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Home My WebLink AboutDIO 030 A INDEX Disposal Injection Order 30 and 30A NNA #2 1. March 23, 2005 Unocal’s Application for an Disposal Injection Order for Deep Creek Unit NNA #2 2. March 30, 2005 Notice of Hearing, Affidavit of publication, e-mail Distribution list, bulk mailing 3. May 3, 2005 Sign In Sheet for Public Hearing 4. May 3, 2005 Transcript 5. May 4, 2005 e-mail to operator 6. May 19, 2005 Ltr from operator regarding application 7. May 23, 2005 e-mail to operator 8. January 29, 2025 Application to amend DIO 47 (DIO 30A.001) 9. March 13, 2025 DIO 47 amendment email chain (DIO 30A.001) Disposal Injection Order 30 and 30A i STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West 7th Avenue, Suite 100 Anchorage Alaska 99501 Re: THE APPLICATION OF Union Oil Company of California for disposal of Class II oil field wastes by underground injection in the Sterling and Beluga Formations in the Deep Creek Unit NNA No.2 Well, Section 11, T2S, R13W, S.M. IT APPEARING THAT: Disposal Injection Order No~ 30A Deep Creek Unit NNA No.2 Well Originally Issued June 1, 2005 Corrected and Amended June 14, 2005 1. By correspondence to the Alaska Oil and Gas Conservation Commission received on March 23, 2005, Union Oil Company of California ("Unocal") requested authorization to allow the underground injection of non-hazardous Class II oil field waste fluids into the Sterling and Beluga Formations within the Deep Creek Unit NNA No.2 ("NNA #2") well bore. 2. The Commission published notice of opportunity for public hearing in the Anchorage Daily News on March 30, 2005 in accordance with 20 AAC 25.540. 3. The Commission did not receive any protests to the application, comments, or requests for a public hearing. 4. A hearing was held on May 3, 2005 at which Unocal provided sworn testimony addressing engineering and geologic considerations in support of the NNA #2 disposal injection order application. The record was held open to allow Unocal to provide supplemental information about the projected zone of influence from injected waste as requested by the Commission. 5. Unocal provided supplemental information addressing the zone of influence, rate of injection, and duration for NNA #2 disposal injection in a letter dated May 19, 2005. 6. Disposal Injection Order No. 30 was issued on June 1, 2005. 7. The Commission is providing this Disposal Injection Order No. 30A to supersede and replace Disposal Injection Order No. 30, clarifying the fluids authorized for injection. Page 2 of8DisposalInjectionOrder30A NNA No.2 June 14,2005 FINDINGS: 1. Location of adjacent wells (20 AAC 25.252 (c)(1) NNA #2 is planned as a near vertical well located approximately 342 feet from the south line and 420 feet from the west line of Section 11, Township 2 South, Range 13 West, Seward Meridian. The well is proposed to be drilled from an existing drilling pad located on the Kenai Peninsula approximately 6 miles east of the city of Ninilchik. NNA #1, a disposal injection well supporting Deep Creek Unit development is the only well located within 1;4 mile of the planned NNA #2. As proposed, there would be 370 to 440 feet of wellbore separation between NNA #1 and NNA #2 at the proposed injection interval. 2. Notification of Operators/Surface Owners (20 AAC 25.252 (c)(2) and 20 AAC 25.252 (c)(3)) Unocal is the only operator within 1;4 mile radius of the proposed disposal operation. The sole surface owner within a 1;4 mile radius of NNA #2 is Ninilchik Native Association, Inc. Unocal provided evidence that a copy of its application for disposal injection in NNA #2 was sent by certified mail to Ninilchik Native Association, Inc., on March 17,2005. 3. Geologic information on disposal and confining zones (20 AAC 25.252 (c)(4)) Unocal proposes to conduct disposal into the Sterling and Beluga Formations between 2,180 feet and 2,800 feet.! Disposal operations in the NNA #2 will not impact adjacent production from the Happy Valley Field as seismic and well control, including extensive testing demonstrate that NNA #1 and NNA #2 are located off structure and outside of the known productive limits of the Happy Valley Field reservoirs; and the nearest development wells are approximately 2 miles away. In the adjacent near vertical NNA #1 the Sterling Formation is present in the interval from 220 feet to 2,529 feet. Similar depths are expected in NNA #2. The Sterling Formation in the Happy Valley Field vicinity consists of thick and massive sandstones and conglomerates frequently exceeding 100 net feet in thickness interbedded with siltstones, shales, and minor amounts of thin coals. These sediments were deposited in terrestrial (fluvial, lacustrine, alluvial) environments. The sandstones typically have high permeability and porosity with common permeability's exceeding several 100 millidarcies and porosities between 25 and 30 percent. 1 All depths noted in this Order are measured depth ("MD") referenced to NNA #2 and are substantially equivalent to true vertical depth ("TVD") below ground level in this near vertical well. Page 3 of8DisposalInjectionOrder30A NNA No.2 June 14, 2005 The Beluga Formation will be present in NNA #2 from approximately 2,529 feet to total well depth at approximately 2,800 feet. The formation is comprised of thinly bedded and clay rich sediments otherwise lithologically similar to the Sterling Formation. The Beluga Formation was deposited in terrestrial environments similar to the Sterling Formation except Beluga Formation sandstones and conglomerates were deposited in predominately braided stream environments instead of fluvial systems. NNA #2 will encounter sandstones in the Beluga Formation that are generally less than 20 feet thick, have good porosities (20%+ range), but with permeability's generally below 100 millidarcies due to large amounts of depositional clay. Confining strata for the requested Sterling and Beluga Formation disposal zones consist of shales, claystones, siltstones and coal beds that range in thickness from 6 inches to more than 30 feet. Coals at the depths of the requested disposal zone in the Sterling and Beluga Formations do not behave elastically and their properties are difficult to determine from borehole logs, but UNOCAL's experiences in conducting hydraulic fracture treatments in this area suggest that coals typically act importantly as near plastic confining beds. Information provided by Unocal in their March 23, 2005 application identifies approximately 200 ft of confining lithologies between the aquifer exemption depth (1,800 feet per AEO No. 11) and the depth of uppermost planned injection perforations (2,180 feet). From offset well NNA #1, at least 350 feet of confining lithologies have been identified between the depths of 1,930 feet and 2,610 feet. 4. Evaluation of Confining Zones (20 AAC 25.252 (c)(9)) The potential to fracture through the confining lithologies at NNA #2 was modeled by a Unocal consultant. The goal of this evaluation was to predict the expected upward fracture growth for cuttings disposal at NNA #2 using worst-case assumptions. The simulation assumed continuous 2-day injection of 8,000 barrels of slurry. Four perforated intervals spread over the proposed injection interval were individually evaluated, the shallowest being 2,210 feet to 2,240 feet. Slurry make-up was assumed to have a 12 percent solids concentration with 30/50-mesh sand distribution and density of 10 pounds per gallon. Injection rate for the modeling work was 3 barrels per minute. In this worst-case model, the critical factor is vertical fracture propagation, with a critical limit being the freshwater aquifers. The fracture analysis indicates that coal and shale intervals overlying the injection intervals tend to impede the fracture height growth. For the shallowest interval evaluated, the fracture height growth under worst- case modeling does not grow above a depth of 2,180 feet. Unocal further notes that the injection assumptions included in the modeling work significantly exceed maximum estimated fluid injection per day. Unocal's study of regional stresses in the area indicate that any fractures induced in the NNA #2 disposal interval will propagate away from NNA #1. Page 4 of8DisposalInjectionOrder30A NNA No.2 June 14,2005 5. Standard Laboratory Water Analysis of the Disposal Zone (20 AAC 25.252 (c)(10)) A laboratory analysis of water produced from the Beluga formation B-40 sand in the Happy Valley #8 well (taken in January 2005) indicates total dissolved solids greater than 8,000 ppm. 6. Well Logs (20 AAC 25.252 (c)(5)) Unocal plans to drill NNA #2 beginning mid-July 2005. Commission regulation requires the submittal of well logs within 30 days of well completion. Well logs from NNA #1 are on file with the Commission. In addition, there are offset data from the Happy Valley development. 7. Demonstration of Mechanical Integrity and Disposal Zone Isolation (20 AAC 25.252 c )(6)) Well construction for NNA #2 includes conductor pipe driven to refusal (estimated 100 feet) and production casing installed to a depth of 2,812 feet. Production casing will be cemented from total depth to surface. Unocal plans to evaluate the annulus cement with a cement mapping tool to confirm the adequacy of the cement sheath in providing isolation of the injected fluids from freshwater above 1,800 feet. NNA #2 will be equipped with tubing and packer to isolate pressure to the disposal interval. A mechanical integrity test will be conducted prior to injection; Unocal provides a proposed procedure that includes notification to the Commission, proposed test pressure, and documentation. 8. Disposal Fluid Type. Source, Volume and Compatibility with Disposal Zone (20 AAC 25.252 (c)(7)) NNA #1 injection is limited by performance to produced water and clear fluids (no solids). NNA #2 will serve as the primary drilling waste disposal well for drilling at the Happy Valley Field, and a waste disposal well for disposal of approved Class II fluids from other Unocal operated fields. Specific wastes include drilling, completion, production, and workover fluids; stimulation fluids and solids; tracer materials; rig wash fluids; glycol dehydration wastes; drilling mud slurries; naturally occurring radioactive material scale slurries; precipitation accumulating in containment areas; tank bottoms; and other fluids brought to surface and generated in connection with oil and gas development activities. Unocal estimates a maximum of 3,000 barrels per day of fluid will be injected in NNA #2. Page 5 of8DisposalInjectionOrder30A NNA No.2 June 14,2005 9. Estimated Injection Pressure (20 AAC 25.252 (c)(8)) Unocal estimates average surface injection pressure will be 650 pSlg and the maximum surface injection pressure will be 1,300 psig. 10. Aquifer Exemption (20 AAC 25.252 (c)(11)) Pursuant to a separate proceeding, an aquifer exemption has been granted, in Aquifer Exemption Order No. 11, for depths greater than 1,800 feet covering 3 specific areas within the Deep Creek Unit: A ~ mile radius around the NNA #1; All of Section 22, which includes the Happy Valley pad and associated wells; The southeast one-quarter of Section 15; and All of Section 21, which will cover a new drill site and associated wells planned by Unocal for the Deep Creek Unit. NNA #2 well falls within the ~ mile radius around NNA #1. 11. Mechanical Condition of Wells Penetrating the Disposal Zone within ~ Mile ofNNA 2 (20 AAC 25.252 (c)(12) NNA #1 is the only well penetrating the disposal zone within a ~ mile radius ofNNA 2. The top of cement in the 7-inch casing annulus of NNA #1 is approximately 5,860 feet, leaving the casing annulus open across the proposed disposal injection interval. Surface casing in NNA #1 is set and cemented at a depth below the base of the aquifer exemption interval. Approved annular disposal operations in NNA #1 below the surface casing shoe have placed nearly 175,000 barrels of drilling waste (as provided in 20 AAC 25.080) without incident. The receiving zone for annular disposal is coincident (and a subset) to the proposed disposal injection interval. CONCLUSIONS: 1. The application requirements of 20 AAC 25 .252( c) have been met. 2. The proposed well design (casing, cement, tubing and packer) for NNA #2 will provide the necessary protection for freshwater by isolating injected fluids and pressure to the wellbore and intended injection zone. Verification of well design through cement evaluation and mechanical integrity testing will be necessary prior to injection. 3. As planned, there are approximately 200 ft of confining lithologies between the aquifer exemption depth (1,800 feet per AEO No. 11) and the depth of the uppermost planned injection perforations (2,180 feet). Annular disposal of nearly 175,000 Page 6 of 8DisposalInjectionOrder30A NNA No.2 June 14,2005 barrels of drilling waste coincident to this interval in NNA #1 has proven the effective isolation of injected material from the freshwater aquifer. 4. Worst-case fracture modeling confirms that waste fluids will be contained within the receiving intervals by the confining lithologies within the Sterling Formation, cement isolation of the well bore and operating conditions. Experience from hydraulic fracture treatments and simulation has shown that shales, claystones, siltstones and coal beds are the main components of the confining interval and will impede fracture height growth. 5. Disposal injection operations in NNA #2 will be conducted at rates and pressures below those estimated to fracture through the confining zones. Therefore, oil field wastes will not enter freshwater strata. 6. Supplemental mechanical integrity demonstrations and surveillance of injection operations are appropriate to ensure waste fluids are contained within the disposal interval. Included are mechanical integrity testing, temperature surveys, monitoring of injection performance (pressures, rates), and analysis of the data for indications of anomalous events. 7. Additional information was provided that documents a zone of influence (calculated volumetric pore space available within the disposal interval) because of the NNA #2's proximity to the aquifer exemption boundary (1/4 mile around NNA #1). Using conservative estimates of effective porosity and net thickness for the receiving zones, and a realistic daily injection rate based on historical disposal injection in analogous fields on the Kenai Peninsula, NNA #2 can operate 10-plus years before wastes reach the aquifer exemption boundary. The operator should periodically review with the Commission the actual performance of disposal injection in NNA #2. NOW, THEREFORE, IT IS ORDERED THAT this Disposal Injection Order NO 30A supersedes Disposal Injection Order No. 30, and that the following rules are adopted: RULE 1: Authorized In.iection Strata for Disposal Subject to the other provisions of this order, injection of authorized fluids for purposes of underground disposal of oil field wastes is permitted into the Sterling and Beluga Formations between 2,180 feet and 2,800 feet in NNA #2. The Commission may immediately suspend, revoke, or modify this authorization if injected fluids fail to be confined within the designated injection strata. RULE 2: Authorized Fluids This authorization is limited only to Class II waste fluids as follows: produced water, drilling, completion, production and work over fluids (including stimulation fluids and solids, and tracer materials), rig wash, drilling mud slurries, NORM scale, precipitation accumulating within containment areas, tank bottoms, and glycol dehydration wastes. Page 7 of8DisposalInjectionOrder30A NNA NO.2 June 14,2005 The Commission may authorize the disposal of additional fluids not identified above on a case-by-case basis if the Commission determines they are suitable for disposal in a Class II well. RULE 3: Demonstration of Mechanical Inte2ritv The mechanical integrity of NNA #2 must be demonstrated before injection begins, and before returning the well to service following a workover affecting mechanical integrity. A Commission-witnessed mechanical integrity test must be performed after injection is commenced for the first time in NNA #2, to be scheduled when injection conditions temperature, pressure, rate, etc.) have stabilized. Subsequent tests must be performed at least once every two years thereafter. The Commission must be notified at least 24 hours in advance to enable a representative to witness mechanical integrity tests. Unless an alternate means is approved by the Commission, mechanical integrity must be demonstrated by a tubing/casing annulus pressure test using a surface pressure of 1,500 psi or 0.25 psi/ft multiplied by the vertical depth of the packer, whichever is greater, that shows stabilizing pressure and does not change more than 10 percent during a 30 minute period. A writtern record of the results of all mechanical integrity tests must be readily available for Commission inspection. RULE 4: Well Inte2rity Failure and Confinement Whenever any pressure communication, leakage or lack of inj ection zone isolation is indicated by injection rate, operating pressure observation, test, survey, log, or other evidence, the operator shall notify the Commission by the next business day and submit a plan of corrective action on a Form 10-403 for Commission approval. The operator shall immediately shut in the well if continued operation would be unsafe or would threaten contamination of freshwater, or if so directed by the Commission. A monthly report of daily tubing and casing annuli pressures and injection rates must be provided to the Commission for all injection wells indicating well integrity failure or lack of injection zone isolation. RULE 5: Surveillance The operator shall obtain a baseline temperature log and a baseline step rate test prior to initial injection. A subsequent temperature log must be performed 1 month after injection begins, to demonstrate the receiving zone of the injected fluids. Surface pressures and rates must be monitored continuously during injection for any indications of fracture height growth. Results of daily wellhead pressure observations in both NNA #1 and NNA #2 must be documented and available to the Commission upon request. Subsequent temperature surveys or other surveillance logging (oxygen activation, acoustic) will be based on the results of the initial and follow-up temperature surveys, and injection performance monitoring data. An annual report evaluating the performance of the disposal operation must be submitted to the Commission by July 1 of each year. The report shall include pressures, fluid volumes (disposal and clean fluid sweeps), injection rates, an assessment of fracture height growth, a description of any anomalous injection results, and a calculated zone of influence by the injection fluids. Page 8 of8DisposalInjectionOrder30A NNA No.2 June 14,2005 RULE 6: Notification of Improper Class II Iniection The operator must immediately notify the Commission if it learns of any improper Class II injection including any movement of injection fluids outside the area covered by Aquifer Exemption Order #11. Additionally, notification requirements of any other State or Federal agency remain the operator's responsibility. RULE 7: Administrative Action Unless notice and public hearing are otherwise required, the Commission may administratively waive or amend any rule stated above as long as the change does not promote waste or jeopardize correlative rights, is based on sound engineering and geoscience principles, and will not result in fluid movement outside of the authorized injection zone. RULE 8: Conditions It is a condition of this authorization that operations be conducted in accordance with the rules set out in this order, with AS 31.05, and (unless specifically superseded by Commission order) with 20 AAC 25. Failure to comply with an applicable provision of AS 31.05, 20 AAC 25, or these rules may result in the sus ension or revocation of this authorization. 6:ioner AS 31.05.080 provides that within 20 days after receipt of written notice of the entry of an order, a person affected by it may file with the Commission an application for rehearing. A request for rehearing must be received by 4:30 PM on the 23rd day following the date of the order, or next working day if a holiday or weekend, to be timely filed. The Commission shall grant or refuse the application in whole or in part within 10 days. The Commission can refuse an application by not acting on it within the 10-day period. An affected person has 30 days from the date the Commission refùses the application or mails (or otherwise distributes) an order upon rehearing, both being the final order of the Commission, to appeal the decision to Superior Court. Where a request for rehearing is denied by nonaction of the Commission, the 30-day period for appeal to Superior Court runs from the date on which the request is deemed denied (i.e., 10th day after the application for rehearing was filed). mended Orders Cook Inlet and Admin Approv~ Q)edoubt Subject: Amended Orders Cook Inlet and Admin Approval Redoubt From: Jody Colombie <jody _colombie@admin.state.akus> Date: Wed, 15 Jun 2005 11 :30:50 -0800 To: undisclosed-recipients:; of2 6/15/2005 11 :31 AM Citgo Petroleum Corporation PO Box 3758 Tulsa, OK 74136 Mona Dickens Tesoro Refining and Marketing Co. Supply & Distribution 300 Concord Plaza Drive San Antonio, TX 78216 Jerry Hodgden Hodgden Oil Company 408 18th Street Golden, CO 80401-2433 Kay Munger Munger Oil Information Service, Inc PO Box 45738 Los Angeles, CA 90045-0738 Mark Wedman Halliburton 6900 Arctic Blvd. Anchorage, AK 99502 Ciri Land Department PO Box 93330 Anchorage, AK 99503 Jill Schneider US Geological Survey 4200 University Dr. Anchorage, AK 99508 Darwin Waldsmith PO Box 39309 Ninilchick, AK 99639 Penny Vadla 399 West Riverview Avenue Soldotna, AK 99669-7714 Bernie Karl K&K Recycling Inc. PO Box 58055 Fairbanks, AK 99711 Mary Jones XTO Energy, Inc. Cartography 810 Houston Street, Ste 2000 Ft. Worth, TX 76102-6298 Robert Gravely 7681 South Kit Carson Drive Littleton, CO 80122 Richard Neahring NRG Associates President PO Box 1655 Colorado Springs, CO 80901 Samuel Van Vactor Economic Insight Inc. 3004 SW First Ave. Portland, OR 97201 Schlumberger Drilling and Measurements 2525 Gambell Street #400 Anchorage, AK 99503 Baker Oil Tools 4730 Business Park Blvd., #44 Anchorage, AK 99503 Gordon Severson 3201 Westmar Cr. Anchorage, AK 99508-4336 James Gibbs PO Box 1597 Soldotna, AK 99669 Richard Wagner PO Box 60868 Fairbanks, AK 99706 Williams Thomas Arctic Slope Regional Corporation Land Department PO Box 129 Barrow, AK 99723 David McCaleb IHS Energy Group GEPS 5333 Westheimer, Ste 100 Houston, TX 77056 George Vaught, Jr. PO Box 13557 Denver, CO 80201-3557 John Levorsen 200 North 3rd Street, #1202 BOise,ID 83702 Michael Parks Marple's Business Newsletter 117 West Mercer St, Ste 200 Seattle, WA 98119-3960 David Cusato 200 West 34th PMB 411 Anchorage, AK 99503 Ivan Gillian 9649 Musket Bell Cr.#5 Anchorage, AK 99507 Jack Hakkila PO Box 190083 Anchorage, AK 99519 Kenai National Wildlife Refuge Refuge Manager PO Box 2139 Soldotna, AK 99669-2139 Cliff Burglin PO Box 70131 Fairbanks, AK 99707 North Slope Borough PO Box 69 Barrow, AK 99723 J7a//d ç;f¢ '5 Alaska Oil and Gas Conservation Commission 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907.279.1433 Fax: 907.276.7542 www.aogcc.alaska.gov ADMINISTRATIVE APPROVAL DISPOSAL INJECTION ORDER 47.001 DISPOSAL INJECTION ORDER 28A.001 DISPOSAL INJECTION ORDER 30A.001 Mr. Daniel Taylor, P.E. Well Integrity Engineer Hilcorp Alaska, LLC. 3800 Centerpoint Drive Anchorage, AK 99503 Re: Docket Number: DIO-25-001 Disposal Injection Order 47.001 Request for Amendment to Rule 2 of Disposal Injection Order (DIO) 47 Amendment to Rule 6 of DIO 47 Susan Dionne 8 (PTD 2130510), Ninilchik Unit, Kenai Peninsula DIO 28A.001 Amendment to Rule 2 and Rule 5, Rescinding Rule 7 of DIO 28A NNA-1 (PTD 2012150) Deep Creek Unit, Kenai Peninsula DIO 30A.001 Expiration of DIO 30A NNA-2 (PTD N/A) Deep Creek Unit, Kenai Peninsula Dear Mr. Taylor: By emailed letter dated January 29, 2025, Hilcorp Alaska, LLC (Hilcorp) requested an amendment to Rule 2 of DIO 47 to allow disposal of wastes Hilcorp generated from other Units. In accordance with 20 AAC 25.556(d), the Alaska Oil and Gas Conservation Commission (AOGCC) hereby GRANTS Hilcorp’s request to amend DIO 47 Rule 2: Authorized Fluids, to authorize disposal of Hilcorp generated wastes from additional Units. In addition, on its own motion, AOGCC amends DIO 47 Rule 2, to authorize commercial disposal operations (i.e. wastes generated from other operators, and/or from other Units). In addition, on its own motion, AOGCC amends DIO 47 Rule 6: Surveillance, to increase reporting requirements. In addition, on its own motion, AOGCC amends DIO 28A Rule 2: Authorized Fluids, to authorize commercial disposal operations, amends DIO 28A Rule 5: Surveillance, to increase reporting DIO 47.001 DIO 28A.001 DIO 30A.001 March 19, 2025 Page 2 of 5 requirements, and rescinds DIO 28A Rule 7: Administrative Action. Administrative action of an AOGCC issued order is now authorized under 20 AAC 25.556(d). In addition, on its own motion, in accordance with 20 AAC 25.556(c)(1), AOGCC concludes that DIO 30A has EXPIRED. DIO 30A was issued on June 14, 2005, but the proposed disposal well NNA-2 was not drilled and as such disposal operations did not commence. NOW THEREFORE IT IS ORDERED THAT: DIO 47 shall be amended to read as follows: RULE 2: Authorized Fluids This authorization is limited to Class II eligible waste fluids generated during drilling, production, workover, or abandonment operations, including: Drilling fluids; drill cuttings; well workover fluids; stimulation fluids and solids; produced water; rig wash water; formation materials; naturally occurring radioactive materials; scale; tracer materials; glycol dehydration; reserve pit fluids; chemicals used in the well or for production processing at the surface (in direct contact with produced fluids); and precipitation accumulating in drilling and production impoundment areas. The eligibility of other fluids for Class II waste disposal injection will be considered by the AOGCC on a case-by-case basis upon application by the operator. Commercial Class II oil field waste disposal is approved. Commercial (third party non- Hilcorp generated, and/or generated from other Units) Class II oil field waste disposal shall be in compliance with all rules of this DIO and it remains the responsibility of Hilcorp to accurately account for volumes and ensure that all fluids injected meet Class II eligibility requirements. RULE 6: Surveillance The operator shall run a baseline temperature log and perform a baseline step-rate test prior to initial injection. A subsequent temperature log must be run one month after injection begins to delineate the receiving zone of the injected fluids. The operator shall perform an annual reservoir pressure survey of the disposal zone. Surface pressures and rates must be monitored continuously during injection for any indications of anomalous conditions. Results of daily wellhead pressure observations must be documented and available to the AOGCC upon request. The conduct of subsequent temperature surveys or other surveillance logging (e.g., water flow; acoustic) will be based on the results of the initial and follow-up temperature surveys and injection performance monitoring data. The annual report of underground injection (Form 10-413) shall also include data sufficient to characterize the disposal operation, including, among other information, the following: injection and annuli pressures (i.e., daily average, maximum, and minimum pressures); fluid volumes injected (i.e., in disposal and clean fluid sweeps); injection rates; an assessment of the fracture geometry; a description of any anomalous injection results; a calculated zone of influence for the injected fluids; and an assessment of the applicability DIO 47.001 DIO 28A.001 DIO 30A.001 March 19, 2025 Page 3 of 5 of the disposal order findings, conclusions, and rules based on actual performance. The annual report must be submitted by July 1st. The annual report shall also include a section titled “Induced Seismicity” in which the operator shall detail its monitoring efforts and evaluate the risks. Commercial disposal injection details shall also be provided in the annual performance report. The report shall include: 1. an overview of commercial activities for the year; 2. a list, based on manifests, showing waste generating company, identification of well or pad where the waste was generated, type of waste, volume, transport company/driver, signature/name of Hilcorp authority confirming waste as Class II; 3. a list of the operators that Hilcorp has a Facility User Agreement (FUA) with; 4. a list of operators that Hilcorp has a Road Use Agreement (RUA) with; 5. a list of Hilcorp employees having completed the Hilcorp commercial Class II training and are authorized to accept waste; 6. a review of the Hilcorp Waste Analysis Plan (WAP) and any changes to the plan; 7. a review of the External Manifest procedures including any changes to the process; and 8. a review of the pre-call and approval policy that is designed to ensure the facility is ready and able to accept and process the commercial waste. DIO 28A shall be amended to read as follows: RULE 2: Authorized Fluids This authorization is limited to Class II eligible waste fluids generated during drilling, production, workover, or abandonment operations, including: Drilling fluids; drill cuttings; well workover fluids; stimulation fluids and solids; produced water; rig wash water; formation materials; naturally occurring radioactive materials; scale; tracer materials; glycol dehydration; reserve pit fluids; chemicals used in the well or for production processing at the surface (in direct contact with produced fluids); and precipitation accumulating in drilling and production impoundment areas. The eligibility of other fluids for Class II waste disposal injection will be considered by the AOGCC on a case-by-case basis upon application by the operator. Commercial Class II oil field waste disposal is approved. Commercial (third party non- Hilcorp generated, and/or generated from other Units) Class II oil field waste disposal shall be in compliance with all rules of this DIO and it remains the responsibility of Hilcorp to accurately account for volumes and ensure that all fluids injected meet Class II eligibility requirements. DIO 47.001 DIO 28A.001 DIO 30A.001 March 19, 2025 Page 4 of 5 RULE 5: Surveillance The operator shall obtain a baseline temperature log and a baseline step-rate test prior to initial injection. A subsequent temperature log must be run one month after injection begins to delineate the receiving zone of the injected fluids. The operator shall perform an annual reservoir pressure survey of the disposal zone. Surface pressures and rates must be monitored continuously during injection for any indications of anomalous conditions. Results of daily wellhead pressure observations must be documented and available to the AOGCC upon request. The conduct of subsequent temperature surveys or other surveillance logging (e.g., water flow; acoustic) will be based on the results of the initial and follow-up temperature surveys and injection performance monitoring data. The annual report of underground injection (Form 10-413) shall also include data sufficient to characterize the disposal operation, including, among other information, the following: injection and annuli pressures (i.e., daily average, maximum, and minimum pressures); fluid volumes injected (i.e., in disposal and clean fluid sweeps); injection rates; an assessment of the fracture geometry; a description of any anomalous injection results; a calculated zone of influence for the injected fluids; and an assessment of the applicability of the disposal order findings, conclusions, and rules based on actual performance. The annual report must be submitted by July 1st. The annual report shall also include a section titled “Induced Seismicity” in which the operator shall detail its monitoring efforts and evaluate the risks. Commercial disposal injection details shall also be provided in the annual performance report. The report shall include: 1. an overview of commercial activities for the year; 2. a list, based on manifests, showing waste generating company, identification of well or pad where the waste was generated, type of waste, volume, transport company/driver, signature/name of Hilcorp authority confirming waste as Class II; 3. a list of the operators that Hilcorp has a Facility User Agreement (FUA) with; 4. a list of operators that Hilcorp has a Road Use Agreement (RUA) with; 5. a list of Hilcorp employees having completed the Hilcorp commercial Class II training and are authorized to accept waste; 6. a review of the Hilcorp Waste Analysis Plan (WAP) and any changes to the plan; 7. a review of the External Manifest procedures including any changes to the process; and 8. a review of the pre-call and approval policy that is designed to ensure the facility is ready and able to accept and process the commercial waste. RULE 7: Administrative Action (Rescinded by 20 AAC 25.556(d)) NOW THEREFORE IT IS ORDERED THAT DIO 30A is expired. DIO 47.001 DIO 28A.001 DIO 30A.001 March 19, 2025 Page 5 of 5 DONE at Anchorage, Alaska and dated March 19, 2025. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner RECONSIDERATION AND APPEAL NOTICE As provided in AS 31.05.080(a), within 20 days after written notice of the entry of this order or decision, or such further time as the AOGCC grants for good cause shown, a person affected by it may file with the AOGCC an application for reconsideration of the matter determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration must set out the respect in which the order or decision is believed to be erroneous. The AOGCC shall grant or refuse the application for reconsideration in whole or in part within 10 days after it is filed. Failure to act on it within 10 days is a denial of reconsideration. If the AOGCC denies reconsideration, upon denial, this order or decision and the denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision denying reconsideration, UNLESS the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which the application for reconsideration was filed. If the AOGCC grants an application for reconsideration, this order or decision does not become final. Rather, the order or decision on reconsideration will be the FINAL order or decision of the AOGCC, and it may be appealed to superior court. That appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on reconsideration. In computing a period of time above, the date of the event or default after which the designated period begins to run is not included in the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00 p.m. on the next day that does not fall on a weekend or state holiday. Gregory C. Wilson Digitally signed by Gregory C. Wilson Date: 2025.03.19 12:30:59 -08'00' Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.03.19 13:58:52 -08'00' From:Coldiron, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Disposal Injection Orders 47.001, 28A.001, and 30A.001expired (Hilcorp) Date:Wednesday, March 19, 2025 2:25:56 PM Attachments:DIO47.001_DIO28A.001_DIO30A.001expire.pdf Docket Number: DIO-25-001 Disposal Injection Order 47.001 Request for Amendment to Rule 2 of Disposal Injection Order (DIO) 47 Amendment to Rule 6 of DIO 47 Susan Dionne 8 (PTD 2130510), Ninilchik Unit, Kenai Peninsula DIO 28A.001 Amendment to Rule 2 and Rule 5, Rescinding Rule 7 of DIO 28A NNA-1 (PTD 2012150) Deep Creek Unit, Kenai Peninsula DIO 30A.001 Expiration of DIO 30A NNA-2 (PTD N/A) Deep Creek Unit, Kenai Peninsula Samantha Coldiron AOGCC Special Assistant Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, AK 99501 (907) 793-1223 __________________________________ List Name: AOGCC_Public_Notices@list.state.ak.us You subscribed as: samantha.coldiron@alaska.gov Unsubscribe at: https://list.state.ak.us/mailman/options/aogcc_public_notices/samantha.coldiron%40alaska.go v 9 CAUTION: External sender. DO NOT open links or attachments from UNKNOWN senders. From:Daniel Taylor To:Wallace, Chris D (OGC) Cc:Wyatt Rivard; Noel Nocas Subject:RE: [EXTERNAL] RE: Ninilchik SD 8 (PTD 213051) / DIO 47 Amendment Application Date:Thursday, March 13, 2025 1:44:19 PM Mr. Wallace, Your suggestion to authorize commercial disposal (DIO 47 & DIO 28A) under the same conditions as DIO 34B Rule 6 is reasonable. You are correct about the NNA #2 well (DIO 30A). The project never materialized and should be expired. Regards, Daniel Taylor, P.E. Well Integrity O: 907-777-8319 C: 907-947-8051 From: Wallace, Chris D (OGC) <chris.wallace@alaska.gov> Sent: Wednesday, March 12, 2025 12:41 PM To: Daniel Taylor <dtaylor@hilcorp.com> Cc: Wyatt Rivard <wrivard@hilcorp.com>; Noel Nocas <Noel.Nocas@hilcorp.com> Subject: [EXTERNAL] RE: Ninilchik SD 8 (PTD 213051) / DIO 47 Amendment Application Daniel, We are reviewing this application and are looking to amend the DIO 47 to authorize commercial disposal (other operators and/or other Units) and increase reporting by the same conditions as DIO 34B Rule 6 . Any concerns? We are also looking to do the same for DIO 28A. Any concerns? I note DIO 30A for NNA #2 was also a Deep Creek DIO - but I cannot find NNA 2 and no DIO 30A reporting which makes me think the well was not drilled and that the DIO 30A should be expired based on no disposal. Please confirm and let me know if I am missing anything. Are there any additional Class II wells in Ninilchik/Deep Creek/ road access corridor that I should authorize for commercial disposal with increased reporting requirements (same as DIO 34B) at this time? Thanks and Regards, Chris Wallace, Sr. Petroleum Engineer, Alaska Oil and Gas Conservation Commission, 333 West 7th Avenue, Anchorage, AK 99501, (907) CAUTION: This email originated from outside the State of Alaska mail system. Do not click links or open attachments unless you recognize the sender and know the content is safe. 793-1250 (phone), (907) 276-7542 (fax), chris.wallace@alaska.gov CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, contains information from the Alaska Oil and Gas Conservation Commission (AOGCC), State of Alaska and is for the sole use of the intended recipient(s). It may contain confidential and/or privileged information. The unauthorized review, use or disclosure of such information may violate state or federal law. If you are an unintended recipient of this e-mail, please delete it, without first saving or forwarding it, and, so that the AOGCC is aware of the mistake in sending it to you, contact Chris Wallace at 907-793-1250 or chris.wallace@alaska.gov. From: Daniel Taylor <dtaylor@hilcorp.com> Sent: Tuesday, February 4, 2025 8:55 AM To: Wallace, Chris D (OGC) <chris.wallace@alaska.gov> Cc: Wyatt Rivard <wrivard@hilcorp.com>; Noel Nocas <Noel.Nocas@hilcorp.com> Subject: Ninilchik SD 8 (PTD 213051) / DIO 47 Amendment Application Mr. Wallace, Ninilchik field, Susan Dionne 8 (PTD 213051) is planned to be converted to a Class II disposal well operating under DIO 47. Please see the attached Application for Amendment of DIO 47 clarifying and requesting injection of Hilcorp Alaska, LLC eligible Class II waste generated outside of the Ninilchik Unit. Regards, Daniel Taylor, P.E. Well Integrity O: 907-777-8319 C: 907-947-8051 The information contained in this email message is confidential and may be legally privileged and is intended only for the use of theindividual or entity named above. If you are not an intended recipient or if you have received this message in error, you are herebynotified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, pleaseimmediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently delete this message. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that theonward transmission, opening, or use of this message and any attachments will not adversely affect its systems or data. No responsibilityis accepted by the company in this regard and the recipient should carry out such virus and other checks as it considers appropriate. The information contained in this email message is confidential and may be legally privileged and is intended only for the use of the individual or entity named above. If you are not an intended recipient or if you have received this message in error, you are hereby notified that any dissemination, distribution, or copy of this email is strictly prohibited. If you have received this email in error, pleaseimmediately notify us by return email or telephone if the sender's phone number is listed above, then promptly and permanently deletethis message. While all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that theonward transmission, opening, or use of this message and any attachments will not adversely affect its systems or data. No responsibility is accepted by the company in this regard and the recipient should carry out such virus and other checks as it considers appropriate. 8 January 29, 2025 Jessie Chmielowski, Commissioner Greg Wilson, Commissioner Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, AK 99501 RE: Application for Amendment Disposal Injection Order 47 Kenai, Alaska Dear Commissioners: Hilcorp Alaska, LLC (“Hilcorp”), as Operator of the Ninilchik Unit (“NU”) in Kenai Alaska, hereby respectfully submits this application to amend Disposal Injection Order 47 (“DIO 47”) issued August 8, 2024, to modify the below sections of Rule 2 by removing the stipulations noted below (bold & strikethrough): RULE 2: Authorized Fluids This authorization is limited to Class II eligible waste fluids generated within the NU during drilling, production, workover, or abandonment operations, including: Drilling fluids; drill cuttings; well workover fluids; stimulation fluids and solids; produced water; rig wash water; formation materials; naturally occurring radioactive materials; scale; tracer materials; glycol dehydration; reserve pit fluids; chemicals used in the well or for production processing at the surface (in direct contact with produced fluids); and precipitation accumulating in drilling and production impoundment areas. The eligibility of other fluids for Class II waste disposal injection will be considered by the AOGCC on a case-by-case basis upon application by the operator. Commercial Class II disposal injection (i.e., fluids from a different operator or from a different unit) is prohibited. Hilcorp requests the ability to inject authorized waste fluids per DIO 47 Rule 2 that are generated from other Hilcorp Alaska, LLC operated fields on the Kenai Peninsula. Having this capability increases the available well stock and flexibility for managing eligible Class II waste fluids. Having additional Class II disposal locations also provides shorter trucking options and the ability to address seasonal road conditions that affect Hilcorp’s primary disposal well in the Ninilchik area, Deep Creek Unit NNA No. 1 (NNA-1). Per the original DIO 47 permit application, the Susane Dionne 8 (SD-8) disposal well is intended to provide backup capacity for the NNA 1 disposal well. NNA 1 currently injects fluids trucked in from the Ninilchik Unit, Deep Creek Unit and Niolaevsk (“Red Pad”)” and is expected to be utilized for additional development of the Cottonfield, Whiskey Gulch and Seaview prospects. 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 Phone: 907-777-8319 Email: dtaylor@hilcorp.com In accordance with 20 AAC 25.252 (section c, 7), Hilcorp’s application stated, “The primary disposal fluid planned for SD-8 is formation fluid from NU and other fields in the Kenai Peninsula. Waste disposal injection may also include other fluids eligible for Class II injection.” The term “other fields” is a reference to Hilcorp Alaska, LLC lease properties only and was not intended to include third parties or Harvest. Fluids eligible for Class II injection will be manifested to SD-8 using the Cook Inlet-Kenai Manifest. Employees and contractors who manifest wastes to Hilcorp’s injection facilities receive training every 2 years in Hilcorp’s Waste Management and Manifesting Training. Hilcorp maintains records concerning the nature and composition of injected fluids until three years after the well is plugged and abandoned. Manifests are kept on-site for at least one year after which they are forwarded to Anchorage for archiving. Should you require additional information regarding this application, please don’t hesitate to contact me at 777-8319. Sincerely, Daniel Taylor, P.E. Well Integrity Engineer Hilcorp Alaska, LLC cc: Chris Wallace Senior Petroleum Engineer, AOGCC (via e-mail) Samantha Coldiron Special Assistant, AOGCC (via e-mail) Digitally signed by Daniel Taylor (1691) DN: cn=Daniel Taylor (1691) Date: 2025.02.03 13:28:00 - 09'00' Daniel Taylor (1691)