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Home My WebLink AboutCO 207 CCONSERVATION ORDER 207C August 22, 2018 BPXA's request for Administrative Approval to Commingle Production from Lisburne Oil Pool (CO207B) and Prudhoe Oil Pool (CO 341F) in Prudhoe Bay Unit well L5-21 2. November 18, 2018 Notice of hearing, affidavit of publication, email distribution, mailings 3. December 5, 2019 BPXA spacing exception application L5-07 (CO 207C.001) 4. December 5, 2019 BPXA spacing exception application L3-26 (CO 207C.002) 5. December 5, 2019 BPXA spacing exception by Administrative Approval under Conservation Order No. 207C to allow drilling, completion, and production of the Prudhoe Bay Unit K-322 development oil well within the same governmental quarter sections as wells that are, or may be capable of, producing from the same pool. CO 207C.003) ORDERS STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West 7t" Avenue Anchorage, Alaska 99501 Re: THE APPLICATION OF BP ) Docket Number: CO -18-025 EXPLORATION (ALASKA) INC. for an ) Conservation Order 207C order to allow downhole commingling in ) Prudhoe Bay Unit Well PBU L5-21 between the Lisburne and ) Lisburne Oil Pool Prudhoe Oil Pools ) North Slope Borough, Alaska April 22, 2019 IT APPEARING THAT: 1. By letter dated August 22, 2018, BP Exploration (Alaska), Inc. (BPXA), operator of the Prudhoe Bay Unit, applied for amendments to Conservation Orders (CO) 341G' and 207B to allow commingled downhole production between the Prudhoe Oil Pool (POP) and the Lisburne Oil Pool (LOP) in well PBU L5-21 (L5-21) (PTD 187-057). 2. Pursuant to 20 AAC 25.540, the Alaska Oil and Gas Conservation Commission (AOGCC) scheduled a public hearing for December 19, 2018. On November 16, 2018, the AOGCC published notice of that hearing on the State of Alaska's Online Public Notice website, 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 to all persons on the AOGCC's mailing distribution list. On November 18, 2018, the notice was published in the Anchorage Daily News. 3. No comments or requests to hold the hearing were received by the AOGCC. 4. BPXA provided sufficient information in its application to make a decision, so the proposed hearing was vacated. FINDINGS: 1. Lisburne Oil Pool The LOP, described in CO 207 and in production since 1982, is a complex carbonate reservoir that underlies the POP. 2. Prudhoe Oil Pool The POP, in production since 1977, consists of an immense oil rim overlain by a massive gas cap. The POP has numerous enhanced recovery projects underway. POP wells are typically very productive due to the high-quality reservoir rocks within the pool. Proposed Commineline Operation The L5-21 well is completed in the LOP and has produced approximately 1.8 million barrels of oil since being brought on production in October 1987. The L5-21 well intersects the POP in an area that contains liquids -rich gas. Commingling of production will have two benefits. First, gas from the POP will act as an in-situ gas lift for oil production from the LOP and thus improve ultimate recovery from the LOP. Second, targeting small, liquids -rich gas 'The application actually requested an amendment to CO 341F, but CO 341G was issued after the application was received. CO 207C April 22, 2019 Page 2 of 9 accumulations that have not been swept during years of lean gas re-injection into the POP gas cap has proven a successful means to increase ultimate recovery from the POP. These unswept gas accumulations are typically not large enough to warrant drilling of dedicated wells, but they are targets of opportunity when identified in existing wellbores. 4. Potential for Crossflow There is potential for crossflow between the POP and the LOP if L5-21 is shut in. For a short duration shut in period, crossflow is not expected to be significant as the POP and LOP have similar reservoir pressures within this portion of the Prudhoe Bay Field. In the event of a longer duration shut in period, the POP and LOP could be mechanically isolated downhole via through -wellbore cementing techniques to prevent crossflow. Production Allocation Since the L5-21 well is completed in the oil rim of the LOP and the gas cap of the POP BPXA proposes allocating 100% of the oil and water production from the well to the LOP and 100% of the NGL production attributed to the POP. Gas production will be allocated to the LOP based on the oil rate times the solution gas -oil -ratio of the LOP, with the remainder of the gas produced from the well allocated to the POP. Proposed gas allocation formulas are: Prudhoe Formation Gas Rate = Total Gas Rate — Lisburne Formation Gas Rate Lisburne Formation Gas Rate = allocated oil rate x Lisburne Oil Pool Solution Gas Oil Ratio Lisburne Oil Pool Solution Gas Oil Ratio = 863 scf/stbo Production logs could be run if necessary. CONCLUSIONS: 1. Downhole commingling of production between the POP and LOP will improve resource recovery from the Prudhoe Bay Unit by encouraging production of resources within the POP that would not be recoverable as a standalone development and by improving recovery from the existing LOP completion of L5-21. 2. Crossflow between the POP and LOP is not expected to be significant due to similar reservoir pressures in this portion of the Prudhoe Bay Field. 3. BPXA's proposed allocation methodology will provide acceptable results. NOW THEREFORE IT IS ORDERED: Development and operation of the Lisburne Oil Pool are subject to the following rules and the statewide requirements under 20 AAC 25 to the extent not superseded by these rules. This order supersedes conservation orders 207, 207A, and 207B and all of their associated administrative approvals, except for CO 207.1. The records of those orders and approvals are incorporated by reference into this order. CO 207C April 22, 2019 Page 3 of 9 AFFECTED AREA: UMIAT MERIDIAN TION, R13E Sections 1, 2, 3, 10, 11, and 12. TION, R14E Sections 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 35, and 36. TION, R15E All. TION, R16E All. TION, R17E Sections 3, 4, 5, 6, 7, 8, 9, 10, 15, 16, 17, 18, 19, 20, 21, 22, 27, 28, 29, 30, 31, 32, 33, and 34. T11N, R13E Sections 1, 2, 3, 4, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, and 36. T11N, R14E All. TI IN, R15E All. TI IN, R16E All. TI IN, R17E Sections 3, 4, 5, 6, 7, 8, 9, 10, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, and 36. T12N, R13E Sections 35 and 36. T12N, R14E Sections 13, 14, 15, 16, 21, 22, 23, 24, 25, 26, 27, 28, 31, 32, 33, 34, 35, and 36. T12N R15E Sections 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, and 36. T12N, R16E Sections 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, and 36. Rule 1. FIELD AND POOL NAME (Source: CO 207) The field is the Prudhoe Bay Field and the pool is the Lisburne Oil Pool. CO 207C April 22, 2019 Page 4 of 9 Rule 2. POOL DEFINITION (Source: CO 207 The Lisburne Oil Pool is defined as the accumulations of oil and gas which occur in stratigraphic sections which correlate with the stratigraphic section found in the Atlantic Richfield -Humble Prudhoe Bay State No. 1 well between the depths of 8,790 feet measured depth and 10,440 feet measured depth. Rule 3. WELL SPACING (Source: CO 207) The well spacing unit shall be one producing well per governmental quarter section. No pay may be opened in a well closer than 1,000 feet to the pay opened in another well or opened in a well which is closer than 500 feet to the boundary of the affected area. Rule 4. CASING AND CEMENTING (Source: CO 207, Revised: CO 207.2) a) A conductor casing shall be set at least 75 feet below the surface and sufficient cement shall be used to fill the annulus behind the pipe to the surface. Rigid high- density polyurethane foam may be used as an alternate to cement, upon approval by the Commission. The Commission may also administratively approve other sealing materials which are supported by sound engineering principles and performance data. b) Surface casing to provide proper anchorage for equipment to prevent uncontrolled flow, to withstand anticipated interval pressure and to protect the well from the effects of permafrost thaw -subsidence or freeze back loadings shall be set at least 500 feet, measured depth, below the base of the permafrost but not below 5000 feet true vertical depth. Sufficient cement shall be used to fill the annulus behind the casing to the surface. c) Surface casing types and grades approved for use through the permafrost interval include: 1) 13-3/8 inch, 72 pounds/foot, L-80 Buttress; 2) 13-3/8 inch, 72 pounds/foot, N-80 Buttress; 3) 13-3/8 inch, 68 pounds/foot, MN -80 Buttress; and 4)13-3/8 inch, 68 pounds/foot, K-55 d) The Commission may administratively approve additional types and grades of surface casing through the permafrost interval upon a showing that the proposed casing and connection can withstand the permafrost thaw -subsidence and freeze back loadings which may be experienced. Evidence submitted to the Commission shall include: 1) full scale tension and compression testing: or 2) finite element model studies: or 3) other types of axial strain data acceptable to the Commission. e) Alternate casing programs may be administratively approved by the Commission upon application and presentation of data which show the alternatives are appropriate, based upon accepted engineering principles. CO 207C April 22, 2019 Page 5 of 9 Rule 5. COMPLETION PRACTICES (Source: CO 207). Wells completed for production may utilize casing strings or liners cemented through the productive intervals and perforated, slotted liners, screen -wrapped liners, gravel packs or open hole methods, or combinations thereof. The Commission may administratively approve alternate completion methods where appropriate. Rule 6. HYDROGEN SULFIDE (Rescinded CO 207B). Rule 7. AUTOMATIC SHUT-IN EOUIPMENT (Rescinded by Other Order No. 66) Rule 8. GAS VENTING OR FLARING (Source: CO 207) a) The venting or flaring of gas is prohibited except for operational necessities and for safety volumes set out in this rule; b) A daily average volume of 1,000 MCF per day is approved for the safety flare at the Lisburne Production Center; c) Volumes of gas to provide safety flares for additional facilities may be approved by administrative order upon proper application; d) The volumes of gas for safety flares may be decreased or increased by administrative order; and e) Gas flaring may be approved by administrative order during commissioning of new equipment, purging, and start-ups after major repairs or interruptions. Rule 9. GAS -OIL RATIO TESTS (Source: CO 207) a) Between 90 and 120 days after regular production commences and each six months thereafter a gas -oil ratio test will be taken on each well for as long as it produces oil; b) The gas -oil ratio tests will be for a minimum of four hours and shall be taken at the normal producing rate of the well; and c) The results of the gas -oil ratio tests will be reported on Form 10-409, Gas -Oil Ratio Test and will be submitted in January and July of each year. Rule 10. PRESSURE SURVEYS (Source: CO 207, Revised CO 207.11). a) All new wells shall have an acceptable pressure survey, as defined in part (c), taken prior to regular production or injection. b) One pressure survey per producing drillsite per year shall be taken. Pressure surveys from producing or water and gas injection wells may be used for this pressure requirement. Pressure surveys covered in section (a) may be substituted for a drillsite pressure. c) Acceptable pressure surveys include static surveys, RFT/FMT, pressure buildup and falloff tests, and multi -rate pressure transient tests in production or injection wells. Other quantitative methods may be administratively approved by the Commission. d) The pressure datum for the Lisburne Oil Pool is 8900 feet subsea. The Commission may administratively amend this datum or create an additional datum when more information is available on the reservoir. CO 207C April 22, 2019 Page 6 of 9 e) Data from the pressure surveys, along with additional pressure data obtained through proper management of the reservoir, shall be filed on form 10-412 by the last day of the month following the month that the pressure survey was obtained. Submitted pressure data shall include other information as necessary such as rate, time, depth, temperature, and well conditions to allow for a complete analysis of the pressure survey. f) The operator shall schedule an annual meeting with the Commission to review the pressure monitoring program and discus future plans for reservoir management. Rule 11. UNITIZATION (Source: CO 207) To ensure the protection of correlative rights and to prevent waste, the Lisburne Oil Pool shall be administered in accordance with the Prudhoe Bay Unit Agreement. Rule 12. PILOT PROJECTS (Source: CO 207 Upon application, the Commission may administratively approve field pilot projects, well production and injection tests and other filed operations necessary for the purpose of developing a prudent enhanced recovery method and reservoir depletion program. Rule 13. POOL OFFTAKE RATE (Source: CO 207) No more than 160,000 barrels of oil per day may be produced from the Lisburne Oil Pool. However, when evidence can be presented to the Commission showing that a higher offtake rate will not affect ultimate recovery, the Commission may increase the daily offtake rate by administrative order. Rule 14. CONSERVATION ORDER NO. 83-C (Source: CO 207) Conservation Order No. 83-C is hereby cancelled. Rule 15. ANNULAR PRESSURES (Source: CO 492. Revised by: CO 207.17) a) The operator shall conduct and document a pressure test of tubulars and completion equipment in each development well at the time of installation or replacement that is sufficient to demonstrate that planned well operations will not result in failure of well integrity, uncontrolled release of fluid or pressure, or threat to human safety. b) The operator shall monitor each development well daily to check for sustained pressure, except if prevented by extreme weather conditions, emergency situations, or similar unavoidable circumstances. Monitoring results shall be made available for AOGCC inspection. c) The operator shall notify the AOGCC within three working days after the operator identifies a well as having (a) sustained inner annulus pressure that exceeds 2500 psig for wells processed through the Lisburne Processing Center and 2000 psig for all other development wells, or (b) sustained outer annulus pressure that exceeds 1000 psig. d) The AOGCC may require the operator to submit in an Application for Sundry Approvals (Form 10-403) a proposal for corrective action or increased surveillance for any development well having sustained pressure that exceeds a limit set out in CO 207C April 22, 2019 Page 7 of 9 paragraph 3 of this rule. The AOGCC may approve the operator's proposal or may require other corrective action or surveillance. The AOGCC may require that corrective action be verified by mechanical integrity testing or other AOGCC approved diagnostic tests. The operator shall give AOGCC sufficient notice of the testing schedule to allow AOGCC to witness the tests. e) If the operator identifies sustained pressure in the inner annulus of a development well that exceeds 45% of the burst pressure rating of the well's production casing for inner annulus pressure, or sustained pressure in the outer annulus that exceeds 45% of the burst pressure rating of the well's surface casing for outer annulus pressure, the operator shall notify the AOGCC within three working days and take corrective action. Unless well conditions require the operator to take emergency corrective action before AOGCC approval can be obtained, the operator shall submit in an Application for Sundry Approvals (Form 10-403) a proposal for corrective action. The AOGCC may approve the operator's proposal or may require other corrective action. The AOGCC may also require that corrective action be verified by mechanical integrity testing or other AOGCC approved diagnostic tests. The operator shall give AOGCC sufficient notice of the testing schedule to allow AOGCC to witness the tests. f) Except as otherwise approved by the AOGCC under paragraph 4 or 5 of this rule, before a shut-in well is placed in service, any annulus pressure must be relieved to a sufficient degree (a) that the inner annulus pressure at operating temperature will be below 2500 psig for wells processed through the Lisburne Production Center and below 2000 psig for all other development wells, and (b) that the outer annulus pressure at operating temperature will be below 1000 psig. However, a well that is subject to paragraph 3, but not paragraph 5, of these rules may reach an annulus pressure at operating temperature that is described in the operator's notification to the AOGCC under paragraph 3, unless the AOGCC prescribes a different limit. g) For purposes of these rules, "inner annulus" means the space in a well between tubing and production casing; "outer annulus" means the space in a well between production casing and surface casing; "sustained pressure" means pressure that (a) is measurable at the casing head of an annulus, (b) is not caused solely by temperature fluctuations, and (c) is not pressure that has been applied intentionally. Rule 16. GAS -CAP WATER INJECTION PROJECT (Source: CO 207B) a) Water injection is authorized into Well L5-29 only and is limited to perforations within the upper Wahoo Formation (Zone 6) between the measured depths of 13,585' and 13,634'; b) The Well L5-29 injection rate is limited to 20,000 barrels of water injected per day; and c) Injection pressures must be maintained below 0.55 psi/ft. CO 207C April 22, 2019 Page 8 of 9 Rule 17. ADMINISTRATIVE ACTION (Source: CO 207B) Upon proper application, or its own motion, and unless notice and public hearing are otherwise required, the Commission my administratively waive the requirements of any rule stated herein or administratively amend this order as long as the change does not promote waste or jeopardize correlative rights, is based on sound engineering and geoscience principles, and will not result in an increased risk of fluid movement into freshwater aquifers. Rule 18. DOWNHOLE COMMINGLING OF PRODUCTION IN WELL PBU L5-21 (New This Order) Downhole commingling of production between the POP and LOP in the PBU L5-21 well is approved subject to the following allocation methodology; (a) All oil and water allocated to the well shall be allocated to the LOP, (b) All NGLs allocated to the well shall be allocated to the POP, (c) Gas shall be allocated to the POP and LOP based on the following formulas; i. Prudhoe Formation Gas Rate = Total Gas Rate — Lisburne Formation Gas Rate ii. Lisburne Formation Gas Rate = allocated oil rate x Lisburne Oil Pool Solution Gas Oil Ratio iii. Lisburne Oil Pool Solution Gas Oil Ratio = 863 scf/stbo DONE at Anchorage, Alaska and dated April 22, 2019. Daniel T. Se t, Jr. Je e L. Chmielowski Commissioner qlunissioner 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 maybe 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 tan is not included in the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00 p.m. on the next day that does not fall on a weekend or state holiday. Bernie Karl K&K Recycling Inc. P.O. Box 58055 Fairbanks, AK 99711 George Vaught, Jr. P.O. Box 13557 Denver, CO 80201-3557 Gordon Severson 3201 Westmar Cir. Anchorage, AK 99508-4336 Darwin Waldsmith P.O. Box 39309 Ninilchik, AK 99639 Penny Vadla 399 W. Riverview Ave. Soldotna, AK 99669-7714 Richard Wagner P.O. Box 60868 Fairbanks, AK 99706 THE STATE °fALASKA GOVERNOR MIKE DUNLEAVY Ms. Katrina Garner Alaska Oil and Gas Conservation Commission ADMINISTRATIVE APPROVAL CONSERVATION ORDER NO. 207C.001 West Area Manager, Reservoir Management, Prudhoe Bay Unit BP Exploration (Alaska) Inc. 900 East Benson Boulevard P.O. Box 196612 Anchorage, AK 99519-6612 Re: Docket Number: CO -19-024 333 west Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907.279.1433 Fax: 907.276.7542 www.aogcc.alaska.gov Request for a spacing exception by Administrative Approval under Conservation Order 207C to allow drilling, completion, and production of the Prudhoe Bay Unit L5-07 development oil well within the same governmental quarter sections as wells that are, or may be capable of, producing from the same pool. Prudhoe Bay Unit L5-07 (PTD 219-102) Prudhoe Bay Field Lisburne Oil Pool Dear Ms. Garner: By application received December 11, 2019, BP Exploration (Alaska) Inc. (BPXA) requests a spacing exception by Administrative Approval under Conservation Order 207C (CO 207C) to allow drilling, completion, and production of the Prudhoe Bay Unit L5-07 development oil well (L5-07) within the same governmental quarter sections as wells that are, or may be capable of, producing from the same pool. FINDINGS: 1. The surface location for L5-07 will be in Section 2 of Ti 1N, R15E, Umiat Meridian (UM). L5- 07 will open the Lisburne Oil Pool in Section I 1 of TI IN, R15E, UM, and it will reach total depth in Section 15 of TI IN, R15E, UM. 2. BPXA is the operator for the Lisburne Oil Pool, affected State of Alaska Leases ADL028320, ADL034631, and ADL034631, and all surrounding leases. 3. CO 207C governs the Lisburne Oil Pool, and Rule 3 of that order establishes well spacing requirements for the pool. 4. Rule 3 specifies the well spacing unit for the pool shall be one producing well per governmental quarter section. Rule 3 also specifies no pay may be opened in a well closer than 1,000 feet to the pay opened in another well or opened in a well that is closer than 500 feet to the boundary of the Affected Area. 5. L5-07 will lie within the Affected Area of CO 207C. 6. L5-07 will be open to the Lisburne Oil Pool more than 1,000 feet from the nearest well open to the same pool. 7. L5-07 will be located more than 500 feet from the boundary of the Affected Area of CO 207C. CO 207C-001 January 22, 2020 Page 2 of 2 8. L5-07 will be open to the Lisburne Oil Pool within the same governmental quarter section as a producing well—L3-12—open to the same pool. 9. BPXA's selected trajectory for L5-07 through the Lisburne reservoir is necessary to access un- drained reserves that cannot be reached by wells conforming to applicable spacing requirements. 10. Rule 17 of CO 207C allows the AOGCC to administratively waive the requirements of any rule stated therein or to administratively amend CO 207C as long as the change does not promote waste or jeopardize correlative rights, is based on sound engineering and geoscience principles, and will not result in an increased risk of fluid movement into freshwater aquifers. BPXA's plan for L5-07 meets these criteria. CONCLUSIONS: 1. An exception to the well spacing requirements of Rule 3 of CO 207C is necessary to allow drilling, completion, and production of the L5-07 development oil well to maximize resource recovery from the Lisburne Oil Pool. 2. A spacing exception to allow drilling, completion, and production of the L5-07 development oil well is consistent with sound engineering and geoscience principles, and it will not result in waste, jeopardize correlative rights of adjoining or nearby owners, or increase the risk of fluid movement into freshwater aquifers. NOW THEREFORE IT IS ORDERED: BPXA's December 11, 2019 application for an order granting an exception to the well spacing requirements of Rule 3 of Conservation Order No. 207C to allow drilling, completion, and production of the L5-07 development oil well is approved. BPXA may proceed as long as it complies with the terms of the Prudhoe Bay Unit agreement, applicable Alaska laws, and all other legal requirements. DONE at Anchorage, Alaska and dated January 22, 2020. J re0..1riceDani . Seamount, Jr. J sic L. Chmelowski °�mssioner Commissioner Ummissioner 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 atter which the designated period begins to ren 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. Carlisle, Samantha J (CED) From: Carlisle, Samantha J (CED) Sent: Wednesday, January 22, 2020 10:54 AM To: 'AOGCC Public Notices' Subject: Conservation Order 207C.001 Attachments: co207c.001.pdf Docket Number: CO -19-024 Request for a spacing exception by Administrative Approval under Conservation Order 207C to allow drilling, completion, and production of the Prudhoe Bay Unit L5-07 development oil well within the same governmental quarter sections as wells that are, or may be capable of, producing from the same pool. Prudhoe Bay Unit L5-07 (PTD 219-102) Prudhoe Bay Field Lisburne Oil Pool Samantha Carlisle Executive Secretary III Alaska Oil and Gas Conservation Commission 333 West 7u, Avenue Anchorage, AK 99501 (907) 793-1.223 COtiFIOENI 1AI 11Y N077C1: Mi e-maflm ssa„e,inehrdingurvaha<-hmuvta, contatinv intoem'rllon ITum hili Alaska O, I and tion Comnuasion (Kith( -C'), StnIt, of Alaska and Is for 1110 snlc uvn of Ilse mlvndod rccipient(s). It mav' centaIiI Confidential and/or privileged information. I'lle ummlhorved revieav, use or discloses, u1 such inftivuwtion may violate stole or look rtal Ina. II you at an unin to'] drot IrrlIncnt.,I t r -mail, please dulote it, without histsaviug or fonvar ioi}, it, and, so that the A0C(-Cis aware oY the mistake in srndiu}; it I() volt. ciniYlc1 Sannn,L9ra f ai bsle at (917 ) 793'1221or Srunantha.Carlisle«�'.ala�ka e��v. Bernie Karl K&K Recycling Inc. Gordon Severson Penny Vadla P.O. Box 58055 3201 Westmar Cir. 399 W. Riverview Ave. Fairbanks, AK 99711 Anchorage, AK 99508-4336 Soldotna, AK 99669-7714 George Vaught, Jr. Darwin Waldsmith Richard Wagner P.O. Box 13557 P.O. Box 39309 P.O. Box 60868 Denver, CO 80201-3557 Ninilchik, AK 99639 Fairbanks, AK 99706 M (D stip �ti c�� THE STATE °fALASKA GOVERNOR MIKE DUNLEAVY Ms. Katrina Garner Alaska Oil and Gas Conservation Commission ADMINISTRATIVE APPROVAL CONSERVATION ORDER NO. 207C.002 West Area Manager, Reservoir Management, Prudhoe Bay Unit BP Exploration (Alaska) Inc. P.O. Box 196612 Anchorage, AK 99519-6612 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907.279.1433 Fax: 907.276.7542 w .00gcc.alasko.gov Re: Docket Number: CO -19-025 Request for a spacing exception by Administrative Approval under Conservation Order No. 207C to allow drilling, completion, and production of the Prudhoe Bay Unit L3-26 development oil well within the same governmental quarter sections as wells that are, or may be capable of, producing from the same pool. Prudhoe Bay Unit L3-26 (PTD 220-015) Prudhoe Bay Field Lisburne Oil Pool Dear Ms. Garner: By application received December 05, 2019, BP Exploration (Alaska) Inc. (BPXA) requests a spacing exception by Administrative Approval under Conservation Order No. 207C (CO 207C) to allow drilling, completion, and production of the Prudhoe Bay Unit L3-26 development oil well (L3-26) within the same governmental quarter sections as wells that are, or may be capable of, producing from the same pool. FINDINGS: 1. The surface location for L3-26 will be in Section 22 of T1 IN, R15E, Umiat Meridian (UM). L3-26 will open the Lisburne Oil Pool in Section 22 of TI IN, RI 5E, UM, and it will reach total depth in Section 23 of TI 1N, R15E, UM. 2. BPXA is the operator for the Lisburne Oil Pool, affected State of Alaska Leases ADL028322, ADL028323, and all surrounding leases. 3. CO 207C governs the Lisburne Oil Pool, and Rule 3 of that order establishes well spacing requirements for the pool. 4. Rule 3 specifies the well spacing unit for the pool shall be one producing well per governmental quarter section. Rule 3 also specifies no pay may be opened in a well closer than 1,000 feet to the pay opened in another well or opened in a well that is closer than 500 feet to the boundary of the Affected Area. 5. L3-26 will lie within the Affected Area of CO 207C. CO 207C-001 February 5, 2020 Page 2 of 3 6. L3-26 will be open to the Lisburne Oil Pool more than 1,000 feet from the nearest well open to the same pool. 7. L3-26 will be located more than 500 feet from the boundary of the Affected Area of CO 207C. 8. L3-26 will be open to the Lisburne Oil Pool within the same governmental quarter section as a producing well—L3-24—open to the same pool. 9. BPXA's selected trajectory for L3-26 through the Lisburne reservoir is necessary to access undrained reserves that cannot be reached by wells conforming to applicable spacing requirements. 10. Rule 17 of CO 207C allows the AOGCC to administratively waive the requirements of any rule stated therein or to administratively amend CO 207C as long as the change does not promote waste or jeopardize correlative rights, is based on sound engineering and geoscience principles, and will not result in an increased risk of fluid movement into freshwater aquifers. BPXA's plan for L3-26 meets these criteria. CONCLUSIONS: 1. An exception to the well spacing requirements of Rule 3 of CO 207C is necessary to allow drilling, completion, and production of the L3-26 development oil well to maximize resource recovery from the Lisburne Oil Pool. 2. A spacing exception to allow drilling, completion, and production of the L3-26 development oil well is consistent with sound engineering and geoscience principles, and it will not result in waste, jeopardize correlative rights of adjoining or nearby owners, or increase the risk of fluid movement into freshwater aquifers. NOW THEREFORE IT IS ORDERED: BPXA's December 05, 2019 application for an order granting an exception to the well spacing requirements of Rule 3 of Conservation Order No. 207C to allow drilling, completion, and production of the L3-26 development oil well is approved. BPXA may proceed as long as it complies with the terms of the Prudhoe Bay Unit agreement, applicable Alaska laws, and all other legal requirements. DONE at Anchorage, Alaska and dated February 5, 2020. J Price Daniel T. Seamount, Jr.J s� ie L. Chair, Commissioner Commissioner Commiss CO 207C-001 February 5, 2020 Page 3 of 3 RECONSIDERATION 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 daze 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. Bernie Karl K&K Recycling Inc. P.O. Box 58055 Fairbanks, AK 99711 George Vaught, Jr. P.O. Box 13557 Gordon Severson 3201 Westmar Cir. Anchorage, AK 99508-4336 Darwin Waldsmith P.O. Box 39309 Penny Vadla 399 W. Riverview Ave. Soldotna, AK 99669-7714 Richard Wagner P.O. Box 60868 Denver, CO 80201-3557 Ninilchik, AK 99639 Fairbanks, AK 99706 TI IE STATE °ALASKA GOVERNOR MICHAEL 1. DUNLEAVY Ms. Katrina Garner Alaska Oil and Gas Conservation Commission ADMINISTRATIVE APPROVAL CONSERVATION ORDER NO. 207C.003 West Area Manager, Reservoir Management, Prudhoe Bay Unit BP Exploration (Alaska) Inc. 900 East Benson Boulevard P.O. Box 196612 Anchorage, AK 99519-6612 Re: Docket Number: CO -19-026 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907.279.1433 Fax: 907.276.7542 www.aogcc.a laska.gov Request for a spacing exception by Administrative Approval under Conservation Order No. 207C to allow drilling, completion, and production of the Prudhoe Bay Unit K-322 development oil well within the same governmental quarter sections as wells that are, or may be capable of, producing from the same pool. Prudhoe Bay Unit K-322 (PTD 220-029) Prudhoe Bay Field Lisburne Oil Pool Dear Ms. Garner: By application received December 05, 2019, BP Exploration (Alaska) Inc. (BPXA) requests a spacing exception by Administrative Approval under Conservation Order No. 207C (CO 207C) to allow drilling, completion, and production of the Prudhoe Bay Unit K-322 development oil well (K-322) within the same governmental quarter sections as wells that are, or may be capable of, producing from the same pool. FINDINGS: 1. The surface location for K-322 will be in Section 04 of TI IN, R14E, Umiat Meridian (UM). K-322 will open the Lisburne Oil Pool in Section 04 of TI IN, R14E, UM, and it will reach total depth in Section 34 of TI 2N, R14E, UM. 2. BPXA is the operator for the Lisburne Oil Pool, affected State of Alaska Leases ADL028303, ADL028300, and all surrounding leases. 3. CO 207C governs the Lisburne Oil Pool, and Rule 3 of that order establishes well spacing requirements for the pool. 4. Rule 3 specifies the well spacing unit for the pool shall be one producing well per governmental quarter section. Rule 3 also specifies no pay may be opened in a well closer than 1,000 feet to the pay opened in another well or opened in a well that is closer than 500 feet to the boundary of the Affected Area. 5. K-322 will lie within the Affected Area of CO 207C. CO 207C-001 March 31, 2020 Page 2 of 3 6. K-322 will be open to the Lisburne Oil Pool less than 1,000 feet from the nearest well open to the same pool. 7. K-322 will be located more than 500 feet from the boundary of the Affected Area of CO 207C. 8. K-322 will be open to the Lisburne Oil Pool within the same governmental quarter section as two producing wells—K-317B and K-333—both open to the same pool. 9. BPXA's selected trajectory for K-322 through the Lisburne reservoir is necessary to access undrained reserves that cannot be reached by wells conforming to applicable spacing requirements. 10. Rule 17 of CO 207C allows the AOGCC to administratively waive the requirements of any rule stated therein or to administratively amend CO 207C as long as the change does not promote waste or jeopardize correlative rights, is based on sound engineering and geoscience principles, and will not result in an increased risk of fluid movement into freshwater aquifers. BPXA's plan for K-322 meets these criteria. CONCLUSIONS: I . An exception to the well spacing requirements of Rule 3 of CO 207C is necessary to allow drilling, completion, and production of the K-322 development oil well to maximize resource recovery from the Lisburne Oil Pool. 2. A spacing exception to allow drilling, completion, and production of the K-322 development oil well is consistent with sound engineering and geoscience principles, and it will not result in waste, jeopardize correlative rights of adjoining or nearby owners, or increase the risk of fluid movement into freshwater aquifers. NOW THEREFORE IT IS ORDERED: BPXA's December 05, 2019 application for an order granting an exception to the well spacing requirements of Rule 3 of Conservation Order No. 207C to allow drilling, completion, and production of the K-322 development oil well is approved. BPXA may proceed as long as it complies with the terms of the Prudhoe Bay Unit agreement, applicable Alaska laws, and all other legal requirements. DONE at Anchorage, Alaska and dated March 31, 2020. Jeremy hmn/MY"¢ wre:zamuuol M. Price ° Daniel T. 1p"" ""9°`"°r wo�ar. s,—t a. Seamount Jr. °"eS030.°40l I P.1635MLtl Jessie L. Niwr�Mewa. L Chmielowski+"ro.o,,,,..::�mnd Jeremy M. Price Daniel T. Seamount, Jr. Jessie L. Chmielowski Chair, Commissioner Commissioner Commissioner CO 207C-001 March 31, 2020 Page 3 of 3 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 in 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. Bernie Karl K&K Recycling Inc. Gordon Severson Penny Vadla P.O. Box 58055 3201 Westmar Cir. 399 W. Riverview Ave. Fairbanks, AK 99711 Anchorage, AK 99508-4336 Soldotna, AK 99669-7714 George Vaught, Jr. P.O. Box 13557 Denver, CO 80201-3557 Darwin Waldsmith P.O. Box 39309 Ninilchik, AK 99639 Richard Wagner P.O. Box 60868 Fairbanks, AK 99706 INDEXES by 0 BP Exploration (Alaska; Inc. 930 East Benson Boulevard P G Box 196612 Anchorage, Alaska 99519-6612 (907) 561 5.11 December 5, 2019 Mr. Jeremy Price, Chair Alaska Oil and Gas Conservation Commission 333 West 7d Ave, Suite 100 Anchorage, AK 99501 RE: Prudhoe Bay Unit Lisburne Oil Pool Spacing Exception Applications Six Lisburne Development Oil Wells Dear Chair Price: BP Exploration (Alaska), Inc (BPXA), as operator of the Prudhoe Bay Unit, requests that the Commission grant spacing exceptions via Administrative Approval for 6 upcoming Lisburne Oil Pool wells: L5-07, L3-26, K322, K-333, Ll -13L1, L1-01LL CO 207B Rule 3 states "The well spacing unit shall be one producing well per governmental quarter section. No pay may be opened in a well closer than 1,000 feet to the pay opened in another well or opened in a well which is closer than 500 feet to the boundary of the affected area". BPXA respectfully submits that approving the requested exception to the one producing well per governmental quarter section spacing requirement & 1000' rule, as applicable, of CO 207B Rule 3 would promote a greater ultimate recover of hydrocarbon resources by providing access to resources that otherwise may not be recovered under the existing rules. Four of the six proposed wells require governmental quarter section exceptions while 2 require both governmental quarter section and I000'exceptions to Rule 3. On November 19, 2019, BPXA representatives met with AOGCC staff members to review confidential geological maps for each of these spacing exceptions. BPXA explanations for wanting to drill within the quarter section or 1000' limitations received a positive reception from AOGCC staff. Lease maps showing the trajectory of the proposed wells were left with the commission staff as documentation to this application. BPXA is requesting exceptions for the six wells as explained in the tables below. Each well is summarized by its name, surface and TD ADL lease number, Section, Township, Range and the ADL lease number, Section, Township, Range and the quarter section that ss- tb a �.i wuY wu Y Pr DEC 1 1 2019 AOGCC Mr. Jeremy Price, Chair PBU: Application for 6 Lisburne Oil Pool Spacing Exceptions December 5, 2019 its trajectory will have interaction with another well, or is closer than 1000'. In all cases, BPXA is the operator of the affected lease and all surrounding leases; there are no property boundaries within 500' of the wells. In all cases the chosen Lisburne reservoir trajectory is more than 500' from the external boundary of the Affected Area of the Lisburne Oil Pool. Governmental Quarter Section exceptions L5-07 Surface TD Lease ADL028320 ADL028322 Section UO11N015E02 UO11N015E15 1/4 section SE NE L5-07 Lisburne trajectory Interaction Lease AD 028320 Section U011N015EII LA section NW L5-03 Lease ADL028320 Section UO1IN015EIl 1/4 section SW L5-08 Lease ADL02832 Section U011N015E15 1/4 section NE L3-12 L3-26 Surface TD Lease ADL028322 ADL028323 Section UO11N015E22 U011N015E23 1/4 section NW SE L3-26 Lisburne trajectory Interaction Lease ADL028323 Section UO11N015E23 1/4 section SW L3-24 K322 Surface TD Lease ADL028303 ADL028300 Section UO11N014E04 U012N014E34 1/4 section NW SW K322 Lisburne trajectory Interaction Lease ADL028303 Section UO11N014E04 1/4 section NE I K317B Mr. Jeremy Price, Chair PBU: Application for 6 Lisburne Oil Pool Spacing Exceptions December 5, 2019 Governmental Quarter Section exceptions (cont'd) 1333 Surface TD Lease ADL028303 ADL028303 Section UO11N014E04 U011NOl4El0 I/4 section NW NW 1333 Section Interaction Lease ADL028303 1/4 section Section U011N014E03 1/4 section NW K322 Governmental Quarter Section and 1000' exceptions L1 -13L1 Surface TD Lease ADL028302 ADL028303 Section UO11N014E01 UO1lN014E10 1/4 section SW SE L1 -13L1 Lisburne trajectory Interaction Lease ADL028302 Section U011N014E10 1/4 section NE L1-13 L1 -01L1 Surface TD LeaseADL028302 ADL028307 Section UO11N014E01 UO11N0ME13 1/4 section SW NW L101L1 Lisburne trajectory Interaction Lease ADL028302 Section UO11N014E12 1/4 section SW Ll -01 Mr. Jeremy Price, Chair PBU: Application for 6 Lisburne Oil Pool Spacing Exceptions December 5, 2019 These requested exceptions do not promote waste or jeopardize correlative rights, promote greater ultimate recovery, and are based on sound engineering and geoscience principles, and will not result in an increased risk of fluid movement into freshwater aquifers. If you have any questions regarding these requests please contact Bill Bredar at 564-5348 or through email at William.bredar@bp.com. Respectfully, Katrina Garner West Area Manager/Reservoir Management, Prudhoe Bay Unit Alaska Reservoir Development, BPXA Cc: Jon Schultz, ConocoPhillips Alaska, Inc Jeff Farr, ExxonMobil Alaska, Production Inc Dave White, Chevron USA Dave Roby, AOGCC by z BP ExoloraM1rn (Alaska; Inc. 9a5 East Benson Poulevard P G Box 1966'2 Anchorage, Alaska 99519-6612 (907) 561 5.11 December 5, 2019 Mr. Jeremy Price, Chair Alaska Oil and Gas Conservation Commission 333 West 7s' Ave, Suite 100 Anchorage, AK 99501 RE: Prudhoe Bay Unit Lisburne Oil Pool Spacing Exception Applications Six Lisburne Development Oil Wells Dear Chair Price: BP Exploration (Alaska), Inc (BPXA), as operator of the Prudhoe Bay Unit, requests that the Commission grant spacing exceptions via Administrative Approval for 6 upcoming Lisburne Oil Pool wells: L5-07, L3-26, K322, K-333, Ll -13L1, L1 -01L1. CO 207B Rule 3 states "The well spacing unit shall be one producing well per governmental quarter section. No pay may be opened in a well closer than 1,000 feet to the pay opened in another well or opened in a well which is closer than 500 feet to the boundary of the affected area". BPXA respectfully submits that approving the requested exception to the one producing well per governmental quarter section spacing requirement & 1000' rule, as applicable, of CO 207B Rule 3 would promote a greater ultimate recover of hydrocarbon resources by providing access to resources that otherwise may not be recovered under the existing rules. Four of the six proposed wells require governmental quarter section exceptions while 2 require both governmental quarter section and 1000'exceptions to Rule 3. On November 19, 2019, BPXA representatives met with AOGCC staff members to review confidential geological maps for each of these spacing exceptions. BPXA explanations for wanting to drill within the quarter section or 1000' limitations received a positive reception from AOGCC staff. Lease maps showing the trajectory of the proposed wells were left with the commission staff as documentation to this application. BPXA is requesting exceptions for the six wells as explained in the tables below. Each well is summarized by its name, surface and TD ADL lease number, Section, Township, Range and the ADL lease number, Section, Township, Range and the quarter section that 6. DEC 11 2019 Aoccc Mr. Jeremy Price, Chair PBU: Application for 6 Lisburne Oil Pool Spacing Exceptions December 5, 2019 its trajectory will have interaction with another well, or is closer than 1000'. In all cases, BPXA is the operator of the affected lease and all surrounding leases; there are no property boundaries within 500' of the wells. In all cases the chosen Lisburne reservoir trajectory is more than 500' from the external boundary of the Affected Area of the Lisburne Oil Pool. Governmental Quarter Section exceptions L5-07 Surface TD Lease ADL028320 ADL028322 Section UO11N015E02 UO11N015E15 1/4 section SE NE L5-07 Lisburne trajectory Interaction Lease ADL028320 Section U01IN015EII 1/4 section NW L5-03 Lease ADL028320 Section UO1IN015EII 1/4 section SW L5-08 Lease ADL02832 Section U011N015E15 1/4 section NE L3-12 L3-26 Surface TD Lease ADL028322 ADL028323 Section U011N015E22 UO11N015E23 1/4 section NW SE L3-26 Lisburne trajectory Interaction Lease ADL028323 Section UO11N015E23 1/4 section SW L3-24 K322 Surface TD Lease ADL028303 ADL028300 Section UO11N014E04 U012N014E34 1/4 section I NW SW K322 Lisburne trajectory Interaction Lease AD 028303 Section UOIIN0I4E04 1/4 section NE K317B Mr. Jeremy Price, Chair PBU: Application for 6 Lisburne Oil Pool Spacing Exceptions December 5, 2019 Governmental Quarter Section exceptions (cont'd) K333 Surface TD Lease ADL028303 ADL028303 Section UO11N0WE04 U011N014E10 1/4 section NW NW K333 Section Interaction Lease ADL028303 1/4 section Section U011N014E03 1/4 section NW KM Governmental Quarter Section and 1000' exceptions Ll -13L1 Surface TD Lease ADL028302 ADL028303 Section U011N014E01 U011N014E10 1/4 section SW SE Ll -13L1 Lisburne trajectory Interaction Lease ADL028302 Section U011N014E10 1/4 section NE L1-13 Ll-0IL1 Surface TD Lease ADL028302 ADL028307 Section U01IN014E01 UO1IN014E13 1/4 section SW NW L101Ll Lisburne trajectory Interaction Lease ADL028302 Section U011N014E12 1/4 section SW Ll -01 Mr. Jeremy Price, Chair PBU: Application for 6 Lisburne Oil Pool Spacing Exceptions December 5, 2019 These requested exceptions do not promote waste or jeopardize correlative rights, promote greater ultimate recovery, and are based on sound engineering and geoscience principles, and will not result in an increased risk of fluid movement into freshwater aquifers. If you have any questions regarding these requests please contact Bill Bredar at 564-5348 or through email at William.bredar@bp.com. Respectfully, Katrina Garner West Area Manager/Reservoir Management, Prudhoe Bay Unit Alaska Reservoir Development, BPXA Cc: Jon Schultz, ConocoPhillips Alaska, Inc Jeff Farr, ExxonMobil Alaska, Production Inc Dave White, Chevron USA Dave Roby, AOGCC by 0 BP Exploration (Alaska; Inc 9J6 East Benson Boulevard PC Box 196612 Anchorage, Alaska 99519-6612 (967) 565-5.11 December 5, 2019 Mr. Jeremy Price, Chair Alaska Oil and Gas Conservation Commission 333 West Ph Ave, Suite 100 Anchorage, AK 99501 RE: Prudhoe Bay Unit Lisburne Oil Pool Spacing Exception Applications Six Lisburne Development Oil Wells Dear Chair Price: BP Exploration (Alaska), Inc (BPXA), as operator of the Prudhoe Bay Unit, requests that the Commission grant spacing exceptions via Administrative Approval for 6 upcoming Lisburne Oil Pool wells: L5-07, L3-26, K322, K-333, Ll -13L1, Ll-01LL CO 207B Rule 3 states "The well spacing unit shall be one producing well per governmental quarter section. No pay may be opened in a well closer than 1,000 feet to the pay opened in another well or opened in a well which is closer than 500 feet to the boundary of the affected area". BPXA respectfully submits that approving the requested exception to the one producing well per governmental quarter section spacing requirement & 1000' rule, as applicable, of CO 207B Rule 3 would promote a greater ultimate recover of hydrocarbon resources by providing access to resources that otherwise may not be recovered under the existing rules. Four of the six proposed wells require governmental quarter section exceptions while 2 require both governmental quarter section and 1000'exceptions to Rule 3. On November 19, 2019, BPXA representatives met with AOGCC staff members to review confidential geological maps for each of these spacing exceptions. BPXA explanations for wanting to drill within the quarter section or 1000' limitations received a positive reception from AOGCC staff. Lease maps showing the trajectory of the proposed wells were left with the commission staff as documentation to this application. BPXA is requesting exceptions for the six wells as explained in the tables below. Each well is summarized by its name, surface and TD ADL lease number, Section, Township, Range and the ADL lease number, Section, Township, Range and the quarter section that DEC 11 2019 AOGCC Mr. Jeremy Price, Chair PBU: Application for 6 Lisburne Oil Pool Spacing Exceptions December 5, 2019 its trajectory will have interaction with another well, or is closer than 1000'. In all cases, BPXA is the operator of the affected lease and all surrounding leases; there are no property boundaries within 500' of the wells. In all cases the chosen Lisburne reservoir trajectory is more than 500' from the external boundary of the Affected Area of the Lisburne Oil Pool. Governmental Quarter Section exceptions L5-07 Surface TD Lease ADL028320 ADL028322 Section U011N015E02 U011N015E15 1/4 section SE NE L5-07 Lisburne trajectory Interaction Lease ADL028320 Section UO1IN015EII 1/4 section NW L5-03 Lease ADL028320 Section UO11N015E11 1/4 section SW L5-08 Lease ADL02832 Section U011N015E15 1/4 section NE L3-12 L3-26 Surface TD Lease ADL028322 ADL028323 Section UO11N015E22 UO11N015E23 1/4 section NW SE L3-26 Lisburne trajectory Interaction Lease ADL028323 Section UO11N015E23 1/4 section SW L3-24 K322 Surface TD Lease ADL028303 ADL028300 Section UO11N014E04 U012N014E34 1/4 section NW SW K322 Lisburne trajectory Interaction LeaseADL028303 Section UO11N014E04 1/4 section I NE K317B Mr. Jeremy Price, Chair PBU: Application for 6 Lisburne Oil Pool Spacing Exceptions December 5, 2019 Governmental Quarter Section exceptions (cont'd) K333 Surface TD Lease ADL028303 ADL028303 Section U01IN014E04 U011N014E10 1/4 section NW NW K333 Section Interaction Lease ADL028303 1/4 section Section U011N014E03 1/4 section NW K322 Governmental Quarter Section and 1000' exceptions L1 -13L1 Surface TD Lease ADL028302 ADL028303 Section U011N014E0I UO11N014E10 1/4 section SW SE LI -13L1 Lisburne trajectory Interaction Lease ADL028302 Section UO11N014E10 1/4 section NE L1-13 L1-0IL1 Surface TD Lease ADL028302 ADL028307 Section UO1IN014E01 UO11N014E13 1/4 section SW NW L101L1 Lisburne trajectory Interaction Lease ADL028302 Section UO1IN014EI2 1/4 section SW LI -01 Mr. Jeremy Price, Chair PBU: Application for 6 Lisburne Oil Pool Spacing Exceptions December 5, 2019 These requested exceptions do not promote waste or jeopardize correlative rights, promote greater ultimate recovery, and are based on sound engineering and geoscience principles, and will not result in an increased risk of fluid movement into freshwater aquifers. If you have any questions regarding these requests please contact Bill Bredar at 564-5348 or through email at William.bredar@bp.com. Respectfully, Katrina Gamer West Area Manager/Reservoir Management, Prudhoe Bay Unit Alaska Reservoir Development, BPXA Cc: Jon Schultz, ConocoPhillips Alaska, Inc Jeff Farr, ExxonMobil Alaska, Production Inc Dave White, Chevron USA Dave Roby, AOGCC 2 Notice of Public Hearing STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION Re: Docket Number: CO -18-025 Prudhoe Bay Unit, Prudhoe and Lisburne Oil Pools The application of BP Exploration (Alaska) Inc (BPXA) for an order in accordance with 20 AAC 25.215 authorizing the downhole commingling of production in the wellbore of the Prudhoe Bay Unit L5-21 (PBU L5-21) well. BPXA, by letter dated August 22, 2018, requests the Alaska Oil and Gas Conservation Commission (AOGCC) issue an order in accordance with 20 AAC 25.215 to authorize the downhole commingling of production from the Prudhoe and Lisburne Oil Pools in the PBU L5-21 well. The AOGCC has tentatively scheduled a public hearing on this application for December 19, 2018, at 11:00 a.m. at 333 West 7`h Avenue, Anchorage, Alaska 99501. To request that the tentatively scheduled hearing be held, a written request must be filed with the AOGCC no later than 4:30 p.m. on December 2, 2018. If a request for a hearing is not timely filed, the AOGCC may consider the issuance of an order without a hearing. To learn if the AOGCC will hold the hearing, call (907) 793-1221 after December 4, 2018. In addition, written comments regarding this application may be submitted to the AOGCC, at 333 West 7`h Avenue, Anchorage, Alaska 99501. Comments must be received no later than 4:30 p.m. on December 18, 2018, except that, if a hearing is held, comments must be received no later than the conclusion of the December 19, 2018 hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, contact the AOGCC's Special Assistant, Jody Colombie, at (907) 793-1221, no later than December 17, 2018. Hollis S. French Chair, Commissioner Notice of Public Hearing STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION Re: Docket Number: CO -18-025 Prudhoe Bay Unit, Prudhoe and Lisburne Oil Pools The application of BP Exploration (Alaska) Inc (BPXA) for an order in accordance with 20 AAC 25.215 authorizing the downhole commingling of production in the wellbore of the Prudhoe Bay Unit L5-21 (PBU L5-21) well. BPXA, by letter dated August 22, 2018, requests the Alaska Oil and Gas Conservation Commission (AOGCC) issue an order in accordance with 20 AAC 25.215 to authorize the downhole commingling of production from the Prudhoe and Lisburne Oil Pools in the PBU L5-21 well. The AOGCC has tentatively scheduled a public hearing on this application for December 19, 2018, at 11:00 a.m. at 333 West 7a' Avenue, Anchorage, Alaska 99501. To request that the tentatively scheduled hearing be held, a written request must be filed with the AOGCC no later than 4:30 p.m. on December 2, 2018. If a request for a hearing is not timely filed, the AOGCC may consider the issuance of an order without a hearing. To learn if the AOGCC will hold the hearing, call (907) 793-1221 after December 4, 2018. In addition, written comments regarding this application may be submitted to the AOGCC, at 333 West 7s' Avenue, Anchorage, Alaska 99501. Comments must be received no later than 4:30 p.m. on December 18, 2018, except that, if a hearing is held, comments must be received no later than the conclusion of the December 19, 2018 hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, contact the AOGCC's Special Assistant, Jody Colombie, at (907) 793-1221, no later than December 17, 2018. //signature on file// Hollis S. French Chair, Commissioner STATE OF ALASKA ADVERTISING ORDER NOTICE TO PUBLISHER SUBMIT INVOICE SHOWING ADVERTISING ORDER NO.,CERTIFIED AFFIDAVIT OF PUBLICATION WITH ATTACHED COPY OF ADVERTISMENT. ADVERTISING ORDER NUMBER s� AO'I9'OIS FROM: AGENCY CONTACT: Jody Colombie/Samantha Carlisle Alaska Oil and Gas Conservation Commission DATE OF A.O.AGENCY PHONE: 333 West 7th Avenue 11/16/2018 (907) 279-1433 Anchorage, Alaska 99501 DATES ADVERTISEMENT REQUIRED: COMPANY CONTACT NAME: PHONE NUMBER: ASAP FAX NUMBER: (907) 276-7542 TO PUBLISHER: Anchorage Daily News, LLC SPECIAL INSTRUCTIONS: PO Box 140147 Anchorage, Alaska 99514-0174 TYPE OF ADVERTISEMENT: r LEGAL f DISPLAY W CLASSIFIED r OTHER (Specify below) DESCRIPTION PRICE CO-18-025 Initials of who prepared AO: Alaska Non -Taxable 92-600185 $0 BMITIPivotC4SDoW11NG:9P RTI5119G. >.:ORDERNO;, GER'hl{IIEb gFGIUANTdP!< >►UELICAT}ON:N'iTHq'iTwCHE6COP1'OP> ADVER'1'LSMENRTO,.. AOGCC 333 West 7th Avenue Anchorage, Alaska 99501 Pae 1 of 1 Total of All Pa es $ REF Type Number Amount Date Comments 1 PVN IVC 191711 2 Ao AO-19-015 3 4 FIN AMOUNT SY Act. Template I PGM LGR Object FY I DIST LIQ 1 19 A14100 3046 19 2 3 4 5 Purcha g thPurchasing Title: Authority's Signature Telephone Number 1. rw?W4 agency ame muo,21Ipear on all invoices and documents relating to this purchase. 2. h state Is registered for tax free transacticrder Chapter 32, IRS code. Registration number 92-73-0006 K. Items are for the eaclusive use of the state and not for re i)R1BU�F30N Div non Flsed. t rlgmal AO Ctiple; 'PubhCher.lfgxsdj, a)iJisitin Fiscal Receiving::: Form: 02-901 Revised: 11/16/2018 Bernie Karl K&K Recycling Inc. P.O. Box 58055 Fairbanks, AK 99711 George Vaught, Jr. P.O. Box 13557 Denver, CO 80201-3557 Gordon Severson 3201 Westmar Cir. Anchorage, AK 99508-4336 Darwin Waldsmith P.O. Box 39309 Ninilchik, AK 99639 Penny Vadla 399 W. Riverview Ave. Soldotna, AK 99669-7714 Richard Wagner P.O. Box 60868 Fairbanks, AK 99706 ANCHOWNGE MAN NEWS AFFIDAVIT OF PUBLICATION Account#: 270227 ST OF AK/AK OILAND GAS Cost CONSERVATION COMMISSION Cost 333 WEST 7TH AVE STE 100 aurrunoar-c av oosmaFoo STATE OF ALASKA THIRD JUDICIAL DISTRICT Sarah Jennett being first duly sworn on oath deposes and says that he/she is a representative of the Anchorage 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 aforesaid place of publication of said newspaper. That the annexed is a copy of an advertisement as it was published in regular issues (and not in supplemental form) of said newspaper on November 18, 2018 and that such newspaper was regularly distributed to its subscribers during all of said period. That the full amount of the fee charged for the fo gojng publication is not in excess of the rete c d private individuals. Signed Jennett ed and sworn to before me this/19th day of Novemblif, 2018 Notary Public In and for The State bfAlaska. Third Division Anchorage, Alaska MY COMMISSION EXPI Notary Public BRITNEY L. THOMPSON State of Alaska My Commission Expires Feb 23, 2019 0001430663 Product ADN -Anchorage Daily News $234.08 Placement 0300 Position 0301 STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION Re: Docket Number: CO -18-025 Prudhoe Bay unit, Prudhoe and Lisburne Oil Pools The application of BP Exploration (Alaska) Inc (SPXA) for an order in accordance with 20 AAC 25.215 authorizing the downhole commingling ofproduction in the Wellbore of the Prudhoe Bay Unit 1.5-21 (PBU 15-21) well. BPXA, by letter dated August 22, 2018, requests the Alaska Oil and Gas Conservation Commission (AOGCC) issue an order in accordance with 20 AAC 25.215 to authorize the downhole commiegling of production from the Prudhoe and Lisburne Oil Pools in the PBU 15-21 well. The AOGCC has tentatively scheduled a public hearing on this application for December 19, 2018, at 11:00 a.m. at 333 West 7th Avenue, Anchora�ea, Alaska 99501. To request that the tentatively wiitth the AOGCC hearing er thaheld, 30 p.m. written on Decembber 22,, 2018. If a request for a hearing is not timely filed, the AOGCC mayy consider the issuance of an order without a hearing. To learn if the AOGCC will hold the hearing, call (907) 793-1221 after December 4, 2018. In addition, written comments regarding this application may be submitted to the AOGCC, at 333- West 7th Avenue, Anchorage, Alaska 99501. Comments must be received no later than 4:30 P6' on December 18, 2018, except that, if a hearing is held, comments must be received no later than the conclusion of the December 19, 2018 hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, contact the AOGCC's Special Assistant, Jody Colombia, at (907)%3-1221, no later than December 17, 2018 //signature on file// Hollis S. French Chair, Commissioner 1 3 August 22, 2018 Hollis French, Chair Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, AK 99501 B:' Exploration !Alaska; Inc 979 East Benson Boa•avard P O Box 196612 Ancho'age..A aska 99519-66'1 (907) 5615111 RECEIVED AUG 2 4 2018 AOGCC RE: Application for Administrative Approval to Commingle Production from Lisburne Oil Pool (CO 207B) and Prudhoe Oil Pool (CO 341F) in Prudhoe Bay Unit well L5-21 Dear Chair French: BP Exploration (Alaska) Inc. (BPXA), as the Operator of the Prudhoe Bay Unit which includes the Lisburne Oil Pool (LOP) and the Prudhoe Oil Pool (POP), respectfully requests that the commission administratively approve commingling of production from the Lisburne Oil Pool and Prudhoe Oil Pool in well L5-21 which produces to the Lisburne Production Center (LPC). The commission previously approved downhole commingling of production of the POP and the LOP in the proposed K-322 well (CO 721). L5-21 is an existing well that produces exclusively from the Lisburne Wahoo Formation. Planned add-perfs into the Ivishak Oil Pool would be commingled with Lisburne Oil Pool fluids and produced up L5 -21's tubing to the LPC. Well integrity is not expected to be compromised with the addition of these perforations. L5-21 would be perforated in the Prudhoe Oil Pool to allow Prudhoe gas to serve as in-situ artificial lift for the Lisburne production and capture high liquid yield gas production from a part of the Ivishak Oil Pool that would not otherwise be produced. The proposed completion for L5-21 is shown in Exhibit A. Additional information in support of this application is included below. BPXA staff are available should you have any questions or need any additional information. If you need any additional information, please contact Bill Bredar at 564- 5348. Sincerely, Diane Richmond Attachment: Exhibit A - L5-21 Wellbore Schematic Cc: Mr. Eric Reinhold, ConocoPhillips Alaska, Inc. Mr. Doug Sturgis, ExxonMobil Alaska, Production Inc. Mr. Jeffery Farr, ExxonMobil Alaska, Production Inc. Mr. Dave White, Chevron USA Jenny Jemison Carl Lundgren Frank Paskvan Bill Bredar Additional Information in Support of Application Introduction Commingling of production within the same well -bore from two pools is permitted under 20 AAC 25.215(b) if the Commission, after notice and opportunity for public hearing, "(1) finds that waste will not occur, and that production from separate pools can be properly allocated; and (2) issues an order providing for commingling for wells completed from these pools within the field." Waste Will Not Occur 1. Production Considerations Surveillance and appraisal activities in the POP identified the presence of rich gas condensate in sections of the original gas cap up -dip from POP lean gas re-injection wells. Further development of these portions of the POP has not been pursued due to the lack of offtake points in the area. Several wells exist that penetrate and could be completed in both the POP and the LOP. By commingling production from the two pools within the same well -bore, the fluid rate and velocity in the tubing can be increased, resulting in improved lift efficiency. Consequently, commingling of production from the POP and LOP within the same well- bore will not cause waste, but rather will allow for recovery of a greater quantity of oil and gas condensate from both the POP and LOP. 2. Cross flow Based on the reservoir fluids in the POP and LOP, fluid incompatibility and formation damage due to commingling and crossflow is not expected. If changes to produced fluid compositions or ratios result in potential fluid incompatibility, chemical inhibition to prevent productivity degradation would be evaluated. Crossflow associated with short term shut in periods under typical operations are not anticipated to result in significant volume flowing between pools or to adversely impact reservoir management. Reservoir pressure is not expected to be substantially different between the two pools with the local LOP pressure most recently measured at 3647 psig (8900' TVDSS datum) and the local POP estimated to be at approximately 3664 psig (8800' TVDSS datum). Reservoir permeability between pools is also expected to be similar with a calculated LOP L5-21 average perm of 26 mD for the currently open perforations and an estimated POP L5-21 perm of 190 mD for the proposed zone to be perforated. Crossflow of significant volume between pools in commingled wells that experience extended shut in periods could be prevented through mechanical isolation of the pools which would require additional well intervention cementing activity. Appropriate Surveillance and Production Allocation Will Be Assured Appropriate surveillance and production allocation measures will be undertaken to meet reservoir management objectives and to provide an acceptable allocation methodology. 1. Production Allocation With all anticipated offtake from the POP occurring in the original gas cap and LOP offtake occurring in the original oil column BPXA proposed using the following production allocation methodology: 100% of all NGLs will be allocated to POP, 100% of oil and water will be allocated to the LOP. Produced gas will be allocated to POP minus LOP gas calculated at a solution GOR of 836 scf/stb or less as needed to keep the POP gas volume from dropping below zero. Gas Allocation Equation: Prudhoe Formation Gas Rate = Total Gas Rate — Lisburne Formation Gas Rate Lisburne Formation Gas Rate = Allocated Oil Rate * Lisburne Oil Pool Solution Gas Oil Ratio Lisburne Oil Pool Solution Gas Oil Ratio = 836 scf/stbo 2. Reservoir Surveillance If necessary differential production rates from the LOP and POP can be measured via cased hole production logging. If mechanical isolation of the two pools became necessary options to do so exist using through -wellbore cementing techniques. Conclusion BP requests approval for wellbore commingling of production from the Lisburne Oil Pool (LOP) and the Prudhoe Oil Pool (POP) in well L5-21. BPXA respectfully submits that this activity will not cause waste, will promote conservation through greater ultimate recovery of oil and gas resources by allowing increased recovery from the POP. Produced liquids and gas from the separate pools can be properly allocated based on the production allocation procedure in the proposed methodology. LXni oil A: ACTUATOR- A KB FIN = % REV= KOP Lg Amo = 59" Minimum LD -L1 wenoore 6cnemanc Proposedivishak COMMi%1ingperfs Minimum LNR ID = 1.812"@ 12405' 2-318' CAMCO D NIPPLE 1133'6' CSG. 7". L.&1. D - 12 347' H 3001 IATCC(W7K115'1H 7 1 �9N6'CS[:17AKION1N10)I-{ 76l0` roP aF r LNq NCN IWDIM IDII `uTAfM11Y I REF LOG: zOL DA ON072N6J Ar ATTOPFIW 1191n6T NNe: IbfK b RoduCfon OB la IebdeYPeA ENA SIZE SPF NIBNAL opVSgx D11E S�-f M15EO TONOLTA _ J—.— SI L5-21 SAFETY KWW.CAT INOSMMS(PPMLK ABLE TO BIiT WMULIC SHEAR SU3YE ON T7SV on -Am). -Rs" r X 161085M NOSEEOGP fl -7-7T 111 1 1 HUNG W IN PFOFLE 5D 1./ SO. Wr PETE GILLS ON TOP OF PNM FROM BTIM. JET CUF TAIL PPEQ 124W 011011019 TO ESTABLISH COMM BMOW DDT Rot o=x317. ST W TVD (EV nfE VLV LATCH M0 --MBE 1 2720 nil 15 `G D OGLE —R( 7 5560 19BT 56 TOED SORx['16 3 09® 6561 57 TO1D DN A 1% 7677 A6 7CiD OMI5 1/N615 TPN ISSN 6317 76 TGPD M0 i00121A19 t 4.)IB• BIBNMIH HtR pl• > xA 1• 1119x0- 119501vishak Perfs(approxirate depths) I MlE FEV a. UI iA MIL i¢V BY OWA NTS 1M77M7 ORGML COMPLETM 052616 WY FULLUR t0AE5SED RESET{ OO( UW IMro 0526118 A6.J G.V=(0622716) 09T7AC 15 ALL CM N TOGUNIOIOWII ONNI6LW RLAIDROD( SMEENC07110016) ®?d 15 .151 N659115Af1ID C50 LFAK 03oN17 A6SE5106I3Vtll 1/N615 TPN 6M.L CNOfETAI�-SEF OJ/lOf10 LfUf2 NESS OORf8.T10fS IWIW15q SETROCK SCREENOW3115) WLFG, D= 2"r K2V XOHLLD).V-IA95'I _.. ML.ET QJr N PKR TALKIE pI0Jl0YB9 USBUFML f Wt11: LS -21 Pew W. 187-0570 ARtb %WS21732-00 BP txpl ..Wn IAInks) F39SORATC1iJ 61A491RY FS LOG. 20L d1 CN07RV87 ANGI.FAT TCPFEW 3r 012129' Fbte: Meter In RWucnn C6 far haW Aperfd WE SfP NFF3NAL OpNS97 alE 2- 6 12120-12130 D 06(3/,17 2' 6 12fW-1x150 0 (BOVf7 2 -IM' 1 12161, 12163, 12165, 121M O /dIIM7 2 1M' 1 12184 121N O 1d12187� 2-116' 1 12216, 17218 22 . 120, IM4. D 1012'8! L -fro' '1 12224 12226, 122.11. 12247, O ItItM71 2-118• 1 1220.9, 12257, 12254 12261 I 0 101267 2-1M' 1 12217. 12221. 12225, 12231, I O 052ml 2-1M' 1 12247. 12258 jFC-FSf) O OY26M 2-1M• 1 12276,12274 1229(1, 12284 12297 O 1011"71 2-118' 1 120", 11306. 123M 12316. 0 101W 2-178 1 12318, 12320 12325, 12327, O tdt1M7 2-178' 1 12329.12311.12394.12347, 0 �101V67� 2-118• 1 12350. 12359, 12366. 123540 10IIM7 2-118' 1 12384 12365, t2375.12379.12382 O 2 1M' 1 12274 122M 12305, 123W, D (1011"71 0 5fJ8186 2-1M'1 1238. 12321 12325,123N, 0 05128M9 2-110' 1 12341,12345 12394 12353. O 0526"9 2-116' 1 12357.12361.12365.12369, 0 0&12669 2-1M• 1 11375, 12381 (W -PHM) O 0928(69 2-W 1 1N11, 12414, 12417, 1N" O 1011"7 2-1M' 1 12432, 1245. 12"9.124" 0 W IA7 2-1M 1 12486.12497,12499 0 1011"7 2-1M' 1 12514 12519 O 1d1/Mll —J L5-21 CATE I FEV BY I COM@tf6 I 617E I BF.V BT I LSBMELMT NAL LS2t P88.41' W 187-0570 ARW: 50029-2173b00 SFS 2, T11µ 1115E 1992F& 6152 FS Ism TA? OMML COMPLETION 6 W FUJM. REDFI9S®, FaW OOCMK 02@11" FNM 6 J aV 00 —(MMMS) 50FI5 JLWM ML CMF N T6C WQiONN 7H2/16 FLLL®RDCKS i0J(07Hd16) I 0623115 519I— W3S WIWA®CSG K 7 AOF$>f5(O8MV17) 1/MV157PN LLL CWf81EfANBireP-SET 121&15 D111' SET B0..1(SCfHN(1213115)I 7/!0118 IlBlporatbnlAbsta) 9'J AANORViBS COR6CIpt6