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Home My WebLink AboutDIO 028 A INDEX DISPOSAL INJECTION ORDER NO. 28 and 28A Deep Creek Unit NNA No. 1 Well 1. October 4, 2004 Unocal’s application for DIO 2. October 8, 2004 Notice of hearing, affidavit of publication, email distribution, and mailings 3. November 9, 2004 Sign-in sheet 4. November 9, 2004 Transcript 5. November 16, 2004 Unocal’s answers to 11/9/04 hearing questions 6. November 24, 2004 Unocal’s letter of clarification 7. December 21, 2004 Emails: Methanol Spilled at Happy Valley 8. -------------------- Monthly Pressure Reports 9. -------------------- Annual Disposal Reports 10. July 16, 2007 Memo to Files 11. November 26, 2007 Email: Request to Dispose Precipitation in NNA-1 (no action needed by AOGCC) 12. December 16, 2010 Email: Delinquent Annual Reports 13. January 29, 2025 Hilcorp application to amend DIO 47 (DIO 28A.001) 14. March 13, 2025 DIO 47 amendment email chain (DIO 28A.001) STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West 7 Avenue, Suite 100 Anchorage Alaska 99501 Re: THE APPLICATION OF Union Oil Disposal Injection Order No. 28A Company of California for disposal of Class II oil field wastes by Deep Creek Unit underground injection in the Tyonek NNA No. 1 Well Formation in the Deep Creek Unit NNA No. 1 Well, Section 11, T2S,Originally Issued December 7, 2004 R13W, S.M.Corrected and Amended June 14, 2005 IT APPEARING THAT: 1. By correspondence to the Alaska Oil and Gas Conservation Commission Commission ") dated October 1, 2004 and received on October 4, 2004, Union Oil Company of California ( "Unocal ") requested authorization to allow the underground injection of non - hazardous Class II oil field waste fluids into the Tyonek Formation within the Deep Creek Unit NNA No. 1 ( "NNA #1 ") well bore. The well is located on the Kenai Peninsula approximately 6 miles east of the city of Ninilchik; 2. The Commission published notice of opportunity for public hearing in the Anchorage Daily News on October 8, 2004 in accordance with 20 AAC 25.540; 3. The Commission did not receive any protests to the application, comments, or requests for a public hearing; 4. A hearing was held on November 9, 2004, at which Unocal provided sworn testimony addressing engineering and geologic considerations in support of the NNA #1 disposal injection order application. The record was held open to allow Unocal to provide supplemental information about the confining lithologies isolating injected waste fluids from shallow freshwater aquifers as requested by the Commission; and 5. Unocal provided supplemental information addressing fluids eligible for disposal into NNA #1 in a letter dated November 24, 2004. 6. Disposal Injection Order No. 28 was issued on December 7, 2004. 7. The Commission is providing this Disposal Injection Order No. 28A to supersede and replace Disposal Injection Order No. 28, clarifying the fluids authorized for injection. Disposal Injection Order 28A Page 2 of 7 NNA No. 1 Well June 14, 2005 FINDINGS: 1. Location of adjacent wells (20 AAC 25.252 (c)(1) NNA #1 is a near - vertical well that is located approximately 272 feet from the south line and 510 feet from the west line of Section 11, Township 2 South, Range 13 West, Seward Meridian. There are no wells within 1 /4 mile of NNA #1; 2. Notification of Operators /Surface Owners (20 AAC 25.252 (c)(2) and 20 AAC 25.252 (c)(3)) Unocal is the only operator within 1 /4 mile radius of the proposed disposal operation. The sole surface owner within a 1 /4 mile radius of NNA #1 is Ninilchik Native Association, Inc. Unocal provided evidence that a copy of its application for disposal injection in NNA #1 was sent by certified mail to Ninilchik Native Association, Inc., on October 1, 2004; 3. Geologic information on disposal and confining zones (20 AAC 25.252 (c)(4)) Unocal proposes to conduct disposal into the Tyonek Formation ( "Tyonek ") between the measured depths of 6,182 ft and 9,278 ft. Individual sand intervals within the Tyonek Formation were perforated after drilling to test for natural gas; no commercial gas rates were achieved. Disposal operations in NNA #1 will not impact adjacent production from the Happy Valley field as the nearest development wells are approximately 2 miles away; Geologic information provided by Unocal notes that the Tyonek Formation consists of interbedded conglomerates, sandstones, siltstones, shales and coals deposited in fluvial, lacustrine, alluvial, and terrestrial systems. Sandstones within the proposed disposal interval have estimated porosities up to 22 %, permeabilities in excess of 20 millidarcies, and can approach 40 -ft in thickness (average 20 ft). Unocal has provided evidence that the numerous coal beds ranging in thickness from 6 inches to 30 ft, as well as tight carbonaceous and impervious claystone beds provide vertical confinement for injection into the Tyonek. The Beluga Formation is several thousand feet thick and occurs at depths greater than 2,000 ft in the Deep Creek Unit. This formation is comprised of thinly laminated sandstones, siltstones, shales and coals. Individual sandstone beds within the Beluga Formation are generally less than 30 ft thick, resulting in a heterogeneous sequence of rocks with very poor or no vertical connectivity or permeability. In the area considered for disposal injection, the top of the Beluga Formation is at a depth of approximately 2,400 ft and marked by locally continuous, 75 -ft thick shale. I All depths noted in this Order are measured depth ( "MD ") referenced to NNA #1 and are substantially equivalent to true vertical depth ( "TVD ") below ground level in this near - vertical well. 1 Disposal Injection Order 28A Page 3 of 7 NNA No. 1 Well June 14, 2005 Supplemental information provided by Unocal on November 17, 2004 identifies more than 1,000 ft of confining lithologies between the aquifer exemption depth (1,800 ft per AEO No. 11) and the depth of uppermost injection perforations (6,182 ft); 4. Well Logs (20 AAC 25.252 (c)(5)) Well logs from NNA #1 are on file with the Commission; 5. Demonstration of Mechanical Integrity and Disposal Zone Isolation (20 AAC 25.252 c)(6)) Drilling records show that Unocal ran 7" casing and cemented it with 172 - barrel lead and 66- barrel tail cement slurries. An Ultra -Sonic Imaging Tool (USIT) was run in the well 4 days after cementing 7" casing to evaluate the cement sheath in the vicinity of the disposal intervals, focusing specifically on the interval from 5,700 ft to 6,182 ft. Analysis of the USIT results indicates competent cement around the 7" casing below 5,860 ft, isolating the uppermost injection interval with approximately 320 ft of cement. Unocal conducted a successful 3000 -psi mechanical integrity test of the tubing- casing annulus in NNA #1 on August 24, 2004. The pressure test was performed in accordance with 20 AAC 25.412(c); 6. Disposal Fluid Type, Source, Volume and Compatibility with Disposal Zone 20 AAC 25.252 (c)(7)) The primary disposal fluid planned for this well is formation fluid from the Happy Valley Field as well as approved Class II fluids from other Unocal operated fields. Specific wastes include drilling, completion, production, and workover fluids; stimulation fluids and solids; tracer materials; rig wash fluids; glycol dehydration wastes; drilling mud slurries; naturally occurring radioactive material scale slurries; precipitation accumulating within containment areas; tank bottoms; and other fluids brought to surface and generated in connection with oil and gas development activities. Unocal estimates a maximum of 3,000 barrels per day of fluid will be injected in NNA #1; 7. Estimated Injection Pressure (20 AAC 25.252 (c)(8)) , Unocal estimates average surface injection pressure will be 2,200 psig and the maximum surface injection pressure will be 4,000 psig; 2 Maximum injection pressure clarified in public hearing record for DIO 28 (November 9, 2004), pgs 9 -10 Disposal Injection Order 28A Page 4 of 7 NNA No. 1 Well June 14, 2005 8. Evaluation of Confining Zones (20 AAC 25.252 (c)(9)) The potential to fracture through the confining lithologies at NNA #1 was modeled by a Unocal consultant. Included in the consultant's analysis was experience from observed behavior of Beluga - Tyonek facture treatments in the region. The goal of this evaluation was to predict the expected upward fracture growth for cuttings disposal at NNA #1 using worst -case assumptions. The simulation assumed continuous 2 -day injection of 8,000 barrels of slurry in 10 equal events separated by 59.5- barrel sweeps with clean fluid. Slurry make -up was assumed to have a 12 percent solids concentration with 30/50 -mesh sand distribution and density of 10 pounds per gallon. Injection rate for the modeling work was 2.5 barrels per minute. Only the uppermost perforated interval (6,182 ft — 6,222 ft) is assumed open. In this worst -case model, the critical factor is vertical fracture propagation, with a critical limit being the log- derived top of cement in the production casing annulus 5,860 ft, or 322 ft above the top of perforations). The fracture analysis indicates that coal intervals overlying the injection interval tend to impede the fracture height growth within the Tyonek Formation. Modeling shows the fracture height is not expected to grow beyond the top of cement. Unocal further notes that the injection assumptions included in the modeling work significantly exceed maximum estimated fluid injection per day; 9. Standard Laboratory Water Analysis of the Disposal Zone (20 AAC 25.252 (c)(10)) A laboratory analysis of formation water sampled from one of the Tyonek sands in NNA #1 identified total dissolved solids greater than 7,000 ppm; 10. Aquifer Exemption (20 AAC 25.252 (c)(11)) Pursuant to a separate proceeding, an aquifer exemption has been granted, in Aquifer Exemption Order No. 11, for depths greater than 1,800 ft covering 3 specific areas within the Deep Creek Unit: A 1 /4 mile radius around NNA #1; All of Section 22, which includes the Happy Valley pad and associated wells; The southeast one - quarter of Section 15; and All of Section 21, which will cover a new drillsite and associated wells planned by Unocal for the Deep Creek Unit; and 11. Mechanical Condition of Wells Penetrating the Disposal Zone within 1 /4 Mile of NNA 1 20 AAC 25.252 (c)(12) There are no wells penetrating the disposal zone within 1A mile radius of NNA #1. D 1 isposal Injection Order 28A Page 5 of 7 NNA No. 1 Well June 14, 2005 CONCLUSIONS: 1. The application requirements of 20 AAC 25.252(c) have been met; 2. Mechanical integrity of the tubing- casing annulus to a depth of 6,097 ft has been demonstrated in NNA #1 by pressure test. Competent cement has been demonstrated in the casing annulus to 5,860 ft. NNA #1 has been cased and the casing cemented in a manner that will isolate the disposal zone and protect oil, gas, and freshwater sources; 3. At NNA #1, there are approximately 180 ft of confining lithologies between the top of cement in the 7" casing annulus and the uppermost perforations. While other confining lithologies are documented, the Commission does not recognize these as effective confining zones since the uncemented annulus above 5,860 ft provides a communication path for fluid migration up hole should the 180 -ft net thickness be compromised; 4. Worst -case fracture modeling confirms that waste fluids will be contained within the receiving intervals by the confining lithologies within the Tyonek Formation, cement isolation of the well bore and operating conditions; 5. Disposal injection operations in NNA #1 will be conducted at rates and pressures below those estimated to fracture through the confining zones. Therefore, oil field wastes will not enter freshwater strata; and 6. Supplemental mechanical integrity demonstrations and surveillance of injection operations are appropriate to ensure waste fluids are contained within the disposal interval. Included are mechanical integrity testing, temperature surveys, monitoring of injection performance (pressures, rates), and analysis of the data for indications of anomalous events. NOW, THEREFORE, IT IS ORDERED THAT this Disposal Injection Order No. 28A supersedes Disposal Injection Order No. 28, and that the following rules are adopted: RULE 1: Authorized Injection Strata for Disposal Injection of authorized fluids for purposes of underground disposal of oil field wastes is permitted into the Tyonek Formation below 6,000 ft in NNA #1. The Commission may immediately suspend, revoke, or modify this authorization if injected fluids fail to be confined within the designated injection strata. RULE 2: Authorized Fluids This authorization is limited only to Class II waste fluids as follow: produced water, drilling, completion, production and work over fluids (including stimulation fluids and solids, and tracer materials), rig wash, drilling mud slurries, NORM scale, precipitation Disposal Injection Order 28A Page 6 of 7 NNA No. 1 Well June 14, 2005 accumulating within containment areas, tank bottoms, and glycol dehydration wastes. The Commission may authorize the disposal of additional fluids not identified above on a case -by -case basis if the Commission determines they are suitable for disposal in a Class II well. RULE 3: Demonstration of Mechanical Integrity The mechanical integrity of NNA #1 must be demonstrated before injection begins, and before returning a well to service following a workover affecting mechanical integrity. A Commission - witnessed mechanical integrity test must be performed after injection is commenced for the first time in NNA #1, to be scheduled when injection conditions temperature, pressure, rate, etc.) have stabilized. Subsequent tests must be performed at least once every four years thereafter except at least once every two years in the case of a slurry injection well. The Commission must be notified at least 24 hours in advance to enable a representative to witness mechanical integrity tests. Unless an alternate means is approved by the Commission, mechanical integrity must be demonstrated by a tubing /casing annulus pressure test using a surface pressure of 1,500 psi or 0.25 psi /ft multiplied by the vertical depth of the packer, whichever is greater, that shows stabilizing pressure and does not change more than 10 percent during a 30 minute period. Results of mechanical integrity tests must be readily available for Commission inspection. RULE 4: Well Integrity Failure and Confinement Whenever any pressure communication, leakage or lack of injection zone isolation is indicated by injection rate, operating pressure observation, test, survey, log, or other evidence, the operator shall notify the Commission by the next business day and submit a plan of corrective action on a Form 10 -403 for Commission approval. The operator shall immediately shut in the well if continued operation would be unsafe or would threaten contamination of freshwater, or if so directed by the Commission. A monthly report of daily tubing and casing annuli pressures and injection rates must be provided to the Commission indicating well integrity failure or lack of injection zone isolation. RULE 5: Surveillance The operator shall obtain a baseline temperature log and a baseline step rate test prior to initial injection. A subsequent temperature log must be performed 1 month after injection begins to demonstrate the receiving zone of the injected fluids. Additional temperature survey requirements will be based on the results of the initial and follow -up temperature surveys. An annual report for the calendar year evaluating the performance of the disposal operation must be submitted by July 1 of each year. The report shall include pressures, fluid volumes (disposal and clean fluid sweeps), fluid make -up, injection rates, an assessment of fracture height growth, and a description of any anomalous injection results. During the first year of injection, a monthly evaluation of injection monitoring results must be provided to the Commission with an emphasis on fracture height growth. Disposal Injection Order 28A Page 7 of 7 NNA No. 1 Well June 14, 2005 RULE 6: Notification of Improper Class II Injection The operator must immediately notify the Commission if it learns of any improper Class II injection. Additionally, notification requirements of any other State or Federal agency remain the operators' responsibility. RULE 7: Administrative Action Unless notice and public hearing is otherwise required, the Commission may administratively waive or amend any rule stated above 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 fluid movement outside of the authorized injection zone. RULE 8: Conditions It is a condition of this authorization that operations be conducted in accordance with the rules set out in this order, with AS 31.05, and (unless specifically superseded by Commission order) with 20 AAC 25. Failure to comply with an applicable provision of AS 31.05, 20 AAC 25, or these rules may result in the suspension or revocation of this authorization. DONE at Anchorage, Alaska and dated J 1 4 11 OIL I. IL "` d I r ' . Nor ! , ChairmMIIIII 41------- . 7 -,,--- n f 0 i ,K - : Daniel T. Seamount, Jr., Commissioner n 9 7 3+ P il - - ' -t./..„a/ /Ars( IOjS CO Cathy ' . Foers er, Commissioner AS 31.05.080 provides that within 20 days after receipt of written notice of the entry of an order, a person affected by it may file with the Commission an application for rehearing. A request for rehearing must be received by 4:30 PM on the 23rd day following the date of the order, or next working day if a holiday or weekend, to be timely filed. The Commission shall grant or refuse the application in whole or in part within 10 days. The Commission can refuse an application by not acting on it within the 10 -day period. An affected person has 30 days from the date the Commission refuses the application or mails (or otherwise distributes) an order upon rehearing, both being the final order of the Commission, to appeal the decision to Superior Court. Where a request for rehearing is denied by nonaction of the Commission, the 30 -day period for appeal to Superior Court runs from the date on which the request is deemed denied (i.e., 10th day after the application for rehearing was filed). Amended Orders Cook Inlet and Admin Approv edoubt Subject: Amended Orders Cook Inlet and Admin Approval Redoubt From: Jody Colombie < jody _colombie @admin.state.ak.us> Date: Wed, 15 Jun 2005 11:30:50 -0800 To: undisclosed- recipients:; BCC: Robert E Mintz <robert_mintz @law.state.ak.us >, Christine Hansen c.hansen@iogcc.state.ok.us >, Terrie Hubble <hubbletl @bp.com >, Sondra Stewman StewmaSD @BP.com >, Scott & Cammy Taylor <staylor @alaska.net >, stanekj <stanekj @unocal.com >, ecolaw <ecolaw @trustees.org >, roseragsdale <roseragsdale @gci.net >, trmjrl <trmjr1 @aol.com >, jbriddle <jbriddle @marathonoil.com >, shaneg <shaneg @evergreengas.com >, jdarlington jdarlington@forestoil.com >, nelson <knelson @petroleumnews.com >, cboddy cboddy @usibelli.com >, Mark Dalton <mark.dalton @hdrinc.com >, Shannon Donnelly shannon .donnelly @conocophillips.com >, "Mark P. Worcester" mark. p .worcester @conocophillips.com >, Bob <bob @inletkeeper.org >, wdv <wdv @dnr.state.ak.us >, tjr <tjr @dnr.state.ak.us >, bbritch <bbritch @alaska.net >, mjnelson <mjnelson @purvingertz.com >, Charles O'Donnell <charles.o'donnell @veco.com >, "Randy L. Skillern" <SkilleRL @BP.com >, Deborah J. Jones" <JonesD6 @BP.com >, , "Steven R. Rossberg" <RossbeRS @BP.com >, Lois lois @inletkeeper.org >, Dan Bross <kuacnews @kuac.org >, Gordon Pospisil <PospisG @BP.com >, Francis S. Sommer" <SommerFS @BP.com >, Mikel Schultz <Mikel.Schultz @BP.com >, "Nick W. Glover" <GloverNW @BP.com >, "Daryl J. Kleppin" <KleppiDE @BP.com >, "Janet D. Platt" PlattJD @BP.com >, "Rosanne M. Jacobsen" <JacobsRM @BP.com >, ddonkel <ddonkel @cfl.rr.com >, mckay <mckay @gci.net >, Barbara F Fullmer < barbara .£fullmer @conocophillips.com >, bocastwf bocastwf@bp.com >, Charles Barker <barker @usgs.gov >, doug_schultze doug_schultze @xtoenergy.com >, Hank Alford <hank.alford @exxonmobil.com >, Mark Kovac yesnol @gci.net >, gspfoff <gspfoff@aurorapower.com >, Gregg Nady <gregg.nady @shell.com >, Fred Steece <fred.steece @state.sd.us >, rcrotty <rcrotty@ch2m.com >, jejones <jejones @aurorapower.com >, dapa <dapa @alaska.net>, jroderick <jroderick @gci.net >, eyancy <eyancy @seal- tite.net>, "James M. Ruud" < james .m.ruud @conocophillips.com >, Brit Lively <mapalaska @ak.net >, jah jah @dnr.state.ak.us >, Kurt E Olson <kurt_olson @legis.state.ak.us >, buonoje <buonoje @bp.com >, Mark Hanley <mark_hanley @anadarko.com >, loren_leman <loren_leman @gov.state.ak.us >, Julie Houle <julie_houle @dnr.state.ak.us >, John W Katz <jwkatz @sso.org >, Suzan J Hill suzan_hill @dec.state.ak.us >, tablerk <tablerk@unocal.com >, Brady <brady @aoga.org >, Brian Havelock <beh @dnr.state.ak.us >, bpopp <bpopp @borough.kenai.ak.us >, Jim White jimwhite @satx.rr.com >, "John S. Haworth" <john.s.haworth @exxonmobil.com >, marry marty @rkindustrial.com >, ghammons <ghammons @aol.com >, rmclean <rmclean@pobox.alaska.net >, mkm7200 <mkm7200 @aol.com >, Brian Gillespie <ifbmg @uaa.alaska.edu >, David L Boelens dboelens @aurorapower.com >, Todd Durkee <TDURKEE @KMG.com >, Gary Schultz gary_schultz @dnr.state.ak.us >, Wayne Rancier <RANCIER @petro- canada.ca >, Bill Miller BillMiller @xtoalaska.com >, Brandon Gagnon <bgagnon @brenalaw.com >, Paul Winslow pmwinslow @forestoil.com >, Garry Catron <catrongr @bp.com >, Sharmaine Copeland copelasv @bp.com >, Kristin Dirks <kristin_dirks @dnr.state.ak.us >, Kaynell Zeman kjzeman @marathonoil.com >, John Tower <John.Tower @eia.doe.gov >, Bill Fowler Bill_Fowler @anadarko.COM >, Vaughn Swartz <vaughn.swartz @rbccm.com >, Scott Cranswick scott.cranswick @mms.gov >, Brad McKim <mckimbs @BP.com >, Steve Lambe lambes @unocal.com >, jack newell <jack.newell @acsalaska.net >, James Scherr james_scherr@yahoo.com >, david roby <David.Roby @mms.gov >, Tim Lawlor of 2 6/15/2005 11:31 AM Amended Orders Cook Inlet and Admin Appro edoubt Tim_Lawlor @ak.blm.gov >, Lynnda Kahn <Lynnda_Kahn @fws.gov >, Jerry Dethlefs Jerry.C.Dethlefs @conocophillips.com >, Jerry Dethlefs <n1617 @conocophillips.com >, crockett @aoga.org, Tamera Sheffield <sheffield @aoga.org >, Jon Goltz Jon.Goltz @conocophillips.com >, Roger Belman < roger .belman@conocophillips.com >, Mindy Lewis mlewis @brenalaw.com >, Harry Lampert <harry.lampert@honeywell.com >, Kari Moriarty moriarty @aoga.org >, Patty Alfaro <palfaro @yahoo.com >, Cynthia B Mciver bren mciver @admin.state.ak.us> Content -Type:application/pdf ER02.001.pdf Content - Encoding: base64 Content -Type:application/pdf DI030A.pdf Content- Encoding: base64 Content -Type:application/pdf DIO28A.pdf Content- Encoding: base64 2 of 2 6/15/2005 11:31 AM Citgo Petroleum Corporation Mary Jones David McCaleb PO Box 3758 XTO Energy, Inc.IHS Energy Group Tulsa, OK 74136 Cartography GEPS 810 Houston Street, Ste 2000 5333 Westheimer, Ste 100 Ft. Worth, TX 76102 -6298 Houston, TX 77056 Mona Dickens Robert Gravely George Vaught, Jr. Tesoro Refining and Marketing Co.7681 South Kit Carson Drive PO Box 13557 Supply & Distribution Littleton, CO 80122 Denver, CO 80201 -3557 300 Concord Plaza Drive San Antonio, TX 78216 Jerry Hodgden Richard Neahring John Levorsen Hodgden Oil Company NRG Associates 200 North 3rd Street, #1202 408 18th Street President Boise, ID 83702 Golden, CO 80401 -2433 PO Box 1655 Colorado Springs, CO 80901 Kay Munger Samuel Van Vactor Michael Parks Munger Oil Information Service, Inc Economic Insight Inc.Marple's Business Newsletter PO Box 45738 3004 SW First Ave.117 West Mercer St, Ste 200 Los Angeles, CA 90045 -0738 Portland, OR 97201 Seattle, WA 98119 -3960 Mark Wedman Schlumberger David Cusato Halliburton Drilling and Measurements 200 West 34th PMB 411 6900 Arctic Blvd.2525 Gambell Street #400 Anchorage, AK 99503 Anchorage, AK 99502 Anchorage, AK 99503 Ciri Baker Oil Tools Ivan Gillian Land Department 4730 Business Park Blvd., #44 9649 Musket Bell Cr. #5 PO Box 93330 Anchorage, AK 99503 Anchorage, AK 99507 Anchorage, AK 99503 Jill Schneider Gordon Severson Jack Hakkila US Geological Survey 3201 Westmar Cr.PO Box 190083 4200 University Dr.Anchorage, AK 99508 -4336 Anchorage, AK 99519 Anchorage, AK 99508 Darwin Waldsmith James Gibbs Kenai National Wildlife Refuge PO Box 39309 PO Box 1597 Refuge Manager Ninilchick, AK 99639 Soldotna, AK 99669 PO Box 2139 Soldotna, AK 99669 -2139 Penny Vadla Richard Wagner Cliff Burglin 399 West Riverview Avenue PO Box 60868 PO Box 70131 Soldotna, AK 99669 -7714 Fairbanks, AK 99706 Fairbanks, AK 99707 Bernie Karl Williams Thomas North Slope Borough K &K Recycling Inc.Arctic Slope Regional Corporation PO Box 69 PO Box 58055 Land Department Barrow, AK 99723 Fairbanks, AK 99711 PO Box 129 Barrow, AK 99723 ga/%6 / / s Alaska Oil and Gas Conservation Commission 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907.279.1433 Fax: 907.276.7542 www.aogcc.alaska.gov ADMINISTRATIVE APPROVAL DISPOSAL INJECTION ORDER 47.001 DISPOSAL INJECTION ORDER 28A.001 DISPOSAL INJECTION ORDER 30A.001 Mr. Daniel Taylor, P.E. Well Integrity Engineer Hilcorp Alaska, LLC. 3800 Centerpoint Drive Anchorage, AK 99503 Re: Docket Number: DIO-25-001 Disposal Injection Order 47.001 Request for Amendment to Rule 2 of Disposal Injection Order (DIO) 47 Amendment to Rule 6 of DIO 47 Susan Dionne 8 (PTD 2130510), Ninilchik Unit, Kenai Peninsula DIO 28A.001 Amendment to Rule 2 and Rule 5, Rescinding Rule 7 of DIO 28A NNA-1 (PTD 2012150) Deep Creek Unit, Kenai Peninsula DIO 30A.001 Expiration of DIO 30A NNA-2 (PTD N/A) Deep Creek Unit, Kenai Peninsula Dear Mr. Taylor: By emailed letter dated January 29, 2025, Hilcorp Alaska, LLC (Hilcorp) requested an amendment to Rule 2 of DIO 47 to allow disposal of wastes Hilcorp generated from other Units. In accordance with 20 AAC 25.556(d), the Alaska Oil and Gas Conservation Commission (AOGCC) hereby GRANTS Hilcorp’s request to amend DIO 47 Rule 2: Authorized Fluids, to authorize disposal of Hilcorp generated wastes from additional Units. In addition, on its own motion, AOGCC amends DIO 47 Rule 2, to authorize commercial disposal operations (i.e. wastes generated from other operators, and/or from other Units). In addition, on its own motion, AOGCC amends DIO 47 Rule 6: Surveillance, to increase reporting requirements. In addition, on its own motion, AOGCC amends DIO 28A Rule 2: Authorized Fluids, to authorize commercial disposal operations, amends DIO 28A Rule 5: Surveillance, to increase reporting DIO 47.001 DIO 28A.001 DIO 30A.001 March 19, 2025 Page 2 of 5 requirements, and rescinds DIO 28A Rule 7: Administrative Action. Administrative action of an AOGCC issued order is now authorized under 20 AAC 25.556(d). In addition, on its own motion, in accordance with 20 AAC 25.556(c)(1), AOGCC concludes that DIO 30A has EXPIRED. DIO 30A was issued on June 14, 2005, but the proposed disposal well NNA-2 was not drilled and as such disposal operations did not commence. NOW THEREFORE IT IS ORDERED THAT: DIO 47 shall be amended to read as follows: RULE 2: Authorized Fluids This authorization is limited to Class II eligible waste fluids generated during drilling, production, workover, or abandonment operations, including: Drilling fluids; drill cuttings; well workover fluids; stimulation fluids and solids; produced water; rig wash water; formation materials; naturally occurring radioactive materials; scale; tracer materials; glycol dehydration; reserve pit fluids; chemicals used in the well or for production processing at the surface (in direct contact with produced fluids); and precipitation accumulating in drilling and production impoundment areas. The eligibility of other fluids for Class II waste disposal injection will be considered by the AOGCC on a case-by-case basis upon application by the operator. Commercial Class II oil field waste disposal is approved. Commercial (third party non- Hilcorp generated, and/or generated from other Units) Class II oil field waste disposal shall be in compliance with all rules of this DIO and it remains the responsibility of Hilcorp to accurately account for volumes and ensure that all fluids injected meet Class II eligibility requirements. RULE 6: Surveillance The operator shall run a baseline temperature log and perform a baseline step-rate test prior to initial injection. A subsequent temperature log must be run one month after injection begins to delineate the receiving zone of the injected fluids. The operator shall perform an annual reservoir pressure survey of the disposal zone. Surface pressures and rates must be monitored continuously during injection for any indications of anomalous conditions. Results of daily wellhead pressure observations must be documented and available to the AOGCC upon request. The conduct of subsequent temperature surveys or other surveillance logging (e.g., water flow; acoustic) will be based on the results of the initial and follow-up temperature surveys and injection performance monitoring data. The annual report of underground injection (Form 10-413) shall also include data sufficient to characterize the disposal operation, including, among other information, the following: injection and annuli pressures (i.e., daily average, maximum, and minimum pressures); fluid volumes injected (i.e., in disposal and clean fluid sweeps); injection rates; an assessment of the fracture geometry; a description of any anomalous injection results; a calculated zone of influence for the injected fluids; and an assessment of the applicability DIO 47.001 DIO 28A.001 DIO 30A.001 March 19, 2025 Page 3 of 5 of the disposal order findings, conclusions, and rules based on actual performance. The annual report must be submitted by July 1st. The annual report shall also include a section titled “Induced Seismicity” in which the operator shall detail its monitoring efforts and evaluate the risks. Commercial disposal injection details shall also be provided in the annual performance report. The report shall include: 1. an overview of commercial activities for the year; 2. a list, based on manifests, showing waste generating company, identification of well or pad where the waste was generated, type of waste, volume, transport company/driver, signature/name of Hilcorp authority confirming waste as Class II; 3. a list of the operators that Hilcorp has a Facility User Agreement (FUA) with; 4. a list of operators that Hilcorp has a Road Use Agreement (RUA) with; 5. a list of Hilcorp employees having completed the Hilcorp commercial Class II training and are authorized to accept waste; 6. a review of the Hilcorp Waste Analysis Plan (WAP) and any changes to the plan; 7. a review of the External Manifest procedures including any changes to the process; and 8. a review of the pre-call and approval policy that is designed to ensure the facility is ready and able to accept and process the commercial waste. DIO 28A shall be amended to read as follows: RULE 2: Authorized Fluids This authorization is limited to Class II eligible waste fluids generated during drilling, production, workover, or abandonment operations, including: Drilling fluids; drill cuttings; well workover fluids; stimulation fluids and solids; produced water; rig wash water; formation materials; naturally occurring radioactive materials; scale; tracer materials; glycol dehydration; reserve pit fluids; chemicals used in the well or for production processing at the surface (in direct contact with produced fluids); and precipitation accumulating in drilling and production impoundment areas. The eligibility of other fluids for Class II waste disposal injection will be considered by the AOGCC on a case-by-case basis upon application by the operator. Commercial Class II oil field waste disposal is approved. Commercial (third party non- Hilcorp generated, and/or generated from other Units) Class II oil field waste disposal shall be in compliance with all rules of this DIO and it remains the responsibility of Hilcorp to accurately account for volumes and ensure that all fluids injected meet Class II eligibility requirements. DIO 47.001 DIO 28A.001 DIO 30A.001 March 19, 2025 Page 4 of 5 RULE 5: Surveillance The operator shall obtain a baseline temperature log and a baseline step-rate test prior to initial injection. A subsequent temperature log must be run one month after injection begins to delineate the receiving zone of the injected fluids. The operator shall perform an annual reservoir pressure survey of the disposal zone. Surface pressures and rates must be monitored continuously during injection for any indications of anomalous conditions. Results of daily wellhead pressure observations must be documented and available to the AOGCC upon request. The conduct of subsequent temperature surveys or other surveillance logging (e.g., water flow; acoustic) will be based on the results of the initial and follow-up temperature surveys and injection performance monitoring data. The annual report of underground injection (Form 10-413) shall also include data sufficient to characterize the disposal operation, including, among other information, the following: injection and annuli pressures (i.e., daily average, maximum, and minimum pressures); fluid volumes injected (i.e., in disposal and clean fluid sweeps); injection rates; an assessment of the fracture geometry; a description of any anomalous injection results; a calculated zone of influence for the injected fluids; and an assessment of the applicability of the disposal order findings, conclusions, and rules based on actual performance. The annual report must be submitted by July 1st. The annual report shall also include a section titled “Induced Seismicity” in which the operator shall detail its monitoring efforts and evaluate the risks. Commercial disposal injection details shall also be provided in the annual performance report. The report shall include: 1. an overview of commercial activities for the year; 2. a list, based on manifests, showing waste generating company, identification of well or pad where the waste was generated, type of waste, volume, transport company/driver, signature/name of Hilcorp authority confirming waste as Class II; 3. a list of the operators that Hilcorp has a Facility User Agreement (FUA) with; 4. a list of operators that Hilcorp has a Road Use Agreement (RUA) with; 5. a list of Hilcorp employees having completed the Hilcorp commercial Class II training and are authorized to accept waste; 6. a review of the Hilcorp Waste Analysis Plan (WAP) and any changes to the plan; 7. a review of the External Manifest procedures including any changes to the process; and 8. a review of the pre-call and approval policy that is designed to ensure the facility is ready and able to accept and process the commercial waste. RULE 7: Administrative Action (Rescinded by 20 AAC 25.556(d)) NOW THEREFORE IT IS ORDERED THAT DIO 30A is expired. DIO 47.001 DIO 28A.001 DIO 30A.001 March 19, 2025 Page 5 of 5 DONE at Anchorage, Alaska and dated March 19, 2025. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner RECONSIDERATION AND APPEAL NOTICE As provided in AS 31.05.080(a), within 20 days after written notice of the entry of this order or decision, or such further time as the AOGCC grants for good cause shown, a person affected by it may file with the AOGCC an application for reconsideration of the matter determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration must set out the respect in which the order or decision is believed to be erroneous. The AOGCC shall grant or refuse the application for reconsideration in whole or in part within 10 days after it is filed. Failure to act on it within 10 days is a denial of reconsideration. If the AOGCC denies reconsideration, upon denial, this order or decision and the denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision denying reconsideration, UNLESS the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which the application for reconsideration was filed. If the AOGCC grants an application for reconsideration, this order or decision does not become final. Rather, the order or decision on reconsideration will be the FINAL order or decision of the AOGCC, and it may be appealed to superior court. That appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on reconsideration. In computing a period of time above, the date of the event or default after which the designated period begins to run is not included in the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00 p.m. on the next day that does not fall on a weekend or state holiday. Gregory C. Wilson Digitally signed by Gregory C. Wilson Date: 2025.03.19 12:30:59 -08'00' Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.03.19 13:58:52 -08'00' From:Coldiron, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Disposal Injection Orders 47.001, 28A.001, and 30A.001expired (Hilcorp) Date:Wednesday, March 19, 2025 2:25:56 PM Attachments:DIO47.001_DIO28A.001_DIO30A.001expire.pdf Docket Number: DIO-25-001 Disposal Injection Order 47.001 Request for Amendment to Rule 2 of Disposal Injection Order (DIO) 47 Amendment to Rule 6 of DIO 47 Susan Dionne 8 (PTD 2130510), Ninilchik Unit, Kenai Peninsula DIO 28A.001 Amendment to Rule 2 and Rule 5, Rescinding Rule 7 of DIO 28A NNA-1 (PTD 2012150) Deep Creek Unit, Kenai Peninsula DIO 30A.001 Expiration of DIO 30A NNA-2 (PTD N/A) Deep Creek Unit, Kenai Peninsula 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 14 CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. From:Daniel Taylor To:Wallace, Chris D (OGC) Cc:Wyatt Rivard; Noel Nocas Subject:RE: [EXTERNAL] RE: Ninilchik SD 8 (PTD 213051) / DIO 47 Amendment Application Date:Thursday, March 13, 2025 1:44:19 PM Mr. Wallace, Your suggestion to authorize commercial disposal (DIO 47 & DIO 28A) under the same conditions as DIO 34B Rule 6 is reasonable. You are correct about the NNA #2 well (DIO 30A). The project never materialized and should be expired. Regards, Daniel Taylor, P.E. Well Integrity O: 907-777-8319 C: 907-947-8051 From: Wallace, Chris D (OGC) <chris.wallace@alaska.gov> Sent: Wednesday, March 12, 2025 12:41 PM To: Daniel Taylor <dtaylor@hilcorp.com> Cc: Wyatt Rivard <wrivard@hilcorp.com>; Noel Nocas <Noel.Nocas@hilcorp.com> Subject: [EXTERNAL] RE: Ninilchik SD 8 (PTD 213051) / DIO 47 Amendment Application Daniel, We are reviewing this application and are looking to amend the DIO 47 to authorize commercial disposal (other operators and/or other Units) and increase reporting by the same conditions as DIO 34B Rule 6 . Any concerns? We are also looking to do the same for DIO 28A. Any concerns? I note DIO 30A for NNA #2 was also a Deep Creek DIO - but I cannot find NNA 2 and no DIO 30A reporting which makes me think the well was not drilled and that the DIO 30A should be expired based on no disposal. Please confirm and let me know if I am missing anything. Are there any additional Class II wells in Ninilchik/Deep Creek/ road access corridor that I should authorize for commercial disposal with increased reporting requirements (same as DIO 34B) at this time? Thanks and Regards, Chris Wallace, Sr. Petroleum Engineer, Alaska Oil and Gas Conservation Commission, 333 West 7th Avenue, Anchorage, AK 99501, (907) 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. 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: Daniel Taylor <dtaylor@hilcorp.com> Sent: Tuesday, February 4, 2025 8:55 AM To: Wallace, Chris D (OGC) <chris.wallace@alaska.gov> Cc: Wyatt Rivard <wrivard@hilcorp.com>; Noel Nocas <Noel.Nocas@hilcorp.com> Subject: Ninilchik SD 8 (PTD 213051) / DIO 47 Amendment Application Mr. Wallace, Ninilchik field, Susan Dionne 8 (PTD 213051) is planned to be converted to a Class II disposal well operating under DIO 47. Please see the attached Application for Amendment of DIO 47 clarifying and requesting injection of Hilcorp Alaska, LLC eligible Class II waste generated outside of the Ninilchik Unit. Regards, Daniel Taylor, P.E. Well Integrity O: 907-777-8319 C: 907-947-8051 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 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 responsibility is accepted by the company in this regard and the recipient should carry out such virus and other checks as it considers appropriate. 13 January 29, 2025 Jessie Chmielowski, Commissioner Greg Wilson, Commissioner Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, AK 99501 RE: Application for Amendment Disposal Injection Order 47 Kenai, Alaska Dear Commissioners: Hilcorp Alaska, LLC (“Hilcorp”), as Operator of the Ninilchik Unit (“NU”) in Kenai Alaska, hereby respectfully submits this application to amend Disposal Injection Order 47 (“DIO 47”) issued August 8, 2024, to modify the below sections of Rule 2 by removing the stipulations noted below (bold & strikethrough): RULE 2: Authorized Fluids This authorization is limited to Class II eligible waste fluids generated within the NU during drilling, production, workover, or abandonment operations, including: Drilling fluids; drill cuttings; well workover fluids; stimulation fluids and solids; produced water; rig wash water; formation materials; naturally occurring radioactive materials; scale; tracer materials; glycol dehydration; reserve pit fluids; chemicals used in the well or for production processing at the surface (in direct contact with produced fluids); and precipitation accumulating in drilling and production impoundment areas. The eligibility of other fluids for Class II waste disposal injection will be considered by the AOGCC on a case-by-case basis upon application by the operator. Commercial Class II disposal injection (i.e., fluids from a different operator or from a different unit) is prohibited. Hilcorp requests the ability to inject authorized waste fluids per DIO 47 Rule 2 that are generated from other Hilcorp Alaska, LLC operated fields on the Kenai Peninsula. Having this capability increases the available well stock and flexibility for managing eligible Class II waste fluids. Having additional Class II disposal locations also provides shorter trucking options and the ability to address seasonal road conditions that affect Hilcorp’s primary disposal well in the Ninilchik area, Deep Creek Unit NNA No. 1 (NNA-1). Per the original DIO 47 permit application, the Susane Dionne 8 (SD-8) disposal well is intended to provide backup capacity for the NNA 1 disposal well. NNA 1 currently injects fluids trucked in from the Ninilchik Unit, Deep Creek Unit and Niolaevsk (“Red Pad”)” and is expected to be utilized for additional development of the Cottonfield, Whiskey Gulch and Seaview prospects. 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 Phone: 907-777-8319 Email: dtaylor@hilcorp.com In accordance with 20 AAC 25.252 (section c, 7), Hilcorp’s application stated, “The primary disposal fluid planned for SD-8 is formation fluid from NU and other fields in the Kenai Peninsula. Waste disposal injection may also include other fluids eligible for Class II injection.” The term “other fields” is a reference to Hilcorp Alaska, LLC lease properties only and was not intended to include third parties or Harvest. Fluids eligible for Class II injection will be manifested to SD-8 using the Cook Inlet-Kenai Manifest. Employees and contractors who manifest wastes to Hilcorp’s injection facilities receive training every 2 years in Hilcorp’s Waste Management and Manifesting Training. Hilcorp maintains records concerning the nature and composition of injected fluids until three years after the well is plugged and abandoned. Manifests are kept on-site for at least one year after which they are forwarded to Anchorage for archiving. Should you require additional information regarding this application, please don’t hesitate to contact me at 777-8319. Sincerely, Daniel Taylor, P.E. Well Integrity Engineer Hilcorp Alaska, LLC cc: Chris Wallace Senior Petroleum Engineer, AOGCC (via e-mail) Samantha Coldiron Special Assistant, AOGCC (via e-mail) Digitally signed by Daniel Taylor (1691) DN: cn=Daniel Taylor (1691) Date: 2025.02.03 13:28:00 - 09'00' Daniel Taylor (1691)