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Home My WebLink AboutAIO 010 DAREA INJECTION ORDER 10D Milne Point Field Milne Point Unit Nikaitchuq Field Nikaitchuq Unit Schrader Bluff Oil Pool 1. February 4, 2025 Hilcorp Application for Expansion of AIO 10C 2. February 4, 2025 Hilcorp Revised Application for Expansion of AIO 10C 3. February 24, 2025 AOGCC Notice of Public Hearing 4. August 27, 2025 Hilcorp request for continued water injection operations in Well SI26-NW2 (PTD 214-157) (AIO 10D.001) (confidential documents held in secure storage) STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 W. 7th Avenue Anchorage Alaska 99501 Re: THE APPLICATION OF HILCORP ALASKA, LLC. to expand the Affected Area of Area Injection Order Number 10C to include the newly expanded Schrader Bluff Oil Pool into the Nikaitchuq Unit. ) ) ) ) ) ) ) ) ) ) ) ) ) Area Injection Order 10D Milne Point Field Milne Point Unit Kuparuk River Oil Pool Schrader Bluff Oil Pool Sag River Oil Pool Nikaitchuq Field Nikaitchuq Unit Schrader Bluff Oil Pool September 18, 2025 ERRATA NOTICE The Alaska Oil and Gas Conservation Commission (AOGCC) notes that Area Injection Order 10D (AIO 10D) had sections of the original affected area of Area Injection Order 10C (AIO 10C) omitted from the Affected Area tables. “Table 1. Legal description for MPU and NU SBOP” and “Table 2. Legal description for MPU KROP and MPU SROP” have been corrected accordingly. These corrections will be reflected in an Area Injection Order 10D Errata to be issued by the AOGCC. DONE at Anchorage, Alaska and dated September 18, 2025. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.09.18 11:40:43 -08'00' Gregory C Wilson Digitally signed by Gregory C Wilson Date: 2025.09.18 13:01:53 -08'00' NSTATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West 7th Avenue Anchorage, Alaska 99501 Re: THE APPLICATION OF HILCORP ALASKA, LLC. to expand the Affected Area of Area Injection Order Number 10C to include the newly expanded Schrader Bluff Oil Pool into the Nikaitchuq Field, Nikaitchuq Unit. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Docket Number: AIO-25-004 Area Injection Order 10D Errata Milne Point Field Milne Point Unit Kuparuk River Oil Pool Schrader Bluff Oil Pool Sag River Oil Pool Nikaitchuq Field Nikaitchuq Unit Schrader Bluff Oil Pool September 17, 2025 Nunc pro tunc May 6, 2025 IT APPEARING THAT: 1. By application dated February 4, 2025, Hilcorp Alaska, LLC. (Hilcorp), as the operator of the Milne Point Unit (MPU) and the Nikaitchuq Unit (NU), requested the Alaska Oil and Gas Conservation Commission (AOGCC) issue an amended order to expand the Affected Area of Area Injection Order Number 10C (AIO 10C), which authorizes the underground injection of fluids for pressure maintenance and enhanced oil recovery in the MPU Schrader Bluff Oil Pool (SBOP), the MPU Kuparuk River Oil Pool (KROP), and the MPU Sag River Oil Pool (SROP), to include the NU, only as to the SBOP. 2. Pursuant to 20 AAC 25.540, the AOGCC tentatively scheduled a public hearing for April 3, 2025, at 10:00 AM. On February 24, 2025, the AOGCC published notice of that hearing on the State of Alaska’s Online Public Notice website and on the AOGCC’s website and electronically transmitted the notice to all persons on the AOGCC’s email distribution list. On February 26, 2025, the notice was also published in the Anchorage Daily News. 3. The AOGCC received no comments or request to hold the proposed hearing. The tenta- tively scheduled hearing was vacated. 4. Hilcorp’s application, AOGCC’s records, and publicly available information provide suf- ficient information upon which to make an informed decision. FINDINGS: 1. Order History x Area Injection Order Number 10 (AIO 10), issued September 19, 1986, authorized certain fluids for injection for pressure maintenance and enhanced oil recovery (EOR) within the MPU KROP. AIO 10 was amended December 30, 1991, to allow for Area Injection Order 10D Errata September 18, 2025 Page 2 of 9 pressure maintenance and EOR injection operations into the MPU SBOP. AIO 10 was again amended May 3, 1994, recognizing a change in operatorship to BP Exploration Alaska (BPXA). x Area Injection Order Number 10A (AIO 10A), issued October 29, 2001 to BPXA , authorized certain fluids for injection for pressure maintenance and EOR into the MPU KROP and into the MPU SBOP, while also newly allowing for miscible gas injection into the KROP. x Area Injection Order Number 10B (AIO 10B), issued April 23, 2002, to BPXA, further authorized certain injection fluids for pressure maintenance and EOR for the MPU SROP. x Area Injection Order Number 10C (AIO 10C), issued May 29, 2024, to Hilcorp Alaska, LLC, expanded the affected area of AIO 10B. x Area Injection Order Number 36 (AIO 36) issued January 19, 2011, to Eni US Operating Company Inc (Eni), authorized certain injection fluids for pressure maintenance and EOR for the NU Nikaitchuq Schrader Bluff Oil Pool (NSBOP). 2. Operators Hilcorp is the operator of the MPU, the NU, and the proposed Affected Area. 3. Owners and Landowners The affected landowner of the MPU and NU is the State of Alaska, Department of Natu- ral Resources (DNR). All lands within the Affected Area are leased from the State of Alaska. Hilcorp, Herbaly Exploration LLC, and George Alan Joyce are the lease holders of the MPU. Hilcorp is the sole lease holder of the NU. Hilcorp has 100% working inter- est in both the MPU and NU. 4. Affected Injection Strata AIO 10C authorizes injection into multiple strata in the MPU. It authorizes EOR injection into the KROP (6,474’ to 6,880’ measured depth (MD) in the well West Sak River State Number 1, API Number 50-029-20090-00-00), the SBOP (4,174’ to 4,800’ MD in well MPU Number A-01, API Number 50-029-20376-00-00), and the SROP (8,810’ to 8,884’ MD in well MPU Number A-01, API Number 50-029-20376-00-00). Area Injection Order Number 36 (AIO 36) authorizes injection for enhanced recovery into the NU NSBOP (3,530’ to 3,867’ MD in exploratory well Kigun Number 1, API Number 50-629-23239-01-00) in the NU. 5. Expansion of the Affected Area Hilcorp proposes to expand the Affected Area of the SBOP portion of AIO 10C to match their concurrently proposed expansion of the SBOP. Hilcorp proposes to expand the MPU SBOP to include all the NU, adding to the size of the existing SBOP by an additional ~21,228.6 acres, thereby defining the current NSBOP and current SBOP as one contiguous oil pool. The new, expanded SBOP would underlie the MPU and all the NU. Hilcorp provided a map (Figure 1, below) showing the current and proposed boundaries of AIO 10C along with a table of township/range values of the proposed expanded Area Injection Order 10D Errata September 18, 2025 Page 3 of 9 affected area. Tables 1 and 2, below, present legal descriptions for the proposed SBOP, the KROP, and the SROP Affected Areas. 6. Expansion Justification To support the proposed pool and concordant AIO expansions, Hilcorp provided confidential data to the AOGCC, consisting of a seismic cross-section, annotated with well logs, that passes through the NU (west to east) and the MPU (northwest to southeast), and a structure map of Schrader Bluff OA Sand showing a continuous oil- water contact that crosses the MPU and NU boundary. These data give Hilcorp high confidence that the Schrader Bluff forms a common reservoir within both units. Hilcorp’s initial plan is to further develop the Schrader Bluff Reservoir by drilling wells from the Milne Point Raven Pad that cross the NU-MPU boundary. Figure 1 also depicts the locations of proposed Schrader Bluff OA sands wells to be drilled from the Milne Point Raven Pad. CONCLUSIONS: 1. The AOGCC accepts Hilcorp’s request to keep the seismic, and OA Sand structure map con- fidential because they are based on interpreted data. 2. Information provided by Hilcorp demonstrates that the SBOP is continuous across the MPU and the NU boundary, and that defining the NSBOP and the MPU SBOP as one single, con- tiguous pool is appropriate. 3. The AOGCC agrees that a single area injection order can apply to the expanded SBOP. The AOGCC agrees that polymer flooding will help to prevent waste and increase hydrocarbon recovery from the SBOP within the NU. NOW, THEREFORE, IT IS ORDERED: 1. This conservation order hereby supersedes AIO 10, 10A, 10B, and 10C (dated May 29, 2024) and all associated administrative approvals, except AIO 10B.006, AIO 10B.009, AIO 10B.010, AIO 10B.014, AIO 10B.017, 10B.018, AIO 10B.019, and AIO 10C.002 which remain in effect. The record, findings, and conclusions of AIO 10, 10A, 10B, and 10C and all associated administrative approvals are incorporated by reference into the record for this order. 2. This conservation order hereby supersedes AIO 36 (dated January 19, 2011) and all previously issued administrative approvals except AIO 36.004, AIO 36.009, AIO 36.010, and AIO 36.011, which remain in effect. The findings, conclusions, and administrative record for these orders are incorporated in this order. The record, findings, and conclusions of AIO 36 are incorporated by reference into the record for this order. 3. The former NU NSBOP and MPU SBOP are hereby defined as the SBOP. 4. The following rules, in addition to statewide requirements under 20 AAC 25 (to the extent not superseded by these rules), govern enhanced oil recovery injection operations in the fol- lowing area. This area corresponds to the leases held in the MPU and NU as of the effective date of this order. Area Injection Order 10D Errata September 18, 2025 Page 4 of 9 Affected Area for SBOP (Revised this order): Umiat Meridian Town- ship/Range Sections 12N-10E 1, 2, 11, 12 12N-11E 1-12 13N-9E 1, N ½ of 2, SE ¼ of 2, NE ¼ of 11, 12-14, 23, 24 13N-10E 1-36 13N-11E 7, 8, 17-20, 27-34 14N-8E 1, 2 (protracted), 3(protracted), 4(protracted), 9-15, 22-26, 35, 36 14N-9E 5-8, 11-36 14N-10E 5-8, 15-22, 27-35 15N-8E 33(protracted), 35(protracted), 36(protracted) Table 1. Legal description for MPU and NU SBOP Affected Area for MPU KROP and MPU SROP: Umiat Meridian Town- ship/Range Sections 12N-10E 1, 2, 11, 12 12N-11E 1-12 13N-9E 1, N ½ of 2, SE ¼ of 2, NE ¼ of 11, 12-14, 23, 24 13N-10E 1-36 13N-11E 7, 8, 17-20, 27-34 14N-9E 11-15, 22-27, 34-36 14N-10E 5-8, 15-22, 27-35 Table 2. Legal description for MPU KROP and MPU SROP Area Injection Order 10D Errata September 18, 2025 Page 5 of 9 Figure 1. Affected Area defined in AIO 10C and Proposed Expansion of AIO 10C SBOP Affected Area (Source: Hilcorp North Slope, LLC) Rule 1: Authorized Injection Strata for Enhanced Recovery and Authorized Injection Fluids (Initially Revised by AIO 10B.012) Subject to the conditions and limitations set out below, EOR injection operations as described in the operator's currently effective applications are approved for the KROP, SBOP, and the SROP within the above defined area. Authorized injection strata and authorized injection fluids are set out below for KROP (Part A), SBOP (Part B), and SROP (Part C). PART A – MPU KROP 1. MPU KROP - Authorized Injection Stratum: Authorized fluids may be injected into the stratum that correlates with the interval between the measured depths of 6,474 feet and 6,880 feet in well ARCO Alaska, Inc. West Sak River State Number 1 (API Number 50-029-20090-00-00). Area Injection Order 10D Errata September 18, 2025 Page 6 of 9 2. MPU KROP - Authorized Injection Fluids: Fluids authorized for injection for the KROP: a. produced water and gas from MPU production for purposes of pressure maintenance and enhanced recovery; b. source water from the Prince Creek Formation; c. seawater to thermally fracture gas injection wells; d. tracer survey fluid to monitor reservoir performance; e. fluids injected for the purposes of stimulation per 20 AAC 25.280(a)(2), f. miscible gas injectant (including NGLs imported from the Prudhoe Bay Unit for purposes of pressure maintenance and enhanced recovery); g. freeze protection fluids; h. boiler condensation; and i. non-hazardous treated wastewater from the Milne Point Wastewater Treatment Plant and non-hazardous water collected from MPU reserve pits, well house cellars and standing ponds. PART B – MPU - NU SBOP 1. MPU - NU SBOP Authorized Injection Stratum: Authorized fluids may be injected into the stratum that correlates with the interval between the measured depths of 4,174 feet and 4,800 feet in well Conoco MPU Number A-1 (API Number 50-029-20376-00-00), and between the measured depths of 3,530 feet and 3,867 feet on the EWR well log recorded in the NU exploratory well Kigun Number 1 (API Number 50-629-23239-01-00). 2. MPU – NU SBOP Authorized fluids: Fluids authorized for injection for the SBOP are: a. produced water from MPU production and from NU production, for purposes of pressure maintenance and enhanced recovery; b. source water from the Prince Creek Formation; c. tracer survey fluid to monitor reservoir performance; d. fluids injected for the purposes of stimulation per 20 AAC 25.280(a)(2); e. polymer solutions; f. freeze protection fluids; g. boiler condensation; h. non-hazardous treated wastewater from the Milne Point Wastewater Treatment Plant and non-hazardous water collected from MPU and NU reserve pits well house cellars and standing ponds; and Area Injection Order 10D Errata September 18, 2025 Page 7 of 9 i. source water from the Ivishak Formation. j. standard oil field chemicals (corrosion and scale inhibitors, defoamers, emulsion breakers, etc.) PART C – MPU SROP 1. MPU SROP - Authorized Injection Stratum: Authorized fluids may be injected into the stratum that correlate with the interval between the measured depths of 8810 and 8884 feet within well MPU Number A-1 (API Number 50-029-20376-00-00). 2. MPU SROP - Authorized Injection Fluids: Fluids authorized for injection for the SROP are: a. produced water and gas from MPU production for purposes of pressure maintenance and enhanced recovery; b. source water from the Prince Creek Formation; c. seawater to thermally fracture gas injection wells; d. tracer survey fluid to monitor reservoir performance; e. fluids injected for the purposes of stimulation per 20 AAC 25.280(a)(2); f. freeze protection fluids; g. boiler condensation; and h. non-hazardous treated wastewater from the Milne Point Wastewater Treatment Plant and non-hazardous water collected from MPU reserve pits well house cellars and standing ponds. Authorization to continue injection of these fluids is subject to a report on December 31, 2003, confirming fluid compatibility with SROP. Rule 2: Fluid Injection Wells (Restated from AIO 10C) The underground injection of fluids must be 1) through a well permitted for drilling as a service well for injection in conformance with 20 AAC 25.005; 2) through a well approved for conversion to a service well for injection in conformance with 20 AAC 25.280; or 3) through a well that existed as a service well for injection purposes on the effective date of AIO 10 (September 19, 1986). Rule 3: Monitoring the Tubing-Casing Annulus Pressure Variations (Restated from AIO 10C) The tubing-casing annulus pressure and injection rate of each injection well must be checked at least weekly to confirm continued mechanical integrity. Area Injection Order 10D Errata September 18, 2025 Page 8 of 9 Rule 4: Demonstration of Tubing-Casing Annulus Mechanical Integrity (Restated from AIO 10C) A schedule must be developed and coordinated with the AOGCC that ensures that the tubing- casing annulus for each injection well is pressure tested prior to initiating injection, following well workovers affecting mechanical integrity, and at least once every four years thereafter. Rule 5: Notification of Well Integrity Failure (Restated from AIO 10C) Whenever injection rates and/or operating pressure observations or pressure tests indicate pressure communication or leakage of any casing, tubing or packer, the operator must immediately shut in and secure the well, notify the AOGCC on the first working day following the observation, and submit a plan of corrective action on Form 10-403 for AOGCC approval. Additionally, notification requirements of any other State or Federal agency remain the operators’ responsibility. Rule 6: Notification of Improper Class II Injection (Restated from AIO 10C) Injection of fluids other than those listed in Rule 1, above, without prior authorization is considered improper Class II injection. Upon discovery of such an event, the operator must immediately notify the AOGCC, provide details of the operation, and propose actions to prevent recurrence. Additionally, notification requirements of any other State or Federal agency remain the operator’s responsibility. Rule 7: Other Conditions (Restated from AIO 10C) a. It is a condition of this authorization that the operator comply with all applicable AOGCC regulations. b. The AOGCC may suspend, revoke, or modify this authorization if injected fluids fail to be confined within the designated injection stratum. Rule 8: Administrative Action (Rescinded by regulation 20 AAC 25.556(d)) Rule 9: Injection Well Survey Requirements for Kuparuk River Oil Pool (Restated from 10C.001) A quantitative injection profile survey will be obtained on each multiple zone injector within 9 months of sustained injection. Single and multiple zone injectors may be surveyed at the operator’s discretion if anomalous injection performance is evident, or mechanical damage is suspected or if required to obtain data for waterflood management. Multiple pool injectors will require a quantitative injection profile survey within 9 months of sustained injection. Follow-up surveys will be performed on a rotating basis on one-third of the multiple pool injectors each calendar year. Completed injection well profile surveys will be filed with the AOGCC as part of the annual Milne Point Unit Waterflood and Reservoir Surveillance Report. Rule 10: Well Construction (Restated and Reworded from AIO 36 Rule 2) Packers in injection wells may be located more than 200 feet measured depth (MD) above the top of the SBOP, in both the MPU and the NU; however, packers shall not be located above the confining zone. The production casing cement volume must be sufficient to place cement a minimum of 250 feet true vertical depth (TVD) above the planned packer depth. Cement placement must be confirmed by cement bond log or another method approved in advance by the AOGCC. Area Injection Order 10D Errata September 18, 2025 Page 9 of 9 DONE at Anchorage, Alaska and dated September 18, 2025. Nunc pro tunc May 6, 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 reconsider- ation 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. Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.09.18 11:43:13 -08'00' Gregory C Wilson Digitally signed by Gregory C Wilson Date: 2025.09.18 13:00:52 -08'00' STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West 7th Avenue Anchorage, Alaska 99501 Re: THE APPLICATION OF HILCORP ALASKA, LLC. to expand the Affected Area of Area Injection Order Number 10C to include the newly expanded Schrader Bluff Oil Pool into the Nikaitchuq Unit. ) ) ) ) ) ) ) ) ) ) Docket Number: AIO-25-004 Area Injection Order 10D Milne Point Field Milne Point Unit Nikaitchuq Field Nikaitchuq Unit Schrader Bluff Oil Pool May 6, 2025 IT APPEARING THAT: 1.By application dated February 4, 2025, Hilcorp Alaska, LLC. (Hilcorp), as the operator of the Milne Point Unit (MPU) and the Nikaitchuq Unit (NU), requested the Alaska Oil and Gas Conservation Commission (AOGCC) issue an amended order to expand the Affected Area of Area Injection Order Number 10C (AIO 10C), which authorizes the underground injection of fluids for pressure maintenance and enhanced oil recovery in the MPU Schrader Bluff Oil Pool (SBOP), the MPU Kuparuk River Oil Pool (KROP), and the MPU Sag River Oil Pool (SROP), to include the NU, only as to the SBOP. 2.Pursuant to 20 AAC 25.540, the AOGCC tentatively scheduled a public hearing for April 3, 2025, at 10:00 AM. On February 24, 2025, the AOGCC published notice of that hearing on the State of Alaska’s Online Public Notice website and on the AOGCC’s website, elec- tronically transmitted the notice to all persons on the AOGCC’s email distribution list. On February 26, 2025, the notice was also published in the Anchorage Daily News. 3.The AOGCC received no comments or request to hold the proposed hearing. 4.The tentatively scheduled hearing was vacated. Hilcorp’s application, AOGCC’s records, and publicly available information provide sufficient information upon which to make an informed decision. FINDINGS: 1. Order History x Area Injection Order Number 10 (AIO 10), issued September 19, 1986, authorized certain fluids for injection for pressure maintenance and enhanced oil recovery (EOR) within the MPU KROP. AIO 10 was amended December 30, 1991, to allow for pressure maintenance and EOR injection operations into the MPU SBOP. x Area Injection Order Number 10A (AIO 10A), issued October 29, 2001, to BP Exploration Alaska (BPXA), authorized certain fluids for injection for pressure maintenance and EOR into the MPU KROP and into the MPU SBOP, while also newly allowing for miscible gas injection into the KROP. Area Injection Order 10D May 6, 2025 Page 2 of 9 x Area Injection Order Number 10B (AIO 10B), issued April 23, 2002, to BPXA, further authorized certain injection fluids for pressure maintenance and EOR for the MPU SROP. x Area Injection Order Number 10C (AIO 10C), issued May 29, 2024, expanded the affected area of AIO 10B. x Area Injection Order Number 36 (AIO 36) issued January 19, 2011, to Eni US Operating Company Inc (Eni), authorized certain injection fluids for pressure maintenance and EOR for the NU Nikaitchuq Schrader Bluff Oil Pool (NSBOP). 2. Operators Hilcorp is the operator of the MPU, the NU, and the proposed Affected Area. 3. Owners and Landowners The affected landowner of the MPU and NU is the State of Alaska, Department of Natu- ral Resources (DNR). All lands within the Affected Area are leased from the State of Alaska. Hilcorp, Herbaly Exploration LLC, and George Alan Joyce are the lease holders of the MPU. Hilcorp is the sole lease holder of the NU. Hilcorp has 100% working inter- est in both the MPU and NU. 4. Affected Injection Strata AIO 10C authorizes injection into multiple strata in the MPU. It authorizes EOR injection into the KROP (6,474’ to 6,880’ measured depth (MD) in the West Sak River State Number 1 well, API Number 50-029-20090-00-00), the SBOP (4,174’ to 4,800’ MD in the MPU Well Number A-01, API Number 50-029-20376-00-00), and the SROP (8,810’ to 8,884’ MD in the MPU Well Number A-01, API Number 50-029-20376-00-00). Area Injection Order Number 36 (AIO 36) authorizes injection for enhanced recovery into the NU NSBOP (3,530’ to 3,867’ MD in the stratigraphic section occurring in the Nikaitchuq exploratory well Kigun Number 1, API Number 50-629-23239-01-00) in the NU. 5. Expansion of the Affected Area Hilcorp proposes to expand the Affected Area of the SBOP portion of AIO 10C to match their concurrently proposed expansion of the SBOP. Hilcorp proposes to expand the MPU SBOP to include all the NU, adding to the size of the existing SBOP by an additional ~21,228.6 acres, thereby defining the current NSBOP and current SBOP as one contiguous oil pool. The new, expanded SBOP would underlie the MPU and all the NU. Hilcorp provided a map (Figure 1, below) showing the current and proposed boundaries of AIO 10C along with a table of township/range values of the proposed expanded affected area. Tables 1 and 2, below, present legal descriptions for the proposed SBOP, the KROP, and the SROP Affected Areas. 6. Expansion Justification To support the proposed pool and concordant AIO expansions, Hilcorp provided confidential data to the AOGCC, consisting of a seismic cross-section, annotated with well logs, that passes through the NU (west to east) and the MPU (northwest to Area Injection Order 10D May 6, 2025 Page 3 of 9 southeast), and a structure map of Schrader Bluff OA Sand showing a continuous oil- water contact that crosses the MPU and NU boundary. Hilcorp has high confidence that this data suggests that the Schrader Bluff Formation forms a common reservoir that lies within both units. Hilcorp requested that the seismic data and OA Sand map be held confidential. Hilcorp’s initial plan is to further develop the Schrader Bluff Reservoir from the Milne Point Raven Pad, into the NU. Figure 1 depicts the locations of proposed Schrader Bluff OA sands wells to be drilled from the Milne Point Raven Pad. CONCLUSIONS: 1. The AOGCC accepts Hilcorp’s request to keep the seismic, and OA Sand structure map con- fidential because all are based on interpreted data. 2. Information provided by Hilcorp demonstrates that the SBOP is continuous across the MPU and the NU boundary, and that defining the NSBOP and the MPU SBOP as one single, con- tiguous pool, is appropriate. 3. The AOGCC agrees that a single area injection order can apply to the expanded SBOP. The AOGCC agrees that polymer flooding will help to prevent waste and increase hydrocarbon recovery from the SBOP within the NU. NOW, THEREFORE, IT IS ORDERED: 1. This conservation order hereby supersedes AIO 10, 10A, 10B, and 10C (dated May 29, 2024) and all associated administrative approvals, except AIO 10B.006, AIO 10B.009, AIO 10B.010, AIO 10B.014, AIO 10B.017, 10B.018, AIO 10B.019, and AIO 10C.002 which remain in effect. The record, findings, and conclusions of AIO 10, 10A, 10B, and 10C and all associated administrative approvals are incorporated by reference into the record for this order. 2. This conservation order hereby supersedes AIO 36 (dated January 19, 2011) and all previously issued administrative approvals except AIO 36.004, AIO 36.009, AIO 36.010, and AIO 36.011, which remain in effect. The findings, conclusions, and administrative record for these orders are incorporated in this order. The record, findings, and conclusions of AIO 36 are incorporated by reference into the record for this order. 3. The NU NSBOP and MPU SBOP are hereby defined as the SBOP. 4. The following rules, in addition to statewide requirements under 20 AAC 25 (to the extent not superseded by these rules), govern enhanced oil recovery injection operations in the fol- lowing area. This area corresponds to the leases held in the MPU and NU as of the effective date of this order. Area Injection Order 10D May 6, 2025 Page 4 of 9 Affected Area for SBOP (Revised this order): Umiat Meridian Town- ship/Range Sections 12N-10E 1, 2, 11, 12 12N-11E 2, 3, 4, 5, 6, 7, 8, 9, 10, 11 13N-9E 1, N ½ of 2, SE ¼ of 2, NE ¼ of 11, 12, 13, 14, 23, 24 13N-10E W ½ of 2, SE ¼ of 2, 3-11, S ½ of 12, 13-36 13N-11E 18, 19, W ½ of 20, SW ¼ of 27, 28-33, W ½ of 34 14N-9E 5-8, 11-36 14N-8E 1, 2 (protracted), 3(protracted), 4(protracted), 9-15, 22-26, 35, 36 15N-8E 33(protracted), 35(protracted), 36(protracted) Table 1. Legal description for MPU and NU SBOP Affected Area for MPU KROP and MPU SROP: Umiat Meridian Town- ship/Range Sections 12N-10E 1, 2, 11, 12 12N-11E 2, 3, 4, 5, 6, 7, 8, 9, 10, 11 13N-9E 1, N ½ of 2, SE ¼ of 2, NE ¼ of 11, 12, 13, 14, 23, 24 13N-10E W ½ of 2, SE ¼ of 2, 3-11, S ½ of 12, 13-36 13N-11E 18, 19, W ½ of 20, SW ¼ of 27, 28-33, W ½ of 34 14N-9E 11-15, 22-27, 34-36 Table 2. Legal description for MPU KROP and MPU SROP Area Injection Order 10D May 6, 2025 Page 5 of 9 Figure 1. Affected Area defined in AIO 10C and Proposed Expansion of AIO 10C SBOP Affected Area (Source: Hilcorp North Slope, LLC) Rule 1: Authorized Injection Stratum for Enhanced Recovery and Authorized Injection Fluids (Initially Revised by AIO 10B.012) Subject to the conditions and limitations set out below, EOR injection operations as described in the operator's currently effective applications are approved for the KROP, SBOP and the SROP within the above defined area. Authorized injection stratum and authorized injection fluids are set out below for KROP (Part A), SBOP (Part B), and SROP (Part C). PART A – MPU KROP 1. MPU KROP - Authorized Injection Stratum: Authorized fluids may be injected into the stratum that correlates with the interval between the measured depths of 6,474 feet and 6,880 feet in the ARCO Alaska, Inc. West Sak River State Well Number 1 (API Number 50-029-20090-00-00). Area Injection Order 10D May 6, 2025 Page 6 of 9 2. MPU KROP - Authorized Injection Fluids: Fluids authorized for injection for the KROP: a. produced water and gas from MPU production for purposes of pressure maintenance and enhanced recovery; b. source water from the Prince Creek Formation; c. seawater to thermally fracture gas injection wells; d. tracer survey fluid to monitor reservoir performance; e. fluids injected for the purposes of stimulation per 20 AAC 25.280(a)(2), f. miscible gas injectant (including NGLs imported from the Prudhoe Bay Unit for purposes of pressure maintenance and enhanced recovery); g. freeze protection fluids; h. boiler condensation; and i. non-hazardous treated wastewater from the Milne Point Wastewater Treatment Plant and non-hazardous water collected from MPU reserve pits, well house cellars and standing ponds. PART B – MPU - NU SBOP 1. MPU - NU SBOP Authorized Injection Stratum: Authorized fluids may be injected into the stratum that correlates with the interval between the measured depths of 4,174 feet and 4,800 feet in the Conoco MPU Well Number A-1 (API Number 50-029-20376-00-00), and between the measured depths of 3,530 feet and 3,867 feet on the EWR well log recorded in the NU exploratory well Kigun Number 1 (API Number 50-629-23239-01-00). 2. MPU – NU SBOP Authorized fluids: Fluids authorized for injection for the SBOP are: a. produced water from MPU production and from NU production, for purposes of pressure maintenance and enhanced recovery; b. source water from the Prince Creek Formation; c. tracer survey fluid to monitor reservoir performance; d. fluids injected for the purposes of stimulation per 20 AAC 25.280(a)(2); e. polymer solutions; f. freeze protection fluids; g. boiler condensation; h. non-hazardous treated wastewater from the Milne Point Wastewater Treatment Plant and non-hazardous water collected from MPU and NU reserve pits well house cellars and standing ponds; and i. Source water from the Ivishak Formation. j. Standard oil field chemicals (corrosion and scale inhibitors, defoamers, emulsion breakers, etc.) Area Injection Order 10D May 6, 2025 Page 7 of 9 PART C – MPU SROP 1. MPU SROP - Authorized Injection Stratum: Authorized fluids may be injected into the stratum that correlate with the interval between the measured depths of 8810 and 8884 feet within MPU Well Number A-1 (API Number 50-029-20376-00-00). 2. MPU SROP - Authorized Injection Fluids: Fluids authorized for injection for the SROP are: a. produced water and gas from MPU production for purposes of pressure maintenance and enhanced recovery; b. source water from the Prince Creek Formation; c. seawater to thermally fracture gas injection wells; d. tracer survey fluid to monitor reservoir performance; e. fluids injected for the purposes of stimulation per 20 AAC 25.280(a)(2); f. freeze protection fluids; g. boiler condensation; and h. non-hazardous treated wastewater from the Milne Point Wastewater Treatment Plant and non-hazardous water collected from MPU reserve pits well house cellars and standing ponds. Authorization to continue injection of these fluids is subject to a report on December 31, 2003, confirming fluid compatibility with SROP. Rule 2: Fluid Injection Wells (Restated from AIO 10C) The underground injection of fluids must be 1) through a well permitted for drilling as a service well for injection in conformance with 20 AAC 25.005; 2) through a well approved for conversion to a service well for injection in conformance with 20 AAC 25.280; or 3) through a well that existed as a service well for injection purposes on the effective date of AIO 10 (September 19, 1986). Rule 3: Monitoring the Tubing-Casing Annulus Pressure Variations (Restated from AIO 10C) The tubing-casing annulus pressure and injection rate of each injection well must be checked at least weekly to confirm continued mechanical integrity. Rule 4: Demonstration of Tubing-Casing Annulus Mechanical Integrity (Restated from AIO 10C) A schedule must be developed and coordinated with the AOGCC that ensures that the tubing- casing annulus for each injection well is pressure tested prior to initiating injection, following well workovers affecting mechanical integrity, and at least once every four years thereafter. Rule 5: Notification of Well Integrity Failure (Restated from AIO 10C) Whenever injection rates and/or operating pressure observations or pressure tests indicate pressure communication or leakage of any casing, tubing or packer, the operator must immediately shut in and secure the well, notify the AOGCC on the first working day following the observation, and submit a plan of corrective action on Form 10-403 for AOGCC approval. Additionally, notification requirements of any other State or Federal agency remain the operators’ responsibility. Area Injection Order 10D May 6, 2025 Page 8 of 9 Rule 6: Notification of Improper Class II Injection (Restated from AIO 10C) Injection of fluids other than those listed in Rule 1, above, without prior authorization is considered improper Class II injection. Upon discovery of such an event, the operator must immediately notify the AOGCC, provide details of the operation, and propose actions to prevent recurrence. Additionally, notification requirements of any other State or Federal agency remain the operator’s responsibility. Rule 7: Other Conditions (Restated from AIO 10C) a. It is a condition of this authorization that the operator comply with all applicable AOGCC regulations. b. The AOGCC may suspend, revoke, or modify this authorization if injected fluids fail to be confined within the designated injection stratum. Rule 8: Administrative Action (Rescinded by regulation 20 AAC 25.556(d)) Rule 9: Injection Well Survey Requirements for Kuparuk River Oil Pool (Restated from 10C.001) A quantitative injection profile survey will be obtained on each multiple zone injector within 9 months of sustained injection. Single and multiple zone injectors may be surveyed at the operator’s discretion if anomalous injection performance is evident, or mechanical damage is suspected or if required to obtain data for waterflood management. Multiple pool injectors will require a quantitative injection profile survey within 9 months of sustained injection. Follow-up surveys will be performed on a rotating basis on one-third of the multiple pool injectors each calendar year. Completed injection well profile surveys will be filed with the AOGCC as part of the annual Milne Point Unit Waterflood and Reservoir Surveillance Report. Rule 10: Well Construction (Restated and Reworded from AIO 36 Rule 2) Packers in injection wells may be located more than 200 feet measured depth (MD) above the top of the SBOP, in both the MPU and the NU; however, packers shall not be located above the confining zone. The production casing cement volume must be sufficient to place cement a minimum of 250 feet true vertical depth (TVD) above the planned packer depth. Cement placement must be confirmed by cement bond log or another method approved in advance by the AOGCC. DONE at Anchorage, Alaska and dated May 6, 2025. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.05.06 14:24:24 -08'00' Gregory C. Wilson Digitally signed by Gregory C. Wilson Date: 2025.05.06 14:53:52 -08'00' Area Injection Order 10D May 6, 2025 Page 9 of 9 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 reconsider- ation 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. From:Coldiron, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Conservation Order 477B and Area Injection Order 10D (Hilcorp) Date:Tuesday, May 6, 2025 3:53:10 PM Attachments:CO477B.pdf AIO10D.pdf THE APPLICATION OF HILCORP ALASKA, LLC. To expand the Affected Area of Area Injection Order Number 10C to include the newly expanded Schrader Bluff Oil Pool into the Nikaitchuq Unit. THE APPLICATION OF Hilcorp North Slope, LLC to amend Conservation Order No. 477A to expand the areal extent of the Milne Point Unit Schrader Bluff Oil Pool into the Nikaitchuq Field, Nikaitchuq Unit 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 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 AREA INJECTION ORDER 10D.001 Ms. Sara Hannegan WNS Operations Manager Hilcorp Alaska, LLC. 3800 Centerpoint Dr., Suite 1400 Anchorage, AK 99503 Re: Docket Number: AIO-25-019 Request for Administrative Approval to Area Injection Order 10D; Water Injection Nikaitchuq Unit SI26-NW2 (PTD 2141570), Schrader Bluff Oil Pool Dear Ms. Hannegan: By emailed letter dated August 27, 2025, Hilcorp Alaska, LLC (Hilcorp) requested administrative approval to continue water injection in the subject well. In accordance with 20 AAC 25.556(d), the Alaska Oil and Gas Conservation Commission (AOGCC) hereby GRANTS, subject to conditions, Hilcorp’s request for administrative approval to continue water injection in the subject well. On June 21, 2025, the well failed the 4 year mechanical integrity test of the inner annulus (MITIA) confirming a tubing by inner annulus (TxIA) pressure communication. Hilcorp performed diagnostics and monitoring including a passing non-state witnessed combination MIT of the tubing and inner annulus on August 22, 2025, with a deep set tubing plug set at 15,366 ft MD. This confirms integrity of the 9-5/8” casing to the packer at 15,324 ft MD/3,602 ft TVD. The top stacker packer as set at 15,324 ft MD/3602 ft TVD is 172 ft TVD below the top of the approved Schrader Bluff injection zone at 14,020 ft MD/3,430 ft TVD. The top of cement for the 9-5/8” casing, as determined by Sonic Log, is 13,150 ft MD/3,118 ft TVD which is 870 ft MD above the Schrader Bluff injection zone. Hilcorp has continuous pressure monitoring for the inner and outer annuli. AOGCC believes Hilcorp can safely manage the TxIA with periodic pressure bleeds. Accordingly, the AOGCC believes that the well’s condition does not compromise overall well integrity so as to threaten human safety or the environment. AOGCC’s approval to continue water injection only in SI26-NW2 is conditioned upon the following: 1. Hilcorp shall record wellhead pressures and injection rate daily; AIO 10D.001 September 2, 2025 Page 2 of 2 2. Hilcorp shall submit to the AOGCC a monthly report of well pressures, injection rates, and pressure bleeds for all annuli. Bleeds to be flagged on the report; 3. Hilcorp shall perform a combination MIT of the tubing and inner annulus every two years to the greater of the maximum anticipated injection pressure or 0.25 x packer TVD, but not less than 1500 psi; 4. Hilcorp shall limit the well’s inner annulus operating pressure to 2000 psi, and the outer annulus operating pressure to 1000 psi. Audible control room alarms shall be set at or below these limits; 5. Hilcorp shall monitor the inner and outer annulus pressures in real time with its Supervisory Control and Data Acquisition (SCADA) system; 6. Hilcorp shall immediately shut in the well and notify the AOGCC if there is any change in the well's mechanical condition; 7. After well shut in due to a change in the well's mechanical condition, AOGCC approval shall be required to restart injection; and 8. The next required combination MIT shall be completed before or during the month of August 2026. AOGCC must be provided the opportunity to witness the MIT for a test to establish a new test due date. DONE at Anchorage, Alaska and dated September 2, 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: 2025.09.02 11:22:32 -08'00' Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.09.02 12:01:26 -08'00' From:Coldiron, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Area Injection Order 10D.001 (Hilcorp) Date:Tuesday, September 2, 2025 12:07:04 PM Attachments:AIO10D.001.pdf Docket Number: AIO-25-019 Request for Administrative Approval to Area Injection Order 10D; Water Injection Nikaitchuq Unit SI26-NW2 (PTD 2141570), Schrader Bluff Oil Pool 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 4 August 27, 2025 Commissioner Jessie Chmielowski & Greg Wilson Alaska Oil & Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, AK 99501 Subject: Nikaitchuq PWI Well SI26-NW2 (PTD# 2141570) Request For Administrative Approval to AIO 10D: Continued Water Injection Operations Dear Commissioners, Hilcorp Alaska, LLC (HAK) requests approval for continued water only injection into Nikaitchuq PWI well SI26-NW2 (PTD # 2141570) until a RWO can be completed during the 2025/2026 winter ice road season to replace the injection tubing up until 06/01/2026. SI26-NW2 failed an AOGCC witnessed 4 year MIT-IA on 6/21/25 to 1500 psi, losing 448 psi in 5 minutes. Following the MIT attempt, IA pressure began to equalize with tubing pressure indicating TxIA communication following the MIT. On 8/22/25 a non-AOGCC witnessed CMIT-TxIA passed to 1676 psi, confirming competent production casing and packer. The packer is set 172’ TVD below the top of the Schrader Bluff formation. HAK believes Nikaitchuq well SI26-NW2 is safe to operate with the proposed operating and monitoring plan outlined in the technical justification and requests approval for continued water only injection operations under administrative approval. If you have any additional questions, please call me at 907-564-4624 or Ryan Thompson at 907-564-5005. Sincerely, Sara Hannegan WNS Operations Manager 3800 Centerpoint Drive Suite 1400 Anchorage, AK 99503 By Samantha Coldiron at 8:47 am, Aug 28, 2025 Digitally signed by Sara Hannegan (2519) DN: cn=Sara Hannegan (2519) Date: 2025.08.27 12:20:27 - 05'00' Sara Hannegan (2519) Page | 2 SI26-NW2 Technical Justification for Administrative Approval Request August 26, 2025 Well History and Status SI26-NW2 is a Nikaitchuk Schrader Bluff water injector. The well was drilled and completed in Q4 2014 as a water injector. In April 2021 the well failed an MIT-IA and a tubing leak was identified @ 10,439’ MD. In July 2021 a RWO was performed to replace tubing with a new stacker packer completion. The well remained on injection until failing an AOGCC 4 year MIT-IA on 6/21/25 and the well was shut in. A subsequent PPPOT-T passed on 6/24/25 indicating the leak was not across the wellhead. On 8/22/25 a non AOGCC witnessed CMIT-TxIA passed to 1676 psi with a plug set in the GX nipple at 15,366’, below the top stacker packer. The packer is set at 15,324’ MD / 3,602’ TVD which is 172’ TVD below the top of the Schrader Bluff formation (14,020’ MD / 3,430’ TVD). Cement top of the 9 5/8” casing based on the Sonic log run during drilling operations is at 13,150’ MD / 3,118’ TVD, which is 870’ MD of cement coverage above the top of the Schrader Bluff Formation. In summary the production casing has been pressure tested below the top of the Schrader bluff injection interval. The tubing on SI26-NW2 goes on a vacuum once shut in. Recent Well Events: 6/21/25: MIT-IA to 1500 psi failed 6/24/25: PPPOT-T to 5000 psi & PPPOT-IC to 2500 psi passed 8/22/25: CMIT-TxIA to 1676 psi passed Page | 3 Proposed Operating and Monitoring Plan 1) PWI Injection only. 2) Record wellhead pressures and injection rate daily. 3) Submit a monthly report of well pressures and injection rates to the AOGCC. Flag annular bleeds. 4) The well’s IA pressure will be limited to 2000 psi and OA pressure limited to 1000 psi. 5) Real time SCADA monitoring of the IA and OA pressures with alarm set points below MOASP values. 6) The well will be shut-in and the AOGCC notified if there is a change in the well’s mechanical condition. 7) After well shut-in due to a change in the well’s mechanical condition, AOGCC approval shall be required to restart injection. 8) By 6/1/2025 the well will be worked over to repair the TxI communication or shut in. Page | 4 3 Notice of Public Hearing STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION RE: Docket Numbers: AIO-25-004 and CO-25-004 By applications dated February 4, 2025, Hilcorp Alaska, LLC (Hilcorp) requests that the Alaska Oil and Gas Conservation Commission (AOGCC) expand the map extent of the Schrader Bluff Oil Pool (SBOP), and its associated Area Injection Order, in and around the Milne Point Unit. Conservation Order No. 477A defines the SBOP and prescribes rules for its development. Area Injection Order (AIO) No. 10C prescribes rules for injecting fluids for enhanced recovery purposes into the SBOP. Hilcorp proposes to amend these orders to incorporate include the area covered by the Schrader Bluff Oil Pool, and its associated AIO, in the Nikaitchuq Unit to allow for unified operations of the SBOP. This notice does not contain all the information filed by Hilcorp. To obtain more information, contact the AOGCC’s Special Assistant, Samantha Coldiron, at (907) 793-1223 or samantha.coldiron@alaska.gov. A public hearing on the matter has been tentatively scheduled for April 3, 2025, at 10:00 a.m. The hearing, which may be changed to full virtual, if necessary, will be held in the AOGCC hearing room located at 333 West 7th Avenue, Anchorage, AK 99501. The audio call-in information is (907) 202-7104 Conference ID: 239 074 590#. Anyone who wishes to participate remotely using MS Teams video conference should contact Ms. Coldiron at least two business days before the scheduled public hearing to request an invitation for the MS Teams. To request that the tentatively scheduled hearing be held, a written request must be filed with the AOGCC no later than 4:30 p.m. on March 13, 2025. If a request for a hearing is not timely filed, the AOGCC may issue an order without a hearing. To learn if the AOGCC will hold the hearing, call (907) 793-1223 after March 14, 2025. In addition, written comments regarding this application may be submitted to the AOGCC, at 333 west 7th Avenue, Anchorage, AK 99501 or samantha.coldiron@alaska.gov. Comments must be received no later than 4:30 p.m. on March 28, 2025, except that, if a hearing is held, comments must be received no later than the conclusion of the April 3, 2025, hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, contact Samantha Coldiron, at (907) 793-1223, no later than March 27, 2025. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.02.24 09:35:55 -09'00' Gregory C. Wilson Digitally signed by Gregory C. Wilson Date: 2025.02.24 11:04:10 -09'00' From:Coldiron, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Public Hearing Notice (Hilcorp) Date:Monday, February 24, 2025 11:40:18 AM Attachments:AIO-25-004 and CO-25-004 Public Hearing Notice MPU SBOP Expansion.pdf Docket Numbers: AIO-25-004 and CO-25-004 By applications dated February 4, 2025, Hilcorp Alaska, LLC (Hilcorp) requests that the Alaska Oil and Gas Conservation Commission (AOGCC) expand the map extent of the Schrader Bluff Oil Pool (SBOP), and its associated Area Injection Order, in and around the Milne Point Unit. 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 Lisi Misa being first duly sworn on oath deposes and says that she is a representative of the An- chorage Daily News, a daily newspaper. That said newspaper has been approved by the Third Judicial Court, Anchorage, Alaska, and it now and has been published in the English language continually as a daily newspaper in Anchorage, Alaska, and it is now and during all said time was printed in an office maintained at the afore- said place of publication of said newspaper. That the annexed is a copy of an advertisement as it was published in regular issues (and not in supplemental form) of said newspaper on AFFIDAVIT OF PUBLICATION ______________________________________ Notary Public in and for The State of Alaska. Third Division Anchorage, Alaska MY COMMISSION EXPIRES ______________________________________ 02/26/2025 and that such newspaper was regularly distrib- uted to its subscribers during all of said period. That the full amount of the fee charged for the foregoing publication is not in excess of the rate charged private individuals. Signed________________________________ Subscribed and sworn to before me Account #: 100869 ST OF AK/AK OIL AND GAS CONSERVATION COMMISSION333 W. 7TH AVE STE 100, ANCHORAGE, AK 99501 Order #: W0051017 Cost: $319.93 Notice of Public HearingSTATE OF ALASKAALASKA OIL AND GAS CONSERVATION COMMISSION RE: Docket Numbers: AIO-25-004 and CO-25-004 By applications dated February 4, 2025, Hilcorp Alaska, LLC (Hilcorp) requests that the Alaska Oil and Gas Conservation Commission (AOGCC) expand the map extent of the Schrader Bluff Oil Pool (SBOP), and its associated Area Injection Order, in and around the Milne Point Unit. Conservation Order No. 477A defines the SBOP and prescribes rules for its development. Area Injection Order (AIO) No. 10C prescribes rules for injecting fluids for enhanced recovery purposes into the SBOP. Hilcorp proposes to amend these orders to incorporate include the area covered by the Schrader Bluff Oil Pool, and its associated AIO, in the Nikaitchuq Unit to allow for unified operations of the SBOP. This notice does not contain all the information filed by Hilcorp. To obtain more information, contact the AOGCC’s Special Assistant, Samantha Coldiron, at (907) 793-1223 or samantha.coldiron@ alaska.gov. A public hearing on the matter has been tentatively scheduled for April 3, 2025, at 10:00 a.m. The hearing, which may be changed to full virtual, if necessary, will be held in the AOGCC hearing room located at 333 West 7th Avenue, Anchorage, AK 99501. The audio call-in information is (907) 202-7104 Conference ID: 239 074 590#. Anyone who wishes to participate remotely using MS Teams video conference should contact Ms. Coldiron at least two business days before the scheduled public hearing to request an invitation for the MS Teams. To request that the tentatively scheduled hearing be held, a written request must be filed with the AOGCC no later than 4:30 p.m. on March 13, 2025. If a request for a hearing is not timely filed, the AOGCC may issue an order without a hearing. To learn if the AOGCC will hold the hearing, call (907) 793-1223 after March 14, 2025. In addition, written comments regarding this application may be submitted to the AOGCC, at 333 west 7th Avenue, Anchorage, AK 99501 or samantha.coldiron@alaska.gov. Comments must be received no later than 4:30 p.m. on March 28, 2025, except that, if a hearing is held, comments must be received no later than the conclusion of the April 3, 2025, hearing. If, because of a disability, special accommodations may be needed to comment or attend the hearing, contact Samantha Coldiron, at (907) 793-1223, no later than March 27, 2025. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner Pub: Fab. 26, 2025 STATE OF ALASKA THIRD JUDICIAL DISTRICT ______________________________________2025-04-04 2029-01-23 Document Ref: 9OCHJ-CFDK6-5F6LY-YVS5G Page 19 of 25 2 February 4, 2025 Jessie Chmielowski, Commissioner Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, Alaska 99501 RE: Application for Expansion of Area Injection Order 10C Schrader Bluff Oil Pool Milne Point Field Nikaitchuq Field Commissioner Chmielowski: Hilcorp Alaska, LLC (“Hilcorp”), as Operator of the Milne Point Unit and the Nikaitchuq Unit, hereby submits this application for expanding the Affected Area of the Milne Point Unit Area Injection Order 10C (“AIO 10C”) to include the Nikaitchuq Field, only as to the Schrader Bluff Oil Pool (“SBOP”). Proposed Affected Area Expansion Hilcorp requests to expand the Affected Area of AIO 10C to include 21,228.6 acres, more or less, of additional lands within the Nikaitchuq Unit (“Expansion Area”), as depicted on Figure 1. The Nikaitchuq Field Schrader Bluff Oil Pool is currently governed by Area Injection Order 36 (“AIO 36”) and Conservation Order No. 639. This application requests that AIO 36 be superseded in its entirety and AIO 10C, only as to the Schrader Bluff Oil Pool, be amended into a new Area Injection Order to include the following Expansion Area. Additionally, we request to keep the following orders active: AIO 36.004, 36.005, 36.006, 36.009, 36.010 and 36.011, all related to water injection. AIO 10C proposed Expansion Area: Lease Number Description Township 14N., Range 9 E., Umiat Meridian, Alaska. ADL 388581 Section 5, Protracted, All tide and submerged lands; (Nikaitchuq Unit, Tract 4) Section 6, Protracted, All tide and submerged lands; Section 7, Protracted, All tide and submerged lands; Section 8, Protracted, All tide and submerged lands; Township 14N., Range 9 E., Umiat Meridian, Alaska. ADL 388583 Section 17, Unsurveyed, All tide and submerged lands; Post Office Box 244027 Anchorage, AK 99524-4027 3800 Centerpoint Drive Suite 1400 Anchorage, AK 99503 Phone: (907) 777-8341 Fax: (907) 777-8301 Email: jamie.wilson@hilcorp.com Hilcorp Alaska, LLC Application for Expansion of AIO 10C February 4, 2025 Page 2 of 9 (Nikaitchuq Unit, Tract 7) Section 18, Unsurveyed, All tide and submerged lands; Section 20, Protracted, All tide and submerged lands; Township 14N., Range 9 E., Umiat Meridian, Alaska, Tract A Section 17, Unsurveyed, All Uplands; Section 18, Unsurveyed, All Uplands; Township 14N., Range 9 E., Umiat Meridian, Alaska. ADL 388582 Section 16, Unsurveyed, All tide and submerged lands; (Nikaitchuq Unit, Tract 8) Section 21, Unsurveyed, All tide and submerged lands; Township 14N., Range 9 E., Umiat Meridian, Alaska, Tract A Section 16, Unsurveyed, All Uplands; Section 21, Unsurveyed, All Uplands; Township 14N., Range 9 E., Umiat Meridian, Alaska. ADL 390615 Section 28, Protracted, All; (Nikaitchuq Unit, Tract 9) Section 33, Protracted, All; Township 14N., Range 9 E., Umiat Meridian, Alaska. ADL 390616 Section 29, Protracted, All; (Nikaitchuq Unit, Tract 10) Section 32, Protracted, All; Township 14N., Range 8 E., Umiat Meridian, Alaska. ADL 388571 Section 1, Protracted, All tide and submerged lands; (Nikaitchuq Unit, Tract 11) Section 2, Protracted, All tide and submerged lands within the computed territorial sea, listed as "State Acreage" on Alaska's seaward boundary diagram approved by the State on April 15, 1996; Section 11, Protracted, All tide and submerged lands; Section 12, Protracted, All tide and submerged lands; Township 15N., Range 8 E., Umiat Meridian, Alaska. Section 35, Protracted, All tide and submerged lands within the computed territorial sea, listed as "State Acreage" on Alaska's seaward boundary diagram approved by the State on April 15, 1996; Section 36, Protracted, All tide and submerged lands within the computed territorial sea, listed as "State Acreage" on Alaska's seaward boundary diagram approved by the State on April 15, 1996; Hilcorp Alaska, LLC Application for Expansion of AIO 10C February 4, 2025 Page 3 of 9 Township 14N., Range 8 E., Umiat Meridian, Alaska. ADL 388572 Section 3, Protracted, All tide and submerged lands within the computed territorial sea, listed as "State Acreage" on Alaska's seaward boundary diagram approved by the State on April 15, 1996; Section 4, Protracted, All tide and submerged lands within the computed territorial sea, listed as "State Acreage" on Alaska's seaward boundary diagram approved by the State on April 15, 1996; (Nikaitchuq Unit, Tract 12) Section 9, Protracted, All tide and submerged lands; Section 10, Protracted, All tide and submerged lands; Township 15N., Range 8 E., Umiat Meridian, Alaska. Section 33, Protracted, All tide and submerged lands within the computed territorial sea, listed as "State Acreage" on Alaska's seaward boundary diagram approved by the State on April 15, 1996; Township 14N., Range 8 E., Umiat Meridian, Alaska. ADL 388574 Section 13, Protracted, All tide and submerged lands; (Nikaitchuq Unit, Tract 14) Section 14, Protracted, All tide and submerged lands; Section 23, Protracted, All tide and submerged lands; Township 14N., Range 8 E., Umiat Meridian, Alaska. ADL 388575 Section 15, Protracted, All tide and submerged lands; (Nikaitchuq Unit, Tract 15) Section 22, Protracted, All tide and submerged lands; Township 14N., Range 8 E., Umiat Meridian, Alaska. ADL 388577 Section 26, Protracted, All tide and submerged lands; (Nikaitchuq Unit, Tract 16) Section 35, Protracted, All tide and submerged lands; Township 14N., Range 8 E., Umiat Meridian, Alaska. ADL 391283 Section 24, Protracted All (Nikaitchuq Unit, Tract 18A & 18B) Section 25, Protracted, All; Section 36, Protracted, All; Township 14N., Range 9 E., Umiat Meridian, Alaska. Section 19, Protracted All Section 30, Protracted, All; Section 31, Protracted, All; Hilcorp Alaska, LLC Application for Expansion of AIO 10C February 4, 2025 Page 4 of 9 Additional Modifications to AIO 10C (Applicable to Kuparuk River Pool, Schrader Bluff Oil Pool and/or Sag River Oil Pool) Hilcorp requests to amend AIO 10C to incorporate certain provisions from AIO 36, as detailed below. The requested changes are intended to align operational flexibility and consistency across facilities while maintaining safety and compliance standards. 1. Adoption of AIO 36 Rule 2: Well Construction We propose adopting the language from Rule 2 of AIO 36 be incorporated into AIO 10C. These variances, previously granted in Milne Point on a well-by-well basis, have been utilized at Nikaitchuq with a more comprehensive approach, ensuring effective and consistent application. We propose this to be applicable only to the Schrader Bluff Oil Pool. 1. Incorporation of AIO 36 Rule 7: Well Integrity and Confinement We propose adopting the language from Rule 7 of AIO 36, which allows for immediate shutdown of operations only if continued operation would be unsafe in the event of suspected loss of containment. This language provides slightly more operational flexibility compared to the immediate shut-in requirement under AIO 10C. While the difference is not critical, it offers practical benefits without compromising safety. We propose this to be applicable only to the Kuparuk River Pool, Schrader Bluff Oil Pool and Sag River Oil Pool. 2. Correction of Clerical Error in AIO 10C Rule 1, Part B(2)(d) We want to note AIO 10C Rule 1, Part A(2)(e), Part B(2)(d), and Part C(2)(e) contains a clerical error. The correct reference should read as “20 AAC 25.280(a)(2)” instead of “20 AAC 24.280(2)”. We request that this be corrected as part of the amendment process. Authorized Injection Stratum The defined stratum authorized for injection subject to the conditions and limitations of AIO 10C are defined as: Schrader Bluff Oil Pool (SBOP) The stratum that correlates with the interval between the measured depths of 4,174 feet and 4,800 feet in the Conoco MPU Well No. A-1. Development Drilling Plans and Geology Hilcorp Alaska, LLC Application for Expansion of AIO 10C February 4, 2025 Page 5 of 9 Between October 19, 2019, through December 16, 2022, polymer injection was tested to enhance waterflood injectivity within the Nikaitchuq Field under AIO’s 36.001, 36.002, and 36.003, as submitted by the previous Operator, Eni US Operating Co. Inc. (“Eni”). Results of the polymer pilot project, submitted to the Commission on February 7, 2023, demonstrated successful outcomes in reservoir conformance, injectivity, and enhanced recovery rates. The polymer pilot test results showed a positive effect on the oil production rate of the OP12-01 and OP17-02 producer wells and a clear change in the water cut trends. Results were quantified using a dynamic model and decline curve analysis (DCA). An estimated incremental oil recovered of approximately 54,000 stb corresponds to an average of +120 bopd in the trial period. The water cut trends of the OP12-01 and OP17-02 wells were found to be in coherence with the observed oil production. OP12-01 saw a reduction of approximately 4% WC, and OP17-02 experienced a flattening of the WC curve, reinforcing the positive impact of the polymer pilot test. Both the oil and water cut results were found to be encouraging, especially considering that OP12-01 and OP17-02 were only half supported by a single polymer injection well. Effective November 1, 2024, Eni assigned all of its right, title and interest in the Nikaitchuq Unit to Hilcorp, the current Operator. Hilcorp, as Operator of the offsetting Milne Point Unit, has successfully utilized polymer injection since 2018. Hilcorp will utilize the operational expertise of the Milne Point Unit to effectively implement polymer injection within the Nikaitchuq Unit. Polymer injection within the Nikaitchuq Unit will help to prevent waste and increase enhanced recovery of the SBOP reserves within the unit. There are two different projects proposed within the SBOP which would both involve polymer injection: 1. OA sands. Drill extended horizontal injection and producer wells from the Milne Point Unit R-Pad that will partially produce and inject into/from the Nikaitchuq Unit. The first well will be drilled as soon as April 2025. 2. N sands. Drill 3 grassroots Nikaitchuq wells (2 injectors; 1 producer) on the Spy Island Drillsite. The first well will be drilled as soon as mid-year 2025. Well data within the proposed Expansion Area shows that the Schrader Bluff is structurally continuous across the Nikaitchuq and Milne Point Units. Hilcorp has submitted confidential seismic data to the Commission (Figure 2) depicting a seismic cross section and Type Wells through the Nikaitchuq Unit (West to East) and the Milne Point Unit (Northwest to Southeast). Reviewing this internal seismic data gives Hilcorp high confidence that the Schrader Bluff formation is a continuously mappable seismic horizon. Hilcorp Alaska, LLC Application for Expansion of AIO 10C February 4, 2025 Page 6 of 9 Figure 2.1 depicts the shared lease line between the Nikaitchuq Unit, Milne Point Unit, and the known Schrader Bluff OA Sand Well Tops. The well control and mappable fluid contact also indicate that the Schrader Bluff is structurally continuous across the units. As of the date of delivery of this application, and in accordance with 20 AAC 25.055(d)(1), notice of Hilcorp’s proposal to expand the AIO 10C Affected Area has been sent by certified mail to those certain owners, landowners, and operators of property within 1,000 feet of the proposed Expansion Area listed in Exhibit “A”. A copy of the notice and corresponding certified mailing receipts have been attached to this application. Pursuant to 20 AAC 25.055(d)(3), and attached as Exhibit “B”, is an affidavit executed by a person acquainted with all pertinent facts of this application and verifying that all facts set forth herein are true. It is requested that the Commission schedule a public hearing to review Hilcorp’s application for expansion of AIO 10C in accordance with 20 AAC 25.540. Should you require additional information regarding this application, please contact me by phone at (907) 777-8341 or by email at jamie.wilson@hilcorp.com. Sincerely, Jamie Wilson Sr. Landman Hilcorp Alaska, LLC cc: Samantha Carlisle, Special Assistant, AOGCC (via email) Heather Beat, Unit Manager, State of Alaska, DNR (via email) Ashley Ethridge, Unit Manager, State of Alaska, DNR (via email) Derek Nottingham, Director, Division of Oil and Gas (via email) Hilcorp Alaska, LLC Application for Expansion of AIO 10C February 4, 2025 Page 7 of 9 FIGURE 1. Affected Area defined in AIO 10C with proposed Expansion Area lands. Hilcorp Alaska, LLC Application for Expansion of AIO 10C February 4, 2025 Page 8 of 9 EXHIBIT “A” APPLICATION FOR EXPANSION OF AIO 10C SCHRADER BLUFF OIL POOL Unit/Lease Landowner Owner Operator Milne Point Unit - ADL 355016 Department of Natural Resources Division of Oil & Gas 550 W. 7th Avenue, Suite 1100 Anchorage, AK 99501-3560 Attn: Derek Nottingham, Director Hilcorp Alaska, LLC 3800 Centerpoint Drive, Suite 1400 Anchorage, Alaska 99503 Herbaly Exploration LLC ATTN: Dave Herbaly 1420 W. Canal Ct., Suite 150 Littleton, Colorado 80120 George Joyce, Jr. 2923 Izabella Ct. Frisco, Texas 75033 Hilcorp Alaska, LLC 3800 Centerpoint Drive Suite 1400 Anchorage, Alaska 99503 Milne Point Unit - ADL 355021 Department of Natural Resources Division of Oil & Gas 550 W. 7th Avenue, Suite 1100 Anchorage, AK 99501-3560 Attn: Derek Nottingham, Director Hilcorp Alaska, LLC 3800 Centerpoint Drive, Suite 1400 Anchorage, Alaska 99503 Herbaly Exploration LLC ATTN: Dave Herbaly 1420 W. Canal Ct., Suite 150 Littleton, Colorado 80120 George Joyce, Jr. 2923 Izabella Ct. Frisco, Texas 75033 Hilcorp Alaska, LLC 3800 Centerpoint Drive Suite 1400 Anchorage, Alaska 99503 1 February 4, 2025 Jessie Chmielowski, Commissioner Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, Alaska 99501 RE: Application for Expansion of Area Injection Order 10C Schrader Bluff Oil Pool Milne Point Field Nikaitchuq Field Commissioner Chmielowski: Hilcorp Alaska, LLC (“Hilcorp”), as Operator of the Milne Point Unit and the Nikaitchuq Unit, hereby submits this application for expanding the Affected Area of the Milne Point Unit Area Injection Order 10C (“AIO 10C”) to include the Nikaitchuq Field, only as to the Schrader Bluff Oil Pool (“SBOP”). Proposed Affected Area Expansion Hilcorp requests to expand the Affected Area of AIO 10C to include 21,228.6 acres, more or less, of additional lands within the Nikaitchuq Unit (“Expansion Area”), as depicted on Figure 1. The Nikaitchuq Field Schrader Bluff Oil Pool is currently governed by Area Injection Order 36 (“AIO 36”) and Conservation Order No. 639. This application requests that AIO 36 be superseded in its entirety and AIO 10C, only as to the Schrader Bluff Oil Pool, be amended into a new Area Injection Order to include the following Expansion Area. Additionally, we request to keep the following orders active: AIO 36.004, 36.005, 36.006, 36.009, 36.010 and 36.011, all related to water injection. AIO 10C proposed Expansion Area: Lease Number Description Township 14N., Range 9 E., Umiat Meridian, Alaska. ADL 388581 Section 5, Protracted, All tide and submerged lands; (Nikaitchuq Unit, Tract 4) Section 6, Protracted, All tide and submerged lands; Section 7, Protracted, All tide and submerged lands; Section 8, Protracted, All tide and submerged lands; Township 14N., Range 9 E., Umiat Meridian, Alaska. ADL 388583 Section 17, Unsurveyed, All tide and submerged lands; Post Office Box 244027 Anchorage, AK 99524-4027 3800 Centerpoint Drive Suite 1400 Anchorage, AK 99503 Phone: (907) 777-8341 Fax: (907) 777-8301 Email: jamie.wilson@hilcorp.com Hilcorp Alaska, LLC Application for Expansion of AIO 10C February 4, 2025 Page 2 of 9 (Nikaitchuq Unit, Tract 7) Section 18, Unsurveyed, All tide and submerged lands; Section 20, Protracted, All tide and submerged lands; Township 14N., Range 9 E., Umiat Meridian, Alaska, Tract A Section 17, Unsurveyed, All Uplands; Section 18, Unsurveyed, All Uplands; Township 14N., Range 9 E., Umiat Meridian, Alaska. ADL 388582 Section 16, Unsurveyed, All tide and submerged lands; (Nikaitchuq Unit, Tract 8) Section 21, Unsurveyed, All tide and submerged lands; Township 14N., Range 9 E., Umiat Meridian, Alaska, Tract A Section 16, Unsurveyed, All Uplands; Section 21, Unsurveyed, All Uplands; Township 14N., Range 9 E., Umiat Meridian, Alaska. ADL 390615 Section 28, Protracted, All; (Nikaitchuq Unit, Tract 9) Section 33, Protracted, All; Township 14N., Range 9 E., Umiat Meridian, Alaska. ADL 390616 Section 29, Protracted, All; (Nikaitchuq Unit, Tract 10) Section 32, Protracted, All; Township 14N., Range 8 E., Umiat Meridian, Alaska. ADL 388571 Section 1, Protracted, All tide and submerged lands; (Nikaitchuq Unit, Tract 11) Section 2, Protracted, All tide and submerged lands within the computed territorial sea, listed as "State Acreage" on Alaska's seaward boundary diagram approved by the State on April 15, 1996; Section 11, Protracted, All tide and submerged lands; Section 12, Protracted, All tide and submerged lands; Township 15N., Range 8 E., Umiat Meridian, Alaska. Section 35, Protracted, All tide and submerged lands within the computed territorial sea, listed as "State Acreage" on Alaska's seaward boundary diagram approved by the State on April 15, 1996; Section 36, Protracted, All tide and submerged lands within the computed territorial sea, listed as "State Acreage" on Alaska's seaward boundary diagram approved by the State on April 15, 1996; Hilcorp Alaska, LLC Application for Expansion of AIO 10C February 4, 2025 Page 3 of 9 Township 14N., Range 8 E., Umiat Meridian, Alaska. ADL 388572 Section 3, Protracted, All tide and submerged lands within the computed territorial sea, listed as "State Acreage" on Alaska's seaward boundary diagram approved by the State on April 15, 1996; Section 4, Protracted, All tide and submerged lands within the computed territorial sea, listed as "State Acreage" on Alaska's seaward boundary diagram approved by the State on April 15, 1996; (Nikaitchuq Unit, Tract 12) Section 9, Protracted, All tide and submerged lands; Section 10, Protracted, All tide and submerged lands; Township 15N., Range 8 E., Umiat Meridian, Alaska. Section 33, Protracted, All tide and submerged lands within the computed territorial sea, listed as "State Acreage" on Alaska's seaward boundary diagram approved by the State on April 15, 1996; Township 14N., Range 8 E., Umiat Meridian, Alaska. ADL 388574 Section 13, Protracted, All tide and submerged lands; (Nikaitchuq Unit, Tract 14) Section 14, Protracted, All tide and submerged lands; Section 23, Protracted, All tide and submerged lands; Township 14N., Range 8 E., Umiat Meridian, Alaska. ADL 388575 Section 15, Protracted, All tide and submerged lands; (Nikaitchuq Unit, Tract 15) Section 16, Protracted, All tied and submerged lands; Section 21, Protracted, All tide and submerged lands; Section 22, Protracted, All tide and submerged lands; Township 14N., Range 8 E., Umiat Meridian, Alaska. ADL 388577 Section 26, Protracted, All tide and submerged lands; (Nikaitchuq Unit, Tract 16) Section 35, Protracted, All tide and submerged lands; Township 14N., Range 8 E., Umiat Meridian, Alaska. ADL 391283 Section 24, Protracted All (Nikaitchuq Unit, Tract 18A & 18B) Section 25, Protracted, All; Section 36, Protracted, All; Township 14N., Range 9 E., Umiat Meridian, Alaska. Section 19, Protracted All Hilcorp Alaska, LLC Application for Expansion of AIO 10C February 4, 2025 Page 4 of 9 Section 30, Protracted, All; Section 31, Protracted, All; Additional Modifications to AIO 10C (Applicable to Kuparuk River Pool, Schrader Bluff Oil Pool and/or Sag River Oil Pool) Hilcorp requests to amend AIO 10C to incorporate certain provisions from AIO 36, as detailed below. The requested changes are intended to align operational flexibility and consistency across facilities while maintaining safety and compliance standards. 1. Adoption of AIO 36 Rule 2: Well Construction We propose adopting the language from Rule 2 of AIO 36 be incorporated into AIO 10C. These variances, previously granted in Milne Point on a well-by-well basis, have been utilized at Nikaitchuq with a more comprehensive approach, ensuring effective and consistent application. We propose this to be applicable only to the Schrader Bluff Oil Pool. 1. Incorporation of AIO 36 Rule 7: Well Integrity and Confinement We propose adopting the language from Rule 7 of AIO 36, which allows for immediate shutdown of operations only if continued operation would be unsafe in the event of suspected loss of containment. This language provides slightly more operational flexibility compared to the immediate shut-in requirement under AIO 10C. While the difference is not critical, it offers practical benefits without compromising safety. We propose this to be applicable only to the Kuparuk River Pool, Schrader Bluff Oil Pool and Sag River Oil Pool. 2. Correction of Clerical Error in AIO 10C Rule 1, Part B(2)(d) We want to note AIO 10C Rule 1, Part A(2)(e), Part B(2)(d), and Part C(2)(e) contains a clerical error. The correct reference should read as “20 AAC 25.280(a)(2)” instead of “20 AAC 24.280(2)”. We request that this be corrected as part of the amendment process. Authorized Injection Stratum The defined stratum authorized for injection subject to the conditions and limitations of AIO 10C are defined as: Schrader Bluff Oil Pool (SBOP) The stratum that correlates with the interval between the measured depths of 4,174 feet and 4,800 feet in the Conoco MPU Well No. A-1. Development Drilling Plans and Geology Hilcorp Alaska, LLC Application for Expansion of AIO 10C February 4, 2025 Page 5 of 9 Between October 19, 2019, through December 16, 2022, polymer injection was tested to enhance waterflood injectivity within the Nikaitchuq Field under AIO’s 36.001, 36.002, and 36.003, as submitted by the previous Operator, Eni US Operating Co. Inc. (“Eni”). Results of the polymer pilot project, submitted to the Commission on February 7, 2023, demonstrated successful outcomes in reservoir conformance, injectivity, and enhanced recovery rates. The polymer pilot test results showed a positive effect on the oil production rate of the OP12-01 and OP17-02 producer wells and a clear change in the water cut trends. Results were quantified using a dynamic model and decline curve analysis (DCA). An estimated incremental oil recovered of approximately 54,000 stb corresponds to an average of +120 bopd in the trial period. The water cut trends of the OP12-01 and OP17-02 wells were found to be in coherence with the observed oil production. OP12-01 saw a reduction of approximately 4% WC, and OP17-02 experienced a flattening of the WC curve, reinforcing the positive impact of the polymer pilot test. Both the oil and water cut results were found to be encouraging, especially considering that OP12-01 and OP17-02 were only half supported by a single polymer injection well. Effective November 1, 2024, Eni assigned all of its right, title and interest in the Nikaitchuq Unit to Hilcorp, the current Operator. Hilcorp, as Operator of the offsetting Milne Point Unit, has successfully utilized polymer injection since 2018. Hilcorp will utilize the operational expertise of the Milne Point Unit to effectively implement polymer injection within the Nikaitchuq Unit. Polymer injection within the Nikaitchuq Unit will help to prevent waste and increase enhanced recovery of the SBOP reserves within the unit. There are two different projects proposed within the SBOP which would both involve polymer injection: 1. OA sands. Drill extended horizontal injection and producer wells from the Milne Point Unit R-Pad that will partially produce and inject into/from the Nikaitchuq Unit. The first well will be drilled as soon as April 2025. 2. N sands. Drill 3 grassroots Nikaitchuq wells (2 injectors; 1 producer) on the Spy Island Drillsite. The first well will be drilled as soon as mid-year 2025. Well data within the proposed Expansion Area shows that the Schrader Bluff is structurally continuous across the Nikaitchuq and Milne Point Units. Hilcorp has submitted confidential seismic data to the Commission (Figure 2) depicting a seismic cross section and Type Wells through the Nikaitchuq Unit (West to East) and the Milne Point Unit (Northwest to Southeast). Reviewing this internal seismic data gives Hilcorp high confidence that the Schrader Bluff formation is a continuously mappable seismic horizon. Hilcorp Alaska, LLC Application for Expansion of AIO 10C February 4, 2025 Page 6 of 9 Figure 2.1 depicts the shared lease line between the Nikaitchuq Unit, Milne Point Unit, and the known Schrader Bluff OA Sand Well Tops. The well control and mappable fluid contact also indicate that the Schrader Bluff is structurally continuous across the units. As of the date of delivery of this application, and in accordance with 20 AAC 25.055(d)(1), notice of Hilcorp’s proposal to expand the AIO 10B Affected Area has been sent by certified mail to those certain owners, landowners, and operators of property within 1,000 feet of the proposed Expansion Area listed in Exhibit “A”. A copy of the notice and corresponding certified mailing receipts have been attached to this application. Pursuant to 20 AAC 25.055(d)(3), and attached as Exhibit “B”, is an affidavit executed by a person acquainted with all pertinent facts of this application and verifying that all facts set forth herein are true. It is requested that the Commission schedule a public hearing to review Hilcorp’s application for expansion of AIO 10C in accordance with 20 AAC 25.540. Should you require additional information regarding this application, please contact me by phone at (907) 777-8341 or by email at jamie.wilson@hilcorp.com. Sincerely, Jamie Wilson Sr. Landman Hilcorp Alaska, LLC cc: Samantha Carlisle, Special Assistant, AOGCC (via email) Heather Beat, Unit Manager, State of Alaska, DNR (via email) Ashley Ethridge, Unit Manager, State of Alaska, DNR (via email) Derek Nottingham, Director, Division of Oil and Gas (via email) Digitally signed by Jamie Wilson (2170) DN: cn=Jamie Wilson (2170) Date: 2025.02.11 11:43:15 - 09'00' Jamie Wilson (2170) Hilcorp Alaska, LLC Application for Expansion of AIO 10C February 4, 2025 Page 7 of 9 FIGURE 1. Affected Area defined in AIO 10C with proposed Expansion Area lands. Hilcorp Alaska, LLC Application for Expansion of AIO 10C February 4, 2025 Page 8 of 9 EXHIBIT “A” APPLICATION FOR EXPANSION OF AIO 10C SCHRADER BLUFF OIL POOL Unit/Lease Landowner Owner Operator Milne Point Unit - ADL 355016 Department of Natural Resources Division of Oil & Gas 550 W. 7th Avenue, Suite 1100 Anchorage, AK 99501-3560 Attn: Derek Nottingham, Director Hilcorp Alaska, LLC 3800 Centerpoint Drive, Suite 1400 Anchorage, Alaska 99503 Herbaly Exploration LLC ATTN: Dave Herbaly 1420 W. Canal Ct., Suite 150 Littleton, Colorado 80120 George Joyce, Jr. 2923 Izabella Ct. Frisco, Texas 75033 Hilcorp Alaska, LLC 3800 Centerpoint Drive Suite 1400 Anchorage, Alaska 99503 Milne Point Unit - ADL 355021 Department of Natural Resources Division of Oil & Gas 550 W. 7th Avenue, Suite 1100 Anchorage, AK 99501-3560 Attn: Derek Nottingham, Director Hilcorp Alaska, LLC 3800 Centerpoint Drive, Suite 1400 Anchorage, Alaska 99503 Herbaly Exploration LLC ATTN: Dave Herbaly 1420 W. Canal Ct., Suite 150 Littleton, Colorado 80120 George Joyce, Jr. 2923 Izabella Ct. Frisco, Texas 75033 Hilcorp Alaska, LLC 3800 Centerpoint Drive Suite 1400 Anchorage, Alaska 99503 Digitally signed by Jamie Wilson (2170) DN: cn=Jamie Wilson (2170) Date: 2025.02.11 11:43:36 - 09'00' Jamie Wilson (2170)