area is so contaminated and is situated at depths that make recovery for drinking water purposes economically impractical.” Has AOGCC reviewed laboratory analysis data? 2)Will injection be limited to ensure no fracturing of the subsurface? Has it been shown that injection won’t create new conduits for fluid movement outside the intended zone? 3)What method did Hilcorp use to gather water samples from the Beluga 135 sand in well Susan Dionne 1A? Was there possibility of sample contamination by drilling fluid or other oilfield fluids during this process, or prior to collection? Was the wellbore flushed? 4)The draft documents state that, “In Susan Dionne 1A, the Beluga 135 interval lies only about 140’ from that same interval in SD8…” Please explain the direction/orientation referenced in the phrase, “…140’ from the same interval…” 5)AOGCC notes that “…the concentrations of six metals and 16 organic compounds measured in these samples exceed—and in many cases far exceed—the Groundwater Human Health Cleanup Levels specified in Alaska Regulation 18 AAC 75.345…” How did AOGCC determine that the known levels of contamination have removed the possibility of future potable use (i.e., how is it known that water treatment of the Beluga 135 would be economically/technologically impractical, based on economic or technological analysis)? 6)On Page 5, AOGCC indicates that the proposed exemption area is, “…mineral, hydrocarbon, or geothermal energy producing, or can be demonstrated by a permit applicant as part of a permit application for a Class II or Class II operation to contain minerals or hydrocarbons…” Please clarify whether the Beluga 135 zone contains hydrocarbons. On page 7 it states, “…the Beluga 135 produced large amounts of water with some sand. It was subsequently shut-in during May of 2014.” 7)Are there any water quality concerns regarding the primary shallow aquifer used for drinking water in the area of the exemption request? I.e., is quality expected to be fit for human consumption now and into the future? Are there any prominent risks to future water quality posed by industry or other activities? 8)Were the entities listed in Tables 1 and 2 contacted as part of public participation? Are there plans to do so? 9)Does AOGCC have any other information concerning fractures in the caprock above the proposed exemption area? 10)What’s the thickest continuous section of shale/other highly impermeable formation above the exemption zone? 11)Is AOGCC aware of any hydrogeologic connections, whether natural (i.e., groundwater flow, fractures, etc.) or artificial (i.e., wellbores) between the requested interval and shallower aquifers? 3 12) Did AOGCC evaluate the proposed costs to develop an “ultra-deep freshwater well” stated at the bottom of page 18? Are these costs reasonable based on local economic factors? 13) Are there potential secondary water sources that could be used in the event that the shallow aquifer currently used in this area is no longer able to meet drinking water needs? 14) Page 19 of the checklist indicates that the “source of contaminants in the aquifer” would be considered in the evaluation. Has this been done? 15) Are contaminant levels in the Beluga 135 consistent across the aquifer? Are water quality samples available from wells other than the Susan Dionne 1A? 16) Page 20 of the draft checklist states that, “With plentiful near-surface water supplies, it will not—in the foreseeable future—be economic or necessary to drill a 3,700-foot well for freshwater.” EPA recommends removing the word “foreseeable” as this is not consistent with regulatory language or intent. 17) Page 21 states that, “the Ninilchik Unit is sparsely populated and will likely remain very lightly inhabited for the foreseeable future with little potential for agricultural, industrial, or commercial growth…” What is the source of this information? Has AOGCC relied on state or federal government-provided census data in the evaluation of population/economic forecasts? 18) Page 21 states that, “…upper portions of the Sterling Formation between roughly 10 feet depth and sea level, have TDS concentrations below 5,000 mg/l, which—with treatment—may provide a secondary water-supply source.” Would this hypothetical water source be less or more expensive to develop than the Beluga 135? CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. From:Osborne, Evan To:Davies, Stephen F (OGC) Subject:Automatic reply: Request for Response - EPA comments on draft Aquifer Exemption Checklist for the proposed Susan Dionne No. 8 Class II injection well Date:Monday, September 23, 2024 8:39:06 AM I will be out of office until Monday, Septmeber 30. For time-critical matters please contact Tim Mayers (mayers.timothy@epa.gov, 907-271- 3410). Thank you, Evan Osborne 206-553-1747 CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. From:Davies, Stephen F (OGC) To:Osborne, Evan Subject:RE: AE comments Date:Wednesday, October 9, 2024 5:30:00 PM Hi Evan, Thanks for checking in. I’ve been exceedingly busy lately with other rush projects and applications and haven’t had much time yet to respond. Hopefully, I can get back to this later in the week or early next week. I’ll keep in touch regarding progress. Thanks Again, Steve Davies AOGCC From: Osborne, Evan <Osborne.Evan@epa.gov> Sent: Wednesday, October 9, 2024 2:53 PM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Subject: AE comments Hi Steve, I’m following-up on the comments our team sent to you regarding the proposed AE. Would you like to have a call to discuss? I am free much of next week – feel free to propose a time or two that work for you. Best, Evan Osborne U.S. EPA Region 10 Underground Injection Control Program ph. 206-553-1747 CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. From:Casey Morse To:Davies, Stephen F (OGC) Cc:Wallace, Chris D (OGC); Dewhurst, Andrew D (OGC) Subject:RE: [EXTERNAL] AEO for Susan Dionne 8 Date:Tuesday, October 29, 2024 8:31:00 AM Good morning, Steve. I wanted to check in with you on the status of this AEO request. Where is this in the review process? What are the next steps? Thank you, Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 From: Casey Morse <casey.morse@hilcorp.com> Sent: Friday, September 6, 2024 10:14 AM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Steve, The average volumes we pumped into NNA-1 for the past year were approximately 300 bpd. The average porosity for the disposal interval in the SD-8 well is estimated at 25%. The disposal interval is 45 ft thick, and we will likely perforate across most (or all) of that interval. Here are the assumptions I used to calculate a radius of impact: 20-year project life with 300 bpd average daily rate Disposal zone height of 45 ft Average porosity of disposal zone is 25% Injected fluids remain vertically confined within the disposal zone Injection is proportionally distributed amongst the perforations There is piston-like displacement of native reservoir fluids CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. Based on these assumptions, the impacted radius would be 590 ft. Thank you, Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Wednesday, August 28, 2024 12:44 PM To: Casey Morse <casey.morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: [EXTERNAL] AEO for Susan Dionne 8 Casey, I’m working on the Aquifer Exemption Order for the Susan Dionne 8 well. We’re making good progress, but I have a few questions for you. As I recall from the companion Disposal Injection Order NO. 47, this well will be used as a back up for the NNA 1 primary disposal well. If so, could Hilcorp please provide estimates for the volume of fluids expected to be disposed in Susan Dionne 8 over the life of the project in this backup capacity? Should NNA 1 fail and Susan Dionne 8 be used as the primary disposal well, could Hilcorp please provide estimates of the daily disposal volumes, the total estimated volume, and the radius of the affected area surrounding the well? Please provide the parameters used to calculate these volumes (thickness, average porosity, native-fluid displacement effectiveness, expected affected radius, etc.). Thanks and Be Well, Steve Davies AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov The information contained in this email message is confidential and may be legally privileged and is intended only for the use of the individual or entity named above. If you are not an intended recipient or if you have received this message in error, you are hereby notified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, please immediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently deletethis message. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that theonward transmission, opening, or use of this message and any attachments will not adversely affect its systems or data. No responsibilityis accepted by the company in this regard and the recipient should carry out such virus and other checks as it considers appropriate. CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. From:Davies, Stephen F (OGC) To:Casey Morse Cc:Wallace, Chris D (OGC); Dewhurst, Andrew D (OGC) Subject:RE: [EXTERNAL] AEO for Susan Dionne 8 Date:Tuesday, October 29, 2024 10:44:00 AM Casey, Hilcorp’s request is still under review. The process is this: I reviewed Hilcorp’s application and--since EPA concurrence is needed on all Aquifer Exemptions issued by AOGCC--I contacted EPA Region 10 to discuss the project. EPA has a required, very detailed Aquifer Exemption Checklist, so I filled out the checklist for the project, submitted it to them, waited, and received their reply, which consists of a list of 18 or so additional questions. While waiting, I wrote up the draft text for the order. I’m currently working my way through EPA’s questions, making certain that each one is answered completely. I’ll then revise the draft text for the order accordingly, AOGCC’s Commissioners will decide to issue the order or deny Hilcorp’s request, and if approved and issued, a copy of the order will be sent to the EPA. EPA then has 45 days to decide whether to concur, take no action on, or not concur with AOGCC’s order. So, the entire process will likely take at least more two months to complete. If I need additional information to answer any of EPA’s questions, I won’t hesitate to contact you. Hope this helps. Regards and Be Well, Steve Davies AOGCC From: Casey Morse <Casey.Morse@hilcorp.com> Sent: Tuesday, October 29, 2024 8:31 AM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Good morning, Steve. I wanted to check in with you on the status of this AEO request. Where is this in the review process? What are the next steps? Thank you, Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 From: Casey Morse <casey.morse@hilcorp.com> Sent: Friday, September 6, 2024 10:14 AM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Steve, The average volumes we pumped into NNA-1 for the past year were approximately 300 bpd. The average porosity for the disposal interval in the SD-8 well is estimated at 25%. The disposal interval is 45 ft thick, and we will likely perforate across most (or all) of that interval. Here are the assumptions I used to calculate a radius of impact: 20-year project life with 300 bpd average daily rate Disposal zone height of 45 ft Average porosity of disposal zone is 25% Injected fluids remain vertically confined within the disposal zone Injection is proportionally distributed amongst the perforations There is piston-like displacement of native reservoir fluids Based on these assumptions, the impacted radius would be 590 ft. Thank you, Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Wednesday, August 28, 2024 12:44 PM To: Casey Morse <casey.morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. <andrew.dewhurst@alaska.gov> Subject: [EXTERNAL] AEO for Susan Dionne 8 Casey, I’m working on the Aquifer Exemption Order for the Susan Dionne 8 well. We’re making good progress, but I have a few questions for you. As I recall from the companion Disposal Injection Order NO. 47, this well will be used as a back up for the NNA 1 primary disposal well. If so, could Hilcorp please provide estimates for the volume of fluids expected to be disposed in Susan Dionne 8 over the life of the project in this backup capacity? Should NNA 1 fail and Susan Dionne 8 be used as the primary disposal well, could Hilcorp please provide estimates of the daily disposal volumes, the total estimated volume, and the radius of the affected area surrounding the well? Please provide the parameters used to calculate these volumes (thickness, average porosity, native-fluid displacement effectiveness, expected affected radius, etc.). Thanks and Be Well, Steve Davies AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov The information contained in this email message is confidential and may be legally privileged and is intended only for the use of the individual or entity named above. If you are not an intended recipient or if you have received this message in error, you are herebynotified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, pleaseimmediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently deletethis message. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that theonward transmission, opening, or use of this message and any attachments will not adversely affect its systems or data. No responsibilityis accepted by the company in this regard and the recipient should carry out such virus and other checks as it considers appropriate. CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. From:Casey Morse To:Davies, Stephen F (OGC) Cc:Wallace, Chris D (OGC); Dewhurst, Andrew D (OGC) Subject:RE: [EXTERNAL] AEO for Susan Dionne 8 Date:Tuesday, October 29, 2024 11:03:24 AM Thank you, Steve. I appreciate the explanation on that. Casey From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Tuesday, October 29, 2024 10:44 AM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, Hilcorp’s request is still under review. The process is this: I reviewed Hilcorp’s application and--since EPA concurrence is needed on all Aquifer Exemptions issued by AOGCC--I contacted EPA Region 10 to discuss the project. EPA has a required, very detailed Aquifer Exemption Checklist, so I filled out the checklist for the project, submitted it to them, waited, and received their reply, which consists of a list of 18 or so additional questions. While waiting, I wrote up the draft text for the order. I’m currently working my way through EPA’s questions, making certain that each one is answered completely. I’ll then revise the draft text for the order accordingly, AOGCC’s Commissioners will decide to issue the order or deny Hilcorp’s request, and if approved and issued, a copy of the order will be sent to the EPA. EPA then has 45 days to decide whether to concur, take no action on, or not concur with AOGCC’s order. So, the entire process will likely take at least more two months to complete. If I need additional information to answer any of EPA’s questions, I won’t hesitate to contact you. Hope this helps. Regards and Be Well, Steve Davies AOGCC From: Casey Morse <Casey.Morse@hilcorp.com> Sent: Tuesday, October 29, 2024 8:31 AM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Good morning, Steve. I wanted to check in with you on the status of this AEO request. Where is this in the review process? What are the next steps? Thank you, Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 From: Casey Morse <casey.morse@hilcorp.com> Sent: Friday, September 6, 2024 10:14 AM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Steve, The average volumes we pumped into NNA-1 for the past year were approximately 300 bpd. The average porosity for the disposal interval in the SD-8 well is estimated at 25%. The disposal interval is 45 ft thick, and we will likely perforate across most (or all) of that interval. Here are the assumptions I used to calculate a radius of impact: 20-year project life with 300 bpd average daily rate Disposal zone height of 45 ft Average porosity of disposal zone is 25% Injected fluids remain vertically confined within the disposal zone Injection is proportionally distributed amongst the perforations There is piston-like displacement of native reservoir fluids Based on these assumptions, the impacted radius would be 590 ft. CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. Thank you, Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Wednesday, August 28, 2024 12:44 PM To: Casey Morse <casey.morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: [EXTERNAL] AEO for Susan Dionne 8 Casey, I’m working on the Aquifer Exemption Order for the Susan Dionne 8 well. We’re making good progress, but I have a few questions for you. As I recall from the companion Disposal Injection Order NO. 47, this well will be used as a back up for the NNA 1 primary disposal well. If so, could Hilcorp please provide estimates for the volume of fluids expected to be disposed in Susan Dionne 8 over the life of the project in this backup capacity? Should NNA 1 fail and Susan Dionne 8 be used as the primary disposal well, could Hilcorp please provide estimates of the daily disposal volumes, the total estimated volume, and the radius of the affected area surrounding the well? Please provide the parameters used to calculate these volumes (thickness, average porosity, native-fluid displacement effectiveness, expected affected radius, etc.). Thanks and Be Well, Steve Davies AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov The information contained in this email message is confidential and may be legally privileged and is intended only for the use of theindividual or entity named above. If you are not an intended recipient or if you have received this message in error, you are herebynotified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, pleaseimmediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently deletethis message. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that theonward transmission, opening, or use of this message and any attachments will not adversely affect its systems or data. No responsibilityis accepted by the company in this regard and the recipient should carry out such virus and other checks as it considers appropriate. The information contained in this email message is confidential and may be legally privileged and is intended only for the use of theindividual or entity named above. If you are not an intended recipient or if you have received this message in error, you are herebynotified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, pleaseimmediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently deletethis message. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that the onward transmission, opening, or use of this message and any attachments will not adversely affect its systems or data. No responsibility is accepted by the company in this regard and the recipient should carry out such virus and other checks as it considers appropriate. From:Davies, Stephen F (OGC) To:Casey Morse Cc:Wallace, Chris D (OGC); Dewhurst, Andrew D (OGC) Subject:RE: [EXTERNAL] AEO for Susan Dionne 8 Date:Thursday, November 14, 2024 2:59:00 PM Casey, EPA has a few questions with regard to their checklist that I filled out and submitted for Susan Dionne 8. They are: What method did Hilcorp use to gather water samples from the Beluga 135 sand in well Susan Dionne 1A? Was there possibility of sample contamination by drilling fluid or other oilfield fluids during this process, or prior to collection? Was the wellbore flushed? Any additional information you can provide will be appreciated. Thanks and Be Well, Steve Davies AOGCC From: Casey Morse <casey.morse@hilcorp.com> Sent: Friday, September 6, 2024 10:14 AM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Steve, The average volumes we pumped into NNA-1 for the past year were approximately 300 bpd. The average porosity for the disposal interval in the SD-8 well is estimated at 25%. The disposal interval is 45 ft thick, and we will likely perforate across most (or all) of that interval. Here are the assumptions I used to calculate a radius of impact: 20-year project life with 300 bpd average daily rate Disposal zone height of 45 ft Average porosity of disposal zone is 25% Injected fluids remain vertically confined within the disposal zone Injection is proportionally distributed amongst the perforations CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. There is piston-like displacement of native reservoir fluids Based on these assumptions, the impacted radius would be 590 ft. Thank you, Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Wednesday, August 28, 2024 12:44 PM To: Casey Morse <casey.morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: [EXTERNAL] AEO for Susan Dionne 8 Casey, I’m working on the Aquifer Exemption Order for the Susan Dionne 8 well. We’re making good progress, but I have a few questions for you. As I recall from the companion Disposal Injection Order NO. 47, this well will be used as a back up for the NNA 1 primary disposal well. If so, could Hilcorp please provide estimates for the volume of fluids expected to be disposed in Susan Dionne 8 over the life of the project in this backup capacity? Should NNA 1 fail and Susan Dionne 8 be used as the primary disposal well, could Hilcorp please provide estimates of the daily disposal volumes, the total estimated volume, and the radius of the affected area surrounding the well? Please provide the parameters used to calculate these volumes (thickness, average porosity, native-fluid displacement effectiveness, expected affected radius, etc.). Thanks and Be Well, Steve Davies AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov The information contained in this email message is confidential and may be legally privileged and is intended only for the use of theindividual or entity named above. If you are not an intended recipient or if you have received this message in error, you are herebynotified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, pleaseimmediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently delete this message. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that theonward transmission, opening, or use of this message and any attachments will not adversely affect its systems or data. No responsibilityis accepted by the company in this regard and the recipient should carry out such virus and other checks as it considers appropriate. The information contained in this email message is confidential and may be legally privileged and is intended only for the use of theindividual or entity named above. If you are not an intended recipient or if you have received this message in error, you are herebynotified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, pleaseimmediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently deletethis message. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that the onward transmission, opening, or use of this message and any attachments will not adversely affect its systems or data. No responsibilityis accepted by the company in this regard and the recipient should carry out such virus and other checks as it considers appropriate. From:Davies, Stephen F (OGC) To:Casey Morse Cc:Wallace, Chris D (OGC); Dewhurst, Andrew D (OGC) Subject:RE: [EXTERNAL] AEO for Susan Dionne 8 Date:Friday, November 15, 2024 5:30:00 PM Casey, In addition to the questions listed below, the EPA is also inquiring about the source of contaminants in the Beluga 135 aquifer. Does Hilcorp have any information or explanation concerning the source of these contaminants? Again, any information that Hilcorp can supply will be very helpful. Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Thursday, November 14, 2024 3:00 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, EPA has a few questions with regard to their checklist that I filled out and submitted for Susan Dionne 8. They are: What method did Hilcorp use to gather water samples from the Beluga 135 sand in well Susan Dionne 1A? Was there possibility of sample contamination by drilling fluid or other oilfield fluids during this process, or prior to collection? Was the wellbore flushed? Any additional information you can provide will be appreciated. Thanks and Be Well, Steve Davies AOGCC CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. From: Casey Morse <casey.morse@hilcorp.com> Sent: Friday, September 6, 2024 10:14 AM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Steve, The average volumes we pumped into NNA-1 for the past year were approximately 300 bpd. The average porosity for the disposal interval in the SD-8 well is estimated at 25%. The disposal interval is 45 ft thick, and we will likely perforate across most (or all) of that interval. Here are the assumptions I used to calculate a radius of impact: 20-year project life with 300 bpd average daily rate Disposal zone height of 45 ft Average porosity of disposal zone is 25% Injected fluids remain vertically confined within the disposal zone Injection is proportionally distributed amongst the perforations There is piston-like displacement of native reservoir fluids Based on these assumptions, the impacted radius would be 590 ft. Thank you, Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Wednesday, August 28, 2024 12:44 PM To: Casey Morse <casey.morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: [EXTERNAL] AEO for Susan Dionne 8 Casey, I’m working on the Aquifer Exemption Order for the Susan Dionne 8 well. We’re making good progress, but I have a few questions for you. As I recall from the companion Disposal Injection Order NO. 47, this well will be used as a back up for the NNA 1 primary disposal well. If so, could Hilcorp please provide estimates for the volume of fluids expected to be disposed in Susan Dionne 8 over the life of the project in this backup capacity? Should NNA 1 fail and Susan Dionne 8 be used as the primary disposal well, could Hilcorp please provide estimates of the daily disposal volumes, the total estimated volume, and the radius of the affected area surrounding the well? Please provide the parameters used to calculate these volumes (thickness, average porosity, native-fluid displacement effectiveness, expected affected radius, etc.). Thanks and Be Well, Steve Davies AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov The information contained in this email message is confidential and may be legally privileged and is intended only for the use of theindividual or entity named above. If you are not an intended recipient or if you have received this message in error, you are hereby notified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, please immediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently delete this message. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that theonward transmission, opening, or use of this message and any attachments will not adversely affect its systems or data. No responsibilityis accepted by the company in this regard and the recipient should carry out such virus and other checks as it considers appropriate. The information contained in this email message is confidential and may be legally privileged and is intended only for the use of theindividual or entity named above. If you are not an intended recipient or if you have received this message in error, you are herebynotified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, please immediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently delete this message. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that theonward transmission, opening, or use of this message and any attachments will not adversely affect its systems or data. No responsibilityis accepted by the company in this regard and the recipient should carry out such virus and other checks as it considers appropriate. From:Davies, Stephen F (OGC) To:Casey Morse Cc:Wallace, Chris D (OGC); Dewhurst, Andrew D (OGC) Subject:RE: [EXTERNAL] AEO for Susan Dionne 8 Date:Friday, November 15, 2024 5:45:00 PM Casey, For simplicity, I’ve combined into a single list several additional questions from the EPA that require extra information beyond that provided in Hilcorp’s Aquifer Exemption application for Susan Dionne 8. What method did Hilcorp use to gather water samples from the Beluga 135 sand in well Susan Dionne 1A? Was there possibility of sample contamination by drilling fluid or other oilfield fluids during this process, or prior to collection? Was the wellbore flushed? Does Hilcorp have any information or explanation concerning the source of contaminants in the Beluga 135 aquifer? Please provide the information or an explanation. Are contaminant levels in the Beluga 135 consistent across the aquifer? Are water quality samples available from wells other than the Susan Dionne 1A? Have state or federal government-provided census data been used to evaluate population/economic forecasts for this area? Any additional information that Hilcorp can provide will be appreciated. Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Friday, November 15, 2024 5:30 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, In addition to the questions listed below, the EPA is also inquiring about the source of contaminants in the Beluga 135 aquifer. Does Hilcorp have any information or explanation concerning the source of these contaminants? Again, any information that Hilcorp can supply will be very helpful. Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Thursday, November 14, 2024 3:00 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, EPA has a few questions with regard to their checklist that I filled out and submitted for Susan Dionne 8. They are: What method did Hilcorp use to gather water samples from the Beluga 135 sand in well Susan Dionne 1A? Was there possibility of sample contamination by drilling fluid or other oilfield fluids during this process, or prior to collection? Was the wellbore flushed? Any additional information you can provide will be appreciated. Thanks and Be Well, Steve Davies AOGCC From: Casey Morse <casey.morse@hilcorp.com> Sent: Friday, September 6, 2024 10:14 AM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Steve, CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. The average volumes we pumped into NNA-1 for the past year were approximately 300 bpd. The average porosity for the disposal interval in the SD-8 well is estimated at 25%. The disposal interval is 45 ft thick, and we will likely perforate across most (or all) of that interval. Here are the assumptions I used to calculate a radius of impact: 20-year project life with 300 bpd average daily rate Disposal zone height of 45 ft Average porosity of disposal zone is 25% Injected fluids remain vertically confined within the disposal zone Injection is proportionally distributed amongst the perforations There is piston-like displacement of native reservoir fluids Based on these assumptions, the impacted radius would be 590 ft. Thank you, Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Wednesday, August 28, 2024 12:44 PM To: Casey Morse <casey.morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: [EXTERNAL] AEO for Susan Dionne 8 Casey, I’m working on the Aquifer Exemption Order for the Susan Dionne 8 well. We’re making good progress, but I have a few questions for you. As I recall from the companion Disposal Injection Order NO. 47, this well will be used as a back up for the NNA 1 primary disposal well. If so, could Hilcorp please provide estimates for the volume of fluids expected to be disposed in Susan Dionne 8 over the life of the project in this backup capacity? Should NNA 1 fail and Susan Dionne 8 be used as the primary disposal well, could Hilcorp please provide estimates of the daily disposal volumes, the total estimated volume, and the radius of the affected area surrounding the well? Please provide the parameters used to calculate these volumes (thickness, average porosity, native-fluid displacement effectiveness, expected affected radius, etc.). Thanks and Be Well, Steve Davies AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov The information contained in this email message is confidential and may be legally privileged and is intended only for the use of theindividual or entity named above. If you are not an intended recipient or if you have received this message in error, you are herebynotified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, pleaseimmediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently deletethis message. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that the onward transmission, opening, or use of this message and any attachments will not adversely affect its systems or data. No responsibility is accepted by the company in this regard and the recipient should carry out such virus and other checks as it considers appropriate. The information contained in this email message is confidential and may be legally privileged and is intended only for the use of theindividual or entity named above. If you are not an intended recipient or if you have received this message in error, you are herebynotified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, pleaseimmediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently deletethis message. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that the onward transmission, opening, or use of this message and any attachments will not adversely affect its systems or data. No responsibility is accepted by the company in this regard and the recipient should carry out such virus and other checks as it considers appropriate. From:Davies, Stephen F (OGC) To:Casey Morse Cc:Wallace, Chris D (OGC); Dewhurst, Andrew D (OGC) Subject:RE: [EXTERNAL] AEO for Susan Dionne 8 Date:Monday, November 18, 2024 11:34:00 AM Hi Casey, To keep this moving through the AOGCC approval process, I’d like to let you know that I’ll be out of the office beginning Thursday at 11:30 AM and continuing until December 2nd. Any help additional information regarding my questions below will be most helpful. Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Friday, November 15, 2024 5:46 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, For simplicity, I’ve combined into a single list several additional questions from the EPA that require extra information beyond that provided in Hilcorp’s Aquifer Exemption application for Susan Dionne 8. What method did Hilcorp use to gather water samples from the Beluga 135 sand in well Susan Dionne 1A? Was there possibility of sample contamination by drilling fluid or other oilfield fluids during this process, or prior to collection? Was the wellbore flushed? Does Hilcorp have any information or explanation concerning the source of contaminants in the Beluga 135 aquifer? Please provide the information or an explanation. Are contaminant levels in the Beluga 135 consistent across the aquifer? Are water quality samples available from wells other than the Susan Dionne 1A? Have state or federal government-provided census data been used to evaluate population/economic forecasts for this area? Any additional information that Hilcorp can provide will be appreciated. Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Friday, November 15, 2024 5:30 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, In addition to the questions listed below, the EPA is also inquiring about the source of contaminants in the Beluga 135 aquifer. Does Hilcorp have any information or explanation concerning the source of these contaminants? Again, any information that Hilcorp can supply will be very helpful. Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Thursday, November 14, 2024 3:00 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, EPA has a few questions with regard to their checklist that I filled out and submitted for Susan Dionne 8. They are: What method did Hilcorp use to gather water samples from the Beluga 135 sand in well Susan Dionne 1A? Was there possibility of sample contamination by drilling fluid or other oilfield fluids during this process, or prior to collection? Was the wellbore flushed? Any additional information you can provide will be appreciated. Thanks and Be Well, Steve Davies AOGCC From: Casey Morse <casey.morse@hilcorp.com> Sent: Friday, September 6, 2024 10:14 AM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Steve, The average volumes we pumped into NNA-1 for the past year were approximately 300 bpd. The average porosity for the disposal interval in the SD-8 well is estimated at 25%. The disposal interval is 45 ft thick, and we will likely perforate across most (or all) of that interval. Here are the assumptions I used to calculate a radius of impact: 20-year project life with 300 bpd average daily rate Disposal zone height of 45 ft Average porosity of disposal zone is 25% Injected fluids remain vertically confined within the disposal zone Injection is proportionally distributed amongst the perforations There is piston-like displacement of native reservoir fluids Based on these assumptions, the impacted radius would be 590 ft. Thank you, Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Wednesday, August 28, 2024 12:44 PM CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. To: Casey Morse <casey.morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: [EXTERNAL] AEO for Susan Dionne 8 Casey, I’m working on the Aquifer Exemption Order for the Susan Dionne 8 well. We’re making good progress, but I have a few questions for you. As I recall from the companion Disposal Injection Order NO. 47, this well will be used as a back up for the NNA 1 primary disposal well. If so, could Hilcorp please provide estimates for the volume of fluids expected to be disposed in Susan Dionne 8 over the life of the project in this backup capacity? Should NNA 1 fail and Susan Dionne 8 be used as the primary disposal well, could Hilcorp please provide estimates of the daily disposal volumes, the total estimated volume, and the radius of the affected area surrounding the well? Please provide the parameters used to calculate these volumes (thickness, average porosity, native-fluid displacement effectiveness, expected affected radius, etc.). Thanks and Be Well, Steve Davies AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov The information contained in this email message is confidential and may be legally privileged and is intended only for the use of theindividual or entity named above. If you are not an intended recipient or if you have received this message in error, you are herebynotified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, pleaseimmediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently delete this message. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that theonward transmission, opening, or use of this message and any attachments will not adversely affect its systems or data. No responsibilityis accepted by the company in this regard and the recipient should carry out such virus and other checks as it considers appropriate. The information contained in this email message is confidential and may be legally privileged and is intended only for the use of theindividual or entity named above. If you are not an intended recipient or if you have received this message in error, you are herebynotified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, pleaseimmediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently deletethis message. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that the onward transmission, opening, or use of this message and any attachments will not adversely affect its systems or data. No responsibilityis accepted by the company in this regard and the recipient should carry out such virus and other checks as it considers appropriate. CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. From:Casey Morse To:Davies, Stephen F (OGC) Cc:Wallace, Chris D (OGC); Dewhurst, Andrew D (OGC); Donna Ambruz Subject:RE: [EXTERNAL] AEO for Susan Dionne 8 Date:Monday, November 18, 2024 4:19:13 PM Steve, The Beluga 135 zone was open to flow in the SD-1A from 1962 until 2001. It produced gas and water from that formation. Due to the high water production, Marathon set a liner and cemented across those perfs in 2001 to isolate that formation. There are other wells in the area with active gas production from the Beluga 135 zone. Those wells are >3,000 feet away laterally and >60 feet further up structure from the SD-1A and SD-8. Below is an overview of the procedure we followed on the SD-1A to gather a water sample that would be representative of the disposal interval: Pressured up the well with N2 and pushed fluid level down to 4,926’ Set a CIBP at 4,890’ to seal off the deeper perfs. Perforated the Beluga 135 interval from 3790-3810’. Initial pressures were ~1300 psi Reduced the surface pressure to allow for some inflow. Returned a couple days later with a slickline bailer. Fluid level was at 1950’. Ran in to 2050’ and pulled water sample into the bailer. Returned with 4.5 gallons of water. RIH a second time, fluid was at 1950’ again. Pulled a second sample from 2050’. Returned with 4.5 gallons of water in the bailer. Those 2 samples were analyzed for the purpose of this aquifer exemption request. We followed the procedure above to minimize the chance of any fluid contamination. The sample we received should be representative of the formation fluids. Given that this formation is gas-bearing, the contaminants in this water align with our expectations. We do not have any other isolated Beluga 135 water samples. We reviewed the Kenai Peninsula Borough Comprehensive Plan as well as information regarding public water systems in nearby communities. No publicly available information raised concerns with available water supply from the surface or shallow sources currently utilized in the area. We estimated a capital cost greater than $4 million and ongoing annual operating costs of $138,000 to develop and operate a water supply well in the Beluga 135. This does not include costs for treating the water quality. We concluded that this was not a commercially viable water source given the relative value of property in the area and the availability of other water supplies that are significantly less costly. We did not consider economic or population growth forecasts in our evaluation of the CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. commercial viability for drilling a water supply well into this formation. Regards, Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Monday, November 18, 2024 11:35 AM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Hi Casey, To keep this moving through the AOGCC approval process, I’d like to let you know that I’ll be out of the office beginning Thursday at 11:30 AM and continuing until December 2nd. Any help additional information regarding my questions below will be most helpful. Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Friday, November 15, 2024 5:46 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, For simplicity, I’ve combined into a single list several additional questions from the EPA that require extra information beyond that provided in Hilcorp’s Aquifer Exemption application for Susan Dionne 8. What method did Hilcorp use to gather water samples from the Beluga 135 sand in well Susan Dionne 1A? Was there possibility of sample contamination by drilling fluid or other oilfield fluids during this process, or prior to collection? Was the wellbore flushed? Does Hilcorp have any information or explanation concerning the source of contaminants in the Beluga 135 aquifer? Please provide the information or an explanation. Are contaminant levels in the Beluga 135 consistent across the aquifer? Are water quality samples available from wells other than the Susan Dionne 1A? Have state or federal government-provided census data been used to evaluate population/economic forecasts for this area? Any additional information that Hilcorp can provide will be appreciated. Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Friday, November 15, 2024 5:30 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, In addition to the questions listed below, the EPA is also inquiring about the source of contaminants in the Beluga 135 aquifer. Does Hilcorp have any information or explanation concerning the source of these contaminants? Again, any information that Hilcorp can supply will be very helpful. Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Thursday, November 14, 2024 3:00 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, EPA has a few questions with regard to their checklist that I filled out and submitted for Susan Dionne 8. They are: What method did Hilcorp use to gather water samples from the Beluga 135 sand in well Susan Dionne 1A? Was there possibility of sample contamination by drilling fluid or other oilfield fluids during this process, or prior to collection? Was the wellbore flushed? Any additional information you can provide will be appreciated. Thanks and Be Well, Steve Davies AOGCC From: Casey Morse <casey.morse@hilcorp.com> Sent: Friday, September 6, 2024 10:14 AM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Steve, The average volumes we pumped into NNA-1 for the past year were approximately 300 bpd. The average porosity for the disposal interval in the SD-8 well is estimated at 25%. The disposal interval is 45 ft thick, and we will likely perforate across most (or all) of that interval. Here are the assumptions I used to calculate a radius of impact: 20-year project life with 300 bpd average daily rate Disposal zone height of 45 ft Average porosity of disposal zone is 25% Injected fluids remain vertically confined within the disposal zone CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. Injection is proportionally distributed amongst the perforations There is piston-like displacement of native reservoir fluids Based on these assumptions, the impacted radius would be 590 ft. Thank you, Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Wednesday, August 28, 2024 12:44 PM To: Casey Morse <casey.morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: [EXTERNAL] AEO for Susan Dionne 8 Casey, I’m working on the Aquifer Exemption Order for the Susan Dionne 8 well. We’re making good progress, but I have a few questions for you. As I recall from the companion Disposal Injection Order NO. 47, this well will be used as a back up for the NNA 1 primary disposal well. If so, could Hilcorp please provide estimates for the volume of fluids expected to be disposed in Susan Dionne 8 over the life of the project in this backup capacity? Should NNA 1 fail and Susan Dionne 8 be used as the primary disposal well, could Hilcorp please provide estimates of the daily disposal volumes, the total estimated volume, and the radius of the affected area surrounding the well? Please provide the parameters used to calculate these volumes (thickness, average porosity, native-fluid displacement effectiveness, expected affected radius, etc.). Thanks and Be Well, Steve Davies AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov The information contained in this email message is confidential and may be legally privileged and is intended only for the use of the individual or entity named above. If you are not an intended recipient or if you have received this message in error, you are hereby notified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, please immediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently deletethis message. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that theonward transmission, opening, or use of this message and any attachments will not adversely affect its systems or data. No responsibilityis accepted by the company in this regard and the recipient should carry out such virus and other checks as it considers appropriate. The information contained in this email message is confidential and may be legally privileged and is intended only for the use of theindividual or entity named above. If you are not an intended recipient or if you have received this message in error, you are hereby notified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, please immediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently delete this message. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that theonward transmission, opening, or use of this message and any attachments will not adversely affect its systems or data. No responsibilityis accepted by the company in this regard and the recipient should carry out such virus and other checks as it considers appropriate. The information contained in this email message is confidential and may be legally privileged and is intended only for the use of theindividual or entity named above. If you are not an intended recipient or if you have received this message in error, you are herebynotified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, pleaseimmediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently deletethis message. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that theonward transmission, opening, or use of this message and any attachments will not adversely affect its systems or data. No responsibilityis accepted by the company in this regard and the recipient should carry out such virus and other checks as it considers appropriate. CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. From:Casey Morse To:Davies, Stephen F (OGC) Cc:Wallace, Chris D (OGC); Dewhurst, Andrew D (OGC); Donna Ambruz Subject:RE: [EXTERNAL] AEO for Susan Dionne 8 Date:Monday, November 18, 2024 4:19:13 PM Steve, The Beluga 135 zone was open to flow in the SD-1A from 1962 until 2001. It produced gas and water from that formation. Due to the high water production, Marathon set a liner and cemented across those perfs in 2001 to isolate that formation. There are other wells in the area with active gas production from the Beluga 135 zone. Those wells are >3,000 feet away laterally and >60 feet further up structure from the SD-1A and SD-8. Below is an overview of the procedure we followed on the SD-1A to gather a water sample that would be representative of the disposal interval: Pressured up the well with N2 and pushed fluid level down to 4,926’ Set a CIBP at 4,890’ to seal off the deeper perfs. Perforated the Beluga 135 interval from 3790-3810’. Initial pressures were ~1300 psi Reduced the surface pressure to allow for some inflow. Returned a couple days later with a slickline bailer. Fluid level was at 1950’. Ran in to 2050’ and pulled water sample into the bailer. Returned with 4.5 gallons of water. RIH a second time, fluid was at 1950’ again. Pulled a second sample from 2050’. Returned with 4.5 gallons of water in the bailer. Those 2 samples were analyzed for the purpose of this aquifer exemption request. We followed the procedure above to minimize the chance of any fluid contamination. The sample we received should be representative of the formation fluids. Given that this formation is gas-bearing, the contaminants in this water align with our expectations. We do not have any other isolated Beluga 135 water samples. We reviewed the Kenai Peninsula Borough Comprehensive Plan as well as information regarding public water systems in nearby communities. No publicly available information raised concerns with available water supply from the surface or shallow sources currently utilized in the area. We estimated a capital cost greater than $4 million and ongoing annual operating costs of $138,000 to develop and operate a water supply well in the Beluga 135. This does not include costs for treating the water quality. We concluded that this was not a commercially viable water source given the relative value of property in the area and the availability of other water supplies that are significantly less costly. We did not consider CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. economic or population growth forecasts in our evaluation of the commercial viability for drilling a water supply well into this formation. Regards, Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Monday, November 18, 2024 11:35 AM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Hi Casey, To keep this moving through the AOGCC approval process, I’d like to let you know that I’ll be out of the office beginning Thursday at 11:30 AM and continuing until December 2nd. Any help additional information regarding my questions below will be most helpful. Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Friday, November 15, 2024 5:46 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, For simplicity, I’ve combined into a single list several additional questions from the EPA that require extra information beyond that provided in Hilcorp’s Aquifer Exemption application for Susan Dionne 8. What method did Hilcorp use to gather water samples from the Beluga 135 sand in well Susan Dionne 1A? Was there possibility of sample contamination by drilling fluid or other oilfield fluids during this process, or prior to collection? Was the wellbore flushed? Does Hilcorp have any information or explanation concerning the source of contaminants in the Beluga 135 aquifer? Please provide the information or an explanation. Are contaminant levels in the Beluga 135 consistent across the aquifer? Are water quality samples available from wells other than the Susan Dionne 1A? Have state or federal government-provided census data been used to evaluate population/economic forecasts for this area? Any additional information that Hilcorp can provide will be appreciated. Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Friday, November 15, 2024 5:30 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, In addition to the questions listed below, the EPA is also inquiring about the source of contaminants in the Beluga 135 aquifer. Does Hilcorp have any information or explanation concerning the source of these contaminants? Again, any information that Hilcorp can supply will be very helpful. Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Thursday, November 14, 2024 3:00 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, EPA has a few questions with regard to their checklist that I filled out and submitted for Susan Dionne 8. They are: What method did Hilcorp use to gather water samples from the Beluga 135 sand in well Susan Dionne 1A? Was there possibility of sample contamination by drilling fluid or other oilfield fluids during this process, or prior to collection? Was the wellbore flushed? Any additional information you can provide will be appreciated. Thanks and Be Well, Steve Davies AOGCC From: Casey Morse <casey.morse@hilcorp.com> Sent: Friday, September 6, 2024 10:14 AM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Steve, The average volumes we pumped into NNA-1 for the past year were approximately 300 bpd. The average porosity for the disposal interval in the SD-8 well is estimated at 25%. The disposal interval is 45 ft thick, and we will likely perforate across most (or all) of that interval. Here are the assumptions I used to calculate a radius of impact: 20-year project life with 300 bpd average daily rate Disposal zone height of 45 ft Average porosity of disposal zone is 25% CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. Injected fluids remain vertically confined within the disposal zone Injection is proportionally distributed amongst the perforations There is piston-like displacement of native reservoir fluids Based on these assumptions, the impacted radius would be 590 ft. Thank you, Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Wednesday, August 28, 2024 12:44 PM To: Casey Morse <casey.morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: [EXTERNAL] AEO for Susan Dionne 8 Casey, I’m working on the Aquifer Exemption Order for the Susan Dionne 8 well. We’re making good progress, but I have a few questions for you. As I recall from the companion Disposal Injection Order NO. 47, this well will be used as a back up for the NNA 1 primary disposal well. If so, could Hilcorp please provide estimates for the volume of fluids expected to be disposed in Susan Dionne 8 over the life of the project in this backup capacity? Should NNA 1 fail and Susan Dionne 8 be used as the primary disposal well, could Hilcorp please provide estimates of the daily disposal volumes, the total estimated volume, and the radius of the affected area surrounding the well? Please provide the parameters used to calculate these volumes (thickness, average porosity, native-fluid displacement effectiveness, expected affected radius, etc.). Thanks and Be Well, Steve Davies AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov The information contained in this email message is confidential and may be legally privileged and is intended only for the use of theindividual or entity named above. If you are not an intended recipient or if you have received this message in error, you are herebynotified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, pleaseimmediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently delete this message. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that theonward transmission, opening, or use of this message and any attachments will not adversely affect its systems or data. No responsibilityis accepted by the company in this regard and the recipient should carry out such virus and other checks as it considers appropriate. The information contained in this email message is confidential and may be legally privileged and is intended only for the use of theindividual or entity named above. If you are not an intended recipient or if you have received this message in error, you are herebynotified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, pleaseimmediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently deletethis message. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that the onward transmission, opening, or use of this message and any attachments will not adversely affect its systems or data. No responsibilityis accepted by the company in this regard and the recipient should carry out such virus and other checks as it considers appropriate. The information contained in this email message is confidential and may be legally privileged and is intended only for the use of the individual or entity named above. If you are not an intended recipient or if you have received this message in error, you are hereby notified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, please immediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently deletethis message. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that theonward transmission, opening, or use of this message and any attachments will not adversely affect its systems or data. No responsibilityis accepted by the company in this regard and the recipient should carry out such virus and other checks as it considers appropriate. CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. From:Davies, Stephen F (OGC) To:Casey Morse Cc:Wallace, Chris D (OGC); Dewhurst, Andrew D (OGC); Donna Ambruz Subject:RE: [EXTERNAL] AEO for Susan Dionne 8 Date:Monday, November 18, 2024 5:17:00 PM Thank you, Casey. I appreciate your help with this. Regards and Be Well, Steve Davies AOGCC From: Casey Morse <Casey.Morse@hilcorp.com> Sent: Monday, November 18, 2024 4:19 PM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov>; Donna Ambruz <dambruz@hilcorp.com> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Steve, The Beluga 135 zone was open to flow in the SD-1A from 1962 until 2001. It produced gas and water from that formation. Due to the high water production, Marathon set a liner and cemented across those perfs in 2001 to isolate that formation. There are other wells in the area with active gas production from the Beluga 135 zone. Those wells are >3,000 feet away laterally and >60 feet further up structure from the SD-1A and SD-8. Below is an overview of the procedure we followed on the SD-1A to gather a water sample that would be representative of the disposal interval: Pressured up the well with N2 and pushed fluid level down to 4,926’ Set a CIBP at 4,890’ to seal off the deeper perfs. Perforated the Beluga 135 interval from 3790-3810’. Initial pressures were ~1300 psi Reduced the surface pressure to allow for some inflow. Returned a couple days later with a slickline bailer. Fluid level was at 1950’. Ran in to 2050’ and pulled water sample into the bailer. Returned with 4.5 gallons of water. RIH a second time, fluid was at 1950’ again. Pulled a second sample from 2050’. Returned with 4.5 gallons of water in the bailer. Those 2 samples were analyzed for the purpose of this aquifer exemption request. We followed the procedure above to minimize the chance of any fluid contamination. The CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. sample we received should be representative of the formation fluids. Given that this formation is gas-bearing, the contaminants in this water align with our expectations. We do not have any other isolated Beluga 135 water samples. We reviewed the Kenai Peninsula Borough Comprehensive Plan as well as information regarding public water systems in nearby communities. No publicly available information raised concerns with available water supply from the surface or shallow sources currently utilized in the area. We estimated a capital cost greater than $4 million and ongoing annual operating costs of $138,000 to develop and operate a water supply well in the Beluga 135. This does not include costs for treating the water quality. We concluded that this was not a commercially viable water source given the relative value of property in the area and the availability of other water supplies that are significantly less costly. We did not consider economic or population growth forecasts in our evaluation of the commercial viability for drilling a water supply well into this formation. Regards, Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Monday, November 18, 2024 11:35 AM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Hi Casey, To keep this moving through the AOGCC approval process, I’d like to let you know that I’ll be out of the office beginning Thursday at 11:30 AM and continuing until December 2nd. Any help additional information regarding my questions below will be most helpful. Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Friday, November 15, 2024 5:46 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, For simplicity, I’ve combined into a single list several additional questions from the EPA that require extra information beyond that provided in Hilcorp’s Aquifer Exemption application for Susan Dionne 8. What method did Hilcorp use to gather water samples from the Beluga 135 sand in well Susan Dionne 1A? Was there possibility of sample contamination by drilling fluid or other oilfield fluids during this process, or prior to collection? Was the wellbore flushed? Does Hilcorp have any information or explanation concerning the source of contaminants in the Beluga 135 aquifer? Please provide the information or an explanation. Are contaminant levels in the Beluga 135 consistent across the aquifer? Are water quality samples available from wells other than the Susan Dionne 1A? Have state or federal government-provided census data been used to evaluate population/economic forecasts for this area? Any additional information that Hilcorp can provide will be appreciated. Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Friday, November 15, 2024 5:30 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, In addition to the questions listed below, the EPA is also inquiring about the source of contaminants in the Beluga 135 aquifer. Does Hilcorp have any information or explanation concerning the source of these contaminants? Again, any information that Hilcorp can supply will be very helpful. Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Thursday, November 14, 2024 3:00 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, EPA has a few questions with regard to their checklist that I filled out and submitted for Susan Dionne 8. They are: What method did Hilcorp use to gather water samples from the Beluga 135 sand in well Susan Dionne 1A? Was there possibility of sample contamination by drilling fluid or other oilfield fluids during this process, or prior to collection? Was the wellbore flushed? Any additional information you can provide will be appreciated. Thanks and Be Well, Steve Davies AOGCC From: Casey Morse <casey.morse@hilcorp.com> Sent: Friday, September 6, 2024 10:14 AM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Steve, The average volumes we pumped into NNA-1 for the past year were approximately 300 bpd. The average porosity for the disposal interval in the SD-8 well is estimated at 25%. The disposal interval is 45 ft thick, and we will likely perforate across most (or all) of that interval. Here are the assumptions I used to calculate a radius of impact: 20-year project life with 300 bpd average daily rate Disposal zone height of 45 ft Average porosity of disposal zone is 25% Injected fluids remain vertically confined within the disposal zone Injection is proportionally distributed amongst the perforations There is piston-like displacement of native reservoir fluids Based on these assumptions, the impacted radius would be 590 ft. Thank you, Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Wednesday, August 28, 2024 12:44 PM To: Casey Morse <casey.morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: [EXTERNAL] AEO for Susan Dionne 8 Casey, I’m working on the Aquifer Exemption Order for the Susan Dionne 8 well. We’re making good progress, but I have a few questions for you. As I recall from the companion Disposal Injection Order NO. 47, this well will be used as a back up for the NNA 1 primary disposal well. If so, could Hilcorp please provide estimates for the volume of fluids expected to be disposed in Susan Dionne 8 over the life of the project in this backup capacity? Should NNA 1 fail and Susan Dionne 8 be used as the primary disposal well, could Hilcorp please provide estimates of the daily disposal volumes, the total estimated volume, and the radius of the affected area surrounding the well? Please provide the parameters used to calculate these volumes (thickness, average porosity, native-fluid displacement effectiveness, expected affected radius, etc.). Thanks and Be Well, Steve Davies AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov The information contained in this email message is confidential and may be legally privileged and is intended only for the use of theindividual or entity named above. If you are not an intended recipient or if you have received this message in error, you are herebynotified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, pleaseimmediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently deletethis message. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that theonward transmission, opening, or use of this message and any attachments will not adversely affect its systems or data. No responsibilityis accepted by the company in this regard and the recipient should carry out such virus and other checks as it considers appropriate. The information contained in this email message is confidential and may be legally privileged and is intended only for the use of the individual or entity named above. If you are not an intended recipient or if you have received this message in error, you are herebynotified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, pleaseimmediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently deletethis message. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that theonward transmission, opening, or use of this message and any attachments will not adversely affect its systems or data. No responsibilityis accepted by the company in this regard and the recipient should carry out such virus and other checks as it considers appropriate. The information contained in this email message is confidential and may be legally privileged and is intended only for the use of the individual or entity named above. If you are not an intended recipient or if you have received this message in error, you are hereby notified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, pleaseimmediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently deletethis message. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that theonward transmission, opening, or use of this message and any attachments will not adversely affect its systems or data. No responsibilityis accepted by the company in this regard and the recipient should carry out such virus and other checks as it considers appropriate. CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. From:Davies, Stephen F (OGC) To:Casey Morse Cc:Dewhurst, Andrew D (OGC) Subject:RE: [EXTERNAL] AEO for Susan Dionne 8 Date:Tuesday, November 19, 2024 12:40:00 PM Attachments:image001.png image002.png Casey, Could you please help me sort something out for the requested Aquifer Exemption? In your most recent email, below, you state: “The Beluga 135 zone was open to flow in the SD-1A from 1962 until 2001. It produced gas and water from that formation.” But when I look at AOGCC’s production records, I see this: Well Identification Information for SD-1A (PTD 185-208)Associated Production Record for SD-1A Am I looking at the wrong well? If so, which well are you referring to? If not, could you please provide the perforation depths for the Beluga 135 sand and quantify the amount of gas and water produced? You also state: “There are other wells in the area with active gas production from the Beluga 135 zone.” Could you please provide the names and Permit to Drill or API Numbers for these three wells? Thanks and Be Well, Steve Davies AOGCC From: Casey Morse <Casey.Morse@hilcorp.com> Sent: Monday, November 18, 2024 4:19 PM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov>; Donna Ambruz <dambruz@hilcorp.com> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Steve, The Beluga 135 zone was open to flow in the SD-1A from 1962 until 2001. It produced gas and water from that formation. Due to the high water production, Marathon set a liner and cemented across those perfs in 2001 to isolate that formation. There are other wells in the area with active gas production from the Beluga 135 zone. Those wells are >3,000 feet away laterally and >60 feet further up structure from the SD-1A and SD-8. Below is an overview of the procedure we followed on the SD-1A to gather a water sample that would be representative of the disposal interval: Pressured up the well with N2 and pushed fluid level down to 4,926’ Set a CIBP at 4,890’ to seal off the deeper perfs. Perforated the Beluga 135 interval from 3790-3810’. Initial pressures were ~1300 psi CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. Reduced the surface pressure to allow for some inflow. Returned a couple days later with a slickline bailer. Fluid level was at 1950’. Ran in to 2050’ and pulled water sample into the bailer. Returned with 4.5 gallons of water. RIH a second time, fluid was at 1950’ again. Pulled a second sample from 2050’. Returned with 4.5 gallons of water in the bailer. Those 2 samples were analyzed for the purpose of this aquifer exemption request. We followed the procedure above to minimize the chance of any fluid contamination. The sample we received should be representative of the formation fluids. Given that this formation is gas-bearing, the contaminants in this water align with our expectations. We do not have any other isolated Beluga 135 water samples. We reviewed the Kenai Peninsula Borough Comprehensive Plan as well as information regarding public water systems in nearby communities. No publicly available information raised concerns with available water supply from the surface or shallow sources currently utilized in the area. We estimated a capital cost greater than $4 million and ongoing annual operating costs of $138,000 to develop and operate a water supply well in the Beluga 135. This does not include costs for treating the water quality. We concluded that this was not a commercially viable water source given the relative value of property in the area and the availability of other water supplies that are significantly less costly. We did not consider economic or population growth forecasts in our evaluation of the commercial viability for drilling a water supply well into this formation. Regards, Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Monday, November 18, 2024 11:35 AM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Hi Casey, To keep this moving through the AOGCC approval process, I’d like to let you know that I’ll be out of the office beginning Thursday at 11:30 AM and continuing until December 2nd. Any help additional information regarding my questions below will be most helpful. Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Friday, November 15, 2024 5:46 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, For simplicity, I’ve combined into a single list several additional questions from the EPA that require extra information beyond that provided in Hilcorp’s Aquifer Exemption application for Susan Dionne 8. What method did Hilcorp use to gather water samples from the Beluga 135 sand in well Susan Dionne 1A? Was there possibility of sample contamination by drilling fluid or other oilfield fluids during this process, or prior to collection? Was the wellbore flushed? Does Hilcorp have any information or explanation concerning the source of contaminants in the Beluga 135 aquifer? Please provide the information or an explanation. Are contaminant levels in the Beluga 135 consistent across the aquifer? Are water quality samples available from wells other than the Susan Dionne 1A? Have state or federal government-provided census data been used to evaluate population/economic forecasts for this area? Any additional information that Hilcorp can provide will be appreciated. Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Friday, November 15, 2024 5:30 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, In addition to the questions listed below, the EPA is also inquiring about the source of contaminants in the Beluga 135 aquifer. Does Hilcorp have any information or explanation concerning the source of these contaminants? Again, any information that Hilcorp can supply will be very helpful. Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Thursday, November 14, 2024 3:00 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, EPA has a few questions with regard to their checklist that I filled out and submitted for Susan Dionne 8. They are: What method did Hilcorp use to gather water samples from the Beluga 135 sand in well Susan Dionne 1A? Was there possibility of sample contamination by drilling fluid or other oilfield fluids during this process, or prior to collection? Was the wellbore flushed? CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. Any additional information you can provide will be appreciated. Thanks and Be Well, Steve Davies AOGCC From: Casey Morse <casey.morse@hilcorp.com> Sent: Friday, September 6, 2024 10:14 AM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Steve, The average volumes we pumped into NNA-1 for the past year were approximately 300 bpd. The average porosity for the disposal interval in the SD-8 well is estimated at 25%. The disposal interval is 45 ft thick, and we will likely perforate across most (or all) of that interval. Here are the assumptions I used to calculate a radius of impact: 20-year project life with 300 bpd average daily rate Disposal zone height of 45 ft Average porosity of disposal zone is 25% Injected fluids remain vertically confined within the disposal zone Injection is proportionally distributed amongst the perforations There is piston-like displacement of native reservoir fluids Based on these assumptions, the impacted radius would be 590 ft. Thank you, Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Wednesday, August 28, 2024 12:44 PM To: Casey Morse <casey.morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: [EXTERNAL] AEO for Susan Dionne 8 Casey, I’m working on the Aquifer Exemption Order for the Susan Dionne 8 well. We’re making good progress, but I have a few questions for you. As I recall from the companion Disposal Injection Order NO. 47, this well will be used as a back up for the NNA 1 primary disposal well. If so, could Hilcorp please provide estimates for the volume of fluids expected to be disposed in Susan Dionne 8 over the life of the project in this backup capacity? Should NNA 1 fail and Susan Dionne 8 be used as the primary disposal well, could Hilcorp please provide estimates of the daily disposal volumes, the total estimated volume, and the radius of the affected area surrounding the well? Please provide the parameters used to calculate these volumes (thickness, average porosity, native-fluid displacement effectiveness, expected affected radius, etc.). Thanks and Be Well, Steve Davies AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov The information contained in this email message is confidential and may be legally privileged and is intended only for the use of the individual or entity named above. If you are notan intended recipient or if you have received this message in error, you are hereby notified that any dissemination, distribution, or copy of this email is strictly prohibited. If you havereceived this email in error, please immediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently delete thismessage. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that the onward transmission, opening, or use of thismessage and any attachments will not adversely affect its systems or data. No responsibility is accepted by the company in this regard and the recipient should carry out such virusand other checks as it considers appropriate. The information contained in this email message is confidential and may be legally privileged and is intended only for the use of the individual or entity named above. If you are notan intended recipient or if you have received this message in error, you are hereby notified that any dissemination, distribution, or copy of this email is strictly prohibited. If you havereceived this email in error, please immediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently delete thismessage. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that the onward transmission, opening, or use of thismessage and any attachments will not adversely affect its systems or data. No responsibility is accepted by the company in this regard and the recipient should carry out such virusand other checks as it considers appropriate. The information contained in this email message is confidential and may be legally privileged and is intended only for the use of the individual or entity named above. If you are notan intended recipient or if you have received this message in error, you are hereby notified that any dissemination, distribution, or copy of this email is strictly prohibited. If you havereceived this email in error, please immediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently delete thismessage. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that the onward transmission, opening, or use of thismessage and any attachments will not adversely affect its systems or data. No responsibility is accepted by the company in this regard and the recipient should carry out such virusand other checks as it considers appropriate. From:Davies, Stephen F (OGC) To:Casey Morse Cc:Dewhurst, Andrew D (OGC) Subject:RE: [EXTERNAL] AEO for Susan Dionne 8 Date:Tuesday, November 19, 2024 6:03:00 PM Attachments:image001.png image002.png Casey, Reviewing well records for Susan Dionne 1A (SD1A) and associated wells, I now understand that the Beluga 135 in SD1A was perforated in 1962 by a previous operator and that those perforations were left open until 2001, but were not actively produced other than the initial, limited-duration, 1962 flow test that produced water and a small, unmeasured amount of gas. It would speed my review if you could provide the requested names and API Numbers for other wells that have produced from the Beluga 135 zone (see previous email below). Also, I don’t recall seeing an estimate of the cumulative fluids that will be disposed over the anticipated 30-year life of the current development. Could Hilcorp please provide an estimated volume for the wastes to be injected, an estimate of the volume of Beluga 135 sand that will be affected, and the parameters used to calculate that volume (thickness, porosity, displacement type and efficiency percentage, affected radius, etc.)? Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Tuesday, November 19, 2024 12:41 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, Could you please help me sort something out for the requested Aquifer Exemption? In your most recent email, below, you state: “The Beluga 135 zone was open to flow in the SD-1A from 1962 until 2001. It produced gas and water from that formation.” But when I look at AOGCC’s production records, I see this: Well Identification Information for SD-1A (PTD 185-208)Associated Production Record for SD-1A Am I looking at the wrong well? If so, which well are you referring to? If not, could you please provide the perforation depths for the Beluga 135 sand and quantify the amount of gas and water produced? You also state: “There are other wells in the area with active gas production from the Beluga 135 zone.” Could you please provide the names and Permit to Drill or API Numbers for these three wells? CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. Thanks and Be Well, Steve Davies AOGCC From: Casey Morse <Casey.Morse@hilcorp.com> Sent: Monday, November 18, 2024 4:19 PM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov>; Donna Ambruz <dambruz@hilcorp.com> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Steve, The Beluga 135 zone was open to flow in the SD-1A from 1962 until 2001. It produced gas and water from that formation. Due to the high water production, Marathon set a liner and cemented across those perfs in 2001 to isolate that formation. There are other wells in the area with active gas production from the Beluga 135 zone. Those wells are >3,000 feet away laterally and >60 feet further up structure from the SD-1A and SD-8. Below is an overview of the procedure we followed on the SD-1A to gather a water sample that would be representative of the disposal interval: Pressured up the well with N2 and pushed fluid level down to 4,926’ Set a CIBP at 4,890’ to seal off the deeper perfs. Perforated the Beluga 135 interval from 3790-3810’. Initial pressures were ~1300 psi Reduced the surface pressure to allow for some inflow. Returned a couple days later with a slickline bailer. Fluid level was at 1950’. Ran in to 2050’ and pulled water sample into the bailer. Returned with 4.5 gallons of water. RIH a second time, fluid was at 1950’ again. Pulled a second sample from 2050’. Returned with 4.5 gallons of water in the bailer. Those 2 samples were analyzed for the purpose of this aquifer exemption request. We followed the procedure above to minimize the chance of any fluid contamination. The sample we received should be representative of the formation fluids. Given that this formation is gas-bearing, the contaminants in this water align with our expectations. We do not have any other isolated Beluga 135 water samples. We reviewed the Kenai Peninsula Borough Comprehensive Plan as well as information regarding public water systems in nearby communities. No publicly available information raised concerns with available water supply from the surface or shallow sources currently utilized in the area. We estimated a capital cost greater than $4 million and ongoing annual operating costs of $138,000 to develop and operate a water supply well in the Beluga 135. This does not include costs for treating the water quality. We concluded that this was not a commercially viable water source given the relative value of property in the area and the availability of other water supplies that are significantly less costly. We did not consider economic or population growth forecasts in our evaluation of the commercial viability for drilling a water supply well into this formation. Regards, Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Monday, November 18, 2024 11:35 AM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Hi Casey, To keep this moving through the AOGCC approval process, I’d like to let you know that I’ll be out of the office beginning Thursday at 11:30 AM and continuing until December 2nd. Any help additional information regarding my questions below will be most helpful. Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Friday, November 15, 2024 5:46 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, For simplicity, I’ve combined into a single list several additional questions from the EPA that require extra information beyond that provided in Hilcorp’s Aquifer Exemption application for Susan Dionne 8. What method did Hilcorp use to gather water samples from the Beluga 135 sand in well Susan Dionne 1A? Was there possibility of sample contamination by drilling fluid or other oilfield fluids during this process, or prior to collection? Was the wellbore flushed? Does Hilcorp have any information or explanation concerning the source of contaminants in the Beluga 135 aquifer? Please provide the information or an explanation. Are contaminant levels in the Beluga 135 consistent across the aquifer? Are water quality samples available from wells other than the Susan Dionne 1A? Have state or federal government-provided census data been used to evaluate population/economic forecasts for this area? Any additional information that Hilcorp can provide will be appreciated. Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Friday, November 15, 2024 5:30 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, In addition to the questions listed below, the EPA is also inquiring about the source of contaminants in the Beluga 135 aquifer. Does Hilcorp have any information or explanation concerning the source of these contaminants? Again, any information that Hilcorp can supply will be very helpful. Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Thursday, November 14, 2024 3:00 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, EPA has a few questions with regard to their checklist that I filled out and submitted for Susan Dionne 8. They are: What method did Hilcorp use to gather water samples from the Beluga 135 sand in well Susan Dionne 1A? Was there possibility of sample contamination by drilling fluid or other oilfield fluids during this process, or prior to collection? Was the wellbore flushed? Any additional information you can provide will be appreciated. Thanks and Be Well, Steve Davies AOGCC From: Casey Morse <casey.morse@hilcorp.com> Sent: Friday, September 6, 2024 10:14 AM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Steve, The average volumes we pumped into NNA-1 for the past year were approximately 300 bpd. The average porosity for the disposal interval in the SD-8 well is estimated at 25%. The disposal interval is 45 ft thick, and we will likely perforate across most (or all) of that interval. Here are the assumptions I used to calculate a radius of impact: 20-year project life with 300 bpd average daily rate Disposal zone height of 45 ft Average porosity of disposal zone is 25% Injected fluids remain vertically confined within the disposal zone Injection is proportionally distributed amongst the perforations There is piston-like displacement of native reservoir fluids Based on these assumptions, the impacted radius would be 590 ft. Thank you, CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Wednesday, August 28, 2024 12:44 PM To: Casey Morse <casey.morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: [EXTERNAL] AEO for Susan Dionne 8 Casey, I’m working on the Aquifer Exemption Order for the Susan Dionne 8 well. We’re making good progress, but I have a few questions for you. As I recall from the companion Disposal Injection Order NO. 47, this well will be used as a back up for the NNA 1 primary disposal well. If so, could Hilcorp please provide estimates for the volume of fluids expected to be disposed in Susan Dionne 8 over the life of the project in this backup capacity? Should NNA 1 fail and Susan Dionne 8 be used as the primary disposal well, could Hilcorp please provide estimates of the daily disposal volumes, the total estimated volume, and the radius of the affected area surrounding the well? Please provide the parameters used to calculate these volumes (thickness, average porosity, native-fluid displacement effectiveness, expected affected radius, etc.). Thanks and Be Well, Steve Davies AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov The information contained in this email message is confidential and may be legally privileged and is intended only for the use of the individual or entity named above. If you are notan intended recipient or if you have received this message in error, you are hereby notified that any dissemination, distribution, or copy of this email is strictly prohibited. If you havereceived this email in error, please immediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently delete thismessage. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that the onward transmission, opening, or use of thismessage and any attachments will not adversely affect its systems or data. No responsibility is accepted by the company in this regard and the recipient should carry out such virusand other checks as it considers appropriate. The information contained in this email message is confidential and may be legally privileged and is intended only for the use of the individual or entity named above. If you are notan intended recipient or if you have received this message in error, you are hereby notified that any dissemination, distribution, or copy of this email is strictly prohibited. If you havereceived this email in error, please immediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently delete thismessage. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that the onward transmission, opening, or use of thismessage and any attachments will not adversely affect its systems or data. No responsibility is accepted by the company in this regard and the recipient should carry out such virusand other checks as it considers appropriate. The information contained in this email message is confidential and may be legally privileged and is intended only for the use of the individual or entity named above. If you are notan intended recipient or if you have received this message in error, you are hereby notified that any dissemination, distribution, or copy of this email is strictly prohibited. If you havereceived this email in error, please immediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently delete thismessage. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that the onward transmission, opening, or use of thismessage and any attachments will not adversely affect its systems or data. No responsibility is accepted by the company in this regard and the recipient should carry out such virusand other checks as it considers appropriate. CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. From:Casey Morse To:Davies, Stephen F (OGC) Cc:Dewhurst, Andrew D (OGC); Donna Ambruz Subject:RE: [EXTERNAL] AEO for Susan Dionne 8 Date:Wednesday, November 20, 2024 11:54:06 AM Attachments:image001.png image002.png Steve, We currently have ongoing production from the Beluga 135 in these 3 offset wells: Kalotsa 2 (API 5013320659) Kalotsa 3 (API 5013320661) Paxton 10 (API 5013320691) And historical production from these offset wells: Susan Dionne 5 (API 5013320562) Susan Dionne 6 (API 5013320582) The response in the email chain below from September 6 should address your other questions regarding volumes and the radius of impact. Thanks, Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Tuesday, November 19, 2024 6:04 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, Reviewing well records for Susan Dionne 1A (SD1A) and associated wells, I now understand that the Beluga 135 in SD1A was perforated in 1962 by a previous operator and that those perforations were left open until 2001, but were not actively produced other than the initial, limited-duration, 1962 flow test that produced water and a small, unmeasured amount of gas. It would speed my review if you could provide the requested names and API Numbers for other wells that have produced from the Beluga 135 zone (see previous email below). Also, I don’t recall seeing an estimate of the cumulative fluids that will be disposed over the anticipated 30-year life of the current development. Could Hilcorp please provide an estimated volume for the wastes to be injected, an estimate of the volume of Beluga 135 sand that will be affected, and the parameters used to calculate that volume (thickness, porosity, displacement type and efficiency percentage, affected radius, etc.)? Thanks and Be Well, Steve Davies AOGCC CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. From: Davies, Stephen F (OGC) Sent: Tuesday, November 19, 2024 12:41 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, Could you please help me sort something out for the requested Aquifer Exemption? In your most recent email, below, you state: “The Beluga 135 zone was open to flow in the SD-1A from 1962 until 2001. It produced gas and water from that formation.” But when I look at AOGCC’s production records, I see this: Well Identification Information for SD-1A (PTD 185-208)Associated Production Record for SD-1A Am I looking at the wrong well? If so, which well are you referring to? If not, could you please provide the perforation depths for the Beluga 135 sand and quantify the amount of gas and water produced? You also state: “There are other wells in the area with active gas production from the Beluga 135 zone.” Could you please provide the names and Permit to Drill or API Numbers for these three wells? Thanks and Be Well, Steve Davies AOGCC From: Casey Morse <Casey.Morse@hilcorp.com> Sent: Monday, November 18, 2024 4:19 PM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov>; Donna Ambruz <dambruz@hilcorp.com> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Steve, The Beluga 135 zone was open to flow in the SD-1A from 1962 until 2001. It produced gas and water from that formation. Due to the high water production, Marathon set a liner and cemented across those perfs in 2001 to isolate that formation. There are other wells in the area with active gas production from the Beluga 135 zone. Those wells are >3,000 feet away laterally and >60 feet further up structure from the SD-1A and SD-8. Below is an overview of the procedure we followed on the SD-1A to gather a water sample that would be representative of the disposal interval: CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. Pressured up the well with N2 and pushed fluid level down to 4,926’ Set a CIBP at 4,890’ to seal off the deeper perfs. Perforated the Beluga 135 interval from 3790-3810’. Initial pressures were ~1300 psi Reduced the surface pressure to allow for some inflow. Returned a couple days later with a slickline bailer. Fluid level was at 1950’. Ran in to 2050’ and pulled water sample into the bailer. Returned with 4.5 gallons of water. RIH a second time, fluid was at 1950’ again. Pulled a second sample from 2050’. Returned with 4.5 gallons of water in the bailer. Those 2 samples were analyzed for the purpose of this aquifer exemption request. We followed the procedure above to minimize the chance of any fluid contamination. The sample we received should be representative of the formation fluids. Given that this formation is gas-bearing, the contaminants in this water align with our expectations. We do not have any other isolated Beluga 135 water samples. We reviewed the Kenai Peninsula Borough Comprehensive Plan as well as information regarding public water systems in nearby communities. No publicly available information raised concerns with available water supply from the surface or shallow sources currently utilized in the area. We estimated a capital cost greater than $4 million and ongoing annual operating costs of $138,000 to develop and operate a water supply well in the Beluga 135. This does not include costs for treating the water quality. We concluded that this was not a commercially viable water source given the relative value of property in the area and the availability of other water supplies that are significantly less costly. We did not consider economic or population growth forecasts in our evaluation of the commercial viability for drilling a water supply well into this formation. Regards, Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Monday, November 18, 2024 11:35 AM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Hi Casey, To keep this moving through the AOGCC approval process, I’d like to let you know that I’ll be out of the office beginning Thursday at 11:30 AM and continuing until December 2nd. Any help additional information regarding my questions below will be most helpful. Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Friday, November 15, 2024 5:46 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, For simplicity, I’ve combined into a single list several additional questions from the EPA that require extra information beyond that provided in Hilcorp’s Aquifer Exemption application for Susan Dionne 8. What method did Hilcorp use to gather water samples from the Beluga 135 sand in well Susan Dionne 1A? Was there possibility of sample contamination by drilling fluid or other oilfield fluids during this process, or prior to collection? Was the wellbore flushed? Does Hilcorp have any information or explanation concerning the source of contaminants in the Beluga 135 aquifer? Please provide the information or an explanation. Are contaminant levels in the Beluga 135 consistent across the aquifer? Are water quality samples available from wells other than the Susan Dionne 1A? Have state or federal government-provided census data been used to evaluate population/economic forecasts for this area? Any additional information that Hilcorp can provide will be appreciated. Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Friday, November 15, 2024 5:30 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, In addition to the questions listed below, the EPA is also inquiring about the source of contaminants in the Beluga 135 aquifer. Does Hilcorp have any information or explanation concerning the source of these contaminants? Again, any information that Hilcorp can supply will be very helpful. Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Thursday, November 14, 2024 3:00 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, EPA has a few questions with regard to their checklist that I filled out and submitted for Susan Dionne 8. They are: What method did Hilcorp use to gather water samples from the Beluga 135 sand in well Susan Dionne 1A? Was there possibility of sample contamination by drilling fluid or other oilfield fluids during this process, or prior to collection? CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. Was the wellbore flushed? Any additional information you can provide will be appreciated. Thanks and Be Well, Steve Davies AOGCC From: Casey Morse <casey.morse@hilcorp.com> Sent: Friday, September 6, 2024 10:14 AM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Steve, The average volumes we pumped into NNA-1 for the past year were approximately 300 bpd. The average porosity for the disposal interval in the SD-8 well is estimated at 25%. The disposal interval is 45 ft thick, and we will likely perforate across most (or all) of that interval. Here are the assumptions I used to calculate a radius of impact: 20-year project life with 300 bpd average daily rate Disposal zone height of 45 ft Average porosity of disposal zone is 25% Injected fluids remain vertically confined within the disposal zone Injection is proportionally distributed amongst the perforations There is piston-like displacement of native reservoir fluids Based on these assumptions, the impacted radius would be 590 ft. Thank you, Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Wednesday, August 28, 2024 12:44 PM To: Casey Morse <casey.morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: [EXTERNAL] AEO for Susan Dionne 8 Casey, I’m working on the Aquifer Exemption Order for the Susan Dionne 8 well. We’re making good progress, but I have a few questions for you. As I recall from the companion Disposal Injection Order NO. 47, this well will be used as a back up for the NNA 1 primary disposal well. If so, could Hilcorp please provide estimates for the volume of fluids expected to be disposed in Susan Dionne 8 over the life of the project in this backup capacity? Should NNA 1 fail and Susan Dionne 8 be used as the primary disposal well, could Hilcorp please provide estimates of the daily disposal volumes, the total estimated volume, and the radius of the affected area surrounding the well? Please provide the parameters used to calculate these volumes (thickness, average porosity, native-fluid displacement effectiveness, expected affected radius, etc.). Thanks and Be Well, Steve Davies AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov The information contained in this email message is confidential and may be legally privileged and is intended only for the use of the individual or entity named above. If you are notan intended recipient or if you have received this message in error, you are hereby notified that any dissemination, distribution, or copy of this email is strictly prohibited. If you havereceived this email in error, please immediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently delete thismessage. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that the onward transmission, opening, or use of thismessage and any attachments will not adversely affect its systems or data. No responsibility is accepted by the company in this regard and the recipient should carry out such virusand other checks as it considers appropriate. The information contained in this email message is confidential and may be legally privileged and is intended only for the use of the individual or entity named above. If you are notan intended recipient or if you have received this message in error, you are hereby notified that any dissemination, distribution, or copy of this email is strictly prohibited. If you havereceived this email in error, please immediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently delete thismessage. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that the onward transmission, opening, or use of thismessage and any attachments will not adversely affect its systems or data. No responsibility is accepted by the company in this regard and the recipient should carry out such virusand other checks as it considers appropriate. The information contained in this email message is confidential and may be legally privileged and is intended only for the use of the individual or entity named above. If you are notan intended recipient or if you have received this message in error, you are hereby notified that any dissemination, distribution, or copy of this email is strictly prohibited. If you havereceived this email in error, please immediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently delete thismessage. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that the onward transmission, opening, or use of thismessage and any attachments will not adversely affect its systems or data. No responsibility is accepted by the company in this regard and the recipient should carry out such virusand other checks as it considers appropriate. The information contained in this email message is confidential and may be legally privileged and is intended only for the use of the individual or entity named above. If you are notan intended recipient or if you have received this message in error, you are hereby notified that any dissemination, distribution, or copy of this email is strictly prohibited. If you havereceived this email in error, please immediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently delete thismessage. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that the onward transmission, opening, or use of thismessage and any attachments will not adversely affect its systems or data. No responsibility is accepted by the company in this regard and the recipient should carry out such virusand other checks as it considers appropriate. CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. From:Casey Morse To:Davies, Stephen F (OGC) Cc:Dewhurst, Andrew D (OGC); Donna Ambruz Subject:RE: [EXTERNAL] AEO for Susan Dionne 8 Date:Wednesday, November 20, 2024 11:54:06 AM Attachments:image001.png image002.png Steve, We currently have ongoing production from the Beluga 135 in these 3 offset wells: Kalotsa 2 (API 5013320659) Kalotsa 3 (API 5013320661) Paxton 10 (API 5013320691) And historical production from these offset wells: Susan Dionne 5 (API 5013320562) Susan Dionne 6 (API 5013320582) The response in the email chain below from September 6 should address your other questions regarding volumes and the radius of impact. Thanks, Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Tuesday, November 19, 2024 6:04 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, Reviewing well records for Susan Dionne 1A (SD1A) and associated wells, I now understand that the Beluga 135 in SD1A was perforated in 1962 by a previous operator and that those perforations were left open until 2001, but were not actively produced other than the initial, limited-duration, 1962 flow test that produced water and a small, unmeasured amount of gas. It would speed my review if you could provide the requested names and API Numbers for other wells that have produced from the Beluga 135 zone (see previous email below). Also, I don’t recall seeing an estimate of the cumulative fluids that will be disposed over the anticipated 30-year life of the current development. Could Hilcorp please provide an estimated volume for the wastes to be injected, an estimate of the volume of Beluga 135 sand that will be affected, and the parameters used to calculate that volume (thickness, porosity, displacement type and efficiency percentage, affected radius, etc.)? Thanks and Be Well, Steve Davies AOGCC CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. From: Davies, Stephen F (OGC) Sent: Tuesday, November 19, 2024 12:41 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, Could you please help me sort something out for the requested Aquifer Exemption? In your most recent email, below, you state: “The Beluga 135 zone was open to flow in the SD-1A from 1962 until 2001. It produced gas and water from that formation.” But when I look at AOGCC’s production records, I see this: Well Identification Information for SD-1A (PTD 185-208)Associated Production Record for SD-1A Am I looking at the wrong well? If so, which well are you referring to? If not, could you please provide the perforation depths for the Beluga 135 sand and quantify the amount of gas and water produced? You also state: “There are other wells in the area with active gas production from the Beluga 135 zone.” Could you please provide the names and Permit to Drill or API Numbers for these three wells? Thanks and Be Well, Steve Davies AOGCC From: Casey Morse <Casey.Morse@hilcorp.com> Sent: Monday, November 18, 2024 4:19 PM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov>; Donna Ambruz <dambruz@hilcorp.com> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Steve, The Beluga 135 zone was open to flow in the SD-1A from 1962 until 2001. It produced gas and water from that formation. Due to the high water production, Marathon set a liner and cemented across those perfs in 2001 to isolate that formation. There are other wells in the area with active gas production from the Beluga 135 zone. Those wells are >3,000 feet away laterally and >60 feet further up structure from the SD-1A and SD-8. Below is an overview of the procedure we followed on the SD-1A to gather a water sample that would be representative of the disposal interval: CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. Pressured up the well with N2 and pushed fluid level down to 4,926’ Set a CIBP at 4,890’ to seal off the deeper perfs. Perforated the Beluga 135 interval from 3790-3810’. Initial pressures were ~1300 psi Reduced the surface pressure to allow for some inflow. Returned a couple days later with a slickline bailer. Fluid level was at 1950’. Ran in to 2050’ and pulled water sample into the bailer. Returned with 4.5 gallons of water. RIH a second time, fluid was at 1950’ again. Pulled a second sample from 2050’. Returned with 4.5 gallons of water in the bailer. Those 2 samples were analyzed for the purpose of this aquifer exemption request. We followed the procedure above to minimize the chance of any fluid contamination. The sample we received should be representative of the formation fluids. Given that this formation is gas-bearing, the contaminants in this water align with our expectations. We do not have any other isolated Beluga 135 water samples. We reviewed the Kenai Peninsula Borough Comprehensive Plan as well as information regarding public water systems in nearby communities. No publicly available information raised concerns with available water supply from the surface or shallow sources currently utilized in the area. We estimated a capital cost greater than $4 million and ongoing annual operating costs of $138,000 to develop and operate a water supply well in the Beluga 135. This does not include costs for treating the water quality. We concluded that this was not a commercially viable water source given the relative value of property in the area and the availability of other water supplies that are significantly less costly. We did not consider economic or population growth forecasts in our evaluation of the commercial viability for drilling a water supply well into this formation. Regards, Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Monday, November 18, 2024 11:35 AM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Hi Casey, To keep this moving through the AOGCC approval process, I’d like to let you know that I’ll be out of the office beginning Thursday at 11:30 AM and continuing until December 2nd. Any help additional information regarding my questions below will be most helpful. Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Friday, November 15, 2024 5:46 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, For simplicity, I’ve combined into a single list several additional questions from the EPA that require extra information beyond that provided in Hilcorp’s Aquifer Exemption application for Susan Dionne 8. What method did Hilcorp use to gather water samples from the Beluga 135 sand in well Susan Dionne 1A? Was there possibility of sample contamination by drilling fluid or other oilfield fluids during this process, or prior to collection? Was the wellbore flushed? Does Hilcorp have any information or explanation concerning the source of contaminants in the Beluga 135 aquifer? Please provide the information or an explanation. Are contaminant levels in the Beluga 135 consistent across the aquifer? Are water quality samples available from wells other than the Susan Dionne 1A? Have state or federal government-provided census data been used to evaluate population/economic forecasts for this area? Any additional information that Hilcorp can provide will be appreciated. Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Friday, November 15, 2024 5:30 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, In addition to the questions listed below, the EPA is also inquiring about the source of contaminants in the Beluga 135 aquifer. Does Hilcorp have any information or explanation concerning the source of these contaminants? Again, any information that Hilcorp can supply will be very helpful. Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Thursday, November 14, 2024 3:00 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, EPA has a few questions with regard to their checklist that I filled out and submitted for Susan Dionne 8. They are: What method did Hilcorp use to gather water samples from the Beluga 135 sand in well Susan Dionne 1A? Was there possibility of sample contamination by drilling fluid or other oilfield fluids during this process, or prior to CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. collection? Was the wellbore flushed? Any additional information you can provide will be appreciated. Thanks and Be Well, Steve Davies AOGCC From: Casey Morse <casey.morse@hilcorp.com> Sent: Friday, September 6, 2024 10:14 AM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Steve, The average volumes we pumped into NNA-1 for the past year were approximately 300 bpd. The average porosity for the disposal interval in the SD-8 well is estimated at 25%. The disposal interval is 45 ft thick, and we will likely perforate across most (or all) of that interval. Here are the assumptions I used to calculate a radius of impact: 20-year project life with 300 bpd average daily rate Disposal zone height of 45 ft Average porosity of disposal zone is 25% Injected fluids remain vertically confined within the disposal zone Injection is proportionally distributed amongst the perforations There is piston-like displacement of native reservoir fluids Based on these assumptions, the impacted radius would be 590 ft. Thank you, Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Wednesday, August 28, 2024 12:44 PM To: Casey Morse <casey.morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: [EXTERNAL] AEO for Susan Dionne 8 Casey, I’m working on the Aquifer Exemption Order for the Susan Dionne 8 well. We’re making good progress, but I have a few questions for you. As I recall from the companion Disposal Injection Order NO. 47, this well will be used as a back up for the NNA 1 primary disposal well. If so, could Hilcorp please provide estimates for the volume of fluids expected to be disposed in Susan Dionne 8 over the life of the project in this backup capacity? Should NNA 1 fail and Susan Dionne 8 be used as the primary disposal well, could Hilcorp please provide estimates of the daily disposal volumes, the total estimated volume, and the radius of the affected area surrounding the well? Please provide the parameters used to calculate these volumes (thickness, average porosity, native-fluid displacement effectiveness, expected affected radius, etc.). Thanks and Be Well, Steve Davies AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov The information contained in this email message is confidential and may be legally privileged and is intended only for the use of the individual or entity named above. If you are notan intended recipient or if you have received this message in error, you are hereby notified that any dissemination, distribution, or copy of this email is strictly prohibited. If you havereceived this email in error, please immediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently delete thismessage. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that the onward transmission, opening, or use of thismessage and any attachments will not adversely affect its systems or data. No responsibility is accepted by the company in this regard and the recipient should carry out such virusand other checks as it considers appropriate. The information contained in this email message is confidential and may be legally privileged and is intended only for the use of the individual or entity named above. If you are notan intended recipient or if you have received this message in error, you are hereby notified that any dissemination, distribution, or copy of this email is strictly prohibited. If you havereceived this email in error, please immediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently delete thismessage. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that the onward transmission, opening, or use of thismessage and any attachments will not adversely affect its systems or data. No responsibility is accepted by the company in this regard and the recipient should carry out such virusand other checks as it considers appropriate. The information contained in this email message is confidential and may be legally privileged and is intended only for the use of the individual or entity named above. If you are notan intended recipient or if you have received this message in error, you are hereby notified that any dissemination, distribution, or copy of this email is strictly prohibited. If you havereceived this email in error, please immediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently delete thismessage. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that the onward transmission, opening, or use of thismessage and any attachments will not adversely affect its systems or data. No responsibility is accepted by the company in this regard and the recipient should carry out such virusand other checks as it considers appropriate. The information contained in this email message is confidential and may be legally privileged and is intended only for the use of the individual or entity named above. If you are notan intended recipient or if you have received this message in error, you are hereby notified that any dissemination, distribution, or copy of this email is strictly prohibited. If you havereceived this email in error, please immediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently delete thismessage. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that the onward transmission, opening, or use of thismessage and any attachments will not adversely affect its systems or data. No responsibility is accepted by the company in this regard and the recipient should carry out such virusand other checks as it considers appropriate. CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. From:Davies, Stephen F (OGC) To:Casey Morse Cc:Dewhurst, Andrew D (OGC); Donna Ambruz Subject:RE: [EXTERNAL] AEO for Susan Dionne 8 Date:Wednesday, November 20, 2024 11:58:00 AM Attachments:image001.png image002.png Thanks Casey, Apologies, I overlooked your September 6th email. Thanks Again for Your Help, Steve Davies AOGCC From: Casey Morse <Casey.Morse@hilcorp.com> Sent: Wednesday, November 20, 2024 11:54 AM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Cc: Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov>; Donna Ambruz <dambruz@hilcorp.com> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Steve, We currently have ongoing production from the Beluga 135 in these 3 offset wells: Kalotsa 2 (API 5013320659) Kalotsa 3 (API 5013320661) Paxton 10 (API 5013320691) And historical production from these offset wells: Susan Dionne 5 (API 5013320562) Susan Dionne 6 (API 5013320582) The response in the email chain below from September 6 should address your other questions regarding volumes and the radius of impact. Thanks, Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Tuesday, November 19, 2024 6:04 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, Reviewing well records for Susan Dionne 1A (SD1A) and associated wells, I now understand that the Beluga 135 in SD1A was perforated in 1962 by a previous operator and that those perforations were left open until 2001, but were not actively produced other than the initial, limited-duration, 1962 flow test that produced water and a small, unmeasured amount of gas. It would speed my review if you could provide the requested names and API Numbers for other wells that have produced from the Beluga 135 zone (see previous email below). Also, I don’t recall seeing an estimate of the cumulative fluids that will be disposed over the anticipated 30-year life of the current development. Could Hilcorp please provide an estimated volume for the wastes to be injected, an estimate of the volume of Beluga 135 sand that will be affected, and the parameters used to calculate that volume (thickness, porosity, displacement type and efficiency percentage, affected radius, etc.)? Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Tuesday, November 19, 2024 12:41 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, Could you please help me sort something out for the requested Aquifer Exemption? In your most recent email, below, you state: “The Beluga 135 zone was open to flow in the SD-1A from 1962 until 2001. It produced gas and water from that formation.” But when I look at AOGCC’s production records, I see this: Well Identification Information for SD-1A (PTD 185-208)Associated Production Record for SD-1A Am I looking at the wrong well? If so, which well are you referring to? If not, could you please provide the perforation depths for the Beluga 135 sand and quantify the amount of gas and water produced? You also state: “There are other wells in the area with active gas production from the Beluga 135 zone.” Could you please provide the names and Permit to Drill or API Numbers for these three wells? Thanks and Be Well, Steve Davies AOGCC From: Casey Morse <Casey.Morse@hilcorp.com> Sent: Monday, November 18, 2024 4:19 PM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov>; Donna Ambruz <dambruz@hilcorp.com> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. Steve, The Beluga 135 zone was open to flow in the SD-1A from 1962 until 2001. It produced gas and water from that formation. Due to the high water production, Marathon set a liner and cemented across those perfs in 2001 to isolate that formation. There are other wells in the area with active gas production from the Beluga 135 zone. Those wells are >3,000 feet away laterally and >60 feet further up structure from the SD-1A and SD-8. Below is an overview of the procedure we followed on the SD-1A to gather a water sample that would be representative of the disposal interval: Pressured up the well with N2 and pushed fluid level down to 4,926’ Set a CIBP at 4,890’ to seal off the deeper perfs. Perforated the Beluga 135 interval from 3790-3810’. Initial pressures were ~1300 psi Reduced the surface pressure to allow for some inflow. Returned a couple days later with a slickline bailer. Fluid level was at 1950’. Ran in to 2050’ and pulled water sample into the bailer. Returned with 4.5 gallons of water. RIH a second time, fluid was at 1950’ again. Pulled a second sample from 2050’. Returned with 4.5 gallons of water in the bailer. Those 2 samples were analyzed for the purpose of this aquifer exemption request. We followed the procedure above to minimize the chance of any fluid contamination. The sample we received should be representative of the formation fluids. Given that this formation is gas-bearing, the contaminants in this water align with our expectations. We do not have any other isolated Beluga 135 water samples. We reviewed the Kenai Peninsula Borough Comprehensive Plan as well as information regarding public water systems in nearby communities. No publicly available information raised concerns with available water supply from the surface or shallow sources currently utilized in the area. We estimated a capital cost greater than $4 million and ongoing annual operating costs of $138,000 to develop and operate a water supply well in the Beluga 135. This does not include costs for treating the water quality. We concluded that this was not a commercially viable water source given the relative value of property in the area and the availability of other water supplies that are significantly less costly. We did not consider economic or population growth forecasts in our evaluation of the commercial viability for drilling a water supply well into this formation. Regards, Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Monday, November 18, 2024 11:35 AM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Hi Casey, To keep this moving through the AOGCC approval process, I’d like to let you know that I’ll be out of the office beginning Thursday at 11:30 AM and continuing until December 2nd. Any help additional information regarding my questions below will be most helpful. Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Friday, November 15, 2024 5:46 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, For simplicity, I’ve combined into a single list several additional questions from the EPA that require extra information beyond that provided in Hilcorp’s Aquifer Exemption application for Susan Dionne 8. What method did Hilcorp use to gather water samples from the Beluga 135 sand in well Susan Dionne 1A? Was there possibility of sample contamination by drilling fluid or other oilfield fluids during this process, or prior to collection? Was the wellbore flushed? Does Hilcorp have any information or explanation concerning the source of contaminants in the Beluga 135 aquifer? Please provide the information or an explanation. Are contaminant levels in the Beluga 135 consistent across the aquifer? Are water quality samples available from wells other than the Susan Dionne 1A? Have state or federal government-provided census data been used to evaluate population/economic forecasts for this area? Any additional information that Hilcorp can provide will be appreciated. Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Friday, November 15, 2024 5:30 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, In addition to the questions listed below, the EPA is also inquiring about the source of contaminants in the Beluga 135 aquifer. Does Hilcorp have any information or explanation concerning the source of these contaminants? Again, any information that Hilcorp can supply will be very helpful. Thanks and Be Well, Steve Davies AOGCC From: Davies, Stephen F (OGC) Sent: Thursday, November 14, 2024 3:00 PM To: Casey Morse <Casey.Morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Casey, EPA has a few questions with regard to their checklist that I filled out and submitted for Susan Dionne 8. They are: What method did Hilcorp use to gather water samples from the Beluga 135 sand in well Susan Dionne 1A? Was there possibility of sample contamination by drilling fluid or other oilfield fluids during this process, or prior to collection? Was the wellbore flushed? Any additional information you can provide will be appreciated. Thanks and Be Well, Steve Davies AOGCC From: Casey Morse <casey.morse@hilcorp.com> Sent: Friday, September 6, 2024 10:14 AM To: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: RE: [EXTERNAL] AEO for Susan Dionne 8 Steve, The average volumes we pumped into NNA-1 for the past year were approximately 300 bpd. The average porosity for the disposal interval in the SD-8 well is estimated at 25%. The disposal interval is 45 ft thick, and we will likely perforate across most (or all) of that interval. Here are the assumptions I used to calculate a radius of impact: 20-year project life with 300 bpd average daily rate Disposal zone height of 45 ft Average porosity of disposal zone is 25% Injected fluids remain vertically confined within the disposal zone Injection is proportionally distributed amongst the perforations There is piston-like displacement of native reservoir fluids Based on these assumptions, the impacted radius would be 590 ft. Thank you, Casey Morse Well Integrity Engineer Hilcorp Alaska, LLC (907) 777-8322 From: Davies, Stephen F (OGC) <steve.davies@alaska.gov> Sent: Wednesday, August 28, 2024 12:44 PM To: Casey Morse <casey.morse@hilcorp.com> Cc: Wallace, Chris D (OGC) <chris.wallace@alaska.gov>; Dewhurst, Andrew D (OGC) <andrew.dewhurst@alaska.gov> Subject: [EXTERNAL] AEO for Susan Dionne 8 CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. Casey, I’m working on the Aquifer Exemption Order for the Susan Dionne 8 well. We’re making good progress, but I have a few questions for you. As I recall from the companion Disposal Injection Order NO. 47, this well will be used as a back up for the NNA 1 primary disposal well. If so, could Hilcorp please provide estimates for the volume of fluids expected to be disposed in Susan Dionne 8 over the life of the project in this backup capacity? Should NNA 1 fail and Susan Dionne 8 be used as the primary disposal well, could Hilcorp please provide estimates of the daily disposal volumes, the total estimated volume, and the radius of the affected area surrounding the well? Please provide the parameters used to calculate these volumes (thickness, average porosity, native-fluid displacement effectiveness, expected affected radius, etc.). Thanks and Be Well, Steve Davies AOGCC 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 Steve Davies at 907-793-1224 or steve.davies@alaska.gov The information contained in this email message is confidential and may be legally privileged and is intended only for the use of the individual or entity named above. If you are notan intended recipient or if you have received this message in error, you are hereby notified that any dissemination, distribution, or copy of this email is strictly prohibited. If you havereceived this email in error, please immediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently delete thismessage. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that the onward transmission, opening, or use of thismessage and any attachments will not adversely affect its systems or data. No responsibility is accepted by the company in this regard and the recipient should carry out such virusand other checks as it considers appropriate. The information contained in this email message is confidential and may be legally privileged and is intended only for the use of the individual or entity named above. If you are notan intended recipient or if you have received this message in error, you are hereby notified that any dissemination, distribution, or copy of this email is strictly prohibited. If you havereceived this email in error, please immediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently delete thismessage. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that the onward transmission, opening, or use of thismessage and any attachments will not adversely affect its systems or data. No responsibility is accepted by the company in this regard and the recipient should carry out such virusand other checks as it considers appropriate. The information contained in this email message is confidential and may be legally privileged and is intended only for the use of the individual or entity named above. If you are notan intended recipient or if you have received this message in error, you are hereby notified that any dissemination, distribution, or copy of this email is strictly prohibited. If you havereceived this email in error, please immediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently delete thismessage. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that the onward transmission, opening, or use of thismessage and any attachments will not adversely affect its systems or data. No responsibility is accepted by the company in this regard and the recipient should carry out such virusand other checks as it considers appropriate. The information contained in this email message is confidential and may be legally privileged and is intended only for the use of the individual or entity named above. If you are notan intended recipient or if you have received this message in error, you are hereby notified that any dissemination, distribution, or copy of this email is strictly prohibited. If you havereceived this email in error, please immediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently delete thismessage. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that the onward transmission, opening, or use of thismessage and any attachments will not adversely affect its systems or data. No responsibility is accepted by the company in this regard and the recipient should carry out such virusand other checks as it considers appropriate. 2 Notice of Public Hearing STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION RE: Docket Number: AEO-24-001 Hilcorp Alaska, LLC Aquifer Exemption Application for Well Susan Dionne 8, Ninilchik Unit, Kenai Peninsula, Alaska Hilcorp Alaska, LLC (Hilcorp), by application dated May 15, 2024, requests the Alaska Oil and Gas Conservation Commission (AOGCC) issue an order for aquifer exemption for an area extending one-quarter mile beyond the proposed injection zone in well Susan Dionne 8 within Sections 6 and 7 of Township 1 South, Range 13 West, Seward Meridian that lies within the boundaries of the Ninilchik Unit. An aquifer is an underground body of water-saturated rock or sediments that can store and/or transmit water. Regulations allow the United States Environmental Protection Agency (EPA) and the State of Alaska to exempt an aquifer or a portion of an aquifer if it does not currently serve as a source of drinking water, if it will not serve as a source of drinking water in the future, or if it meets other criteria such as the natural presence of hydrocarbons, existing contamination, or elevated dissolved solids concentration. An order granting an exemption allows an underground aquifer or a specified portion of an aquifer to be used for oil- or gas-related production, injection, or disposal purposes in compliance with EPA’s requirements under the Safe Drinking Water Act and State of Alaska regulations. This notice does not contain all the information filed by Hilcorp. To obtain more information, contact the AOGCC’s Special Assistant, Samantha Coldiron, at (907) 793-1223 or samantha.coldiron@alaska.gov. A public hearing on the matter has been tentatively scheduled for July 16, 2024, at 10:00 a.m. The hearing, which may be changed to full virtual, if necessary, will be held in the AOGCC hearing room located at 333 West 7th Avenue, Anchorage, AK 99501. The audio call in information is (907) 202 7104 Conference ID: 977 858 930#. Anyone who wishes to participate remotely using MS Teams video conference should contact Ms. Coldiron at least two business days before the scheduled public hearing to request an invitation for the MS Teams. To request that the tentatively scheduled hearing be held, a written request must be filed with the AOGCC no later than 4:30 p.m. on June 17, 2024. If a request for a hearing is not timely filed, the AOGCC may issue an order without a hearing. To learn if the AOGCC will hold the hearing, call (907) 793-1223 after June 18, 2024. In addition, written comments regarding this application may be submitted to the AOGCC, at 333 west 7th Avenue, Anchorage, AK 99501 or samantha.coldiron@alaska.gov. Comments must be received no later than 4:30 p.m. on July 3, 2024, except that, if a hearing is held, comments must be received no later than the conclusion of the July 16, 2024, hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, contact Samantha Coldiron, at (907) 793-1223, no later than July 9, 2024. Brett W. Huber, Sr. Chair, Commissioner Brett W. Huber, Sr. Digitally signed by Brett W. Huber, Sr. Date: 2024.05.30 09:13:22 -08'00' Lisi Misa being first duly sworn on oath deposes and says that she is a representative of the An- chorage Daily News, a daily newspaper. That said newspaper has been approved by the Third Judicial Court, Anchorage, Alaska, and it now and has been published in the English language continually as a daily newspaper in Anchorage, Alaska, and it is now and during all said time was printed in an office maintained at the afore- said place of publication of said newspaper. That the annexed is a copy of an advertisement as it was published in regular issues (and not in supplemental form) of said newspaper on AFFIDAVIT OF PUBLICATION ______________________________________ Notary Public in and for The State of Alaska. Third Division Anchorage, Alaska MY COMMISSION EXPIRES ______________________________________ 06/02/2024 and that such newspaper was regularly distrib- uted to its subscribers during all of said period. That the full amount of the fee charged for the foregoing publication is not in excess of the rate charged private individuals. Signed________________________________ Subscribed and sworn to before me Account #: 100869 ST OF AK/AK OIL AND GAS CONSERVATION COMMISSION333 W. 7TH AVE STE 100, ANCHORAGE, AK 99501 Order #: W0046115 Cost: $367.46 Notice of Public HearingSTATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION RE: Docket Number: AEO-24-001Hilcorp Alaska, LLC Aquifer Exemption Application for Well Susan Dionne 8, Ninilchik Unit, Kenai Peninsula, Alaska Hilcorp Alaska, LLC (Hilcorp), by application dated May 15, 2024, requests the Alaska Oil and Gas Conservation Commission (AOGCC) issue an order for aquifer exemption for an area extending one-quarter mile beyond the proposed injection zone in well Susan Dionne 8 within Sections 6 and 7 of Township 1 South, Range 13 West, Seward Meridian that lies within the boundaries of the Ninilchik Unit. An aquifer is an underground body of water-saturated rock or sediments that can store and/or transmit water. Regulations allow the United States Environmental Protection Agency (EPA) and the State of Alaska to exempt an aquifer or a portion of an aquifer if it does not currently serve as a source of drinking water, if it will not serve as a source of drinking water in the future, or if it meets other criteria such as the natural presence of hydrocarbons, existing contamination, or elevated dissolved solids concentration. An order granting an exemption allows an underground aquifer or a specified portion of an aquifer to be used for oil- or gas-related production, injection, or disposal purposes in compliance with EPA’s requirements under the Safe Drinking Water Act and State of Alaska regulations. This notice does not contain all the information filed by Hilcorp. To obtain more information, contact the AOGCC’s Special Assistant, Samantha Coldiron, at (907) 793-1223 or samantha.coldiron@alaska.gov. A public hearing on the matter has been tentatively scheduled for July 16, 2024, at 10:00 a.m. The hearing, which may be changed to full virtual, if necessary, will be held in the AOGCC hearing room located at 333 West 7th Avenue, Anchorage, AK 99501. The audio call in information is (907) 202 7104 Conference ID: 977 858 930#. Anyone who wishes to participate remotely using MS Teams video conference should contact Ms. Coldiron at least two business days before the scheduled public hearing to request an invitation for the MS Teams. To request that the tentatively scheduled hearing be held, a written request must be filed with the AOGCC no later than 4:30 p.m. on June 17, 2024. If a request for a hearing is not timely filed, the AOGCC may issue an order without a hearing. To learn if the AOGCC will hold the hearing, call (907) 793-1223 after June 18, 2024. In addition, written comments regarding this application may be submitted to the AOGCC, at 333 west 7th Avenue, Anchorage, AK 99501 or samantha.coldiron@alaska.gov. Comments must be received no later than 4:30 p.m. on July 3, 2024, except that, if a hearing is held, comments must be received no later than the conclusion of the July 16, 2024, hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, contact Samantha Coldiron, at (907) 793-1223, no later than July 9, 2024. Brett W. Huber, Sr.Chair, Commissioner Pub: June 2, 2024 STATE OF ALASKA THIRD JUDICIAL DISTRICT ______________________________________2024-06-03 2024-07-14 Document Ref: KRTF2-TYZYM-MZRKN-RWROF Page 28 of 36 From:Coldiron, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Public Hearing Notices (Hilcorp) Date:Thursday, May 30, 2024 12:29:33 PM Attachments:DIO-24-002 Public Hearing Notice Susan Dionne 8.pdf AEO-24-001 Public Hearing Notice Susan Dionne 8.pdf Docket Number: AEO-24-001 Hilcorp Alaska, LLC (Hilcorp), by application dated May 15, 2024, requests the Alaska Oil and Gas Conservation Commission (AOGCC) issue an order for aquifer exemption for an area extending one-quarter mile beyond the proposed injection zone in well Susan Dionne 8 within Sections 6 and 7 of Township 1 South, Range 13 West, Seward Meridian that lies within the boundaries of the Ninilchik Unit. Docket Number: DIO-24-002 Hilcorp Alaska, LLC (Hilcorp), by letter dated May 15, 2024, filed an application to the Alaska Oil and Gas Conservation Commission (AOGCC) for a Class II Underground Injection Control Disposal Injection Order for existing well Susan Dionne 8, onshore in the Ninilchik Unit (NU), Kenai Peninsula, Alaska. 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 Hilcorp Alaska, LLC May 15, 2024 Chairman Brett Huber, Sr. Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, Alaska 99501 Re: Hilcorp Alaska, LLC Susan Dionne Well 8 Aquifer Exemption Request Dear Chairman Huber: Hilcorp Alaska, LLC (Hilcorp) requests a Class II Aquifer Exemption (AE) for the proposed disposal interval in the Beluga 135 sand between approximately 3,700 and 3,900’ true vertical depth (TVD) and within one-quarter (1/4) mile of the Hilcorp property at the Susan Dionne Well 8 (SD-8). In accordance with the regulatory criteria established within 20 AAC 25.440, Hilcorp proposes to demonstrate: 1) that the aquifer does not currently serve as a source of drinking water and 2) it cannot now and will not in the future serve as a source of drinking water [20 AAC 25.440 (a)(1)] as it is situated at a depth or location which makes recovery of water for drinking water purposes economically or technologically impractical. The proposed AE is located at 60.112353˚ North latitude, -151.575897˚ West longitude in Section 6, Township 1 South, Range 13 West, Seward Meridian. The proposed AE shall extend one-quarter (1/4) mile beyond Hilcorp Susan Dionne Well 8 where the well penetrates the top of the Beluga 135 as shown in the attached surface site map. The upper elevation of the proposed exempted aquifer is approximately 3,700’ TVD. The base elevation is approximately 3,900’ TVD as shown on the attached Beluga 135 Type Log and Beluga 135 Structure Map. A review of the lithology identified numerous confining layers (coal facies) between the top depth of the intended disposal interval in the Beluga 135 and the shallow sources of existing drinker water wells in the region. These confining layers range from a few inches thick to as much as eight feet thick. A coal facies cross section illustrating the individual confining layers that separate the Beluga 135 interval from the surface aquifers is included as an attachment. Post Office Box 244027 Anchorage, AK 99524-4027 3800 Centerpoint Drive Suite 1400 Anchorage, AK 99503 Phone: 907/777-8300 Fax: 907/777-8301 By Samantha Coldiron at 1:57 pm, May 15, 2024 1) Demonstrate that the aquifer or portion thereof does not currently serve as a source of drinking water per 20 AAC 25.440(a)(1). Hilcorp reviewed the groundwater wells within the area. A summary table of the identified wells is enclosed. There is one well located within one-quarter mile of the proposed AE. That well is owned by Hilcorp and is located at the Susan Dionne Pad to supply water to the facility. Nine additional private residential wells were found within an approximate one- mile radius of the proposed AE. The depths of the wells range from 50’ to 257’. Two Public Water System source wells were identified in the area. A Transient, Non- Community well at Scenic View RV Park is located 1.8 miles northeast of the proposed AE. No well log was found, but based on the depths of nearby wells, the well is likely less than 200’ deep. A Transient, Non-Community well at Ninilchik 132.6 Cabins and RV Park is located three miles southwest of the proposed AE and drilled to a depth of 45’. The nearest Community Public Water Systems are the City of Soldotna and the City of Homer. The City of Soldotna Public Water System is located approximately 30 miles northeast of the proposed aquifer exemption. The City of Soldotna utilizes four groundwater wells at a depth of 295’ or less in addition to five seasonal wells at approximately the same depth. The City of Homer is located approximately 35 miles south of the proposed AE. The City of Homer utilizes a dammed surface water source forming the Bridge Creek Reservoir. This source is the city’s sole water source; no other groundwater wells or surface sources are operated by the City of Homer. Water supply for current and potential users in the area includes shallow unconfined and confined aquifers. The rural population of the area currently utilizes shallow wells to access these unconfined and confined aquifers that generally range from 40’-250’. Current usage as a percentage of capacity of these aquifers cannot be determined at this time. Given the low-density population of the area, relatively few points of use, and high mean annual precipitation from the maritime climate indicating a high potential aquifer recharge rate, the current usage as a percentage of capacity is likely low. Suitable water supply from the shallow unconfined and confined aquifers (less than 250’) appears to be readily available for private residences and small, non-community public water systems in the area. No publicly available reports indicate lack of water supply for drinking water or other uses in the area. Access to these water sources is readily available through the drilling of groundwater wells to comparatively shallow depths. Minimal information is publicly available regarding the quality of the groundwater supply from shallow (less than 250’) unconfined and confined aquifers in the area, as the majority of the wells are private. However, data submitted to the Alaska Department of Environmental Conservation from the two Transient, Non-Community public water systems in the area indicate that the untreated water meets the Maximum Contaminant Levels for Nitrate, Nitrite, and Total Coliforms (bacteria) established in 40 CFR 141 – National Primary Drinking Water Regulations. No monitoring of other analytes is required for those systems. Based on the data available, it appears that the water quality of the shallow unconfined and confined aquifers in the area is suitable for drinking water supply without additional treatment requirements. Hilcorp collected representative water samples from the proposed exempted aquifer for analysis by extracting water from the Susan Dionne 1A (PTD 185-208) (“SD-1A”) as part of Sundry 321-179. This water analysis is attached. SD-1A penetrates the Beluga 135 at ~3,607’ TVDss, which is slightly downdip from where SD-8 penetrates the Beluga 135 at 3,597’ TVDss. In 3D space these wells are ~80’ apart in the Beluga 135. The proximity of SD-1A to SD-8 makes it a strong analogue for comparison. The analysis of these water samples shows many contaminants that exceed the State of Alaska Groundwater Cleanup Levels described in 18 AAC 75.345 Table C. Therefore, water treatment systems would be necessary to render this water fit for consumption. This is further evidence that water from the Beluga 135 is not currently serving as a source of drinking water. 2) Demonstrate that the aquifer or portion thereof is situated at a depth or location that makes recovery of water for drinking water purposes economically or technologically impractical per 20 AAC 25.440 (a)(1)(B)). The upper elevation of the proposed exempted aquifer is approximately 3,700’ TVD. Compared to the shallow wells (40’ to 250’) that are typically utilized for water supply in the area, the proposed exempted aquifer is extremely deep. The cost of drilling a private residential or small commercial public water system well in the area is approximately $85 per foot1. Based on typical well depths (up to 250’), drilling a well costs approximately $21,250. The additional cost of a well pump is approximately $5,000. Conversely, drilling a deep water well (3,500’ or more) requires an alternate specialized drilling rig. Due to the construction requirements associated with this depth, a 3,500’ well for drinking water would cost approximately $3,000,0002, or more than 140 times the cost of a typical drinking water well in the area. Hilcorp reviewed the available deep well pumps. Due to the extreme depth of the well, a typical submersible well pump will not provide adequate head pressure. Instead, a specialized Electrical Submersible Pump (ESP), typically used for oil recovery, is required. No commercially available ESPs are ANSI/NSF Standard 61 certified for use with drinking water. Thus, their use for supply to a Public Water System would require special authorization. Estimated cost for an ESP installation meeting the system requirements is approximately $1,200,000. Additionally, due to wear associated with the high pressures, the lifespan of an ESP is typically only five years. Costs for ESP replacement would need to be budgeted annually. 1 Kraxberger Drilling, July 2021 2 Hilcorp Alaska, LLC cost projection, July 2021 An ESP at this depth providing water supply for a private residence or small, non- community water system will require approximately 175 kilowatts of power per day. Onsite generation using a natural gas powered microturbine is the most cost-effective and reliable power supply at a capital cost of approximately $95,000. Based on local natural gas prices, power supply for the ESP will cost roughly $11,500/month or $138,000/year. Based on the capital cost of drilling a deep well (greater than 3,500’) and installation and operation of a deep well pump, it is economically impractical for a private residence or small non-community public water system to recover water from the proposed exempted aquifer for drinking water purposes. Based on a review of Kenai Peninsula Borough tax assessment values, the costs of developing this aquifer for water supply are significantly greater than the developed property values (approximately $300,000) of the typical parcel where the water would be utilized3. Based on these costs it is economically impractical to develop and treat the water from the proposed exempted aquifer. No community water systems are located near the proposed AE. As such, the costs for development and operation of the proposed exempted aquifer for supply to a community system such as the City of Soldotna or City of Homer have not been calculated. If you have any questions or comments, please contact me at (907) 777-8322 or casey.morse@hilcorp.com Sincerely, Casey Morse Well Integrity Engineer Encl.: 1) Quarter Mile Boundary Surface Site Map 2) Beluga 135 in SD-8 Type Log 3) Beluga 135 Structure Map 4) Coal Facies Cross Section 5) Drinking Water Wells: Summary Table 6) Private Drinking Water Wells: Location Map 7) Public Drinking Water Wells: Location Map 8) SGS Environmental Laboratory Report 3 Kenai Peninsula Borough Parcel Tax Assessed Values https://gis.kpb.us/map/index.html?viewer=basic July 2021 Digitally signed by Casey Morse (11458) DN: cn=Casey Morse (11458) Date: 2024.05.15 09:42:39 - 08'00' Casey Morse (11458) -3900-3900-39003900-3650-3650 -3650-3650-3650-3 6 5 0 -3650 -3650 -365 0 -3650-3650-3650 -3 6 5 0 -3650 -3650 -3650 -3950-39500-360 0 -3600 -3600-3600-3600-36 0 0-3600 -3600 -3600-3600- 3 6 0 0 -36 0 0 -3600 -3600 -4050 -4050 -3550 -3550 -3550-3550-3 5 5 0 -3550 -3550 -3550-3550-3 5 5 0 -3550 -3500 -3500-3500-3500 -3500 -3500 -3500-35 0 0-4000-4000 -3850-3850-3850-3850-3800 -380 0 - 3 8 0 0 -3800-3800-3800-3800-3800-375 0 -375 0 -3750 -3750 -3750-3750 -3750-3750-3750-375 0 700-3700 -3700-3700-3700-3700-3700 -3700-3700-3700-3700-3 7 00 -37 0 0 -3700 -3700 4250 -4200 -4150 -4100-4100 -4350 -3450 -3450 -3450 -3450 -3450-3450-3400 Dionne 1A Dionne 2 Dionne 3 Dionne 4 Dionne 5 Dionne 6 Dionne 7 Dionne 8 Kalotsa 1 Kalotsa 2 Kalotsa 3 Kalotsa 4 Kalotsa 6 Paxton 1 Paxton 2 Paxton 3 Paxton 4 Paxton 8 Paxton 10 Paxton 6 Paxton 11 Kalotsa 7 Kalotsa 8 202400 203200 204000 204800 205600 206400 207200 208000 208800 209600 210400 211200 212000 212800 213600 214400 215200 202400 203200 204000 204800 205600 206400 207200 208000 208800 209600 210400 211200 212000 212800 213600 214400 2152002229600223040022312002232000223280022336002234400223520022360002236800223760022384002239200224000022408002241600222960022304002231200223200022328002233600223440022352002236000223680022376002238400223920022400002240800224160005001000150020002500ftUS 1:11742 Hilcorp: Kenai Team Ninilchik: Paxton/Kalotsa/Susan Dionne Beluga 135 Structure Susan Dionne 8 Disposal Well Contour inc 50 Date 04/02/2024 Sean Wagner Top Beluga 135: -4400.00 -4350.00-4300.00 -4250.00 -4200.00-4150.00 -4100.00 -4050.00 -4000.00-3950.00 -3900.00 -3850.00-3800.00 -3750.00 -3700.00-3650.00 -3600.00 -3550.00 -3500.00 -3450.00 -3400.00 -3350.00 TVDss depth [ft] Top disposal zone in Susan Dionne 8 A A' Well Number Owner (At time of AK DNR Filing) Private/Public Purpose Distance From Susan Dionne Pad Depth of Well (feet) Well Log Attatched Source of Data1293 Carolyn Issermoyer Private Drinking Water 1.5 miles 50 Yes AK DNR2282 John Mollette Private Drinking Water 0.55 miles 200 Yes AK DNR8259 Bob Wallis Private Drinking Water 0.43 miles 127 Yes AK DNR19164 Leo Thornton Private Drinking Water 1.1 miles 58 Yes AK DNR19165 Foster Leng Private Drinking Water 1.1 miles 58 Yes AK DNR19190 Albert Jones Private Drinking Water 1.0 miles 55 Yes AK DNR21474 Darrell Jones Private Drinking Water 1.1 miles 101 Yes AK DNR25804 Marathon Oil Co.* Private Drinking Water 0.0 miles 257 Yes AK DNR26930 J Inman Private Drinking Water 1.2 miles 100 Yes AK DNR42933 Lawrence Baker Private Drinking Water 1.1 miles 120 Yes AK DNR47475 Robert Frost Private Drinking Water 1.1 miles UNK Partial AK DNR43335 Glen Thomas Public Drinking Water 3.0 miles 45 Yes AK DNRNA Sandy Vincent** Public Drinking Water 1.8 miles UNK No NA*Well on Susan Dionne Pad, now owned by Hilcorp**Owner information obtained from ADEC Public Water System DataArea Well Summary Table Well Location Map #1Private WellsDate: 7/15/2021 Scale: NoneHilcorp Susan Dionne Well 8Aquifer Exemption RequestNinilchik, AlaskaHilcorp Alaska, LLC Susan Dionne PadAnd Well SD-8N1293269302147422828259258041916519164191904293347475LEGENDWell Well Location Map #2 Public Wells Date: 7/15/2021 Scale: As Shown Hilcorp Susan Dionne Well 8 Aquifer Exemption Request Ninilchik, Alaska Hilcorp Alaska, LLC Susan Dionne Pad And Well SD-8 N LEGEND Public Water System Well Scenic View RV Park PWSID AK2247466 Ninilchik 132.6 Cabins and RV Park PWSID AK2249226 !" # $% &! 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")")) + + '9;;' ;1'& - -=' >3 -&' !3 : %)()+%)???!-' 6 of 142 '0@. !"*%" A+0@. !" -0$.8 !"( . !"(# 0$.8 !"%# <' !" @.4' 7 !"( &'* !"(, - 2A; 5+ !" .9' &'* < <' '>*'* !"% ")")) + + '9;;' ;1'& - -=' >3 -&' !3 : %)()+%)???!-' 7 of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of 142 ( '0@. !"%*%" A+0@. !")% -0$.8 !" . !"((# 0$.8 !"))# <' !" @.4' 7 !" &'* !"((, - 2A; 5+ !"( .9' &'* <% <' '>*'* !" ()! ) $ !"()! * !"# ()! ( $ !")! !")# ")")) + + '9;;' ;1'& - -=' >3 -&' !3 : %)()+%)???!-' 9 of 142 ! "#$%& ' '()* '&'+ '&', - +. /0''&#1 -2 '1& 3 45 3&'5 5 6 - + 7 $8 - + !$ 94 - +':; - + 8 6 <; ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 10 of 142 ! "#$%& ' '()* '&'+ !" '&', - +. /0''&#1 -2 '1& -& & &? =4B - + &? = =40 -' &? = =40 7 & 66 &? = 45 =4 7+& 5 &? =5 =40 7 &? =40 & &? 5 =40 & &? =40 $ & = &? = =4B &? =40 = &? =4 =4 &? =4B &? 5 =4 ! ?'& &? =40 ! ? ' === &? 5 =4 !&+ &? = =40 !+ & &? = =40 :C &? 5 =40 ''& = &? = =4B & = &? = =4B &? =40 & = &? = =4 8$ & &? 5 =40 D & &? = 4 =40 ; 4 &? 6 =4B 7 $!EE=6 !$ 9=7 8 95D5 F" D - + 7 $!!4= - + !$ 97 - +'-/ - + 8 =4 <8 ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 11 of 142 ! "#$%& ' '()* '&'+# '&', - +. /0''&#1 -2 '1& ? + / '$ ?'/ 65 65 6=(G*H - + 7 $/3D - + !$ 97 - +'!5- - + 8 6= <; ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 12 of 142 ! "#$%& ' '()* '&'+! $ % &" '&', - +. /0''&#1 -2 '1& <!$+ $$ &? =5 = <!$+ $$ &? =5 = - $$ &? =5 = - $$+ 5 &? =5 =0 -$ 5 &? =5 =0 7.( *-$ 5 &? 5 5= 0 7.I J+ 5 &? 5 5== 0 7.IJ/& $ 5 &? 5 5= 0 7.I?@$@J+ 5 &? 5 5= 0 7.ICJ,& $ 5 &? 5 5= 0 $+' 56= &? 5 5= B .I @$J $ 5 &? 5 5== 0 /& $ 5 &? 5 5= 0 /& 6 &? =5 = I@@=<@ J+ 5 &? 5 5= 0 : $$ = &? =5= = $ $ 4 &? =5 = + 54 &? 5 5= $' <!$+ $$ < ('&* ) < =H /& $< ('&* ) <46 H 7 $EEE6 !$ 9==- 8 95D5 F" D - + 7 $E! - + !$ 6 !D(-3* - +'-9 - + 8 = <0 7 $EEE6 !$ 9==- 8 95D5 F" D - + 7 $E! - + !$ 6 !D(-3* - +'-9 - + 8 <0 ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 13 of 142 ! "#$%& ' '()* '&'+( #' )$ '&', - +. /0''&#1 -2 '1& ' ?#? ' = ? =5= 4 $' - ' ('&* ) < 4H 7 $EEE6= !$ 9= 8 95D5 F" D - + 7 $E/4 - + !$ -A - +'D! - + 8 4 < ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 14 of 142 ! "#$%& ' '()* '&'+( #' &" '&', - +. /0''&#1 -2 '1& @@<8$. 5 ? 5 5 =0 @< $. 5 ? 5 5 =0 @=< $. 5 ? 5 5 =0 @< $. 5 ? 5 5 =0 <$ $$ 5 ? 5 5 =0 <!$+ $$ 5 ? 5 5 = @@<8$$ 5 ? 5 5 =0 @@<8$$ 5 ? 5 5 =0 @< $$ 5 ? 5 5 =0 @< $+$ 54 ? 5 5 =B @< $ 5 ? 5 5 =0 @< & 5 ? 5 5 =0 @< $$ 5 ? 5 5 =0 @< & 5 ? 5 5 =0 <$ $$ 5 ? 5 5 =0 <$$ 5 ? 5 5 =0 <!$+<@< $ 5 ? 5 5 =0 <!$+ $$ 5 ? 5 5 = <!$+$(<'* 5 ? 5 5 =0 <: 5 ? 5 5 =0 <:$ 5 ? 5 5 =0 =K<!$+$(K <'* 5 ? 5 5= =0 =@=< $. 5 ? 5 5 =0 =<: 5 ? 5 5 =0 <7 $+<$+$ 5 ? 5 5 =0 <$<=< $+$ 5 ? 5 5 =0 <$ 5 ? 5 5 =0 <$$+<$+$ 5 ? 5 5 =0 <: 5 ? 5 5 =0 <:$ 5 ? 5 56 =0 - $$ 5 ? 5 5 =0 - $$+ 5 ? 5 5 =0 - 5 ? 5 56 =0 -$ 5 ? 5 5 =0 -.. 5 ? 5 5 =0 7.( *-$ 5 ? 5 5 =0 ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 15 of 142 ! "#$%& ' '()* '&'+( #' &" '&', - +. /0''&#1 -2 '1& 7.I J+ 5 ? 5 5 =0 7.IJ/& $ 5 ? 5 5 =0 7.I?@$@J+ 5 ? 5 5 =0 7.ICJ,& $ 5 ? 5 5 =0 7. 5 ? 5 5 =0 7.+ $ 5 ? 5 5 =0 7'($ $+$+*F$ 5 ? 5 5 =0 7'(<$$"+* $ 5 ? 5 5 =0 7'(<$$+*$ 5 ? 5 5 =0 '(<F$+$"+*$$ 56 ? 5 5 =B 7&+.+$$ 5 ? 5 5 =0 . 5 ? 5 5 =0 $+' 5 ? 5 5 =0 .I @$J $ 5 ? 5 5 =0 .,& 5 ? 5 56 = $+$$ 5 ? 5 5 =0 $+$$ 5 ? 5 5 =0 <<&+$$ 5 ? 5 5 =0 <<#+$$ 5 ? 5 5 =0 /& $ 5 ? 5 5 =0 /& 56 ? 5 5 = 3" $. 5 ? 5 5 =0 3" $& 5 ? 5 5 =0 3" $+ 56 ? 5 56 =0 3" $$ 5 ? 5 5 =0 I@@=<@ J+ 5 ? 5 5 =0 '$ 5 ? 5 5 =0 : $$ =5 ? 5 5 = :. 5 ? 5 5 =0 :<:' $+ 5 ? 5 5 =0 :<:'< <<+ 5 ? 5 5 =0 :<:' $+ 5 ? 5 5 =0 $$ 5 ? 5 56 =0 $ $ 56 ? 5 5 = $ 5 ? 5 5 =0 + 5 ? 5 5 =0 ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 16 of 142 ! "#$%& ' '()* '&'+( #' &" '&', - +. /0''&#1 -2 '1& $' @@<8 $('&* 45 ) =< = </&$+('&* 5 ) <4 = </&$('&* =54 ) 4<4 = :.< ('&* 45 ) < = $< ('&* 5 ) < = 8$+< ('&* 45 ) <= = 7 $EEE6 !$ 9= 8 4 95D5 F" D - + 7 $E!= - + !$ 96 - +':7 - + 8 = <9 ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 17 of 142 ! "#$%& ' '()* '&'+*!( #' &" '&', - +. /0''&#1 -2 '1& @@<8$$ 5= ? 56 56 =6(L*0 @@<8$$ 5= ? 56 56 =6(L*0 @< & 5= ? 56 56 =6(L5=*0 <!$+$(<'* 5 ? 56 56 =6(L*B =K<!$+$(K <'* 56 ? 56 5=4 =6(L*0 3" $. 5= ? 56 56 =6(L5=*0 3" $& 5= ? 56 56 =6(L5*0 3" $$ 5= ? 56 56 =6(L=*0 :. 5= ? 56 56 =6(L*0 $$ 5 ? 5= 5= =6(L*0 + 56 ? 56 5=4 =6(L*0 $' @@<8 $('&* 6 ) =< =6 </&$+('&* 5= ) <4 =6 </&$('&* =5 ) 4<4 =6 :.< ('&* 54 ) < =6H $< ('&* =56 ) < =6 8$+< ('&* 65 ) <= =6 7 $EEE6 !$ 9= 8 4 95D5 F" D - + 7 $E!= - + !$ 96 8 - +':7 - + 8 =6 <M ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 18 of 142 ! "#$%& ' '()* '&'+*!+ &" '&', - +. /0''&#1 -2 '1& @< $$ 5 ? 5 5 =(L56*0 @< $$ 5 ? 5 56 =(L5*0 @< $. 5 ? 5 56 =(L65*0 <7& (!FA* 56 ? 5 5 =(L* 7. 56 ? 5 5 =(L5* $ 5 ? 5 5 =(L5*0 $. 5 ? 5 56 =(L*0 $, 5 ? 5 5 =(L*0 3" $& 5 ? 5 5 =(L5*0 8 $$ 5 ? 5 5 =(L56*0 8$$ 5 ? 5 5 =(L5*0 D+$ 5 ? 5 5 =(L5*0 $' @< $$ < ('&* ) < = <7 ,&.('&* ) < = 8&< ('&* 4454 ) 4< = 7 $DEE=6 !$ 9=7 8 95D5 F" D - + 7 $D!6 - + !$ 9 8 - +'B!> - + 8 = <! ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 19 of 142 ! "#$%& ' '()* '&'++ )$ '&', - +. /0''&#1 -2 '1& > ' ?#? ' 54 ? 5 =5 $' <7 ,&.('&* ) < 7 $DEE=6 !$ 9=7 8 95D5 F" D - + 7 $D/ - + !$ -A - +'! 8 - + 8 <B ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 20 of 142 ! "#$%& ' '()* '&'++ &" '&', - +. /0''&#1 -2 '1& @@@<8 $$ 5 &? 5 65 0 @@<8$$ 5 &? 5 5 0 @@@<8 $$ 5 &? 5 65 0 @@<8$$ 5 &? 5 5 0 @< $$ 5 &? 5 5 0 @< $$ 5 &? 5 5 0 @< $ 5 &? 5 5 0 @@=<8$. 5 &? 5 5 0 @@=<8$ 5 &? 5 5 0 @@<8$. 5 &? 5 5 0 @@<8 $+. &? 5 5 @< <=<$ &? 0 @< $ 5 &? =56 54 0 @< $. 5 &? 5 5 0 @< $$ 5 &? 5 65 0 @< $ 5 &? 5 5 0 @=@<8 $+. &? 5 5 @=< $. 5 &? 5 5 0 @=< $ 5 &? 5 65 0 @< $. 5 &? 5 65 0 @< $ 5 &? 5 5 0 <7& (!FA* 64= &? <$& 5 &? 5 5 0 <3" &? 0 <$& 5 &? 5 5 0 <'+& &? 5 5 <!$+<< (!7A* &? 0 7. =5 &? 5 5 7 . 5 &? 5 5 0 7 $ $ 5 &? 5 5 0 7 $ $ 5 &? 5 65 0 7 , 5 &? 5 5 0 7 $ &? 0 '&, &? 0 $ 5 &? 5 5 0 $. 5 &? 5 65 0 ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 21 of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of 142 ! "#$%& ' '()* '&'++ &" '&', 7 $DEE=6 !$ 9=7 8 95D5 F" D - + 7 $D!6 - + !$ 9 - +'B!> - + 8 <- ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 23 of 142 ! "#$%& ' '()* '&'+, '&', - +. /0''&#1 -2 '1& #K> '3F! ? 5 5 =4 - + 7 $83#> - + !$ F-7 - +'F99 - + 8 =4 < - +. /0''&#1 -2 '1& $ 5 ? 5 5 = +, $ 54 8 = 7 $9EE=4 !$ !F83# 8 95D5 F" D - + 7 $9 - + !$ F-=5 - +'-5- - + 8 = <; - +. /0''&#1 -2 '1& 8 '' ' 6 ? =5 - + 7 $846= - + !$ ! - +'F99 - + 8 <; ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 24 of 142 ) ! "#$%& ' '()* '&'+ '&', ) - +. /0''&#1 -2 '1& 3 45 3&'5 5 6 - + 7 $8 - + !$ 94 - +':; - + 8 6 <; ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 25 of 142 ) ! "#$%& ' '()* '&'+ !" '&', ) - +. /0''&#1 -2 '1& -& & &? =B - + &? = =0 -' &? = =0 7 & &? = 45 = 7+& 5 &? =5 =0 7 &? =0 & &? 5 =0 & &? =B $ & 6 &? = =B &? =0 6 &? = &? = &? 5 = ! ?'& &? =0 ! ? ' &? 5 = !+ & &? = =0 :C 56 &? 5 =B ''& =6 &? = =B & &? = =B &? =0 & &? = = 8$ & &? 5 =0 D & &? = 4 =0 ; ==4 &? 6 = 7 $!EE=6 !$ 9=7 8 95D5 F" D - + 7 $!!4= - + !$ 97 - +'-/ - + 8 = <8 ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 26 of 142 ) ! "#$%& ' '()* '&'+# '&', ) - +. /0''&#1 -2 '1& ? + / '$ G ?'/ 65 65 6=(G* - + 7 $/3D - + !$ 97 - +'!5- - + 8 6= <; ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 27 of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of 142 ) ! "#$%& ' '()* '&'+( #' )$ '&', ) - +. /0''&#1 -2 '1& ' ?#? ' 6 ? 5 4 $' - ' ('&* ) < 4H 7 $EEE6= !$ 9= 8 95D5 F" D - + 7 $E/4 - + !$ -A - +'D! - + 8 4 < ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 29 of 142 ) ! "#$%& ' '()* '&'+( #' &" '&', ) - +. /0''&#1 -2 '1& @@<8$. 5 ? 5 5 60 @< $. 5 ? 5 5 60 @=< $. 5 ? 5 5 60 @< $. 5 ? 5 5 60 <$ $$ 5 ? 5 5 60 <!$+ $$ =5 ? 5 5 6 @@<8$$ 5 ? 5 5 60 @@<8$$ 5 ? 5 5 60 @< $$ 5 ? 5 5 60 @< $+$ 5 ? 5 5 60 @< $ 5 ? 5 5 60 @< & 5 ? 5 5 60 @< $$ 5 ? 5 5 60 @< & 5 ? 5 5 60 <$ $$ 5 ? 5 5 60 <$$ 5 ? 5 5 60 <!$+<@< $ 5 ? 5 5 60 <!$+ $$ 5 ? 5 5 6 <!$+$(<'* 5 ? 5 5 60 <: 5 ? 5 5 60 <:$ 5 ? 5 5 60 =K<!$+$(K <'* 5 ? 5 =5 60 =@=< $. 5 ? 5 5 60 =<: 5 ? 5 5 60 <7 $+<$+$ 5 ? 5 5 60 <$<=< $+$ 5 ? 5 5 60 <$ 5 ? 5 5 60 <$$+<$+$ 5 ? 5 5 60 <: 5 ? 5 5 60 <:$ 5 ? 5 65 60 - $$ 5 ? 5 5 60 - $$+ 5 ? 5 5 60 - 5 ? 5 65 60 -$ 5 ? 5 5 60 -.. 5 ? 5 5 60 7.( *-$ 5 ? 5 5 60 ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 30 of 142 ) ! "#$%& ' '()* '&'+( #' &" '&', ) - +. /0''&#1 -2 '1& 7.I J+ 5 ? 5 5 60 7.IJ/& $ 5 ? 5 5 60 7.I?@$@J+ 5 ? 5 5 60 7.ICJ,& $ 5 ? 5 5 60 7. 5 ? 5 5 60 7.+ $ 5 ? 5 5 60 7'($ $+$+*F$ 5 ? 5 5 60 7'(<$$"+* $ 5 ? 5 5 60 7'(<$$+*$ 5 ? 5 5 60 '(<F$+$"+*$$ 5 ? 5 5 60 7&+.+$$ 5 ? 5 5 60 . 5 ? 5 5 60 $+' 5 ? 5 5 60 .I @$J $ 5 ? 5 5 60 .,& 5 ? 5 56 6 $+$$ 5 ? 5 5 60 $+$$ 5 ? 5 5 60 <<&+$$ 5 ? 5 5 60 <<#+$$ 5 ? 5 5 60 /& $ 5 ? 5 5 60 /& 45= ? 5 5 6 3" $. 5 ? 5 5 60 3" $& 5 ? 5 5 60 3" $+ 65 ? 5 56 60 3" $$ 5 ? 5 5 60 I@@=<@ J+ 5 ? 5 5 60 '$ 5 ? 5 5 60 : $$ 5 ? 5 5 6 :. 5 ? 5 5 60 :<:' $+ 5 ? 5 5 60 :<:'< <<+ 5 ? 5 5 60 :<:' $+ 5 ? 5 5 60 $$ 5 ? 5 65 60 $ $ 5 ? 5 5 6 $ 5 ? 5 5 60 + 5 ? 5 5 60 ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 31 of 142 ) ! "#$%& ' '()* '&'+( #' &" '&', ) - +. /0''&#1 -2 '1& $' @@<8 $('&* 65 ) =< 6 </&$+('&* ) <4 6H </&$('&* =5 ) 4<4 6 :.< ('&* 5 ) < 6 $< ('&* =5 ) < 6 8$+< ('&* 4 ) <= 6 7 $EEE6 !$ 9= 8 4 95D5 F" D - + 7 $E!= - + !$ 96 - +':7 - + 8 6 <9 ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 32 of 142 ) ! "#$%& ' '()* '&'+*!( #' &" '&', ) - +. /0''&#1 -2 '1& @@<8$$ 5 ? 5 5 (L*0 @@<8$$ 5 ? 5 5 (L*0 @< & 5 ? 5 5 (L5=*0 <!$+$(<'* 5= ? 5 5 (L*B =K<!$+$(K <'* 5 ? 5 54 (L*0 3" $. 5 ? 5 5 (L5=*0 3" $& 5 ? 5 5 (L5*0 3" $$ 5 ? 5 5 (L=*0 :. 5 ? 5 5 (L*0 $$ 5 ? 5 5 (L*0 + 5 ? 5 54 (L*0 $' @@<8 $('&* 65 ) =< </&$+('&* 65 ) <4 </&$('&* =456 ) 4<4 :.< ('&* 5 ) < $< ('&* 5 ) < 8$+< ('&* 6=56 ) <= 7 $EEE6 !$ 9= 8 4 95D5 F" D - + 7 $E!= - + !$ 96 8 - +':7 - + 8 <M ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 33 of 142 ) ! "#$%& ' '()* '&'+*!+ &" '&', ) - +. /0''&#1 -2 '1& @< $$ 5 ? 5 5 (L56*0 @< $$ 5 ? 5 56 (L5*0 @< $. 5 ? 5 56 (L65*0 <7& (!FA* 564 ? 5 5 (L* 7. 54= ? 5 5 (L5* $ 5 ? 5 5 (L5*0 $. 5 ? 5 56 (L*0 $, 5 ? 5 5 (L*0 3" $& 5 ? 5 5 (L5*0 8 $$ 5 ? 5 5 (L56*0 8$$ 5 ? 5 5 (L5*0 D+$ 5 ? 5 5 (L5*0 $' @< $$ < ('&* ) < <7 ,&.('&* ) < H 8&< ('&* 44 ) 4< 7 $DEE=6 !$ 9=7 8 95D5 F" D - + 7 $D!6 - + !$ 9 8 - +'B!> - + 8 <! ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 34 of 142 ) ! "#$%& ' '()* '&'++ )$ '&', ) - +. /0''&#1 -2 '1& > ' ?#? ' 65= ? 5 =5 = $' <7 ,&.('&* 6 ) < = 7 $DEE=6 !$ 9=7 8 95D5 F" D - + 7 $D/ - + !$ -A - +'! 8 - + 8 = <B ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 35 of 142 ) ! "#$%& ' '()* '&'++ &" '&', ) - +. /0''&#1 -2 '1& @@@<8 $$ 5 &? 5 65 0 @@<8$$ 5 &? 5 5 0 @@@<8 $$ 5 &? 5 65 0 @@<8$$ 5 &? 5 5 0 @< $$ 5 &? 5 5 0 @< $$ 5 &? 5 5 0 @< $ 5 &? 5 5 0 @@=<8$. 5 &? 5 5 0 @@=<8$ 5 &? 5 5 0 @@<8$. 5 &? 5 5 0 @@<8 $+. 6 &? 5 5 @< <=<$ &? 0 @< $ 5 &? =56 54 0 @< $. 5 &? 5 5 0 @< $$ 5 &? 5 65 0 @< $ 5 &? 5 5 0 @=@<8 $+. = &? 5 5 @=< $. 5 &? 5 5 0 @=< $ 5 &? 5 65 0 @< $. 5 &? 5 65 0 @< $ 5 &? 5 5 0 <7& (!FA* 6 &? <$& 5 &? 5 5 0 <3" &? 0 <$& 5 &? 5 5 0 <'+& &? 5 5 <!$+<< (!7A* &? 0 7. 5 &? 5 5 7 . 5 &? 5 5 0 7 $ $ 5 &? 5 5 0 7 $ $ 5 &? 5 65 0 7 , 5 &? 5 5 0 7 $ &? 0 '&, &? 0 $ 5 &? 5 5 0 $. 5 &? 5 65 0 ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 36 of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of 142 ) ! "#$%& ' '()* '&'++ &" '&', ) 7 $DEE=6 !$ 9=7 8 95D5 F" D - + 7 $D!6 - + !$ 9 - +'B!> - + 8 <- ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 38 of 142 ) ! "#$%& ' '()* '&'+, '&', ) - +. /0''&#1 -2 '1& #K> '3F! ? 5 5= =4 - + 7 $83#> - + !$ F-7 - +'F99 - + 8 =4 < - +. /0''&#1 -2 '1& $ 5 ? 5 5 = +, $ 56 8 = 7 $9EE=4 !$ !F83# 8 95D5 F" D - + 7 $9 - + !$ F-=5 - +'-5- - + 8 = <; - +. /0''&#1 -2 '1& 8 '' ' 4 ? =5 - + 7 $846= - + !$ ! - +'F99 - + 8 <; ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 39 of 142 )*! = ! "#$%& ' '()* '&'+*!$ '&', )*! - +. /0''&#1 -2 '1& !&+ 5 ? 5= 5 =(L5*0 & 5 ? 5 5= =(L*0 5 ? 5 5 =(L*0 5 ? 5 5 =(L*B -' 5 ? 5 5= =(L*0 7 & 5 ? 5= 54 =(L* & 5 ? 5 5 =(L*0 $ & 5 ? 5 5= =(L*0 7 $!E8 !$ 9=7 8 95D5 F" D - + 7 $!!4= - + !$ 978 - +'-/ - + 8 = =<- ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 40 of 142 )*! ! "#$%& ' '()* '&'+*!$ '&', )*! - +. /0''&#1 -2 '1& -' 5 ? 5 5= (L*0 $ & 5 ? 5 5= (L*0 & 5=4 ? 5 5= (L*B 7 & 5 ? 5= 54 (L* 5 ? 5 5 (L*0 5 ? 5 5 (L*0 & 5 ? 5 5 (L*0 !&+ 5 ? 5= 5 (L5*0 7 $!E8 !$ 9=7 8 95D5 F" D - + 7 $!!4= - + !$ 978 - +'-/ - + 8 <- ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 41 of 142 * ! "9 (&, @F,,5@>& * '()* '&'++ &" '&', * - +. /0''&#1 -2 '1& @@<8$$ 5 &? 5 5= =0 @< $$ 5 &? 5 5= =0 @@=<8$. 5 &? 5 5= =0 @@<8 $+. 5 &? 5 5= =0 @@@<8 $$ 5 &? 5 5 =0 @< $$ 5 &? 5 5= =0 @@=<8$ 5 &? 5 5= =0 @< <=<$ 5 &? 5 =5 =0 @< $$ 5 &? 5 5 =0 @=< $. 5 &? 5 5= =0 @< $ 5 &? 5 5= =0 <3" 5 &? 5 =5 =0 <!$+<< (!7A* 5 &? 5 =5 =0 7 $ $ 5 &? 5 5= =0 7 $ 5 &? 5 5 =0 $. 5 &? 5 5 =0 $ $ 5 &? 5 5= =0 $ $ 5 &? 5 5 =0 F$+. 5 &? 5 5= =0 '+.(& * 5 &? 5 5= =0 : $$ 5 &? 5 5= =0 <E+ 5 &? 5 5= =0 + 5 &? 5 5= =0 8& 5 &? 5 5= =0 8$$ 5 &? 5 5= =0 D+$ 56 &? 5 5 =0 '<@=< $ 5 &? 5 5= =0 8$,& $ 5 &? 5 5= =0 D+ 5 &? 5 =5 =0 E+'( * 5 &? =5 5 =0 /<= 5 &? 5 =5 =0 3" $& 5 &? 5 5= =0 !$+$ 5 &? 5 =5 =0 !$+<<&+$ 5 &? 5 =5 =0 <7&+. 5 &? 5 5= =0 <+. 5 &? 5 5= =0 ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 42 of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of 142 * ! "9 (&, @F,,5@>& * '()* '&'++ &" '&', * 7 $DEE=6 !$ 9=7 8 95D5 F" D - + 7 $D!46 - + !$ 9 - +'B!> - + 8 = <- ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 44 of 142 * ! "9 (&, @F,,5@>& * '()* '&'++ )$ '&', * - +. /0''&#1 -2 '1& > ' ?#? ' 5 ? 5 5= 60 $' <7 ,&.('&* 4=56 ) < 6 7 $DEE=6 !$ 9=7 8 95D5 F" D - + 7 $D/ - + !$ -A - +'! 8 - + 8 6 <- ===-! ! ,>>& >:$- 5 9' -$ ?@-A4 4655==4655=2225&'5'?'5 B, ???' 45 of 142 !" #$%& '# ()*+ ',-./0 1 2',)$ 3 4 # 56 &5 -7/ 8659: 6+& ;8 56,+<2 4 , #+* = =+ = 0+6 4 ;,+>6+3? 44@44AAA444+ 46 of 142 !" #$%& '# ()*+ ',-./0 1 2',)$ 3 4 # 56 &5 -7/ 8659: 6+& ;8 56,+<2 4 , #+* = =+ = 0+6 4 ;,+>6+3? 44@44AAA444+ 47 of 142 ! "#$ % &&' ( ) *+!*# ,! - .!/ 0+ %* 12 ! ) 3456 4% 7 *6 82 * 9 ) *+! 7 ! !# !*/'4 :;:' : "#! 3!3/ "#! 3, !/% *!+2 ! !" "#*! #$% 1 !! &(& ( ( ", , 2 <<+ <!/"2 33:= *!1!! > "3/7 9"? 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"."2'G2 268'1-")"G 6 ( "."2'G2 268'1-")"G 6 5 "" '>' > #, , 6 33( 3"<#6 ))2 . +"5"" B #)<8 0#C !! 2!2>> 2!2!>DDD2(+2+8+2)6 103 of 142 104 of 142 105 of 142 106 of 142 e-Sample Receipt Form If samples received without a temperature blank, the "cooler temperature" will be documented instead & "COOLER TEMP" will be noted to the right. "ambient" or "chilled" will be noted if neither is available. Holding Time / Documentation / Sample Condition Requirements °C Yes 2 @ If <0°C, were sample containers ice free? N/A ***Note: If sample information on containers differs from COC, SGS will default to COC information. No Were samples received within holding time? *If >6°C, were samples collected <8 hours ago? Samples 1P,1Q,1R,1S,2P,2Q,2R,2S, and 2T were received unpreserved. Proceeded by preserving with 2mL and 8mL of HCL Lot# LW09-0463-17-05, And 1mL of HNO3 Lot# Lw09-0463-16-19. Were proper containers (type/mass/volume/preservative***)used? Additional notes (if applicable): Note to Client: Any "No", answer above indicates non-compliance with standard procedures and may impact data quality. Do samples match COC** (i.e.,sample IDs,dates/times collected)? YesWere Trip Blanks (i.e., VOAs, LL-Hg) in cooler with samples? Were all water VOA vials free of headspace (i.e., bubbles ≤ 6mm)? Samples 1E and 2I were received with headspace greater than 6mm. Proceed with limited Volume. Sample 7C was broken upon receipt, proceed with limited Volume. Yes No Note: Refer to form F-083 "Sample Guide" for specific holding times. Volatile / LL-Hg Requirements Were all soil VOAs field extracted with MeOH+BFB?N/A Yes Were analytical requests clear? (i.e., method is specified for analyses with multiple option for analysis (Ex: BTEX, Metals) N/A Therm. ID: Yes **Note: If times differ <1hr, record details & login per COC. Cooler ID: Cooler ID: D57Therm. ID: °C Therm. ID: Cooler ID: Note: Identify containers received at non-compliant temperature . Use form FS-0029 if more space is needed. **Exemption permitted if chilled & collected <8 hours ago, or for samples where chilling is not required 1 @ N/A 2F Exceptions Noted below 3.5 Were Custody Seals intact? Note # & location Cooler ID: Yes Chain of Custody / Temperature Requirements Temperature blank compliant* (i.e., 0-6 °C after CF)? @ ***Exemption permitted for metals (e.g,200.8/6020A). D30 Therm. ID: °C @Yes Therm. ID: Cooler ID: DOD: Were samples received in COC corresponding coolers? @ Yes °C N/A °C 6.0 SGS Workorder #:1212186 1212186 Exemption permitted if sampler hand carries/delivers.Yes Yes Condition (Yes, No, N/A)Review Criteria COC accompanied samples? F102b_SRFpm_20190325107 of 142 ! "# $%& ## $%& # $%& ' $ ( )#* +# $%& ,# $%& -# $%& .# $%& /# $%& 0 # $%& ! 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Test results relate only to samples analyzed. SGS North America Inc. • 4405 Vineland Road • Suite C-15 • Orlando, FL 32811 • tel: 407-425-6700 • fax: 407-425-0707 Test results contained within this data package meet the requirements of the National Environmental Laboratory Accreditation Program and/or state specific certification programs as applicable. Client Service contact: Andrea Colby 407-425-6700 Norm Farmer Technical Director Orlando, FL 05/26/21 e-Hardcopy 2.0 Automated Report 16 SGS is the sole authority for authorizing edits or modifications to this document. Unauthorized modification of this report is strictly prohibited. Review standard terms at: http://www.sgs.com/en/terms-and-conditions The results set forth herein are provided by SGS North America Inc. Please share your ideas about how we can serve you better at: EHS.US.CustomerCare@sgs.com 1 of 16 FA85459 127 of 142 Table of Contents -1- Sections: Section 1: Sample Summary ................................................................................................... 3 Section 2: Case Narrative/Conformance Summary .............................................................. 4 Section 3: Summary of Hits ....................................................................................................5 Section 4: Sample Results ........................................................................................................ 6 4.1:FA85459-1: 21-SD1-BEL135-01 ................................................................................. 7 4.2:FA85459-2: 21-SD1-BEL135-FD1 .............................................................................. 8 Section 5: Misc. Forms ............................................................................................................ 9 5.1:Chain of Custody ........................................................................................................... 10 Section 6: GC Volatiles - QC Data Summaries ..................................................................... 12 6.1:Method Blank Summary ................................................................................................ 13 6.2:Blank Spike/Blank Spike Duplicate Summary .............................................................. 14 6.3:Matrix Spike Summary .................................................................................................. 15 6.4:Duplicate Summary ....................................................................................................... 16 1234562 of 16 FA85459 128 of 142 SGS North America Inc. Sa mp le Su m m a r y SGS North America, Inc J ob No:: FA85459 1212186 Sample C ollected Ma tr ix C lient Number Da t e T ime By R eceived Cod e T yp e Sa mp le I D FA85459-1 05/04/21 10:00 05/12/21 AQ Water 21-SD1-BEL135-01 FA85459-2 05/04/21 10:15 05/12/21 AQ Water 21-SD1-BEL135-FD1 3 of 16 FA854591129 of 142 SAMPLE DELIVERY GROUP CASE NARRATIVE Client: SGS North America, Inc Job No: FA85459 Site: 1212186 Report Date 5/26/2021 4:40:59 PM 2 Sample(s), 0 Trip Blank(s) and 0 Field Blank(s) were collected on 05/04/2021 and were received at SGS North America Inc - Orlando on 05/12/2021 properly preserved, at 1.6 Deg. C and intact. These Samples received an SGS Orlando job number of FA85459. A listing of the Laboratory Sample ID, Client Sample ID and dates of collection are presented in the Results Summary Section. Except as noted below, all method specified calibrations and quality control performance criteria were met for this job. For more information, please refer to QC summary pages. GC Volatiles By Method RSKSOP-147/175 Matrix: AQ Batch ID: G1R193 All samples were analyzed within the recommended method holding time. Sample(s) FA85459-1MS, FA85488-4DUP, FA85459-1MS were used as the QC samples indicated. All method blanks for this batch meet method specific criteria. Matrix Spike Recovery(s) for Methane are outside control limits. Outside control limits due to high level in sample relative to spike amount. SGS Orlando certifies that this report meets the project requirements for analytical data produced for the samples as received at SGS Orlando and as stated on the COC. SGS Orlando certifies that the data meets the Data Quality Objectives for precision, accuracy and completeness as specified in the SGS Orlando Quality Manual except as noted above. This report is to be used in its entirety. SGS Orlando is not responsible for any assumptions of data quality if partial data packages are used Narrative prepared by: ______________________________________ Ariel Hartney, Client Services (signature on file) 4 of 16 FA854592130 of 142 Summary of Hits Page 1 of 1 Job Number:FA85459 Account:SGS North America, Inc Project:1212186 Collected:05/04/21 Lab Sample ID Client Sample ID Result/ Analyte Qual LOQ LOD Units Method FA85459-1 21-SD1-BEL135-01 Methane 5550 5.0 2.5 ug/l RSKSOP-147/175 Ethane 68.3 1.0 0.50 ug/l RSKSOP-147/175 FA85459-2 21-SD1-BEL135-FD1 Methane 5190 5.0 2.5 ug/l RSKSOP-147/175 Ethane 66.7 1.0 0.50 ug/l RSKSOP-147/175 5 of 16 FA854593131 of 142 SGS North America Inc. Sample Results Report of Analysis Orlando, FL Section 4 6 of 16 FA854594132 of 142 SGS North America Inc. Report of Analysis Page 1 of 1 Client Sample ID:21-SD1-BEL135-01 Lab Sample ID:FA85459-1 Date Sampled:05/04/21 Matrix:AQ - Water Date Received:05/12/21 Method:RSKSOP-147/175 Percent Solids:n/a Project:1212186 File ID DF Analyzed By Prep Date Prep Batch Analytical Batch Run #1 1R5111.D 1 05/13/21 10:59 MB n/a n/a G1R193 Run #2 1R5112.D 10 05/13/21 11:19 MB n/a n/a G1R193 Initial Volume Headspace Volume Volume Injected Temperature Run #1 38.0 ml 5.0 ml 500 ul 20 Deg. C Run #2 38.0 ml 5.0 ml 500 ul 20 Deg. C CAS No. Compound Result LOQ LOD DL Units Q 74-82-8 Methane 5550 a 5.0 2.5 1.6 ug/l 74-84-0 Ethane 68.3 1.0 0.50 0.32 ug/l 74-85-1 Ethene 0.50 U 1.0 0.50 0.43 ug/l (a) Result is from Run# 2 U = Not detected LOD = Limit of Detection J = Indicates an estimated value LOQ = Limit of Quantitation DL = Detection Limit B = Indicates analyte found in associated method blank E = Indicates value exceeds calibration range N = Indicates presumptive evidence of a compound 7 of 16 FA8545944.1133 of 142 SGS North America Inc. Report of Analysis Page 1 of 1 Client Sample ID:21-SD1-BEL135-FD1 Lab Sample ID:FA85459-2 Date Sampled:05/04/21 Matrix:AQ - Water Date Received:05/12/21 Method:RSKSOP-147/175 Percent Solids:n/a Project:1212186 File ID DF Analyzed By Prep Date Prep Batch Analytical Batch Run #1 1R5110.D 1 05/13/21 10:49 MB n/a n/a G1R193 Run #2 1R5113.D 10 05/13/21 11:31 MB n/a n/a G1R193 Initial Volume Headspace Volume Volume Injected Temperature Run #1 38.0 ml 5.0 ml 500 ul 20 Deg. C Run #2 38.0 ml 5.0 ml 500 ul 20 Deg. C CAS No. Compound Result LOQ LOD DL Units Q 74-82-8 Methane 5190 a 5.0 2.5 1.6 ug/l 74-84-0 Ethane 66.7 1.0 0.50 0.32 ug/l 74-85-1 Ethene 0.50 U 1.0 0.50 0.43 ug/l (a) Result is from Run# 2 U = Not detected LOD = Limit of Detection J = Indicates an estimated value LOQ = Limit of Quantitation DL = Detection Limit B = Indicates analyte found in associated method blank E = Indicates value exceeds calibration range N = Indicates presumptive evidence of a compound 8 of 16 FA8545944.2134 of 142 SGS North America Inc. Misc. Forms Custody Documents and Other Forms Includes the following where applicable: • Chain of Custody Orlando, FL Section 5 9 of 16 FA854595135 of 142 FA85459: Chain of Custody Page 1 of 2 10 of 16 FA8545955.1136 of 142 Job Number:FA85459 Client:SGS ALASKA Date / Time Received:5/12/2021 10:30:00 AM Delivery Method:FX Project:1212186 Airbill #'s:1483 4801 5286 Cooler Information 1. Custody Seals Present 2. Custody Seals Intact 4. Cooler temp verification 3. Temp criteria achieved 5. Cooler media IR Gun Ice (Bag) Trip Blank Information 1. Trip Blank present / cooler 2. Trip Blank listed on COC 2. Samples preserved properly Sample Information 1. Sample labels present on bottles 5. Sample recvd within HT 4. Condition of sample 3. Sufficient volume/containers recvd for analysis: Intact Comments SM001 Rev. Date 05/24/17 SGS Sample Receipt Summary Cooler Temps (Raw Measured) °C: Cooler Temps (Corrected) °C: Cooler 1: (3.4); Cooler 1: (1.6); 3. Type Of TB Received W or S N/A 6. Dates/Times/IDs on COC match Sample Label 7. VOCs have headspace 8. Bottles received for unspecified tests 9. Compositing instructions clear 10. Voa Soil Kits/Jars received past 48hrs? 11. % Solids Jar received? Misc. Information 25-Gram 5-GramNumber of Encores:Number of 5035 Field Kits:Number of Lab Filtered Metals: Test Strip Lot #s:pH 0-3 230315 pH 10-12 219813A Other: (Specify) Y or N N/A Y or N Therm ID:IR 1; Therm CF:-1.8; # of Coolers:1 Y or N N/A 12. Residual Chlorine Present? Residual Chlorine Test Strip Lot #: Technician:Reviewer:PETERH Date:Date: 5/12/2021 10:30:00 A FA85459: Chain of Custody Page 2 of 2 11 of 16 FA8545955.1137 of 142 SGS North America Inc. GC Volatiles QC Data Summaries Includes the following where applicable: • Method Blank Summaries • Blank Spike Summaries • Matrix Spike and Duplicate Summaries Orlando, FL Section 6 12 of 16 FA854596138 of 142 Method Blank Summary Page 1 of 1 Job Number:FA85459 Account:SGSAKA SGS North America, Inc Project:1212186 Sample File ID DF Analyzed By Prep Date Prep Batch Analytical Batch G1R193-MB 1R5106.D 1 05/13/21 MB n/a n/a G1R193 The QC reported here applies to the following samples: Method:RSKSOP-147/175 FA85459-1, FA85459-2 CAS No. Compound Result RL MDL Units Q 74-82-8 Methane ND 0.50 0.16 ug/l 74-84-0 Ethane ND 1.0 0.32 ug/l 74-85-1 Ethene ND 1.0 0.43 ug/l 13 of 16 FA8545966.1.1139 of 142 Blank Spike/Blank Spike Duplicate Summary Page 1 of 1 Job Number:FA85459 Account:SGSAKA SGS North America, Inc Project:1212186 Sample File ID DF Analyzed By Prep Date Prep Batch Analytical Batch G1R193-BS 1R5107.D 1 05/13/21 MB n/a n/a G1R193 G1R193-BSD 1R5108.D 1 05/13/21 MB n/a n/a G1R193 The QC reported here applies to the following samples: Method:RSKSOP-147/175 FA85459-1, FA85459-2 Spike BSP BSP BSD BSD Limits CAS No. Compound ug/l ug/l % ug/l % RPD Rec/RPD 74-82-8 Methane 108 85.5 79 93.6 87 9 62-139/30 74-84-0 Ethane 219 176 80 195 89 10 67-141/30 74-85-1 Ethene 290 240 83 264 91 10 68-141/30 * = Outside of Control Limits. 14 of 16 FA8545966.2.1140 of 142 Matrix Spike Summary Page 1 of 1 Job Number:FA85459 Account:SGSAKA SGS North America, Inc Project:1212186 Sample File ID DF Analyzed By Prep Date Prep Batch Analytical Batch FA85459-1MS 1R5114.D 10 05/13/21 MB n/a n/a G1R193 FA85459-1 1R5111.D 1 05/13/21 MB n/a n/a G1R193 FA85459-1 1R5112.D 10 05/13/21 MB n/a n/a G1R193 The QC reported here applies to the following samples: Method:RSKSOP-147/175 FA85459-1, FA85459-2 FA85459-1 Spike MS MS CAS No. Compound ug/l Q ug/l ug/l % Limits 74-82-8 Methane 5550 b 1080 7560 186*a 62-139 74-84-0 Ethane 68.3 2190 2160 96 67-141 74-85-1 Ethene 1.0 U 2900 2860 99 68-141 (a) Outside control limits due to high level in sample relative to spike amount. (b) Result is from Run #2. * = Outside of Control Limits. 15 of 16 FA8545966.3.1141 of 142 Duplicate Summary Page 1 of 1 Job Number:FA85459 Account:SGSAKA SGS North America, Inc Project:1212186 Sample File ID DF Analyzed By Prep Date Prep Batch Analytical Batch FA85488-4DUP 1R5123.D 1 05/13/21 MB n/a n/a G1R193 FA85488-4 1R5120.D 1 05/13/21 MB n/a n/a G1R193 The QC reported here applies to the following samples: Method:RSKSOP-147/175 FA85459-1, FA85459-2 FA85488-4 DUP CAS No. Compound ug/l Q ug/l Q RPD Limits 74-82-8 Methane 1.9 1.8 530 74-84-0 Ethane 1.0 U ND nc 30 74-85-1 Ethene 1.0 U ND nc 30 * = Outside of Control Limits. 16 of 16 FA8545966.4.1142 of 142