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Home My WebLink AboutCO 556 A1. March 12, 2017 2. April 20, 2017 3. April 20, 2017 4. July 2, 2018 5. July 2, 2018 Index Conservation Order 556A Prudhoe Bay Field Notice of Hearing and Affidavit of Publication CPA response Transcript and hearing sign -in sheet BPXA application for reconsideration BPXA Request for Reconsideration STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Avenue Anchorage, Alaska 99501 Re: Proposed amendment of rules waiving certain requirements of 20 AAC 25.280 concerning well work operations sundry application and reporting requirements IT APPEARING THAT: Docket Number: CO -17-006 Conservation Order 556A Prudhoe Bay Field Prudhoe Bay Oil Pool Pt. McIntyre Oil Pool Stump Island Oil Pool Lisburne Oil Pool Niakuk Oil Pool Aurora Oil Pool Borealis Oil Pool Schrader Bluff Oil Pool Polaris Oil Pool Midnight Sun Oil Pool North Prudhoe Bay Oil Pool West Beach Oil Pool Raven Oil Pool Put River Oil Pool June 12, 2018 1. Conservation Order 556 (CO 556), issued July 29, 2005, currently waives the requirements of 20 AAC 25.280(a) for certain wells in the Prudhoe Bay Oil Pool, Prudhoe Bay Field (PBF). 2. Fourteen oil pools have been defined in the Prudhoe Bay Field: Prudhoe Bay Oil Pool Pt. McIntyre Oil Pool Stump Island Oil Pool Lisburne Oil Pool Niakuk Oil Pool West Beach Oil Pool North Prudhoe Bay Oil Pool Midnight Sun Oil Pool Aurora Oil Pool Borealis Oil Pool Polaris Oil Pool Schrader Bluff Oil Pool Raven Oil Pool Put River Oil Pool Conservation Order 341 D Conservation Order 317B Conservation Order 317B Conservation Order 207 and 218 Conservation Order 329A Conservation Order 311B Conservation Order 345 Conservation Order 452 Conservation Order 457B Conservation Order 471 Conservation Order 484 Conservation Order 505 Conservation Order 570 Conservation Order 559 Conservation Order 556A June 7, 2018 Page 2 of 6 3. On its own motion, the Alaska Oil and Gas Conservation Commission (AOGCC) proposed to amend CO 556, Rule 1 and Rule 6 and add Rule 9 and to extend the waiver to all oil pools in PBF. 4. Pursuant to 20 AAC 25.540, the Alaska Oil and Gas Conservation Commission (AOGCC) scheduled a public hearing for April 20, 2017. On March 12, 2017, the AOGCC published notice of the opportunity for that hearing on the State of Alaska's Online Public Notice website, on the AOGCC's website, electronically transmitted the notice to all persons on the AOGCC's email distribution list, and mailed printed copies of the notice to all persons on the AOGCC's mailing distribution list. On March 12, 2017, the AOGCC published the notice in the ALASKA DISPATCH NEWS. 5. No protests to the proposal were filed with the AOGCC and no public request for a hearing was made. 6. BP Exploration (Alaska), Inc. (BPXA) is the operator of the PBF Oil Pools. 7. The AOGCC held the hearing as noticed. FINDINGS: 1. Under 20 AAC 25.280(a) operators are required to file an Application for Sundry Approvals (Form 10-403) and receive approval prior to performing well workovers (i.e., perforating or reperforating casing, stimulation, pulling tubing, altering casing, and repairing wells) on any well. 2. Under 20 AAC 25.280(d) operators are required to file a Report of Sundry Well Operations (Form 10-404), including supporting documentation, within 30 days after completing workover operations. 3. In addition to relieving the operator of the sundry approval requirement for certain wells in specified pools in the PBF for the type of operations in 20 AAC 25.280(a), CO 556 Rule 6 required the operator, on a weekly basis, to supply the AOGCC with a report of workover operations performed the previous week that did not require submission of a Form 10-403. 4. The required weekly reports have proven to be of limited utility to the AOGCC. Conservation Order 556A June 7, 2018 Page 3 of 6 5. Work within the production casing/liner or the production tubing is generally standard and routine in development and service wells in the PBF pools. However, some routine work within service wells requires additional monitoring due to the requirements of the Underground Injection Control ("UIC") Program delegated to the AOGCC by EPA. 6. Alteration of casing which provides a physical barrier between the wellbore and the subsurface formations in development and service wells is not routine and does not warrant waiving the requirement of advance approval. 7. CO 492, dated June 26, 2003 and CO 503, dated October 16, 2003 require the operator to notify the AOGCC when any development well in the PBF experiences sustained annulus pressure exceeding a specified value in order to prevent failure of well integrity, uncontrolled release of fluid or pressure, or threat to human safety. 8. Well workovers on development wells in the PBF pools generally do not call for additional monitoring beyond that imposed by regulation. 9. Injection well workover operations frequently call for additional scrutiny, including mechanical integrity tests and cement quality logs. CONCLUSIONS: 1. Modifying or waiving the requirements of 20 AAC 25.280(a) for development wells in the PBF pools is based on sound engineering and geoscience principles, will not promote waste, jeopardize correlative rights, or result in an increased risk of fluid movement into freshwater. 2. Waiving or modifying the requirements of 20 AAC 25.280(a) for service wells in the PBF pools is based on sound engineering and geoscience principles, will not promote waste, jeopardize correlative rights, or result in an increased risk of fluid movement into freshwater. 3. Modifying or waiving the requirements of 20 AAC 25.280(a) for service wells in the PBF pools comports with the requirements of the Class II UIC program (Increased regulatory scrutiny for those wells reported to the AOGCC in compliance with the Sustained Casing Pressure Rules (COs 492 and 503) is appropriate.) 4. Increased regulatory scrutiny for any well with compromised ability to contain pressure is appropriate. 5. Increased regulatory scrutiny for work to repair casing (20 AAC 25.280 (a) (4)) is appropriate. Conservation Order 556A June 7, 2018 Page 4 of 6 6. The attachment sets out the sundry approval and reporting requirements for frequently performed well operations in the PBF pools. NOW, THEREFORE IT IS ORDERED THAT: This order supersedes CO 556, dated July 29, 2005. Rule 1 of CO 556 is amended, Rule 6 of CO 556 is deleted and Rule 9 and Rule 10 are added. The findings, conclusions and administrative record for CO 556 are adopted by reference and incorporated in this decision to the extent that they do not conflict with this order. In addition to the statewide regulatory requirements not superseded by this order, the following rules apply to the affected areas established in Conservation Order 341 D (Prudhoe Bay Oil Pool), Conservation Order 317B (Pt. McIntyre and Stump Island Oil Pools), Conservation Order 207 and 218 (Lisburne Oil Pool), Conservation Order 329A (Niakuk Oil Pool), Conservation Order 311B (West Beach Oil Pool), Conservation Order 345 (North Prudhoe Bay Oil Pool), Conservation Order 452 (Midnight Sun Oil Pool), Conservation Order 457B (Aurora Oil Pool), Conservation Order 471 (Borealis Oil Pool), Conservation Order 484 (Polaris Oil Pool) and Conservation Order 505 (Schrader Bluff Oil Pool), Conservation Order 570 (Raven Oil Pool), and Conservation Order 559 (Put River Oil Pool). Rule 1 Except as provided in Rules 4 and 5, submission of an Application for Sundry Approvals (Form 10-403) and supporting documentation for workover activities described in 20 AAC 25.280(a) is waived or modified for development wells as provided in the Attachment. Rule 2 Except as provided in Rules 4 and 5, submission of an Application for Sundry Approvals (Form 10-403) and supporting documentation for workover activities described in 20 AAC 25.280(a) is waived or modified for service wells as provided in the Attachment Rule 3 The Attachment summarizing the sundry approval and reporting requirements applies to operations in the specific well types. Conservation Order 556A June 7, 2018 Page 5 of 6 Rule 4 The waivers provided under Rule 1 above, do not apply to wells that are required to be reported to the AOGCC under the provisions of an applicable Sustained Casing Pressure Rule in Conservation Order 492 or 503. Rule 5 The AOGCC reserves the right to require an Application for Sundry Approvals for a particular well or for a particular operation on any well. Rule 6 Repealed. Rule 7 Nothing in this order precludes filing an Application for Sundry Approvals (Form 10-403) in advance of any well work. Rule 8 Unless notice and public hearing are otherwise required, the AOGCC may administratively waive or amend the requirements of any rule stated above or administratively amend the Attachment, as long as the change does not promote waste or jeopardize correlative rights, is based on sound engineering and geoscience principles, and will not result in an increased risk of fluid movement into freshwater. Rule 9 The Attachment applies while BPXA is the operator of Prudhoe Bay Field. Rule 10 No change of operator will be effective until the current operator requests the AOGCC to amend this order to change the name of the operator and the AOGCC approves the required designation of operator form. Conservation Order 556A June 7, 2018 Page 6 of 6 DONE at Anchorage, Alaska and dated June 12, 2018. AIM! Hollis S. French Daniel T. Seamo Jr. Cathy/P. Forester Chair, Commissioner Commission Commissioner o�� 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. 3 9 y d W _ O y V E m u cG V m c an d a— L N QQ o o v c E E OU mu V3 G p d C u.9 a p� s'c n � o 0... a o O V s C C E = o O zgz z cc g U �w 3 o F 0 F O 0 3 V d F a K O C E S d 9 a d 3 .a C v 5 a' a vSy a. u e o m 9 rXFUr%UUD ........ ..... .. ......... g 0 V •'- d O `o 0 u a tC C 3 u m V 15 F ' Q m z O b c p z 3 0 �j � x K 331 C v c a o• U S o o c �v' �° vv Eav, O U a � y � v z o g Moo q U' W 7 u deo a a 8 Y r3 Z y V' rig .7 4 0. 1y O fY d d .; d a �W o� �a d�aeo a d `w " r O � Oe Z'e sm 3 9 K = `a = a [sl = z�" �� 3� ac .a U o a m 6 a T O 9 C 'J y STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMNHSSION 333 West Seventh Avenue Anchorage, Alaska 99501 Re: Proposed amendment of rules waiving certain requirements of 20 AAC 25.280 concerning well work operations sundry application and reporting requirements IT APPEARING THAT: Docket Number: CO -17-006 Conservation Order 556A Prudhoe Bay Field Prudhoe Bay Oil Pool Pt. Mchityre Oil Pool Stump Island Oil Pool Lisburne Oil Pool Niakuk Oil Pool Aurora Oil Pool Borealis Oil Pool Schrader Bluff Oil Pool Polaris Oil Pool Midnight Sun Oil Pool North Prudhoe Bay Oil Pool West Beach Oil Pool Raven Oil Pool Put River Oil Pool June 12, 2018 1. Conservation Order 556 (CO 556), issued July 29, 2005, currently waives the requirements of 20 AAC 25.280(a) for certain wells in the Prudhoe Bay Oil Pool, Prudhoe Bay Field (PBF). 2. Fourteen oil pools have been defined in the Prudhoe Bay Field: Prudhoe Bay Oil Pool Pt. McIntyre Oil Pool Stump Island Oil Pool Lisburne Oil Pool Niakuk Oil Pool West Beach Oil Pool North Prudhoe Bay Oil Pool Midnight Sun Oil Pool Aurora Oil Pool Borealis Oil Pool Polaris Oil Pool Schrader Bluff Oil Pool Raven Oil Pool Put River Oil Pool Conservation Order 341 D Conservation Order 317B Conservation Order 317B Conservation Order 207 and 218 Conservation Order 329A Conservation Order 311 B Conservation Order 345 Conservation Order 452 Conservation Order 457B Conservation Order 471 Conservation Order 484 Conservation Order 505 Conservation Order 570 Conservation Order 559 Conservation Order 556A June 7, 2018 Page 3 of 6 5. Work within the production casing/liner or the production tubing is generally standard and routine in development and service wells in the PBF pools. However, some routine work within service wells requires additional monitoring due to the requirements of the Underground Injection Control ("UIC") Program delegated to the AOGCC by EPA. 6. Alteration of casing which provides a physical barrier between the wellbore and the subsurface formations in development and service wells is not routine and does not warrant waiving the requirement of advance approval. 7. CO 492, dated June 26, 2003 and CO 503, dated October 16, 2003 require the operator to notify the AOGCC when any development well in the PBF experiences sustained annulus pressure exceeding a specified value in order to prevent failure of well integrity, uncontrolled release of fluid or pressure, or threat to human safety. 8. Well workovers on development wells in the PBF pools generally do not call for additional monitoring beyond that imposed by regulation. 9. Injection well workover operations frequently call for additional scrutiny, including mechanical integrity tests and cement quality logs. CONCLUSIONS: I. Modifying or waiving the requirements of 20 AAC 25.280(a) for development wells in the PBF pools is based on sound engineering and geoscience principles, will not promote waste, jeopardize correlative rights, or result in an increased risk of fluid movement into freshwater. 2. Waiving or modifying the requirements of 20 AAC 25.280(a) for service wells in the PBF pools is based on sound engineering and geoscience principles, will not promote waste, jeopardize correlative rights, or result in an increased risk of fluid movement into freshwater. 3. Modifying or waiving the requirements of 20 AAC 25.280(a) for service wells in the PBF pools comports with the requirements of the Class II UIC program (Increased regulatory scrutiny for those wells reported to the AOGCC in compliance with the Sustained Casing Pressure Rules (COs 492 and 503) is appropriate.) 4. Increased regulatory scrutiny for any well with compromised ability to contain pressure is appropriate. 5. Increased regulatory scrutiny for work to repair casing (20 AAC 25.280 (a) (4)) is appropriate. Conservation Order 556A June 7, 2018 Page 5 of 6 Rule 4 The waivers provided under Rule 1 above, do not apply to wells that are required to be reported to the AOGCC under the provisions of an applicable Sustained Casing Pressure Rule in Conservation Order 492 or 503. Rule 5 The AOGCC reserves the right to require an Application for Sundry Approvals for a particular well or for a particular operation on any well. Rule 6 Repealed. Rule 7 Nothing in this order precludes filing an Application for Sundry Approvals (Form 10-403) in advance of any well work. Rule S Unless notice and public hearing are otherwise required, the AOGCC may administratively waive or amend the requirements of any rule stated above or administratively amend the Attachment, as long as the change does not promote waste or jeopardize correlative rights, is based on sound engineering and geoscience principles, and will not result in an increased risk of fluid movement into freshwater. Rule 9 The Attachment applies while BPXA is the operator of Prudhoe Bay Field. Rule 10 No change of operator will be effective until the current operator requests the AOGCC to amend this order to change the name of the operator and the AOGCC approves the required designation of operator form. u e eg yy� E M ..pb ILp 00 L !I L A N oaxoe^ 3y �� a y e �0 rn o a °u 9 Y �o Z, ym y VA C yA. e a c p O$ c> E c e 6 E i:, E e o V a� t 4 _ C a E y 3i a s Cc E q f C 'W 3 -, as a c. bSvE d�`= \y V Y � I 11 yssy VI W q y X e a a W 2 E e 6^ a V€ N E 'a mr c O Z3 i O c •'� E E S 3` K o=ar, a apl1 p�� i p O V a V a ; > ` zx a x vat � •ao o cE o z � d 3 0 d Well Work Operations Sundry Application and Reporting Requirements Sundry Matrix Conservation Order 556A Operator: BP Exploration (Alaska), Inc June 12, 2018 Procedure lists for Printouts. Sundry Application / Repo nRequirements: 10,403 Not Required, 10404 Not Required General Well Work: Surveys: Well Logs: Production/Injection: Artificial Lift: Pumping Operations: Tag Fill Pressure (CNL) Compensated Neutron Water Flood Regulator Change GLV Scale Set or pull retrievable plugs Temperature (TDT) Thermal Decay Time Sliding Sleeve Change downhole pump/ Sludge to secure wells not in zone Spinner (CO) Cuban Oxygen AVA Nipple Oelpump/ESP) Ice Plug Run dummy drift or gauge ring Obtain bottom hole sample (CCL) Casing Collar Locator Production Mandrel Install/remove packofT/patch Free= protect Run dummy or gauge ring Gyro Cement Evaluation Downhole Choke GLM Inhibitor squeeze Punch tubing Production/Injection profile Temperature Reperforate existing interval Perform hot oil treatment Dump or bail sand/ sluggits Pressure Isolation sleeve regulator Acidize Tubing Tubing scrapes (scale, Video valve CTU clean out paraftigetc.) Caliper Sand or rockscreen FCO Nr Change GLV Acoustic LDL Stint guNStim tube Displace well with fluid Other Flowback after stimulation Perform high pressure perf breakdown Nitrogen lift pressure test Booster pump in conductor Schmoo-B-Gone Sundn ADDUC8111011! Repo nRequirements: 10403 Re mired. 10404/407 Required Casing Alterations (Rig/coil): Remedial Cement: Polymer/Resin: Mechanical Completion (Rig/coil): Casing Shoe Micro -annulus Down Squeeze Tubing Casing patch Micro -annulus Down Squeeze Pressure Activated Sealant Mill Packer Straddle packer IA Cement Squeeze Gel Squeezes Velocity String Subsidence repair OA Cement Squeeze ESP completion Replace casing Jet pump completion Scab liner PCP completion Tiebacks Stack Packer Page 3 of 3 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 Carlisle, Samantha J (DOA) From: Carlisle, Samantha J (DOA) Sent: Tuesday, June 12, 2018 3:23 PM To: 'Ballantine, Tab A (LAW) (tab.ballantine@alaska.gov)'; Bell, Abby E (DOA); 'Bixby, Brian D (DOA)'; 'Brooks, Phoebe L (DOA) (phoebe.brooks@alaska.gov)'; Carlisle, Samantha J (DOA); 'Colombie, Jody 1 (DOA) Qody.colombie@alaska.gov)'; 'Cook, Guy D (DOA)'; 'Davies, Stephen F (DOA) (steve.davies@alaska.gov)'; Earl, Adam G (DOA); Erickson, Tamara K (DOA);'Foerster, Catherine P (DOA)(cathy.foerster@alaska.gov)';'French, Hollis (DOA)';'Frystacky, Michal(michal.frystacky@alaska.gov)';'Guhl, Meredith (DOA sponsored) (meredith.guhl@alaska.gov)'; Herrera, Matthew F (DOA);'Jones, Jeffery B (DOA) Qeffjones@alaska.gov)'; Kair, Michael N (DOA); Laubenstein, Lou (DOA); Loepp, Victoria T (DOA); Martin, Teddy J (DOA); McLeod, Austin (DOA); Mcphee, Megan S (DOA); 'Mumm, Joseph (DOA sponsored) (oseph.mumm@alaska.gov)'; 'Noble, Robert C (DOA) (bob.noble@alaska.gov)';'Paladijczuk, Tracie L (DOA) (tracie.paladijczuk@alaska.gov)'; 'Pasqual, Maria (DOA) (maria.pasqual@alaska.gov)'; 'Regg, James B (DOA) 6im.regg@alaska.gov)'; Rixse, Melvin G (DOA); 'Roby, David S (DOA) (dave.roby@alaska.gov)'; 'Schwartz, Guy L (DOA) (guy.schwartz@alaska.gov)'; 'Seamount, Dan T (DOA) (dan.seamount@alaska.gov)'; 'Wallace, Chris D (DOA) (chris.wallace@alaska.gov)'; 'Aaron Gluzman'; 'Aaron Sorrell'; 'Ajibola Adeyeye'; 'Alan Dennis'; 'Andy Bond'; 'Bajsarowicz, Caroline Y; 'Bruce Williams'; 'Casey Sullivan'; 'Corey Munk';'Don Shaw';'Eppie Hogan';'Eric Lidji';'Garrett Haag'; 'Graham Smith'; Heusser, Heather A (DNR);'Holly Fair'; Hyun, James J (DNR);'Jamie M. Long';'Jason Bergerson'; 'Jeanne McPherren'; 'Jesse Chielowski'; 'Jim Magill'; 'Joe Longo'; 'John Martineck';'Josh Kindred'; 'Keith Lopez'; 'Laney Vazquez'; 'Lois Epstein'; Longan, Sara W (DNR); 'Marc Kuck'; 'Marcia Hobson'; 'Marie Steele'; 'Matt Armstrong'; 'Melonnie Amundson'; 'Mike Franger'; 'Morgan, Kirk A (DNR)'; 'Pascal Umekwe'; 'Pat Galvin'; 'Patricia Bettis'; 'Pete Dickinson'; 'Peter Contreras'; 'Rachel Davis';'Radio Kenai'; 'Richard Garrard'; 'Richmond, Diane M'; 'Robert Province';'Ryan Daniel';'Sandra Lemke'; 'Susan Pollard';'Talib Syed'; 'Tina Grovier (tmgrovier@stoel.com)';'William Van Dyke';'AK, GWO Projects Well Integrity'; 'AKDCWellIntegrityCoordinator'; 'Alan Bailey'; 'Alex Demarban'; 'Alicia Showalter'; 'Allen Huckabay';'Andrew VanderJack';'Ann Danielson'; 'Anna Lewallen'; 'Anna Raff';'Barbara F Fullmer'; 'bbritch'; 'Becky Bohrer';'Ben Boettger';'Bill Bredar'; 'Bob'; 'Bonnie Bailey'; 'Brandon Viator';'Brian Havelock'; 'Bruce Webb'; 'Caleb Conrad'; 'Candi English'; 'Cody Gauer'; 'Cody Terrell'; 'Colleen Miller'; 'Connie Downing'; 'Crandall, Krissell';'D Lawrence';'Dale Hoffman'; 'Danielle Mercurio';'Darci Horner';'Dave Harbour';'David Boelens';'David Duffy';'David House';'David McCaleb';'David Pascal'; 'ddonkel@cfl.rr.com'; Diemer, Kenneth J (DNR);'DNROG Units';'Donna Ambrui;'Ed Jones'; 'Elizabeth Harball'; 'Elowe, Kristin'; 'Elwood Brehmer'; 'Evan Osborne'; 'Evans, John R (LDZX)'; 'Garrett Brown'; 'George Pollock'; 'Gordon Pospisil'; Greeley, Destin M (DOR); 'Gretchen Stoddard';'gspfoff; Hurst, Rona D (DNR);'Jacki Rose';'Jason Brune'; 'Jdarlington oarlington@gmail.com)';'Jerry Hodgden';'Jill Simek';'Jim Shine';'1im Watt'; 'Jim White';'Jim Young';'Joe Lastufka';'John Burdick'; 'John Easton';'John Larsen';'Jon Goltz'; 'Josef Chmielowski'; 'Joshua Stephen'; 'Juanita Lovett'; 'Judy Stanek'; 'Kari Moriarty'; 'Kasper Kowalewski'; 'Kazeem Adegbola'; 'Keith Torrance'; 'Keith Wiles'; 'Kelly Sperback';'Kevin Frank'; Kruse, Rebecca D (DNR);'Kyla Choquette'; 'Laura Silliphant (laura.gregersen@alaska.gov)';'Leslie Smith';'Lori Nelson';'Luke Keller';'Marc Kovak'; 'Mark Dalton'; 'Mark Hanley (mark.hanley@anadarko.com)';'Mark Landt';'Mark Wedman';'Michael Bill';'Michael Calkins'; 'Michael Moora';'Michael Quick';'Michael Schoetz';'Mike Morgan';'MJ Loveland';'Motteram, Luke A'; Mueller, Marta R (DNR); 'Nathaniel Herz;'nelson';'Nichole Saunders'; 'Nick Ostrovsky';'NSK Problem Well Supv'; 'PattyAlfaro';'Paul Craig';'Paul Decker (paul.decker@alaska.gov)'; 'Paul Mazzolini'; Pike, To: Kevin W (DNR);'Randall Kanady';'Renan Yanish';'Richard Cool';'Robert Brelsford'; 'Robert Tirpack'; 'Robert Warthen'; 'Ryan Gross'; 'Sara Leverette'; 'Scott Griffith'; 'Shahla Farzan';'Shannon Donnelly'; 'Sharon Yarawsky';'Skutca, Joseph E (DNR)'; Smith, Kyle S (DNR); Spuhler, Jes 1 (DNR); 'Stephanie Klemmer';'Stephen Hennigan';'Stephen Ratcliff'; 'Sternicki, Oliver R';'Steve Moothart (steve.moothart@alaska.gov)';'Steve Quinn'; 'Suzanne Gibson';'Tamera Sheffield';'Tanisha Gleason'; 'Ted Kramer'; 'Teresa Imm'; 'Terry Caetano';'Tim Mayers';'Todd Durkee';'Tom Maloney';'Tyler Senden'; Umekwe, Maduabuchi P (DNR); 'Vern Johnson'; 'Vinnie Catalano'; 'Well Integrity'; 'Well Integrity'; 'Weston Nash';'Whitney Pettus' Subject: Conservation Order 2618, 556A and 735 Attachments: co261b.pdf; co556a.pdf; co735.pdf Please see attached. Samantha Carlisle Executive Secretary III Alaska Oil and Gas Conservation Commission 333 West 71" Avenue Anchorage, AK 99501 (907) 793-1.223 CONFIDENTL9LITY NOTICE. This e-mail message, including any attachments, contains infonnation 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 mid/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 m in sending it to you, contact Sarnantha Carlisle at (907) 793-1223 or Samantha CirlisleiTalaska.¢ov. 5 KE BP Exploration (Alaska) Inc. 900 East Benson Boulevard P.O. Box 196612 Anchorage, Alaska 99519-6612 (907)561-5111 JUL 0 2 2018 July 2, 2018 A0GCG Hollis S. French Commission Chair Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, Alaska 99501 Re: Docket Number: CO -17-006 - Application for Reconsideration Conservation Order 556A Sundry Matrix requirements Prudhoe Bay Field Dear Chair French, BP Exploration (Alaska), Inc. (BPXA) as operator of the Prudhoe Bay Unit (PBU), respectfully submits this Application for Reconsideration regarding Conservation Order 556A issued on June 12th, 2018. BPXA appreciates the efforts of the commission to revise the sundry matrix to improve efficiency with well work operations. The sundry matrix approved by the commission in Conservation Order 556A reflects new well work technologies and procedures that have evolved since the previous approved sundry matrix from 2005. However, there are a few edits to the revised sundry matrix, dated June 12, 2018, that BPXA would like to address. BPXA respectfully proposes the edits made in red in the attached mark-up of the sundry matrix, be considered for clarification and consistency purposes. Justification for Reconsideration BPXA respectfully submits the following justifications for this Application for Reconsideration, listed in order of our redlined edits to the sundry matrix by page number and corresponding sections: Application for Reconsideration Docket Number: Conservation Order 556A Prudhoe Bay Field July 2, 2018 Page 1 Third Column: THRU-TUBING OPERATIONS/ 10-403 Required, 10-404 /407 Required: Second Bullet. BPXA proposes adding the verbiage "Reservoir Zonal Abandonment" to "Plug & Abandon / Suspend / Reservoir Zonal Isolation". We believe this requirement was omitted by mistake and adding it would provide consistency between the production and injection well work requirements in the Sundry Matrix. Fifth Bullet. The reference to "SSV/ SSSV" (surface safety valve/sub-surface safety valves) appears to be an error, and BPXA believes the intended reference is to "SSCSSV" (sub -surface controlled sub- surface safety valves). BPXA proposes that the statement read "Initial SSCSSV valve installation and design". This revision would provide clarity as sub -surface controlled sub -surface safety valves (for example: K -valves) require different approvals than safety valves and sub -surface safety valves that are controlled by surface equipment. Third Column: OTHER OPERATIONS: 10-403 Required, 10-404 /407 Required: Second Bullet. BPXA proposes removing "major welding repair on wellhead" from this column as the meaning is unclear, and BPXA cannot identify another welding activity that is not already included in: "repair weld on starting head/bradenhead connections" or "surface casing welding repairs" well work operations. This edit would also provide consistency between the production and injection well work requirements of the sundry matrix. Third Bullet. BPXA proposes editing this bullet to read: "Drilling/Completions Operations Shutdown" to be consistent with the similar statement on sundry matrix Page 2 for Injection Wells. Fourth Bullet. BPXA proposes removing the quotations around "cutaways" as that appears to be an error and the term is not defined. This edit would provide consistency between production and injection well work requirements in the sundry matrix. Ninth Bullet. BPXA proposes removing "cement" from "Cement top job on surface casing by conductor annulus". Removing the specification on using cement provides consistency between the production and injection well work requirements in the sundry matrix. Tenth Bullet. BPXA proposes removing this "Gravel pack or Sandscreen" bullet from this section. Gravel pack is a completion design. (BPXA is also proposing below on Page 3 that this reference be included with other completion designs under the "Mechanical Completion (Rig/coil)" column.) Sandscreen are installed after tubing is installed in a wellbore and is already included in the production/injection control list. F] Application for Reconsideration Docket Number., Conservation Order 556A Prudhoe Bay Field July 2, 2018 Page 2 First Column: OTHER OPERATIONS / 10-403 Not Required, 10-404/407 Not Required: Second Bullet. BPXA proposes removing "WI" and replacing that reference with "Water Alternating Gas (WAG)' for clarification. BPXA believes that the reference to "WI" is an error, as we do not see a purpose for including "WI" in the "WI/WAG swaps" statement. Second Column: OTHER OPERATIONS / 10-403 Not Required, 10-404 /407 Required: Fifth Bullet. BPXA proposes adding a new bullet reading "Conduct suspended well inspection (initial & subsequent)' for injection wells. Adding this requirement provides consistency between production and injection well work requirements in the sundry matrix. Third Column: OTHER OPERATIONS / 10-403 Required. 10-404 /407 Required: Tenth Bullet. BPXA proposes adding a new bullet reading "Surface casing welding repair". Adding this requirement would provide consistency between production and injection well work requirements in the sundry matrix. Page 3 First Column: General Well Work: Fifth Line. BPXA proposes removing "Run dummy or gauge ring" as it is duplicative of- "Run dummy drift or gauge ring" - listed in the same section. Tenth Line. BPXA proposes removing "Change GLV" as it is a duplicate since it is already listed in the Artificial Lift list. Third Column: Mechanical Completion (Rig/coil): First Line. BPXA proposes changing "tubing" to "pulling tubing" for consistency with the Conservation Order 556A, Finding 1. The word tubing is vague. Seventh Line. BPXA proposes adding a new seventh line that reads "Gravel Pack completion". (Please see the Page 1 discussion above.) Fourth Column: Production/Infection: Seventh Line. BPXA proposes adding a new seventh line that reads "Isolation sleeve" to this list, as they are different from the "Isolation sleeve regulator valves" referenced in this section. Isolation sleeves are intended to be opened or closed and isolation sleeve regulator valves control rate. Application for Reconsideration Docket Number. Conservation Order 556A Prudhoe Bay Field July 2, 2018 For all the reasons discussed above, BPXA respectfully requests that the commission reconsider its order, and amend the sundry matrix in accordance with the enclosed redlined markup. BPXA and the PBU owners share AOGCC's focus on safety and integrity of PBU wells. BPXA welcomes further discussion of these proposed m ifications to CO 556A sundry matrix. Sincerely, Ryan Daniel Intervention and Integrity Engineering Team Leader BP Exploration (Alaska) Inc. G O 0 a Q Ln C 14) O � Cv j a o a O 4 O an b O OI t Y set O DEVELOPMENT 1PRODUCTION) WELLS' Well Work Operations idry Application and Reporting Requirements Sundry Matrix Conservation Order 556A Operator: BP Exploration (Alaska), Inc June 12,2018 10.403 Not Required 10-403 Not Required 10-403 Required 10-404 Not Required 10-404 10-40 /40] R THRU-TUBING Of ERAT IONS THRII-TUBINGOPERATIONS THRU-TUBING OP ERAT IONS • General Well Work List Perfirmte new interval within a pool Perforate anew pool • Surreys list Install/Remove Liner Top Packer Plug& Abandon /Suspend/ Reservoir Zonal Abandonment • log list Dulnp/Bail Cement (for permanent plug) Ron permanent/retrievable scab liner • Production/Injection Control list Cut tailpipe or tailing Set whipstock for sidetrack or lateral • Artificial Lit • Install/Remove mechanical device (plug or packer) to control Bund Initial SSWBSSV SSCSSSV valve installation & design movement in zone • Installlubingpatch PUMPINGOPERATIONS INCLUDING USING COIL PUMPING OPERATIONS INCLUDING USING COIL PUMPING OPERATIONS INCLUDING USING COIL • Pumping Operations list SHlnulate(HCI. Mudacid. acid) -Non-fractm'e stimulation • Remedial Cement list • Squeeze/plugto control Fluid movement in zone • Polymer/Resin Repair list • Inject polymer for profile improvement • Proppant or Acid Fracture Stimulation RIGCOIL OPERATIONS RIOCOIL OPERATIONS RIC/COIL OPERATIONS • Mechanical Completions list • Casing .Alterations list OTHER OPERATIONS OTHER OPERAT IONS OTHEROPERATIONS • Replace/Repair Xmas tree or wellhead valve Repair weld oa starting heallbrade.head connections Convert proAmelto injector • Repair wellheatEree pack off with sealant material Mem • Conduct suspended well inspection (initial & subsequent) Drillin¢Complet ions Operations Shutdown Hia: i9 is •• Conduct.,�'Lntnsssys cutaways • Surface casing welding repairs • Conductor extension • Repair external Surface Casing • Plug for redrill Cement top job on surface casing by conductor annulus Goo o sle track OFF nanu • W rapW rapn wellhead o 11) Ona case -bye se bits is.a11.410n'ill Inc mquimd 6r a puarnr nbcan ro,mlrom n i( the A OGCC requests in. The operrshO nM co nsull pith the AOGCC to dencrmine ifa 11-411.3 a needod Page Iof3 TW cz Q b Ln t. QJ a 1Z N C Well Work Operations tdry Application and Reporting Requirements Sundry Matrix Conservation Order 556A Operator: BP Exploration (Alaska), Inc June 12, 2018 ISERVICEl W1 LLS'' 10-403 Not Required 10403 Not Required 10-403 Required 10-404 Not Rerruired 10-404 1407 Recruited 10-404 1407 Remained T HRU-TUBING OPERATIONS THRU-TUBING OPERATIONS T HRU-TUBING OP ERATIONS • General Well Work list Perforate new interval witbin a pool Perforate a new pool • Surveys list Install/Remove mechanical device,(plugor packer) to control Curt tailpipe or tubing • log list fluid movement in zone Damp/Bad Cement (For permanent plug) • Producion/Injection Control list Install/Remove Liner Top Packer • Plug&Abandon / Suspend / Reservoir Zonal Abandonment • Ran permanent/retrievable scab liner • Set whipstock for sidetrack or lateral • Install tubing patch PUMPING OP ERAT IONS INCLUDING USING COIL PUMPING OPERATIONS INCLUDING USING COIL PUMPING OPERATIONS, INCLUDING USING COIL • Pumping Operations list Squeeze/plug to control fluid movement in zone • Remedial Cement list • Inject Polymer for profile improvement • Polymer/Resin Repair list • Proppant or Acid Fracture Stimulation • Water Wash Cos Injector • Acid SIinmdmum(HCI,Mnd Acid) RIOCO1L OPERATIONS RIG'COIL OPERATIONS RC)COILOP ERATIONS • Casing Alterations list • Mechanical Completions list OTHEROPERATIONS OTHER OPERATIONS OTHER OPERATIONS • Replace/Repair Xmax tree orwellhead&valve Convert Flom inithdooderinjectorlo WAGinjector Wrap/Clamp Camomile on wellhead • WI/WAGSwaps Convert from injector to producer if Bowing back Repair Wellhead/'free with sealant material more than 30 days Repair external surface casing • Repair weld on Slatting heaNBradenhead connections Top job on surface casing by conductor annulus • Sealant Material & Conductor fill Convert Injector to Producer • Conduct suspended well Inspection (Initial & subsequent) Plug for redrlll • Conductor extension • Conductor cutaway • Drilling/Complet ions Operations Shutdown • Smiace casingweldognepaire 11) On a case-b)ease basis.a 91.403 will be required faro pnaeuhirwcll oro pe rale, irlhe AOGCC requests it. The opera to rshouldco us a 11 odh the AOGCC to dconnine if p-403 is needed. (2) Opeanins on deposal—lis aper manual cgmucl AOGCC to delcm,inc Srrdrics requicd. Page 2 of 3 EE G O O aLnb O h L C13 00 U a_ a O z m O WCX O Y N M. O O scK Q v CL Procedure lists for Printouts. Well Work Operations a and Reporting Requirements Sundry Morris Conservation Order 556A Opermor: BP Exploration (Alaska), Inc June 12,2018 Still A lication / Renoritina Requirements: 10-403 Not Required, 10-404 Not Required General Well Work: Surveys: Well Logs: Production/Injection: Artificial Lift: Pam ping O pe rations: Tag Fill Pressure Temperature Spinner (CNL) Compensated Neutron Water Flood Regulator Change GLV Scale Set or pull retrievable plugs China bottom hole sample IT DT) T hernial Decay Time $hiding Sleeve Change downhole pump/ Sludge to secure rills not in zone Gyro (CO) Carbon Oxygen AVA Nipple Qetpump/ESP) Ice Plug Run dummy drift or gauge ring Production/Injection profile (CCL) Casing Collar Locator Production Mandrel Install/remove packofflpatnh GLM Freeze protect Rai Cement Evaluation Downhole Choke Inhibitor squeeze -dummy-er- neater -rixg- Punch tubing TemperaturePressure Reperforate existing interval Perform hot Od treatment Dump or bail sand/ Mangos Video Caliper Isolation Sleeve Amdize Tubing Tubingsempes(wale. Acoustic LDL Other Isolation sleeve regulator CTU clean out paraffn,etc.) valve FCO N. Glia 8.- 61 1 Send or rockscreen Displace well with fluid Stam gun/Stam tube Flowback after stimulation Perform high pressure pc,f breakdown Nitrogen lift pressure test Boaster pump in conductor Sehmoo-B-Gone Suntin Application I Re in irem n :10-40) M aptiped,10-404407 Required Remedial Cement: Polymer/Resin: Mechanical C ompletion(Rig/eoill: Casing Alterations Casing Shoe Micro -annulus Down Squeeze Pull Tatar, (Rig/coil): Micro -annulus Down Squeeze Pressure Activated Sealant Mall Packer Caungpatch IA Cement Squeeze Gel Squeezes Velocity String Straddle packer OA Cement Squeeze ESP completion Subsidence repair Jet pump completion Replace casing PCP completion Scab liner Gravel Peek completion Tiebacks Stack Packer Pone 3 of 3 M Li KE BP Expl0'0"On lAlaskal Inc. 90o East Benson Boulevard P.O. 8. 196612 Anchorage, Alaska 99519-6612 19071561-5111 July 2, 2018 Hollis S. French Commission Chair Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, Alaska 99501 Re; Docket Number: CO -17-006 - A lication for Reconsideration Conservation Order 556A sundry Matrix requirements Prudhoe Bay Field Dear Chair French, (pBrespectfully submits this BP Exploration (Alaska), Inc. (BPXA) as operator of the Prudhoe Bay unit Application for Reconsideration regarding Conservation Order 556A issuueded o IV', 2018. BPXA on lune appreciates the efforts of the commission to revise the sundry matrix to improve efficiency with well work operations. The sundry matrix approved by the commission in Conservation Orderro ed sundrycmatrix from 2005. technologies and procedures that have evolved since the previous app roses the edits made in red in the attached mark-up of the sundry matrix, address. BPXA respectfully p However, there are a few editss to the revised sundry matrix, dated lune 12, 2018, that BPXA would like to p purposes. be considered for clarification and consistency pur p Justification for Reconsideration BPXA respectfully submits the following justifications for this Application for Reconsideration, listed in order of our redlined edits to the sundry matrix by page number and corresponding sections: Application for Reconsideration Docket Number: Conservation Order 556A Prudhoe Bay Field July 2, 2018 page 1 Third Column: THRU-TUBING OPERATIONS 10 403 Re uired 10_404L407 Re uired: Second Bullet. BPXA proposes adding the verbiage "Reservoir Zonal Abandonment" tby o "Plug & Abandon /suspend/ Reservoir Zonal Isolation". We believe this requir oneand ai jecHonitted wemis\ aokk s am and adding it would provide consistency between the product requirements in the Sundry Matrix. ears to Fifth Bullet. The reference to "SSV/ SSSv" (surface safety valve/sub surface safety valves) app (sub -surface controlled sub - be an error, and BPXA believes theintended that the hestatement read'Initial SSCSSV alvference is to "SCSV" e installation and surface safety valves). BPXA prop design". This revision would provide cla royals than safety valves end sub -surface safety valves that example: K -valves) require different app are controlled by surface equipment. j Column: OTHER OPEKA1IUrva. •- - Second Bullet. BPXA proposes removing "major welding repair on wellhead" from this column as the er ng ty that is not already icluded in: meas nweld on stir and BPXA cnnot identify arting head/bradenhead connections or olyd"surfacle'casing weldi g repairs" well wo k "reap air This edit would also provide consistency between the production and injection well work requirements of the sundry matrix. Third Bullet. BPXA proposes editing this bullet to read: "Drilling/Compietions Operations Shutdown" Th Thbe consistent with the similar statement on sundry matrix Page 2 for Injection Wells. to und "cutaways' as that appears to be an Fourth Bullet. BPXA proposes removing the quotations aro error and the term is not defined. This edit would provide consistency between production and injection well work requirements in the sundry matrix. by Ninth Bullet. BPXA proposes removing "cement" from ,Cement top job surface casing conductor annulus'. Removing the specification on using cement provides consistency between the production and injection well work requirements in the sundry matrix. Tenth Bullet. BPXA proposes removing this Gravel packo below cr Pageb3llet from s reference be s section. column.) Gravel pack is a completion design. (BPXA is also proposing included in the included with other completion designs under the "Mechanical Completion (Rig/nclud Sandscreen are installed after tubing is installed in a wellbore and is already production/injection control list. 2 Application for Reconsideration Docket Number: Conservation order 556A Prudhoe Bay Field July 2, 2018 Page 2 First Column OTHER OPERATIONS 110-403 Not Required 30-404/407 Not Required: Second Bullet. BPXA proposes removing "WI" and replacing that reference with "Water Alternating Gas (WAG)" for clarification. BPXA believes that the reference to -WI- is an error, as we do not see a purpose for including "WI" in the "WI/WAG swaps" statement. Second Column OTHER OPERATIONS / 10-403 Not Required 10-404 /407 Required: Fifth Bullet. BPXA proposes adding a new bullet reading "Conduct suspended well inspection (initial & subsequent)" for injection wells, Adding this requirement provides consistency between production and injection well work requirements in the sundry matrix. Third Column OTHER OPERATIONS / 10-403 Required 10-404 /407 Re ua ired: Tenth Bullet. BPXA proposes adding a new bullet reading "Surface casing welding repair". Adding this requirement would provide consistency between production and injection well work requirements in the sundry matrix. Page 3 First Column: General Well Work: Fifth Line. BPXA proposes removing "Run dummy or gauge ring" as it is duplicative of - "Run dummy drift or gauge ring' - listed in the same section. Tenth Line. BPXA proposes removing "Change GLV" as it is a duplicate since it is already listed in the Artificial Lift list. Third Column: Mechanical Completion (Riy,/coill: first Line. BPXA proposes changing "tubing" to "pulling tubing" for consistency with the Conservation Order 556A, Finding 1. The word tubing is vague. Seventh Line. BPXA proposes adding anew seventh line that reads "Gravel Pack completion". (Please see the Page 1 discussion above.) Fourth Column: Production/Iniection: Seventh Line. BPXA proposes adding a new seventh line that reads "Isolation sleeve to this list, as they are different from the "Isolation sleeve regulator valves" referenced in this section. Isolation sleeves are intended to be opened or closed and isolation sleeve regulator valves control rate. I:1 Application for Reconsideration Docket Number: Conservation Order 556A Prudhoe Bay Field July 2, 2018 For all the reasons discussed above, BPXA respectfully requests that the commission reconsider its order, and amend the sundry matrix in accordance with the enclosed redlined m of PBU wells. BPXA welcomes and integ tY BPXA and the PBU owners share AOGCC's focifications to CO 556A sundry matrix. us on safety further discussion of these proposed mod sincerely, Ryan Daniel Engineering Team Leader Intervention and integrityg BP Exploration (Alaska) Inc. 4 Application for _. , o ¥»+r Con_mr Order 556A Prudhoe oay Aa alz2,ns 1, k{ `k \k \ \ �\ { C,\ 1, C,\ �\� \� \ ( 1, ( Application for Reconsideration o m»+r Conservation order s A Prudhoe Bay and , zz a | . __ - _ � ! 5 `© !$ 0 0 \ _ — !;A !;;!! • � !! 9 ; � 1}iC\ ` \ \\E` " 4 ! | Application for Reconsideration Docket Number: Conservation Order 556A Prudhoe Bay Field July 2, 2018 3 E 6 c. r =G i.sa og r o 3 - - - 3 _ - 5 F F N y w Y rc S 3 a - O � rt 3 E 6 c. r =G i.sa og r o 3 - - - 3 _ - 5 3 E 6 c. r =G i.sa og 3 - - - 3 H3° 7 Select bolded lists to reveal drop-down menus. Also available on the last page. Well Work Operations Matrix d Reporting Requirements Sundry ApPlleation eoSundry Conservation Order 586A Operator: BP Exploration (Alaska), Inc Juae 12,2018 DEVELOPMENT IPR )DUCTIONuj WELLS... General Well Work List Surveys List Log List Praduction/Injection Control List Artificial Lift Pam,Ing operations List THEK urc Mr----- Replace/Repan Xeres nor or wollhead valve Page 1 of 3 Perforate new iramal wilbrn a Pool lnstall/Remove Liner Top Packeent plug) Dompn3ail Cement (for pent ker Cuttailpipeortubingto control fluid movement in Instell/Rentov0 mechanical device (Plug or pecker) Install tubing patch JMPING OPERA luno, -- mutation _ Squeeze/plug to cod wid. rdcontrol fluidmo amen in eon Indoor polymer for profile improvement fHEROPERAOuno denhead connections Repmr weld on starting he al(bre lent material Repair wellheadltree Peck offwith aes Conduct suspended well inspection (initial & subsequenQ Perforate a new pool d! Reservoir Lnnal Abavdnnmem Plug & Abandon! Suspen Ron Pronarmarstrievable scab liner Set whipstock for sidetrack or lateral initial 88Wglig" SSCSSSV valve installation & design Remedial Cement List Polymer/Resin Repair list pruppmtt or Acid Fracture Stimulation Mechanical Completions List Casing Alterations List Convert producer to injecHO d prillinp/C Operations Shutdo Conducrol " uwaY� cutaways Sorfuce casing weldmg repairs Conductor extension Repair extemal Surfaca Casing Plug for redrlllconductor anulus �o'raface casing by G�dsoceea W.P/Clamp fnrrrmnno on wellhead W,g Work Operations Sundry Application sod Reporting Requirements Sundry Metrix oration (Alaska)• Inc Conservation Order 556A Operator! P Exit' Genernl Well Work List Survevs List Log Lis[ Production/luiection Control List Pumping Operations List i"ER OPERATRma eor wellhead&valve ReolaceBmav Xmsx tr^ WI/WAG Swaps (,) Ona • dwells: operator must (2) Oaesat aux on discos Page 2 of 3 Perforac new humid within a Pool Acker) to control lostall/RemoW mechanical device (Plug or P lintd movement in zone )Mru—-- --- - "- Squeexe/plug to control fluid movement in mne Inject Polymer for profile improvement T,—IFR OPERA"lilting Convert from initial water infector to WAG t ack Convert from infector to producer if Flowing bback more than 30 days Repair weld on Stanineheallisce head connections Sealant Material & Conductor fill Conduct susneoded well inrarcti^^ (initial & subsepuen0 detmnine Sundries reached. Perforate a new Pool Cmmilpipeormbfng anent lug) D.,upBatl Cement (for pens P Install/Remove Liner Top Packer Plue & Abandon / Suspend / Reservoir Tonal Abandomnem Rm oeranent/romevdle cab feet Set whipstock for sidetrack or laterai Install mbfng Patch Remedial Cement List Polvmer/Resin Repair list Proopent or Aad Pr^^^^e Stimulation Water Wash Gas Iniector Acid Stimulaticn (HCI, Mud Acid) Casing Alterations List Mechanical ComPlettons List rmvROrercn I--- on wellhead Wrap/Clamp furan' te Retain WellhOadlrree with sealant material Repair e,nomal mince casing Too fob on surface casing by conductor amulus Convert Iniector to Producer Plug for redrill Conductor extension Conductor cutaway. Orflling/Completions Operatons Shutdown welding repairs Surface | � ,•!§,5 !i!\|I\ 3 AGOCC 1 4/20/2017 ITMO: PROPOSED AMENDMENT TOWAIW CERTAIN REQUIREMENTS DOCKET No. CO 17-006 ALASKA OIL AND GAS CONSERVATION COMMISSION Before Commissioners: Cathy Foerster, Chair Daniel T. Seamount Hollis French In the Matter of the Proposed Amendment to Waive Certain Requirements of 20 AAC 25.280 Concerning Applications for Sundry Approvals for Workover Operations and the Document Well Work Operations and Sundry Notice/ Reporting Requirements for Pools Subject to Sundry Waiver Rules dated July 29, 2005 and Applications for Sundry Approvals for Workover Operations. t No.: CO 17-006 CO 17-007 CO 17-008 PUBLIC HEARING ALASKA OIL and GAS CONSERVATION COMMISSION Anchorage, Alaska April 20, 2017 9:00 o'clock a.m. Recorded and transcribed by: Computer Matrix Court Reporters, LLC 135 Christensen Drive, Suite 2 Anchorage, AK 99501 907-243-0668/sahile@gci.net Computer Matrix, LLC Phone: %7-243-0666 135 Christensen Or., Ste. 2., Anoh. AK 99501 Fax: %7-243-1473 Email enhilt, ,ei nel AGOCC 420/2019 ITMO PROPOSED AMENDMENT TO WAIVE CERTAIN REQUIREOM17 006 ENTS DOCKET No Computer Matrix, LLC Phone 907-2437668 Lmnil mhll Mogen nn 135 Chrineneen Or., Ste 2., Anch. AK 99501 Pax 907-243-1471 Page 2 1 TABLE OF CONTENTS 2 Opening remarks by Chair Foerster 03 3 Remarks by Ms. Loepp 06 4 Remarks by Mr. Kanady 09 5 Remarks by Ms. Ohmes 17 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Computer Matrix, LLC Phone 907-2437668 Lmnil mhll Mogen nn 135 Chrineneen Or., Ste 2., Anch. AK 99501 Pax 907-243-1471 r AGOCC 4/202017 ITMO. PROPOSED AMENDNFM TO WANE CERTAIN REQUIREMENTS DOCKET No. CO 17-OOfi Page 3 1 P R O C E E D I N G S 2 (On record - 9:00 a.m.) 3 CHAIR FOERSTER: I'll call this hearing to 4 order. Today is April 20, 2017, the time is 9:00 a.m. 5 We're located at the offices of the Alaska Oil and Gas 6 Conservation Commission, 333 West Seventh Avenue, 7 Anchorage, Alaska. To my left is Commissioner Dan 8 Seamount, to my right is Commissioner Hollis French and 9 I'm Cathy Foerster. 10 Today's hearing is regarding docket number CO 11 17-006, well work operations and sundry notice 12 reporting requirements, conservation order 556 which 13 includes the following fields and pools. Prudhoe Bay 14 field, Prudhoe oil pool, Point McIntyre oil pool, Stump 15 Island oil pool, Lisburne oil pool, Niakuk oil pool, 16 Aurora oil pool, Borealis oil pool, Orion oil pool, 17 Polaris oil pool, Midnight Sun oil pool, North Prudhoe 18 Bay oil pool and West Beach oil pool. 19 It also includes -- today's hearing covers 20 docket number CO 17-007, well work operations and 21 sundry notice reporting requirements, CO 261A which 22 includes the following field and pools. Kuparuk River 23 field, Kuparuk River oil pool, West Sak oil pool, 24 Tabasco oil pool, Tarn oil pool, Meltwater oil pool. 25 And docket number CO 17-008, well work and Computer Metrix, LLC Phone: 9W-2434668 135 Christensen Or, Ste. 2.. Anch. AK 99501 Fox: 90]-243-14)3 Email: sahile@i SG net AOOCC 4W2017 ITMO: PROPOSED AMENDMENT TOWAIVECERTAIN REQUIREh NTS DOCKET No, CO 17-006 Page 4 1 operations and sundry notice reporting requirements for 2 conservation order 443B, Colville River field, Alpine 3 pool; conservation order 562, Colville River field, 4 Fiord pool; conservation order 569, Colville River 5 field, Nanuq pool; and conservation order 605 Colville 6 River field, Qannik pool. 7 On its own motion the AOGCC is proposing an 8 amendment to rules waiving certain requirements of 20 9 AAC 25.280 concerning applications for sundry approval 10 for well work operations and the document Well Work 11 Operations and Sundry Notice Reporting Requirements for 12 pools subject to sundry waiver rules. 13 We have a couple of maybes and a couple of 14 yeses on testimony. And we may have some new people in 15 the room so I'll lay out the lay of the land in how the 16 process will work. 17 Commissioners will ask questions, they may ask 18 questions during testimony, we may also take a recess 19 to consult with staff to determine whether additional 20 information or clarifying questions are necessary or as 21 I like to say to make sure our questions are 22 intelligent. If a member of the audience has a 23 question that he or she feels should be asked please 24 submit that question in writing to Jody Colombie who's 25 doing the float wave in the back. She'll provide the Computer Mauix, LLC Phone, 907-243-0668 135 Christensen Dr., Ste. 2., Ana. AK 99501 Fax 907-243.1403 Email sahitcQi go no AWCC 4120/20/7 ITMO-. PROPOSED AMENDMENT TO WANE CERTAM REQUIREMENTS DOCKET No. CO 17-006 Page 5 1 questions to the Commissioners and if we feel that 2 asking any question will assist us in making our 3 determination we will ask that question. 4 When you're testifying please keep in mind that 5 you must speak into the microphone so that those in the 6 audience and court reporter can hear your testimony. 7 But before you do that you need to make sure that the 8 little green light is shining brightly. Also please 9 remember if you have any slides to reference them so 10 that someone reading the public record in the future 11 can follow along. For example refer to the slides by 12 their number and if they're not numbered refer to them 13 by the heading or other identifying feature on the 14 slide. 15 All testimony must be relevant to the purposes 16 of the hearing that I outlined a few minutes ago and to 17 the statutory authority of the AOGCC. I think the 18 people in this room know how to follow that 19 requirement. Anyone desiring to testify may do so, but 20 if the testimony drifts off subject we'll limit the 21 testimony to three minutes. Additionally testimony 22 will not take the form of cross examination. As I said 23 before Commissioners ask the questions. Finally 24 testimony that is disrespectful or inappropriate will 25 not be allowed. Computer Matrix, LLC Phone: 9W-243-0666 135 Christensen Dr, Ste. 2., MO. AK 99501 Fax: 90]-243-14]3 EMMI sahlIC&O net AGOCC 4202019 ITMO- PROPOSED AMENDMLNI IOWA I VE CERTAIN RFQ W REMENTS DOCKET N. CO I9-006 Page 6 1 Commissioner Seamount, do you have anything to 2 add for the good of the order? 3 COMMISSIONER SEAMOUNT: I have nothing. 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CHAIR FOERSTER: Commissioner French. COMMISSIONER FRENCH: No, thank you. CHAIR FOERSTER: Okay. Well, let's start with testimony. I think the best place to start would be if Victoria Loepp who works for the AOGCC gives a little bit of the groundwork behind why we've called for this hearing. So, Ms. Loepp, raise your right hand. (Oath administered) MS. LOEPP: I do. VICTORIA LOEPP called as a witness on behalf of the AOGCC, testified as follows on: DIRECT EXAMINATION CHAIR FOERSTER: All right. Do we need to qualify whether she's an expert in the job that we have hired her to do or can we just accept that as recognition of her expertise? MR. BALLANTINE: (Indiscernible - away from microphone)..... CHAIR FOERSTER: Okay. Please proceed. Yes, we can accept that. Conipwer Metrix, LLC Phone.907-243-0668 135 Chrinensen Dr., Six 2, Arid, AK 99501 Pax 407-243-1473 Ymaif snM1ile_dgei na AGOCC I 4/202017 ITMO: PROPOSED AI NDMENT TO WAM CERTAIN REQUIREMENTS DOCKET No. CO 17-006 Page 7 1 MS. LOEPP: On its own motion the AOGCC 2 scheduled this hearing to amend the sundry matrix which 3 is referenced in several conservation orders for 4 Prudhoe Bay field and Kuparuk River field and to adopt 5 the sundry matrix for the Colville River field. Copies 6 of the proposed sundry matrix have been submitted to 7 the court reporter for each of the fields. 8 The sundry matrix is a reference and guidance 9 table that clarifies and outlines sundry application 10 and reporting requirements for well work operations, 11 specifically 10-403 and 10-404 application 12 requirements. The original sundry matrix was included 13 in several conservation orders and was introduced July 14 29th, 2005. The sundry matrix has not been updated for 15 almost 12 years. 16 The Commission proposes to make the following 17 amendments or changes to the conservation orders. The 18 first is to modify the format and content of the sundry 19 matrix as outlined in the drafted documents. And one 20 of the changes will be to make the sundry matrix -- 21 each sundry matrix specific to a conservation order and 22 to an operator. We also plan to change the title to 23 include the conservation order that it applies to as 24 well as the operator. 25 We will propose to add a rule nine to both the Computer Matrix, LLC Phone: 907-243-0668 135 Chrisensen Dr., Ste. 2., Ara AK 99101 Fax 907-243-1473 Email: sahile@gainer AGOCC 1 ( 4nOR017 ITMO: PROPOS ED AMENDMENT TO WAIVE CERTAIN REQUIREMENTS DOCKET UI CO I)NODS Page 8 1 Kuparuk and Prudhoe Bay conservation orders and this 2 rule would specify that the sundry matrix applies to 3 the current operator and will not be effective for a 4 change in operatorship. 5 And the last minor amendment would be delete 6 rule six which is some reporting -- submission of a 7 weekly report that was submitted by the operators that 8 is no longer needed or has not been needed. 9 So that sums up our changes. 10 CHAIR FOERSTER: Okay. Thank you, Ms. Loepp. 11 Commissioner Seamount, do you have any questions? 12 COMMISSIONER SEAMOUNT: No, I don't. 13 CHAIR FOERSTER: Commissioner French. 14 COMMISSIONER FRENCH: No. 15 CHAIR FOERSTER: Nor do I. Thank you for 16 getting this kicked off for us. 17 All right. I'm going to go to the yeses and 18 let the maybes commit later. All right. Going just 19 down the list the -- well, the only other yes we have 20 is Mr. Kanady from ConocoPhillips. 21 Mr. Kanady, come on up. 22 MR. KANADY: Good morning. 23 CHAIR FOERSTER: Good morning. Raise your 24 right hand. 25 (Oath administered) Computer Matrix, LLC Phone: 907-2434M68 . sehile©Bci. 135 Christensen Dr., Ste. 2., Arch. " 99501 Pax: 907-243-1473 Email net AGOCC I 4MI2017 ITMO-. PROPOSED AMENDMENT TO WAIVE CERTAM REQUIREMENTS DOCKET N. CO 17-006 Page 9 1 MR. KANADY: I do. 2 CHAIR FOERSTER: And I'm guessing that you want 3 to be recognized as an expert? 4 MR, KANADY: I really don't need to this 5 morning. 6 CHAIR FOERSTER: Okay. Okay. But let the 7 record reflect we've recognized you as an expert many 8 times before and it would probably not be a problem, 9 but go ahead. 10 MR. KANADY: Okay. Thank you. 11 RANDALL KANADY 12 called as a witness on behalf of ConocoPhillips, 13 testified as follows on: 14 DIRECT EXAMINATION 15 MR. KANADY: So ConocoPhillips appreciates the 16 opportunity to provide comments on the proposed well 17 work operations and sundry report requirements for the 18 Kuparuk and Alpine fields. And Conoco would like to 19 thank the Commission for all the upfront work the 20 Commission has done in developing the proposed sundry 21 matrix. It is not an easy job to put this all 22 together. 23 Today Conoco is submitting several minor 24 proposed changes to the matrix, to the sundry matrix, 25 which we would like to review with the Commission Computer Matrix, LLC Phone: 907-243 0 8 135 Christensen Dc, Ste. 2., An6 AK 99501 Fax 90)-243-14]3 Email: sahile@gci.net AGOCC 4202017 ITMO PROPOSED AMENDMENT TO WANE CERTAIN REOOIREMENIS DOCKET No CO 17.006 Page 10 1 today. The type of changes that Conoco has proposed 2 are on routine maintenance work that is currently being 3 done at Kuparuk under a 10-404 report. Conoco is doing 4 the routine maintenance work, complying with all state 5 and federal requirements and reporting this work to the 6 Commission on the 10-404 report. And we look at this 7 as a performance based type approach which we feel is g more efficient on routine type work. And these changes 9 are highlighted in our written comments that we 10 submitted to the Commission today and I'd like to 11 highlight those. 12 So today Conoco has submitted written comments. 13 The first three pages is a general discussion on our 14 justification for the changes. So the first three 15 pages are the general description..... 16 CHAIR FOERSTER: Mr. Kanady, can we..... 17 Is there anyone in the audience who feels that lg they need to have a copy of this in order for us to 19 continue or..... 20 (No comments) 21 CHAIR FOERSTER: All the heads are moving left 22 and right. Okay. I'm sorry for the interruption. 23 MR. KANADY: So we did submit 10 copies of 24 this..... 25 CHAIR FOERSTER: Okay. Computer Matrix, LLC Phone 90-243-0868 135 Ch iter m Dr, Ste 2., Amph AK 99501 Fax 907-243-1493 Email OhileQ¢yci net AGOCC 4/202019 ITMO.PROPOSEDAVlENDhIENrTOWAIVECERTAINRF_QUIR NIFNTS DOCKET No CO 1]-006 Page 11 1 MR, KANADY: .....of the comments. So..... 2 CHAIR FOERSTER: So there probably are some in 3 the back of the room. 4 MR. KANADY: .....hopefully..... 5 UNIDENTIFIED VOICE: (Indiscernible - away from 6 microphone)..... 7 MR. KANADY: Good. g CHAIR FOERSTER: Okay. Thank you. 9 MR. KANADY: I think we're good. And then the 10 next three pages are what we received from the AOGCC, 11 the proposed matrix, and what I would like to focus on 12 is the last three pages or our proposed comments which 13 are in red. 14 So the first proposed change is included on 15 attachment two, page 1, and the category is on 16 production wells, rig operations and replacing tubing 17 with no casing alterations. This implementation of the lg 2005 sundry matrix, 10-403, which is a request for 19 approval for sundry work has not been required for 20 tubing replacement at Kuparuk. Tubing replacements 21 with no casing alternations is a routine operation at 22 the Kuparuk and Alpine fields. And this has been a 23 successful and efficient program that Conoco is not 24 aware of any issues that have arisen from a lack of a 25 403 approval, a 10-403 approval. So Conoco is Phone 907 243U669 13 S Chr Computer Matrix, LLC US Mislenzen Dc, Sie. 2., Anch. AK 99501 Fax 907- T+ Emrvil zahil"p-1 nee243-I4 AO'OCC 4;2012017 IT%40 PROPOSED AMENDMENT TOW AI PI4 CER FAIN RFNb IRECUIN,TS Page 12 1 requesting that tubing replacements be allowed without 2 a 10-403 approval. Approximately 205 workovers have 3 been completed at Kuparuk since 210 and 150 of those 4 have been workovers on producers of which 120 were 5 worked on with just a 10-404 report. 6 So that's our first request or first comment. 7 Our second comment is on page 2 of attachment 8 two in regards to injectors, injection wells, rig 9 operations, replacing tubing with no casing 10 alterations. And this is similar to the preceding 11 request, that Conoco is requesting that an injection 12 well tubing replacement be allowed without a 10-403 13 approval since tubing replacements do not cause a 14 significant change in the operational condition of the 15 well. Utilizing a performance based requirement on the 16 Kuparuk production well tubing replacements has shown 17 to be very efficient and a fit for purpose process. 18 Let's see, moving on to back to page 1 on 19 attachment one. On production wells, other operations 20 down at the -- in the middle at the bottom, this is in 21 regards to sealant material and conductor fill. And 22 Conoco requests that for production wells other 23 operations, operations of sealant material and 24 conductor fill be included in the middle column so that 25 a 10-403 would not be required, but a 10-404 would be Compwer Mnlnx, LLC Phone: W7-243-0668 EIn 11 snM1lleQgci ml a 135 Chn-,s ,, De, SIe 2, An,h AK 99501 Pa. 909-245 1473 AGOCC 4I2N2019 ITMO'. PROPOSED Abffi HENT TO W AIVECERTAM U UI C NTS DOC Page 13 1 required. The current established system for routine 2 maintenance, top offs of the conductor and the -- with 3 cement and/or sealant is a successful program and has 4 been working efficiently at Kuparuk and Conoco is not 5 aware of any issue that has arisen from the lack of a 6 10-403 approval on this type of work. 7 So finally the Kuparuk field has been utilizing g the 2005 sundry matrix that was adopted to the 9 conservation order number 261A. And Conoco supports 10 updating conservation order 261A to adopt the proposed 11 sundry matrix with the changes that we've recommended 12 in our written comments. And similarly Conoco would 13 support developing a conservation order similar to 261A 14 to adopt the proposed sundry matrix for the pools in 15 the Colville field. 16 And this concludes Conoco's comments today and 17 thank you for your attention. lg CHAIR FOERSTER: Thank you, Mr. Kanady. 19 Commissioner Seamount, do you have any questions? 20 COMMISSIONER SEAMOUNT: No, I don't. Thank 21 you, Mr. Kanady. 22 CHAIR FOERSTER: Commissioner French. 23 COMMISSIONER FRENCH: just one. Mr. Kanady, 24 can you go over the -- when you were talking about the 25 first point you made about whether or not you need a Computer Matrix, LLC Phane: 961-24343668 Email sahile,3i yci.ne� 135 Christensen Dr., Ste. 2, Anch. AK 99501 Fax: 907-243-1473 AGOCC 4/202017 I1h10 PROPOSED AMENDMENT TO N'AIVI' CERTAINEITAIN REQUI E NNIS Nil Page 14 1 permit to simply replace the tubing, you gave us some 2 statistics about the number of workovers since 2010, 3 205 workovers since 2010. 4 MR. KANADY: Yeah, uh-huh. 5 COMMISSIONER FRENCH: Can you just run through 6 those numbers again, I was jotting them down as fast as 7 I could? g MR. KANADY: Sure. So approximately 205 9 workovers have been completed in Kuparuk since 2010. 10 And 150 of those have been on producers and 120 of 11 those have -- of those workovers have been completed 12 under a 10-404. Basically those were just tubing swaps 13 and they weren't -- didn't require casing repairs. 14 Anything that..... 15 COMMISSIONER FRENCH: Pull the tube -- you pull 16 the tubing, replace the tubing and submit a 10-404? 17 MR. KANADY: Right. And we adhere to all the 18 AOGCC requirements for BOPE testing and other 19 requirements. And it's a performance test, we take the 20 responsibility to comply with all the regulations and 21 we report on the work that we've done. 22 COMMISSIONER FRENCH: Sure. Thanks. That's my 23 only question. Thank you. 24 CHAIR FOERSTER: Okay. I have a couple. I'm 25 an engineer, you know how we think. I'm looking at Phom, 907 -243 -lm- Email sahilei�)5o "I Computer Matrix, LEC Fax 907-243-147.+ 135 Christensen D,., Ste 2, Am,h. AK 99501 AGOCC 4802019 I I'MO. PROPOSED AMENDMENT 100 AIVECEKTAN REQ oI REPOM1 0116 NTS DOC Page 15 1 pages 1, 2 and 3 and I'm seeing red comments that you 2 didn't address in your oral testimony. 3 MR. KANADY: Yeah. Yes. 4 CHAIR FOERSTER: Are those of importance to 5 you, should we disregard them, would you like to talk 6 about them? 7 MR. KANADY: They are -- well, so under page 1 8 of attachment 2 the -- under through tubing operations, 9 it's just more of an editorial comment. We think it 10 makes it more clear that -- the highlighted red 11 comments that we have there for install slash remove 12 mechanical device, a plug or a pack I guess for -- and 13 it's for zonal isolation, it's more of a -- I think we 14 -- that makes it more clear I think for what it's 15 trying to do as opposed to control fluid movement. 16 It's a judgment call. We really don't feel 17 extremely..... 18 CHAIR FOERSTER: That's a suggestion? 19 MR. KANADY: That's a suggestion. 20 CHAIR FOERSTER: Okay. And then on page 3 you 21 had another one. 22 MR. KANADY: Yeah. So that's on the remedial 23 cement work list and we're suggesting that we add an IA 24 cement squeeze in there. And I think that would fall 25 under requiring a 403 approval before that's completed. Ph.9, 901-243-0668 Compute Ma,d 901-243-1413 x, LLC gmail seMle(�yci net 135 Chns,e . D[.519 2_ Md AK 99501 Pex 4/20/2017 ITMO. PROPOSED AMENDMENT TO WANE CERTAINDOCKRLOREEIFNIS Nb CO 1 IS AGOCC 1 CHAIR FOERSTER: Okay. Okay. Thank you, Mr 2 Kanady 3 MR KANADY: You're welcome. 4 CHAIR FOERSTER: Any other questions now that 5 I've stirred the pot? 6 COMMISSIONER FRENCH: No. 7 CHAIR FOERSTER: No. Okay. All right. Thank g you so much. 9 MR KANADY: Thank you. 10 CHAIR FOERSTER: All right. Now I have 11 Danielle Ohmes and Ryan Daniel as maybes. Are you 12 willing to commit to a yes or a no on whether you want 13 to testify? 14 MR. DANIEL: I'll take the lead. At this stage 15 I don't have any additional testimony other than what 16 my (indiscernible - away from microphone)..... 17 CHAIR FOERSTER: Oh, if you're going to talk 18 you need to let the court reporter hear you. 19 MR. DANIEL: I think the answer's no. 20 CHAIR FOERSTER: Okay. We love speeches, Ryan, 21 so don't let us stop you. 22 MR. DANIEL: I'm happy to talk too. 23 CHAIR FOERSTER: I know you are. All right. 24 Is there anyone else in the audience who desires to 25 testify who we've missed? Phone: 907-243-ohmsEmniF sahile�gli net Computer Matrix, LLC Far 907-243-1473 135 Chrotensen Or.. Ste 2., Aoah AK 99501 AGOCC 4/2MOI7 ITMO PROPOSED AMENDMENT TOWAIVE CER I AIN Rl UIRIO,IIN116 TS DO( KE Page 17 1 All right. I -- one of our maybes committed to 2 a yes. All right. Please step up to a microphone, 3 make sure the green light is shining brightly..... 4 MS. OHMES: Okay. 5 CHAIR FOERSTER: .....and raise you right hand. 6 Oh, first your name for the record. 7 MS. OHMES: Danielle Ohmes with BP. 8 CHAIR FOERSTER: And you represent BP. Okay. 9 No matter what it says on this piece of paper. Raise 10 your right hand. 11 (Oath administered) 12 MS. OHMES: Yes. 13 CHAIR FOERSTER: And do you wish to be 14 recognized as an expert. 15 MS. OHMES: Probably not necessary..... 16 CHAIR FOERSTER: You can put your hand down. 17 MS. OHMES: .....for this. 18 CHAIR FOERSTER: Okay. All right. Please 19 proceed. 20 DANIELLE OHMES 21 called as a witness on behalf of BP testified as 22 follows on: 23 DIRECT EXAMINATION 24 MS. OHMES: Just wanted to mention it wasn't 25 included in the opening, but we have two additional Fhone. 901 44J Veoe 14.111114.1111 seh111111 yd re, Compmer Metrix, LLC Fex 907-2431493 135 Christensen Dr., Ste. 2. Arch. AK 99501 AGOCC 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 412012017 ITMO: PROPOSED AMENDMENT TO WAIVE CER AM KEhffiNTS DOCKET Not O1]-006 Page 18 pools that Prudhoe operates, the Raven which is conservation order 570 and the Put River conservation order 559. And we'd like them included with conservation 556 updates. We did send a note in on that, but it wasn't mentioned..... CHAIR FOERSTER: That was my fault. MS. OHMES: .....at the beginning. CHAIR FOERSTER: Okay. Thank you. MS. OHMES: So I just wanted to make sure that didn't get overlooked. CHAIR FOERSTER: included. Yeah, and those will be MS. OHMES: Thank you. That's all. CHAIR FOERSTER: All right. Thank you so much for catching that. All right. Anyone else wish to testify? (No comments) CHAIR FOERSTER: Going once, twice. Anything for the good of the order before we adjourn, Commissioner Seamount? COMMISSIONER SEAMOUNT: No. CHAIR FOERSTER: Commissioner French. COMMISSIONER FRENCH: No, thank you. CHAIR FOERSTER: All right. At 9:19 we're adjourned. Compiler Maori., LLC Nal 90]-243-147J Phone' 9PY343Lbe6 Email sahileggci an 135 Christensen Dr., Ste. I, Anch. AK 99501 r 4/2012017 ITMO'. PROPOSED Ah MN NT TO WAIVE CERTAIN REQUIRRIUNTS UIRRIUNTS DOCKET AGOCC Page 19 1 (Hearing adjourned 9:19 a.m.) 2 (END OF REQUESTED PORTION) 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Phone'. 90M,13-0 8 Email. sahileQgci nei Computer Matrix, LLC Fix907-243-1473 135 Christensen Dr., Ste. 2., Anch. AK 99501 AGOCC 4/202 M 01] ITMO: PROPOSED AMENDMENT TO WAIVE CERTAIN RE UI OMENTS 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 Page 20 TRANSCRIBER'S CERTIFICATE I, Salena A. Hile, hereby certify that the foregoing pages numbered 02 through 20 are a true, accurate, and complete transcript of proceedings in re: Docket No.: CO 17-006; CO 17-007; CO 17-008 public hearing, transcribed under my direction from a copy of an electronic sound recording to the best of our knowledge and ability. Date Salena A. Hile, Transcriber CamPaher Metrix, LLC Phone: 90b243-0668 Emaii . sahoe@Rci. net 135 Christensen Dr., She. 2., Arch, AK 99501 Fax: 909-243-1403 STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION Docket No. CO 17-006, CO 17-007 and CO 17-008 April 20, 2017 at 9:00 am NAME AFFILIATION Testify (yes or no) A _ I _ _1.: P11P AIC9 rji)AC. t, IRNA 0 OJUA#4 Rvck 0 PA NO - C lnr s Wc<.'lI ac.p� iQ L/ � mac, �/icfori LoCp,u .14-o6cic VCs • -1... i ♦ TTAWT Testifv (ve% or no) pj� ConocoPhillips Alaska, Inc. April 20, 2017 Commissioner Cathy Foerster, Chair Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, Alaska 99501 Re: Docket Number CO -17-007 RECEIVED APR 2 0 2017 AOGCC Shon D. Robinson Manager Drilling & Wells 700 G Street, ATO 1520 Anchorage, AK 99501 907 265 6306 shon.d.robinson@cop.com Hand Delivered Docket Number CO -17-008 Well Work Operations and Sundry Notice/Reporting Requirements Dear Commissioner Foerster: ConocoPhillips supports AOGCC's proposed Well Work Operations and Sundry Notice/Report Requirements (Sundry Matrix), subject to three recommended changes. The proposed Sundry Matrix will help clarify the approval and reporting requirements for wellwork in the Kuparuk and Alpine fields. CPAI has worked closely with AOGCC staff on developing the proposed Sundry Matrix (attachment 1) and is generally in agreement with the proposal, but would like to propose the minor changes highlighted in RED on the draft Sundry Matrix included as Attachment II. The justifications for the proposed changes are included below. 1. Production Wells - Rig Operations — Replacing Tubing (with no casing alterations) CPAI requests that tubing replacements on production wells be allowed without 10-403 form. • Since implementation of the 2005 Sundry Matrix, 10-403's have not been required for tubing replacements within the Kuparuk Field. This has been a successful program and CPAI is not aware of issues arising from the lack of a 403 approval. • Requiring a 10-403 approval for tubing replacements would require additional administrative work with no identifiable benefit. The 10-403 approval process would potentially cause delays in completing rig workovers. Not requiring 10-403's would allow the rig schedule to be Alaska Oil and Gas Conservation Commission April 20, 2017 Page 2 optimized when operations change unexpectedly. Since 2010 there have been 151 Producer workovers in Kuparuk and 120 of those workovers were tubing swaps. By continuing with the current practice of requiring a 10-404 sundry reports on tubing swaps (no 10-403 application), ensures that the administrative work would not increase for routine maintenance work (such as tubing swaps). AOGCC staff expressed a desire to specify the required BOP test pressure in advance of RWO operations, but we believe BOP test pressure are adequately regulated as follows: o regulations codified at 20 AAC 25.035 already clearly specify the pressure that is required for operations; 0 opportunity to verify adequate test pressures exists during the witness notification process, since operators are required to provide 24 hour notification of BOP testing to the AOGCC; and o the 10-404 describes to what pressure the BOP's were tested. 2. Infection Wells - Rig Operations - Replacing Tubing (with no casing alterations) Similar to the preceding request, ConocoPhillips respectfully requests that an injection well tubing replacement be allowed without a 10-403 form since tubing replacement does not cause a significant change in the operational condition of the well. For the following reasons, we think it is in the best interest of all parties to eliminate the requirement for a 10-403 in advance of rig workover tubing change (with no casing alterations) for water and gas injection wells. • Tubing replacements are considered routine operations to improve the current condition of a well. • Requiring a 10-403 approval for tubing replacements will require additional administrative work with no identifiable benefit. The 10-403 approval process would potentially cause delays in completing rig workovers. 3. Production Wells - Other Operations - Sealant Material & Conductor Fill: CPAI requests that for Production Wells - OTHER OPERATIONS, the operation "Sealant Material & Conductor Fill" be included in the middle column, so that a 10-403 would not be required, but a 10-404 would be required. Listed below is a description of CPAI's current system for maintenance top -offs of the conductor with cement and/or sealant, which explains why no change is necessary: • A well is identified with a low cement top in the surface casing by conductor annulus. • After several wells have been identified, the Well Integrity group tops the wells off with cement. These are typically volumes of only a couple of gallons. • Once the cement has had time to cure properly, the cement is topped off with Sealant (RG -2401). Alaska Oil and Gas Conservation Commission April 20, 2017 Page 3 • Once a batch of wells have been completed, a spreadsheet tallying all the wells and a cover letter are sent to the AOGCC. Historically, that was approved to fulfill the requirement for a 10-404. • No 10-403 have been required for these small top jobs that have been done in groups. Currently the Kuparuk field has been utilizing the 2005 Sundry Matrix that was adopted through the Conservation Order No. 261A. CPAI would support updating CO 261A to adopt the proposed Sundry Matrix, with the changes recommended here. Similarly, CPAI would support a Conservation Order like CO 261A be developed and adopted for pools in the Colville River Field. CPAI appreciates the opportunity to work with the AOGCC on developing the new Sundry Matrix for the Kuparuk and Alpines Fields. Please let myself or Randall Kanady (907-263-4126) know if you have any question regarding this request. Shon D. Robinson Manager Drilling & Wells ConocoPhillips Alaska, Inc. Attachments SDR:rbk ATTACHMENT I DRAFT 3232017 Modifications Well Work Operations and Sundry Notice / Reporting Requirements for Pools Subject to Sundry Waiver Rules June 1, 2017 Select bolded lists to reveal drop-down menus. Also available on the last page. DEVELOPMENT [PRODUCTION] WELLS('i 10403 Not Required 10403 Not Required 10-403 Required 10-404 Not Required 10-4041407 Required 10-404 / 407 Required THRU-TUBING OPERATIONS THRU-TUBING OPERATIONS THRU-TUBING OPERATIONS • General Well Work List • Perforate new interval within a pool • Perforate anew pool • Surveys List • Install/Remove Liner Top Packer • Plug & Abandon / Suspend • Log List • Dump/Bail Cement (for permanent plug) • Run permanent/retrievable scab liner • Production/Injection Control List • Cut tailpipe or tubing • Set whipstock for sidetrack or lateral • Artificial Lift • Install/Remove mechanical device (plug or packed) to control • Initial SSC/SSSV valve installation & design fluid movement in zone • Install tubing patch PUMPING OPERATIONS, INCLUDING USING COIL PUMPING OPERATIONS, INCLUDING USING COIL PUMPING OPERATIONS, INCLUDING USING COIL • Pumping Operations List • Stimulate (HCI, Mud acid, acid) -Non-fracture stimulation • Remedial Cement List • Squeeze/plug to control fluid movement in zone • Polymer/Resin Repair list • Inject polymer for profile improvement • Proppant or Acid Fracture Stimulation RIG/COIL OPERATIONS RIG/COIL OPERATIONS RIG/COIL OPERATIONS • Mechanical Completions List • Casing Alterations List OTHER OPERATIONS OTHER OPERATIONS OTHER OPERATIONS • Replace/Repair Xmax tree or wellhead valve • Repair weld on starting head/bradenhead connections • Convert producer to injector • Repair wellhead/tree pack off with sealant material • Major welding repair on wellhead • Conduct suspended well inspection (initial & subsequent) • Operations Shutdown (Drilling/Completions Operations • Conductor"cutaways" • Surface casing welding repairs • Conductor extension • Repair external Surface Casing • Plug for redrill • Cement top job on surface casing by conductor annulus • Gravel pack or Sandscreen • Wrap/Clamp furmanite on wellhead (l) On a case-by-case basis, a 10-403 will be required for a particular well or operation if the AOGCC requests it. The operator should consult with the AOGCC to aetermme it it IU-4UJ IS ueeaea. Incorporated Conservation Orders: 261 A, 556, 443 B, 562, 569, 605 Page 1 of 3 ATTACHMENT 1 DRAFT 323/2017 Modifications Well Work Operations and Sundry Notice / Reporting Requirements for Pools Subject to Sundry Waiver Rules June 1, 2017 INJECTION WELLS(pl2) 10-403 Not Required 10-403 Not Required 10-403 Required 10-404 Not Required 10-404 1407 Required 10-404 / 407 Reculdred THRU-TUBING OPERATIONS THRU-TUBING OPERATIONS THRU-TUBING OPERATIONS • General Well Work List • Perforate new interval within a pool • Perforate a new pool • Surveys List • Install/Remove Liner Top Packer • Cut tailpipe or tubing • Log List • Install/Remove mechanical device (plug or packed) to control • Dump/Bail Cement (for permanent plug) • Production/Injection Control List fluid movement in zone • Install/Remove Liner Top Packer • Plug & Abandon / Suspend / Reservoir Zonal Abandonment • Run permanenNretrievable scab liner • Set whipstock for sidetrack or lateral • Install tubing patch PUMPING OPERATIONS, INCLUDING USING COIL PUMPING OPERATIONS, INCLUDING USING COIL PUMPING OPERATIONS, INCLUDING USING COIL • Pumping Operations List • Squeeze/plug to control fluid movement in zone • Remedial Cement List • Inject Polymer for profile improvement • Polymer/Resin Repair list • Proppant or Acid Fracture Stimulation • Water Wash Gas Injector • Acid Stimulation (HCI, Mud Acid) RIG/COIL OPERATIONS RIG/COIL OPERATIONS RIG/COIL OPERATIONS • Casing Alterations List • Mechanical Completions List OTHER OPERATIONS OTHER OPERATIONS OTHER OPERATIONS • Replace/Repair Xmax tree or wellhead & valve • Convert from initial water injector to WAG injector • Wrap/Clamp farmanim on wellhead • WI/WAG Swaps • Convert from injector to producer if flowing back • Repair Wellhead/Trice with sealant material more than 30 days • Repair external surface casing • Repair weld on Starting headBradenhead connections • Top job on surface casing by conductor annulus • Sealant Material & Conductor fill • Convert Injector to Producer • Plug for redrill • Conductor extension • Conductor cutaway • Drilling/Completions Operations Shutdown (1) On a case-by-case basis, a 10403 will be required for a particular well or operation if the AOGCC requests it. The operator should consult with the AOGCC to determine if a 10-403 is needed. (2) Operations on disposal wells: operator must contact AOGCC to determine Sundries required. Page 2 of 3 ATTACHMENT 1 DRAFT 3/23/2017 Modifications Well Work Operations and Sundry Notice / Reporting Requirements for Pools Subject to Sundry Waiver Rules June 1, 2017 Sundry Notice/ ReportingRc uirements: 10-403 Not Reqaired, 10-404 Not Required General Well Work: Surveys: Well Logs: Production/Injection: Artificial Lift: Pumping Operations: Tag Fill Pressure (CNL) Compensated Neutron Water Flood Regulator Change GLV Scale Set or pull retrievable plugs Temperature (TDT) Thermal Decay Time Sliding Sleeve Change downhole pump/ Sludge to secure wells not in zone Spinner (CO) Carbon Oxygen AVA Nipple Qetpump/ESP) Ice Plug Run dummy drift or gauge ring Obtain bottom hole sample (CCL) Casing Collar Locator Production Mandrel Install/remove packoff/patch Freeze protect Run dummy or gauge ring Gyro Cement Evaluation Downhole Choke GLM Inhibitor squeeze Punch tubing Production/injection profile Temperature Reperforate existing interval Perform hot oil treatment Dump or bail sand/ sluggits Pressure Isolation sleeve regulator Acidize Tubing Tubing scrapes (scale, Video valve CTU clean out paraffin,etc.) Caliper Sand or rockscreen FCO Ni Change GLV Acoustic LDL Stim gun/Slim tube Displace well with fluid Other Flowback after stimulation Perform high pressure perf breakdown Nitrogen lift pressure test Booster pump in conductor Schmoo-B-Gone Sundry Notice / Re orcin Re uirements: 10-403 Required, 10-404/407 Required Remedial Cement: Polymer/Resin: Mechanical Completion (Rig/coil): Casing Alterations (Rig/coil): Casing Shoe Micro -annulus Down Squeeze Tubing Casing patch Micro -annulus Down Squeeze Pressure Activated Sealant Mill Packer Straddle packer Gel Squeezes Velocity String Subsidence repair ESP completion Replace casing Jet pump completion Scab liner PCP completion Tiebacks Stack Packer Page 3 of 3 ATTACHMENT 11 - ConocPhillips Alaska Proposed Changes DRAFT 4/4/2017 Modifications Well Work Operations and Sundry Notice / Reporting Requirements for Pools Subject to Sundry Waiver Rules Select bolded lists to reveal drop-down menus. Also available on the last page. -DUCTION WELLS(/ DEVELOPMENT(PR 1 10 Required 10-403 Not Required 10-403 Not Required 10-404 / 407 Required 10-4044 1 / 407 Required 10404 Not Required THRU-TUBING OPERATIONS THRU-TUBING OPERATIONS THRU-TUBING OPERATIONS • General Well Work List Perforate new interval within a pool Perforate anew pool • Surveys List Install/Remove Liner Top Packer • Plug & Abandon / Suspend • Log List Dump/Bail Cement (for permanent plug) • Ran permanent/retrievable scab liner • Production/Injection Control List Cut tailpipe or tubing • Set whipstock for sidetrack or lateral Install/Remove mechanical device (plug or packed) to-eeuuol- • Initial SSC/SSSV valve installation & design • Artificial Lift -fluid iuovement inaene for zonal isolation • Install tubing patch PUMPING OPERATIONS, INCLUDING USING COIL PUMPING OPERATIONS, INCLUDING USING COIL PUMPING OPERATIONS, INCLUDING USING COIL • Pumping Operations List • Stimulate (HCI, Mud acid, acid) -Non-fracture stimulation • Remedial Cement List • Squeeze/plug to control fluid movement in zone • Polymer/Resin Repair list • Inject polymer for profile improvement Proppant or Acid Fracture Stimulation RIG/COIL OPERATIONS RIG/COIL OPERATIONS RIG/COIL OPERATIONS • Replace tbg • Mechanical Completions List • Casing Alterations List OTHER OPERATIONS OTHER OPERATIONS OTHER OPERATIONS • Replace/Repair Xmax tree or wellhead valve • Repair weld on starting head/bradenhead connections • Convert producer to injector • Repair wellhead/tree pack off with sealant material • Major welding repair on wellhead • Conduct suspended well inspection (initial & subsequent) • Operations Shutdown (Drilling/Completions Operations • Sealant Material & Conductor fill • Conductor "cutaways" • Surface casing welding repairs • Conductor extension • Repair external Surface Casing • Plug for redrill • Cement top job on surface casing by conductor annulus • Gravel pack or Sandscreen • Wrap/Clamp farmanite on wellhead .. ._. .,.,-..,._____._:. T.____._.....w....un..,at„h. Annrr m determine if a 10-403 is needed. (1) On a case-by-case basis, a 10-403 will be required for a particular wen or opeaanon a me AOGCC icy"csas ,...,...,r..... Incorporated Conservation Orders: 261 A, 556, 443 B, 562, 569, 605 Page 1 of 3 ATTACHMENT 11 - ConocPhillips Alaska Proposed Changes DRAFT 4/4/2017 Modifications Well Work Operations and Sundry Notice / Reporting Requirements for Pools Subject to Sundry Waiver Rules INJECTION WELLS(p(2) 10-403 Not Required 10-403 Not Required 10-403 Required 10404 Not Re uired 10-404 1407 Required 10404 / 407 Required THRU-TUBING OPERATIONS THRU-TUBING OPERATIONS THRU-TUBING OPERATIONS • General Well Work List • Perfomte new interval within a pool • Perforate a new pool • Surveys List • Install/Remove Liner Top Packer • Cut tailpipe or tubing • Log List • Install/Remove mechanical device (plug or packed)ko flkol • Dump/Bail Cement (for permanent plug) • Production/Injection Control List -loid-movement "i zone for zonal isolation • Install/Remove Liner Top Packer • Plug & Abandon / Suspend / Reservoir Zonal Abandonment • Run permanent/retrievable scab liner • Set whipstock for sidetrack or lateral • Install tubing patch PUMPING OPERATIONS, INCLUDING USING COIL PUMPING OPERATIONS, INCLUDING USING COIL PUMPING OPERATIONS, INCLUDING USING COIL • Pumping Operations List • Squeeze/plug to control fluid movement in zone • Remedial Cement List • Inject Polymer for profile improvement • Polymer/Resin Repair list • Proppant or Acid Fracture Stimulation • Water Wash Gas Injector • Acid Stimulation (HCI, Mud Acid) RIG/COIL OPERATIONS RIG/COIL OPERATIONS RIG/COIL OPERATIONS • Replace tbg • Casing Alterations List • Mechanical Completions List OTHER OPERATIONS OTHER OPERATIONS OTHER OPERATIONS • Replace/Repair Xmax tree or wellhead & valve • Convert from initial water injector to WAG injector Wrap/Clamp furmanite on wellhead • WI/WAG Swaps • Convert from injector to producer if flowing back Repair Wellhead/Tree with sealant material more than 30 days Repair external surface casing • Repair weld on Starting headBradenhead connections Topjob on surface casing by conductor annulus • Sealant Material & Conductor fill Convert Injector to Producer • Plug for redrill • Conductor extension • Conductor cutaway • Drilling/Completions Operations Shutdown (1) On a case-by<ase basis, a 10-403 will be required for a particular well or operation if the AOGCC requests it. The operator should consult with the AOGCC to determine if a 10-403 is needed. (2) Operations on disposal wells: operator must contact AOGCC to determine Sundries required. Page 2 of 3 ATTACHMENT It - ConocPhillips Alaska Proposed Changes DRAFT Well Work Operations and Sundry Notice / Reporting Requirements for Pools Subject to Sundry Waiver Rules Tag Fill Pressure (CNL)Compensated Neutron Set or pull retrievable plugs Temperature (TDT) TheDecay Time to secure wells not inz�.= Spinner (CO) Carbon Oxygen Run dummy drift or gauge ring Obtain bottom hole sample (CCL) Casing Collar Locator Run dummy or gauge ring Gyro Cement Evaluation Punch tubing Production/Injection profileTempemture Dump or bail sand/ sluggits Pressure Tubing scrapes (scale, Video paraf£n,etc.) Caliper Change GLV Acoustic LDL Completion ;ing Shoe Micro -annulus Down Squeeze I ubmg Iro-annulus Down Squeeze Pressure Activated Sealant Mill Packer Cement Sqz Gel Squeezes Velocity String ESP completion Jet pump completion PCP completion Water Flood Regulator Sliding Sleeve AVA Nipple Production Mandrel Downhole Choke Reperfomte existing interval Isolation sleeve regulator valve Sand or rockscreen Stam gun/Stim tube .Alterations (Rig/coil); patch packer nate repair liner ,cks Packer tificial Lift: sage GLV ange downhole pump/ (jetpump/ESP) tall/remove packoff/patch GLM 4/4/2017 Modifications Operations: cc Plug -reeze protect nhibitor squeeze 'erfonm hot oil treatment Acidize Tubing CTU clean out FCO Nr Displace well with fluid Flowback after stimulation Perform high pressure perf breakdown Nitrogen lift pressure test Rnnater numn in conductor Page 3 of 3 1 Notice of Public Hearing STATE OF ALASKA Alaska Oil and Gas Conservation Commission Re: Docket Number: CO -17-006 Well Work Operations and Sundry Notice/Reporting Requirements On its own motion the Alaska Oil and Gas Conservation Commission (AOGCC) will hold a hearing to propose an amendment to rules waiving certain requirements of 20 AAC 25.280 concerning Applications for Sundry Approval for workover operations and the document Well Work Operations and Sundry Notice/Reporting Requirements for Pools Subject to Sundry Waiver Rules dated July 29, 2005 for Conservation Order 556 and the following field and pools: Prudhoe Bay Field, Prudhoe Bay Oil Pool Prudhoe Bay Field, Pt. McIntyre Oil Pool Prudhoe Bay Field, Stump Island Oil Pool Prudhoe Bay Field, Lisburne Oil Pool Prudhoe Bay Field, Niakuk Oil Pool Prudhoe Bay Field, Aurora Oil Pool Prudhoe Bay Field, Borealis Oil Pool Prudhoe Bay Field, Orion Oil Pool Prudhoe Bay Field, Polaris Oil Pool Prudhoe Bay Field, Midnight Sun Oil Pool Prudhoe Bay Field, North Prudhoe Bay Oil Pool Prudhoe Bay Field, West Beach Oil Pool The AOGCC has scheduled a public hearing on this matter for April 20, 2017 at 9:00 a.m. at 333 West 7th Avenue, Anchorage, Alaska 99501. 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 the conclusion of the April 20, 2017 hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing contact the AOGCC at (907)279-1433 no later thanApril13, 2017. Cathy, dotster Chair, Commissioner Form: 02-901 Revised: 3/9/2017 ADVERTISPIG ORDER NUMBER STATE OF ALASKA ADVERTISING ORDER NOTICE TO PUBLISHER SUBMIT MWICE SHOWING ADVERTISING ORDER NO., CERTD'MD AFFIDANTF OF PUBLICATION WITH ATTACHED COPY OF ADYERTLSMFW' AO-17-�26 FROM: AGENCY CONTACT: Jod Colombie/Samantha Carlisle Alaska Oil and Gas Conservation Commission DATE OF A.O. AGENCY PHONE: 333 West 7th Avenue 03/09/17 907 279-1433 Anchorage, Alaska 99501 DATES ADVERTISEMENT REQUIRED: COMPANY CONTACT NAME: PHONE NUMBER: ASAP FAX NUMBER: 1907 276-7542 TO PUBLISHER: SPECIAL INSTRUCTIONS: Alaska Dispatch News PO Box 149001 Anchorage, Alaska 99514 TYPE OF ADVERTISEMENT: Fv LEGAL F_ DISPLAY 1— CLASSIFIED OTHER (Specify belDWj DESCRIPTION PRICE CO -17-006, CO -17-007, CO -17-008 Initials of who re ared AO: . . . . . . :::�j7B431TiNi'VICCSIiAW[14G+9YER'ItSING:: Ri'IFIEUjtFR1U�.Y1T'QP>::;: :: rUsl:l !?!ghiwlTi!:yrrAd pf1Plty .::;:: :<:nPycprlglai•:Nt:'[0;:::;:::::::::>.::.. Alaska Non -Taxable 92-600185 Department of Administration Division of AOGCC 333 West 7th Avenue Total of Anchors e, Alaska 99501 Pae 1 of I All Pa es $ REF Type Numbe,.. Amount Daft Conimrnb I PVN ADN89311 2 AO AO -17-026 3 4 FEN AMOUNT SY 1 17 Appr Unit I PGM I LGR Object FY DIST LIQ 0211477173046 17 2 3 4 5 ority Name:' Purchasing Authe: rc m this 's Si Telephone Number I,C�K 1. A.D. # and receiving agency name must appear on all Invoices and documents relating to this porch 2. The stale is registered for tax free transactions under Chapter 32. IRS code. Registrslim number 92-7 K. Items are far the exclusive use of the state and not for resale. DlS FRIBU fIONc DiviSioa Riscal(Original AO. Copses :Pub �(faxbd) Urvnion Fiscal Relelvt, g Form: 02-901 Revised: 3/9/2017 270227 0001401646 $219.14 STATE OF ALASKA RECEIVED MAR 15 2017 AOGGG AFFIDAVIT OF PUBLICATION THIRD JUDICIAL DISTRICT Emma Dunlap being first duly sworn on oath deposes and says that he/she is a representative of the Alaska Dispatch News, a daily newspaper. That said newspaper has been approved by the Third Judicial Court, Anchorage, Alaska, and it now and has been published in the English language continually as a daily newspaper in Anchorage, Alaska, and it is now and during all said time was printed in an office maintained at the aforesaid place of publication of said newspaper. That the annexed is a copy of an advertisement as it was published in regular issues (and not in supplemental form) of said newspaper on March 12. 2017 and that such newspaper was regularly distributed to its subscribers during all of said period. That the full amount of the fee charged for the foregoing publication is not in excess of the rate charged private individuals. �\ Signed Subscribed and sworn to before me this 13th day of March, 2017 Notary Pub is in and for The State of Alaska. Third Division Anchorage, Alaska MY COMMISSION EXPIRES 4-'g x/ NotiCe Of Pub11C Nearing STATE OF ALASKA Alaska Oil and Gas Conservation Commission Re: - Docket Number: CO -17-006 Well Work Operations and Sundry Notice/Reporting Requirements its own motion the Alaska Oil and Gas Conservation Commission GCC) will hold a hearing to propose an amendment to rules waiving tain requirements of 20 AAC 25.290 concerning Applications for idry Approval for workover operations and the document Well Work nations and Sundry Notice/Reporting Requirements for Pools eject to Sundry Waiver Rules dated July 29, 2005 for Conservation ler 556 and the following field and pools: Prudhoe Bay Field, Prudhoe Bay Oil Pool Prudhoe Bay Field, Pt. Mclnrire oil Pool Prudhoe eav Field. Stump Is and Oil Pool Bay Bay Bay Bay Bay .,, The 2017 at scheduledC has 0 a.m. at 333West? 7th publichearing enue, Anchorthis age, Alaska 995011 20 In addition, written comments regarding this application may be submitte99501. Commeto ntsAm must beat 333 West 7th received no later than the conclusion ofl thea April 20, 2017 hearing. If, because of a disability, special accommodations may be needed to comment or attend the Bearing contact the AOGCC at (907)279-1433 no later than April 13, 2017. AO -17-026 Published: March 12, 2017 Notary Public { BRITNEY L. THOMPSON ? State of Alaska My Commission Expires Feb 23, 2019 Notice of Public Hearing STATE OF ALASKA Alaska Oil and Gas Conservation Commission Re: Docket Number: CO -17-006 Well Work Operations and Sundry Notice/Reporting Requirements On its own motion the Alaska Oil and Gas Conservation Commission (AOGCC) will hold a hearing to propose an amendment to rules waiving certain requirements of 20 AAC 25.280 concerning Applications for Sundry Approval for workover operations and the document Well Work Operations and Sundry Notice/Reporting Requirements for Pools Subject to Sundry Waiver Rules dated July 29, 2005 for Conservation Order 556 and the following field and pools: Prudhoe Bay Field, Prudhoe Bay Oil Pool Prudhoe Bay Field, Pt. McIntyre Oil Pool Prudhoe Bay Field, Stump Island Oil Pool Prudhoe Bay Field, Lisburne Oil Pool Prudhoe Bay Field, Niakuk Oil Pool Prudhoe Bay Field, Aurora Oil Pool Prudhoe Bay Field, Borealis Oil Pool Prudhoe Bay Field, Orion Oil Pool Prudhoe Bay Field, Polaris Oil Pool Prudhoe Bay Field, Midnight Sun Oil Pool Prudhoe Bay Field, North Prudhoe Bay Oil Pool Prudhoe Bay Field, West Beach Oil Pool The AOGCC has scheduled a public hearing on this matter for April 20, 2017 at 9:00 a.m. at 333 West 7th Avenue, Anchorage, Alaska 99501. 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 the conclusion of the April 20, 2017 hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing contact the AOGCC at (907)279-1433 no later than April 13, 2017. //signature on file// Cathy P. Foerster Chair, Commissioner Berme Karl Gordon Severson Penny Vadla K&K Recycling Inc. 3201 Westmar Cir. 399 W. Riverview Ave. P.O. Box 58055 Anchorage, AK 99508-0336 Soldotna, AK 99669-7714 Fairbanks, AK 99711-0055 George Vaught, Jr. Darwin Waldsmith Richard Wagner P.O. Box 13557 P.O. Box 39309 P.O. Box 60868 Denver, CO 80201-3557 Ninilchik, AK 99639-0309 Fairbanks, AK 99706-0868 -Zj _ct _ 2a \-( rm Sinqh, Anqela K (DOA) From: Carlisle, Samantha J (DOA) Sent: Thursday, March 09, 2017 1:44 PM To: Nathan (nwhcmatrix@hotmail.com); Salena (sahile@gci.net); Ballantine, Tab A (LAW); Bender, Makana K (DOA); Bettis, Patricia K (DOA); Bixby, Brian D (DOA); Brooks, Phoebe L (DOA); Carlisle, Samantha J (DOA); Colombie, Jody J (DOA); Cook, Guy D (DOA); Davies, Stephen F (DOA); Eaton, Loraine E (DOA); Foerster, Catherine P (DOA); French, Hollis (DOA); Frystacky, Michal (DOA); Grimaldi, Louis R (DOA); Guhl, Meredith D (DOA); Herrera, Matthew F (DOA); Jones, Jeffery B (DOA); Kair, Michael N (DOA); Link, Liz M (DOA); Loepp, Victoria T (DOA); Mumm, Joseph (DOA sponsored); Noble, Robert C (DOA); Paladijczuk, Tracie L (DOA); Pasqua], Maria (DOA); Quick, Michael J (DOA); Regg, James B (DOA); Roby, David S (DOA); Scheve, Charles M (DOA); Schwartz, Guy L (DOA); Seamount, Dan T (DOA); Singh, Angela K (DOA); Wallace, Chris D (DOA); AK, GWO Projects Well Integrity; AKDCWellIntegrityCoordinator, Alan Bailey; Alex Demarban; Alexander Bridge; Allen Huckabay; Andrew Vandedack; Ann Danielson; Anna Raff; Barbara F Fullmer, bbritch; bbohrer@ap.org; Ben Boettger; Bill Bredar; Bob Shavelson; Brandon Viator, Brian Havelock; Bruce Webb; Caleb Conrad; Candi English; Cocklan- Vendl, Mary E; Colleen Miller, Connie Downing; Crandall, Krissell; D Lawrence; Dale Hoffman; Darci Horner, Dave Harbour, David Boelens; David Duffy; David House; David McCa]eb; David McCraine; David Tetta; ddonkel@cfl.rr.com; DNROG Units (DNR sponsored); Donna Ambruz; Ed Jones; Elizabeth Harball; Elowe, Kristin; Elwood Brehmer; Evan Osborne; Evans, John R (LDZX); George Pollock, Gordon Pospisil; Greeley, Destin M (DOR); Gretchen Stoddard; gspfoff; Hurst, Rona D (DNR); Hyun, James 1 (DNR); Jacki Rose; Jdarlington oarlington@gmail.com); Jeanne McPherren; Jerry Hodgden; Jill Simek; Jim Watt; Jim White; Joe Lastufka; Radio Kenai; Burdick, John D (DNR); Easton, John R (DNR); Larsen, John M (DOR); John Stuart; Jon Goltz; Chmielowski, Josef (DNR); Juanita Lovett; Judy Stanek; Kari Moriarty; Kasper Kowalewski; Kazeem Adegbola; Keith Torrance; Keith Wiles; Kelly Sperback; Frank, Kevin J (DNR); Kruse, Rebecca D (DNR); Gregersen, Laura S (DNR); Leslie Smith; Lori Nelson; Louisiana Cutler; Luke Keller; Marc Kovak; Dalton, Mark (DOT sponsored); Mark Hanley (mark.han]ey@anadarko.com); Mark Landt; Mark Wedman; Mealear Tauch; Michael Bill; Michael Calkins, Michael Moora; MJ Loveland; mkm7200; Motteram, Luke A; Mueller, Marta R (DNR); Munisteri, Islin W M (DNR); kne]son@petroleumnews.com; Nichole Saunders; Nikki Martin; NSK Problem Well Supv; Patty Alfaro; Paul Craig; Decker, Paul L (DNR); Paul Mazzolini; Pike, Kevin W (DNR); Randall Kanady; Renan Yanish; Richard Cool; Robert Brelsford; Ryan Tunseth; Sara Leverette; Scott Griffith; Shahla Farzan; Shannon Donnelly, Sharmaine Copeland; Sharon Yarawsky; Skutca, Joseph E (DNR); Smart Energy Universe; Smith, Kyle S (DNR); Stephanie Klemmer, Stephen Hennigan; Sternicki, Oliver R; Moothart, Steve R (DNR); Steve Quinn; Suzanne Gibson; sheffie]d@aoga.org; Ted Kramer, Teresa Imm; Thor Cutler, Tim Jones; Tim Mayers; Todd Durkee; trmjrl; Tyler Senden; Umekwe, Maduabuchi P (DNR); Vinnie Catalano; Well Integrity; Well Integrity; Weston Nash; Whitney Pettus; Aaron Gluzman; Aaron Sorrell; Ajibola Adeyeye; Alan Dennis; Assmann, Aaron A; Bajsarowicz, Caroline J; Bruce Williams; Bruno, Jeff J (DNR); Casey Sullivan; Catie Quinn; Corey Munk; Don Shaw; Eric Lidji; Garrett Haag; Smith, Graham O (DNR); Dickenson, Hak K (DNR); Heusser, Heather A (DNR); Fair, Holly S (DNR); Holly Pearen; Jamie M. Long; Jason Bergerson; Jesse Chielowski; Jim Magill; Joe Longo; John Martineck; Josh Kindred; Laney Vazquez; Lois Epstein; Longan, Sara W (DNR); Marc Kuck; Marcia Hobson; Steele, Marie C (DNR); Matt Armstrong; Franger, James M (DNR); Morgan, Kirk A (DNR); Umekwe, Maduabuchi P (DNR); Pat Galvin; Pete Dickinson; Peter Contreras; Richard Garrard; Richmond, Diane M; Robert Province; Ryan Daniel; Sandra Lemke; Pollard, Susan R (LAW); Talib Syed; Tina Grovier (tmgrovier@stoel.com); Tostevin, Breck C (LAW); To: Wayne Wooster, William Van Dyke Subject: Public Hearing Notices Attachments: CO -17-006 Public Hearing Notice.pdf, CO -17-007 Public Hearing Notice.pdf, CO -17-008 Public Hearing Notice.pdf Docket Numbers: CO -17-006, CO -17-007, CO -17-008 Well Work Operations and Sundry Notice/ Reporting Requirements Samantha Carlisle Executive Secretary III Alaska Oil and Gas Conservation Commission 333 West 701 Avenue Anchorage, AK 99501 (907)793-1223 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 Samantha Carlisle at (907) 793-1223 or Samantha.CmUsle@alaska.gov.